Legal
Privacy Policy
Sold OffMarket — sold-offmarket.com.au
Operated by White Tree Systems Pty Ltd ACN 697 785 916
Effective Date: 12 May 2026 · Last Updated: 12 May 2026
1. Introduction and Scope
White Tree Systems Pty Ltd (ACN 697 785 916), trading as Sold OffMarket ("we", "us", "our"), operates an online platform at sold-offmarket.com.au (the "Platform") that connects real estate agents holding off-market property listings with buyers and buyer agents searching for properties that are not publicly advertised.
This Privacy Policy explains how we collect, hold, use, disclose, and protect personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). By registering for and using the Platform, you acknowledge that you have read and understood this policy.
This policy applies to all users of the Platform, including real estate agents, buyer agents, individual buyers, and any third parties whose personal information is submitted by users with their authorisation.
2. Key Commitments at a Glance
- –We will never sell your personal information to third parties for their own commercial gain.
- –We collect only what is reasonably necessary to provide the matching service.
- –Off-market property data is treated as commercially sensitive and subject to strict access controls.
- –Contact details are disclosed to counterparties only when a match is confirmed — which is the fundamental purpose of the Platform and to which you consent by using it.
- –You may access, correct, or request deletion of your personal information at any time.
- –Concerns that we cannot resolve may be escalated to the Office of the Australian Information Commissioner (OAIC).
3. About Us
4. Personal Information We Collect
4.1 Real Estate Agents
When you register and use the Platform as a real estate agent, we collect:
- –Full name and professional licence number or registration details
- –Agency or business name and business address
- –Contact details: email address and phone number
- –Off-market property listing details: property address, property type, indicative price range, number of bedrooms and bathrooms, land size, and any additional attributes you choose to provide
- –Account credentials used to authenticate your account (managed via Firebase Authentication)
4.2 Buyer Agents and Individual Buyers
When you register and use the Platform as a buyer or buyer agent, we collect:
- –Full name and, if applicable, agency or business name
- –Contact details: email address and phone number
- –Search criteria profiles, including preferred suburb(s), property type, price range, number of bedrooms and bathrooms, and any additional search parameters you supply
- –Account credentials used to authenticate your account (managed via Firebase Authentication)
4.3 Property Owner Information Submitted by Agents
Real estate agents may submit details about properties owned by third parties. If you are a real estate agent, by submitting a listing you confirm that: (a) you are authorised by the relevant property owner to submit their property information to the Platform; and (b) the property owner understands that their property details may be shared with verified, matched buyers as part of the matching process described in this policy.
4.4 Client Information Submitted by Buyer Agents
Buyer agents submit search criteria on behalf of their clients. If you are a buyer agent, by submitting a search profile you confirm that: (a) you are authorised by your client to submit their search criteria and preferences to the Platform; and (b) your client understands that their search criteria will be used to identify matching properties and that their agent's contact details will be disclosed to a matched listing agent.
4.5 Technical and Usage Data
We may also collect non-personal technical data, including:
- –Device type, browser type, and operating system
- –IP address and general geographic location (city or region level only)
- –Pages viewed, features used, and session activity on the Platform
This data is used only to maintain, improve, and secure the Platform. It is not used to identify individual users and is not shared in identifiable form.
4.6 Sensitive Information
We do not intentionally collect sensitive information as defined in the Privacy Act (such as health information, racial or ethnic origin, political opinions, or financial account details). Please do not submit sensitive information through the Platform. If we inadvertently receive sensitive information, we will delete it promptly.
5. How We Collect Your Information
We collect personal information:
- –directly from you when you register, create a listing, or submit a search criteria profile;
- –automatically through your use of the Platform (technical and usage data); and
- –via Firebase Authentication when you log in to your account.
We do not collect information about you from third-party data brokers, credit reporting bodies, or social media platforms unless you explicitly connect such a service.
6. How and Why We Use Your Information
6.1 Providing the Core Matching Service
- –Running our matching algorithm to identify property listings compatible with buyer search profiles
- –Notifying buyers and buyer agents when a listing matching their criteria is added to the Platform
- –Disclosing property listing details and the listing agent's contact information to a buyer upon a confirmed match (and vice versa), as described in Section 7 below
6.2 Account and Platform Management
- –Creating, verifying, and administering user accounts
- –Sending service notifications, including match alerts, account updates, and security notices
- –Investigating and responding to user queries, complaints, and support requests
- –Detecting, preventing, and investigating fraudulent, unauthorised, or unlawful activity on the Platform
- –Monitoring and improving Platform performance, security, and functionality
6.3 Legal and Compliance Obligations
- –Meeting obligations imposed by Australian law, including record-keeping requirements
- –Responding to lawful requests from law enforcement, regulators, and courts
We will not use your personal information for purposes that are incompatible with those set out in this policy without first obtaining your consent or as otherwise permitted by the APPs.
7. Disclosure of Your Information
We do not sell, rent, or trade personal information. We disclose it only in the following circumstances.
7.1 Matched Counterparties (Core Service Disclosure)
The essential function of the Platform is to introduce matched parties. When a buyer's search criteria aligns with a real estate agent's listing at or above our matching threshold, we disclose to each matched party:
- –The relevant property listing details (including address, price range, and features)
- –The real estate agent's name and contact details
- –The buyer agent's or buyer's name and contact details
By registering for and using the Platform, both agents and buyers expressly consent to this disclosure. This consent is a prerequisite for using the matching service. You may withdraw consent at any time by deactivating or closing your account; however, doing so will prevent us from providing the matching service to you.
7.2 Technology and Service Providers
We engage third-party service providers to help us operate the Platform. These providers act on our instructions and are bound by appropriate confidentiality and data-handling obligations. Current categories include:
- –Google Firebase (authentication, database, and cloud hosting services)
- –Email and SMS delivery providers (for match and service notifications)
- –Analytics providers (de-identified, aggregated usage data only)
We do not permit service providers to use your personal information for their own purposes beyond providing services to us.
7.3 Legal Obligations
We may disclose your personal information to law enforcement agencies, government bodies, courts, or regulators where required or authorised by Australian law, or where we have a good-faith belief that disclosure is necessary to protect the rights, property, or safety of ourselves, our users, or the public.
7.4 Business Transfers
If we sell, merge, or otherwise restructure our business, personal information held by us may be transferred to a successor entity as part of that transaction. We will notify affected users and ensure the successor is bound by obligations consistent with this policy.
8. Overseas Disclosure and Cross-Border Data Transfers
Our Platform is hosted on Google Firebase / Google Cloud infrastructure. Google LLC is headquartered in the United States and may store or process data in countries outside Australia. We take reasonable steps to ensure that overseas recipients handle personal information in a manner consistent with the APPs, including by relying on Google's contractual data processing terms.
By using the Platform, you consent to the transfer and storage of your personal information outside Australia as described in this section. You acknowledge that such overseas recipients may be subject to foreign laws that provide different levels of protection to personal information than Australian law.
9. Security of Your Information
We take reasonable technical and organisational steps to protect personal information from misuse, interference, loss, and unauthorised access, modification, or disclosure. Our current security measures include:
- –Account access controls — only verified, authenticated users may access the Platform
- –Off-market property details are visible only to buyers whose search criteria match that specific listing
- –Encrypted, authenticated sessions via Firebase Authentication
- –Confidentiality obligations for any team members or contractors with access to Platform data
- –Regular review of security practices in line with industry standards
Despite these safeguards, no system can guarantee absolute security. If you suspect your account has been compromised, please contact us immediately at team@sold-offmarket.com.au.
In the event of a data breach that is likely to result in serious harm to affected individuals, we will comply with our mandatory data breach notification obligations under the Notifiable Data Breaches (NDB) scheme, including notifying affected individuals and the OAIC as required.
9.1 Data Retention
- –Active listings and search profiles are available in the matching engine while your account remains open.
- –On account closure or deletion request, active listings and search profiles are removed from the matching engine promptly.
- –We may retain records for up to seven (7) years where required by Australian law (including tax and financial records) or for the purpose of resolving disputes or enforcing our agreements.
- –When retention is no longer required or legally mandated, we will securely destroy or permanently de-identify your information.
10. Automated Decision-Making
Our matching algorithm uses the property attributes submitted by listing agents and the search criteria submitted by buyers to calculate a compatibility score and determine whether a match notification should be issued. This automated process uses personal information (including location, price range, and property features) and produces decisions — namely, whether to notify a buyer of a particular listing — that may materially affect whether a buyer is introduced to an available property.
In preparation for the automated decision-making transparency requirements under APP 1.7 of the Privacy Act (which take effect on 10 December 2026 under the Privacy and Other Legislation Amendment Act 2024 (Cth)), we disclose the following:
- –Personal information used: property attributes (type, location, price range, bedrooms, bathrooms, land size), buyer search criteria parameters, and user account status.
- –Nature of automated decisions: whether a buyer's search profile is a compatible match with a given listing, and whether a match notification is dispatched to the buyer.
- –Significance: a match decision determines whether a buyer receives information about a specific off-market property and whether their contact details are disclosed to the listing agent.
Human review: our automated matching process is rule-based. No human reviews individual match decisions before notifications are issued. However, users who believe a match was made in error or that a notification was sent inappropriately may contact us to raise a concern.
11. Your Privacy Rights
11.1 Access to Your Information
You may request access to the personal information we hold about you. We will respond within 30 days of receiving a valid request. There is no charge for making a request, though a reasonable fee may apply to cover retrieval costs in complex cases. We will advise you of any applicable fee before proceeding.
11.2 Correction of Your Information
If you believe that personal information we hold about you is inaccurate, incomplete, or out of date, you may request that we correct it. We will take reasonable steps to correct the information within 30 days, or notify you if we do not agree that a correction is warranted (and explain your options in that case).
11.3 Deletion of Your Information
You may request that we delete your account and the associated personal information. We will action this request promptly, subject to any legal obligations that require us to retain certain records (see Section 9.1 above). We will confirm deletion to you in writing.
11.4 Withdrawal of Consent
Where we rely on your consent to process your information, you may withdraw consent at any time by contacting us or closing your account. Withdrawal of consent will prevent us from providing the matching service to you and will result in deactivation of your account.
11.5 Opting Out of Communications
You may opt out of non-essential communications (such as product updates or promotional messages) at any time by using the unsubscribe link in any such communication or contacting us directly. Match notifications and essential account communications are a core part of the service and cannot be suppressed while your account remains active.
12. Privacy Concerns and Complaints
We take privacy concerns seriously. If you believe we have not handled your personal information in accordance with this policy or the APPs, please contact our Privacy Officer at team@sold-offmarket.com.au. We will:
- –acknowledge receipt of your concern within five (5) business days; and
- –endeavour to investigate and respond substantively within thirty (30) days.
If you are not satisfied with our response, or if we fail to respond within 30 days, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC):
13. Cookies and Tracking Technologies
The Platform may use cookies and similar technologies (such as local storage or session tokens) to maintain your logged-in session, remember your preferences, and collect aggregated analytics about Platform usage.
You may configure your browser to block or delete cookies; however, doing so may prevent some features of the Platform from functioning correctly. Analytics data collected via cookies is aggregated and de-identified before any use or disclosure.
14. Children's Privacy
The Platform is intended exclusively for use by licensed real estate professionals and adult buyers. We do not knowingly collect personal information from individuals under the age of 18. If we become aware that a minor has submitted personal information through the Platform, we will delete it promptly. If you believe a minor has created an account, please notify us at team@sold-offmarket.com.au.
15. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes to our practices, technology, or legal obligations. When we make material changes, we will notify affected users by email or via a prominent notice on the Platform at least fourteen (14) days before the changes take effect (where practicable).
The current version of this policy is always available at sold-offmarket.com.au. Continued use of the Platform after the effective date of any updated policy constitutes acceptance of the revised terms. If you do not agree to a material change, you may close your account before the change takes effect.
16. How to Contact Us
For any questions, requests, or concerns regarding this Privacy Policy or our handling of your personal information, please contact:
We will acknowledge your contact within five (5) business days and aim to resolve your enquiry within thirty (30) days.
This Privacy Policy was prepared for White Tree Systems Pty Ltd ACN 697 785 916 (trading as Sold OffMarket). It is an original work drafted to comply with the Privacy Act 1988 (Cth) and the Australian Privacy Principles as at the date shown above.
For questions, contact us at team@sold-offmarket.com.au or visit sold-offmarket.com.au.