Privacy Policy

1. About this Privacy Policy

THG respects the privacy of the individuals, customers, clients, investors, suppliers, contractors, employees, applicants, business partners and other persons with whom we interact.

This Privacy Policy describes how THG manages personal information and is intended to support our obligations under applicable Australian privacy laws, including the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), where those laws apply to our activities.

Certain THG entities, businesses, products or services may also be subject to additional privacy, financial services, credit reporting, anti-money laundering, consumer, property, employment, telecommunications or other legal obligations.

Where a separate privacy notice, collection notice, product-specific notice or contractual privacy provision applies, that additional notice should be read together with this Privacy Policy.

2. Who We Are

In this Privacy Policy, "THG", "we", "our" and "us" refer to TRAN Holdings Group and, where applicable, its related bodies corporate, subsidiaries, controlled entities and business divisions.

THG's activities may include:

• financial services and financial acquisitions;
• financial technology and digital financial platforms;
• commercial property development;
• residential property development;
• construction and project delivery;
• property leasing and associated services;
• investment and corporate activities;
• agricultural businesses and projects;
• procurement, supply and distribution;
• goods and services;
• technology and digital services; and
• other related commercial activities undertaken by THG.

3. Scope of this Policy

This Privacy Policy may apply when you:

• visit or use a THG website;
• use a THG application, portal or digital service;
• create an account with us;
• request information or submit an enquiry;
• purchase, obtain or enquire about goods or services;
• apply for or use a financial or fintech product;
• apply for finance, credit or investment opportunities;
• purchase, lease, rent or enquire about property;
• enter into a construction or development arrangement;
• invest in or conduct business with THG;
• provide goods or services to THG;
• visit a THG office, development or project site;
• communicate with our personnel;
• attend a THG event;
• subscribe to communications from us;
• apply for employment or contracting opportunities; or
• otherwise interact with THG.

4. Personal Information We Collect

The type of information we collect depends on the nature of your relationship with THG and the products, services or activities involved.

4.1 Identity information

• full name;
• date of birth;
• age;
• gender where relevant;
• signature;
• photograph;
• customer or account identifiers;
• identity verification information;
• driver licence details;
• passport details; and
• other identity documents where reasonably necessary.

4.2 Contact information

• residential or business address;
• postal address;
• email address;
• telephone number; and
• other contact information you provide.

4.3 Financial information

Where relevant to a transaction or service, we may collect:

• bank account details;
• payment information;
• transaction information;
• income information;
• assets and liabilities;
• expenses;
• financial statements;
• investment information;
• loan or finance information;
• credit-related information where legally permitted;
• source-of-funds information; and
• other information necessary to assess or administer a financial transaction.

4.4 Business and professional information

• company name;
• job title;
• business contact details;
• ABN, ACN or other business identifiers;
• professional qualifications;
• business ownership information;
• director or officeholder information;
• supplier and contractor information; and
• details about your dealings with THG.

4.5 Transaction information

This may include records relating to:

• products or services purchased;
• quotes and proposals;
• contracts;
• payments and invoices;
• property transactions;
• finance applications;
• investment activity;
• leases;
• projects;
• service history; and
• customer support interactions.

4.6 Communications

We may retain communications you have with us, including emails, telephone records, online enquiries, support communications, forms, correspondence and other records relating to your interaction with THG.

4.7 Digital and device information

When you interact with our digital services, we may collect:

• IP address;
• device identifiers;
• browser type;
• operating system;
• website usage data;
• pages visited;
• date and time of access;
• referral source;
• session data;
• cookie identifiers;
• approximate location derived from network information; and
• security and fraud-prevention information.

5. Sensitive Information

Certain information is treated as sensitive information under Australian privacy law and is subject to additional protections.

THG will generally only collect sensitive information where it is reasonably necessary for our functions or activities and where we have your consent, or where collection is otherwise permitted or required by law.

Depending on the circumstances, this may include information concerning:

• health or medical matters;
• racial or ethnic origin;
• professional or trade association membership;
• criminal history;
• biometric information used for identification; or
• other information classified as sensitive under applicable law.

6. How We Collect Personal Information

We may collect personal information directly from you when you:

• complete a form;
• create an account;
• contact us;
• enter into a transaction;
• submit an application;
• sign a contract;
• make a payment;
• attend one of our premises or sites;
• use our website or digital services;
• participate in an event or promotion; or
• otherwise communicate with THG.

We may also collect information from third parties including:

• your authorised representatives;
• financial institutions;
• brokers;
• accountants;
• lawyers;
• real estate professionals;
• property managers;
• contractors and suppliers;
• payment providers;
• identity verification providers;
• fraud-prevention providers;
• credit reporting bodies where legally permitted;
• government agencies;
• regulatory authorities;
• publicly available registers;
• commercial information providers;
• related THG entities; and
• business partners.

7. Why We Collect and Use Personal Information

We may collect, hold, use and disclose personal information to:

• provide our products and services;
• respond to enquiries;
• establish and manage customer relationships;
• verify identity;
• create and administer accounts;
• process transactions and payments;
• assess applications;
• administer contracts;
• provide finance-related products or services;
• manage property transactions and leases;
• manage development and construction projects;
• conduct due diligence;
• assess business opportunities;
• manage suppliers and contractors;
• conduct risk assessments;
• prevent fraud and financial crime;
• secure our systems and facilities;
• undertake accounting, auditing and reporting;
• manage disputes and complaints;
• enforce contractual rights;
• meet legal and regulatory obligations;
• improve our products, services and operations;
• conduct research and analytics;
• develop new products or services;
• communicate information about THG;
• market products and services where permitted;
• manage corporate transactions;
• protect THG, our customers and third parties; and
• carry out other activities reasonably related to our business functions.

8. Finance, Financial Services and Fintech

Where THG provides, arranges, facilitates or supports financial or fintech products, additional personal and financial information may be required.

We may use such information to:

• verify your identity;
• assess financial applications;
• assess affordability, eligibility or suitability;
• undertake credit or risk assessments where permitted;
• establish and administer financial accounts;
• process payments and settlements;
• detect suspicious or fraudulent activity;
• meet anti-money laundering and counter-terrorism financing requirements;
• perform sanctions or politically exposed person screening where required;
• meet taxation and financial reporting requirements;
• manage investments and transactions; and
• comply with regulatory obligations.

Where credit reporting laws apply to a particular THG entity or product, a separate credit reporting policy or credit information notice may also apply.

9. Property, Development, Construction and Leasing

For our commercial property, residential property, construction, development and leasing activities, we may collect information about property owners, purchasers, prospective purchasers, tenants, prospective tenants, investors, contractors, consultants and representatives.

This may include information necessary to:

• manage property enquiries;
• undertake property transactions;
• administer leases;
• process deposits and payments;
• manage settlements;
• coordinate contractors and consultants;
• manage construction sites;
• perform project management;
• manage workplace health and safety obligations;
• manage building access and security;
• communicate project updates; and
• meet legal and regulatory requirements.

CCTV and site security

THG premises, buildings, developments or construction sites may use CCTV or other security systems for safety, security, incident investigation, loss prevention and access-control purposes.

10. Digital, Website and Technical Information

When you use our websites, applications or online systems, our systems or technology providers may automatically collect technical information.

This information may be used to:

• operate our website and applications;
• maintain security;
• authenticate users;
• remember preferences;
• analyse website performance;
• diagnose technical issues;
• prevent abuse or fraud;
• understand visitor engagement;
• measure advertising effectiveness; and
• improve user experience.

11. Cookies and Similar Technologies

Our websites may use cookies, pixels, tags, local storage, analytics technologies and similar tools.

Strictly necessary technologies

These technologies help provide core website functionality, security, account access and network management.

Analytics technologies

These technologies help us understand how visitors interact with our websites and digital services.

Functional technologies

These technologies may remember settings and preferences and provide enhanced functionality.

Advertising technologies

Where used and permitted, advertising technologies may measure advertising campaigns or assist in delivering content and advertisements that may be more relevant to users.

You may be able to manage cookies through your browser settings or a cookie preference tool provided on our website.

12. Direct Marketing

Where permitted by law, THG may use personal information to communicate with you about products, services, projects, developments, investments, events, promotions and other matters that we believe may be relevant to you.

Marketing communications may be delivered by:

• email;
• SMS;
• telephone;
• online advertising;
• postal mail; or
• other electronic communication channels.

You may opt out of direct marketing communications at any time by using an unsubscribe facility provided in the communication or by contacting us.

We may still send non-marketing communications that are necessary to administer an account, transaction, contract or service.

13. Who We May Disclose Personal Information To

We do not disclose personal information indiscriminately. Where reasonably necessary for our activities or permitted by law, information may be disclosed to:

• related THG companies;
• banks and financial institutions;
• payment processors;
• financial service providers;
• brokers and advisers;
• credit reporting bodies where legally permitted;
• identity verification providers;
• fraud and financial crime prevention providers;
• accountants and auditors;
• lawyers and professional advisers;
• insurers and insurance brokers;
• real estate professionals;
• property managers;
• builders and contractors;
• architects, engineers and consultants;
• technology and cloud service providers;
• data hosting providers;
• communications providers;
• analytics providers;
• marketing providers;
• customer relationship management providers;
• security providers;
• government authorities;
• regulators;
• courts and law enforcement agencies;
• prospective purchasers or investors in a THG business or asset; and
• other parties where you have authorised or requested the disclosure.

14. Sharing Within the THG Group

THG may operate through multiple companies, subsidiaries, divisions, brands or joint ventures.

Subject to applicable law, personal information may be shared within the THG group where reasonably necessary for:

• customer administration;
• financial management;
• corporate governance;
• risk management;
• information security;
• legal compliance;
• project delivery;
• business operations;
• internal reporting; and
• providing integrated products and services.

15. Overseas Disclosure and Processing

Some of our suppliers, technology providers, cloud infrastructure providers, professional advisers or related entities may operate outside Australia.

As a result, personal information may be disclosed to or processed by recipients located outside Australia.

Where practicable, THG will identify the countries in which overseas recipients are likely to be located.

THG takes reasonable steps in relation to overseas disclosures as required by applicable Australian privacy law.

16. Government-Related Identifiers

THG may collect government-related identifiers where required or authorised by law or where reasonably necessary for identity verification or regulatory compliance.

We do not generally use government-related identifiers as our own customer identifier unless permitted by law.

17. How We Protect Personal Information

THG takes reasonable steps to protect personal information from misuse, interference, loss and unauthorised access, modification or disclosure.

Depending on the circumstances, safeguards may include:

• access controls;
• authentication controls;
• role-based permissions;
• encryption where appropriate;
• secure hosting;
• network security controls;
• system monitoring;
• logging and auditing;
• backup processes;
• physical security;
• employee confidentiality obligations;
• cybersecurity procedures;
• vendor assessments;
• incident response processes; and
• staff privacy and security awareness measures.

No internet transmission or electronic storage system can be guaranteed to be completely secure. Accordingly, we cannot guarantee absolute security of information.

18. Data Retention and Destruction

We retain personal information for as long as reasonably necessary for the purposes for which it was collected and for any additional period required or permitted by law.

Retention periods may depend on:

• the nature of the information;
• the type of transaction;
• contractual requirements;
• financial and taxation obligations;
• regulatory requirements;
• applicable limitation periods;
• dispute management requirements;
• fraud and security considerations; and
• legitimate record-keeping requirements.

When personal information is no longer required and we are not legally required to retain it, we will take reasonable steps to destroy or de-identify it.

19. Data Breaches

THG maintains procedures for identifying, assessing, containing and responding to suspected privacy and cybersecurity incidents.

Where a data breach is subject to notification requirements under applicable Australian law, including the Notifiable Data Breaches scheme where applicable, THG will take appropriate steps in accordance with those requirements.

20. Access, Correction and Your Privacy Rights

Subject to applicable exceptions, you may request access to personal information that THG holds about you.

You may also request that we correct information that is inaccurate, out of date, incomplete, irrelevant or misleading.

You may contact us to:

• request access to personal information;
• request correction of personal information;
• update your contact information;
• withdraw a consent where applicable;
• change marketing preferences;
• make a privacy enquiry; or
• make a privacy complaint.

To protect your privacy and security, we may need to verify your identity before processing certain requests.

If we refuse an access or correction request in circumstances where the law permits us to do so, we will generally provide reasons as required by applicable law.

21. Anonymity and Pseudonymity

Where practicable and permitted by law, you may interact with THG anonymously or by using a pseudonym.

In many circumstances, however, we will need to know your identity in order to provide services, enter transactions, verify ownership, process payments, provide financial services, meet regulatory obligations or respond effectively to your request.

22. Automated Systems, Analytics and Artificial Intelligence

THG may use analytics, software automation and artificial intelligence systems to support business operations, subject to applicable laws and internal controls.

These technologies may be used to assist with:

• fraud detection;
• risk analysis;
• document processing;
• customer support;
• business analytics;
• cybersecurity;
• workflow automation;
• property or market analysis;
• financial analysis;
• service improvement; and
• other legitimate business processes.

Where personal information is processed through such systems, THG will seek to apply appropriate privacy, confidentiality, security and governance safeguards.

We may provide additional notices where a particular automated system materially affects how personal information is handled or where additional disclosure is required by law.

23. Children's Privacy

THG's general commercial services are not ordinarily directed to children.

Where it is necessary for THG to collect information relating to a child, we will take reasonable steps appropriate to the circumstances, including obtaining consent from a parent or guardian where required or appropriate.

24. Employees, Contractors and Job Applicants

If you apply for employment, contracting or other work with THG, we may collect information including:

• your name and contact information;
• résumé or curriculum vitae;
• employment history;
• education;
• qualifications;
• professional memberships;
• references;
• work eligibility information;
• background screening information where appropriate and lawful;
• interview notes; and
• other information relevant to your application.

Information relating to current and former employees may also be subject to specific employment-related legal rules and exemptions.

25. Third-Party Websites and Services

THG websites and digital services may contain links to websites, applications or services operated by third parties.

Those third parties may have their own privacy policies and information-handling practices. THG is not responsible for the privacy practices of independent third-party services.

We recommend reviewing the privacy policies of third-party services before providing them with personal information.

26. Privacy Enquiries and Complaints

If you have a question, concern or complaint about how THG has handled your personal information, please contact our Privacy Officer using the details below.

Please provide sufficient information to enable us to understand the issue and investigate your concern.

THG will assess privacy complaints and seek to respond within a reasonable period, taking into account the nature and complexity of the matter.

If you are not satisfied with our response, you may have the right to contact the Office of the Australian Information Commissioner (OAIC) or another relevant regulator.

27. Changes to this Privacy Policy

THG may update this Privacy Policy periodically to reflect changes to our businesses, technology, products, services, regulatory obligations or information-handling practices.

The current version will be published on our website and will display the date on which it was last updated.

Where a change is material and additional notification is appropriate or legally required, THG may provide additional notice through our website, email, applications or other appropriate communication channels.

28. Contact TRAN Holdings Group "THG"

For privacy questions, access or correction requests, consent enquiries or privacy complaints, please contact:

© TRAN Holdings Group (Aust) Pty Ltd. All rights reserved.