Privacy Policy & Terms of Service
Prepared for: [Lux Living Collective] · ABN [XX XXX XXX XXX]
Website: [(https://luxlivingcollective.au/)]
Jurisdiction: New South Wales, Australia
Version: 1.0 · Draft
Prepared: March 2026
| ⚠️ LEGAL REVIEW REQUIRED These documents are working drafts prepared to structure the key provisions required for launch. They must be reviewed and approved by a qualified Australian solicitor before publication. Placeholders marked [LIKE THIS] must be completed before legal review. |
Document Index
This file contains two documents:
- Part A — Privacy Policy (pages 2–6)
- Part B — Terms of Service (pages 7–14)
- Appendix — Cookie & Tracking Disclosure
| 📌 Both documents should be published as separate pages on your website. Link to both in your site footer and reference the Privacy Policy in all lead capture forms. |
PART A
Privacy Policy
Last updated: [DATE] · Version 1.0
This Privacy Policy explains how [Lux Living Collective] ABN [XX XXX XXX XXX] (“we”, “us”, “our”) collects, uses, stores, and discloses your personal information when you visit [luxlivingcollective.au] (the “Site”) or engage with our property advisory services.
We are committed to handling your personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) contained in that Act.
| ⚠️ LEGAL REVIEW REQUIRED Confirm whether you are an APP entity (generally, businesses with annual turnover over $3M, or those that trade in personal information). If below the threshold, compliance remains best practice and is strongly recommended given you handle financial and personal data from quiz completions. |
1. Information We Collect
1.1 Information you provide directly
When you complete a quiz on our Site, we collect the following personal information:
- First name and email address (required to receive your results)
- Mobile number (optional, provided at your discretion)
- Your responses to quiz questions, including investment goals, budget range, property preferences, suburb preferences, and purchase timeline
- Any free-text responses you provide
When you book a consultation, we collect:
- Name, email address, and phone number
- Your preferred appointment time and any notes you provide at booking
1.2 Information collected automatically
When you visit our Site, we may automatically collect:
- IP address and approximate location (city/region level)
- Browser type, device type, and operating system
- Pages visited, time on site, and referring URL
- Cookie identifiers and session data (see Cookie & Tracking Disclosure, Appendix A)
1.3 Information from third parties
We may receive information about you from:
- Advertising platforms (Meta, Google) — if you click an ad that leads to our Site, we may receive aggregated audience data. We do not receive your name or contact details from these platforms.
- Calendly — if you book a consultation via our Calendly integration, Calendly collects and processes your booking details under their own privacy policy.
- Email marketing platforms — we use [Mailchimp / Brevo/ SmartledAi] to send emails. Engagement data (opens, clicks) is collected by that platform.
2. How We Use Your Information
We use the personal information we collect for the following purposes:
2.1 Delivering your quiz results
- To generate and display your personalised property shortlist
- To send your results to the email address you provide
- To match your responses against our development database to identify relevant properties
2.2 Following up with you
- To contact you by email or phone (if provided) to discuss your results and next steps
- To book and manage consultation appointments
- To respond to enquiries you send us
2.3 Email marketing
With your consent, we may send you:
- Property market updates and insights relevant to your quiz segment (investor, downsizer, or first home buyer)
- Information about new developments that match your stated criteria
- Educational content about the Sydney new apartment market
You can unsubscribe from marketing emails at any time by clicking the unsubscribe link in any email or by contacting us directly. Opting out of marketing does not affect our ability to send you transactional communications related to a service you have requested.
2.4 Improving our services
- To analyse quiz completion rates and refine our matching logic
- To understand how visitors use our Site and improve its performance
- To measure the effectiveness of our advertising campaigns (using aggregated, anonymised data only)
3. How We Store Your Information
3.1 Storage infrastructure
Personal information submitted through our quiz and lead capture forms is stored in Strapi, a headless content management system. Our Strapi instance is hosted on [hosting provider — e.g., Railway, Render, AWS, DigitalOcean].
| ⚠️ LEGAL REVIEW REQUIRED Confirm your Strapi hosting provider and its data residency location. If data is stored outside Australia, you must comply with APP 8 (cross-border disclosure) and either confirm the overseas recipient meets equivalent privacy standards, or obtain explicit consent from users. This is particularly important if using a US-based hosting provider. |
We implement the following security measures for data stored in Strapi:
- Access is restricted to authorised personnel only
- Authentication is protected by strong passwords and, where available, two-factor authentication
- API endpoints that expose personal data are protected by authentication tokens
- We do not store financial information, credit card details, or government identifiers
3.2 Email marketing platform
Email addresses and subscriber preferences are stored and processed by [Mailchimp / ActiveCampaign / your email platform], which is hosted and operated by [platform provider and jurisdiction]. Their privacy policy is available at [URL].
3.3 Booking platform
Consultation booking data is stored and processed by Calendly, Inc. (United States). By using our booking link, you agree to Calendly’s Privacy Policy, available at calendly.com/privacy.
3.4 Retention
We retain your personal information for as long as reasonably necessary to provide our services and for a period of [24 months / specify] after your last interaction with us, unless a longer retention period is required by law.
You may request deletion of your personal information at any time (see Section 7).
4. Disclosure of Your Information
We do not sell your personal information to third parties. We do not share your name, email, or contact details with property developers.
We may disclose your personal information to:
- Our team members and authorised consultants, for the purpose of delivering your shortlist and consultation services
- Third-party service providers who assist us in operating our Site and services (including our hosting provider, email marketing platform, and booking platform), under data processing agreements that require them to protect your information
- Professional advisors such as lawyers and accountants, where reasonably necessary
- Law enforcement or government agencies, where required or authorised by law
5. Cookies and Tracking Technologies
Our Site uses cookies and similar tracking technologies. For full details of what we collect, why, and how to manage your preferences, see the Cookie & Tracking Disclosure in Appendix A of this document.
By continuing to use our Site after being presented with our cookie consent notice, you consent to our use of cookies as described in Appendix A.
6. Third-Party Links
Our Site may contain links to third-party websites, including property developer websites, government resources, and booking platforms. We are not responsible for the privacy practices of those websites. We encourage you to read their privacy policies before providing any personal information.
7. Your Privacy Rights
Under the Australian Privacy Principles, you have the right to:
- Access the personal information we hold about you
- Request correction of inaccurate or outdated information
- Request deletion of your personal information (subject to our legal obligations)
- Opt out of direct marketing communications at any time
- Make a complaint about our handling of your personal information
To exercise any of these rights, contact us at:
- Email: [privacy@yourwebsite.com.au]
- Post: [Company Name], [Street Address], [Suburb NSW XXXX]
We will respond to requests within 30 days. If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.
8. Changes to This Policy
We may update this Privacy Policy from time to time. When we do, we will revise the “Last updated” date at the top of this page. We encourage you to review this policy periodically.
For material changes, we will take reasonable steps to notify existing subscribers by email.
9. Contact Us
[Lux Living Collective]
[ABN]
[Street Address, Suburb NSW XXXX]
[privacy@yourwebsite.com.au]
[Phone number]
PART B
Terms of Service
Last updated: [DATE] · Version 1.0
These Terms of Service (“Terms”) govern your access to and use of the website located at [yourwebsite.com.au] (the “Site”) and the property advisory services offered by [Company Name] ABN [XX XXX XXX XXX] (“we”, “us”, “our”).
By accessing our Site or using our services, you agree to be bound by these Terms. If you do not agree, please do not use our Site or services.
| ⚠️ LEGAL REVIEW REQUIRED These Terms are drafted for a non-licensed advisory service that provides information and referrals. If you hold or intend to hold a real estate agent licence, buyer’s agent licence, or any financial services licence, your Terms must reflect your specific regulatory obligations. Confirm your licensing position with your solicitor before publication. |
1. Our Services
1.1 What we provide
We operate a property matching and advisory service that helps prospective buyers — including investors, downsizers, and first home buyers — identify new apartment developments in Sydney that may suit their needs.
Our services include:
- An online quiz that collects your preferences and generates a personalised shortlist of matched developments
- Delivery of quiz results by email and/or displayed on our Site
- Free consultation calls with a member of our advisory team to discuss your shortlist
- General information about the Sydney new apartment market
1.2 Nature of our services — not financial or legal advice
Our services are informational and referral-based in nature. Nothing on our Site, in your quiz results, or discussed during a consultation constitutes:
- Financial product advice within the meaning of the Corporations Act 2001 (Cth)
- Legal advice
- Formal buyer’s agent services unless separately agreed in writing
- A guarantee of investment returns, rental yield, or capital growth
You should seek independent financial, legal, and property advice before making any property purchase decision. We strongly recommend engaging a licensed conveyancer or solicitor, and a qualified financial adviser, before exchanging contracts on any property.
| ⚠️ LEGAL REVIEW REQUIRED This clause is critical. If your service model evolves to include formal buyer’s agent services (representing a buyer under an agency agreement), you will need a real estate licence in NSW and these terms will need to be substantially updated. Your solicitor should confirm whether your current service model requires any licence or registration. |
1.3 No developer relationship
We are not agents of, or affiliated with, any property developer whose developments may appear in your quiz results or be discussed in a consultation. We do not receive commissions, referral fees, or any other remuneration from developers in exchange for including their developments in our matching results.
| ⚠️ LEGAL REVIEW REQUIRED If this changes — for example, if you enter a referral or marketing agreement with any developer — this clause must be updated immediately and appropriate disclosure obligations under NSW fair trading and consumer law will apply. Take legal advice before entering any such arrangement. |
2. Use of Our Site
2.1 Eligibility
Our Site and services are intended for adults aged 18 years or over who are residents of Australia. By using our Site, you represent that you meet these requirements.
2.2 Permitted use
You may use our Site for personal, non-commercial purposes in accordance with these Terms. You agree not to:
- Use our Site in any way that is unlawful, fraudulent, or harmful
- Submit false or misleading information in quiz responses or lead capture forms
- Attempt to gain unauthorised access to any part of our Site or its underlying systems
- Use automated means (bots, scrapers) to access or extract content from our Site
- Reproduce, distribute, or commercially exploit any content on our Site without our written consent
2.3 Account and quiz submissions
We do not currently operate a user account system. Quiz submissions are associated with the email address you provide. You are responsible for ensuring the contact details you provide are accurate.
3. Quiz Results and Shortlist
3.1 How matches are generated
Your quiz results and shortlist are generated based on the information you provide in the quiz. Results reflect our assessment of which developments in our database may align with your stated preferences at the time the quiz is completed.
Shortlists are a starting point for conversation, not a definitive recommendation. Developments included in your shortlist have not been independently assessed against your personal financial position, borrowing capacity, or specific legal circumstances.
3.2 Accuracy and currency
We take reasonable steps to ensure the information in our development database is accurate and current. However:
- Development availability, pricing, and specifications change frequently
- Information provided in quiz results reflects our database at the time of generation
- We do not guarantee that any development shown in your results will be available, at the price indicated, or will proceed to completion
- You should independently verify all material information about any development before making a purchase decision
3.3 No obligation on either party
Receiving a shortlist does not create any obligation on you to proceed with a consultation or a purchase. Providing you with a shortlist does not create any obligation on us to continue to provide services, or to update your results if our database changes after your quiz is completed.
4. Consultations
4.1 Free initial consultations
We offer free initial consultations of up to 15 to 20 minutes in duration. These consultations are conducted by phone or video call and are intended to discuss your shortlisted results and answer general questions about the developments or the purchasing process.
4.2 Conduct of consultations
Our consultants will:
- Review your quiz results before the call where possible
- Provide honest, impartial guidance about the developments in your shortlist
- Not pressure you to make any purchasing decision
- Disclose any relevant information about our relationships with developers if asked
Consultations are not recorded without your prior consent.
4.3 Cancellations and rescheduling
You may cancel or reschedule a booked consultation at any time via the booking platform link provided in your confirmation email. We ask that you provide at least 24 hours’ notice where possible, as a courtesy to our team.
4.4 Limitations
During a consultation, our advisors will not:
- Provide formal financial advice or model your personal financial position
- Provide legal advice about contracts or title
- Commit to any specific price, yield, or outcome on behalf of a developer
- Act as your buyer’s agent unless a separate written agreement is in place
5. Intellectual Property
All content on our Site, including but not limited to text, graphics, quiz logic, matching algorithms, development descriptions, and the shortlist format, is owned by or licensed to [Company Name] and is protected by Australian copyright law.
You may not reproduce, modify, distribute, or create derivative works from any content on our Site without our prior written consent.
6. Disclaimer of Warranties
To the maximum extent permitted by Australian law:
- Our Site and services are provided “as is” and “as available” without any warranty of any kind
- We do not warrant that our Site will be uninterrupted, error-free, or free of viruses or other harmful components
- We do not warrant the accuracy, completeness, or suitability of any information on our Site for your particular purposes
Nothing in these Terms excludes, restricts, or modifies any consumer guarantee or right that you may have under the Australian Consumer Law that cannot be excluded by agreement.
7. Limitation of Liability
To the maximum extent permitted by law, [Company Name] and its officers, employees, and contractors will not be liable to you for any loss or damage (including loss of profit, loss of data, or indirect or consequential loss) arising from:
- Your use of, or inability to use, our Site or services
- Any decision you make in reliance on information provided through our Site, quiz results, or consultation
- Any inaccuracy or change in information relating to a development included in your shortlist
- Unauthorised access to or alteration of your data
Where our liability cannot be excluded, it is limited to the re-supply of the relevant services.
| ⚠️ LEGAL REVIEW REQUIRED Limitation of liability clauses are regularly reviewed by Australian courts and their enforceability depends heavily on the specific circumstances. Your solicitor should review this section carefully, particularly in the context of the Australian Consumer Law and any applicable industry regulations. |
8. Indemnity
You agree to indemnify and hold harmless [Company Name] and its officers, employees, and contractors from any claims, damages, losses, or expenses (including legal fees) arising from:
- Your breach of these Terms
- Your misuse of our Site or services
- Any false or misleading information you provide through our Site
9. Third-Party Platforms and Links
Our Site integrates with or links to third-party platforms including Calendly (booking), [email marketing platform], and property developer websites. These platforms are governed by their own terms of service and privacy policies.
We are not responsible for the content, availability, or practices of any third-party platform. Any transaction or interaction you enter into with a third party is solely between you and that party.
10. Termination
We reserve the right to suspend or terminate your access to our Site or services at any time and for any reason, including if we reasonably believe you have breached these Terms.
Provisions of these Terms that by their nature should survive termination (including intellectual property, limitation of liability, and indemnity) will continue to apply after termination.
11. Governing Law
These Terms are governed by the laws of New South Wales, Australia. You submit to the non-exclusive jurisdiction of the courts of New South Wales.
12. Changes to These Terms
We may update these Terms from time to time. We will indicate the date of the most recent update at the top of this page. Continued use of our Site after any changes constitutes your acceptance of the revised Terms.
For material changes, we will take reasonable steps to notify registered users by email.
13. Contact
For questions about these Terms, please contact:
[Company Name]
[ABN]
[Street Address, Suburb NSW XXXX]
[legal@yourwebsite.com.au]
APPENDIX A
Cookie & Tracking Disclosure
Last updated: [DATE] · Part of Privacy Policy v1.0
This disclosure explains what cookies and tracking technologies we use on [yourwebsite.com.au], what they do, and how you can manage your preferences.
A1. What Are Cookies?
Cookies are small text files placed on your device when you visit a website. They are widely used to make websites work more efficiently and to provide information to the website operator. Cookies do not give us access to your computer or personal files.
A2. What We Use
| Cookie / Tool | Provider | Purpose | Can You Opt Out? |
| Session cookie | Our Site | Keeps you logged in during a quiz session. Expires when you close your browser. | No — strictly necessary |
| Analytics (_ga, _gid) | Google Analytics | Tracks page views, session duration, and traffic sources. Data is anonymised and aggregated. | Yes — via cookie banner or browser settings |
| Meta Pixel | Meta (Facebook/Instagram) | Records website visits from users who clicked our ads. Used for ad performance measurement and retargeting. | Yes — via cookie banner or Meta ad settings |
| Google Ads tag | Records conversions from Google ad clicks. Used to measure ad effectiveness. | Yes — via cookie banner or Google ad settings | |
| Calendly embed | Calendly, Inc. | Set when you interact with our booking widget. Governed by Calendly’s own cookie policy. | Yes — do not use the booking widget |
| [Email platform] tracking pixel | [Mailchimp / ActiveCampaign] | Placed in emails we send you. Tracks whether emails are opened and links clicked. | Yes — unsubscribe from emails |
A3. Cookie Consent
When you first visit our Site, you will be presented with a cookie consent banner. You may:
- Accept all cookies — enables analytics, advertising, and functional cookies
- Reject non-essential cookies — only strictly necessary session cookies will be set
- Manage preferences — choose which categories of cookies to enable
Your preference is stored in a cookie for [12 months / specify]. You can change your preferences at any time by clicking the “Manage cookies” link in our Site footer.
| ⚠️ LEGAL REVIEW REQUIRED You must implement a functional cookie consent management platform (CMP) before launch — for example, Cookiebot, Osano, or a custom solution. The banner must block all non-essential tracking scripts until consent is given. Google Analytics, Meta Pixel, and ad tracking scripts must not fire on page load before consent is obtained. This is a requirement for compliance with the Australian Privacy Act and international standards (GDPR and UK GDPR apply if any users access your site from those jurisdictions). |
A4. Do Not Track
Some browsers allow you to set a “Do Not Track” signal. Our Site does not currently respond to Do Not Track signals. Managing your cookie preferences via our consent banner is the most effective way to control tracking on our Site.
A5. Managing Cookies in Your Browser
You can control and delete cookies through your browser settings. Note that disabling cookies may affect the functionality of our Site and other websites. For guidance on managing cookies in your browser, visit:
- Google Chrome: support.google.com/chrome/answer/95647
- Safari: support.apple.com/en-au/guide/safari/sfri11471
- Firefox: support.mozilla.org/en-US/kb/enable-and-disable-cookies
- Microsoft Edge: support.microsoft.com/en-us/windows/manage-cookies
A6. Third-Party Advertising
We use Meta Pixel and Google Ads tags to measure the effectiveness of our advertising campaigns and to show relevant ads to people who have visited our Site (retargeting). This means that after visiting our Site, you may see our ads on Facebook, Instagram, or Google.
To opt out of interest-based advertising:
- Facebook/Instagram: facebook.com/ads/preferences
- Google: adssettings.google.com
- Industry opt-out: youronlinechoices.com.au (Australian Digital Advertising Alliance)
| Pre-Publication Checklist — Legal Review Before publishing these documents, confirm the following with your solicitor: - All [PLACEHOLDER] fields have been completed with accurate company details - Strapi hosting provider and data residency location confirmed — cross-border disclosure obligations assessed - Email marketing platform identified and its sub-processor status documented - Licensing position confirmed — no licence required for current service model, or appropriate licence obtained - Developer relationship policy confirmed — referral fee or commission arrangements (if any) are disclosed - Cookie consent management platform implemented and tested before go-live - Tracking scripts confirmed not to fire before cookie consent is given - Privacy Policy linked from all lead capture forms and quiz entry points - Both documents linked in site footer - Email unsubscribe mechanism tested and functional - Data retention policy implemented in Strapi (automated deletion or review process in place) - Staff briefed on how to handle access, correction, and deletion requests |