Introduction

Blackfox Property Group Pty Ltd (“Blackfox Property”, “we”, “us”, or “our”) is a privately owned Australian business engaged in property development, investment, and funds management.

The group comprises Blackfox Property Group Pty Ltd (ABN 24 669 267 789), the holder of Australian Financial Services Licence No. 477413, together with its related and associated entities (collectively referred to as Blackfox Property).

This Privacy Policy applies to all members of the Blackfox Property group, including in their own capacity and as trustee of any trusts or managed investment schemes they operate (each referred to as a Fund).

Throughout this Policy:

• “Blackfox Property”, “we”, “us”, and “our” refer to any entity forming part of the Blackfox Property group, including in its various capacities.
• “you” and “your” refer to any individual with whom we interact — including clients, potential clients, investors, tenants, employees, applicants, suppliers, and users of our website or services.
• Words in the singular include the plural, and vice versa.

Commitment to Privacy

Blackfox Property respects the confidentiality of personalinformation and is committed to handling it responsibly and inaccordance with the Privacy Act 1988 (Cth) (Privacy Act)and the Australian Privacy Principles (APPs).

This Privacy Policy explains how wecollect, store, use, and disclose personal information in connectionwith our operations. It applies to all personal information handledby entities within the Blackfox Property group.

By providing your personalinformation to us, you consent to its collection and handling asdescribed in this Policy.

Collection and Use of Personal Information

We collect personal information in the course of carrying out our business activities and providing our products and services. The type of information collected and the reason for its collection depend on your relationship with us — for example, whether you are an investor, tenant, employee, job applicant, or service provider.

What Is Personal Information?

‘Personal information’ means any information or opinion (whether true or not) about an individual who is identified or reasonably identifiable, regardless of whether the information is recorded in material form.

Information We May Collect

Depending on your dealings with us, we may collect:

• Name, date of birth, contact details, and address
• Identification details required under Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) or other laws relating to verification, taxation, or reporting;
• Evidence supporting classification as a wholesale client or sophisticated investor under the Corporations Act 2001 (Cth)
• Your Tax File Number (if lawfully provided) and banking details;
• Tenancy information, including rental or leasing history;
• Employment application materials such as résumés, references, and qualification details;
• Correspondence and communications with our staff; and
• Any additional information provided during enquiries, applications, or transactions with us.

How We Collect Personal Information

Whenever reasonable and practicable, we collect personal information directly from you. This may occur when you:

• Complete an application or registration form for a product, investment, or tenancy;
• Use our website or social media channels;
• Communicate with our representatives in person, by telephone, email, or post; or
• Participate in marketing or promotional activities we conduct.

We may also receive information about you from third parties such as:

• Financial advisers, brokers, or other intermediaries;
• Your authorised representatives (e.g., executors, administrators, or attorneys);
• Recruitment agencies, referees, or past employers;
• Contractors and outsourced service providers; and
• Any other person you have authorised to provide your information to us.

Storage and Security

All personal information collected by Blackfox Property is storedsecurely, whether in electronic or physical form. We applyappropriate safeguards — including secure servers, restricted useraccess, firewalls, encryption, and password protection — to protectagainst unauthorised access, loss, misuse, or alteration.

We cannot, however, guarantee thesecurity of information transmitted to us via the internet, which isinherently insecure. Any online transmission of information isundertaken at your own risk.

When personal information is nolonger required (and retention is not mandated by law), we will takereasonable steps to securely destroy or de-identify it.

Blackfox Property also complies withthe Notifiable Data Breaches Scheme (Part IIIC of the PrivacyAct). Where a breach occurs that is likely to cause serious harm,affected individuals and the Office of the Australian InformationCommissioner (OAIC) will be notified as required by law.

Why We Collect and Use Personal Information

The reasons for collecting, storing, using, or disclosing your personal information depend on your dealings with us. Generally, we do so to:

• Conduct and manage our property, investment, and funds management business;
• Assess and administer investments or interests in a Fund;
• Verify your identity and satisfy AML/CTF and other statutory obligations;
• Maintain investor and client relationships and respond to enquiries or complaints;
• Provide you with details about our products, services, and opportunities;
• Manage leases, tenancies, or property transactions;
• Consider applications for employment or engagement, and manage employment relationships;
• Undertake administrative, operational, and marketing functions (including direct marketing); and
• Prepare internal and regulatory reports, audits, or compliance documentation.

Disclosure of Personal Information

We may share personal information within the Blackfox Property group and with third parties for legitimate business or legal purposes. These parties may include:

• Service providers involved in the management or administration of our operations, including custodians, registries, IT providers, payment processors, and mail houses;
• Auditors, consultants, and professional advisers such as accountants and lawyers;
• Government agencies and regulators (e.g. ASIC, ATO, AUSTRAC);
• Financial intermediaries including advisers or brokers; and
• Any third party you have authorised us to deal with.

Before disclosing any personal information to another party, we take reasonable steps to ensure that the recipient has appropriate privacy safeguards or that your consent has been obtained.

We may also disclose information to trusted service providers located overseas — including within the United States, the United Kingdom, Israel, and countries of the European Union — where necessary to securely store or process data. In such cases, we ensure equivalent protections are applied consistent with Australian privacy standards, except where otherwise permitted by law or with your consent.

Website and Cookies

Our website uses cookies and similar technologies to enhance user experience, analyse traffic, and improve our services. Cookies are small data files stored on your device when you visit certain webpages.

They may be used for purposes such as:

• Analysing site performance and usage patterns (e.g. through Google Analytics);
• Remembering user preferences and settings;
• Managing website sessions and authentication; and
• Recording user acknowledgements, such as acceptance of terms or policies.

You can disable cookies in your browser settings, though this may limit the functionality of our website.

Direct Marketing

We may from time to time send you information about products or services that we believe may interest you. These communications may be delivered by post, email, or other permitted methods.

You can opt out of receiving marketing material at any time by contacting our Privacy Officer or using the “unsubscribe” option in our emails.

Even if you opt out of marketing communications, we may still send you essential service or account information where required by law.

We do not sell or rent personal information to any third party.

Access and Correction

You may request access to, or correction of, your personal information at any time.

If access is restricted by law, we will explain why.

We endeavour to keep all information accurate and up to date. If you believe any information we hold is inaccurate, incomplete, or outdated, please notify us and we will take reasonable steps to correct it.

If we disagree with your requested amendment, we will note your statement of disagreement in our records.

Requests should be directed to our Privacy Officer (contact details below).

Privacy Complaints

If you believe we have breached this Policy or the APPs, you may lodge a written complaint with our Privacy Officer, providing relevant details and any supporting evidence.

We will investigate your complaint and respond in writing, generally within 30 days.

If you remain dissatisfied, you may refer the matter to the Office of the Australian Information Commissioner (OAIC). Further information is available at www.oaic.gov.au/privacy/privacy-complaints.

Obtaining a Copy of This Policy

The most current version of this Privacy Policy is available free of charge on our website at www.blackfoxproperty.com.

You may also request a printed or alternative-format copy at no cost.

Contact Details

Privacy Officer
Blackfox Property
Level 4, 2 Bligh Street
Sydney NSW 2000
Email: info@blackfoxproperty.com

Last Updated: October 2025