PRIVACY POLICY

Business Classifieds Pty Ltd (ACN 130 005 426) ATF Business Classifieds Trust trading as Gold Coast Business Brokers Licensed Real Estate Agent under the Property Occupations Act 2014 (Qld)

Last updated: May 2026

1. Our Commitment to Privacy

Gold Coast Business Brokers is committed to protecting the privacy of all individuals who interact with us, including buyers, sellers, and website visitors. This Privacy Policy explains how we collect, use, store, disclose, and manage your personal information in accordance with:

• the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), including amendments introduced by the Privacy and Other Legislation Amendment Act 2024;
• the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (“AML/CTF Act”); and
• the Property Occupations Act 2014 (Qld) and the Agents Financial Administration Act 2014 (Qld).

By engaging our services or submitting information to us, you acknowledge that you have read and understood this Privacy Policy.

2. What Personal Information We Collect

We collect personal information that is necessary to provide our services as a licensed business broker. This may include:

From Buyers:

• Full legal name, date of birth, and residential address
• Contact details including email address and telephone number
• Photo identification documents (front and back of driver’s licence or passport)
• Identity verification selfie photographs
• Intended source of funds and source of wealth information
• Beneficial ownership information, including details of any third party on whose behalf you are acting
• Politically Exposed Person (PEP) status and sanctions screening information
• Investment range and business acquisition preferences
• Marketing preferences
• Bank account details for refund of deposit and settlement purposes

From Sellers:

• Full legal name, date of birth, and residential address
• Contact details including email address and telephone number
• Photo identification documents (front and back of driver’s licence or passport)
• Identity verification selfie photographs
• Beneficial ownership information, including details of any third party on whose behalf you are acting
• Politically Exposed Person (PEP) status and sanctions screening information
• Business and financial information relating to the business being sold
• Bank account details for settlement purposes

From Website Visitors:

• Information submitted through enquiry, contact, or registration forms
• Standard website usage data including IP addresses and cookies (where consent is provided)

We collect personal information directly from you wherever practicable. In some circumstances we may collect information from third parties such as identity verification services, credit agencies, or publicly available sources.

3. Why We Collect Your Personal Information

We collect and use your personal information for the following purposes:

a) To provide our broking services, including introducing buyers to sellers, facilitating business sales, and managing the sale process.

b) To comply with our legal obligations, including:

• verifying your identity and conducting customer due diligence as required under the AML/CTF Act before providing designated services;
• assessing money laundering, terrorism financing, and proliferation financing risks;
• submitting reports to AUSTRAC where required by law, including Suspicious Matter Reports (SMRs) and Threshold Transaction Reports (TTRs); and
• meeting our obligations under the Property Occupations Act 2014 (Qld).

c) To communicate with you about business listings, the sale process, and matters relevant to your enquiry.

d) To send you marketing communications, including new business listings, investment opportunities, and industry updates — but only where you have provided your express consent to receive such communications.

e) To improve our services, including analysing website usage and customer interactions.

We will not use your personal information for any purpose that is incompatible with the purpose for which it was collected without your consent, unless required or authorised by law.

4. AML/CTF Customer Due Diligence

As a reporting entity under the AML/CTF Act, we are required by law to conduct customer due diligence (CDD) before providing designated services. This means we must:

• verify the identity of all buyers before disclosing confidential business information;
• understand the nature and purpose of the business relationship;
• identify and verify beneficial owners and any persons acting on behalf of a customer;
• screen customers against sanctions lists and assess Politically Exposed Person (PEP) status;
• collect and verify source of funds and, where required, source of wealth information; and
• conduct ongoing monitoring of the business relationship.

We are unable to provide our services if satisfactory customer due diligence cannot be completed.

We are prohibited by law from disclosing to you, or any other person, that a Suspicious Matter Report (SMR) has been filed with AUSTRAC, or that AUSTRAC is investigating a matter connected to you. This is known as the “tipping off” prohibition under the AML/CTF Act.

All CDD records are retained for a minimum of seven (7) years in accordance with the AML/CTF Act.

5. Disclosure of Your Personal Information

We do not sell your personal information to third parties. We may disclose your personal information in the following circumstances:

• to the Seller, to the extent necessary to facilitate a business sale;
• to professional advisors including lawyers, accountants, and financiers, where necessary to facilitate the transaction;
• to identity verification service providers engaged by us to assist with our AML/CTF obligations;
• to AUSTRAC, law enforcement agencies, or other regulatory authorities where required or authorised by law;
• to our IT and business service providers who assist us in operating our business, under confidentiality obligations; and
• where you have otherwise consented to the disclosure.

We will take reasonable steps to ensure that any third party to whom we disclose personal information is bound by appropriate confidentiality and privacy obligations.

6. Overseas Disclosure

We do not routinely disclose personal information to overseas recipients. In the event that any disclosure to an overseas recipient becomes necessary, we will take reasonable steps to ensure that the recipient handles your information in a manner consistent with the Australian Privacy Principles, or we will seek your consent prior to disclosure.

7. Marketing Communications

We will only send you marketing communications where you have expressly opted in to receive them. You may withdraw your consent to receive marketing communications at any time by:

• clicking the unsubscribe link in any marketing email or SMS;
• completing our Opt-Out form at goldcoastbusinessbrokers.com.au/opt-out/; or
• emailing us at sales@goldcoastbusinessbrokers.com.au.

We will action all opt-out requests promptly. Withdrawing marketing consent will not affect our ability to send you communications that are necessary for the provision of our services.

8. Data Quality and Security

We take reasonable steps to ensure that the personal information we collect is accurate, complete, and up to date. We encourage you to notify us of any changes to your personal information promptly.

We protect your personal information from misuse, interference, loss, unauthorised access, modification, and disclosure through the following measures:

• password-protected computer systems and databases;
• secure electronic transmission of personal information where possible;
• restricted staff access to personal information on a need-to-know basis; and
• secure disposal of personal information that is no longer required, subject to our record-keeping obligations under the AML/CTF Act and other applicable laws.

9. Access and Correction

You have the right to request access to the personal information we hold about you and to request corrections where the information is inaccurate, incomplete, or out of date. To make a request, please contact us using the details below.

We will respond to access and correction requests within a reasonable timeframe. We may ask you to verify your identity before providing access to your information. There is no charge for making a request, though we may charge a reasonable fee for the cost of providing access in some circumstances.

In limited circumstances we may decline an access or correction request where permitted by law, including where the information relates to an SMR filed with AUSTRAC.

10. Anonymity

Where practicable, we will allow you to interact with us anonymously or using a pseudonym. However, due to our obligations under the AML/CTF Act, we are required to verify the identity of all buyers before providing designated services. Anonymous interactions are therefore not possible at the point of buyer registration.

11. Cookies and Website Data

Our website may use cookies and similar technologies to improve your browsing experience and analyse website usage. You may disable cookies through your browser settings, however this may affect the functionality of our website. We do not use cookies or tracking technologies for marketing purposes without your express consent.

12. Privacy Complaints

If you believe we have mishandled your personal information, we encourage you to contact us in the first instance so that we can attempt to resolve the matter. All privacy complaints will be handled confidentially and in a timely manner.

To lodge a complaint, please contact us at:

Gold Coast Business Brokers Email: sales@goldcoastbusinessbrokers.com.au Phone: 07 5619 6863

If we are unable to resolve your complaint to your satisfaction, you may refer the matter to:

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