PRIVACY POLICY

BANQ Group
Effective Date: 1 September 2026

1. Purpose

BANQ Group is committed to protecting personal information and handling it responsibly, securely and transparently.

This Privacy Policy explains how we collect, hold, use, disclose and protect personal information in connection with our websites, businesses, projects, developments, construction activities, refurbishment activities, enquiries and other operations.

This Privacy Policy is intended to operate in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) to the extent they apply to the relevant BANQ Entity.

2. BANQ Group

For the purposes of this Privacy Policy, “BANQ”, “BANQ Group”, “we”, “our” or “us” means BANQ Group Pty Ltd and entities within the BANQ group from time to time, including:

  • BANQ Projects Pty Ltd;

  • BANQ Constructions Pty Ltd;

  • subsidiaries and related bodies corporate of BANQ Group Pty Ltd;

  • controlled entities and business divisions operating under the BANQ brand; and

  • any other affiliated entity that expressly adopts this Privacy Policy,

each a BANQ Entity.

Where you deal with a particular BANQ Entity, that entity will generally be responsible for personal information collected in connection with that dealing.

Information may be shared between BANQ Entities where reasonably necessary for legitimate group operations, project delivery, administration, compliance or another purpose permitted by law.

Independent contractors, consultants, joint venture partners and other third parties do not become BANQ Entities merely because they have a commercial relationship with BANQ.

3. Who This Policy Applies To

This Privacy Policy may apply to personal information relating to:

  • website visitors;

  • prospective and existing clients;

  • property owners;

  • purchasers and prospective purchasers;

  • development partners;

  • investment and joint venture parties;

  • consultants and professional advisers;

  • builders, subcontractors, trades and suppliers;

  • agents and representatives;

  • investors and prospective investors;

  • job applicants and prospective personnel;

  • people attending BANQ offices, sites or projects; and

  • other individuals with whom BANQ interacts.

Employee records may also be subject to separate internal policies, contractual arrangements and applicable employment laws.

4. Personal Information We May Collect

The personal information we collect will depend on the nature of your dealings with BANQ.

It may include:

Identity and Contact Information

  • name;

  • address;

  • email address;

  • telephone number;

  • date of birth where reasonably required; and

  • other contact or identification information.

Property and Project Information

  • property addresses;

  • ownership information;

  • information about land or property;

  • development requirements;

  • project briefs;

  • building requirements;

  • architectural plans;

  • specifications;

  • selections;

  • budgets;

  • project preferences; and

  • information relevant to assessing, designing or delivering a project.

Commercial Information

  • enquiries;

  • correspondence;

  • proposals;

  • quotations;

  • contracts;

  • transaction information;

  • invoices;

  • payment records;

  • project records; and

  • information relating to goods or services requested from or provided by BANQ.

Financial Information

Where reasonably required, we may collect:

  • bank account details;

  • payment information;

  • financial capacity information;

  • funding information; and

  • other financial information relevant to a transaction, project, due diligence process, investment or commercial arrangement.

Where payments are processed by a third-party payment provider, BANQ may not directly receive or store complete payment-card information.

Business and Professional Information

We may collect:

  • company details;

  • ABNs;

  • licences;

  • registrations;

  • qualifications;

  • insurance details;

  • employment information; and

  • information regarding your relationship with another organisation.

Construction and Compliance Information

We may collect information relating to:

  • project access;

  • site inductions;

  • licences;

  • insurance;

  • workplace health and safety;

  • incidents;

  • defects;

  • warranties;

  • regulatory requirements;

  • contractor management; and

  • project administration.

Recruitment Information

This may include:

  • CVs;

  • qualifications;

  • employment history;

  • references;

  • professional experience; and

  • other information supplied in connection with employment or contracting opportunities.

Website and Technical Information

When you interact with our website or digital services we may collect:

  • IP address;

  • device type;

  • browser type;

  • operating system;

  • pages viewed;

  • referring websites;

  • website interactions;

  • approximate location derived from technical information;

  • cookies;

  • analytics information; and

  • similar technical data.

Communications

We may retain:

  • emails;

  • telephone enquiry records;

  • website enquiries;

  • messages;

  • correspondence; and

  • other communications with BANQ.

We may also collect other information you voluntarily provide.

5. Sensitive Information

BANQ does not generally seek sensitive information through its public website.

In limited circumstances, our operations may require sensitive information, including health or injury information associated with workplace health and safety, site incidents, insurance, accessibility requirements or legal obligations.

Sensitive information will only be collected where permitted by law.

6. How We Collect Personal Information

We may collect personal information directly from you when you:

  • visit or use a BANQ website;

  • submit an enquiry;

  • complete a contact form;

  • contact us by telephone, email or other means;

  • request information;

  • request a quotation or proposal;

  • enter into an agreement with us;

  • participate in a development, construction, refurbishment or property project;

  • engage with us as a supplier, subcontractor, consultant or adviser;

  • discuss an investment, acquisition or joint venture;

  • attend a BANQ office or site;

  • apply for employment or contracting opportunities; or

  • otherwise interact with BANQ.

Where permitted by law, we may also collect information from:

  • publicly available sources;

  • government and regulatory databases;

  • company and property searches;

  • referral partners;

  • real estate agents;

  • architects;

  • engineers;

  • planners;

  • builders;

  • contractors;

  • consultants;

  • suppliers;

  • professional advisers;

  • insurers;

  • financiers;

  • recruitment providers; and

  • other people or organisations involved in a transaction or project.

If you provide personal information about another individual, you warrant that you are authorised to provide that information where such authority is required.

7. Why We Collect, Hold and Use Information

BANQ may collect, hold and use personal information for purposes including:

  • responding to enquiries;

  • communicating with clients and prospective clients;

  • assessing projects and opportunities;

  • undertaking feasibility assessments;

  • preparing concepts, estimates, proposals and quotations;

  • designing projects;

  • developing property;

  • delivering construction and refurbishment projects;

  • administering contracts;

  • managing client relationships;

  • procuring goods and services;

  • coordinating builders, subcontractors, trades and consultants;

  • processing payments and accounts;

  • managing defects and warranties;

  • undertaking due diligence;

  • assessing investments, acquisitions and joint ventures;

  • managing property and development enquiries;

  • satisfying workplace health and safety requirements;

  • managing insurance and risk;

  • recruitment;

  • administering BANQ websites and information systems;

  • maintaining cybersecurity;

  • detecting or preventing fraud or unlawful activity;

  • analysing and improving our services;

  • internal management and business planning;

  • resolving disputes;

  • managing legal claims;

  • meeting legal, taxation, accounting, licensing, planning, construction and regulatory obligations; and

  • otherwise carrying on BANQ's legitimate business activities.

We will not use personal information for a materially unrelated purpose unless permitted by law.

8. Sharing Information Within BANQ Group

BANQ operates through a group structure.

Personal information collected by one BANQ Entity may be provided to another BANQ Entity where reasonably necessary for:

  • responding to an enquiry;

  • project assessment;

  • design;

  • development;

  • construction;

  • refurbishment;

  • procurement;

  • project administration;

  • accounting;

  • legal or regulatory compliance;

  • risk management;

  • management and administration of BANQ Group; or

  • another related purpose permitted by law.

For example, information provided to BANQ Developments may need to be provided to BANQ Constructions, BANQ Projects or another entity involved in delivering the relevant project.

Access will be limited so far as reasonably practicable to information necessary for the relevant purpose.

9. Disclosure to Third Parties

Where reasonably required, BANQ may disclose personal information to:

  • architects;

  • designers;

  • engineers;

  • planners;

  • surveyors;

  • consultants;

  • builders;

  • subcontractors;

  • trades;

  • suppliers;

  • project managers;

  • superintendents;

  • building certifiers;

  • quantity surveyors;

  • real estate agents;

  • valuers;

  • lawyers;

  • accountants;

  • auditors;

  • insurers;

  • insurance brokers;

  • banks;

  • financiers;

  • payment providers;

  • technology providers;

  • website providers;

  • hosting providers;

  • cloud providers;

  • CRM providers;

  • project management platforms;

  • electronic signature providers;

  • telecommunications providers;

  • marketing providers;

  • recruitment providers;

  • government departments;

  • councils;

  • statutory authorities;

  • regulators;

  • law enforcement agencies;

  • courts and tribunals;

  • prospective purchasers of, investors in or financiers of a BANQ business or project where appropriate; and

  • other persons authorised by you or permitted by law.

BANQ does not sell personal information to data brokers or third parties for their independent marketing purposes.

10. Overseas Processing and Disclosure

Some service providers used by BANQ may store, process or access information outside Australia.

This may occur through:

  • cloud infrastructure;

  • software providers;

  • technology support;

  • communications platforms;

  • marketing platforms;

  • professional service providers; or

  • other outsourced services.

Where Australian privacy law applies to an overseas disclosure, BANQ will take reasonable steps required by law.

The countries involved may change depending upon the technology and service providers used by BANQ.

Where practicable and required by law, BANQ will identify relevant overseas locations in this Privacy Policy or an applicable privacy collection notice.

11. Cookies, Analytics and Similar Technologies

BANQ websites may use cookies, analytics tools, pixels and similar technologies.

These may be used to:

  • operate the website;

  • maintain security;

  • remember preferences;

  • analyse website traffic;

  • measure website performance;

  • improve user experience;

  • understand how visitors reach and interact with BANQ;

  • measure advertising performance; and

  • improve marketing.

Information collected may include IP addresses, device identifiers, browser information, page views and user interactions.

You can generally restrict or disable cookies through your browser or available website cookie settings.

Some website functions may not operate correctly if certain cookies are disabled.

Third-party services may process information in accordance with their own privacy policies.

12. Direct Marketing

Where permitted by law, BANQ may communicate with you regarding relevant:

  • developments;

  • projects;

  • construction services;

  • refurbishment services;

  • property opportunities;

  • company news;

  • events; and

  • other BANQ services or opportunities.

Electronic marketing communications will be managed in accordance with applicable law.

Where express consent is requested, marketing consent will be obtained separately from the provision of information reasonably required to respond to an enquiry.

Marketing communications will include an appropriate unsubscribe mechanism.

You may opt out at any time.

Opting out of marketing does not prevent BANQ from sending communications reasonably necessary to administer an existing enquiry, contract, transaction or project.

13. Security

BANQ takes reasonable steps to protect personal information against:

  • misuse;

  • interference;

  • loss;

  • unauthorised access;

  • modification;

  • disclosure; and

  • cyber threats.

Depending on the circumstances, measures may include:

  • secure digital systems;

  • access controls;

  • authentication measures;

  • permissions and role-based access;

  • secure cloud services;

  • cybersecurity controls;

  • staff and contractor access restrictions;

  • appropriate contractual protections with service providers;

  • system monitoring;

  • secure document management; and

  • physical security measures.

No website, computer system, communications network, cloud service or electronic transmission can be guaranteed to be completely secure.

Accordingly, while BANQ takes reasonable precautions, we cannot guarantee that unauthorised access, cyberattack, system compromise or other security incidents will never occur.

Nothing in this Privacy Policy excludes any obligation or liability that cannot lawfully be excluded.

14. Data Breaches

BANQ maintains processes for managing actual and suspected data breaches.

Where an incident occurs or is suspected, BANQ may:

  • take steps to contain the incident;

  • investigate the circumstances;

  • assess the information affected;

  • assess potential harm;

  • engage cybersecurity, legal or forensic advisers;

  • take remedial action;

  • notify insurers;

  • cooperate with service providers or authorities; and

  • make notifications required by law.

Where the Notifiable Data Breaches scheme applies and an eligible data breach occurs, BANQ will comply with applicable notification obligations.

15. Third-Party Security Incidents

BANQ may rely upon third-party technology, communications, professional and cloud service providers.

A security incident involving a third-party provider is not necessarily within BANQ's direct control.

BANQ will take reasonable steps appropriate to the circumstances in selecting, contracting with and managing providers that handle personal information.

Nothing in this Privacy Policy makes BANQ liable for an independent third party's conduct to an extent greater than that imposed by applicable law.

16. Retention

BANQ retains personal information for as long as reasonably necessary for a legitimate business or legal purpose.

Retention periods may be affected by:

  • construction and building records;

  • contractual requirements;

  • project documentation;

  • defects;

  • warranties;

  • taxation;

  • accounting;

  • insurance;

  • licensing;

  • workplace health and safety;

  • regulatory requirements;

  • disputes;

  • litigation; and

  • other legal requirements.

Where information is no longer reasonably required and there is no lawful reason to retain it, BANQ will take reasonable steps to securely destroy or de-identify it.

17. Access and Correction

You may request access to personal information BANQ holds about you.

You may also request correction if information is:

  • inaccurate;

  • incomplete;

  • out of date;

  • irrelevant; or

  • misleading.

BANQ may require verification of identity before providing access or making changes.

In some circumstances, access may lawfully be refused.

Where required, we will explain a refusal.

18. Anonymity and Pseudonyms

Where lawful and practicable, individuals may deal with BANQ anonymously or using a pseudonym.

This will generally not be practicable where BANQ needs to establish identity to:

  • enter into a contract;

  • assess or deliver a project;

  • verify property ownership;

  • administer a transaction;

  • comply with legal or regulatory requirements; or

  • provide particular services.

19. Artificial Intelligence and Automated Systems

BANQ may use artificial intelligence, software and automated technologies to assist with:

  • administrative work;

  • document processing;

  • communications;

  • analysis;

  • project administration;

  • research; and

  • other business functions.

BANQ remains responsible for complying with applicable privacy obligations in relation to personal information used through these systems.

Where applicable privacy legislation requires BANQ to provide additional information regarding computer programs used to make or substantially assist decisions that could significantly affect an individual's rights or interests, BANQ will provide the information required by law.

20. Third-Party Websites

BANQ websites may contain links to third-party websites and platforms.

BANQ does not control and is not responsible for the privacy, security, availability or content of those third-party services.

Users should review the privacy policies and terms applying to third-party services.

21. Privacy Complaints

If you believe BANQ has not handled your personal information appropriately, please contact:

Privacy Officer
BANQ Group

using the contact details published on the BANQ Group website.

Please provide enough information to allow us to understand and investigate the issue.

BANQ will investigate complaints and respond within a reasonable period.

Where applicable, you may also have the right to complain to the Office of the Australian Information Commissioner.

22. Changes to This Privacy Policy

BANQ may update this Privacy Policy from time to time.

Changes may reflect:

  • changes to BANQ Group;

  • new businesses or services;

  • changes to technology;

  • changes to information-handling practices;

  • changes to applicable legislation; or

  • changes to regulatory guidance.

The current version will be published on the BANQ website and will show the effective or last-updated date.

23. Contact

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

Privacy Officer
BANQ Group

using the contact details published on our website.

Effective Date: 1 September 2026