Privacy Policy

1. Scope of Privacy Policy

This Privacy Policy applies to AVID Property Group Holdings Pty Ltd (ACN 608 054 833) and its subsidiaries and related entities (collectively, “AVID”, “we”, “us” and “our”).

2. Purpose of privacy policy

AVID is committed to respecting and safeguarding the personal information of the individuals with whom it deals. AVID handles your personal information in accordance with the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (the “Privacy Act”). This Privacy Policy sets out how we collect, store, use and disclose your personal information, and how to contact us if you have any queries about our management of your personal information.

In addition to our general personal information management practices, the section of this Privacy Policy titled “AVID WEBSITES” further explains how an individual’s personal information is handled when they access and interact with the AVID website (at www.avid.com.au) or our project websites.

From 1 July 2026, AVID is required to comply with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (“AML/CTF Act”) as a reporting entity providing designated services in connection with real estate transactions. As part of meeting these obligations, AVID will collect, hold, use and disclose personal information about customers, beneficial owners, and related parties for the purpose of conducting customer due diligence (“CDD”), ongoing monitoring, risk assessment and, where required, reporting to AUSTRAC. This policy further explains how information collected for this purpose will be dealt with.

Acts and practices of employers that are directly related to both employee records and a current or former employment relationship are exempt from the Privacy Act and are not covered by this Privacy Policy. This exemption does not, however, apply to the collection of personal information about prospective employees.

3. Collection of personal information

3.1. The kinds of personal information AVID collects and holds

Personal information is information or an opinion, in any form and whether true or not, that can identify an individual or from which the identity of the individual can be reasonably ascertained.

The kinds of personal information we collect and hold about you will depend upon the dealings which you may have with AVID and the circumstances of collection, including whether we collect the information from you as a customer, supplier, contractor, consultant, job applicant or in some other capacity.

For example, types of personal information we may collect and hold include:

• information that identifies or reasonably identifies an individual (for example, name, gender, address, contact details, date of birth, occupation, or photographic or video images);
• other personal information that is contained in communications between you and AVID;
• personal information about an individual that is required or authorised by law;
• an individual’s opinion about AVID which identifies or reasonably identifies that individual;
• certain personal information collected where AVID provides you with services; and
• for AML/CTF compliance purposes: identity documents (including passports and driver’s licences), date of birth, residential address, beneficial ownership details, source of funds and wealth information, company or trust documentation (including ASIC records, trust deeds and partnership agreements), sanctions and politically exposed person (PEP) screening results, and any other information required to fulfil AVID’s obligations under the AML/CTF Act.

If you deal with us in some other capacity, we may collect your name and contact details and any other information you choose to provide to us. We may also collect details of the interactions you have with us.

3.2. How we collect personal information

We collect personal information in a variety of ways, including when you interact with us in writing, electronically or by telephone or when you communicate with us through our websites (as explained in further detail below) or social media channels.

For example, AVID may collect and hold personal information about individuals who:

• purchase, or express an interest to purchase, AVID land, AVID house and land, or an AVID apartment (for example, when entering into a sale and purchase agreement, or when responding to requests for information about an AVID home or apartment);
• enter into or are involved in a property transaction with AVID (as a buyer, vendor, investor, beneficial owner, trustee, director, or shareholder), where AVID is required to conduct customer due diligence under the AML/CTF Act, including where personal information is collected through AVID’s authorised CDD platform (First AML);
• apply for open vacancies, or who fill in an expression of interest for a position at AVID, including collecting details of your employment history, and other information provided as part of AVID’s recruitment process;
• seek employment with AVID or are AVID employees (for example, when conducting background checks for the purposes of employment);
• register or subscribe to join AVID programs, newsletters or competitions;
• use AVID’s websites, social media and other online services;
• use mobile applications developed by AVID; or
• may otherwise come into contact with AVID.

AVID only collects personal information which is reasonably necessary for its functions or activities and to comply with its obligations at law.

We do not generally collect sensitive information about you. Sensitive information includes information or an opinion relating to:

• racial or ethnic origin;
• political opinions;
• membership of a political association;
• religious beliefs or affiliations;
• philosophical beliefs;
• sexual preferences or practices;
• criminal convictions;
• membership of a professional or trade association; or
• health information.

We generally try to collect personal information directly from you or through your authorised intermediaries. When we obtain personal information from third parties to whom you refer us, we will assume and you must ensure that you have made that third party aware that you have referred us to them and of the purposes involved in the collection, use and disclosure of the relevant personal information.

If you provide us with personal information about another person, please make sure that you tell them about this Privacy Policy.

3.3. The purposes for which we collect, hold, use and disclose personal information

We collect, hold, use and disclose personal information provided by you or your authorised intermediaries for a range of purposes, including:

• to provide you with quality products and services;
• to meet our obligations under the AML/CTF Act, including conducting customer due diligence, ongoing monitoring of customers and transactions, assessing money laundering and terrorism financing (ML/TF) risks, and reporting to AUSTRAC where required by law (including suspicious matter reports, threshold transaction reports and cross-border movement reports);
• to do all things necessary to administer, manage, develop and protect those products and services (for example, to respond to inquiries about our products and services, and process payments made to us);
• to manage the relationships with our customers, suppliers and contractors;
• to provide you with customer service or technical support, and deal with any complaints or feedback you have;
• to improve and optimise our websites (for example, by generating analytics about how our customers browse and interact with the websites) and to assess the success of our marketing and advertising campaigns;
• to perform research and analysis, and improve or develop our products;
• if you enter one of our competitions or promotions, to administer your participation in that competition or promotion;
• to consider applications and approaches which you make to us;
• for administrative purposes and internal record keeping (for example, to maintain your contact details); and
• to consider you for employment opportunities with AVID.

3.4. Consequences if personal information not provided

When we ask you to provide us with personal information, if you do not provide us with that information, or if that information is incomplete or inaccurate, it may:

• prevent us from providing our products and services to you;
• limit our ability to provide you with the level of service which you would normally expect from us; or
• prevent us from being able to contact you or engage in other dealings with you.

4. USE AND DISCLOSURE OF PERSONAL INFORMATION

Personal information which is collected by AVID is generally only used and disclosed for:

• the primary purpose for which the information was collected; or
• related secondary purposes, which would be within your reasonable expectations.

We may otherwise use or disclose your personal information where the use or disclosure is required or authorised by law (for example, disclosure to government regulatory and law enforcement agencies) or in emergency situations.

If AVID wishes to use or disclose your personal information for secondary purposes, we will usually seek your consent to do so.

Members of AVID may share an individual’s personal information with related entities. In this case, the information may only be used or disclosed by the related entity for the primary purpose for which it was collected, for purposes related to the primary purpose which is within the individual’s reasonable expectations, where required or authorised by law, in emergency situations, or where the individual has consented.

4.1. Disclosure of personal information to third parties

We may disclose your personal information to our contractors and service providers that assist us in the operation of our business or the provision of services (for example, our internet service provider or mailing house). AVID requires these organisations to agree to comply with this Privacy Policy.

We may also disclose your personal information to other third parties and for other purposes where we are required or authorised by or under law to do so (including where you have provided your consent).

In addition, for the purposes of complying with the AML/CTF Act, AVID may disclose your personal information to:

• AUSTRAC, including by submitting suspicious matter reports, threshold transaction reports, and cross-border movement reports;
• AVID’s authorised CDD service provider, First AML, for the purposes of identity verification, screening, and record-keeping;
• other regulated entities (such as conveyancers and legal practitioners) where AVID is relying on, or providing, CDD information under a written third-party reliance arrangement pursuant to the AML/CTF Rules; and
• law enforcement agencies or other government bodies where required or authorised by law. Disclosure of personal information to AUSTRAC may occur without your consent and without notifying you, as required or permitted by the AML/CTF Act and the Privacy Act.

4.2. Disclosure of personal information to recipients outside Australia

A small number of our related entities and third party service providers are located in countries outside of Australia. As a result, personal information collected and held by us may be disclosed to recipients in other countries, including recipients located in the United States of America, Japan and Singapore. Our contracts with these parties generally include an obligation for them to comply with Australian privacy law and our Privacy Policy.

4.3. Marketing

The Spam Act 2003 (Cth) restricts the circumstances in which AVID can send you commercial electronic messages (including email and SMS text messages). Other privacy laws, such as the Privacy Act, further restrict when AVID may send other advertising material to you. If you no longer wish to receive such promotional information from AVID, you may advise us in writing or use the opt out/unsubscribe facility in our communications. Commercial electronic messages from AVID will identify AVID as the sender, and include information about how to contact us and unsubscribe. AVID’s records would normally be amended within 30 days or as otherwise required by the Spam Act. Details of how to contact us are set out below. Your consent will be deemed if you do not opt out when we offer you the opportunity to do so, and will remain current until you advise us otherwise.

5. How we hold information and the security of your personal information

• AVID will take reasonable steps to protect personal information that it holds from unauthorised access, disclosure or modification, as well as misuse, interference and loss. AVID maintains physical security measures over its physical premises, and a range of computer and network security measures (such as systems access, firewalls and data encryption) over its electronic systems. AVID’s employees are required to maintain the confidentiality of any personal information held. This protection applies in relation to information stored in both electronic and hard copy form.
• AVID will destroy or permanently de-identify any personal information collected which is no longer required. External organisations which provide support services to AVID are also required to appropriately safeguard the security of the personal information which we provide to them.
• AVID has an ongoing obligation to handle personal information we hold in accordance with the Notifiable Data Breaches scheme within the Privacy Act. The steps to be taken are set out in the Data Breach Policy and Response Plan. If there is a suspected or known data breach, AVID’s first step is to contain the breach were possible. This will require steps to immediately limit further access or distribution of the affected personal information, investigate the cause and extent of the breach and what remedial action can be taken to prevent likelihood of serious harm to affected individuals. It may also necessitate reporting to the Office of the Australian Information Commissioner (OAIC) and notifying the individual affected.
• AVID may use servers owned by a third party hosting provider(s) and/or third party software. AVID requires its service providers to maintain appropriate organisational and technical measures to protect the security of your personal information. Unfortunately, despite all these measures, no data transmission over the internet or security procedures can be guaranteed to be 100% secure. AVID cannot guarantee the security of any information you transmit to us, and in providing it to us you do so at your own risk.

6. Accessing and correcting personal information

You may request access to your personal information or request us to correct information which we hold about you. To make a request, please put your request in writing using the contact details below. We may require proof of your identification before we can provide you with access to your personal information.

In normal circumstances we will give you full access to the personal information which we hold about you. However, in some circumstances, we may not be permitted by law to provide an individual with access to or to correct their personal information. If this is the case, you will be provided with the reason(s) for our decision.

We will normally provide access without charge unless you request access to a large volume of personal information or we have to access our archived records to obtain the information. In these circumstances, we may impose a fee to recover our reasonable costs.

7. AVID websites

This section provides further details on the way we handle personal information which we collect when an individual uses the AVID website or our project websites.

We outsource the development, maintenance and hosting of the websites to third party service providers. We may disclose personal information about an individual to our third party service providers so that they can effectively provide these services.

7.1. Collection of personal information

An individual may visit the AVID websites without providing us with any personal information. However, we may collect personal information about an individual accessing the website at www.avid.com.au if they use the ‘Contact us’ or ‘Enquire Now’ sections of that website, arrive at our website via a paid advertisement (for example, through Google or Meta), in which case information about the advertisement and campaign that referred them may be collected alongside any information they submit, or where an individual applies for open vacancies or submits an expression of interest for a position at AVID.

7.2. Use of cookies and web tracking

A cookie is a small data file that contains information about your visit to a website. This information is provided by your computer during your first visit to a web server.

The server records this information in a text file and stores this file on your hard drive. When you visit the same website again, the server looks for the cookie and structures itself based on the information provided. Cookies are necessary to allow the AVID websites and the user’s computer to interact effectively and enhance security.

Cookies can record information about the user’s visit to assist AVID in better understanding the needs of the user. For example, user traffic data may be collected and used to infer the website user’s demographic using various web analytic technologies.

In addition to general website functionality and analytics, AVID uses cookies, tracking pixels and UTM (Urchin Tracking Module) parameters as part of its paid advertising campaigns, run through platforms including Google and Meta. These technologies allow AVID to:

• understand which advertising campaign, channel or search term referred a visitor to our website;
• measure the effectiveness of our marketing and advertising campaigns; and
• follow up with individuals who have submitted an enquiry, in accordance with this Privacy Policy.

Where an individual submits an enquiry or brochure request form through our website, information collected via cookies and UTM parameters (such as the campaign, advertisement or search term that referred them) may be associated with the personal information they provide in that form (for example, their name, email address, phone number and postcode). This combined information is stored in AVID’s customer relationship management (CRM) systems and is used to manage AVID’s relationship with that individual, including responding to their enquiry and providing relevant marketing communications in accordance with section 4.3 of this Privacy Policy.

Advertising and analytics cookies used for this purpose may be retained for up to 12 months, after which they expire or are refreshed on your next visit.

Where AVID does not collect an individual’s personal information directly (for example, general website analytics from visitors who do not submit a form), that data is used and reported on an aggregate, non-identifying basis to help AVID understand website usage and improve the relevance of our content and advertising.

Most browsers are initially set up to accept cookies. You can reset your browser to refuse all cookies or to warn you before accepting cookies. If you have set your browser to warn you before accepting cookies, you will receive the warning message with each cookie. You may also manage or opt out of interest-based advertising directly through Google Ads Settings and Meta’s ad preferences.

7.3. Links

We may, from time to time, include links in the website to the websites of other organisations which may be of interest to you. We are not responsible for the privacy practices of these websites.

7.4. Website security

As with any internet transaction, the transmission of data over the internet is not completely secure. While we take reasonable steps to protect all the personal information in our possession that we have collected via the website in accordance with our general personal information management practices, we cannot guarantee the security of all data submitted to us over the internet.

7.5. Email

If an individual emails us, the email may contain personal information about that individual. We will treat the information in accordance with our general personal information management practices outlined in this Privacy Policy.

8. Contact us

If you have any questions or feedback about this Privacy Policy or your personal information, please contact the Privacy Officer at:

Privacy Officer
AVID Property Group Level 5, 7 Macquarie Pl
Sydney NSW 2000
Phone: (02) 8316 7700
Email: enquiries@avid.com.au

You may also contact the Office of the Australian Information Commissioner as follows:

Phone: 1300 363 992
Web: www.oaic.gov.au
Address: GPO Box 5288 Sydney, NSW 2001

9. Complaints

If you wish to make a privacy complaint, you may contact the Privacy Officer using the contact details above. You will need to provide us with sufficient details regarding your complaint, as well as any supporting evidence and/or information.

The Privacy Officer will investigate the issue and determine the steps we will undertake to resolve your complaint within a reasonable period of time (usually within 30 days). We will contact you if we require any additional information and will notify you in writing of the determination of our Privacy Officer.

If you feel that we have not adequately dealt with your complaint, you may contact the Office of the Australian Information Commissioner via www.oaic.gov.au.

10. Changes to this privacy policy

This is our current Privacy Policy outlining our personal information management practices. It replaces any other Privacy Policy published by us to date, whether on the website or in hard copy. We reserve the right to revise this Privacy Policy from time to time. Amended versions will be posted at https://avid.com.au/privacy-policy.

11. Related policy

Related to this policy
Related policies	Data Breach Policy and Response Plan Compliance with Anti-Money Laundering and Counter-Terrorism Financing Act 2006 and Regulations Policy
Related/relevant forms or other organisational documents
Related legislation/statutory entitlements	Privacy Act 1988 (Cth) Privacy Amendment (Enhancing Privacy Protection) Act 2012 The Spam Act 2003 Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth)

12. Commencement and review

Policy issue date and latest version number:	June 2018 Version 7
Authority and date adopted:	Policy Approval Committee – April 2023
Date last reviewed:	June 2026
Suggested review date:	As legislation changes and/or every 3 years
Owner of Policy:	Group General Counsel (GGC)