Commercial & General Pty Ltd and all of its subsidiaries, associated and related entities within the Commercial & General Group of companies (C&G Group) (we, us, our) are bound by the Australia Privacy Principles (APPs) in the Privacy Act 1988 (Cth) (Privacy Act) and the Spam Act 2003 (Cth). We recognise the importance of protecting your personal information and are committing to handling it in a responsible and transparent manner.

This Privacy Policy explains how we collect, use, disclose and otherwise manage personal information (being information or an opinion about an identified individual, or an individual who is reasonably identifiable), as well as our obligations and your rights in relation to that information.

This Privacy Policy applies to all websites owned, operated or controlled by members of the C&G Group, and to all personal information collected through those websites and in the course of our business operations, regardless of which specific C&G Group entity is responsible for the relevant website, including:

• all C&G Group corporate website and all project marketing websites
• digital campaigns, landing pages and online platforms
• communications via email, telephone, social media and in-person

By accessing our websites or providing your information, you agree to this Privacy Policy and our Terms of Use.

Please take a moment to read this Privacy Policy to understand how we handle personal information, including personal information collected via any C&G Group website. .

1. How we collect your personal information

We will collect and hold your personal information in a fair and lawful manner, and not in an intrusive way. Where it is reasonably practical to do so, we will collect your personal information directly from you. We may collect the personal information you directly give us through some of the following means:

a. Where you provide this in person, for example, when you visit one of our offices, Sales & Information Centres, or display homes

b. When you make an inquiry or order in relation to goods or services through one of our Websites or social media and digital advertising campaigns

c. In administering and performing any contracts with service providers

d. When you contact us via telephone

e. From correspondence (whether in writing or electronically)

f. Through any mobile applications provided by our organisation

g. While conducting customer satisfaction and market research surveys

h. When administering any of our services

i. When you register an account on our websites

j. As otherwise required to manage our business

We may also collect personal information from publicly available sources, such as telephone directories, or from other third parties, such as suppliers, recruitment agencies, contractors, our clients and business partners.

If we collect personal information about you from a third party we will, where required by law, request that the third party inform you that we are holding such information, how we will use and disclose it, and that you may contact us to gain access to and correct and update the information.

2. Types of personal information we collect

The type of personal information we may collect can include (but is not limited to) your name, postal address, email address, phone numbers, date of birth, billing information and, if applicable, employment information. Where you express an interest in our properties, we may also collect information about your circumstances and preferences, such as your target price range, desired property features, and any loan approvals you might hold. Personal information may also include network and device data such as IP address and device or advertising identifiers and information we obtain using cookies or other tracking technologies

We may also collect and hold sensitive information about you, including:

a. Health information

b. Your racial or ethnic origin

c. Your religious beliefs or affiliations

d. Your membership of any trade unions, professional or trade associations, or political parties

We only collect sensitive information about you with your consent, or otherwise in accordance with the Privacy Act.

Where you do not wish to provide us with your personal information, we may not be able to provide you with requested goods or services, or otherwise adequately respond to your queries.

We also collect personal information from third-party sources and platforms (including data validation services, authentication service providers, social networking sites, online marketing and segmentation providers and ad targeting companies). If your personal information is collected from third parties, we will notify you and provide you with details relating to the personal information collected and the manner in which it was collected. We will also ensure that we are permitted to receive the information. If we are permitted to receive the information, we will handle it pursuant to the relevant privacy principles. If we determine that we are not permitted to receive the information, we will, as soon as practicable, destroy the information or ensure that it is de-identified.

3. Our purposes for handling your personal information

As a general rule, we only process personal information for purposes that would be considered relevant and reasonable in the circumstances.

We collect, hold, use and disclose personal information to:

a. Respond to enquiries and provide requested information

b. Provide marketing and communications updates on residential, commercial and mixed-use developments

c. Provide investment updates

d. Tailor communications to your preferences

e. Facilitate transactions, contracts and service delivery

f. Improve our services, websites and customer experience

g. Assess and contact prospective employees

h. Manage our contractors

i. Comply with our legal and regulatory obligations

j. Conduct marketing research and analysis

k. Otherwise manage our business

We will not use or disclose your personal information for any other purpose unless we believe that you would reasonably expect this to occur, you have consented to such use or disclosure, or the use or disclosure is otherwise required or permitted by law.

We may disclose personal information between our organisations across the C&G Group to administer services or provide updateson;

a. Residential developments

b. Commercial and mixed-use projects

c. Investment opportunities

d. Integrated client account management

We may also disclose personal information between our organisations across the C&G Group to form data sets which we may analyse to obtain insights for use by the C&G Group and its businesses.

We may also disclose personal information to third parties such as our suppliers, contractors, organisations that provide us with technical and support services, or our professional advisors, where permitted by the Privacy Act. If we disclose information to a third party, we generally require that the third party protect your information to the same extent that we do.

4. Protection of personal information

We will hold personal information as either secure physical records, electronically on our intranet system, in cloud storage, and in some cases, records on third party servers, which may be located overseas.

We maintain appropriate physical, procedural and technical security for our offices and information storage facilities so as to prevent any loss, misuse, unauthorised access, disclosure, or modification of personal information. This also applies to disposal of personal information.

We further protect personal information by restricting access to personal information to only those who need access to the personal information do their job. Physical, electronic and managerial procedures have been employed to safeguard the security and integrity of your personal information.

We will destroy or de-identify personal information once it is no longer needed for a valid purpose or required to be kept by law.

We will not be responsible for any unauthorised use of personal information by third parties which is attributable to factors beyond our control. We are not responsible for the online privacy practices of third parties.

Further, given that no data transmission over the internet can be guaranteed as completely secure, we cannot guarantee the security of any (personal or other) information you transmit to us, and as such we will not be liable for any breach of security or unintended loss or disclosure of information.

Whilst our Websites are professionally hosted and operate in a secure environment, you should be aware that there is always an inherent risk in transmitting your personal information via the internet.

5. Direct marketing

Like most businesses, marketing is important to our continued success. We believe we have a unique range of products and services that we provide to customers at a high standard. We therefore like to stay in touch with customers and other interested individuals to let them know about new opportunities. We may provide you with information about new products, services and promotions either from us, or from third parties which may be of interest to you.

By providing your personal information, you consent to receiving electronic communications from us.

These may include:

a. Project updates and new releases across any C&G Group projects

b. Marketing campaigns and promotions

c. Event invitations

d. Market insights and company updates

You may opt out at any time by:

a. Clicking the unsubscribe link in communications

b. Updating your preferences

c. Request opt out by contacting our Privacy Officer

You may opt out at any time if you no longer wish to receive commercial messages from us. You can make this request by contacting our Privacy Officer.

6. Website Content & Promotional Use

Where you provide feedback, testimonials or engage with our projects, you consent (where reasonably expected or expressly provided) to your information being used for:

a. Testimonials and reviews

b. Case studies and project features

c. Marketing materials and presentations

d. Content on C&G Group websites and project marketing sites

Where identifiable personal information is used (such as your name or image), we will seek consent or provide the opportunity for removal upon request.

7. Cookies

A cookie is a small text file stored in your computer’s memory or on your hard disk for a pre-defined period of time. We use cookies to identify specific machines in order to collect information on how visitors are experiencing our Websites.

Our websites may use cookies and similar technologies to:

a. Improve functionality and performance

b. Analyse website traffic and usage

c. Support targeted marketing and remarketing

You can manage cookies through your browser settings.

8. Accessing and correcting your personal information

You may contact our Privacy Officer to request access to the personal information that we hold about you and/or to make corrections to that information, at any time. On the rare occasions when we refuse access, we will provide you with a written notice stating our reasons for refusing access. We may seek to recover from you reasonable costs incurred for providing you with access to any of the personal information about you held by us.

We are not obliged to correct any of your personal information if we do not agree that it requires correction and may refuse to do so. If we refuse a correction request, we will provide you with a written notice stating our reasons for refusing.

We will respond to all requests for access to or correction of personal information within a reasonable time.

9. Disclosure of Personal Information

We may disclose your personal information to:

a. Entities within the C&G Group

b. Sales agents, project partners and consultants

c. Marketing platforms and CRM providers

d. Professional advisers (legal, financial, accounting)

e. Contractors and service providers

f. Government or regulatory authorities where required

10. Overseas transfers of personal information

From time to time we may engage service providers located outside of Australia to provide services to us, which may involve your personal information being transferred to locations outside of Australia. For example, we may use cloud-based storage providers to hold your personal information on our behalf in locations outside of Australia, such as the United States.

We also engage with joint venture partners, who may be located outside of Australia. As part of these joint ventures, it may be necessary to disclose your personal information to these foreign partners.

By providing your personal information to us, you consent to us disclosing your personal information to any such overseas recipients for purposes necessary or useful in the course of operating our business, and agree that APP 8.1 will not apply to such disclosures. For the avoidance of doubt, in the event that an overseas recipient breaches the Australian Privacy Principles, that entity will not be bound by, and you will not be able seek redress under, the Australian Privacy Act.

11. Resolving personal information concerns

If you have any questions, concerns or complaints about this Privacy Policy, or how we handle your personal information, please contact our Privacy Officer:

The Privacy Officer

Address: 255 Sturt Street, Adelaide SA 5000

Telephone: +61 8 8112 6444

Email: info@c-g.com.au

We take all complaints seriously, and will respond to your complaint within a reasonable period.

If you are dissatisfied with the handling of your complaint, you may contact the Office of the Australian Information Commissioner:

Office of the Australian Information Commissioner

GPO Box 5218

Sydney NSW 2001

Telephone: 1300 363 992

Email: enquiries@oaic.gov.au

WEBSITE TERMS OF USE

12. Use of Website

You agree to use our websites lawfully and not to:

• Engage in unlawful, misleading or fraudulent conduct
• Interfere with website functionality or security
• Attempt unauthorised access to systems or data

We reserve the right to restrict or terminate access where misuse occurs.

13. Jurisdiction

These Terms of Use are governed by the law in force in the State of South Australia, and you irrevocably submit to the non-exclusive jurisdiction of the courts of South Australia for determining any dispute concerning these Terms of Use.

If the whole or any part of a provision of these Terms of Use are void, unenforceable or illegal in a jurisdiction, the relevant part or provision is severed for that jurisdiction. The remainder of these Terms of Use shave full force and effect and the validity or enforceability of that provision in any other jurisdiction is not affected.

14. Prohibited Use

Our websites are only intended to be accessed by persons from within Australia. By using any of our websites, you represent and warrant that you are accessing that website from within Australia.

15. Copyright

Copyright in the content on our websites is owned or licensed by the C&G Group. Except as necessary for viewing the documents or information that form part of our websites on your browser, or as permitted under the Copyright Act 1968 (Cth) or other applicable laws or these Terms of Use, no content on the websites may be reproduced, adapted, uploaded to a third party, linked to, framed, performed in public, distributed, stored, published, displayed or transmitted in any form by any process and you may not create derivative works from any part of the websites or commercialise any information obtained from any part of the websites without the specific written consent of the C&G Group or, in the case of third party material, from the owner of the copyright in that material.

16. Limitation of Liability

To the extent permitted by law, no member of the C&G Group is liable for any loss or damage to any person arising from:

• Use of websites operated by a member of the C&G Group
• Errors or omissions in the content on those websites
• Reliance on any information contained on those websites

17. Acceptance

By using our websites or providing your information, you acknowledge that you have read and understood this Privacy Policy & Terms of Use and consent to the collection, use and disclosure of your personal information as described.

18. Changes

We reserve the right to change the terms of this Privacy Policy and Terms of Use from time to time, without notice to you. An up-to-date copy of our Privacy Policy and Terms of Use is available via our websites, or by contacting our Privacy Officer.

The last update to this document was in May 2026