RealZilla Pty Ltd ("RealZilla", "we", "us", "our") is committed to protecting your privacy in accordance with the Privacy Act 1988 (Cth) ("Privacy Act") and the Australian Privacy Principles ("APPs"). This Privacy Policy explains how we collect, use, disclose, and protect Personal Information.
Aboutthe Platform
RealZilla operates a cloud-based software platform that supports Australian real estate agencies to manage their documents, workflows, communications and transaction records. RealZilla is a software platform only. RealZilla does not perform anti-money laundering (AML), counter-terrorism financing (CTF), customer identification, verification of identity (VOI), sanctions screening, customer due diligence or risk assessment services in its own right, and RealZilla is not an AML reporting entity, AML/CTF service provider or AUSTRAC-enrolled entity.
Where the Platform supports AML/CTF compliance, it does so by integrating with all AML Service Providers that RealZilla integrates with. The agency selects the AML Service Provider. The chosen AML Service Provider performs the verification and is the entity responsible for that service, the accuracy of its outputs, and the handling of personal information in connection with that service.
1.What Information We Collect
1.1Personal Information
We may collect the following types of Personal Information:
- Identity information: name, date of birth, ABN, ACN, and government-issued identification details;
- Contact information: email address, telephone number, and business address;
- Account information: username, password (hashed), and account preferences;
- Financial information: billing details, payment method data (held by our payment processor), and transaction history;
- Usage data: Platform activity logs, feature usage, and device and browser information; and
- AML/KYC data routed through the Platform: where the agency uses an integrated AML Service Provider, identity verification information (including seller and buyer information) may pass through the Platform on its way to the AML Service Provider, which performs the verification as a separate entity under its own privacy policy and terms.
1.2Transactional Data
We collect Transactional Data relating to property transactions processed through the Platform. This data is anonymised and aggregated before any commercial use, in accordance with our agreement with your agency.
1.3How We Collect Information
We collect Personal Information directly from you when you register, use the Platform, contact us, or interact with Integration Partners through the Platform. We may also collect information from third parties (such as Integration Partners) to the extent permitted by law.
2.How We Use Your Information
We use Personal Information for the following purposes:
- to provide, maintain, and improve the Platform and its features;
- to process Subscription payments and Transactional Charges;
- to communicate with you about your account, invoices, and Platform updates;
- to comply with our own legal obligations as a software service provider;
- to facilitate the agency's use of an integrated AML Service Provider, including by routing seller and buyer data between the Platform and the chosen provider, where the agency has elected to use such an integration and the relevant consents have been obtained;
- to investigate and resolve disputes and support queries;
- to commercialise Transactional Data in anonymised and aggregated form (see Section 3.4 below); and
- to send service-related communications via SMSZilla, subject to applicable consent requirements.
RealZilla does not use Personal Information to perform AML, KYC, VOI, sanctions screening or customer due diligence services. Those services are performed by the AML Service Provider selected by the agency.
3.Disclosure of Personal Information
3.1Integration Partners
Personal Information may be disclosed to Integration Partners to the extent necessary to deliver the relevant Integration Partner Service. RealZilla operates as an open integration platform and integrates with multiple third-party providers, including AML Service Providers, title and company search providers, and ancillary service providers (current examples include Dye & Durham, Prime CC, Compare Connect, and Cotality, and the list of integrated AML Service Providers may change from time to time as new providers are onboarded).
Each Integration Partner has its own privacy policy, terms and data handling practices. Where the agency uses an integrated AML Service Provider, the AML Service Provider acts as a separate data controller for the verification it performs. Individuals seeking access, correction or other rights in respect of data processed by an AML Service Provider should contact the relevant provider directly in addition to (or instead of) contacting RealZilla.
3.2Service Providers
We may share Personal Information with trusted service providers (e.g. cloud hosting, payment processors, analytics) on a confidential basis and only to the extent necessary to provide the Platform.
3.3Legal Requirements
We may disclose Personal Information to regulatory authorities (including AUSTRAC, ASIC, and the OAIC) where required by law.
3.4Commercialisation — No Personal Information
We will not sell, license, or otherwise commercialise Personal Information. Only anonymised and aggregated Transactional Data may be commercialised in accordance with our agreement with your agency.
3.5Overseas Disclosure
We will not transfer Personal Information outside Australia without your consent or unless permitted by the Privacy Act. Where overseas disclosure is necessary (e.g. cloud infrastructure or an Integration Partner that processes data offshore), we take reasonable steps to ensure recipients handle information consistently with the APPs.
4.AML Service Providers — Limitation of Responsibility
This section is to be read together with the limitation of liability provisions of our agreement with your agency. To the maximum extent permitted by law:
- No AML service provided by RealZilla. RealZilla does not provide AML, KYC, VOI, sanctions screening or customer due diligence services. Those services are provided by AML Service Providers selected by the agency.
- No warranty as to AML Service Provider outputs. RealZilla makes no representation or warranty as to the accuracy, completeness, timeliness, currency, availability, suitability or regulatory compliance of any output, result, data, record, document or determination provided by any AML Service Provider.
- No responsibility for AML Service Provider acts or omissions. RealZilla is not responsible or liable for any act, omission, failure, error, delay, default, breach, misconduct, negligence or insolvency of any AML Service Provider, or for any handling of Personal Information by an AML Service Provider under its own privacy policy.
- No responsibility for integration failure. RealZilla is not responsible or liable for any loss or damage arising from any failure, malfunction, outage, interruption, or error in any integration, API connection or data exchange between the Platform and any AML Service Provider; any incorrect, incomplete, corrupted, delayed or non-delivered data; any change made by an AML Service Provider to its system, API, or scope of service; or any AML compliance failure attributable in whole or in part to an AML Service Provider.
- Agency responsibility. The agency is solely responsible for selecting an appropriate AML Service Provider, satisfying itself as to the provider's suitability and regulatory standing, performing its own AML/CTF obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and related rules, and verifying outputs delivered through the integration before relying on them.
- Third-party terms apply. Use of any AML Service Provider integration is subject to the AML Service Provider's own terms, privacy policy and pricing. The agency contracts directly with the AML Service Provider. RealZilla is not a party to that arrangement.
- Australian Consumer Law. Nothing in this section excludes, restricts or modifies any consumer guarantee, right or remedy under the Australian Consumer Law or any other law that cannot be excluded, restricted or modified by agreement.
5.Consent & Passing Information to AML Service Providers via SMSZilla
Where a real estate agency uses the RealZilla Platform in connection with AML/CTF compliance obligations, seller and buyer Personal Information may be routed through SMSZilla — RealZilla's integrated SMS communication gateway — to an AML Service Provider selected by the agency. Before any such disclosure occurs, the following consent requirements apply:
5.1Collection Notice
At the point of collecting Personal Information from a seller or buyer, the agency is required to provide a collection notice that identifies RealZilla and the relevant AML Service Provider as recipients of that information, and the purpose for which it will be used (i.e. AML/CTF verification).
5.2Express Consent via SMSZilla
RealZilla facilitates the collection of express consent from sellers and buyers via SMSZilla prior to their Personal Information being transmitted to an AML Service Provider. The consent prompt is delivered by SMS and requires an affirmative response before data is passed through the integration. Records of consent are stored against the relevant transaction record.
5.3Withdrawal of Consent
A seller or buyer may withdraw consent at any time by notifying the agency or RealZilla at hello@realzilla.au. Withdrawal of consent will prevent further transmission of that individual's Personal Information to the AML Service Provider, but will not affect any processing already completed by the AML Service Provider prior to withdrawal.
5.4Agency Obligations
The agency is responsible for ensuring that all required consents are obtained in accordance with the Privacy Act and any applicable AML/CTF obligations before initiating the verification workflow. RealZilla provides the technical mechanism for consent capture but does not verify the adequacy of any consent obtained by the agency outside of the SMSZilla consent flow.
6.Data Security
We implement industry-standard technical and organisational security measures, including encryption, access controls, and regular security assessments, to protect Personal Information from unauthorised access, loss, or disclosure. However, no internet transmission is completely secure and we cannot guarantee absolute security.
7.Data Retention
We retain Personal Information for as long as your account is active and for 7 years after termination, or as required by law (including the 7-year minimum retention period for AML records under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) where the agency stores such records on the Platform). Anonymised Transactional Data may be retained indefinitely for commercial and analytical purposes.
8.Access and Correction
You have the right to request access to the Personal Information we hold about you and to request correction of inaccurate or outdated information. Requests should be directed to hello@realzilla.au. We will respond within 30 days. We may charge a reasonable fee for access requests.
For Personal Information held by an AML Service Provider in connection with verification services, the individual should contact the relevant provider directly, as the provider acts as a separate data controller for that processing.
9.Notifiable Data Breaches
In the event of an eligible data breach under Part IIIC of the Privacy Act, we will notify affected individuals and the OAIC as required by law. Notifications will be made as soon as practicable after we become aware of the breach.
10.Complaints
If you have a complaint about how we handle your Personal Information, please contact hello@realzilla.au. We will investigate and respond 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) at www.oaic.gov.au.
11.Changes to this Privacy Policy
We may update this Privacy Policy at any time. Material changes will be notified via email or in-platform notification with at least 14 days' notice. Continued use of the Platform after the effective date constitutes acceptance of the updated policy.
Privacy enquiries
For any privacy-related question, request to access your data, or complaint, please contact our privacy team:
RealZilla Pty Ltd · ABN 93 627 593 600 · Registered Office: Victoria, Australia