Privacy Policy

This Privacy Policy applies to all personal information collected by JWLN Service and Investing (referred to as “we,” “us,” or “our”) via the website located at www.propertytraders.io (the “Website”).

1. What information do we collect?

The type of Personal Information we collect depends on how you use the Website. The Personal Information we may collect and hold about you includes:

• Personal details: Name, email, phone number, address.
• Account data: Username, password, profile information, business details (if applicable, e.g., trades or agents).
• Property data: Property listings, photos, descriptions, pricing.
• Usage data: Website analytics, cookies, IP addresses, device type, location data (if enabled).
• Communications: Messages between users (trades–owners, agents–buyers, etc.) and support enquiries.

2. Types of information

The Privacy Act 1988 (Cth) defines the types of information we collect, including Personal Information and Sensitive Information.

• Personal Information: Information or opinions about an identified individual, or an individual who is reasonably identifiable, whether true or not, and whether recorded in a material form or not.
• Sensitive Information: Information about an individual’s racial or ethnic origin, political opinions, religious beliefs, trade union membership, criminal record, or health information.

We will only use Sensitive Information:

1. For the primary purpose for which it was obtained.
2. For a secondary purpose directly related to the primary purpose.
3. With your consent or where required or authorized by law.

3. How we collect your Personal Information

We may collect Personal Information when you:

• Enter information on the Website or related apps.
• Provide information to us directly.

We may also use cookies to track your usage of the Website and to improve your experience. Types of cookies include:

• Essential cookies: Required for Website functionality.
• Analytical cookies: Help improve user experience.
• Marketing cookies: May be set by third parties.

Cookies may be retained for up to [DAYS] days and can be managed through your browser settings. Third-party cookies are subject to their respective privacy policies.

Your Personal Information may be transferred and stored outside Australia. In such cases, we ensure compliance with Australian Privacy Principle 8 through Standard Contractual Clauses, adequacy determinations, or your explicit consent. You may request further information about transfer mechanisms.

Where practical, we collect Personal Information directly from you. In some cases, we may receive it from third parties, and we will inform you of such collection where feasible.

4. Purpose of collection

We collect Personal Information to:

• Provide you with the best service experience on the Website.
• Communicate with you about updates or developments in our business.

We may disclose Personal Information to service providers who assist us in operating the Website. Your information may also be accessed by maintenance and support personnel in the normal course of their duties.

By using our Website, you consent to receiving direct marketing materials. We will only use your Personal Information for marketing if:

• It was collected directly from you.
• The content is relevant to services you would reasonably expect.

You can opt out of marketing communications through unsubscribe links included in all messages.

All service providers and subcontractors are bound by written Data Processing Agreements, ensuring:

• Data is processed only as instructed.
• Equivalent security measures are implemented.
• No unauthorized disclosure occurs.
• Assistance with data subject requests is provided.
• Data breaches are reported within [12] hours.

5. Security, Access and Correction

1. We store your Personal Information in a way that reasonably protects it from unauthorised access, misuse, modification or disclosure. When we no longer require your Personal Information for the purpose for which we obtained it, we will take reasonable steps to destroy your client files and anonymise or de-identify it. Most of the Personal Information that is stored in our client files and records will be kept for a maximum of 7 years to fulfil our record-keeping obligations.
2. The Australian Privacy Principles:
   1. permit you to obtain access to the Personal Information we hold about you in certain circumstances (Australian Privacy Principle 12); and
   2. allow you to correct inaccurate Personal Information subject to certain exceptions (Australian Privacy Principle 13).
3. Where you would like to obtain such access, please contact us in writing on the contact details set out at the bottom of this privacy policy.
4. We implement industry-standard security measures including AES-256 encryption for data in transit and at rest, role-based access controls, regular security audits, and multi-factor authentication for administrative access. In the event of a data breach likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner within the timeframes required under the Privacy Act 1988 (Cth).

6. Complaint procedure

If you have a complaint concerning the manner in which we maintain the privacy of your Personal Information, please contact us as on the contact details set out at the bottom of this policy. All complaints will be considered by Wazma Jawlan and we may seek further information from you to clarify your concerns. If we agree that your complaint is well-founded, we will, in consultation with you, take appropriate steps to rectify the problem. If you remain dissatisfied with the outcome, you may refer the matter to the Office of the Australian Information Commissioner.

7. Overseas transfer

Your Personal Information will not be disclosed to recipients outside Australia unless you expressly request it. Please note that overseas recipients are not required to comply with the Australian Privacy Principles, and we are not liable for mishandling in such circumstances.

8. How to contact us about privacy

If you have any queries, or if you seek access to your Personal Information, or if you have a complaint about our privacy practices, you can contact us through: info@propertytraders.io