Privacy Policy

1. About This Policy

Keyli Pty Ltd ('Keyli', 'we', 'us', 'our') operates keyli.com.au and associated mobile applications (the 'Platform'). The Keyli Platform is a dual-sided property marketplace and expert services directory that:

• enables private property owners to list and sell or rent their own homes directly to buyers and tenants (For Sale By Owner / FSBO), and earn a commission-based arrangement with Keyli upon completion of sale; and
• connects users with a curated Expert Directory of property-related professionals — real estate agents, solicitors, licensed conveyancers, mortgage brokers, registered property valuers, building and pest inspectors, property photographers, and property-related tradies and handymen — and operates an escrow-based payment model for expert services.

This Privacy Policy ('Policy') explains how we handle personal information in accordance with the Privacy Act 1988 (Cth), the 13 Australian Privacy Principles (APPs), the Privacy and Other Legislation Amendment Act 2024 (Cth), and the Privacy Regulations 2025 (Cth).

By using the Platform you consent to the practices described in this Policy. If you do not agree, please do not use the Platform.

2. Personal Information We Collect

2.1 Sellers (FSBO and Agent-Listed)

• Full legal name, date of birth, residential address
• Email address and phone number(s)
• Government-issued identity documents (drivers licence, passport) — for identity verification and AML/CTF compliance
• Property details: address, title reference, photographs, floor plans, inclusions, exclusions, and sale price
• Bank account details for commission invoicing and payment
• Communications with buyers, experts, and Keyli support

2.2 Buyers

• Full name, email address, phone number
• Property search preferences and saved listings
• Enquiry messages sent to sellers
• Identity verification documents where required for offer or contract processes
• Payment details where a buyer engages an expert through the Platform's escrow system

2.3 Experts (All Categories)

• Full name, trading name, ABN/ACN
• Professional licence numbers, registration details, and category credentials
• Contact details, service area(s), and professional profile content
• Bank account details for receiving disbursements net of Keyli's Expert Commission after escrow release
• Insurance certificates (public liability; professional indemnity for licensed professionals)
• Identity and licence verification documents

2.4 Tradies and Handymen (Sub-category of Experts)

• ABN and business name
• Contact details and service area
• Trade licence number(s) and ABN — verified by Keyli at registration
• Public liability insurance certificate (noted but not independently verified by Keyli)

Note: Tradies and handymen are not required to hold professional licences equivalent to those required of licensed agents, solicitors, or other regulated professionals. Users should conduct their own checks on tradie qualifications.

2.5 Information Collected Automatically

• IP address, device type, browser, operating system
• Pages visited, search queries, listing views, session duration
• Location data (general from IP; precise only if you grant permission)
• Cookies and tracking technologies (see Section 10)

2.6 Escrow and Payment Information

When a user books an expert through the Platform, Keyli collects and processes payment information as follows:

• Credit/debit card or bank transfer details — collected via our PCI-DSS compliant payment processor
• Transaction amount (expert's fee + user-side service fee)
• Escrow hold dates, dispute notifications, and release confirmations
• Keyli Expert Commission (deducted from expert payout on escrow release)

3. How We Use Personal Information (APP 6)

3.1 Primary Purposes

• Create and maintain your Keyli account
• Publish and manage property listings
• Facilitate connections between sellers, buyers, and experts
• Operate the escrow payment system: hold funds on behalf of users, add the user-facing service fee to expert invoices, release funds to experts net of Keyli's Expert Commission upon confirmed delivery, and handle disputes
• Earn and collect the Sale Commission (% of sale price) upon settlement of properties introduced through the Platform
• Verify identity and comply with AML/CTF obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth)
• Process, hold, and disburse payments through the escrow system
• Provide customer support and dispute resolution
• Send transactional notifications (enquiry alerts, escrow status updates, release confirmations, commission invoices)

3.2 Secondary Purposes (with consent or where permitted by law)

• Direct marketing: property market updates, Platform features, featured experts (opt-out always available)
• Analytics and Platform improvement
• Aggregated, de-identified market intelligence
• Fraud detection and financial crime prevention

4. Disclosure of Personal Information

4.1 Between Platform Users

When a buyer enquires about a listing, the seller receives the buyer's name and contact details to facilitate property communication. When a user engages an expert, their name, contact details, and relevant property information are shared with that expert to enable service delivery.

4.2 To Experts

Experts receive the personal information necessary to perform their booked service. Experts are contractually required to handle user personal information in compliance with the Privacy Act 1988 (Cth) and APPs.

4.3 Escrow and Payment Processor

To operate the escrow payment system, Keyli shares transaction data with its third-party payment processor(s). Payment processors are PCI-DSS compliant and bound by data processing agreements. Keyli does not store full payment card numbers.

4.4 Service Providers

Cloud hosting, analytics, customer support, email delivery, and identity verification providers — all bound by confidentiality agreements.

4.5 Legal and Regulatory Disclosure

Law enforcement, regulatory bodies, courts, and government authorities as required or authorised by law, including under the AML/CTF Act 2006 (Cth), AUSTRAC reporting obligations, and the Privacy Act 1988 (Cth).

4.6 No Sale of Personal Information

Keyli does not sell, rent, or trade your personal information to third parties for their own marketing purposes.

4.7 Overseas Disclosure (APP 8)

Some service providers (cloud hosting, payment processing) may process data outside Australia, primarily in the USA and EU. Keyli takes reasonable steps to ensure these recipients comply with the APPs or a comparable framework. By using the Platform you consent to such transfers where necessary.

5. Escrow: Specific Privacy Considerations

Keyli's escrow function requires us to hold and process payment data on behalf of both sides of a transaction. The following specific practices apply:

• Keyli acts as a payment intermediary — not a bank or authorised deposit-taking institution — for the purposes of holding funds pending expert service delivery
• Escrow transaction records (amounts, parties, dates, release/dispute outcomes) are retained for 7 years for financial compliance purposes
• In the event of a disputed release, Keyli may share relevant communications and evidence between the disputing user and expert to facilitate resolution
• Keyli may be required to report certain financial transactions to AUSTRAC under the AML/CTF Act

6. Data Security (APP 11)

• AES-256 encryption at rest; TLS 1.3 in transit
• PCI-DSS compliant payment processing — Keyli does not store full card numbers
• Multi-factor authentication on all accounts
• Role-based staff access controls
• Regular penetration testing and vulnerability scanning
• Notifiable Data Breaches scheme compliance (Privacy Act, Part IIIC)

We will notify the OAIC and affected individuals of any eligible data breach without undue delay and in accordance with law.

7. Data Retention (APP 11.2)

• Account data: duration of account + 7 years after closure
• Sale transaction and commission records: 7 years (ATO, AML/CTF requirements)
• Escrow transaction records: 7 years
• Expert engagement records: 7 years
• Identity verification documents: retained only as long as required by AML/CTF obligations
• Marketing preferences: until opt-out or account closure
• Support communications: 3 years after resolution

When information is no longer required it is securely deleted or irreversibly de-identified.

8. Your Rights

8.1 Access (APP 12)

Request a copy of your personal information via hello@keyli.com.au. Response within 30 days.

8.2 Correction (APP 13)

Request correction of inaccurate or incomplete information. Response within 30 days at no charge.

8.3 Complaints

Raise complaints with our Privacy Officer first. If unresolved, escalate to the OAIC (www.oaic.gov.au | 1300 363 992).

9. Direct Marketing (APP 7)

We may send marketing about Keyli services, property market insights, and featured experts. Every communication includes a simple opt-out. You may also opt out via account settings or by emailing hello@keyli.com.au. We do not use sensitive information for marketing.

10. Cookies and Tracking

• Essential cookies: required for Platform and escrow payment operation
• Analytics cookies: usage data to improve the Platform
• Functional cookies: preferences and login state
• Marketing cookies: personalised advertising (where consented)

Manage preferences in your browser settings. All tracking complies with OAIC guidance on tracking pixels and the Privacy Act 1988 (Cth).

11. Children's Privacy

The Platform is not directed at persons under 18. We do not knowingly collect information from minors. Contact hello@keyli.com.au immediately if you believe we hold a minor's information.

12. Automated Decision-Making

Keyli may use automated tools for fraud screening, escrow dispute triage, and expert matching scores. In accordance with the Privacy and Other Legislation Amendment Act 2024, full disclosure of substantially automated decision-making processes will be added to this Policy no later than 10 December 2026.

13. Privacy Officer

Privacy Officer — Keyli Pty Ltd

• Email: hello@keyli.com.au
• Response time: 30 days

14. Policy Updates

We may update this Policy at any time. Material changes will be notified via the Platform and by email with reasonable notice. Continued use after the effective date constitutes acceptance.