Privacy Policy

XGEM Property Management (ABM 60 697 551 456) ("we","us" or the "Company"), property developer, is committed to transparency and dealing with your personal information responsibly and in accordance with all relevant laws.

This privacy policy ("Privacy Policy") describes generally how we manage and deal with personal information and privacy. If you would like more information, please don't hesitate to contact us.

This Privacy Policy forms part of, and is subject to the provisions of, our Website Terms of Use (https://xgemproperty.com.au/privacy-policy).

The Australian Privacy Principles

We will treat all personal information in accordance with any and all obligations that are binding upon us under the Privacy Act 1988 (Cth) (“Privacy Act”). The Privacy Act lays down 13 key principles in relation to the collection and treatment of personal information, which are called the “Australian Privacy Principles”.

What is "Personal Information"?

Personal information held by the Company may include your:

  • name and date of birth;

  • residential and business postal addresses, telephone/mobile/fax numbers and email addresses;

  • your computer and connection information; and

  • any other information that you or any third party otherwise shares with us.

How we may collect your personal information

At this site, we only collect personal information that is necessary for us to conduct our business as a property developer.

Information that you provide to us

We may collect personal information that you or a third party provide to us about you when you or a third party:

  • use this site, including (without limitation) when you or a third party;

  • register for access to premium content or request certain premium features; or

  • complete an online contact form to contact us;

  • provide information to us in person, by telephone or through marketing or competition application forms; or

  • send us an email or other communication.

IP addresses

This site may also collect Internet Protocol (IP) addresses. IP addresses are assigned to computers on the internet to uniquely identify them within the global network. The Company collects and manages IP addresses as part of the service of providing internet session management and for security purposes.

The Company may also collect and use web log, computer and connection information for security purposes and to help prevent and detect any misuse of, or fraudulent activities involving, this site.

Cookies

This site uses "cookies" to help personalise your online experience. A cookie is a text file or a packet of information that is placed on your hard disk by a web page server to identify and interact more effectively with your computer. There are two types of cookies that may be used at this site: a persistent cookie and a session cookie. A persistent cookie is entered by your web browser into the "Cookies" folder on your computer and remains in that folder after you close your browser, and may be used by your browser on subsequent visits to this site. A session cookie is held temporarily in your computer’s memory and disappears after you close your browser or shut down your computer. Cookies cannot be used to run programs. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. In some cases, cookies may collect and store personal information about you. The Company extends the same privacy protection to your personal information, whether gathered via cookies or from other sources.

You can configure your internet browser to accept all cookies, reject all cookies or notify you when a cookie is sent. Please refer to your internet browser’s instructions to learn more about these functions. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience all of the features of this site.

Why we use cookies

This site uses cookies in order to:

  • remember your preferences for using this site;

  • show relevant notifications to you (eg, notifications that are relevant only to users who have, or have not, subscribed to newsletters or email or other subscription services); and

  • remember details of data that you choose to submit to us (eg, through online contact forms).

Many of these cookies are removed or cleared when you log out but some may remain so that your preferences are remembered for future sessions.

Third party cookies

In some cases, third parties may place cookies through this site. For example:

  • Google Analytics, may use cookies de-identified data about how long users spend on this site and the pages that they visit;

  • Google AdSense, may use cookies to serve more relevant advertisements across the web and limit the number of times that a particular advertisement is shown to you; and

  • third party social media applications (eg, Facebook, Twitter, LinkedIn, Pinterest, YouTube, Instagram, etc) may use cookies in order to facilitate various social media buttons and/or plugins in this site.

How we may use your personal information

Your personal information may be used in order to:

  • verify your identity;

  • respond to any queries or feedback that you may have;

  • conduct appropriate checks for credit-worthiness and for fraud;

  • prevent and detect any misuse of, or fraudulent activities involving, this site;

  • conduct research and development in respect of our products and/or services;

  • gain an understanding of your information and communication needs or obtain your feedback or views about our products and/or services in order for us to improve them;

  • maintain and develop our business systems and infrastructure, including testing and upgrading of these systems; and/or

  • where permitted by law, share or sell certain personal information to third parties for commercial purposes (such as marketing, analytics, or data partnerships),

and for any other purpose reasonably considered necessary or desirable by the Company in relation to the operation of our business.

From time to time we may email our customers with news, information and offers relating to our own products or services or those of selected partners. Your personal information may also be collected so that the Company can promote and market products and services to you. This is to keep you informed of products, services, and special offers we believe you will find valuable and may continue after you cease acquiring products and services from us. If you would prefer not to receive promotional or other material from us, please let us know and we will respect your request. You can unsubscribe from such communications at any time if you choose.

When we may disclose your personal information

For the purposes set out above, the Company may disclose your personal information to organisations outside the Company. The Company takes reasonable steps to ensure that these organisations are bound by privacy obligations in relation to the protection of your personal information. These organisations may carry out or provide:

  • customer enquiries;

  • mailing systems;

  • billing and debt-recovery functions;

  • information technology services;

  • marketing, telemarketing and sales services;

  • market research

  • lead generation services; and

  • website usage analysis.

In addition, we may disclose your personal information to:

  • your authorised representatives or legal advisers (when requested by you to do so);

  • credit-reporting and fraud-checking agencies;

  • credit providers (for credit-related purposes such as creditworthiness, credit rating, credit provision and financing);

  • our professional advisers, including our accountants, auditors and lawyers;

  • government and regulatory authorities and other organisations, as required or authorised by law;

  • organisations who manage our business strategies, including those involved in a transfer/sale of all or part of our assets or business (including accounts and trade receivables) and those involved in managing our business risk and funding functions; and

  • the police or other appropriate persons where your communication suggests possible illegal activity or harm to others.

Contacting us about privacy

If you would like more information about the way we manage personal information that we hold about you, would like to opt out of any marketing communications or are concerned that we may have breached your privacy, please contact us by email to [] or by post.

Access to your personal information

In most cases, you may have access to personal information that we hold about you. We will handle requests for access to your personal information in accordance with the Australian Privacy Principles. All requests for access to your personal information must be directed to the Privacy Officer by email using the email address provided above or by writing to us at our postal address. We will deal with all requests for access to personal information within a reasonable time frame. Requests for a large amount of information, or information that is not currently in use, may require further time before a response can be given. We may charge you a fee for access if a cost is incurred by us in order to retrieve your information, but in no case will we charge you a fee for your application for access.

In some cases, we may refuse to give you access to personal information that we hold about you. This may include circumstances where giving you access would:

  • be unlawful (eg, where a record that contains personal information about you is subject to a claim for legal professional privilege by one of our contractual counterparties);

  • have an unreasonable impact on another person’s privacy; or

  • prejudice an investigation of unlawful activity.

We may also refuse access where the personal information relates to existing or anticipated legal proceedings, and we reasonably consider that the information would not be accessible by the process of discovery in those proceedings.

If we refuse to give you access, we will provide you with reasons for our refusal.

Correcting your personal information

We will amend any personal information about you that is held by us and that is inaccurate, incomplete or out of date if you request us to do so. If we disagree with your view about the accuracy, completeness or currency of a record of your personal information that is held by us, and you ask us to associate with that record a statement that you have a contrary view, we will take reasonable steps to do so.

Storage and security of your personal information

We are committed to taking reasonable precautions to protect your personal information from unauthorised use or alteration. In our business, personal information may be stored both electronically (on our computer systems and with our website hosting provider) and in hard-copy form. Tools such as firewalls, anti-virus software and email filters, as well as passwords are used to protect our electronic information. We likewise take reasonable measures to ensure the security of hard-copy information.

Third party websites

You may click-through to third party websites from this site, in which case we recommend that you refer to the privacy statement of the websites you visit. This Privacy Policy applies to this site only and the Company assumes no responsibility for the content of any third party websites.

Re-marketing

We may use remarketing services to advertise on third-party websites to previous visitors to this site based on their activity here. This helps us tailor our marketing to better suit your interests and display advertisements that are more relevant to you.

Such services may include, for example, Google Ads (AdWords) and Facebook remarketing. Advertisements may appear on Google search results pages, websites within the Google Display Network, within Facebook, or on other platforms that provide remarketing services. These providers may use cookies and/or pixel tags to enable remarketing. Any data collected by such third parties will be handled in accordance with their respective privacy policies. You may be able to modify your preferences for advertising by those third parties via their websites .

Changes to this Privacy Policy

From time to time, it may be necessary for us to revise this Privacy Policy. Any changes will be in accordance with any applicable requirements under the Privacy Act and the Australian Privacy Principles. We may notify you about changes to this Privacy Policy by posting an updated version on this site.

If you require any further information about the Privacy Act and the Australian Privacy Principles, you can visit the Federal Privacy Commissioner’s website (see www.oaic.gov.au).

Version number: 1.0

Date of publication: May 1, 2026

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