Privacy Statement


19th August 2025

“PRIVACY STATEMENT “- TIERRA WEBSITE

Our Policy Statement

This Privacy Policy (“Policy”) explains how Tierra Management Pty Ltd (ABN 50 680 261 054), our related companies and trusts (“Tierra group”, “we”, “our” or “us”) collect, store, use, disclose and manage your personal information.

Purpose

Tierra group is committed to conducting our business in line with our core values and business best practice.

Tierra group is committed to protecting and maintaining the privacy of your personal information. Information collected is handled in accordance with Australian privacy laws and regulations, in particular, the Privacy Act, and is retained in accordance with legislated retention requirements.

Tierra group is a diversified group and our key business activities include:

  • Property development;
  • Construction services;
  • Investment in residential communities
  • Investment in financial instruments

 

What personal information do we collect?

The types of personal information Tierra group collects about you will depend on the nature of your interactions with us. In this Policy, “personal information” has the meaning given to it in the Privacy Act and includes any information or opinion, whether true or not, about an identified individual or an individual who is reasonably identifiable.

We may collect the following types of personal information:

  • information to verify your identity including your name, date of birth, gender, address, email address, telephone number or government issued identification documents;
  • financial information including bank accounts, credit card details, your income and third party sourced credit checks;
  • employment application including employment history, referee contact details, tax file number and tax related information and other information provided as part of our recruitment and employee on-boarding process;
  • your preference of our products, services, and construction activities;
  • information about you and your family and any characteristics, preferences or requirements that are relevant to the products and services that we may provide to you;
  • your image and/or voice and other personal information (such as your car licence plate) collected via CCTV or Body Worn Camera (BWC) surveillance systems installed in our residential communities or carparks or via the use of community vehicles with built in cameras, tracking and vehicle data devices;
  • your device ID, device type, geo-location information, IP address, browsing information and any personal information provided directly or indirectly via our websites, Wi-Fi services, mobile applications; any additional personal information required to facilitate your dealings with us

how do we collect sensitive information?

We may also, where you have provided your consent, collect, hold or provide to third parties your sensitive information. Sensitive information is a subset of personal information which includes but is not limited to your race or country of origin, political or religious beliefs, sexual preferences, criminal records or health information. Sensitive information is subject to a higher level of privacy protection than Personal Information.

Sensitive information that may be collected by Tierra includes:

  • medical information and contact information if you are involved in an accident or incident at one of our assets;
  • health related requirements, including life support equipment if you reside in a Tierra residential community and have;
  • health related requirements that includes a disability that needs to be accommodated in the workplace in relation to you working with (or applying to work with) Tierra;
  • CCTV and BWC footage that may contain sensitive information, and as such its use and release is governed by additional policies, this is covered in more detail in the section Access, Correction and Deletion of Personal Information.

How is personal information collected?

We will generally collect personal information when you:

  • communicate or interact with us either directly or indirectly, including by phone, email, face to face or online meetings, online or social media interaction;
  • use our websites or applications;
  • participate in our surveys, competitions, loyalty programs or promotions;
  • visit our residential communities, workplace, construction sites or carparks through our CCTV systems, vehicle with built in cameras, tracking and vehicle data devices provided by Tierra or connect to Tierra provided wi-fi services;
  • apply for a position with us through our recruitment process; or
  • apply for hardship as a Homeowner in a Tierra residential community

We may also collect your personal information from third parties such as:

  • marketing agencies, data collection and research organisations;
  • medical professionals (for example if you are involved in an accident);
  • credit reporting bodies, law enforcement and government entities; or
  • other individuals (for example employment references).

What happens if Tierra cannot collect personal information?

You are not required to provide us with your personal information. If you wish to remain anonymous or decide not to provide personal information, we may not be able to provide or tailor our products, services or information to you, either to the same standard or at all (for example certain functions of our website may not function properly if you disable cookies).

Why do we collect, store, use and disclose personal information?

Personal information you provide to Tierra will be used by authorised employees and/or third parties to conduct Tierra business and for the purposes necessary to complete the enquiry or service. Tierra will not use the information for other reasons than for the purpose it was collected, except where we have obtained your consent to use the information for another purpose, or it is reasonably expected that we may use the information for another purpose notified to you or where required and authorised by law.

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

  • to provide and market our products and services;
  • to communicate with you;
  • to do business with you;
  • for the general management and conduct of our business;
  • to comply with our legal obligations;
  • to investigate incidents (including potential incidents) which occur on or at our premises;
  • to consider the suitability of prospective employees;
  • for security and risk management purposes;
  • to help manage, develop and enhance our services, including our websites, Wi-Fi networks and applications;
  • to assess your eligibility for hardship requests in a Tierra residential community.

Who does Tierra disclose personal information to?

We may disclose your personal information (including in some circumstances, your sensitive information) for the purposes for which it was collected or related purposes (as described above) to:

  • social media channels on which we have a presence such as Facebook (also known as Meta), X (formally known as Twitter) and Instagram (generally in these cases we limit disclosure of your personal information to your first name and surname);
  • regulatory authorities, police or government agencies or bodies where required by law;
  • related parties, entities and trusts of Tierra;
  • other companies, service providers and individuals who assist us in providing our services or managing our operations;
  • electricity distributors, electricity retailers, or our embedded network managers who perform functions to assist us to meet our legislative obligations.

If any Tierra entity or asset is sold to a third party, we may transfer personal information we hold about you to that third party. We may also disclose personal information on a confidential basis to prospective purchasers of a Tierra entity.

Where we have disclosed personal information to a third party acting on our behalf, we request that those third parties do not use the personal information for their own purposes and that they comply with the Privacy Act and this Policy.

CCTV and BWC surveillance Systems

We use CCTV and BWC surveillance systems to monitor and record activities at Tierra properties and premises including our workplace, construction sites and residential communities. CCTV and BWC are used to assist in maintaining a safe and secure environment for our employees, customers and visitors to our assets.

We may use your images gathered from CCTV and BWC for security and risk management, loss prevention, incident investigation and other purposes set out in this Policy, or as permitted by the law.

We also use the data collected from our CCTV surveillance systems to maintain or improve our properties, premises and services. We may do this by:

  • collecting and analysing customer behaviour;
  • monitoring patterns of foot traffic;
  • analysing shopper demographics and browsing habits.

When used for these purposes the data is aggregated anonymously. We do not identify individuals for these uses.

We securely discard the data and images collected from our CCTV and BWC surveillance systems when it is no longer required for business or legal purposes.

Wi-Fi and Bluetooth services

We offer a free Wi-Fi network and third-party applications using Tierra’s infrastructure (including Bluetooth beacon networks) service at certain Tierra premises.

If you are carrying a Wi-Fi and/or Bluetooth enabled device within range of one of our Wi-Fi networks or infrastructure, we may collect technical identity data that is transmitted from your device including whether or not you join our Wi-Fi network, including:

  • your device ID, device type, IP address and MAC address;
  • geo-location information and any movement of your device throughout our premises;
  • any other information which you may voluntarily provide, while accessing our Wi-Fi networks, for example, your name, email address, the details of the websites or mobile applications whilst you are connected to our network or infrastructure.
  • We may link this information to other personal information we hold about you such as your unique device identifier.
  • We will only use information or data collected via our free Wi-Fi network service or third-party applications using Tierra’s infrastructure in accordance with, and for the purposes set out in this Policy, or as permitted by the law.
  • If you do not want your personal information collected, you can disable Wi-Fi and Bluetooth on your device or should not sign into the Wi-Fi network.

Direct marketing communications

We and/or our third-party service providers may send you direct marketing communications and information about:

  • offers or promotions based on how you use our products and services;
  • third party products and services including offers and discounts that may interest you.
  • Direct marketing communications may be sent in various forms, including by telephone, post, email, SMS, via social media or any other form of electronic communication, in accordance with the Privacy Act and the Spam Act 2003 (Cth). By providing us with your contact details you consent to Tierra and/or third-party service providers we engage, sending you electronic marketing communications described above.

Opting out of marketing communications

If at any stage you no longer wish to receive marketing communications, you may opt-out/unsubscribe from specific or all direct marketing communications by following the instructions in the communication (for example the unsubscribe link), or in the case of Tierra, by contacting our Privacy Officer using the contact details below.

In some situations, for example if we are providing services to you, we may still be required to make certain communications to you in connection with providing the services or products to you or as required by law.

Overseas disclosure of personal information

We may disclose your personal information to the following overseas recipients:

  • companies and service providers who assist us in providing services or perform functions on our behalf, including hosting and data storage providers, analytics platforms, and partners involved in the delivery and improvement of our offerings.

We carefully select these organisations to ensure they meet our standards for data protection and privacy compliance.

We will take reasonable steps to ensure overseas recipients use personal information for its intended purpose, comply with the Australian Privacy Act and this Policy.

Cookies, Website Analytics and other technologies

Cookies are text files with small pieces of data that our website places onto your device to remember or track information about your interaction with our website (usually in the browser software folder). The type of information that may be collected while visiting our website, including those cookies provided by third parties, includes:

  • the date and time you visited our website;
  • the pages you viewed and how long you viewed those pages;
  • general location information;
  • information about the type of device you used to visit our website;
  • the IP address automatically assigned by your internet service provider to the device you used to visit our website.

The information stored by Tierra cookies may be used to offer our products and services directly to you and distinguish you from other users to better serve you when you revisit our website. Third-party cookies may also be used for login status, targeted marketing, or playing embedded media. The data may be used to infer demographic information about you by using various web analytic technologies or performance tracking technologies (such as conversion tags, heatmap user website journey, and monitoring of user uploads via a site page or downloadable media) to help Tierra track your behaviour on our websites. The information collected may also be used for general user traffic and performance on an aggregate level to report statistics to assist Tierra in improving the quality and relevancy of its services and delivering relevant marketing material on Tierra’s website or partner sites.

All references within our website, cookies, analytics, or tracking platforms should be understood as applying to Tierra. Whenever you encounter mentions of data collection, management, or user privacy in connection with our online services, these pertain specifically to Tierra’s digital environment and operational practices. Our ongoing commitment is to safeguard your information while enhancing your experience and maintaining compliance with relevant privacy regulations.

You can set your browser to notify you when cookies are used.  This provides you with the opportunity to accept or reject requests to place cookies on your device.  You can reject all cookies by turning them off in your browser.  However, if you do this, certain parts of our website may not function properly. Tierra also uses Meta’s Conversions API (CAPI) to track user interactions on our website. CAPI allows us to send your personal de-identified information and information collected same as cookies from our website directly to Meta’s servers, ensuring accurate conversion tracking while prioritizing user privacy. The data collected through CAPI may include user interactions such as, but not limited to, purchases, registrations, page views and content downloads.

If you do not wish to have your interactions tracked via CAPI, you can manage and change your privacy settings through your Meta account.

Tierra websites use Google suites of analytics programs to track website traffic. Where you have enabled Google to associate your web and app browsing history with your Google account, and to use the information from your Google account to personalise ads, Google will use data from its signed-in users together with Tierra’s Google Analytics data to build an audience lists for cross-device remarketing. For users of Tierra website, Google Analytics will collect Google-authenticated identifiers associated with your Google accounts (therefore personal information). Google analytics will also temporarily join these identifiers to Tierra’s Google Analytics data.

If you do not wish to have your Google-authenticated identifiers joined with Tierra’s Google Analytics data, you should opt out of the ‘personalised ads’ option via your Google account.

Tierra may also use Artificial Intelligence (AI) systems or tools within our business operations. This includes AI created in house and hosted by third parties. When utilising AI technologies, we may include the following types of information:

  • Anonymised Data: Data that has been stripped of personally identifiable information to protect individual privacy to issue reports and statistics for relevant business operations;
  • Operational Data: Non-sensitive business data that supports operational processes;
  • Customer Interactions: Information related to customer queries, feedback, and interactions, provided it is anonymised, or consent is obtained.

We handle personal information collected by cookies, website analytics and other technologies in the same way that we handle all other personal information as described in this Policy.

Security of personal information

We implement various security measures—including physical, administrative, personnel, and technical safeguards—to protect personal information. Nevertheless, the open nature of the internet means there is always a risk of unauthorised access, and absolute security cannot be guaranteed. Additionally, e-mail communications are typically not encrypted and should not be regarded as secure.

We take reasonable steps to destroy or de-identify personal information when it is no longer needed for business or legal purposes. If required by applicable law, we will notify you and, where relevant, the Office of the Australian Information Commissioner or other regulatory authorities in the event of a data breach affecting your personal information.

Our websites and mobile applications may contain links to sites owned and operated by other organisations. When you follow one of these links, you are leaving our site. Unless otherwise stated, we are not responsible for the privacy practices or content of those linked websites. We encourage you to review the privacy policies and terms of any external sites, as they may differ from our Policy. For privacy concerns regarding those sites, please contact the relevant website providers directly.

Should you wish to access, correct, or delete your personal information that we hold, you may contact our Privacy Officer using the details provided below. Depending on your request, we may ask for additional information to verify your identity and may require the request to be made in writing.

There may be circumstances where we cannot provide access to, or delete, certain personal information. This may occur if a legal exemption applies, or where such disclosure would interfere with the privacy of others or breach a duty of confidentiality.

We may keep your personal information in electronic or hard copy form. We take reasonable steps to protect it from misuse, loss, unauthorised access, modification, or disclosure.

Various security measures, including physical, administrative, personnel, and technical safeguards, are used to protect personal information. Due to the open nature of the internet, there is a risk of unauthorised access, and complete security of personal information cannot be ensured. In addition, e-mail communications are generally not encrypted and should not be regarded as secure.

Personal information will be destroyed or de-identified when it is no longer needed for business or legal purposes.

We will notify you and relevant authorities of data breaches involving your personal information, as required by law.

Third Party Links

Our websites and apps may link to external sites. We are not responsible for their privacy practices or content unless stated. Please review their privacy policies, as they may differ from ours, and contact those sites directly with any concerns.

Access, correction and deletion of personal information

To access, correct, or delete your personal information, contact our Privacy Officer using the details below. We may need additional information to verify your identity and may require a written request. In some cases, we may not be able to provide access to or delete certain information, for example,

  • if a legal exemption applies,
  • or where granting access would interfere with the privacy of others or result in a breach of confidentiality, or
  • where we are required to retain or cannot delete the information for legal or if your request is refused, we’ll provide written reasons unless prohibited by law to do so.

When requesting Access to CCTV footage we follow our corporate procedure developed to conform with the Privacy Act; which governs our use and release of CCTV footage.  We may be unable to release CCTV footage if there is an investigation or pending legal action.

To update or delete your personal information, contact our Privacy Officer at privacy@tierragroup.com.au. If we can’t amend or delete it, we’ll explain in writing and add your disagreement to our records.

There is no charge for accessing, correcting, or deleting personal data, though reasonable costs for providing access may apply.

Complaints and concerns about your privacy

For any questions regarding our handling of personal information, or to submit a complaint about our information management practices, please contact our Privacy Officer:

Email: privacy@tierragroup.com.au

Post:

Privacy Officer

Tierra Group

Suite 15, Level 11,

458 Brunswick Street

Fortitude Valley Qld 4006

The Privacy Officer will acknowledge your complaint and, following investigation, provide you with the outcome—typically in writing—within approximately 30 days, and invite your feedback.

If you are not satisfied with the resolution of your concerns regarding our management of your personal information, you may contact the Office of the Australian Information Commissioner:

Email: enquiries@oaic.gov.au

Phone: 1300 363 992

Post:

Office of the Australian Information Commissioner

GPO Box 5218

Sydney NSW 2000

Further information can be found on the OAIC website at www.oaic.gov.au.

 

Changes to Tierra’s Privacy Policy

We may update our Policy as needed to reflect new laws, technologies, or business practices. The latest version is always available at https://tierragroup.com.au/privacy-statement/; please check regularly for updates.

Effective: 19th August 2025