1. Our Commitment to Your Privacy

Transparent Corporation Pty Ltd (ABN: 32 663 905 539) T/A Transparent Agent & AgentREV ("Transparent Agent", "we", "us", "our") is committed to protecting your privacy and handling your personal information in an open and transparent way. We are bound by the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) ("Privacy Act").

This Privacy Policy outlines how we collect, use, store, disclose, and protect personal information when you:

• Visit our website located at https://transparentagent.com.au and any other websites we operate (collectively, "Website");
• Interact with our social media sites;
• Apply to become, or are, a real estate agent or business broker subscribing to and using our 'AgentREV' proprietary software platform and associated services ("Agent" or "Agent User");
• Are an individual whose personal information is processed by an Agent User through their instance of the AgentREV platform (an "Agent's Client" in this context, where the Agent is the primary controller of such data);
• Are a business owner or representative ("Business Seller") who directly subscribes to marketing services from Transparent Agent (referred to herein as "Marketing Services");
• Are a user subscribing to and using our 'REVcaller' AI voice bot service ("REVcaller User").

This policy also describes your rights to access and correct your personal information and how to make a privacy complaint.

By accessing our Website, using the AgentREV platform ("Platform"), engaging our Marketing Services, using the REVcaller service, or otherwise providing us with personal information, you consent to the collection, use, storage, and disclosure of your personal information as described in this Privacy Policy and our applicable Terms and Conditions (including General Terms and any relevant Service-Specific Addendum). If you are an Agent User or REVcaller User providing personal information about third parties (e.g., your Agent's Clients, contacts on a call list), you warrant that you have obtained all necessary consents from them for us to handle their information as described herein and as required by applicable law, and that you are responsible for the lawful handling of that data within the services you use.

Our Contact Details for Privacy Matters:
Privacy Officer
Transparent Corporation Pty Ltd
4 Sandy Court, Mount Coolum QLD 4573, Australia
Phone: 0433 891 539
Email: [email protected] (Subject: Privacy Enquiry)

2. What Personal Information Do We Collect and Hold?

"Personal information" means information or an opinion about an identified individual, or an individual who is reasonably identifiable. The types of personal information we collect depend on the nature of your interaction with us.

2.1. For Visitors to our Website & Social Media Sites:

• Contact Information: If you contact us via forms, email, or social media (e.g., full name, email address, phone number, message content).
• Automatically Collected Information (Usage Data): IP address, browser type, operating system, device identifiers, referring URLs, pages visited, time spent on pages, clickstream data, and interactions with our content. This is often collected via cookies and similar technologies.

2.2. For Agents (Subscribers to AgentREV Platform):

• Account Creation & Profile Information (collected by Transparent Agent): Full name, business name, ABN, email address, phone number, business address, real estate license details (number, expiry, jurisdiction for verification).
• Financial Information (for Agent Subscription): Payment information (e.g., credit card details), primarily collected and processed by our third-party payment processor (e.g., Stripe). We may retain limited transaction history.
• Platform Usage Data (collected by Transparent Agent): Information about how you use features of the Platform we provide, interaction with our training materials.
• Communications with Us: Records of your communications with us (e.g., support requests, feedback).
• Affiliate Program Information: If you participate, details required to manage your referrals and payouts.
• Data Managed by Agent within their AgentREV CRM Instance: Agents use their instance of the AgentREV CRM to manage information about their own business and their Agent's Clients. This data is controlled by the Agent. Transparent Agent provides the platform but does not typically access or use this CRM data except as necessary for platform maintenance, support requested by the Agent, or as legally required. The Agent is responsible for the privacy and lawful handling of data within their CRM.

2.3. For Business Sellers (Directly Engaging Transparent Agent for Marketing Services):

• Identity and Contact Information: Full name of business owner/representative, business name, ABN, email address, phone number, business address.
• Business Information for Marketing Materials: Comprehensive information about the business being marketed for sale, as willingly completed and provided by you for the purpose of creating marketing materials (e.g., Information Memorandums). This may include business type, operational details, financial summaries (as provided by you), stock/chattel information, addresses, and other relevant details.
• Financial Information: Payment information for Marketing Package Fees and Weekly Marketing Service Subscription Fees (processed via Stripe or other designated processors). Details relating to Marketing Funds held in our trust account.
• Marketing Approvals & Communication: Records of your approvals for marketing materials, and communications with us regarding the Marketing Services.
• Client Portal Access: Login credentials for any client portal access provided (e.g., https://agentrev.app.clientclub.net/login).

2.4. For REVcaller Users:

• Registration Information: Full name, business name (if applicable), ABN (if applicable), proof of address, current company extract (if applicable), email address, phone number, trading name, and any other information required by Transparent Agent for the purpose of provisioning a Dedicated Number via our third-party telecommunications provider (e.g., Twilio).
• Account Information: User credentials for accessing any REVcaller service interface or dashboard.
• Financial Information: Payment information for REVcaller setup fees and call packages/credits (processed via Stripe or other designated processors).
• Contact Lists (provided by User): Lists of names, phone numbers, email addresses, suburbs, or other contact details that You provide to us for the AI bot to call. You warrant the lawful basis for providing this information, including all necessary consents.
• Call Campaign Data: Information about call scripts or objectives you define for the AI bot.
• Call Objective Outcomes: Summaries of the objective outcomes of calls made by the AI bot (note: full transcripts or recordings are not provided to You as part of the standard service).
• Internal Training Recordings (Transparent Corp): As detailed in the REVcaller Service Terms Addendum, Transparent Corp may capture voice snippets from REVcaller activities *solely* for its internal AI model training and service improvement. This data is handled with efforts to anonymize and is retained for a limited period (no longer than 12 months).
• Communications with Us: Records of your communications with us.

2.5. For Agent's Clients (whose information is processed by their Agent using AgentREV):

As noted in 2.2, when an Agent uses their instance of the AgentREV CRM, they control the data they input about their Agent's Clients. Transparent Agent's role is that of a platform provider and processor for that data, as directed by the Agent. The Agent is responsible for informing their Agent's Clients about how their data is handled.

2.6. Sensitive Information:

We do not actively seek to collect "sensitive information" (as defined in the Privacy Act). Users of our services (Agents, REVcaller Users, Business Sellers) are responsible for ensuring they do not provide or input sensitive information into our systems unless it is strictly necessary for a lawful purpose directly related to the service they are using, and they have obtained all required explicit consents from the individual concerned for its collection and handling. If we become aware that we have inadvertently collected sensitive information without a proper basis, we will take reasonable steps to delete it.

3. How Do We Collect Personal Information?

We collect personal information in the following ways:

• Directly from you: When you provide it to us (e.g., filling forms, creating accounts, subscribing, making payments, providing Contact Lists for REVcaller, business details for Marketing Services, communicating with us, providing feedback).
• From Agents: Regarding their own account setup, and noting that Agents manage their Agent's Client data within their own AgentREV CRM instance.
• Automatically: Through your use of our Website and Platform (cookies, server logs, etc. - see Section 6).
• From Third Parties: From payment processors (transaction details); publicly available sources (e.g., verifying Agent licenses, business details); analytics providers; telecommunications providers (number provisioning status).

If you provide us with personal information about someone else, you warrant that you have their prior consent to disclose their information to us for the purposes described in this Privacy Policy and as required by law.

4. Why Do We Collect, Hold, Use, and Disclose Personal Information? (Purposes)

We collect, hold, use, and disclose personal information for the following primary purposes:

4.1. To Provide and Manage Our Services:

• To set up and manage Agent, Business Seller, and REVcaller User accounts and platform access.
• To provide Agents with AgentREV Platform features.
• To deliver Marketing Services to Business Sellers, including creating marketing materials, managing portal listings, and handling Marketing Funds in trust.
• To provision and manage Dedicated Numbers for the REVcaller Service.
• To execute outbound call campaigns via the REVcaller Service using Contact Lists provided by REVcaller Users, based on their defined objectives.
• To generate and provide Call Objective Outcomes to REVcaller Users.
• To operate and manage our affiliate/referral program for Agents.
• To process payments for all services.
• To provide training, support, and technical assistance.
• For Transparent Corp's internal AI model training and service improvement of the REVcaller service (using voice snippets from REVcaller activities only as permitted by the REVcaller Service Terms Addendum and this Privacy Policy, with efforts to anonymize, and for a limited retention period of no longer than 12 months).

4.2. For Communication:

• To communicate with you about your account, subscriptions, payments, support requests, and our services.
• To respond to your enquiries and feedback.
• To send important service-related notices.

4.3. For Improvement and Development:

• To understand how our Website and Services are used, analyze trends, and gather demographic information.
• To improve and personalize your experience.
• To develop new features, products, and services.

4.4. For Marketing and Promotion (with your consent where required):

• To send you newsletters and marketing communications about our products and services. You can opt-out (see Section 10).

4.5. For Legal and Security Purposes:

• To protect the security and integrity of our Website, Platform, data, and business.
• To prevent fraud and illegal activities.
• To comply with legal/regulatory obligations (e.g., record keeping, trust accounting, NDB scheme, telecommunications regulations).
• To enforce our Terms and Conditions.
• To resolve disputes and manage complaints.

4.6. For Business Operations:

• For general business administration and financial record keeping.
• In connection with a business transaction (e.g., merger, acquisition).

We will not use or disclose your personal information for a purpose other than a primary purpose (or a related secondary purpose you would reasonably expect) unless we have your consent, or it is otherwise permitted or required by law.

5. To Whom Do We Disclose Personal Information?

We may disclose your personal information to the following types of third parties:

5.1. Third-Party Service Providers:

To perform functions and provide services to us, subject to obligations to protect your information. These include providers of:

• Platform Infrastructure & Core Functionality: (e.g., GoHighLevel, Google Cloud Platform, Amazon Web Services).
• Cloud Storage: (e.g., Google Drive for internal documents necessary for service provision and temporary storage of certain user-provided data like REVcaller call lists or analytics before deletion, storage.googleapis.com via GoHighLevel).
• Payment Processing: (e.g., Stripe, GoCardless).
• Telecommunications Services: (e.g., Twilio for REVcaller Dedicated Numbers).
• AI Technology Providers: (e.g., Retell.ai, OpenAI/ChatGPT for REVcaller functionality).
• Communication & Automation Tools: (e.g., Make.com).
• Email Delivery, Analytics, Customer Support, Accounting/Legal, Domain/Hosting.

5.2. Agents, their Agent's Clients, and Business Sellers (as applicable to the service):

• Information flow as necessary for service provision (e.g., an Agent accesses and manages their client data within their AgentREV CRM instance; leads for a Business Seller's marketing campaign are passed to them or their nominated Agent).

5.3. Real Estate Portals & Marketing Channels:

• For Business Sellers engaging our Marketing Services, business information (as approved by the Seller) is disclosed to online portals (e.g., Commercialrealestate.com, Seek Business) and social media platforms for advertising.

5.4. Legal and Regulatory Authorities:

• If required by law, court order, or to protect rights and safety.

5.5. Business Transactions:

• In connection with a merger, acquisition, or sale of assets.

5.6. With Your Consent:

• To other third parties with your explicit consent.

6. Cookies and Tracking Technologies

Our Website and Platform may use cookies, web beacons, pixels, server logs, and other similar tracking technologies to: enhance your browsing experience, remember your preferences, collect usage information, provide and improve services, for security, analytics, and to measure marketing effectiveness. You can typically manage cookies via browser settings, but some features may not function if disabled. Third-party analytics providers (like Google Analytics) may also collect information.

7. Data Storage, Security, and Cross-Border Disclosure

7.1. Data Storage and Security:

We take reasonable steps to protect personal information from misuse, interference, loss, and unauthorized access, modification, or disclosure. This includes secure servers/cloud infrastructure, access controls, encryption where appropriate, regular security reviews, and restricted personnel access. However, no internet transmission or electronic storage is 100% secure; any transmission is at your own risk.

7.2. Cross-Border Disclosure of Personal Information (APP 8):

Some third-party service providers we use (as listed in Section 5.1, including cloud hosting, payment processors, AI technology providers like Retell.ai, and telecommunications providers like Twilio) may be located or have data servers overseas (e.g., USA, EU, other jurisdictions). Personal information may be transferred to, stored, and processed in these countries, which may have different data protection laws to Australia. By providing your personal information or using our Services, you consent to this disclosure. We take reasonable steps to ensure overseas recipients handle your information consistently with the APPs or are subject to comparable protection schemes, often by using reputable providers with strong data protection commitments.

8. Data Retention

We retain personal information only as long as necessary for the purposes collected, as required by law, or to resolve disputes/enforce agreements.

• Agent Account Information: For subscription duration and a reasonable period after (e.g., up to 7 years for financial records).
• Business Seller Marketing Service Data (including IM information provided by Seller, communication records): For service duration and a reasonable period after (e.g., trust account records for 7 years).
• REVcaller User Registration Information: For service duration and a reasonable period after for legal/compliance.
• REVcaller Contact Lists (provided by User): Securely deleted from Our active systems within 7 business days after call batch completion and successful analytics delivery.
• REVcaller Call Objective Outcomes (Our copies provided to User): Securely deleted from Our active systems within 7 business days post-delivery to User.
• Internal Training Recordings from REVcaller activities (Transparent Corp, if any): Retained for no longer than 12 months, then securely deleted.
• Data Managed by Agents within their AgentREV CRM Instance: This data is controlled by the Agent. Transparent Agent does not set specific retention periods for data within an Agent's CRM; retention and deletion are the Agent's responsibility according to their own policies and legal obligations. Data management upon Agent account termination is per T&Cs.
• Website Usage Data: Shorter periods or longer if anonymized.

When no longer needed, we take reasonable steps to destroy or de-identify personal information, unless law requires retention.

9. Your Rights: Accessing and Correcting Your Personal Information (APP 12 & 13)

You have the right to request access to the personal information we hold about you and to request its correction if you believe it is inaccurate, out-of-date, incomplete, irrelevant, or misleading. Contact our Privacy Officer. We respond within a reasonable period (usually 30 days), may need to verify identity, and may charge a reasonable administrative fee for access. If access/correction is denied, we provide a written explanation. Users can often update some account information directly via their account settings or client portal.

10. Direct Marketing (APP 7)

We may use your personal information to send you direct marketing communications about our products and services if we have your consent or are otherwise permitted by law. You can opt-out at any time via unsubscribe links in emails or by contacting our Privacy Officer. Even if you opt-out of marketing, we may still send essential service-related communications.

11. Anonymity and Pseudonymity (APP 2)

Wherever it is lawful and practicable, you have the option of not identifying yourself, or of using a pseudonym, when dealing with us (e.g., for general enquiries). However, for the provision of most of our services (AgentREV, Marketing Services, REVcaller), full and accurate identification is necessary.

12. Government Related Identifiers (APP 9)

We do not collect, use, or disclose government related identifiers (such as Tax File Numbers or Medicare numbers) unless required or authorised by law. We collect ABNs for Agents, Business Sellers, and REVcaller Users (where applicable) for business identification and invoicing purposes, which is permissible.

13. Making a Privacy Complaint (APP 1)

If you have a concern or complaint about how we have handled your personal information, please contact our Privacy Officer first (details in Section 1) with written details. We will acknowledge receipt promptly, investigate thoroughly, and respond with our findings and any action (usually within 30 days). If you are not satisfied with our response, you have the right to lodge a complaint with the Office of the Australian Information Commissioner (OAIC): Online at www.oaic.gov.au/privacy/privacy-complaints, Phone: 1300 363 992, Mail: GPO Box 5218, Sydney NSW 2001.

14. Third-Party Websites

Our Website and Platform may contain links to third-party websites or services not operated or controlled by us. This Privacy Policy applies only to our services. We are not responsible for the privacy practices of third-party websites. Review their privacy policies before providing personal information.

15. Children's Privacy

Our Website, Platform, and Services are not intended for use by individuals under the age of 18 ("Minors"). We do not knowingly collect personal information from Minors. If you are a parent or guardian and believe your child has provided personal information to us, contact us immediately, and we will take reasonable steps to delete it.

16. Changes to this Privacy Policy

We may update or modify this Privacy Policy from time to time to reflect changes in our privacy practices, business operations, or legal obligations. Changes will be posted on this page with an updated "Effective Date." Significant changes may also be notified via email or a notice on our Website/Platform. Review this policy periodically. Your continued use of our services after changes constitutes acceptance.

17. Contact Us

For questions, concerns, or requests regarding this Privacy Policy or our handling of your personal information, please contact our Privacy Officer:

Privacy Officer
Transparent Corporation Pty Ltd
4 Sandy Court, Mount Coolum QLD 4573, Australia
Phone: 0433 891 539
Email: [email protected] (Please use "Privacy Enquiry" in the subject line)