Privacy Policy

Starena1 Pty Ltd T/A Billings Cloak ACN  660 372 958     ABN 83 660 372 958

Effective Date: 1 July 2026

Version: 1.0

  1. Purpose

Billings Cloak (“we”, “our”, or “us”) is committed to protecting the privacy and confidentiality of personal information entrusted to us.

This Privacy Policy explains how we collect, hold, use, disclose, store and protect personal information in accordance with:

  • the Privacy Act 1988 (Cth);
  • the Australian Privacy Principles (APPs);
  • guidance published by the Office of the Australian Information Commissioner (OAIC);
  • where applicable, the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), including obligations applying to designated services under the AML/CTF reforms (Tranche 2); and
  • other applicable Australian laws.

By engaging our services or interacting with us, you acknowledge this Privacy Policy.

  1. Who We Are

Starena1 Pty Ltd T/A Billings Cloak      ACN 660 372 958         ABN 83 660 372 958

Address: 114 Poath Road, Hughesdale, Victoria 3166

Telephone: 03 9568 1833

Email: astarvaggi@billingscloak.com.au

Privacy Contact:  Angela Starvaggi

  1. Types of Personal Information We Collect

We collect personal information that is reasonably necessary to provide conveyancing and related legal services, comply with our legal obligations, and operate our business.

This may include:

Identification Information

  • Full name
  • Date of birth
  • Residential and postal address
  • Email address
  • Telephone number
  • Driver licence details
  • Passport details
  • Medicare details (where relevant)
  • Foreign identification documents
  • Citizenship or residency information

Verification Information

To comply with legal obligations, including AML/CTF obligations where applicable, we may collect:

  • Identity verification documents
  • Electronic verification records
  • Biometric comparison results where authorised
  • Source of funds information
  • Source of wealth information
  • Politically Exposed Person (PEP) status
  • Beneficial ownership information
  • Company ownership information
  • Trust information
  • Corporate structure documentation

Financial Information

  • Bank account details
  • Mortgage information
  • Loan documentation
  • Settlement statements
  • Financial institution information
  • Payment records

Property Information

  • Property ownership
  • Titles
  • Contracts
  • Settlement information
  • Rates notices
  • Planning information
  • Land tax information

Other Information

  • Communications with us
  • Instructions provided by clients
  • Records of meetings
  • Emails
  • Telephone recordings (where applicable)
  • Website usage information
  • IP address
  • Device information
  • Cookies
  1. How We Collect Personal Information

We collect personal information:

  • directly from you;
  • from your authorised representative;
  • through identity verification providers;
  • from government agencies;
  • from financial institutions;
  • from real estate agents;
  • from mortgage brokers;
  • from legal practitioners;
  • from publicly available registers;
  • from electronic verification systems;
  • through our website;
  • through email correspondence;
  • during telephone conversations;
  • from third parties where authorised by law.
  1. Why We Collect Personal Information

We collect personal information for purposes including:

  • providing conveyancing services;
  • conducting property settlements;
  • preparing legal documentation;
  • verifying identity;
  • complying with AML/CTF obligations;
  • undertaking customer due diligence;
  • assessing money laundering and terrorism financing risk;
  • sanctions screening;
  • fraud prevention;
  • complying with legal and regulatory obligations;
  • communicating with clients;
  • managing payments;
  • maintaining records;
  • responding to enquiries;
  • improving our services;
  • protecting our legal rights.
  1. AML/CTF Compliance

Where required under Australian law, we may collect, verify, use and retain personal information to:

  • identify and verify clients;
  • identify beneficial owners;
  • conduct customer due diligence;
  • conduct enhanced due diligence where required;
  • undertake ongoing customer due diligence;
  • screen against sanctions lists;
  • identify politically exposed persons;
  • monitor transactions;
  • assess suspicious activities;
  • comply with reporting obligations;
  • comply with record-keeping obligations.

Where required by law, we may refuse to provide services if sufficient information is not provided for identity verification or AML/CTF compliance.

  1. Disclosure of Personal Information

We may disclose personal information to:

  • financial institutions;
  • government agencies;
  • state land registries;
  • the Australian Taxation Office;
  • the Australian Securities and Investments Commission;
  • the Australian Transaction Reports and Analysis Centre (AUSTRAC), where required by law;
  • identity verification providers;
  • electronic settlement providers;
  • legal practitioners;
  • barristers;
  • accountants;
  • valuers;
  • mortgage brokers;
  • real estate agents;
  • technology service providers;
  • cloud hosting providers;
  • document management providers;
  • payment providers;
  • professional advisers;
  • insurers;
  • courts and tribunals;
  • regulators;
  • law enforcement agencies;
  • any person authorised by you;
  • any organisation where disclosure is required or authorised by law.

We do not sell personal information.

  1. Overseas Disclosure

Some service providers may store information outside Australia.

Where overseas disclosure occurs, we take reasonable steps to ensure service providers protect personal information in accordance with Australian privacy requirements.

Countries may include:

  • New Zealand
  • Singapore
  • United States
  • United Kingdom

or other jurisdictions where our technology providers operate.

  1. Storage and Security

We take reasonable steps to protect personal information from:

  • misuse;
  • interference;
  • loss;
  • unauthorised access;
  • unauthorised modification;
  • unauthorised disclosure.

Security measures include:

  • encrypted communications;
  • secure cloud storage;
  • password protection;
  • multi-factor authentication;
  • restricted staff access;
  • audit logging;
  • cybersecurity controls;
  • staff confidentiality obligations;
  • secure destruction procedures.
  1. Retention

We retain personal information for as long as necessary:

  • to provide legal services;
  • to comply with legal obligations;
  • to comply with AML/CTF record-keeping requirements;
  • to resolve disputes;
  • to enforce legal rights.

When information is no longer required, we securely destroy or de-identify it where permitted by law.

  1. Cookies and Website Information

Our website may collect:

  • IP addresses;
  • browser information;
  • operating system details;
  • pages viewed;
  • referral websites;
  • cookies;
  • analytics information.

Cookies help improve website functionality and user experience.

Users may disable cookies through browser settings, although this may affect website functionality.

  1. Direct Marketing

We may occasionally send updates regarding our services where permitted by law.

You may opt out of marketing communications at any time.

We do not use personal information for direct marketing where prohibited by law.

  1. Access to Personal Information

You may request access to your personal information.

Requests should be made in writing to our Privacy Officer.

We may refuse access where permitted by the Privacy Act.

  1. Correction of Personal Information

If personal information is inaccurate, incomplete or out of date, you may request correction.

We will respond within a reasonable period.

  1. Making a Privacy Complaint

If you believe your privacy has been breached, please contact:

Privacy Officer Billings Cloak – Angela Starvaggi

Email: astarvaggi@billingscloak.com.au

Telephone: 03 9568 1833

We will:

  • acknowledge your complaint;
  • investigate the matter;
  • respond within a reasonable period;
  • advise the outcome and any corrective action.

If you are dissatisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner.

  1. Notifiable Data Breaches

If an eligible data breach occurs, we will comply with the Notifiable Data Breaches scheme under the Privacy Act.

Where required, we will notify affected individuals and the Office of the Australian Information Commissioner.

  1. Changes to this Policy

We may amend this Privacy Policy from time to time.

The current version will be available on our website.

  1. Contact Us

Privacy Officer Billings Cloak – Angela Starvaggi

Email: astarvaggi@billingscloak.com.au

Telephone: 03 9568 1833

Website: billingscloak.com.au

  1. Your Rights

Subject to applicable law, you may:

  • request access to your personal information;
  • request correction of inaccurate information;
  • make a privacy complaint;
  • withdraw consent where processing is based on consent (subject to legal obligations);
  • ask questions about our privacy practices.

We are committed to handling personal information transparently, securely and in accordance with Australian privacy law and our professional obligations.