Privacy Policy

1. Introduction

Ding Real Estate Pty Ltd (ABN [ABN Number]) ("we", "us", "our", or "Ding Real Estate") is committed to protecting your privacy and complying with the Privacy Act 1988 (Cth), including the Australian Privacy Principles (APPs).

This Privacy Policy explains how we collect, hold, use, and disclose your personal information when you use our property intelligence platform, ASPIRE, and engage with our real estate services.

2. Information We Collect

2.1 Personal Information

We may collect the following types of personal information:

• Identity Information: Full name, date of birth, photographic identification (driver's licence, passport)
• Contact Information: Residential address, email address, telephone numbers
• Financial Information: Bank account details, credit history (with consent), employment details for finance pre-approval
• Property Information: Property ownership details, purchase preferences, investment criteria
• Verification Information: Information required for Anti-Money Laundering (AML) and Know Your Customer (KYC) compliance under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006
• Technical Information: IP address, browser type, device information, cookies and usage data

2.2 Sensitive Information

We generally do not collect sensitive information (such as racial or ethnic origin, political opinions, religious beliefs, or health information) unless required by law or with your explicit consent.

3. How We Collect Information

We collect personal information:

• Directly from you when you register, make enquiries, or use our services
• Through our ASPIRE platform when you conduct property evaluations or market research
• From third parties such as referees, mortgage brokers, solicitors, and conveyancers
• From publicly available sources including property databases, ASIC, and land titles offices
• Through automated technologies including cookies, analytics tools, and AI-powered property intelligence systems

4. Purpose of Collection

We collect and use your personal information to:

• Provide real estate agency services including property sales, purchases, and leasing
• Deliver our ASPIRE property intelligence and evaluation services
• Conduct property market analysis and provide investment insights
• Comply with AML/CTF and KYC regulatory requirements
• Process financial transactions and facilitate settlements
• Communicate with you about properties, market updates, and our services
• Improve our platform through AI-driven analytics and learning systems
• Meet our legal and regulatory obligations

5. Disclosure of Information

We may disclose your personal information to:

• Service Providers: Conveyancers, solicitors, mortgage brokers, property inspectors, and valuers
• Financial Institutions: Banks and lenders for finance applications
• Government Bodies: AUSTRAC, state revenue offices, land titles offices as required by law
• Professional Advisers: Accountants, auditors, and legal advisers
• Technology Partners: Cloud service providers, AI platform operators (including Abacus.AI for our ASPIRE system)
• Other Parties: With your consent or as required by law

5.1 Overseas Disclosure

Some of our technology partners may store data overseas (including the United States). Before disclosing information overseas, we take reasonable steps to ensure recipients comply with the APPs or equivalent privacy standards.

6. AI and Automated Decision-Making

Our ASPIRE platform uses artificial intelligence to provide property evaluations, market analysis, and investment insights. This includes:

• Automated property scoring using our 5-dimension framework (Affordability, Suitability, Profitability, Investment, Risk)
• AI-generated market reports and property recommendations
• Risk assessment algorithms for AML/KYC compliance

You have the right to request human review of any significant automated decision that affects you. Contact us if you wish to exercise this right.

7. Data Security

We implement appropriate technical and organisational measures to protect your personal information, including:

• Encryption of data in transit and at rest
• Secure access controls and authentication
• Regular security assessments and penetration testing
• Staff training on privacy and data protection
• Incident response procedures for potential data breaches

8. Data Retention

We retain personal information for as long as necessary to fulfil the purposes for which it was collected, comply with legal obligations (including a minimum of 7 years for AML/CTF records), and resolve disputes.

9. Your Rights

Under the Privacy Act 1988, you have the right to:

• Access: Request access to personal information we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Complaint: Lodge a complaint about our handling of your personal information
• Anonymity: Deal with us anonymously or pseudonymously where practicable (noting this may limit our ability to provide services)

To exercise these rights, please contact our Privacy Officer using the details below.

10. Cookies and Tracking

Our website uses cookies and similar technologies to enhance your experience, analyse usage patterns, and improve our services. You can control cookie preferences through your browser settings, though this may affect functionality.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be notified via our website or by email. Your continued use of our services after changes constitutes acceptance of the updated policy.

12. Complaints

If you believe we have breached your privacy, please contact our Privacy Officer. We will investigate and respond within 30 days. If unsatisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.