Privacy Policy

M5 Industrial Property Services

1. Introduction

M5 Industrial Property Services is committed to protecting the privacy of individuals and handling personal information responsibly, transparently, and in accordance with the Privacy Act 1988 (Cth), including the Australian Privacy Principles (APPs).

This Privacy Policy explains how we collect, use, disclose, store, and protect personal information and how individuals may access and correct their personal information or make a privacy complaint.

This policy applies to all personal information collected by M5 Industrial Property Services in connection with our real estate and property services, including information relating to clients, customers, tenants, landlords, personnel, contractors, job applicants, website users, and other stakeholders.

2. Applicable Legislation

This Privacy Policy is governed by, and operates in accordance with:

Privacy Act 1988 (Cth)
Australian Privacy Principles (APPs)
Privacy Amendment (Enhancing Privacy Protection) Act 2012 (Cth)
Privacy Amendment (Notifiable Data Breaches) Act 2017 (Cth)

In addition, we may collect, verify, use and disclose personal information where required to comply with applicable laws, including:

Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth)
Applicable Anti-Money Laundering and Counter-Terrorism Financing Rules, Regulations and Legislative Instruments issued or amended from time to time
Autonomous Sanctions Act 2011 (Cth)
Charter of the United Nations Act 1945 (Cth)
Information Privacy Act 2014 (ACT)
Privacy and Personal Information Protection Act 1998 (NSW)

3. Definitions

For the purposes of this Privacy Policy:

Personal information has the meaning given in section 6 of the Privacy Act 1988 (Cth) and means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information is true or not and whether recorded in a material form or not.

Sensitive information includes information about an individual that is defined as sensitive information under the Privacy Act 1988 (Cth), including health information and biometric information.

Credit related information is regulated separately under Part IIIA of the Privacy Act 1988 (Cth) and includes credit information and credit eligibility information as defined under that Part.

4. Open and Transparent Management of Personal Information (APP 1)

M5 Industrial Property Services manages personal information in an open and transparent manner. We maintain practices, procedures, and systems to ensure compliance with the Australian Privacy Principles and to protect personal information from misuse, interference, loss, unauthorised access, modification, or disclosure.

5. Purpose of Collection (APP 1.4(c))

We collect personal information primarily to provide professional real estate and property management services, including the sale, leasing, and management of commercial, industrial and retail properties.

Personal information may also be used for secondary purposes that are directly related to our primary activities and where you would reasonably expect such use or disclosure.

We collect personal information for purposes including:

Providing services as an agent for buying, selling, leasing, and managing properties
Communicating with clients regarding listings, inspections, and transactions
Processing tenancy, leasing, and employment applications
Managing inspections, maintenance, compliance, and property operations
Verifying identity, beneficial ownership, authority to act, sanctions screening, politically exposed person (PEP) screening, anti-money laundering and counter terrorism financing compliance, fraud prevention and risk management.
Meeting legal, regulatory, and professional obligations
Operating, administering, and improving our business
Conducting marketing and promotional activities where permitted by law
Monitoring transactions, activities and client relationships for anti-money laundering and counter terrorism financing compliance and risk management purposes.

You are not required to provide personal information. However, if certain information is not provided, we may be unable to deliver some services, such as arranging inspections, processing tenancy applications, or meeting identification requirements.

Where reasonable and practicable, we will explain why we are collecting personal information and how it will be used.

Where lawful and practicable, you may deal with us anonymously or using a pseudonym, however, this is often not practical for property transactions, compliance, or identity verification purposes.

This Privacy Policy, together with any specific collection notices, forms, or statements provided at the time of collection, constitutes our collection notice for the purposes of Australian Privacy Principle 5 (APP 5).

6. Kinds of Personal Information Collected and Held (APP 1.4(a))

We may collect and hold personal information including:

Name, address, email address, and telephone number
Occupation and employer details
Identification documents such as driver licence or passport
Next of kin or emergency contact details
Financial information, including income, bank account details, and rental payment history
Rental and employment references
Property details owned, leased, or sought
Credit related information where authorised and regulated under Part IIIA of the Privacy Act
Employment history and application information
CCTV footage and visitor log records at our premises
Website usage data including cookies, IP address, and analytics information
Information provided by job applicants, contractors, and service providers
Verification information obtained for compliance, due diligence, risk management and legal obligations
Source of funds, source of wealth and related financial information where required for risk assessment, customer due diligence or compliance purposes.

Where we deal with corporations, trusts, or other entities, we may also collect and hold information to identify and verify those entities and their officers, including:

Company name, ACN or ABN and registered office address
ASIC company searches and extracts
Names and contact details of directors, secretaries, shareholders and beneficial owners
Details of trustees, partners or authorised representatives
Ownership and authority verification information, including title searches, ASIC searches and extracts, trust documentation, trustee information, power of attorney documentation, executor documentation and other information used to verify authority to appoint M5 or transact in relation to property.
Source of funds, source of wealth and related financial information relating to corporations, trusts, beneficial owners or transaction counterparties where required for customer due diligence or compliance purposes.

7. How Personal Information is Collected (APP 1.4(b))

We collect personal information by lawful and fair means, including:

Directly from you in person, by phone, email, SMS, or online forms
From third parties such as landlords, tenants, buyers, vendors, referees, solicitors, accountants, strata bodies, and onsite managers where lawful and where it is unreasonable or impracticable to collect directly from you
From publicly available sources, including property databases, tenancy databases, credit reporting databases and online sources where relevant and lawful
Through website analytics, cookies, pixels, and similar technologies
Through third party identity verification, anti-money laundering, beneficial ownership and compliance service providers engaged by M5 Industrial Property Services.

8. Use and Disclosure of Personal Information (APP 6)

Internal Use

We use personal information for purposes directly related to the operation of our business, including:

Assisting clients with property transactions and management
Responding to enquiries and feedback
Reporting to landlords and vendors
Processing tenancy and leasing applications
Performing administrative, compliance, and operational functions

We may contact you via telephone, email, or SMS as part of providing our services.

Disclosure to Third Parties

We may disclose personal information to:

Agents, representatives, landlords, vendors, buyers, and tenants
Employees, contractors, and service providers including IT providers, payment processors, mailing houses, couriers, and property management software providers
Identity verification providers, anti-money laundering compliance providers, beneficial ownership verification providers, sanctions screening providers and fraud prevention service providers
Professional advisers such as lawyers, accountants, auditors, and valuers
Utilities providers, insurers, banks, and financial institutions where relevant
Credit reporting bodies and tenancy databases where authorised
Government, regulatory, and law enforcement authorities where required or authorised by law
Debt recovery and creditor service providers where required

We may disclose personal information to third party providers for the purpose of identity verification, anti-money laundering compliance, beneficial ownership verification, sanctions screening, politically exposed person screening, fraud prevention and compliance with applicable laws and regulatory requirements.

Disclosure occurs only where:

You have consented
You would reasonably expect the disclosure
The disclosure is required or authorised by law
It is necessary to prevent a serious threat to life, health, or safety

M5 may disclose personal information to AUSTRAC and other government agencies where required by anti-money laundering, counter terrorism financing, sanctions or other applicable laws.

9. Identity Verification and AML Compliance

M5 Industrial Property Services may engage third party identity verification and compliance providers to verify the identity of individuals, directors, trustees, beneficial owners and authorised representatives.

These providers may collect identity documents, biometric information, screening information and related compliance information directly from individuals. Biometric information is only collected where reasonably necessary for identity verification purposes and where permitted by law.

Such information may include identity verification documents, biometric verification data, beneficial ownership information, politically exposed person (PEP) screening results, sanctions screening results and related compliance information.

M5 may receive verification reports, risk ratings, compliance outcomes, reference numbers and related information from these providers and may rely on those reports for regulatory compliance, fraud prevention and risk management purposes.

M5 may also undertake separate ownership and authority verification processes, including title searches, ASIC searches, trust documentation reviews, power of attorney verification and other checks necessary to confirm authority to appoint M5 or transact in relation to property.

M5 may undertake ongoing monitoring of transactions, client relationships and activities where required to comply with applicable anti money laundering and counter terrorism financing obligations.

M5 may apply a risk-based approach to customer due diligence and compliance activities, including enhanced due diligence where required by law or where higher risk circumstances are identified.

10. Overseas Disclosure (APP 8)

We may use third party service providers located overseas, including cloud-based software and data storage providers.

At present, personal information may be disclosed to or stored in the United States.

Where overseas disclosure occurs, we take reasonable steps to ensure overseas recipients handle personal information in a manner consistent with the Australian Privacy Principles, including through contractual and security safeguards, unless an exception under APP 8 applies.

By engaging with us, you acknowledge that overseas disclosures may occur as described in this Privacy Policy.

M5 may engage identity verification and anti-money laundering service providers. At the date of this Privacy Policy, M5's primary identity verification and AML compliance providers store information within Australia. If overseas disclosure occurs, M5 takes reasonable steps to ensure such providers handle personal information in accordance with applicable privacy obligations.

11. Direct Marketing (APP 7)

We may use personal information to provide marketing communications about our services where permitted by law.

You may opt out of receiving marketing communications at any time by:

Using the unsubscribe function in electronic communications
Contacting us using the details set out in this Privacy Policy

Opt out requests will be actioned promptly and at no cost.

We comply with the Privacy Act 1988 (Cth) and the Spam Act 2003 (Cth).

12. Automated Decision Making and Artificial Intelligence

M5 Industrial Property Services may use automated systems, including artificial intelligence tools, to assist with administrative and operational processes.

Automated tools may be used to:

Assist with preliminary tenancy application shortlisting
Support property management workflows and communications
Improve efficiency and consistency in administrative tasks

Automated tools assist but do not replace human judgement. Final decisions regarding tenancy approvals, leasing outcomes, and property management actions are reviewed and confirmed by qualified staff.

You may request information about automated decision making that affects you, to the extent reasonably practicable and permitted by law, and may request human review where appropriate.

13. Website Analytics and Cookies

We use analytics tools such as Google Analytics and Cloudflare to understand website usage, improve functionality, and evaluate marketing performance.

You may manage or disable cookies through your browser settings.
You may opt out of personalised Google advertising through Google Ads Settings or YourAdChoices.

14. Data Security and Retention (APP 11)

We take reasonable technical and organisational measures to protect personal information, including physical security, access controls, encryption, secure networks, and regular security reviews.

Personal information may be stored electronically or in hard copy form.

Retention periods vary depending on legal and regulatory requirements. In many cases, records are retained for a minimum of seven years unless a different retention period applies. Certain records collected for anti money laundering and counter terrorism financing compliance may be retained for periods required under applicable legislation, which may differ from general business record retention periods.

Certain identity verification, anti-money laundering and beneficial ownership records may be collected, stored and retained by third party compliance providers engaged by M5 Industrial Property Services. Where M5 relies on such providers, we take reasonable steps to ensure they maintain appropriate security, privacy and record retention standards and provide access to records where required by law or regulatory authorities.

When personal information is no longer required, we take reasonable steps to securely destroy or de-identify it.

15. Data Breaches

We maintain a Data Breach Response Plan and will assess, contain, and notify affected individuals and the OAIC where required under the Notifiable Data Breaches scheme.

16. Accuracy, Access, and Correction (APPs 10, 12, 13)

We take reasonable steps to ensure personal information is accurate, up to date, and complete.

You may request access to or correction of your personal information by contacting us in writing. We may require identity verification before processing requests.

We aim to respond within a reasonable timeframe. Administrative fees may apply for providing copies.

17. Enquiries and Complaints (APP 1.4(e))

Privacy enquiries and complaints may be made to our Privacy Officer.

We aim to acknowledge complaints within seven days and provide a substantive response within thirty days.

If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner.

18. Updates to This Privacy Policy

We may update this Privacy Policy from time to time. The current version will be published on our website.

19. Contact Details

Privacy Officer
M5 Industrial Property Services
Phone 02 9503 1200
Email [email protected]
Address Suite 4 Level 8 43 Bridge Street Hurstville NSW 2220

Office of the Australian Information Commissioner
Phone 1300 363 992
Website www.oaic.gov.au