Last updated January 14, 2023

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Privacy Policy

PRIVACY NOTICE

Last updated January 14, 2023

This privacy notice for Pathway Property Partners ('Company', 'we', 'us', or 'our'),describes how and why we might collect, store, use, and/or share ( 'process') your information when you use our services ('Services'), such as when you:

Visit our website at https://www.pathwayprop.com.au,or any website of ours that links to this privacy notice

Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at team@pathwayprop.com.au


SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but youcan find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find thesection you are looking for. You can also click here to go directly toour table of contents.

What personal information do we process? When you visit, use, or navigate ourServices, we may process personal information depending on how you interact with Pathway Property Partners and the Services, the choices you make, and theproducts and features you use. Click here to learn more.

Do we process any sensitive personal information? We do not process sensitive personal information.

Do we receive any information from third parties? We may receive information from public databases, marketing partners, social media platforms, and other outside sources. Click here to learn more.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes withyour consent. We process your information only when we have a valid lega lreason to do so. Click here to learn more.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties. Click here to learn more.

How do we keep your information safe? We have organisational and technical processes and procedures in place to protect your personalinformation. However, no electronic transmission over the internet or informationstorage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third partieswill not be able to defeat our security and improperly collect, access, steal,or modify your information. Click here to learn more.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Click here to learn more.

How do you exercise your rights? The easiest way to exercise your rights is by filling out our data subject request form available here, or by contacting us.

We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what Pathway Property Partners does with any information we collect? Click here to review the notice in full.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONALINFORMATION?

4. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

6. HOW LONG DO WE KEEP YOUR INFORMATION?

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

8. DO WE COLLECT INFORMATION FROM MINORS?

9. WHAT ARE YOUR PRIVACY RIGHTS?

10. CONTROLS FOR DO-NOT-TRACK FEATURES

11. DO WE MAKE UPDATES TO THIS NOTICE?

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WECOLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personalinformation you disclose to us

In Short: We collect personalinformation that you provide to us.

We collect personal information that youvoluntarily provide to us when you express an interest in obtaining informationabout us or our products and Services, when you participate in activities onthe Services, or otherwise when you contact us.

PersonalInformation Provided by You. The personalinformation that we collect depends on the context of your interactions with usand the Services, the choices you make, and the products and features you use.The personal information we collect may include the following:

names

phone numbers

email addresses

SensitiveInformation. We do not process sensitiveinformation.

All personal information that you provideto us must be true, complete, and accurate, and you must notify us of anychanges to such personal information.

Informationcollected from other sources

In Short: We may collect limited datafrom public databases, marketing partners, and other outside sources.

In order to enhance our ability to providerelevant marketing, offers, and services to you and update our records, we mayobtain information about you from other sources, such as public databases,joint marketing partners, affiliate programs, data providers, and from otherthird parties. This information includes mailing addresses, job titles, emailaddresses, phone numbers, intent data (or user behaviour data), InternetProtocol (IP) addresses, social media profiles, social media URLs, and customprofiles, for purposes of targeted advertising and event promotion.

2. HOW DO WE PROCESS YOURINFORMATION?

In Short: We process your informationto provide, improve, and administer our Services, communicate with you, forsecurity and fraud prevention, and to comply with law. We may also process yourinformation for other purposes with your consent.

We process your personal information for a variety of reasons,depending on how you interact with our Services, including:

To deliver and facilitate delivery of servicesto the user. We may process your information to provide you with therequested service.

Torespond to user inquiries/offer support to users. Wemay process your information to respond to your inquiries and solve anypotential issues

you might have with the requested service.

Tosend administrative information to you. We mayprocess your information to send you details about our products and services,changes to our

terms and policies, and other similarinformation.

Tofulfil and manage your orders. We may process yourinformation to fulfil and manage your orders, payments, returns, and exchangesmade

through the Services.

Toenable user-to-user communications. We may processyour information if you choose to use any of our offerings that allow forcommunication

with another user.

Todeliver targeted advertising to you. We may processyour information to develop and display personalised content and advertisingtailored to

your interests, location, and more.

To determine the effectiveness of our marketing and promotionalcampaigns. We may process your information tobetter understand how to

provide marketing and promotionalcampaigns that are most relevant to you.

Tocomply with our legal obligations. We may processyour information to comply with our legal obligations, respond to legalrequests, and exercise, establish, or defend our legal rights.

3. WHEN AND WITH WHOM DO WE SHAREYOUR PERSONAL INFORMATION?

In Short: We may share informationin specific situations described in this section and/or with the followingcategories of third parties.

Vendors,Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers,contractors, or agents ('third parties')who perform services for us or on our behalf and require access to suchinformation to do that work. We have contracts in place with our third parties,which are designed to help safeguard your personal information. This means thatthey cannot do anything with your personal information unless we haveinstructed them to do it. They will also not share your personal informationwith any organisation apart from us. They also commit to protect the data theyhold on our behalf and to retain it for the period we instruct. The categoriesof third parties we may share personal information with are as follows:

Ad Networks

Finance & Accounting Tools

Payment Processors

Retargeting Platforms

Sales & Marketing Tools

Social Networks

We also may need to share your personalinformation in the following situations:

BusinessTransfers. We may share or transfer yourinformation in connection with, or during negotiations of, any merger, sale ofcompany assets,

financing, or acquisition of all or aportion of our business to another company.

Business Partners. We may share yourinformation with our business partners to offer you certain products, services,or promotions.

OtherUsers. When you share personal information orotherwise interact with public areas of the Services, such personal informationmay be viewed

by all users and may be publicly madeavailable outside the Services in perpetuity. Similarly, other users will beable to view descriptions of your

activity, communicate with you within ourServices, and view your profile.

4. WHAT IS OUR STANCE ONTHIRD-PARTY WEBSITES?

In Short: We are not responsible forthe safety of any information that you share with third parties that we maylink to or who advertise on our Services, but are not affiliated with, ourServices.

The Services may link to third-partywebsites, online services, or mobile applications and/or contain advertisementsfrom third parties that are not affiliated with us and which may link to otherwebsites, services, or applications. Accordingly, we do not make any guaranteeregarding any such third parties, and we will not be liable for any loss ordamage caused by the use of such third-party websites, services, orapplications. The inclusion of a link towards a third-party website, service,or application does not imply an endorsement by us. We cannot guarantee thesafety and privacy of data you provide to any third parties. Any data collectedby third parties is not covered by this privacy notice. We are not responsiblefor the content or privacy and security practices and policies of any thirdparties, including other websites, services, or applications that may be linkedto or from the Services. You should review the policies of such third partiesand contact them directly to respond to your questions.

5. DO WE USE COOKIES AND OTHERTRACKING TECHNOLOGIES?

In Short: We may use cookies andother tracking technologies to collect and store your information.

We may use cookies and similar trackingtechnologies (like web beacons and pixels) to access or store information.Specific information about how we use such technologies and how you can refusecertain cookies is set out in our Cookie Notice.

6. HOW LONG DO WE KEEP YOURINFORMATION?

In Short: We keep your informationfor as long as necessary to fulfil the purposes outlined in this privacy noticeunless otherwise required by law.

We will only keep your personalinformation for as long as it is necessary for the purposes set out in thisprivacy notice, unless a longer retention period is required or permitted bylaw (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimatebusiness need to process your personal information, we will either delete oranonymise such information, or, if this is not possible (for example, becauseyour personal information has been stored in backup archives), then we willsecurely store your personal information and isolate it from any furtherprocessing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATIONSAFE?

In Short: We aim to protect yourpersonal information through a system of organisational and technical securitymeasures.

We have implemented appropriate andreasonable technical and organisational security measures designed to protectthe security of any personal information we process. However, despite oursafeguards and efforts to secure your information, no electronic transmissionover the Internet or information storage technology can be guaranteed to be100% secure, so we cannot promise or guarantee that hackers, cybercriminals, orother unauthorised third parties will not be able to defeat our security andimproperly collect, access, steal, or modify your information. Although we willdo our best to protect your personal information, transmission of personalinformation to and from our Services is at your own risk. You should onlyaccess the Services within a secure environment.

8. DO WE COLLECT INFORMATION FROMMINORS?

In Short: We do not knowinglycollect data from or market to children under 18 years of age.

We do not knowingly solicit data from ormarket to children under 18 years of age. By using the Services, you representthat you are at least 18 or that you are the parent or guardian of such a minorand consent to such minor dependent€™s use of the Services. If we learn thatpersonal information from users less than 18 years of age has been collected,we will deactivate the account and take reasonable measures to promptly deletesuch data from our records. If you become aware of any data we may havecollected from children under age 18, please contact us at __________.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short:  You may review, change, or terminate youraccount at any time.

Ifyou are located in the EEA or UK and you believe we are unlawfully processingyour personal information, you also have the right to complain to your localdata protection supervisory authority. You can find their contact details here:https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

Ifyou are located in Switzerland, the contact details for the data protectionauthorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Withdrawing your consent: If we are relying on your consent to process your personalinformation, which may be express and/or implied consent depending on theapplicable law, you have the right to withdraw your consent at any time. Youcan withdraw your consent at any time by contacting us by using the contactdetails provided in the section 'HOWCAN YOU CONTACT US ABOUT THIS NOTICE?' below.

However, please note that this will notaffect the lawfulness of the processing before its withdrawal nor, whenapplicable law allows, will it affect the processing of your personalinformation conducted in reliance on lawful processing grounds other thanconsent.

Opting out of marketingand promotional communications: You can unsubscribefrom our marketing and promotional communications at any time by clicking onthe unsubscribe link in the emails that we send, or by contacting us using thedetails provided in the section 'HOWCAN YOU CONTACT US ABOUT THIS NOTICE?' below. You willthen be removed from the marketing lists. However, we may still communicatewith you €” for example, to send you service-related messages that arenecessary for the administration and use of your account, to respond to servicerequests, or for other non-marketing purposes.

Cookies and similartechnologies: Most Web browsers are set to acceptcookies by default. If you prefer, you can usually choose to set your browserto remove cookies and to reject cookies. If you choose to remove cookies orreject cookies, this could affect certain features or services of our Services.To opt out of interest-based advertising by advertisers on our Services visit http://www.aboutads.info/choices/.

10. CONTROLS FOR DO-NOT-TRACKFEATURES

Most web browsers and some mobileoperating systems and mobile applications include a Do-Not-Track ('DNT')feature or setting you can activate to signal your privacy preference not tohave data about your online browsing activities monitored and collected. Atthis stage no uniform technology standard for recognising and implementing DNTsignals has been finalised. As such, we do not currently respond to DNT browsersignals or any other mechanism that automatically communicates your choice notto be tracked online. If a standard for online tracking is adopted that we mustfollow in the future, we will inform you about that practice in a revisedversion of this privacy notice.

11. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update thisnotice as necessary to stay compliant with relevant laws.

We may update this privacy notice fromtime to time. The updated version will be indicated by an updated 'Revised'date and the updated version will be effective as soon as it is accessible. Ifwe make material changes to this privacy notice, we may notify you either byprominently posting a notice of such changes or by directly sending you anotification. We encourage you to review this privacy notice frequently to beinformed of how we are protecting your information.

12. HOW CAN YOU CONTACT US ABOUTTHIS NOTICE?

If you have questions or comments aboutthis notice, you may email us at team@pathwayprop.com.au

13. HOW CAN YOU REVIEW, UPDATE, ORDELETE THE DATA WE COLLECT FROM YOU?

Basedon the applicable laws of your country, you may have the right to requestaccess to the personal information we collect from you, change thatinformation, or delete it. To request to review, update, or delete yourpersonal information, please submit a request form by clicking here.