Privacy Policy
Last updated:June 13, 2025
At Copay, we are committed to protecting your privacy and handling your personal information with care and transparency. This Privacy Policy outlines how Copay (referred to as "we," "us," or "our") collects, uses, discloses, stores, and manages your personal information in accordance with the Australian Privacy Principles (APPs) set out in the Privacy Act 1988 (Cth). By using our website, www.copay.au, and our services, you agree to the terms of this Privacy Policy. We may update this policy from time to time, and any changes will be posted on this page.
1. What is Personal Information?
Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not. This includes information such as your name, contact details, financial information, and property interests.
2. Information We Collect
2.1 Types of Personal Information We May Collect:
- Contact Details:Name, email address, phone number, mailing address.
- Demographic Information:Date of birth, gender.
- Financial Information: Details related to your financial capacity, investment range, and potentially information required for loan applications (if you choose to connect with our finance partners).
- Property Interests & Preferences: Information about your interest in luxury holiday homes or investment properties, preferred locations (e.g., Queensland), desired investment range, and usage preferences.
- Identification Information: As required for legal and compliance purposes related to property transactions (e.g., for secure contracts, KYC/AML checks if applicable through partners).
- Communication Data: Records of your interactions with us, including emails, phone calls, and messages through our platform.
- Usages Data: Information about how you use our website and services, including pages visited, time spent on pages, links clicked, and technical details about your device (IP address, browser type, operating system).
- Social Media Information: If you interact with us through social media platforms or choose to log in using social media credentials, we may collect information such as your username, site ID, profile photo, and email address from that platform.
2.2 How We Use Your Personal Information
We collect personal information in several ways:
- Directly from You:When you register your interest, fill out forms on our website (e.g., "Get Early Access to Properties," "Inquire About This Property," "Connect with a Luxury Agent," "Book a Discovery Call"), subscribe to our newsletter, communicate with us via email or phone, or interact with our services.
- From Our Real Estate Agency Partners:When you inquire about a Copay-enabled property through one of our partner real estate agencies, they may share your relevant information with us to facilitate the co-ownership process.
- From Our Financial Lending Partners:If you choose to explore financing options through our recommended partners, they may share relevant information with us (with your consent) to streamline the process.
- Through Automated Technologies:As you navigate our website, we may use cookies, web beacons, pixels, and other tracking technologies to collect non-personal and some personal information about your browsing activity.
3. How We Use Your Personal Information
We use your personal information for the following purposes:
- To Provide Our Services:To facilitate your interest in co-ownership, connect you with suitable properties and real estate agents, assist in co-owner matchmaking, and manage your co-ownership experience (including legal contracts, financial management, scheduling, and property management services).
- To Respond to Your Inquiries:To communicate with you, answer your questions, and provide customer support.
- To Personalize Your Experience:To tailor our services and communications to your specific interests in luxury holiday homes or investment properties.
- For Marketing and Communication:To send you updates on upcoming properties, newsletters, promotional messages, and other information we believe may be of interest to you, in accordance with applicable marketing laws (e.g., the Spam Act 2003 (Cth)). You can opt-out of these communications at any time.
- For Analytics and Improvement:To understand how our website and services are used, analyze market trends, improve our platform's functionality, and enhance the overall user experience.
- For Security and Compliance:To protect our website and services from fraud or misuse, and to comply with our legal and regulatory obligations (including those under the Corporations Act and ASIC requirements for managed investment schemes, where applicable).
4. Disclosure of Personal Information to Third Parties
We may disclose your personal information to third parties for the purposes described in this Privacy Policy. These third parties may include:
- Real Estate Agency Partners:To connect you with properties and agents who can facilitate your co-ownership purchase.
- Financial Lending Partners:If you express interest in financing, we may share your information with our trusted lending partners to assist with your loan application (with your explicit consent).
- Service Providers:Third-party vendors who provide services on our behalf, such as IT support, data hosting, payment processing, legal services, property management, and marketing services. These providers are obligated to protect your information and use it only for the purposes for which we disclose it to them.
- Legal and Regulatory Bodies:Where required by law, court order, or to comply with regulatory obligations (e.g., ASIC, ATO).
- Professional Advisors:Our accountants, lawyers, and other professional advisors.
- Other Co-Owners:Limited information may be shared with other co-owners of a specific property to facilitate harmonious co-ownership (e.g., for scheduling, communication, and financial transparency within the Copay platform).
Cross-Border Disclosure:
The personal information we collect may be stored and/or processed in Australia or where we or our partners, affiliates, and third-party providers maintain facilities. If we transfer your personal information to third parties in other countries, we will perform those transfers in accordance with the requirements of applicable Australian law, including taking reasonable steps to ensure the overseas recipient does not breach the Australian Privacy Principles.
5. Security of Your Personal Information
We are committed to protecting your personal information from misuse, interference, loss, and unauthorized access, modification, or disclosure. We implement a range of physical, administrative, personnel, and technical security measures, including:
- Secure servers and data encryption.
- Access controls and authentication protocols.
- Regular security audits and vulnerability assessments.
- Employee training on privacy and data handling.
- Adherence to industry best practices for data security (e.g., principles aligned with SOC 2 criteria for security, confidentiality, and processing integrity).
While we strive to protect your personal information, no method of transmission over the Internet or method of electronic storage is 100% secure. We cannot guarantee the absolute security of your information.
6. How Long We Keep Your Personal Information
We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, as outlined in this Privacy Policy, or as required by law. When your personal information is no longer required, we will take reasonable steps to destroy or de- identify it.
7. Your Rights and Access
You have certain rights regarding your personal information:
- Right to Access:You have the right to request access to the personal information we hold about you.
- Right to Correction:You have the right to request that we correct any personal information we hold about you that is inaccurate, out-of-date, incomplete, irrelevant, or misleading.
- Right to Anonymity/Pseudonymity:Where it is lawful and practicable, you have the option of not identifying yourself or using a pseudonym when interacting with us.
- Right to Opt-Out:You can opt-out of receiving direct marketing communications from us at any time by following the unsubscribe instructions in the communication or by contacting us directly.
- Right to Withhold Information:You always retain the right to withhold personal information from us, with the understanding that your experience of our website and services may be affected. We will not discriminate against you for exercising any of your rights.
To exercise any of these rights, please contact us using the details provided below. We will respond to your request within a reasonable period.
8. Use of Cookies
We use "cookies" and similar tracking technologies to collect information about your activity across our website. A cookie is a small piece of data that our website stores on your computer or device, and accesses each time you visit, so we can understand how you use our site, remember your preferences, and improve your browsing experience. You can manage your cookie preferences through your browser settings.
9. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. We will notify you of any significant changes by posting the updated policy on our website. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.
10. Contact Us & Complaint Handling
If you have any questions about this Privacy Policy, our privacy practices, or if you wish to make a complaint about how we have handled your personal information, please contact us using the details below.
Email: director@copay.au
We will acknowledge your complaint and respond to you within a reasonable period. If your complaint is not resolved to your satisfaction, you may contact the Office of the Australian Information Commissioner (OAIC) for further assistance.
Office of the Australian Information Commissioner (OAIC):
Phone: 1300 363 992
Website: www.oaic.gov.au