SmartHomie privacy policy Draft under legal review

Draft date: 8 July 2026. Version: draft 2.

1. Who we are

SmartHomie is a live property market dashboard for Perth, plus a weekly email and optional paid email or SMS alerts. We are funded by our subscribers, not by real estate agents. We do not sell homes.

SmartHomie is operated by Wakeup Matrix Pty Ltd (ABN 54 660 419 376). Our registered office is Unit 2, 200 Winton Road, Joondalup WA 6027.

In this policy, "we", "us" and "our" mean SmartHomie (Wakeup Matrix Pty Ltd). "You" means the person reading this who uses SmartHomie.

2. The kinds of information we handle

We handle two different kinds of information, and we treat them differently. We think this difference matters, so we state it plainly.

Personal information is information about you, a person. This is what you give us when you sign up.

Property facts are public facts about properties, such as the asking price of a listing, the sold price of a home, the suburb it is in, and the day it was listed or sold. These describe places rather than people, although we recognise that an address can sometimes point to a person. We generally research these daily from public sources, subject to source availability. Section 6 explains the rules that keep property facts from becoming information about a person.

3. The personal information we collect when you sign up

To use SmartHomie you sign up with an email and then complete a short registration step. We collect:

• Your email address. This is also how you sign in (we send you a link, not a password).
• Your full name.
• Your street address and suburb. This is the home you want to follow.
• If you are following a home you do not own, we also collect your current living address, so your account reflects where you live as well as the home you follow.
• Your mobile number, so we can send SMS alerts if you choose the paid plan. We check it is a valid Australian mobile number.
• A required confirmation of your relationship to that home: either that you own it, or that you are genuinely following a home you are interested in. We record the time you confirmed this.
• One optional question: how did you hear about us. You can leave this blank.

You can use SmartHomie on the free plan without giving payment details. There is no card needed to start, and no card needed for the one month free trial.

If you do not give us the information we ask for at sign-up, we may not be able to create your account, show you the home and suburb you want to follow, send the weekly email, or provide the alerts you choose.

4. Why we use your personal information

We use the personal information above only to run SmartHomie for you:

• To create and run your account, and to sign you in by the link we email you.
• To show you the home and suburb you asked to follow.
• To send you the weekly email about what changed in the Perth market and your area.
• To send you email or SMS alerts if you choose the paid plan, on the day a home near you lists, sells or changes price.
• To count, in general terms, how people found us, using the optional "how did you hear about us" answer.
• To keep a clear, dated record of your registration and your owner confirmation.

We do not use your personal information to predict what your home is worth, and we do not give you advice about whether to sell. We never do that. We use your details to show you data and send you the updates you asked for.

5. How we keep your personal information safe, and how long we keep it

Your personal information is stored on infrastructure we control, in protected data stores that are kept out of our code repositories and separate from the public website. The sign-in links we email you are single use, they expire, and we store only a hashed reference to them, so a database leak would not reveal a working link. Beyond these specifics, we take reasonable technical and organisational steps to protect all the personal information we hold.

A small number of service providers help us run SmartHomie: the provider that sends our email, the provider that sends SMS alerts on the paid plan, and the infrastructure provider that hosts the service and its data stores. Each one processes only what its job needs (for delivery, that is your email address or mobile number, and the message itself). Some of these providers process or store data outside Australia, including in the United States. Section 7 covers this in full. Beyond running the service this way, we do not send your personal information to third party services.

[BOARD / LAWYER: confirm the overseas disclosure position under APP 8 and the recipient countries for each provider.]

We keep your personal information for as long as your account is active, and afterwards only as long as we need it to meet our legal and record keeping duties (for example, the dated record of your owner confirmation). You can ask us to remove it. See section 9. Once payments are live, payment records may also be retained by our payment processor under its own legal and compliance obligations.

[BOARD / LAWYER: confirm the retention period for an account after closure, and the retention period for the owner confirmation audit record.]

6. Property facts, and the line we will not cross

We generally run our research over public property listings and sales daily, subject to source availability, across roughly 335 Perth suburbs. These are facts about properties: an address, a listing, an asking price, a sold price, a suburb, a day. They are already public.

We publish property facts. We do not publish information about the people who live in a home. Concretely, on any property page or in any content we produce:

• We never publish an owner's or occupant's name.
• We never show how many people are watching a single home. (Any "people are watching homes like yours" signal is shown only at suburb level and only once it passes a threshold, or not at all.)
• We never infer or publish a valuation of a home.
• Every property page has an easy way to ask for a correction or removal.

Where a property fact could reasonably identify a person on its own, we treat it with the same care as personal information.

If you believe a property fact we show is wrong, or you want a property page removed, use the correction or removal link on that page, or contact us (section 11). We assess correction and removal requests within 5 business days, and we remove or suppress a property fact where it is inaccurate, unsafe or unlawful.

7. Who we share your personal information with

We are funded by our subscribers. At the time of this draft, we do not share your personal information with real estate agents, we are not paid by them, and we do not pass your details to anyone as a lead. We do not sell your personal information.

We only share your personal information where it is needed to run the service you asked for, or where the law requires it. The categories of recipients are:

• the provider that hosts the service and its data stores;
• the provider that sends our email;
• the provider that sends SMS alerts on the paid plan;
• once payments are live, our payment processor, which handles card and payment details itself so that we do not have to. We do not store full card numbers; we receive only limited transaction information such as your subscription status, payment date, amount and a transaction reference;
• our professional advisers (for example an accountant, lawyer or insurer), where needed; and
• regulators, courts or law enforcement, where disclosure is required or authorised by law.

If we ever add a service that would share your details with anyone else, we would tell you clearly and update this policy first, and we would only do it with the right basis.

[BOARD / LAWYER: confirm the list of any service providers that process personal information on our behalf (for example, the email and SMS delivery provider once sending is live), and the basis for each.]

8. Analytics

We keep analytics small and honest. We use simple, in-house counts of how the service is used and how people found us (the optional sign-up question, plus tags on our own links). We also keep operational logs, and counts of email delivery and opens, so we can run the service reliably. We do not use a third party analytics tool that profiles you across the web, and we do not do cross-site advertising profiling. We take reasonable steps to keep anything that could identify a person out of our analytics outputs.

9. Your choices and your rights

We handle your personal information in line with the Australian Privacy Principles. You can:

• ask what personal information we hold about you, and ask for a copy;
• ask us to correct it if it is wrong or out of date;
• ask us to remove it, or close your account, where we no longer need it and are not legally required to retain it;
• ask us not to use your personal information for a particular purpose; and
• complain if you think we have handled it badly (section 11).

We may need to verify your identity before acting on a request. We respond within a reasonable period, usually within 30 days. If we refuse an access or correction request, we will explain why in writing unless the law allows otherwise, and tell you about your complaint options.

You can change or stop your emails and alerts in your account at any time. Every commercial email or SMS we send includes a way to unsubscribe or reply STOP that needs no login and costs no fee; we action unsubscribe requests promptly, within 5 business days, and we keep records of consent and unsubscribe requests. You can cancel the paid plan at any time. We will not make it hard to leave.

[BOARD / LAWYER: confirm whether the business is an APP entity (the $3m small-business threshold and any applicable exception), and adjust the rights language if not bound.]

10. Children

SmartHomie is a property market information service for adults. We do not aim it at children, and we do not knowingly collect personal information from children. If you think a child has given us personal information, contact us and we will remove it.

11. Contact and complaints

To ask about your personal information, to correct or remove it, or to make a privacy complaint, contact us:

Email: support@smarthomie.com.au. Post: Wakeup Matrix Pty Ltd, Unit 2, 200 Winton Road, Joondalup WA 6027.

If you have a privacy complaint, please contact us first so we can try to fix it. We aim to acknowledge a complaint within a few days and respond within 30 days. If we cannot resolve it, you can complain to the Office of the Australian Information Commissioner (OAIC), which is the independent body that oversees the Privacy Act 1988 and the Australian Privacy Principles.

12. Changes to this policy

We may update this policy as SmartHomie changes. When we do, we will say what changed and when, and we will tell you in the usual way if a change matters to you. The date at the top of this policy shows when it was last revised.

This policy is governed by the Privacy Act 1988 (Cth) and the Australian Privacy Principles. [BOARD / LAWYER: confirm governing law and jurisdiction, assumed Western Australia.]