1. Introduction

Armour Developments WA Pty Ltd (ACN 644 897 996, ABN 81 644 897 996), trading as Armour Homes (“we”, “us”, “our”), is committed to protecting the privacy of everyone who interacts with our website at www.armourhomes.au and our ChatGPT-powered enquiry assistant (the “ChatGPT App”).

This Privacy Policy explains what personal information we collect, why we collect it, how we use and disclose it, how we keep it secure, and what rights you have in relation to it. It applies to all visitors to our website, prospective and current clients, and any person who interacts with our ChatGPT App.

We are bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) contained in Schedule 1 of that Act. Where our activities engage users in the European Union or United Kingdom, we also observe the General Data Protection Regulation (GDPR) and UK GDPR to the extent applicable. Where our activities engage consumers in California, we observe the California Consumer Privacy Act (CCPA) to the extent applicable.

2. Who We Are & How to Contact Us

For all privacy-related enquiries or requests, please contact us using the details above and mark your correspondence Privacy — Attention: Privacy Officer.

3. What Personal Information We Collect

We collect personal information that is reasonably necessary to provide our home-building and granny-flat construction services and to respond to your enquiries. The categories of personal information we may collect include:

Category	Examples	How collected
Identity & contact information	First and last name, email address, phone number, postal address	Enquiry forms, phone calls, emails, ChatGPT App
Property & project information	Site address, block size, build type (new home / granny flat), budget range, design preferences	Consultation forms, site visits, ChatGPT App
Financial information	General information about financing needs or eligibility (e.g. Keystart, First Home Owner Grant); we do not collect credit card or bank account details directly	Financing enquiry forms, in-person consultations
Communications data	Records of emails, calls, or chat interactions with us	Direct correspondence, ChatGPT App
Technical & usage data	IP address, browser type, device type, pages visited, referring URL, time on page	Automatically via cookies and analytics tools
AI tool interaction data	Questions and inputs submitted to our ChatGPT App (see Section 9)	ChatGPT App

We collect personal information only by lawful and fair means and, where practicable, directly from you. You are not obliged to provide personal information to us; however, if you choose not to, we may not be able to provide the relevant service or respond to your enquiry.

4. How We Use Your Personal Information

We use the personal information we collect for the following purposes:

• To respond to your enquiries and provide you with quotes, design consultations, and building services for new homes and granny flats in Perth, Western Australia.
• To manage your building project, including design, council approvals, construction, and handover.
• To facilitate financing enquiries and connect you with relevant lenders or brokers where requested.
• To send you information about our services, promotions, or updates where you have consented or where we have a legitimate interest.
• To improve our website, services, and the ChatGPT App.
• To comply with legal obligations, including obligations under the Building Services (Registration) Act 2011 (WA) and related regulations.
• To detect, prevent, or investigate fraud, security incidents, or other unlawful activity.

We will not use your personal information for a purpose other than the primary purpose for which it was collected unless you have consented, or the secondary use is directly related to the primary purpose and you would reasonably expect such use, or an exception under the Privacy Act applies.

5. Disclosure of Your Personal Information

We may disclose your personal information to the following categories of recipients:

Recipient category	Organisation / type	Purpose
AI Platform Providers	OpenAI (openai.com)	Processing user inputs from the ChatGPT App
Website analytics	Google Analytics	Website usage analytics and performance monitoring
IT & hosting services	Studio22 PTY LTD	Hosting the website and storing form submissions
Finance & mortgage brokers	In-house brokers and, where relevant, lenders such as Keystart	Assisting clients with home loan and financing applications
Professional advisers	Lawyers, accountants, insurers	Legal, financial, and risk management purposes
Regulators and government bodies	Building and Energy (WA), local councils, OAIC	Compliance with statutory obligations, council approvals
Subcontractors and tradespeople	Licensed builders, bricklayers, roof carpenters, and other trades	Construction and project delivery

We do not sell your personal information to third parties.

Where we disclose personal information to overseas recipients (for example, to OpenAI, whose infrastructure is operated in the United States), we take reasonable steps to ensure those recipients handle your information in a manner consistent with the APPs or that you have consented to the disclosure. By using the ChatGPT App, you acknowledge that your inputs will be transmitted to OpenAI and processed in accordance with OpenAI’s Privacy Policy.

6. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to enhance your browsing experience, analyse site traffic, and support our marketing activities. A cookie is a small text file placed on your device when you visit our website.

Types of cookies we use

• Essential cookies: Required for the website to function correctly (e.g. session management, form submissions).
• Analytics cookies: Help us understand how visitors use our website (e.g. pages visited, time on site). We use Google Analytics for this purpose.
• Marketing / advertising cookies: Google Ads, Meta Pixel

You can control or disable cookies through your browser settings. Note that disabling certain cookies may affect the functionality of our website. For more information on managing cookies, visit www.allaboutcookies.org.

We do not use cookies to collect sensitive personal information.

7. Data Retention

We retain personal information for as long as necessary to fulfil the purposes for which it was collected, or as required by law. The following retention periods apply:

Data type	Retention period	Reason
Client project & contract records	7 years after project completion	Statutory obligations under WA building regulations and taxation law
Enquiry and lead data	2 years from last interaction	Legitimate business interest; follow-up and dispute resolution
ChatGPT Conversational Data	30 days	Unless required longer for security or legal compliance
Website analytics data	26 Months	Website performance and marketing analysis
Marketing contact preferences	Until you withdraw consent or unsubscribe	Consent-based communications

When personal information is no longer required, we will take reasonable steps to destroy or de-identify it securely.

8. Data Security

We take reasonable technical and organisational steps to protect personal information from misuse, interference, loss, unauthorised access, modification, or disclosure. These measures include:

• HTTPS encryption for all data transmitted through our website.
• Access controls limiting access to personal information to staff and contractors who need it to perform their role.
• Secure storage of physical records where applicable.
• Regular review of our security practices.

No method of electronic transmission or storage is completely secure. While we take all reasonable precautions, we cannot guarantee absolute security.

9. AI Tool Interaction Data

Our website includes a ChatGPT-powered conversational assistant (the “ChatGPT App”) to help visitors with general enquiries about Armour Homes’ services, including:

• Learning about our custom home and granny flat designs, floor plans, and build options available in Perth.
• Understanding our construction process, timeline guarantees, and project management approach.
• Exploring financing options, including information about Keystart loans, the First Home Owner Grant, and stamp duty concessions.
• Getting information about how to book a site consultation or request a quote.

When you use the ChatGPT App, any text you submit (your “inputs”) is transmitted to and processed by OpenAI, L.L.C., an artificial intelligence platform provider based in the United States. OpenAI processes these inputs to generate responses on our behalf. Your inputs are handled in accordance with OpenAI’s Privacy Policy (available at openai.com/policies/privacy-policy).

We recommend that you do not submit sensitive personal information (such as financial account details, tax file numbers, health information, or government-issued identification numbers) through the ChatGPT App.

Conversational data from the ChatGPT App is not permanently stored by Armour Homes unless retention is required for support, security, or legal compliance purposes. Where retained, ChatGPT conversational data is held for a maximum of 30 days (see Section 7).

10. Children’s Privacy

Our website and ChatGPT App are available to users aged 13 and older for informational purposes. Our building and construction services are contracted with property owners, account holders, and authorised representatives who are adults with legal capacity to enter into contracts. We do not knowingly collect personal information from children under 13. If we become aware that a child under 13 has submitted information to us, we will delete it immediately. If you believe a child under 13 has provided us with personal information, please contact us at admin@armourdev.au.

11. Your Privacy Rights

Depending on your location and applicable law, you have the following rights in relation to your personal information:

All users (Australian Privacy Principles)

• Access: You may request access to the personal information we hold about you.
• Correction: You may request that we correct personal information that is inaccurate, out of date, incomplete, irrelevant, or misleading.
• Complaints: You may lodge a complaint with us or with the Office of the Australian Information Commissioner (OAIC) — see Section 14.

EU / UK users (GDPR / UK GDPR)

• Right to erasure (“right to be forgotten”): You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to legal retention obligations.
• Right to restriction of processing: You may request that we restrict processing of your data in certain circumstances.
• Right to data portability: You may request a copy of your personal data in a structured, commonly used, machine-readable format.
• Right to object: You may object to processing based on legitimate interests or for direct marketing purposes.
• Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of processing prior to withdrawal.

California users (CCPA)

• Right to know: You may request disclosure of the categories and specific pieces of personal information we have collected about you, and the purposes for which it is used or disclosed.
• Right to delete: You may request deletion of personal information we have collected, subject to certain exceptions.
• Right to opt out of sale: We do not sell personal information. No opt-out is required.
• Right to non-discrimination: We will not discriminate against you for exercising your CCPA rights.

To exercise any of these rights, please contact us at admin@armourdev.au or in writing at the address in Section 2. We will respond within a reasonable time and no later than 30 days (or as required by applicable law). We may need to verify your identity before processing your request.

12. Marketing Communications

We may, from time to time, send you information about Armour Homes’ services, promotions, new home designs, and industry news by email or other channels where you have provided consent or we have a legitimate interest to do so.

You may opt out of marketing communications at any time by:

• Clicking the “unsubscribe” link in any marketing email we send you; or
• Contacting us at admin@armourdev.au with the subject line Unsubscribe.

Opting out of marketing communications will not affect our ability to send you transactional or service-related communications (e.g. updates about your building project).

13. Data Breach Notification

In the event of an eligible data breach (as defined under Part IIIC of the Privacy Act 1988 (Cth) — the Notifiable Data Breaches scheme), we will:

• Assess the breach as quickly as reasonably practicable to determine whether it is likely to result in serious harm to any affected individuals.
• If the breach is eligible, notify the Office of the Australian Information Commissioner (OAIC) and all affected individuals as soon as practicable, and in any event within 30 days of becoming aware of the breach.
• Take immediate steps to contain the breach and prevent further unauthorised access or disclosure.

Where we are required to comply with the GDPR or UK GDPR, we will also notify the relevant supervisory authority within 72 hours of becoming aware of a reportable breach, where feasible.

14. Complaints and Regulator Contact

If you believe we have not complied with this Privacy Policy or your rights under the Privacy Act 1988 (Cth) or applicable privacy legislation, please contact us in the first instance:

We will acknowledge your complaint within 5 business days and aim to resolve it within 30 days. If you are not satisfied with our response, you may escalate your complaint to the relevant regulator:

Australia — Office of the Australian Information Commissioner (OAIC)

• Website: www.oaic.gov.au
• Phone: 1300 363 992
• Post: GPO Box 5218, Sydney NSW 2001

European Union — relevant supervisory authority

EU users may contact the supervisory authority in their EU member state of habitual residence, place of work, or place of alleged infringement. A list of supervisory authorities is available at edpb.europa.eu.

United Kingdom — Information Commissioner’s Office (ICO)

• Website: ico.org.uk
• Phone: 0303 123 1113

California — California Privacy Protection Agency (CPPA)

• Website: cppa.ca.gov

15. Third-Party Websites and Links

Our website may contain links to third-party websites, including lender portals, government grant information pages, and the OpenAI platform. This Privacy Policy applies only to Armour Homes and our website. We are not responsible for the privacy practices of third-party websites and encourage you to read their privacy policies before providing any personal information.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or business operations. The current version will always be available at www.armourhomes.au/privacy-policy. We will note the date of last update at the top of this page. Where changes are material, we will take reasonable steps to notify you (e.g. by posting a notice on our website or contacting you directly).