Privacy Policy

Effective Date: March 5, 2025

1. Introduction
Alaya Property ("we," "our," or "us") is committed to protecting the privacy of our clients and website visitors. This Privacy Policy explains how we collect, use, and safeguard your personal information when you engage with our Buyer’s Agent (BA) services or visit our website.

2. Information We Collect
We may collect the following types of personal information:

• Personal Identifiable Information (PII): Name, email address, phone number, and postal address.

• Financial Information: Payment details, when applicable.

• Property Preferences: Information related to your property search criteria.

• Website Usage Data: IP address, browser type, and cookies to improve our website experience.

3. How We Use Your Information
We use the collected data for the following purposes:

• To provide and personalize our BA services.

• To process transactions and send confirmations.

• To communicate with you about property opportunities, updates, and relevant offers.

• To comply with legal obligations.

• To improve our website and user experience.

4. Sharing of Information
We do not sell, rent, or trade your personal information. However, we may share it with:

• Trusted third-party service providers assisting in delivering our services.

• Legal authorities when required by law.

• Business partners involved in your property search or purchase.

5. Data Security
We implement appropriate security measures to protect your personal information from unauthorized access, disclosure, or alteration. However, no online transmission can be guaranteed 100% secure.

6. Your Rights and Choices
You have the right to:

• Request access to your personal data.

• Update or correct inaccurate information.

• Opt-out of marketing communications.

• Request data deletion, subject to legal and contractual obligations.

7. Cookies and Tracking Technologies
Our website may use cookies to enhance user experience. You can modify your browser settings to refuse cookies, though this may affect website functionality.

8. Third-Party Links
Our website may contain links to third-party sites. We are not responsible for their privacy practices and encourage you to review their policies.

9. Changes to This Privacy Policy
We may update this Privacy Policy periodically. Any changes will be posted on our website with the updated effective date.

10. AML/CTF Obligations

From 1 July 2026, Alaya Property is subject to obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act) and has enrolled with AUSTRAC as a reporting entity ahead of the 1 July 2026 commencement date. These obligations require us to implement a compliant AML/CTF program, which includes collecting and verifying information about our clients before and during the provision of our services.

What information we collect for AML/CTF purposes

As part of our customer due diligence (CDD) and Know Your Customer (KYC) obligations, we may collect and verify the following information:

• Full legal name, date of birth and residential address;

• Government-issued photo identification (e.g. passport, driver's licence);

• Source of funds and source of wealth documentation;

• Trust deeds, company registers, or ASIC searches where you are engaging through an entity; and

• Any other documentation required to satisfy our AML/CTF program from time to time.

How we use and disclose this information

Information collected under our AML/CTF obligations will be used solely for compliance purposes and will be handled in accordance with this Privacy Policy and the Privacy Act 1988 (Cth). We may be required by law to disclose this information to AUSTRAC or other relevant regulatory or law enforcement agencies. We may also disclose this information to third-party compliance service providers who assist us in meeting our AML/CTF obligations. Some of these providers may be located outside of Australia — please refer to the "Overseas Disclosure" section of this Privacy Policy for further information.

We are unable to commence or continue to provide services to you if the required verification information is not provided.

11. Our Use of AI Technology

Alaya Property uses artificial intelligence (AI) tools as part of our internal operations to support the delivery of efficient and high-quality services to our clients. We are committed to using AI responsibly and transparently, and this section explains how AI tools interact with information about you.

What AI tools we use

We currently use AI tools including, but not limited to:

• AI-powered meeting transcription and note-taking software, which may be active on client calls and consultations (you will be notified at the commencement of any call on which this software is in use);

• AI language model platforms used in drafting client communications, analysing property data, and preparing reports and recommendations.

We may adopt new or different AI tools over time as the technology evolves, consistent with our commitment to maintaining efficient and compliant operations.

How we use AI tools in relation to your information

We take reasonable steps to minimise the inclusion of your personally identifiable information (PII) when using AI tools. Where AI tools are used in relation to your matter, we apply the following safeguards:

• We operate on business or team-tier plans for AI platforms where available. Under these plans, information processed within our Alaya Property workspace is not used to train the underlying AI models.

• We do not intentionally input sensitive personal or financial information into AI tools beyond what is reasonably necessary for the purpose for which the tool is being used.

• We periodically review the AI tools we use and their applicable data handling policies to assess their suitability for use in our business.

Overseas processing

Some of the AI tools we use are operated by service providers based outside of Australia, and information processed through these tools may be transferred to and stored on servers located overseas, including in the United States. By engaging with Alaya Property's services, you consent to this overseas processing in the manner described in this Privacy Policy. Please note that by providing this consent, you acknowledge that you may not be able to seek redress against Alaya Property under the Privacy Act 1988 (Cth) in respect of any act or practice of an overseas service provider that would otherwise constitute a breach of the Australian Privacy Principles (APP 8.2(b)). This consent is given freely and with the benefit of the disclosures set out in this section.

We take reasonable steps to satisfy ourselves that overseas AI service providers handle personal information in a manner consistent with the Australian Privacy Principles. However, you should be aware that overseas providers are subject to the laws of the jurisdiction in which they operate, which may differ from Australian privacy law.

No model training on your data

Where we use AI platforms under business or team-tier plans, the applicable terms of those platforms provide that information entered into our workspace is not used by the platform provider to train or improve their AI models. We note, however, that this position is dependent on the terms and conditions of the relevant platform providers and may be subject to change. We will update this policy if there are any material changes to this position.

12. Contact Us
If you have any questions about this Privacy Policy or how we handle your data, please contact us at:

Alaya Property
Adi Chanda
adi@alayaproperty.com