Privacy Policy

I.Application of this Policy

1.1This Policy applies to personal information collected, held, used or disclosed by Valuers4U Pty Ltd (ABN 13 951 044 552) (Valuers4U, we, us, our) through the Valuers4U platform at valuers4u.com and any related communication or service (the Platform).

1.2Valuers4U is bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles (the APPs) set out in Schedule 1 to that Act. References to personal information have the meaning given in section 6 of the Privacy Act.

1.3By using the Platform or providing personal information to us, the user consents to the collection, holding, use and disclosure of that personal information in accordance with this Policy.

II.Information We Collect

We collect only personal information reasonably necessary for, or directly related to, our functions or activities (APP 3).

2.1We do not knowingly collect sensitive information (as defined in section 6 of the Privacy Act) and request that users do not upload sensitive information to the Platform.

2.2The Platform is intended for professional users and is not directed to children. We do not knowingly collect personal information from any individual under the age of 18.

2.3Information about practising valuers obtained from public registers and from B2B data vendors (APP 5 notification). In order to identify and contact Certified Practising Valuers who may be eligible to join the Valuers4U panel, we hold and process business-contact records (full name, firm name, business email, business postal address, business telephone) collected from: (a) statutory public registers including the Queensland Valuers Registration Board (VRBQ) public gazette and equivalent state-territory registers where they exist; (b) the Australian Property Institute’s publicly-listed CPV directory; (c) the licensed B2B contact-enrichment service Apollo.io, operated by Apollo Software Inc. (a United States-based provider); and (d) other publicly-available professional listings. We collect this information about individuals other than the data subject (APP 3.6 exception) because it is impracticable to collect such information directly from each valuer when the purpose is to invite them to join the panel. This Policy serves as collection notice under APP 5 for affected individuals; an opt-out path is provided in clause 8 below and the data subject may at any time email e@valuers4u.com to be removed from the prospect database with effect within 7 days.

2.4Information about engaging professionals obtained from B2B data vendors. We may similarly hold and process business-contact records for prospective engaging professionals (solicitors, accountants, mortgage brokers, financial planners, buyers’ agents, trustees, liquidators, administrators and bankruptcy lawyers) from Apollo.io and equivalent licensed B2B contact-enrichment services. The same APP 5 notification, collection rationale, opt-out path and 7-day removal commitment in clause 2.3 apply.

III.How We Collect Information

3.1We collect personal information directly from the individual concerned wherever reasonably practicable (APP 3.6), including when a user: (a) registers on the Platform; (b) lodges a Request or submits a quote; (c) corresponds with us; or (d) uploads supporting documents.

3.2Where we collect information about a Client from the engaging Professional, the Professional warrants that they have authority to disclose that information to us for the limited purposes set out in this Policy.

3.3We collect technical information automatically through standard server logging and analytics on the Platform.

3.4Collection from third-party data vendors and public registers. Where the source is a third-party B2B contact-enrichment provider, we ensure under the provider’s terms of service and applicable AU/EU data-protection warranties that the provider has a lawful basis for supplying the information. Where the source is a statutory public register, we collect only such information as is published on the register for the purpose for which the register is established.

IV.Why We Collect, Hold, Use and Disclose Information

We use personal information only for the purposes for which it was collected (the primary purpose) and for any related secondary purpose that an individual would reasonably expect (APP 6).

4.1Our primary purposes are to:

1. operate the Platform, including matching Requests with appropriately qualified Valuers and facilitating the quote, Appointment and audit-trail processes;
2. communicate with users about Requests, quotes, Appointments, fees and account matters;
3. issue, deliver and administer tax invoices for platform fees;
4. verify the credentials of Valuers (including against the Australian Property Institute’s public register and other public records);
5. maintain the security and integrity of the Platform, prevent fraud and respond to misuse;
6. comply with applicable law, court orders, regulatory requests and legal process; and
7. improve the Platform, including through aggregated and de-identified analytics.

4.2We will not use or disclose personal information for any other purpose without the individual’s consent, unless permitted under APP 6 (including where required or authorised by law).

V.Disclosure to Third Parties

5.1We may disclose personal information to third parties to the limited extent reasonably necessary for the purposes set out in clause 4.1, including:

1. other users of the Platform participating in the same Request, in accordance with the anonymisation architecture described in clauses 5.3 to 5.5;
2. service providers acting on our behalf under contractual confidentiality obligations, including hosting providers, email and notification providers, accounting and bookkeeping providers (including Xero), banking providers, and analytics providers;
3. professional advisers (legal, accounting, audit and risk) under duties of confidence;
4. regulators, law enforcement and other authorities where required or authorised by law; and
5. any successor entity in connection with a sale, merger, restructure or transfer of the Platform’s business or assets.

5.2We do not sell personal information.

5.3Anonymisation prior to selection. Where a Request is routed to multiple Valuers for competitive quotation, we disclose to each matched Valuer only such property and scope information as is reasonably necessary to enable that Valuer to prepare a fee quote. The identity of the engaging Professional, the engaging Professional’s firm, the Client and the full street address of the property are not disclosed to any matched Valuer at this stage. The brief delivered to matched Valuers is anonymised at the suburb level and contains no personally identifying information of the engaging Professional or the Client.

5.4Disclosure on selection — the directory bridge. When the engaging Professional appoints a Valuer’s quote, we disclose to that appointed Valuer (and to that Valuer alone) such identifying information about the engaging Professional, the engaging Professional’s firm, the Client and the full property address as is reasonably necessary to enable the Valuer to engage with the Professional and the Client directly. Concurrently, we disclose to the engaging Professional the identifying information of the appointed Valuer (name, firm, telephone and email). At and after this moment, Valuers4U acts as a directory bridging the two parties; the appointed Valuer engages the Professional and the Client directly under the Valuer’s own Letter of Engagement.

5.5Notification to unsuccessful Valuers. The two unsuccessful Valuers are notified that another quote has been appointed for the relevant Request. The identity of the engaging Professional, the engaging Professional’s firm, the Client, the appointed Valuer and the appointed quote amount are not disclosed to those unsuccessful Valuers.

5.6By lodging a Request or submitting a quote on the Platform, the engaging Professional and the Valuer each consent to the limited disclosure of identifying information to the other in accordance with clause 5.4 in the event of selection.

VI.Cross-Border Disclosure

6.1Personal information is stored primarily in Australia. Limited cross-border disclosure may occur where service providers operate, store or process data outside Australia, which may include the United States, the European Union and the United Kingdom (where commonly-used cloud-hosting, email and analytics infrastructure is operated).

6.2Where we disclose personal information to an overseas recipient, we take reasonable steps to ensure that the overseas recipient does not breach the APPs in relation to that information, in accordance with APP 8.

6.3Named overseas processors. As at the date of this Policy, the following overseas service providers receive Platform personal information in the course of their services to Valuers4U: (a) Google LLC (United States) — cloud hosting, email delivery via Gmail / Apps Script, analytics and document storage; (b) Apollo Software Inc. (United States) — B2B contact enrichment for prospect outreach; (c) Smartlead AI Inc. and successor entities (United States / Singapore) — outbound email sequencing for cold outreach to valuer prospects. The list of overseas processors is reviewed annually. Disclosure to each provider is limited to what is reasonably necessary to operate the service.

VII.Storage, Security and Retention

7.1We take reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification or disclosure (APP 11), including the use of access controls, encryption in transit, secure hosting and personnel training.

7.2No transmission over the internet or method of electronic storage is entirely secure, and we cannot guarantee absolute security. Users are responsible for the security of their own access credentials.

7.3We retain personal information only for so long as it is reasonably necessary for the purposes set out in clause 4.1, or as required by law (including taxation, anti-money laundering and corporations record-keeping requirements). When personal information is no longer needed, we take reasonable steps to destroy or de-identify it (APP 11.2).

VIII.Direct Marketing and Electronic Messages

8.1We may send commercial electronic messages (including emails and SMS) to users and to identified business contacts in connection with the Platform and our services, in accordance with APP 7 and the Spam Act 2003 (Cth).

8.2Every commercial electronic message we send: (a) clearly identifies Valuers4U Pty Ltd (ABN 13 951 044 552) as the sender; (b) contains accurate sender information; and (c) contains a functional unsubscribe facility. A recipient may unsubscribe at any time by following the instructions in the message or by emailing e@valuers4u.com. Unsubscribe requests are honoured within five (5) business days as required by section 16 of the Spam Act 2003 (Cth). Operational and transactional communications (for example, invoices, account notices and Request status updates) may continue to be sent following an unsubscribe, as they are not commercial electronic messages within the meaning of the Act.

8.3Cold outreach to identified business contacts. Where we send a commercial electronic message to a business contact whose contact details were obtained other than at the recipient’s express request (for example, from a public statutory register, the Australian Property Institute’s public CPV directory or a licensed B2B contact-enrichment provider as described in clauses 2.3 to 2.4), we rely on the “conspicuously published” consent inference in section 5 of Schedule 2 of the Spam Act 2003 (Cth) only where the conditions for that inference are met (the address is conspicuously published in connection with the recipient’s business or occupation, the publication is not accompanied by a statement that the recipient does not wish to receive unsolicited commercial electronic messages, and the message is relevant to that business or occupation). Where those conditions are not met, we obtain prior express consent or do not send. Recipients may unsubscribe at any time per clause 8.2; the address will be added to a permanent suppression list and will not be re-marketed to.

8.4Removal from the prospect database. A recipient who wishes to be removed from the underlying prospect database referred to in clauses 2.3 and 2.4 (and not merely unsubscribed from the current sequence) may email e@valuers4u.com with the words “remove from database” in the subject line, and the recipient’s record will be erased within seven (7) days.

IX.Cookies and Site Analytics

9.1The Platform uses cookies and similar technologies for session management, security, analytics and to improve user experience. A cookie is a small data file placed on the user’s device by a website.

9.2Most browsers allow a user to refuse or delete cookies. Disabling cookies may impair the functionality of the Platform.

9.3Google Analytics 4. We use Google Analytics 4 (Measurement ID G-Y8C1QLRVLN), a web analytics service provided by Google LLC (Google), to collect aggregated and de-identified information about Platform usage, including pages visited, session duration, approximate geographic region (derived from a truncated IP address), device and browser type, and referring source. Google Analytics is implemented using first-party cookies (commencing _ga and _ga_*) that expire up to two years after the user’s most recent visit to the Platform.

9.4Google may transfer information collected through Google Analytics to, and process it on, servers located outside Australia, including in the United States. Google’s processing of that information is governed by Google’s Privacy Policy, available at policies.google.com/privacy.

9.5Opting out. A user may opt out of Google Analytics tracking across all participating websites by installing the Google Analytics Opt-out Browser Add-on at tools.google.com/dlpage/gaoptout, or by enabling “Do Not Track” or equivalent anti-tracking settings in their browser.

9.6We do not use cookies or analytics data to undertake cross-site behavioural advertising or re-marketing, and we do not sell or rent analytics data to any third party. Analytics information is used solely in aggregated, de-identified form to understand and improve the performance, content and usability of the Platform.

X.Access, Correction and Deletion

10.1An individual may request access to the personal information we hold about them (APP 12) by emailing e@valuers4u.com. We will respond within thirty (30) days. We do not charge for making a request, although we may charge our reasonable costs of giving access (for example, retrieval and copying). Before giving access we will take reasonable steps to verify the identity of the requester.

10.2We may decline access in the limited circumstances permitted by the Privacy Act (for example, where giving access would have an unreasonable impact on the privacy of another individual, or would reveal commercially sensitive information such as another valuer’s quote). If we decline, we will give written reasons and the available complaint mechanisms.

10.3An individual may request correction of personal information that is inaccurate, out of date, incomplete, irrelevant or misleading (APP 13). We will take reasonable steps to correct the information within thirty (30) days, or give written reasons for refusal. On request, we will notify any third party to whom we have disclosed the incorrect information of the correction, unless it is impracticable or unlawful to do so.

10.4An individual may request deletion of their personal information by emailing e@valuers4u.com. We will delete or de-identify the information within thirty (30) days except to the extent we are required or permitted by law to retain it (for example, taxation, anti-money laundering and corporations record-keeping requirements, or records of a Request or quote needed to resolve a dispute). Where retention is required, the information is quarantined from further use and deleted when the retention obligation expires. Removal from the prospect database is dealt with separately under clause 8.4.

XI.Notifiable Data Breaches

11.1Valuers4U is subject to the Notifiable Data Breaches scheme in Part IIIC of the Privacy Act 1988 (Cth). An eligible data breach occurs where there is unauthorised access to, unauthorised disclosure of, or loss of personal information held by us, and a reasonable person would conclude that the access, disclosure or loss is likely to result in serious harm to any of the individuals to whom the information relates.

11.2If we suspect that an eligible data breach may have occurred, we will carry out a reasonable and expeditious assessment within thirty (30) days of becoming aware of the grounds for suspicion, and take all reasonable steps to contain the breach and remediate any risk of harm.

11.3Where an eligible data breach is confirmed and no exception applies, we will promptly notify the Office of the Australian Information Commissioner (OAIC) and the affected individuals, including a description of the breach, the kinds of information concerned, and the steps individuals should take in response.

XII.Complaints and Contact

12.1A person who believes that Valuers4U has breached the APPs or otherwise mishandled their personal information may lodge a complaint by emailing e@valuers4u.com with “Privacy complaint” in the subject line, or by writing to Valuers4U Pty Ltd, Suite 316, 45 Glenferrie Road, Malvern VIC 3144.

12.2We will acknowledge a complaint within seven (7) days of receipt, investigate it, and provide a written response within thirty (30) days. If the matter is complex and more time is required, we will explain the delay and provide a revised timeframe.

12.3If the complainant is not satisfied with our response, or does not receive a response within the stated timeframe, the complaint may be escalated to the Office of the Australian Information Commissioner: online at www.oaic.gov.au, by phone on 1300 363 992, or by mail to GPO Box 5288, Sydney NSW 2001.

12.4Questions about this Policy may be directed to e@valuers4u.com. This Policy is reviewed at least annually; the current version, with its effective date, is published on the Platform and supersedes all earlier versions.