Privacy Policy

1. Our commitment to your privacy

Liberty Solutions Australia Pty Ltd (“Liberty Solutions”, “we”, “us” or “our”) respects your privacy and is committed to protecting the personal information entrusted to us.

This Privacy Policy explains how we collect, hold, use, disclose, protect and manage personal information in connection with our business, including information collected through our website, consultations, communications, referral services, real estate and property-related services, and relationships with our professional referral network.

We manage personal information in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs) and other applicable Australian laws.

Where applicable to the services being provided, we must also comply with obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act), associated Rules and AUSTRAC requirements.

For the purposes of this Policy, AML/CTF refers to anti-money laundering and counter-terrorism financing requirements. Relevant obligations may also require us or another regulated service provider to identify and manage proliferation-financing and other financial-crime risks.

2. The personal information we may collect

The type of personal information we collect depends upon your relationship with Liberty Solutions and the services you are considering or receiving.

Information may include:

• your name;
• residential, postal and email addresses;
• telephone numbers;
• date of birth;
• occupation and employment information;
• family or household information relevant to the services being discussed;
• information regarding your income, expenses, assets and liabilities;
• property ownership and proposed property transactions;
• loan, mortgage and credit-related information;
• superannuation and retirement information;
• taxation and accounting-related information;
• investment-related information;
• information contained in correspondence, emails, telephone calls, meetings and enquiries;
• information provided through website forms, questionnaires and calculators;
• records concerning services you have requested or professionals to whom you have been referred;
• feedback, complaints, testimonials and reviews; and
• other information reasonably necessary to provide our services, facilitate professional referrals, meet our legal obligations or administer our relationship with you.

We aim to collect only information that is reasonably necessary for our functions, activities and legal obligations.

3. Identification and AML/CTF information

Where Liberty Solutions provides a service that is a designated service under the AML/CTF Act, or where a professional to whom we refer you is required to comply with AML/CTF obligations, additional identification and customer due-diligence information may be required.

From 1 July 2026, the Australian AML/CTF regime was expanded to include certain designated services commonly provided by real estate professionals, including buyer's and seller's agents, and certain services provided by accountants, lawyers, conveyancers and other professional service providers.

Accordingly, if you decide to proceed with certain services or transactions, you may be required to complete Know Your Customer (KYC) and Customer Due Diligence (CDD) checks.

Depending upon the circumstances and the applicable legal requirements, information collected for these purposes may include:

• your full legal name;
• date of birth;
• residential address;
• nationality or country of residence where relevant;
• driver's licence, passport or other government-issued identification details;
• information required to verify your identity;
• details of persons acting on your behalf and their authority to act;
• details of persons on whose behalf you may be acting;
• details of companies, trusts, partnerships or other entities involved in a transaction;
• information identifying directors, trustees, shareholders, beneficiaries and beneficial owners where applicable;
• the nature and purpose of the proposed transaction or business relationship;
• information concerning the source of funds being used for a transaction;
• information concerning source of wealth where required or appropriate;
• information required to determine whether a person is a politically exposed person (PEP);
• information required for sanctions screening;
• information necessary to assess money-laundering, terrorism-financing, proliferation-financing or other financial-crime risks;
• records of the identification and verification procedures undertaken; and
• the outcome of those verification and risk-assessment procedures.

The extent of information required will depend on the service being provided, the nature of the transaction and the level of financial-crime risk presented.

4. When AML/CTF checks are required

Where Liberty Solutions itself is legally required to undertake customer due diligence, those checks will generally be completed before we begin providing the relevant designated service, unless the AML/CTF legislation expressly permits customer due diligence to be completed within a later prescribed timeframe.

For example, Liberty Solutions' activities as a buyer's agent in connection with the purchase or transfer of real estate may constitute designated services under the AML/CTF regime.

Our professional referral partners may also have their own independent AML/CTF obligations.

Depending upon the service you ultimately engage, this may include an appropriately licensed:

• mortgage or credit professional;
• financial adviser;
• accountant or tax professional;
• lawyer or conveyancer;
• real estate professional; or
• other regulated service provider.

A professional who is a reporting entity under the AML/CTF Act may be legally required to undertake their own customer due diligence before providing a designated service to you.

Accordingly, completion of an identity check for Liberty Solutions does not automatically mean that another professional will not need to conduct additional verification.

5. Customer due-diligence reliance arrangements

Australian AML/CTF legislation permits reporting entities, in certain circumstances, to rely upon customer identification and verification undertaken by another eligible reporting entity.

Where permitted by law and considered appropriate, Liberty Solutions may participate in a customer due-diligence reliance agreement or arrangement, or may rely upon customer due diligence on a case-by-case basis.

This may include appropriately structured arrangements between Liberty Solutions and members of our professional referral network.

The purpose of a lawful reliance arrangement may include:

• reducing unnecessary duplication of identification checks;
• making the client onboarding process more efficient;
• reducing the need for clients to repeatedly provide the same identification information; and
• assisting each reporting entity to satisfy its AML/CTF obligations.

Any such reliance or information sharing will only occur where permitted under applicable AML/CTF and privacy laws.

Each reporting entity remains responsible for determining whether reliance is legally permissible and appropriate to the risks associated with the service it provides.

We cannot guarantee that a referred professional will rely upon an earlier check. A professional may determine that they must undertake additional or separate verification.

6. Electronic identity verification

We may use specialist third-party identity verification, KYC, AML/CTF, fraud-prevention or screening providers to assist us in verifying information.

Where an electronic identity-verification process is used, personal information may be checked against reliable and independent data sources.

Depending upon the service and applicable requirements, this may include verification of government-issued identification information and screening against sanctions, PEP or other compliance databases.

We will seek to limit the personal information collected and retained to information reasonably necessary for the verification and compliance purpose.

7. Copies of identification documents

Identity documents such as passports and driver's licences contain highly valuable personal information and are treated by us as particularly sensitive from a security perspective.

Where practicable, Liberty Solutions will seek to avoid retaining complete copies of identification documents for longer than reasonably necessary.

The AML/CTF legislation does not necessarily require reporting entities to retain full photocopies or scanned copies of identity documents merely for AML/CTF record-keeping purposes.

Where a copy of an identity document has been obtained, we will take reasonable steps to securely destroy or de-identify that copy once it is no longer reasonably required for:

• AML/CTF compliance;
• another lawful business purpose;
• another legal or regulatory obligation; or
• the establishment, exercise or defence of legal rights.

We may instead retain required verification records, including relevant identification details, the type of document examined, the verification undertaken and the outcome of that verification, for the period required by applicable law.

8. What happens if you do not provide required information

You are generally free to decide whether to provide personal information to us.

However, there are circumstances in which particular information is necessary for us or another regulated professional to comply with the law.

Where information is required for AML/CTF customer due diligence, identity verification, regulatory compliance, credit assessment or another mandatory purpose, failure to provide satisfactory information may mean that we or the relevant professional:

• cannot commence a designated service;
• cannot continue providing a designated service;
• cannot proceed with a transaction;
• cannot complete a professional engagement;
• cannot facilitate a particular referral or transaction; or
• may be required to suspend or terminate the relevant business relationship.

We may also request further information where information previously provided cannot be satisfactorily verified or where additional customer due diligence is required.

9. How we collect personal information

We may collect personal information:

• directly from you;
• through our website;
• through telephone calls, emails, SMS messages and correspondence;
• during meetings or video conferences;
• through questionnaires, applications and enquiry forms;
• from documents you provide;
• through electronic identity-verification services;
• from professionals involved in providing services to you;
• from referral partners;
• from your authorised representatives;
• from publicly available sources;
• from government, regulatory or commercial databases where permitted;
• through cookies, website analytics and similar technologies; and
• from other sources where you have authorised the collection or where collection is otherwise permitted by law.

Where practicable, we will collect personal information directly from you.

10. Information received from our referral network

Liberty Solutions has long-standing professional relationships with a network of appropriately licensed, registered and qualified professionals.

Depending upon your requirements, referrals may include professionals involved in:

• financial planning and financial advice;
• mortgage broking and credit assistance;
• taxation and accounting;
• real estate;
• conveyancing and legal services;
• property management; and
• other specialist professional services.

Information may be exchanged between Liberty Solutions and a referred professional where reasonably necessary to:

• arrange an appointment or introduction;
• communicate the nature of your enquiry;
• facilitate the service you have requested;
• administer an existing client relationship;
• progress an agreed transaction;
• satisfy legal or regulatory obligations;
• conduct permitted customer due diligence; or
• otherwise act with your consent or authority.

The professional organisation to whom you are referred is generally a separate business and may have its own Privacy Policy and independent legal obligations.

You should review the privacy and disclosure documents provided by that professional.

11. Why we collect, hold, use and disclose personal information

We may collect, hold, use or disclose personal information for purposes including:

• responding to enquiries;
• providing general information and general advice;
• arranging consultations;
• understanding the type of professional assistance you are seeking;
• providing Liberty Solutions services;
• facilitating referrals to licensed and qualified professionals;
• providing real estate or buyer's-agent services;
• progressing property transactions;
• facilitating financial planning, mortgage, accounting, taxation or other professional engagements;
• maintaining client records;
• administering contracts and service agreements;
• verifying identity;
• undertaking AML/CTF customer due diligence;
• conducting sanctions and PEP screening where required;
• preventing and detecting fraud or other unlawful activity;
• managing legal, regulatory and compliance obligations;
• managing complaints and disputes;
• maintaining and improving our services;
• business administration;
• quality assurance and staff training;
• website analytics and improvement;
• communicating information about services that may be relevant to you; and
• direct marketing where permitted by law.

We will not use or disclose personal information for an unrelated purpose unless we have your consent or the use or disclosure is otherwise permitted or required by law.

12. Disclosure to AUSTRAC and other authorities

Where Liberty Solutions is a reporting entity for a particular designated service, we may be required or authorised by law to disclose information to AUSTRAC.

Depending upon the circumstances, this may include information contained in:

• suspicious matter reports;
• threshold transaction reports where applicable;
• responses to statutory information requests;
• customer due-diligence information; and
• other reports or information required under AML/CTF legislation.

We may also be required or authorised to provide information to Commonwealth, State or Territory regulators, law-enforcement bodies, courts, tribunals, government agencies or other authorities.

In certain circumstances, AML/CTF legislation restricts what we are legally permitted to tell a customer about a suspicious matter, investigation or report.

Nothing in this Privacy Policy requires Liberty Solutions to disclose information where doing so would breach an AML/CTF secrecy, confidentiality or tipping-off obligation.

13. Disclosure to other third parties

We may disclose personal information, where appropriate, to:

• our employees and authorised personnel;
• contractors and service providers;
• professional referral partners;
• financial advisers;
• mortgage brokers and credit professionals;
• accountants and tax professionals;
• lawyers and conveyancers;
• real estate professionals;
• property managers;
• valuers, builders or other property-related professionals where relevant;
• identity-verification and AML/CTF service providers;
• IT and cybersecurity providers;
• CRM and data-storage providers;
• website hosting providers;
• communications providers;
• payment processors;
• auditors;
• insurers;
• professional advisers;
• government bodies, regulators and law-enforcement agencies;
• a purchaser or potential purchaser of all or part of our business, subject to appropriate confidentiality arrangements; and
• other persons where you have authorised us to do so or disclosure is permitted or required by law.

We do not sell your personal information to third parties.

14. Sensitive information

Sensitive information receives a higher level of protection under Australian privacy law.

We will only collect sensitive information where:

• it is reasonably necessary for our functions or activities and you have provided the required consent;
• collection is required or authorised by law; or
• another exception under the Privacy Act applies.

We do not seek to collect sensitive information unnecessarily.

If sensitive information is provided to us that we did not request, we will assess whether it is lawful and appropriate for us to retain it.

15. Government-related identifiers

We may collect government-related identifiers where reasonably necessary for an authorised identity-verification, AML/CTF, taxation or regulatory purpose.

Examples may include driver's licence or passport details.

We will not adopt a government-related identifier as our own identifier for you except where permitted by law.

We will use and disclose government-related identifiers only as permitted or required under applicable law.

16. Storage and security

Liberty Solutions recognises that financial, identity and AML/CTF information can be particularly attractive to criminals and may cause significant harm if compromised.

We take reasonable steps to protect personal information against:

• misuse;
• interference;
• loss;
• unauthorised access;
• unauthorised modification; and
• unauthorised disclosure.

Our safeguards may include appropriate combinations of:

• secure electronic systems;
• access controls;
• authentication measures;
• cybersecurity protections;
• secure cloud or data-storage arrangements;
• restricted staff access;
• staff confidentiality obligations;
• staff training;
• secure document handling;
• monitoring and security processes;
• third-party provider due diligence; and
• procedures for securely destroying or de-identifying information when it is no longer required.

No method of electronic storage or transmission can be guaranteed to be completely secure. However, we take the protection of client information seriously and continually assess our information-security practices.

17. Data breaches and cybersecurity incidents

Liberty Solutions maintains processes for responding to suspected or actual privacy and cybersecurity incidents.

Where a data breach occurs, we will take reasonable steps to:

• contain the incident;
• assess what information has been affected;
• assess the likelihood of harm;
• take appropriate remedial action;
• investigate the cause of the incident; and
• reduce the likelihood of recurrence.

Where the Notifiable Data Breaches Scheme applies and a breach is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner where required by law.

Other regulators, law-enforcement authorities, cybersecurity bodies or affected organisations may also be notified where appropriate or legally required.

18. Retention and destruction

We retain personal information only for as long as reasonably necessary for our business functions, legal obligations and regulatory requirements.

Some records must be retained for specified periods under Australian law, including certain AML/CTF, taxation, corporate, financial-services, credit, real-estate or other regulatory requirements.

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

Because identity documents present heightened privacy and identity-theft risks, we will give particular attention to minimising the unnecessary retention of complete copies of identification documents.

19. Overseas disclosure and cloud services

Some of the technology and service providers we use may store or process information using infrastructure located outside Australia.

This may include cloud hosting, communications, website analytics, customer-management, cybersecurity or other technology providers.

Where we are likely to disclose personal information to an overseas recipient, we will take reasonable steps required by Australian privacy law in relation to that disclosure.

Where practicable, our Privacy Officer can provide further information about the countries in which relevant overseas recipients or service providers are located.

We do not rely on a blanket waiver of Australian privacy protections merely because a service provider is located overseas.

20. Website, cookies and analytics

Our website may use cookies and similar technologies to:

• operate website functionality;
• remember preferences;
• understand how users interact with our website;
• improve website performance;
• measure website traffic;
• protect website forms against spam and misuse; and
• support marketing activities.

Our website may also use third-party services such as analytics platforms, mapping services, CAPTCHA or fraud-prevention technology and embedded video services.

These providers may collect information such as your IP address, device information, browser type and website usage information.

You may be able to manage cookies through your browser settings or the website's cookie-management tools.

Blocking certain cookies may affect website functionality.

21. Direct marketing

Where permitted by law, we may use your contact information to provide information concerning Liberty Solutions, educational material, newsletters, events or services that we reasonably believe may be relevant to you.

You may opt out of direct marketing at any time.

You can:

• use the unsubscribe function in an electronic communication; or
• contact us and request that we stop sending marketing communications.

We will action an opt-out request within a reasonable period.

Opting out of marketing does not prevent us from sending administrative, transactional, legal or service-related communications where necessary.

22. Anonymity and pseudonyms

Where practicable and lawful, you may interact with us anonymously or using a pseudonym for a preliminary or general enquiry.

However, anonymity will generally not be available where identification is reasonably necessary to provide a service or where we are required or authorised by law to establish your identity.

In particular, a person receiving a designated service subject to AML/CTF customer due diligence may be required to satisfactorily establish their identity.

23. Access to your personal information

You may request access to personal information Liberty Solutions holds about you.

To protect your privacy, we may need to verify your identity before providing access.

We will respond to access requests within a reasonable period.

There may be circumstances in which Australian privacy law allows or requires us to refuse access to some information.

If we refuse access, we will generally explain the reason for doing so and the available complaint mechanisms, unless the law prevents us from providing that explanation.

Nothing in this section requires us to provide access to information where disclosure would contravene AML/CTF tipping-off restrictions, legal professional privilege or another applicable law.

24. Correction of personal information

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

If you believe information we hold about you is inaccurate, incomplete, out of date, irrelevant or misleading, please contact us.

Where appropriate, we will take reasonable steps to correct the information.

25. Privacy complaints

If you believe Liberty Solutions has mishandled your personal information or breached its privacy obligations, please contact our Privacy Officer.

Please provide sufficient details to allow us to investigate your concern.

We will:

• acknowledge and assess your complaint;
• investigate it appropriately;
• communicate with you where further information is required; and
• provide you with our response within a reasonable period.

If you are dissatisfied with our response, you may be entitled to lodge a complaint with the Office of the Australian Information Commissioner (OAIC).

26. Third-party websites and professional providers

Our website may contain links to websites operated by other businesses.

Liberty Solutions is not responsible for the privacy practices of third-party websites.

Similarly, a financial adviser, mortgage broker, accountant, lawyer, conveyancer, real estate agent or other professional to whom we refer you may operate under their own Privacy Policy and regulatory framework.

Once that professional collects personal information directly from you, their own privacy obligations apply to their handling of that information.

27. Changes to this Privacy Policy

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

• changes to legislation;
• regulatory guidance;
• AML/CTF requirements;
• changes to our business;
• changes to our referral network;
• technology changes; or
• changes to how we collect and manage personal information.

The current version will be published at www.libertysolutions.com.au and will show the date on which it was last updated.

We intend to review this Privacy Policy regularly to ensure it remains relevant and current.

28. Contacting us

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

Privacy Officer Liberty Solutions Australia Pty Ltd ABN 72 645 162 670

Email: info@libertysolutions.com.au Website: www.libertysolutions.com.au

Important note regarding AML/CTF requirements

Anti-money laundering and counter-terrorism financing obligations are imposed by law on entities that provide particular designated services.

The fact that Liberty Solutions introduces a client to another professional does not, by itself, mean that every service supplied by that professional is subject to identical AML/CTF requirements.

Whether customer due diligence is required, what information must be collected and when those checks must occur will depend upon the service being provided, the reporting entity involved, the customer's circumstances and the applicable AML/CTF legislation and Rules.

Where an AML/CTF check is legally required, satisfactory completion of the required customer due diligence may be a condition of providing or continuing the relevant service.