Privacy Policy

This Privacy Policy explains how MYSPACE MANAGEMENT PTY LTD trading as industrialproperty.ai ("we", "us", "our") collects, holds, uses, and discloses personal information. It has been prepared in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), the Spam Act 2003 (Cth), the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act), and other applicable Australian laws.

By accessing or using our website, platforms, or services, you acknowledge that you have read and understood this Privacy Policy.

1. Information We Collect

We may collect the following categories of personal information:

1.1 Identity & Contact Information

• Full legal name and date of birth
• Residential and business addresses
• Phone numbers and email addresses
• Government-issued identification — required for AML/CTF compliance
• Australian Business Number (ABN) or Australian Company Number (ACN) for business clients

1.2 Financial Information

• Bank account and payment details
• Source of funds and wealth declarations
• Rental income, transaction history, and financial statements

1.3 Property & Transaction Information

• Details of properties owned, leased, or of interest
• Purchase, sale, and lease history
• Appraisal and valuation data
• Inspection appointments and preferences

1.4 Technical & Usage Information

• IP address, browser type, and operating system
• Pages visited, time on site, and referral sources
• Cookies and similar tracking technologies
• Device identifiers

1.5 Sensitive Information

We will only collect sensitive information with your explicit consent, or where required or authorised by law.

2. How We Collect Personal Information

We collect personal information through the following means:

• Directly from you — via enquiry forms, registration, tenancy applications, service agreements, or in person
• From third parties — including real estate databases, government agencies, credit reporting bodies, referees, and identity verification services
• Automatically — through your use of our website and digital platforms via cookies, server logs, and analytics tools
• Through our AI-powered platform — including information submitted via industrialproperty.ai tools, chatbots, or API integrations

3. Purpose of Collection and Use

We collect and use personal information for the following primary purposes:

• Providing real estate and property management services
• Processing tenancy applications, lease agreements, and property transactions
• Conducting identity verification and customer due diligence as required under the AML/CTF Act
• Communicating with you about your enquiries, services, and property listings
• Sending marketing communications (in compliance with the Spam Act 2003)
• Improving and personalising our AI-powered platform and tools
• Complying with legal, regulatory, and reporting obligations
• Fraud prevention, risk management, and internal auditing

4. Anti-Money Laundering & Counter-Terrorism Financing (AML/CTF)

As a reporting entity under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), we are required to:

• Collect and verify the identity of customers before providing designated services (Know Your Customer / KYC)
• Monitor transactions for suspicious activity
• Report threshold transactions and suspicious matters to AUSTRAC
• Retain transaction records and identification documents for a minimum of seven (7) years
• Conduct ongoing customer due diligence, including for Politically Exposed Persons (PEPs) and their associates

AML/CTF compliance data is collected and held in accordance with Part 10A of the AML/CTF Act and may be disclosed to AUSTRAC or other law enforcement agencies without notice to you where legally required. We will not use this information for any purpose beyond our AML/CTF obligations and as otherwise described in this policy.

5. Marketing & Commercial Electronic Messages (Spam Act 2003)

We may send you commercial electronic messages (emails, SMS) about our services, property listings, market updates, or promotions. We will only do so:

• With your express or inferred consent
• Where the message clearly identifies us as the sender
• With a functional, easy-to-use unsubscribe mechanism in every message

You may withdraw your consent at any time by clicking "Unsubscribe" in any message, emailing us at the address in Section 12, or by updating your communication preferences via our platform. We will action unsubscribe requests promptly and within five (5) business days.

We do not use address-harvesting software or purchase email lists from third parties.

6. Disclosure of Personal Information

We may disclose your personal information to:

• Our employees, contractors, and agents who require access to perform their duties
• Third-party service providers — including IT, cloud storage, analytics, identity verification, and payment processing providers — under binding confidentiality arrangements
• Real estate databases, portals, and industry bodies for listing and transaction purposes
• Landlords, tenants, buyers, or sellers where you are acting as a counterparty in a transaction
• Credit reporting bodies where necessary for tenancy or financial assessments
• AUSTRAC, law enforcement, courts, and regulatory authorities as required by law
• Professional advisors including lawyers and accountants, under confidentiality obligations
• Successors in the event of a business sale or merger, subject to continued compliance with this policy

6.1 Outsourced Administrative Functions

We may outsource certain administrative and operational functions to service providers located overseas, including but not limited to data processing, document management, customer support, and back-office administration. Where we do so, we take contractual and other reasonable steps to ensure those providers handle your personal information in a manner consistent with the Australian Privacy Principles.

Countries to which we may disclose information in connection with outsourced functions include, but are not limited to, the United States of America and El Salvador. We will update this list as our service arrangements change.

By using our services, you consent to the disclosure of your personal information to overseas recipients for these purposes. If you do not consent, please notify us before providing your information and we will advise whether we are able to accommodate your request.

6.2 Overseas Technology Providers & APP 8 Notice

Some of our third-party technology and infrastructure providers may be located overseas. Where we disclose personal information to overseas recipients, we take reasonable steps to ensure those recipients handle your information consistently with the Australian Privacy Principles.

Please note that APP 8.1 requires us to take reasonable steps to ensure overseas recipients do not breach the APPs. By providing us with your personal information, you acknowledge this disclosure. You may also consent under APP 8.2(b) to us not being required to take such steps — please contact us if you have questions about this.

7. Security of Personal Information

We take reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification, or disclosure. Our security measures include:

• Encryption of data in transit (TLS/SSL) and at rest
• Role-based access controls and multi-factor authentication
• Secure cloud infrastructure with reputable certified providers
• Regular security reviews and staff training
• Incident response procedures for data breach management

In the event of an eligible data breach under the Notifiable Data Breaches (NDB) scheme (Part IIIC of the Privacy Act 1988), we will notify the Office of the Australian Information Commissioner (OAIC) and affected individuals as required by law.

8. Retention and Destruction of Personal Information

We retain personal information only for as long as necessary to fulfil the purposes for which it was collected, and to comply with our legal obligations, including:

• AML/CTF records: minimum 7 years from end of customer relationship (AML/CTF Act, s. 105)
• Tenancy and property transaction records: as required under applicable real estate legislation in NSW
• Tax and financial records: minimum 5 years (Income Tax Assessment Act)
• General client records: typically 7 years after the relevant matter closes

When personal information is no longer required, we will take reasonable steps to destroy or de-identify it securely.

9. Use of Artificial Intelligence & Automated Decision-Making

Our platform, industrialproperty.ai, incorporates AI-assisted tools to enhance property search, appraisal, and management services. Where we use automated processes that significantly affect you (e.g. automated tenancy scoring), we will:

• Inform you that an automated process is being used
• Provide a means for you to request human review of the outcome
• Not rely solely on automated decision-making in a way that adversely affects your legal rights without appropriate safeguards

AI-generated outputs (such as appraisals or market analysis) are advisory only and do not constitute professional advice. Our licensed agents retain oversight of all significant decisions.

10. Your Rights & Accessing Your Information

Under the Privacy Act 1988 and the Australian Privacy Principles, you have the right to:

10.1 Access

Request access to the personal information we hold about you. We will respond to access requests within 30 days. We may charge a reasonable fee for retrieval in complex cases. We may refuse access in circumstances permitted by law (e.g. where it would reveal information about another person, or compromise an investigation).

10.2 Correction

Request correction of personal information that is inaccurate, out of date, incomplete, irrelevant, or misleading. We will take reasonable steps to correct information within 30 days of your request.

10.3 Complaints

Lodge a complaint if you believe we have breached the Australian Privacy Principles. See Section 12 below for our complaints process.

10.4 Opting Out

Withdraw consent to marketing communications at any time (see Section 5). Note that withdrawal of consent does not affect information held for legal or contractual obligations.

11. Cookies & Tracking Technologies

Our website uses cookies and similar technologies to:

• Remember your preferences and login status
• Analyse website traffic and usage patterns
• Deliver relevant advertising and content
• Improve platform performance

You can manage cookie preferences through your browser settings. Disabling cookies may impact the functionality of certain features on our website. We use Google Analytics (or similar) for anonymous usage tracking. These providers have their own privacy policies governing use of data.

12. Complaints & Contact

If you have a concern about how we handle your personal information, or wish to make an access or correction request, please contact our Privacy Officer:

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our services, legal requirements, or business practices. The current version will always be available at industrialproperty.ai/privacy-policy. We will notify you of material changes via email or a prominent notice on our website prior to the change taking effect.

Continued use of our services after a change constitutes acceptance of the updated policy.

14. Governing Law & Jurisdiction

This Privacy Policy is governed by the laws of New South Wales, Australia. Any disputes relating to this policy shall be subject to the exclusive jurisdiction of the courts of New South Wales.

15. Key Legislation Reference