Privacy Policy

1Introduction

Charlie Property, operated by Corby Property Holdings Pty Ltd (ABN: 40 684 443 061) (“Charlie Property”, “we”, “us”, “our”), provides property deal-sourcing and buyer’s agency services, introducing off-market properties to buyers for a fee. We are committed to protecting your privacy and handling personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

From 1 July 2026, real estate professionals — including buyer’s agents like Charlie Property — are also designated “reporting entities” under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act). This means we are required to collect, verify, and in some cases report certain personal information as part of our legal compliance obligations, regardless of our business turnover.

This policy explains what personal information we collect, why we collect it, how we use, store, and disclose it, and how you can access, correct, or complain about the handling of your information.

2What personal information we collect

Depending on your interaction with us, we may collect:

From prospective and current buyers/clients

• Name, contact details (email, phone, address)
• Property preferences, budget, and finance readiness information
• Information provided through discovery calls, qualification forms, and readiness assessments
• Identity verification documents (e.g. driver’s licence, passport) where required for AML/CTF or contractual purposes
• Financial information relevant to your capacity to transact (e.g. pre-approval status, deposit availability)
• Communications with us (emails, call notes, messages)

From website visitors

• Technical information such as IP address, browser type, device information, and pages visited
• Information submitted via contact forms, newsletter sign-ups, or booking tools

AML/CTF-specific information (from 1 July 2026)

• Verified identity documents
• Source-of-funds information where applicable
• Beneficial ownership information for corporate or trust buyers

We do not knowingly collect sensitive information (such as health, biometric, or criminal history information) unless it is volunteered by you or required for a specific, disclosed purpose — for example, a police check obtained for AML/CTF-related character and fitness requirements applicable to our own personnel, not to clients.

3How we collect personal information

We collect personal information:

• Directly from you — via our website forms, discovery calls, email, phone, or in-person meetings
• Through our client management and workflow tools (Pipedrive, ClickUp, and Zapier), which support our CRM and property database
• From publicly available sources, such as property listing platforms, where relevant to sourcing off-market opportunities
• From third parties where necessary for verification (e.g. identity verification providers, financial institutions) and with appropriate authority

4Why we collect, use, and disclose personal information

We use personal information to:

• Assess your suitability and readiness as a buyer for our deal-sourcing services
• Source, match, and introduce off-market property opportunities
• Prepare and manage Deal Introduction Agreements and related contractual documentation
• Communicate with you about opportunities, updates, and our services
• Meet our legal obligations under the AML/CTF Act, including customer due diligence, ongoing monitoring, and reporting to AUSTRAC where required
• Improve our website and services
• Comply with other applicable laws and regulatory requirements

We do not sell personal information to third parties. We do not use personal information for purposes unrelated to those disclosed here without your consent, unless required or authorised by law.

5Who we disclose personal information to

We may disclose personal information to:

• Our personnel and contractors, on a need-to-know basis
• Service providers who support our operations, including our CRM (Pipedrive), property database (ClickUp), and automation platform (Zapier), and our banking provider
• AUSTRAC and other regulatory or law enforcement bodies, where required under the AML/CTF Act or other legislation
• Third parties involved in a property transaction (e.g. sellers, agents, conveyancers, financiers) where necessary to facilitate a deal, and with your knowledge
• Professional advisers (legal, accounting) where necessary
• Any other party where required or authorised by law, or with your consent

Some of our service providers may store or process data on servers located outside Australia. Where this occurs, we take reasonable steps to ensure your information continues to be handled in accordance with the APPs.

6Automated tools and decision-making

We use qualification and readiness assessment tools to help us understand whether our services are a good fit for you. These tools support — but do not replace — human judgement in our decision-making process. Final decisions about whether to proceed with you as a client are made by our team, not solely by automated means.

7Data security

We take reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification, or disclosure, including:

• Access controls limiting information to authorised personnel
• Secure, reputable third-party platforms for data storage and processing
• Regular review of our data handling practices

No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

8Data retention

We retain personal information only for as long as necessary to fulfil the purposes described in this policy, or as required by law. Under the AML/CTF Act, certain records (including identity verification and transaction-related records) must be retained for a minimum period as prescribed by legislation (currently up to 7 years). When information is no longer required, we take reasonable steps to destroy or de-identify it.

9Access and correction

You may request access to the personal information we hold about you, and request correction if it is inaccurate, out of date, incomplete, or misleading. To make a request, contact us using the details in Section 11. We will respond within a reasonable timeframe. In some circumstances permitted by law (for example, ongoing AML/CTF obligations), we may not be able to fully action a request.

10Complaints

If you believe we have breached the APPs or mishandled your personal information, please contact us first using the details below so we can investigate and respond.

If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC):

• Website: www.oaic.gov.au
• Phone: 1300 363 992

11Contact us

For privacy-related questions, access/correction requests, or complaints:

12Changes to this policy

We may update this policy from time to time to reflect changes in our practices or legal obligations. The updated version will be posted on our website with a revised “last updated” date. We encourage you to review this policy periodically.