MOD Realty Privacy Policy

Version: 1.1 
Effective Date: 6 July 2026 
Approved By: Principal Licensee - MOD Realty 
Review Frequency: Annually 
Next Review Date: 6 July 2027 
Document Owner: MOD Realty

1. Introduction

MOD Realty ("MOD Realty", "we", "our" or "us") is committed to protecting the privacy, confidentiality and security of personal information entrusted to us.

As an independent Queensland real estate agency, we collect and handle personal information in connection with property sales, leasing, property management, appraisals, inspections, marketing, business operations and related real estate services.

This Privacy Policy explains how MOD Realty collects, holds, uses, discloses, stores and protects personal information. It also explains your rights to access and seek correction of your personal information, how to make a privacy complaint, and how we respond to eligible data breaches.

This Privacy Policy is intended to provide an open and transparent explanation of our information-handling practices in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs) and other applicable Australian laws.

2. Purpose

The purpose of this Privacy Policy is to:

  • explain what personal information MOD Realty collects;
  • explain how and why we collect personal information;
  • explain how we use and disclose personal information;
  • explain how we store and protect personal information;
  • explain when information may be disclosed to third parties, including overseas service providers;
  • explain how individuals may access or correct their personal information;
  • explain how privacy complaints are handled; and
  • demonstrate our commitment to compliant and responsible privacy practices.

3. Scope

This Privacy Policy applies to all personal information collected or held by MOD Realty, regardless of the method of collection.

This includes information collected through:

  • our website;
  • online enquiry forms;
  • rental application forms;
  • appraisal request forms;
  • paper forms;
  • email correspondence;
  • SMS and telephone communications;
  • face-to-face meetings;
  • inspections and open homes;
  • auctions;
  • sales and leasing transactions;
  • residential and commercial property management;
  • social media interactions; and
  • other lawful business interactions.

This Privacy Policy applies to personal information collected from:

  • property owners;
  • landlords;
  • tenants and prospective tenants;
  • buyers and prospective buyers;
  • sellers;
  • guarantors;
  • emergency contacts;
  • occupants;
  • contractors, tradespeople and suppliers;
  • website visitors; and
  • other individuals who interact with MOD Realty.

4. Legislative Framework

MOD Realty manages personal information in accordance with applicable Australian legislation, including where relevant:

  • Privacy Act 1988 (Cth);
  • Australian Privacy Principles in Schedule 1 to the Privacy Act 1988 (Cth);
  • Privacy Amendment (Enhancing Privacy Protection) Act 2012 (Cth);
  • Privacy Amendment (Notifiable Data Breaches) Act 2017 (Cth);
  • Spam Act 2003 (Cth);
  • Do Not Call Register Act 2006 (Cth);
  • Electronic Transactions Act 1999 (Cth);
  • anti-money laundering and counter-terrorism financing requirements, where applicable;
  • Queensland residential tenancy legislation;
  • Queensland property and real estate legislation; and
  • other applicable Commonwealth or State laws relating to the handling of personal information.

Where legal requirements or business operations change, we may update this Privacy Policy.

5. Definitions

For the purposes of this Privacy Policy:

Australian Privacy Principles (APPs) means the principles contained in Schedule 1 of the Privacy Act 1988 (Cth).

Personal Information means information or an opinion 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 has the meaning given in the Privacy Act 1988 (Cth) and includes information such as health information, biometric information, racial or ethnic origin, religious beliefs, political opinions, sexual orientation and criminal record.

Client means any person or organisation engaging MOD Realty for real estate services.

Website means the MOD Realty website and associated digital services.

Third Party means any person or organisation other than MOD Realty and the individual to whom the information relates.

6. Our Commitment to Privacy

Protecting personal information is fundamental to our business.

MOD Realty is committed to:

  • collecting personal information only where it is reasonably necessary for our functions and activities;
  • collecting information by lawful and fair means;
  • taking reasonable steps to provide notice about our collection practices;
  • ensuring personal information is accurate, up to date and complete where reasonably practicable;
  • protecting personal information from misuse, interference, loss and unauthorised access, modification or disclosure;
  • providing access to and correction of personal information where required by law;
  • training staff on privacy obligations;
  • reviewing privacy and security practices regularly; and
  • responding appropriately to privacy complaints and data breaches.

7. The Personal Information We Collect

The personal information we collect depends on the nature of your interaction with us and the services we provide.

We may collect the following categories of personal information.

7.1 Identification Information

We may collect:

  • full name;
  • previous names;
  • date of birth;
  • residential and postal address;
  • email address;
  • telephone number;
  • emergency contact details;
  • occupation and employer details;
  • ABN, where applicable;
  • driver's licence details;
  • passport details;
  • proof of age documents;
  • visa information where relevant; and
  • other government-issued identification reasonably required for identity verification.

7.2 Financial Information

Depending on the services being provided, we may collect:

  • bank account details;
  • trust account payment details;
  • rental payment information;
  • salary or income information;
  • employment history;
  • rental affordability information;
  • credit-related information where authorised by law;
  • mortgage broker or lender details;
  • settlement information;
  • payment history; and
  • taxation information where required.

7.3 Property and Transaction Information

We may collect information relating to:

  • residential, commercial, investment and rental properties;
  • property ownership;
  • tenancy details;
  • lease agreements;
  • inspection reports;
  • condition reports;
  • maintenance and repair records;
  • photographs, floor plans and marketing materials;
  • appraisals and valuations; and
  • transaction documents and communications.

7.4 Property Management Information

Where we manage a property, we may collect information including:

  • tenancy applications;
  • lease documents;
  • routine inspection records;
  • entry and exit condition reports;
  • maintenance requests;
  • contractor reports;
  • notices under tenancy legislation;
  • `rental payment and arrears records;

  • insurance claim information where relevant; and

  • dispute or complaint records.

7.5 Sales and Leasing Information

Where we provide sales or leasing services, we may collect:

  • vendor and purchaser details;
  • buyer and seller enquiries;
  • inspection and auction registration information;
  • offers and contract information;
  • settlement information;
  • solicitor or conveyancer details;
  • finance information voluntarily provided; and
  • communications relating to the transaction.

8. Sensitive Information

MOD Realty generally does not collect sensitive information unless:

  • you have consented;
  • the collection is required or authorised by law;
  • the collection is reasonably necessary for our functions or services and permitted by law; or
  • another exception under the Privacy Act applies.

Sensitive information may include information relating to:

  • health or disability;
  • racial or ethnic origin;
  • criminal history where lawfully required;
  • biometric information; or
  • other information classified as sensitive under the Privacy Act.

Where we collect sensitive information, we take reasonable steps to ensure it is used and disclosed only for the purpose for which it was collected, or otherwise as permitted by law.

9. How We Collect Personal Information

We collect personal information by lawful and fair means. Where practicable, we collect it directly from the individual concerned.

We may collect information through:

  • face-to-face meetings;
  • telephone calls;
  • email and SMS communications;
  • written correspondence;
  • online forms;
  • rental application forms;
  • property inspections and open homes;
  • auctions;
  • property transactions;
  • social media interactions;
  • publicly available sources;
  • government authorities where authorised;
  • employers, referees, previous landlords or property managers nominated by applicants;
  • contractors and service providers involved in a transaction; and
  • other third parties where authorised or permitted by law.

Where we collect personal information from a third party, we will take reasonable steps, where required, to ensure the individual is aware of the collection.

10. Why We Collect Personal Information

We collect personal information for purposes including:

  •  providing residential and commercial sales services;
  • providing residential and commercial property management services;
  • conducting leasing activities;
  • assessing rental applications;
  • verifying identity;
  • communicating with clients and prospects;
  • arranging inspections, repairs and maintenance;
  • preparing appraisals and marketing properties;
  • administering contracts and trust account transactions;
  • complying with legal and regulatory obligations;
  • managing disputes and complaints;
  • protecting our legal interests and preventing fraud;
  • improving our services, systems and website; and
  • other purposes reasonably expected in connection with our business activities.

If you do not provide requested personal information, we may be unable to:

  • assess an application;
  • provide requested real estate services;
  • respond fully to an enquiry;
  • verify identity;
  • process a transaction; or
  • comply with our legal obligations.

11. Collection Through Our Website

When you visit our website, we may automatically collect technical and usage information such as:

  • IP address;
  • browser type;
  • operating system;
  • referring website;
  • pages visited;
  • date and time of access;
  • approximate location data derived from device or network information;
  • device identifiers; and
  • browsing and clickstream behaviour.

We use this information to:

  • improve website performance and usability;
  • maintain website security;
  • respond to enquiries;
  • administer online forms and rental applications;
  • analyse traffic and user behaviour; and
  • improve our services and digital experience.

Submission of information through our website is voluntary. However, if you choose not to provide requested information, some website features or services may not be available.

12. Rental Applications and Identity Verification

As part of assessing rental applications and administering tenancy-related services, we may collect information reasonably necessary to assess suitability for tenancy and manage the tenancy relationship.

This may include:

  • proof of identity;
  • proof of current address;
  • proof of income;
  • employment information;
  • rental history;
  • references from previous landlords or property managers;
  • personal references;
  • emergency contact details;
  • vehicle information where relevant;
  • pet information where applicable; and
  • other supporting information voluntarily provided.

We may verify information provided by applicants through employers, referees, former landlords or property managers, publicly available information, identity documents and other lawful verification methods.

Providing false or misleading information may affect the assessment of an application or our ability to provide services.

13. How We Use Personal Information

We use personal information only for purposes that are reasonably necessary for our business activities, for the purpose for which it was collected, for a related purpose you would reasonably expect, or as otherwise permitted or required by law.

These purposes may include:

  • sales, leasing and property management services;
  • property advertising and inspections;
  • processing enquiries and applications;
  • communication with clients, landlords, tenants, buyers and sellers;
  • contract administration and settlement support;
  • trust account administration and payment processing;
  • repairs, maintenance and contractor engagement;
  • identity verification and fraud prevention;
  • compliance with legal obligations;
  • complaint handling and dispute resolution;
  • internal administration, record keeping, business planning and training; and
  • de-identified analytics and service improvement.

14. Disclosure of Personal Information

We may disclose personal information where:

  • you have consented;
  • the disclosure is reasonably necessary to provide our services;
  • the disclosure is required or authorised by law; or
  • another exception under the Privacy Act applies.

Depending on the circumstances, we may disclose personal information to:

  • landlords, owners, vendors, purchasers, buyers, sellers and tenants;
  • prospective landlords, buyers or tenants where reasonably necessary in the transaction context;
  • contractors, tradespeople and maintenance providers;
  • insurers;
  • solicitors and conveyancers;
  • mortgage brokers and financial institutions;
  • government departments and regulators;
  • courts, tribunals and law enforcement bodies where required or authorised;
  • debt recovery agencies where legally permitted;
  • accountants, auditors and professional advisers; and
  • technology, cloud, communications, website, software and marketing service providers who assist our operations.

We do not sell personal information to third parties.

15. Third-Party Service Providers

We engage third-party service providers to support our operations. These providers may collect, process, host or store personal information on our behalf.

These may include providers such as:

  • PropertyMe for property management, tenancy administration, inspections, maintenance and associated records;
  • Microsoft 365 / Outlook for email, calendars, documents, collaboration and business records;
  • realestate.com.au and similar advertising platforms for listings, enquiries, inspections and marketing;
  • Eagle or similar marketing and advertising platforms for campaign preparation and publishing;
  • website developers, hosts and form providers;
  • cloud storage and backup providers;
  • IT support and cybersecurity providers; and
  • SMS, CRM and communications providers.

We take reasonable steps to ensure service providers are reputable and are subject to appropriate confidentiality, privacy and security obligations.

16. Overseas Disclosure

Some third-party service providers we use may store or process personal information outside Australia, including through cloud-based systems, international support teams or distributed server infrastructure.

As a result, personal information may be disclosed to overseas recipients in countries where our service providers or their subcontractors operate, host data or provide support services. Those countries may not have privacy laws equivalent to Australia.

Where overseas disclosure may occur, MOD Realty takes reasonable steps to ensure that the recipient handles personal information in a manner consistent with Australian privacy requirements, including through contractual measures, vendor due diligence and security controls where practicable.

By dealing with us and providing personal information, you acknowledge that such overseas handling may occur in connection with the services we use.

17. Direct Marketing

MOD Realty may use personal information to send communications about:

  • properties for sale or lease;
  • property alerts;
  • newsletters;
  • market updates;
  • auction notices;
  • agency news;
  • service offerings; and
  • other information that may be relevant to your interests.

These communications may be sent by:

  • email;
  • SMS;
  • telephone;
  • post; or
  • other lawful electronic means.

Where required by law, we will obtain consent before sending marketing communications. You may opt out of direct marketing communications at any time by using the unsubscribe facility, following opt-out instructions in the message, or contacting us directly.

We will process opt-out requests within a reasonable period and in accordance with applicable law.

18. Property Alerts

If you subscribe to property alerts, we may send notifications relating to your stated preferences, including:

  • new listings;
  • price changes;
  • inspection times;
  • auction information;
  • leased or sold updates where relevant; and
  • similar property-related information.

You may unsubscribe at any time.

19. Newsletters and SMS Communications

We may send newsletters and SMS communications for business and service-related purposes, including:

  • inspection reminders;
  • appointment confirmations;
  • leasing or tenancy updates;
  • maintenance communications;
  • marketing communications where permitted;
  • market information; and
  • agency updates.

Email and SMS marketing communications will be managed in accordance with applicable Australian law, including the Spam Act where relevant.

Recipients may opt out of marketing communications at any time.

20. Cookies and Website Technologies

Our website uses cookies and similar technologies to improve website functionality, remember user preferences, analyse traffic, support security and help us provide relevant content and services.

Cookies may be used to:

  • remember preferences;
  • improve website performance;
  • analyse visitor behaviour;
  • support website administration and security;
  • assist with property searches;
  • measure campaign effectiveness; and
  • personalise user experience.

Most browsers allow cookies to be disabled or deleted through browser settings. Disabling cookies may affect the functionality of some parts of our website.

21. Website Analytics

We may use website analytics tools to better understand how visitors interact with our website.

Analytics information may include:

  • pages viewed;
  • time spent on pages;
  • navigation paths;
  • referring websites;
  • approximate geographic location;
  • browser type;
  • operating system;
  • device type; and
  • IP address or related technical identifiers where collected.

We use analytics information to:

  • improve usability;
  • identify technical issues;
  • understand customer interests;
  • improve online services;
  • evaluate marketing performance; and
  • enhance customer experience.

Where reasonably practicable, analytics information is used in aggregated or de-identified form.

22. Social Media

We maintain social media profiles to communicate with clients, promote properties and engage with the public.

If you interact with us through social media, we may collect personal information you voluntarily provide, such as:

  • comments;
  • direct messages;
  • reviews;
  • reactions;
  • shared content;
  • photographs;
  • videos; and
  • enquiries.

Information published on social media may be visible to the public depending on your account settings. Social media platforms operate under their own privacy policies, and we are not responsible for the privacy practices of those platforms.

23. CCTV

MOD Realty operates Closed Circuit Television (CCTV) at its office premises and, where applicable, at certain business-controlled areas for legitimate business purposes.

23.1 Purpose of CCTV

CCTV may be used for purposes including:

  • maintaining the security of our office, staff, clients and visitors;
  • preventing and detecting unlawful activity, misconduct or damage to property;
  • investigating incidents, complaints or safety concerns;
  • supporting workplace health and safety measures; and
  • protecting business assets and confidential information.

23.2 Areas Monitored

CCTV may monitor areas such as:

  • office entry and exit points;
  • reception and customer-facing areas;
  • external building access points;
  • car parking or loading areas under our control; and
  • other business premises areas where surveillance is reasonably necessary.

CCTV is not intended to be installed in places where individuals would reasonably expect a high level of privacy, such as toilets or similar private facilities.

23.3 Signage and Notice

Where CCTV operates, appropriate signage will be displayed to notify individuals that surveillance is in use.

23.4 Access, Use and Disclosure

Access to CCTV footage is restricted to authorised personnel and persons acting on our behalf who require access for legitimate business, legal, safety or security purposes.

CCTV footage may be used or disclosed where reasonably necessary for the purposes described above, including to:

  • law enforcement agencies;
  • insurers;
  • legal advisers;
  • courts or tribunals;
  • landlords, building managers or security providers where relevant; or
  • other persons where required or authorised by law.

23.5 Retention and Security of Footage

CCTV recordings are stored securely and retained only for as long as reasonably necessary for security, safety, evidentiary, operational or legal purposes, after which they are deleted, overwritten or securely destroyed.

24. Storage and Security of Personal Information

We take reasonable steps to protect personal information against misuse, interference, loss and unauthorised access, modification or disclosure.

Security measures may include:

  • secure office premises;
  • restricted physical access to records;
  • password-protected systems;
  • multi-factor authentication where appropriate;
  • secure cloud storage;
  • encryption where practicable;
  • antivirus, endpoint protection and firewalls;
  • software updates and patching;
  • access controls based on business need;
  • staff training;
  • system monitoring and incident response measures;
  • secure disposal of documents and devices; and
  • contractual privacy obligations with relevant service providers.

No method of electronic transmission or storage is completely secure. While we take reasonable steps to protect information, we cannot guarantee absolute security.

25. Retention and Destruction

We retain personal information only for as long as reasonably necessary to:

  • provide our services;
  • comply with legal obligations;
  • maintain business and regulatory records;
  • resolve disputes;
  • enforce agreements; and
  • respond to legal or regulatory requests.

When personal information is no longer required, we take reasonable steps to securely destroy or permanently de-identify it unless we are required or authorised by law to retain it.

Secure destruction methods may include:

  • secure shredding of paper records;
  • permanent deletion of electronic records;
  • secure destruction of storage media where appropriate; and
  • de-identification of data.

26. Access to Personal Information

You may request access to personal information we hold about you by contacting us in writing.

Before providing access, we may require proof of identity.

We will respond to access requests within a reasonable period and, where practicable, usually within 30 days.

Access may be refused where permitted by law, including where:

  • providing access would unreasonably affect another person's privacy;
  • the request is frivolous or vexatious;
  • legal professional privilege applies;
  • the information relates to existing or anticipated legal proceedings;
  • providing access would be unlawful; or
  • another exception under the Privacy Act applies.

If we refuse access, we will provide written reasons and information about available complaint mechanisms where required by law.

27. Correction of Personal Information

We take reasonable steps to ensure that the personal information we hold is accurate, up to date, complete, relevant and not misleading.

You may request correction of personal information we hold about you. We will respond within a reasonable period and, where practicable, usually within 30 days.

Where appropriate, we will:

  • update inaccurate information;
  • correct incomplete information; and
  • notify relevant third parties of the correction where required or appropriate.

If we refuse to correct information, we will provide written reasons and, where required, take reasonable steps to associate a statement with the information noting that correction was requested.

28. Privacy Complaints

If you believe we have mishandled your personal information, you may make a privacy complaint in writing using our contact details.

A complaint should include:

  • your name and contact details;
  • details of the privacy concern;
  • relevant dates;
  • any supporting documents; and
  • the outcome you are seeking.

Upon receiving a complaint, we will:

  1. acknowledge receipt within a reasonable timeframe;
  2. consider and investigate the issues raised;
  3. seek further information if necessary;
  4. determine whether a privacy issue or breach has occurred;
  5. notify you of the outcome; and
  6. implement corrective action where appropriate.

29. OAIC Complaints

If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (OAIC).

The OAIC is the independent regulator responsible for administering the Privacy Act 1988 (Cth). We encourage individuals to give us a reasonable opportunity to resolve a complaint before escalating it to the OAIC. OAIC

30. Notifiable Data Breaches

MOD Realty complies with the Notifiable Data Breaches (NDB) scheme under the Privacy Act 1988 (Cth).

If we become aware of an eligible data breach, we will take steps including:

  • promptly investigating the incident;
  • assessing whether the incident is likely to result in serious harm;
  • containing the breach and reducing the risk of harm;
  • notifying affected individuals where required by law;
  • notifying the OAIC where required by law; and
  • reviewing internal practices to reduce the risk of recurrence. OAIC data breach

31. Changes to this Privacy Policy

We may amend this Privacy Policy from time to time to reflect:

  • legislative or regulatory changes;
  • technological developments;
  • changes in business operations;
  • improvements in privacy practices; or
  • operational requirements.

The current version of this Privacy Policy will be published on our website.

32. Contact Details

Questions, requests for access or correction, and privacy complaints should be directed to MOD Realty using the contact details published on our official website.

Our current office address, telephone number and email address are available on the MOD Realty website.

33. Governing Law

This Privacy Policy is governed by the laws of the Commonwealth of Australia and the State of Queensland.

Any dispute relating to this Privacy Policy is subject to the jurisdiction of the courts and tribunals of Queensland and any applicable Australian court or regulatory body.

34. Document Review

This Privacy Policy will be reviewed:

  • at least annually;
  • following significant legislative change;
  • following material changes to business operations;
  • following implementation of new systems or technologies affecting privacy;
  • following an eligible data breach or significant privacy incident; or
  • whenever otherwise considered necessary by MOD Realty.

35. Version History

Version 

Effective Date 

Description 

Approved By 

1.1 

6 July 2026 

Consolidated Privacy Policy 

Principal Licensee