Privacy Policy
Last updated: 1 October 2026

1. About Hayes Commercial
Hayes Commercial is a trading name of HCRE Pty Ltd (ABN 59 649 696 220).
We respect your privacy and are committed to handling personal information in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles and our obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).
Contact details:
HCRE Pty Ltd trading as Hayes Commercial  
PO Box 509  
North Fremantle WA 6159  
Telephone: 0420 200 773  
Email: phil@hayescommercial.com.au

2. Personal information we collect
Depending upon the services we provide, we may collect personal information including:
• your name, address, telephone number and email address;
• your date of birth and occupation;
• information about a property, business or transaction;
• company, trust, partnership and beneficial ownership information;
• information contained in contracts, leases, authorities and related documents;
• identity information, including details from passports, driver’s licences and other identification documents;
• photographs, video or biometric information used for electronic identity verification;
• information regarding the source of funds or source of wealth where required;
• information necessary to assess money-laundering, terrorism-financing and proliferation-financing risk; and
• communications and enquiries you send to us.
We only collect personal information that is reasonably necessary for our services, business activities or legal obligations.

3. How we collect information
We may collect personal information:
• directly from you;
• from a person authorised to act for you;
• through our website, email, telephone or in-person communications;
• through First AML, our identity-verification and AML/CTF service provider;
• from publicly available registers and records;
• from government agencies, identity-document issuers and verification services; or
• from conveyancers, solicitors, accountants, property managers and other parties involved in a transaction.

4. Why we collect and use information
We may collect, hold, use and disclose personal information to:
• provide commercial real estate, property management, leasing, auction and business-broking services;
• respond to enquiries and communicate with clients and prospective clients;
• prepare and administer agency agreements, contracts, leases and other property documents;
• verify identity and beneficial ownership;
• undertake customer due diligence and risk assessments;
• comply with the AML/CTF Act, AML/CTF Rules and other legal and regulatory obligations;
• maintain transaction and compliance records;
• protect against fraud and other unlawful activity; and
• manage complaints, disputes and legal claims.
If required information is not provided, we may be unable to act for you, continue providing a service or complete a transaction.

5. AML/CTF identity verification
Hayes Commercial uses First AML to assist with identity verification, customer due diligence and AML/CTF compliance.
Information provided through First AML may include identity-document details, images, biometric information, contact information, device information and verification results.
First AML generally processes verification information on our behalf. Its handling of personal information is also governed by its published privacy notice and applicable privacy laws.

6. Disclosure of information
We may disclose relevant personal information to:
• First AML and its verification and technology providers;
• AUSTRAC and other government, regulatory or law-enforcement bodies where authorised or required by law;
• the Australian Government Document Verification Service;
• property owners, purchasers, tenants and their authorised representatives where required for a transaction;
• conveyancers, solicitors, accountants, valuers and other professional advisers;
• contractors and service providers assisting us to conduct our business; and
• any other person where you have provided consent or disclosure is authorised or required by law.
We do not sell personal information.

7. Overseas processing
First AML states that its primary Australian hosting regions are Sydney and Melbourne. First AML may transfer or process personal and biometric information through service providers located in Australia, New Zealand, the United Kingdom, the European Union and other countries in which First AML or its trusted providers operate.
Further information is available in First AML’s privacy notice at:
https://www.firstaml.com/about/help/legal/privacy-policy/

8. Storage and security
AML/CTF verification information is stored through First AML. We take reasonable steps to protect personal information from misuse, interference, loss and unauthorised access, modification or disclosure.
No electronic transmission or storage system is completely secure. If we become aware of an eligible data breach, we will respond in accordance with applicable legal requirements.

9. Retention
We retain personal information only for as long as reasonably necessary for our business and legal obligations.
AML/CTF records may need to be retained for periods prescribed by law. We will take reasonable steps to destroy or permanently de-identify personal information when it is no longer required or authorised to be retained.

10. Access and correction
You may request access to personal information we hold about you or ask us to correct information that is inaccurate, out of date, incomplete, irrelevant or misleading.
Please contact:
Phil Hayes  
Email: phil@hayescommercial.com.au  
Telephone: 0420 200 773
We may need to verify your identity before responding to a request. In some circumstances, access may be refused where permitted by law. If that occurs, we will generally explain the reason.

11. Privacy complaints
If you have a concern or complaint about how we have handled your personal information, please contact Phil Hayes using the details above.
We will consider and respond to privacy complaints within a reasonable period.
If you are dissatisfied with our response, you may contact the Office of the Australian Information Commissioner through www.oaic.gov.au.

12. Changes to this policy
We may update this Privacy Policy when our practices or legal obligations change. The current version will be published on our website with its date of revision.