Privacy Policy

Emerald Developments Pty Ltd (ABN 68 640 151 533) trading as EM Developments

Emerald Properties Qld Pty Ltd (ABN 86 650 541 932)

Effective date: 8 October 2026

1. Introduction

1.1 This Privacy Policy applies to Emerald Developments Pty Ltd (ABN 68 640 151 533) and Emerald Properties Qld Pty Ltd (ABN 86 650 541 932) (together, Emerald, we, us or our).

1.2 We are bound by the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs). This Privacy Policy sets out how we collect, hold, use and disclose personal information, and how you may access and seek correction of personal information we hold about you or make a complaint.

1.3 In this Privacy Policy, personal information has the meaning given in the Privacy Act, and means information or an opinion about an identified individual, or an individual who is reasonably identifiable.

1.4 This Privacy Policy applies to personal information we collect about prospective and current clients and purchasers, visitors to our display homes and website, persons referred to us by our sales partners, the representatives of our trades, suppliers, consultants and partners, and job applicants. It does not apply to employee records, the handling of which is exempt under the Privacy Act.

2. Kinds of personal information we collect and hold

2.1 The kinds of personal information we collect and hold depend on the nature of your dealings with us, and may include:

(a) identification and contact details, including your name, address, telephone number and email address;
(b) details of your land and property, including title, lot and site information;
(c) information relating to your home, including designs, plans, selections, tenders, contracts, variations, construction progress, inspections, handover and maintenance requests;
(d) financial information, including details of your lender or broker, finance approval, deposits, payments and bank account details for the purpose of refunds;
(e) identity verification information, including your date of birth and identification documents, where required by law or for the purposes of a transaction;
(f) records of our communications with you, including correspondence, notes of conversations and recordings and transcripts of telephone calls and meetings;
(g) feedback, survey responses, reviews and complaints;
(h) photographs of your site and home taken during construction;
(i) information collected through our website, as described in clause 11; and
(j) in the case of job applicants, employment history, qualifications, referee details and interview notes.

2.2 We do not generally collect sensitive information (as defined in the Privacy Act). Where you provide sensitive information to us, for example health information relevant to the design of your home, we will collect, use and disclose it only with your consent and for the purpose for which it was provided, or as otherwise permitted by law.

3. How we collect personal information

3.1 We collect personal information directly from you where reasonable and practicable, including when you submit an enquiry through our website, communicate with us by telephone, email or other means, visit a display home, meet with our representatives, enter into a contract with us or respond to a survey.

3.2 We may also collect personal information from third parties, including sales partners, real estate agents and land developers who refer you to us, your co-purchaser, solicitor, conveyancer, lender or broker, building certifiers, engineers, surveyors, local councils and utility providers, and publicly available sources such as title searches and property reports.

3.3 Where we receive unsolicited personal information, we will determine whether we could have collected it in accordance with the APPs and, if not, will destroy or de-identify it where lawful and reasonable to do so.

3.4 Where lawful and practicable, you may deal with us anonymously or by using a pseudonym, for example when making a general enquiry. However, we are unable to provide quotations, enter into contracts or construct homes for individuals who do not identify themselves.

4. Call and meeting recordings

4.1 Telephone calls to and from Emerald may be recorded, and recordings may be transcribed and summarised, for quality, training, record-keeping and customer service purposes.

4.2 Where a call or meeting is recorded, we will take reasonable steps to notify you. If you do not wish to be recorded, please advise us and we will make alternative arrangements.

5. Purposes for which we collect, hold, use and disclose personal information

5.1 We collect, hold, use and disclose personal information for the purposes of:

(a) responding to enquiries and preparing designs, quotations, tenders and contracts;
(b) assessing land and site conditions relevant to the design and price of a home;
(c) constructing homes, including engaging trades and suppliers and arranging inspections, approvals and utility connections;
(d) communicating with you during construction, at handover and in relation to maintenance and warranty matters;
(e) processing payments, invoices and refunds;
(f) verifying your identity where required by law or for the purposes of a transaction;
(g) complying with our legal and regulatory obligations, including under building, home warranty insurance, taxation and anti-money laundering laws;
(h) administering our arrangements with sales partners and agents;
(i) obtaining feedback and improving our homes and services;
(j) direct marketing, subject to clause 10;
(k) assessing job applications; and
(l) establishing, exercising or defending legal claims.

5.2 We will not use or disclose personal information for a secondary purpose unless you have consented, you would reasonably expect us to do so and the secondary purpose is related to the primary purpose of collection, or the use or disclosure is otherwise required or authorised by law.

6. Use of technology and artificial intelligence

6.1 We use third-party cloud-based software and services to operate our business, including for email and document management, customer relationship management, accounting, telephony and construction management.

6.2 Some of these services include artificial intelligence (AI) functionality. We may use AI tools to assist our personnel to summarise correspondence, calls and meetings, prepare draft documents and communications, locate and verify information within our records, and prepare reports.

6.3 We use AI tools subject to the following safeguards:

(a) outputs generated by AI tools are reviewed by our personnel before they are relied upon or provided to you;
(b) we use business versions of these services under commercial terms, and we select services and settings that do not permit the provider to use personal information to train its AI models.
(c) access to personal information is restricted to personnel who require it to perform their duties;
(d) our personnel are required to comply with our internal AI Use Policy, which prohibits the entry of client information into public or personal AI tools; and
(e) our information technology systems and cyber security are managed by a specialist external IT provider, and our systems are protected by business-grade firewalls.

Automated decision-making

6.4 We do not make decisions that could reasonably be expected to significantly affect your rights or interests solely by the operation of a computer program.

6.5 Computer programs, including AI, may be used to perform tasks that are substantially and directly related to the following kinds of decisions, which are made by our personnel:

Kind of decision	Kinds of personal information used
Construction requirements for a home on a particular lot (such as bushfire or flood requirements), which may affect the price	The address and lot details of your land
Whether your identity has been verified before a property sale proceeds	Your name, date of birth, address and identification documents
The prioritisation and allocation of enquiries and requests	Your contact details and the content of your communication

7. Disclosure of personal information

7.1 We may disclose personal information, to the extent reasonably necessary for the purposes set out in clause 5, to:

(a) trades, suppliers and consultants engaged in the construction of your home;
(b) building certifiers, engineers, surveyors, designers and drafters;
(c) local councils, the Queensland Building and Construction Commission (QBCC), including in connection with the Queensland Home Warranty Scheme, and utility providers;
(d) your lender, broker, valuer, solicitor or conveyancer, with your authority;
(e) the sales partner, agent or land developer who referred you to us, limited to information reasonably required in relation to your purchase or construction;
(f) our insurers, accountants, auditors, legal advisers and other professional advisers;
(g) the providers of the information technology services referred to in clause 6;
(h) government agencies, regulators, courts and law enforcement bodies, where required or authorised by law; and
(i) a prospective purchaser of all or part of our business, subject to an obligation of confidentiality.

7.2 We do not sell personal information, and we do not disclose personal information to third parties for their own marketing purposes.

8. Cross-border disclosure

8.1 Some of the service providers referred to in clause 6 store or process personal information outside Australia, or have personnel located outside Australia who may access it.

8.2 The countries in which such recipients are likely to be located include the United States, Singapore, Japan, New Zealand, Canada, Ireland, Germany and other member states of the European Union, the United Kingdom and the Philippines.

8.3 Before disclosing personal information to an overseas recipient, we take reasonable steps to ensure that the recipient does not breach the APPs in relation to that information, including through contractual terms and security commitments.

9. Security, retention and data breaches

9.1 We take reasonable steps to protect the personal information we hold from misuse, interference and loss, and from unauthorised access, modification and disclosure. These steps include IT and cyber security management by a specialist external provider, business-grade firewalls, individual user accounts with role-based access controls, the use of reputable cloud service providers that employ encryption, staff training and internal policies, and security assessments of service providers.

9.2 We retain personal information for as long as it is required for the purposes for which it was collected and as required by law, including building records for the applicable statutory warranty periods and financial records for the periods required by taxation law. Personal information that is no longer required is destroyed or de-identified.

9.3 In the event of an eligible data breach, we will notify affected individuals and the Office of the Australian Information Commissioner in accordance with the Notifiable Data Breaches scheme under the Privacy Act.

9.4 Emerald will never notify you of a change to our bank account details by email. If you receive a request to make payment to a different account, please contact us on (07) 3048 3808 before making any payment.

10. Direct marketing

10.1 We may use your personal information to send you information about our homes, offers and services by email, SMS, telephone or post, where permitted by law.

10.2 You may opt out of receiving direct marketing communications at any time by using the unsubscribe facility included in each electronic marketing message or by contacting us. Communications relating to your enquiry, contract or construction are not direct marketing and will continue.

11. Website, cookies and analytics

11.1 When you visit our website, we and our service providers may collect information such as your IP address, browser and device type, pages viewed and referring website.

11.2 Our website uses cookies and similar technologies provided by third parties, including Google (Google Analytics, Google Tag Manager and reCAPTCHA), HubSpot and Meta Platforms (Facebook and Instagram), for the purposes of website analytics, connecting form submissions with our customer records, measuring and delivering advertising, and preventing spam.

11.3 You may disable or delete cookies through your browser settings, although some features of our website may not function correctly as a result. You may manage your advertising preferences through your Google and Meta account settings.

11.4 Our website may contain links to third-party websites. We are not responsible for the privacy practices of those websites.

12. Access and correction

12.1 You may request access to the personal information we hold about you, and request the correction of personal information that is inaccurate, out of date, incomplete, irrelevant or misleading, by contacting our Privacy Officer.

12.2 We do not charge for making a request. Where providing access involves significant cost, we may charge a reasonable fee, of which we will notify you in advance. We do not charge for correcting personal information.

12.3 We will respond to requests within a reasonable period, generally within 30 days, and may require you to verify your identity.

12.4 We may refuse access or correction in circumstances permitted by the Privacy Act. If we do so, we will provide written reasons and details of how you may complain.

13. Complaints and contact details

13.1 Questions and complaints about our handling of personal information should be directed in writing to:

Privacy Officer

Emerald Developments Pty Ltd

PO Box 346, Burpengary QLD 4505

Email: admin@emdevelopments.com.au (marked “Attention: Privacy Officer”)

Telephone: (07) 3048 3808

13.2 We will acknowledge and investigate your complaint and provide a written response within 30 days.

13.3 If you are not satisfied with our response, or we have not responded within 30 days, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au, by telephone on 1300 363 992, or by post to GPO Box 5288, Sydney NSW 2001.

14. Changes to this Privacy Policy

14.1 We may amend this Privacy Policy from time to time. The current version will be published on our website and will take effect from the effective date stated above.