Privacy
Policy

PRIVACY POLICY

Hills Manor Property Group Pty Ltd ACN 610 846 903
Trading as Manor Real Estate

Last updated: February 2026

1. OVERVIEW

Hills Manor Property Group Pty Ltd ACN 610 846 903 and its related entities ("Manor", "we", "us", "our") is committed to protecting the privacy of individuals and ensuring personal and sensitive information is handled responsibly, securely, and transparently.

This Privacy Policy explains how we collect, use, disclose, store and protect personal information in accordance with:

• Privacy Act 1988 (Cth)
• Privacy Amendment (Enhancing Privacy Protection) Act 2012 (Cth)
• Privacy and Other Legislation Amendment Act 2024 (Cth)
• Privacy Amendment (Notifiable Data Breaches) Act 2017 (Cth)
• Spam Act 2003 (Cth)
• Privacy and Personal Information Protection Act 1998 (NSW)
• Information Privacy Act 2014 (ACT)
• Australian Privacy Principles (APPs)

This Privacy Policy operates alongside our internal privacy procedures, data security policies and breach response processes.

This policy applies to personal information collected from clients, buyers, sellers, tenants, landlords, applicants, contractors, employees, website users and other stakeholders through digital, written, verbal or physical interactions.

Where lawful and practicable, individuals may interact with us anonymously or using a pseudonym. However, this may limit our ability to provide services.

We aim to manage personal information in an open and transparent way and maintain systems and procedures that support compliance with privacy law and best practice.

2. SERIOUS INVASIONS OF PRIVACY

Australian law recognises a statutory cause of action for serious invasions of privacy, including misuse of personal information or intrusion into private affairs.

Manor is committed to minimising the risk of such conduct and maintaining reasonable safeguards in handling personal information.

3. WHAT PERSONAL INFORMATION WE COLLECT

Depending on your interaction with us, we may collect:

General information

• Name, address, phone number, email
• Date of birth
• Occupation and employment details
• Property interests and transaction history
• Emergency contact details

Identification information

• Driver's licence details
• Passport details
• Other identity verification documents

Financial information

• Bank details
• Income information
• Rental payment history
• Purchase or sale financial data

Property-related information

• Properties owned, leased or inspected
• Tenancy or sales application information
• Inspection and enquiry history

Credit-related information

• Credit history
• Credit reports from credit reporting bodies
• Rental payment records

Sensitive information (only where necessary)

• Information relating to hardship or vulnerability
• Identity documents containing sensitive identifiers

We only collect information reasonably necessary for our functions and activities.

We take reasonable steps to ensure personal information we collect is accurate, up to date, complete and relevant before using or disclosing it.

4. GOVERNMENT-RELATED IDENTIFIERS

We do not adopt, use or disclose government-related identifiers (such as driver licence or passport numbers) as our own identifiers unless permitted by law.
Such identifiers are used only for verification purposes or where required for legal or regulatory compliance.

5. HOW WE COLLECT PERSONAL INFORMATION

We may collect personal information:

• Directly from you
• Through our website or online forms
• Through property inspections or open homes
• Through tenancy applications
• Through contracts and agency agreements
• Via email, phone or SMS
• Through CRM and marketing platforms
• From referees, credit bodies, solicitors or banks
• From government authorities where required

6. PURPOSE OF COLLECTION

We collect personal information only where:

• You have provided consent
• It is necessary to perform a contract
• It is required or authorised by law
• It is reasonably necessary for our legitimate business activities

This includes:

• Buying, selling, leasing and managing property
• Assessing tenancy or purchase suitability
• Reporting to vendors or landlords
• Communicating with you
• Marketing services where permitted
• Maintaining business records
• Meeting regulatory obligations

In property transactions, certain personal information may be shared between parties as part of normal agency practice and regulatory requirements. We take reasonable steps to ensure such disclosures align with expectations and privacy obligations.

We comply with the Spam Act 2003 (Cth) and only send electronic marketing communications where consent exists or law permits.

Where we use personal information for direct marketing and the information was not collected directly from you, we will, upon request, inform you of the source of that information.

You may unsubscribe at any time.

7. IDENTITY VERIFICATION AND LEGAL COMPLIANCE

We may collect identification documents to verify identity and comply with legal and regulatory obligations, including fraud prevention, property transaction verification and future anti-money laundering requirements applicable to real estate.

8. OPEN HOMES, AUCTIONS AND INSPECTIONS

When you attend an inspection, auction or open home, we may collect:

• Name and contact details
• Identification details where reasonably required
• Property interests or purchasing requirements
• Vehicle registration details (where applicable)
• Images or footage where surveillance operates

Information may be collected via sign-in sheets, QR forms, tablets, CRM systems, CCTV or verbally.

We collect this information to:

• Manage access and ensure safety
• Report attendance and feedback to vendors
• Follow up regarding property interest
• Maintain records
• Meet legal obligations

Vendors may receive inspection attendance information and buyer feedback as part of our agency reporting.

Where permitted by law, contact details may be used for marketing. You may opt out at any time.

9. PHOTOGRAPHY, FILMING AND DRONE FOOTAGE

Photographs, video recordings, drone footage or other visual media may be captured at inspections, auctions or property-related events for marketing, promotional, training, security or record-keeping purposes.

Such recordings may incidentally capture images of attendees.

Where practicable, signage will be displayed when filming occurs.
If you do not wish to be recorded, you may notify staff and we will take reasonable steps to accommodate your request where practicable.

We will not intentionally identify individuals in marketing materials without consent unless permitted by law.

10. HOW PERSONAL INFORMATION IS USED

We may use personal information to:

• Provide real estate services
• Facilitate transactions
• Assess tenancy or purchase suitability
• Communicate with you
• Report to vendors or landlords
• Maintain records
• Provide marketing communications where permitted

11. CREDIT-RELATED INFORMATION

Where tenancy applications are assessed, we may obtain credit information from credit reporting bodies in accordance with Part IIIA of the Privacy Act.

Credit information will only be used to assess tenancy suitability or as permitted by law.

12. DISCLOSURE OF PERSONAL INFORMATION

We may disclose personal information to:

• Vendors or landlords
• Buyers or tenants involved in a transaction
• Solicitors and financial institutions
• Contractors and service providers
• Technology providers and CRM platforms
• Credit reporting bodies
• Government authorities or regulators where required

We may also disclose personal information to law enforcement agencies, courts or regulatory bodies where required or authorised by law, or where reasonably necessary to assist investigations or prevent unlawful activity.

13. BUSINESS TRANSFERS OR RESTRUCTURE

If our business, assets or rent roll are sold, transferred or restructured, personal information may be transferred as part of that transaction, subject to appropriate confidentiality and privacy safeguards.

14. OVERSEAS DISCLOSURE

Some service providers store or process data outside Australia. Due to the use of cloud-based systems, personal information may be stored or processed in multiple locations, including Australia and overseas, depending on system architecture and backup arrangements.

Where this occurs, we undertake due diligence and implement contractual safeguards requiring compliance with privacy protections substantially similar to the APPs.

Current storage locations may include:

• New Zealand
• Singapore
• United States

15. AUTOMATED DECISION-MAKING

We may use software or AI tools to assist in tenant screening or other operational processes.

From 10 December 2026, where automated decisions significantly affect an individual's rights or interests, we will provide meaningful information about the logic involved and offer human review upon request.

16. WEBSITE ANALYTICS AND THIRD-PARTY LINKS

We use analytics tools such as Google to monitor website performance and improve services.

Our website may contain links to third-party websites. We are not responsible for the privacy practices of those sites and encourage you to review their privacy policies.

17. DATA SECURITY

We store information electronically and physically and take reasonable technical and organisational measures including:

• Secure databases and access controls
• Physical security at premises
• Restricted staff access — only personnel who require information to perform their duties may access it
• Confidentiality obligations for staff
• Firewalls and antivirus software
• VPN and encrypted connections
• Secure payment systems

While we take reasonable steps to protect personal information, no system is completely secure and we cannot guarantee the absolute security of information transmitted to or from us.

18. DATA RETENTION

We retain personal information only as long as reasonably necessary or legally required.

For example:

• Property sales and management records may be retained for at least 7 years
• Financial or trust records may be retained as required by law
• Marketing information may be retained until you withdraw consent or it is no longer required

When information is no longer needed, we securely destroy or permanently de-identify it.

19. DATA BREACHES

If a data breach occurs, we will activate our Data Breach Response Plan.

Where a breach is likely to result in serious harm, we will notify affected individuals and the OAIC as soon as practicable in accordance with the Notifiable Data Breaches scheme.

If you suspect misuse or unauthorised access to your information, please contact our Privacy Officer immediately.

20. PRIVACY BY DESIGN

We consider privacy risks when introducing new systems, technologies or business processes and seek to incorporate privacy protections from the outset.

21. CHILDREN AND VULNERABLE INDIVIDUALS

We do not knowingly collect personal information from children without appropriate consent where required.

22. ACCESS, CORRECTION AND ACCURACY

You may request access to or correction of personal information we hold about you.

We aim to respond within 30 days.
Where access is granted, information will be provided in a reasonable and commonly used format where practicable.

You are responsible for ensuring the information you provide to us is accurate and up to date and for notifying us of any changes.

Certain employee records may be exempt under the employee records exemption in the Privacy Act.

23. COMPLAINTS

If you have concerns about how we handle personal information, we encourage you to contact us first so we can attempt to resolve the issue.

We aim to respond within 30 days.

If you are not satisfied, you may contact the Office of the Australian Information Commissioner:

www.oaic.gov.au
1300 363 992

24. UPDATES TO THIS POLICY

We may update this Privacy Policy from time to time. Updates may be posted on our website or notified using contact details provided.

Continued use of our services constitutes acceptance of the updated policy.

25. CONTACT DETAILS

Hills Manor Property Group Pty Ltd
ACN: 610 846 903
Shop 34, 375–383 Windsor Road, Baulkham Hills NSW

Phone: 02 9639 5833
Email: admin@manorre.com

Privacy Officer: Philippa Rowlandson