Privacy Policy

Spinelli Real Estate ("we", "us", "our") is committed to protecting your personal information and respecting your privacy. This Privacy Policy explains how we collect, use, disclose and safeguard your personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). By engaging with our services, visiting our website or providing us with your personal information, you consent to the collection, use and disclosure of your information as described in this Policy. We may update this Policy from time to time. The current version will always be available on our website. Last updated: June 2025.

Spinelli Real Estate is a licensed real estate agency operating in New South Wales, Australia. We provide residential and commercial property sales, property management, project marketing and business sales services across the Illawarra region including Wollongong, Shellharbour and Kiama. Licence No.: 1516793 ABN: 42 407 531 447 Office: 12/2 Memorial Drive, Shellharbour City Centre NSW 2529 Phone: 02 4296 0047 Email: info@spinellirealestate.com.au

We may collect the following types of personal information: Identity & Contact Information — Full name — Residential and/or postal address — Email address — Phone number (mobile and/or landline) — Date of birth (where required for contracts) Property & Financial Information — Property ownership details — Investment portfolio details — Financial capacity or pre-approval status (where voluntarily provided) — Rental history and tenancy references — Employment details and income information (for tenancy applications) Identification Documents (for tenancy applications or AML obligations) — Driver's licence or passport details — Other government-issued identification Website & Communication Data — IP address and browser type — Pages visited and time spent on our website — Enquiry and contact form submissions — Email correspondence and phone records — Open home registration details We collect only the information that is necessary for the purposes set out in this Policy. You are not required to provide personal information to browse our website, however some services (such as submitting an enquiry or tenancy application) require personal information to function.

We collect personal information in the following ways: Directly from you — when you: — Contact us via our website enquiry or contact form — Register for or attend an open home or property inspection — Submit a tenancy application — Sign a sales, management or leasing agreement — Correspond with us by phone, email or in person — Subscribe to our marketing communications From third parties — including: — Property portals such as realestate.com.au, Domain.com.au and Homely — Other real estate agencies (in the case of conjunctional sales) — Reference checks provided by previous landlords or employers — Credit reporting bodies (for tenancy applications, where applicable) — Public registers such as NSW Land Registry Services Automatically — when you visit our website, we may collect non-identifiable data through cookies and analytics tools (see Section 11).

We use your personal information for the following primary purposes: Property Sales & Purchases — Managing your sales enquiry, campaign or transaction — Preparing contracts, agency agreements and other documents — Communicating market updates, appraisals and listing information — Facilitating settlement in conjunction with legal representatives Property Management — Processing tenancy applications and conducting reference checks — Managing lease agreements, rent collection and property inspections — Coordinating maintenance requests and communicating with tradespeople — Issuing financial statements and reports — Managing NCAT proceedings where required Leasing & Tenancy — Processing rental applications and verifying eligibility — Communicating tenancy matters including inspections, renewals and arrears Project Marketing — Registering buyer interest in off-the-plan or new development projects — Managing contracts and settlement for project sales General Business Operations — Responding to enquiries and providing customer service — Meeting our legal and regulatory obligations — Maintaining accurate business records — Improving our services and website We will not use your personal information for any purpose unrelated to these primary purposes without your consent, except where required or permitted by law.

We use Agentbox (operated by Reapit Sales) as our primary Customer Relationship Management (CRM) platform. Personal information you provide to us — including contact details, property preferences, tenancy application data and communication history — is stored within the Agentbox platform. Agentbox / Reapit Sales: — Is an Australian-based real estate CRM provider — Maintains data security in accordance with industry standards — Is subject to its own Privacy Policy, available at reapit.com — Does not use your data for its own marketing purposes Data stored in Agentbox includes: contact records, property enquiries, tenancy applications, open home registrations, lease and management records, and communication history. We ensure that access to Agentbox is restricted to authorised Spinelli Real Estate staff only. All team members are trained in data handling obligations under the Privacy Act. Where data is transmitted to or stored by Agentbox, we take reasonable steps to ensure that Agentbox handles that information in a manner consistent with the APPs.

We may disclose your personal information to third parties in the following circumstances: Service Providers & Technology Partners — Agentbox / Reapit Sales (CRM platform — see Section 6) — realestate.com.au, Domain.com.au and other property portals (listing syndication) — Email and communication platforms — Website hosting and analytics providers Professional Advisors & Transaction Parties — Solicitors, conveyancers and settlement agents involved in your transaction — Financial institutions or mortgage brokers (where relevant) — Building inspectors, pest controllers and other property professionals Regulatory & Legal Requirements — NSW Fair Trading and other government bodies — Courts or tribunals (including NCAT) where required — Law enforcement agencies where required by law Reference Checks — Previous landlords or employers named in tenancy applications (for verification purposes only) We do not sell, rent or trade your personal information to third parties for marketing purposes. We will not disclose your information to parties outside Australia unless you have consented or it is required by law. Where overseas disclosure occurs (e.g. cloud services), we take reasonable steps to ensure those parties comply with the APPs or equivalent standards.

With your consent, we may contact you with marketing communications including: — Property listings, new developments and market updates — Appraisal and investment opportunities — Agency newsletters and suburb reports You may opt out of marketing communications at any time by: — Clicking "Unsubscribe" in any marketing email — Contacting us at info@spinellirealestate.com.au — Calling us on 02 4296 0047 We comply with the Spam Act 2003 (Cth) and will not send unsolicited commercial electronic messages.

We take reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure. Our security measures include: — Secure, password-protected CRM access (Agentbox) with role-based permissions — Secure email communications — Physical security of our office premises — Staff training on privacy obligations and data handling — Regular review of our data storage and access practices While we take reasonable precautions, no data transmission over the internet is completely secure. We cannot guarantee absolute security of information transmitted to or from our website. If we become aware of a data breach that is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) in accordance with the Notifiable Data Breaches (NDB) scheme under the Privacy Act.

We retain personal information for as long as it is required for the purposes for which it was collected or as required by law. Retention periods may include: — Sales and property management records: generally 7 years following completion of a transaction, in accordance with NSW real estate legislation and tax obligations — Tenancy application records (unsuccessful applicants): generally 12 months or as soon as practicable after rejection — Marketing enquiries: until you request removal or opt out — Tenancy records (during and post-tenancy): as required under the Residential Tenancies Act 2010 (NSW) When personal information is no longer required, we will take reasonable steps to destroy or de-identify it securely.

Our website may use cookies — small text files placed on your device — to improve your browsing experience and help us understand how the site is used. Cookies may collect: — Pages visited and navigation paths — Browser type, device and operating system — Time and date of visit — Referring website We may use third-party analytics tools (such as Google Analytics) that collect this information on our behalf. These tools operate under their own privacy policies. You can disable cookies through your browser settings, however this may affect the functionality of certain features on our website. By continuing to use our website, you consent to our use of cookies as described above.

You have the right to request access to the personal information we hold about you, and to request that we correct any information that is inaccurate, incomplete or out of date. To make an access or correction request, please contact us at: Email: info@spinellirealestate.com.au Phone: 02 4296 0047 Post: Spinelli Real Estate, 12/2 Memorial Drive, Shellharbour City Centre NSW 2529 We will respond to your request within a reasonable timeframe (generally within 30 days). We may need to verify your identity before providing access. In some circumstances, we may be unable to provide access — for example, where doing so would unreasonably impact the privacy of other individuals, or where access is restricted by law. We will explain any refusal in writing. We do not charge a fee for access requests, however we may charge a reasonable fee for providing copies of information in certain circumstances.

If you believe we have breached the Australian Privacy Principles or this Privacy Policy, you may make a complaint by contacting us at: Email: info@spinellirealestate.com.au Phone: 02 4296 0047 We will acknowledge your complaint within 5 business days and aim to resolve it within 30 days. If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC): Office of the Australian Information Commissioner Website: www.oaic.gov.au Phone: 1300 363 992 Post: GPO Box 5218, Sydney NSW 2001

For any questions, concerns or requests regarding this Privacy Policy or the handling of your personal information, please contact: Spinelli Real Estate Privacy Officer Phone: 02 4296 0047 Email: info@spinellirealestate.com.au Website: spinellirealestate.com.au