Effective date: 3/11/2025
1.1 Connect360 is a business-to-business software platform owned and operated by Property Dollar Pty Ltd (ACN 656 650 716) as trustee for The Property Dollar Trust (ABN 25 656 650 716) (Property Dollar, we, us or our). Connect360 is a product of Property Dollar and is not a separate legal entity.
1.2 This Privacy Policy explains how we collect, hold, use and disclose personal information in connection with Connect360, including the Connect360 platform, the website at connect360.com.au and related integrations (together, the Services). It also explains how individuals may access or seek correction of their personal information and how they may make a complaint.
1.3 Property Dollar is bound by the Privacy Act 1988 (Cth) (Privacy Act), including the Australian Privacy Principles (APPs), and handles personal information in accordance with them.
1.4 This Privacy Policy applies only to Connect360. The Property Dollar App is a separate product governed by its own terms and privacy policy, available at propertydollar.com.au/privacy-policy.
1.5 This Privacy Policy should be read together with the Connect360 Terms of Service, including Schedule 1 (Client Data Terms), which sets out our contractual commitments to Broker Users in respect of Client Data.
In this Privacy Policy:
Broker User means a business that holds a Connect360 account, and any individual that business authorises to use the Services.
Client means an individual who is a customer or prospective customer of a Broker User.
Client Data means personal information and other information relating to Clients that a Broker User enters into, uploads to or synchronises with Connect360.
Connected Account means an email account or Connected CRM Platform that a Broker User authorises Connect360 to access.
Connected CRM Platform means a third-party customer relationship management platform integrated with Connect360 at the direction of a Broker User.
Edition means C360 MB or C360 REA, as described in section 3.
3.1 Connect360 is offered in two Editions:
(a) Connect360 Mortgage Brokers (C360 MB), for credit licensees, authorised credit representatives and the businesses they operate or work for. C360 MB processes loan-level information such as lender, loan balance, interest rate, loan-to-value ratio (LVR) and fixed-rate expiry date; and
(b) Connect360 Real Estate (C360 REA), for real estate agents, buyer's agents, property developers and the businesses they operate or work for. C360 REA does not collect, hold or display loan or credit information.
3.2 The Editions operate on logically separated systems. Information entered into one Edition is not accessible from, or synchronised with, the other.
3.3 Connect360 is a tool for Broker Users. Clients do not register for, log in to or otherwise use Connect360.
3.4 Access modes. Connect360 may be accessed as a standalone platform or embedded within a Connected CRM Platform. When a Broker User enables the integration, the Connected CRM Platform provides the business and user details needed to establish the connection, and Connect360 issues secure access tokens that are used to exchange information between the two platforms. In embedded mode, Connect360 can only be accessed by a Broker User who is signed in to the Connected CRM Platform. Where the integration supports it, changes a Broker User makes to Client Data in Connect360 are synchronised back to the Connected CRM Platform, so that the Broker User maintains a single, consistent record.
4.1 Broker User information. In respect of information about Broker Users and their personnel, Property Dollar collects and handles personal information in its own right, in accordance with this Privacy Policy.
4.2 Client Data. In respect of Client Data, Property Dollar acts as a service provider to the Broker User. We hold and use Client Data on behalf of the Broker User and only to provide the Services to that Broker User. The Broker User is responsible for the collection of Client Data, for giving any required collection notices to Clients and for obtaining any consents required under the Privacy Act or other applicable law. We remain bound by the APPs in respect of the Client Data we hold.
4.3 Separation of Client Data. Client Data is not made available to, combined with or used by any other product or business operated by Property Dollar, including the Property Dollar App, except as described in section 4.4. Property Dollar does not use Client Data to originate, refer or arrange credit or any other product or service for itself, any related entity or any third party, and does not contact Clients other than through communications initiated or configured by the Broker User.
4.4 White-label applications. Where a Broker User's organisation subscribes to a white-labelled version of the Property Dollar App, the Broker User may invite a Client to that application from within Connect360. Only the information the Broker User elects to include in the invitation is transferred to the white-labelled application, and only when the Broker User sends the invitation. Once a Client accepts the invitation, the Client's use of the white-labelled application is governed by the terms and privacy policy that apply to that application. Property Dollar will not use information received through an invitation to introduce the Client to any other broker, lender or agent.
5.1 Broker User information. We collect:
(a) name, business name, role, email address, telephone number and business address;
(b) credit licence or authorised credit representative numbers, real estate licence details or other professional accreditation details, where relevant to the Edition;
(c) login credentials and account settings;
(d) billing contact details and records of fees and usage;
(e) business and user details provided by a Connected CRM Platform when a Broker User enables an integration, and the access tokens issued for that integration; and
(f) correspondence and support requests.
5.2 Client Data (C360 MB). Client names and contact details, property details, and loan information including lender, loan balance, interest rate and rate type, LVR and fixed-rate expiry date, entered by the Broker User or synchronised from a Connected CRM Platform.
5.3 Client Data (C360 REA). Client names and contact details, properties of interest, listing and transaction information and relationship notes, entered by the Broker User. C360 REA does not collect loan, credit or lender information and is not connected to any Connected CRM Platform used with C360 MB.
5.4 Connected Account information. Where a Broker User connects an email account, we hold the authentication tokens or credentials required to send email from that account, as described in section 8.
5.5 Communications. Records of emails and SMS messages sent through the Services and, for C360 MB, call summaries described in section 9.
5.6 Property and valuation information. Automated valuation model (AVM) estimates and property attributes obtained from valuation data providers, currently Valocity, CoreLogic and Domain, used to display property values, equity and LVR within the Services. The providers we use may change over time.
5.7 Technical information. IP addresses, browser and device information, and system and audit logs generated when Broker Users access the Services, used for security, troubleshooting and service operation.
5.8 Sensitive information. Connect360 is not designed to hold sensitive information (as defined in the Privacy Act), such as health information. Broker Users should not enter sensitive information into free-text fields unless it is necessary and they are authorised to do so.
6.1 We collect information:
(a) directly from Broker Users, including when they register, configure or use the Services or contact us;
(b) from Connected CRM Platforms, when the Broker User enables an integration and during synchronisation, at the direction and with the authorisation of the Broker User;
(c) from valuation data providers; and
(d) automatically, through system logs and the cookies described in section 6.2.
6.2 The Connect360 platform uses cookies and similar technologies that are necessary for authentication, security and session management. The platform does not use advertising cookies. Broker Users may disable cookies in their browser settings, although the Services may not function without them.
7.1 We use Broker User information to:
(a) establish and administer accounts;
(b) provide, maintain, secure and support the Services;
(c) bill and collect fees;
(d) communicate about the Services, including service notices and changes to our terms;
(e) improve the Services; and
(f) comply with our legal obligations.
7.2 We use Client Data only to provide the Services to the Broker User who supplied it, including portfolio monitoring, identification of repricing and refinance review indicators (C360 MB), automation rules configured by the Broker User, communications initiated by the Broker User, and reporting.
7.3 We may send Broker Users information about Connect360 features and updates. Broker Users may opt out of marketing communications at any time using the unsubscribe facility in each message or by contacting us. We do not send marketing communications to Clients.
7.4 We will not use or disclose personal information for any other purpose unless the individual has consented, or the use or disclosure is required or authorised by law.
8.1 Broker Users may connect a Google (Gmail), Microsoft (Outlook) or custom SMTP email account so that emails sent through Connect360, including invitations, automation rule emails and manually composed emails, are sent from the Broker User's own address.
8.2 Google. Connect360 requests the gmail.send scope only. Connect360 can send email from the connected address to recipients specified by the Broker User. It cannot read, modify or delete messages in the Broker User's mailbox and does not access the content of emails the Broker User receives.
8.3 Microsoft. Connect360 uses Microsoft Graph with the minimum send-only permissions required for the same purpose.
8.4 Custom SMTP. Credentials supplied for a custom email provider are stored in encrypted form and used solely to send email from the Broker User's address using standard SMTP protocols.
8.5 A Broker User may disconnect an email account at any time in Settings. On disconnection, we cease sending email from that account and delete the associated tokens or credentials promptly, and in any event within 30 days.
9.1 The automated voice call feature in C360 MB is provided through Brokermate, a solution operated by Effi Technologies Pty Ltd. Brokermate facilitates the calls and generates the call summaries, and its handling of that information is governed by its terms and privacy policy. Call summaries are stored in Connect360 as notes against the relevant Client record.
9.2 Broker Users are responsible for complying with the laws that apply to calls made to their Clients, including laws relating to telemarketing.
10.1 C360 MB uses rules-based computer programs developed by Property Dollar to analyse Client Data and property data and identify indicators for the Broker User's attention, such as an upcoming fixed-rate expiry, a change in LVR, or a loan whose pricing may warrant review. Where a Broker User configures an automation rule, the program may also send a communication to a Client on the Broker User's behalf when the conditions of that rule are met.
10.2 The kinds of personal information used for these purposes are the loan and property information described in section 5.2, together with Client contact details. The outputs are prompts to the Broker User and communications configured by the Broker User. Connect360 does not make decisions about a Client's eligibility for credit, the approval of any loan or the terms on which credit is offered. Any such decision is made by the Broker User and the relevant lender.
10.3 A Client with a question about a communication received through Connect360 should contact their broker. Broker Users may contact us for information about how an indicator was generated.
10.4 Property Dollar does not disclose Client Data to any third-party artificial intelligence or large language model service, and does not use Client Data, or any data obtained through Google or Microsoft APIs, to develop, train or improve any artificial intelligence or machine learning model. If this changes, we will update this Privacy Policy and notify Broker Users before the change takes effect. This section does not extend to call summaries generated by Brokermate, which are addressed in section 9.
10.5 Google API Services. Connect360's use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.
11.1 Connect360 is hosted on Amazon Web Services infrastructure located in Australia. Client Data is stored in Australia.
11.2 Property Dollar operates an information security management system certified to ISO/IEC 27001:2022. The scope of certification includes Connect360.
11.3 Our security measures include:
(a) encryption of data in transit and at rest;
(b) role-based access controls applied on the principle of least privilege;
(c) multi-factor authentication, which Broker Users can enable when accessing the Services directly. Where the Services are accessed through a Connected CRM Platform, sign-in and authentication are managed by that platform;
(d) restriction of access to Client Data to a limited number of authorised technical personnel, permitted only where required to investigate or resolve a technical issue or at the request of the Broker User;
(e) confidentiality obligations for all personnel and annual information security awareness training;
(f) logical separation of the two Editions;
(g) periodic penetration testing of the Services by independent security firms, with identified issues assessed and remediated through our risk management process; and
(h) ongoing review of our controls through internal audit and external certification audit.
11.4 Broker Users are responsible for maintaining the confidentiality of their login credentials and must notify us immediately at info@connect360.com.au of any suspected unauthorised access to their account.
11.5 While we take reasonable steps to protect information, no system is completely secure and we cannot guarantee that information will never be subject to unauthorised access.
12.1 We maintain incident response procedures consistent with the Notifiable Data Breaches scheme in Part IIIC of the Privacy Act.
12.2 If we become aware of a data breach affecting Client Data, we will notify the affected Broker User without undue delay and in any event within 72 hours, and will work with the Broker User to assess and contain the breach and, where required, to notify affected individuals and the Office of the Australian Information Commissioner (OAIC).
13.1 We disclose personal information to the following service providers, to the extent necessary to provide the Services:
| Recipient | Purpose | Location |
|---|---|---|
| Amazon Web Services | Hosting and storage of the Services | Australia |
| Connected CRM Platforms | Two-way synchronisation of Client Data, and embedded access to Connect360, at the direction of the Broker User (C360 MB) | As stated in the relevant provider's privacy policy |
| Google and Microsoft | Sending email from a Broker User's connected account | Global infrastructure, which may include the United States |
| Custom SMTP provider selected by the Broker User | Sending email from a custom email account | As determined by the provider |
| Sinch MessageMedia (Sinch Engage) | Sending SMS messages at the direction of the Broker User | Primarily Australia. Some of the provider's sub-processors are located outside Australia, including the United States |
| Brokermate (Effi Technologies Pty Ltd) | Voice call-back and call summaries (C360 MB) | As stated in Effi's privacy policy |
| Valocity, CoreLogic and Domain | Property valuation estimates. Only property identifiers, such as address, are provided. | Not applicable (no Client contact details are provided) |
13.2 We require our service providers to handle personal information only for the purpose of providing their services to us and to protect it appropriately.
13.3 We may also disclose personal information:
(a) where required or authorised by law, including to a court, regulator or law enforcement agency;
(b) with the consent of the individual concerned; or
(c) to a purchaser or prospective purchaser of all or part of our business, subject to confidentiality obligations and on the basis that Client Data remains subject to protections equivalent to those in this Privacy Policy.
13.4 We do not sell personal information and do not disclose Client Data to any third party for that party's own marketing or commercial purposes.
14.1 Client Data is hosted and stored in Australia.
14.2 Personal information may be processed outside Australia only in the following circumstances:
(a) emails sent through a connected Google or Microsoft account are transmitted using those providers' global infrastructure, which may include the United States;
(b) SMS messages are sent through Sinch MessageMedia, which hosts its platform primarily in Australia but uses some sub-processors located outside Australia, including the United States;
(c) where a Broker User uses a Connected CRM Platform, custom SMTP provider or other service that processes information outside Australia; and
(d) authorised technical personnel, some of whom may be located outside Australia, may view Client Data through secured remote sessions to systems managed in Australia, solely where required to resolve a technical issue and subject to the controls described in section 11.3. Client Data is not transferred to or stored in that location.
14.3 Where personal information is processed outside Australia, we take reasonable steps, including through contractual obligations, to ensure it is handled consistently with the APPs.
15.1 We retain Broker User information while the account is active and afterwards for as long as required for legal, accounting and dispute resolution purposes.
15.2 We retain Client Data for as long as the Broker User's subscription is active. Following closure or termination of an account, the Broker User may export Client Data for 14 days. We then delete Client Data from our production systems within 30 days, and it is removed from backups in the ordinary course of our backup cycle, subject to any retention required by law.
15.3 When personal information is no longer required, we take reasonable steps to destroy or de-identify it.
16.1 Broker Users may access and update their account information within the Services or by contacting us.
16.2 Because we hold Client Data on behalf of Broker Users, Clients should direct requests for access to or correction of their information to their broker. If we receive such a request directly, we will refer it to the relevant Broker User and assist the Broker User to respond.
16.3 For requests we handle directly, we will acknowledge the request within five business days and respond within 30 days. We may need to verify the identity of the person making the request. We do not charge a fee for making a request. If we refuse a request, we will give written reasons and explain how to make a complaint.
17.1 Individuals may deal with us anonymously or by using a pseudonym when making general enquiries. It is not practicable for us to provide the Services to Broker Users who do not identify themselves.
18.1 A complaint about our handling of personal information should be made in writing to our Privacy Officer using the details in section 20. We will acknowledge a complaint within five business days and aim to respond within 30 days.
18.2 If you are not satisfied with our response, you may lodge a complaint with the OAIC at www.oaic.gov.au or on 1300 363 992.
19.1 We may update this Privacy Policy from time to time. The current version will be published at connect360.com.au with its effective date. We will notify Broker Users by email of material changes before they take effect.
20.1 Privacy Officer, Property Dollar Pty Ltd, Level 27, Tower 1, 100 Barangaroo Avenue, Sydney, NSW 2000. Email: info@connect360.com.au. Telephone: +61 403 818 918.