Privacy Policy

1. About This Policy

This policy applies to all personal information collected by HAAVN, including through our website (haavn.au), our expression of interest and registration forms, our customer portal, and any direct communications with us or our related entities.

We may update this policy from time to time. The current version will always be available on our website. Your continued use of our services following any update constitutes acceptance of the revised policy. Where changes are material, we will notify you directly where we are able to do so.

2. What Personal Information We Collect

Depending on how you interact with us, we may collect the following:

Identity and contact information Name, email address, phone number, residential or business address, date of birth where required for identity verification.

Business and investment information Business name, ABN, trust or SMSF details, investment objectives, and professional background for commercial, developer, investor or government enquiries.

Property and land information Land address, title reference, lot and plan details, zoning and council classification, site dimensions, orientation, gradient and accessibility. Survey documents, planning permits or certificates of title you choose to provide.

Expression of interest and waitlist data Home typology preferences, intended use (owner-occupier, investment, development, government), preferred location or region, timeline, budget range and how you heard about HAAVN.

Order and transaction information Home configuration selections including typology, modules and finishes. Reservation records, deposit confirmation, payment receipts and order history. Correspondence related to delivery, installation and completion.

Customer portal and account information Login credentials (stored securely and never in plain text), account settings and preferences, portal activity and build-tracking history.

Financial information Payment card details (collected and processed exclusively by our third-party payment provider; HAAVN does not store card data). Bank account details where required for refund or settlement processing. Financial capacity information provided voluntarily in connection with an order.

Communication records Emails, phone calls, live chat messages, enquiries, complaints and feedback submitted to us through any channel.

Technical and usage data IP address, browser type, device type and operating system, referring URL, pages visited, time on site, actions taken and session identifiers.

Cookie and tracking data Cookie identifiers, advertising identifiers and data collected through analytics and marketing tracking tools. See Section 8 for full details.

Photography and imagery Site photographs or drone images of your land that you submit to assist with configuration or delivery planning. Footage or photography captured during the delivery and installation of your HAAVN home, which may be used for marketing and brand purposes subject to your consent.

Sensitive information We do not routinely collect sensitive information as defined under the Privacy Act (including health information, racial or ethnic origin, political opinions, religious beliefs, sexual orientation or criminal record). Where sensitive information is relevant — for example, accessibility or mobility requirements that affect your home design — we will seek your explicit prior consent and handle it with additional protections.

3. How We Collect Personal Information

We collect personal information:

• Directly from you when you complete a form, create an account, configure a home, make a reservation, or contact us through any channel

• Automatically through our website via cookies, analytics tools and server logs

• Through social media platforms when you interact with our accounts, advertising or campaigns

• From third parties including referral partners, real estate professionals, property data providers, and publicly available sources such as land title registers, council databases and planning portals

• From related entities within the Haavn Management group

Where it is lawful and practicable, you may interact with us anonymously or using a pseudonym. However, we may not be able to provide our products or services if we are unable to identify you or your land.

4. Why We Collect Personal Information

We collect personal information for the following purposes:

• Processing and managing your expression of interest or waitlist registration

• Contacting you with information about HAAVN homes, availability, pricing, and updates relevant to your enquiry

• Assessing the feasibility of delivering a HAAVN home to your site, including site evaluation and logistics planning

• Processing home configuration, reservation and order requests

• Managing the manufacture, delivery, installation and completion of your home

• Processing payments and managing financial transactions

• Operating and maintaining the HAAVN customer portal and build-tracking system

• Providing customer support and managing complaints

• Carrying out identity verification and credit or background checks where required

• Complying with legal, regulatory, financial and tax obligations

• Preventing fraud, managing risk and maintaining the security of our systems and platforms

• Conducting market research, product development and business analytics

• Sending direct marketing communications where you have consented or where permitted by law

• Supporting investor relations, government procurement and commercial partnership activities

5. Disclosure of Personal Information

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

Technology and platform service providers Third-party services used to operate our platform, including customer relationship management (HubSpot or equivalent), email delivery and marketing (Mailchimp or equivalent), website hosting and deployment (Vercel), database management, payment processing (Stripe or equivalent), workflow automation, analytics (including Google Analytics), and cloud storage and media management. These providers access personal information only as necessary to perform their services and are bound by confidentiality obligations.

Manufacturing, logistics and delivery partners To manufacture and deliver your HAAVN home, we may share your name, land address, contact details and home configuration with our factory, transport and installation partners, including HORI7ON Modular and its associated manufacturing and logistics operators.

Architectural and design partners Fraser & Partners and associated design professionals may receive configuration and site information relevant to the design and specification of your home.

Related entities HAAVN is part of the Haavn Management group, which includes 7EVEN Capital and HORI7ON Modular. We may share information within the group for operational, administrative and reporting purposes.

Professional advisers Legal, financial, accounting and technical advisers engaged by HAAVN in the ordinary course of business.

Regulatory and government authorities We will disclose personal information where required by law, court order, or a lawful request from a government, regulatory or law enforcement authority.

Business transactions In the event of a merger, acquisition, restructure, asset sale or other corporate transaction, personal information may be disclosed to relevant parties as part of due diligence or the completion of that transaction.

We do not sell, rent, trade or otherwise transfer your personal information to third parties for their own commercial purposes.

6. Overseas Disclosure

HAAVN's factory-built delivery model involves manufacturing partners located overseas, including in the People's Republic of China. In the course of managing your order, relevant personal information — including your name, land address and home configuration — may be disclosed to entities in those countries.

We also use third-party service providers whose infrastructure is located outside Australia, including in the United States. Your personal information may be stored or processed on servers in these countries.

Where we disclose personal information to overseas recipients, we take reasonable steps to ensure those recipients handle your information in a manner consistent with the Australian Privacy Principles. However, we cannot guarantee that overseas recipients are subject to equivalent privacy protections, and by providing your personal information you acknowledge this.

If you do not consent to the overseas disclosure of your information, please contact us before submitting any personal details. Note that opting out may prevent us from providing our services to you.

7. Direct Marketing

We may use your personal information to contact you with news, updates, availability information, pricing and marketing communications about HAAVN homes and related products. We will only do so where you have consented, or where we are otherwise permitted to do so by law.

Every marketing communication we send will include a clear and functional unsubscribe mechanism. You may also opt out at any time by contacting us directly at the details in Section 14.

We comply with the Spam Act 2003 (Cth). We will not send you unsolicited commercial electronic messages, and we will honour all unsubscribe requests promptly.

8. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies. By using our website, you consent to the use of cookies as described below.

Essential cookies — Required for the website to function correctly. These cannot be disabled without affecting core functionality.

Analytics cookies — Help us understand how visitors use our site, including which pages are visited most frequently and how users navigate. We use Google Analytics and similar tools for this purpose.

Marketing and advertising cookies — Used to deliver relevant advertising, retarget visitors across platforms, and measure the performance of advertising campaigns on Meta (Facebook and Instagram), Google, LinkedIn and other channels.

Preference cookies — Remember your settings and preferences to improve your experience on return visits.

You may manage or disable cookies through your browser settings. Disabling non-essential cookies will not prevent you from using the website but may limit certain functionality. Where required by applicable law, we will seek your prior consent before placing non-essential cookies.

9. Data Security

We implement appropriate technical and organisational measures to protect personal information against unauthorised access, disclosure, alteration, loss or destruction. These include encrypted data storage and transmission (TLS/SSL), access controls and authentication, secure third-party payment processing, and regular security reviews.

HAAVN is subject to the Notifiable Data Breaches (NDB) scheme under the Privacy Act. In the event of a data breach that is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) as required by law, and take all reasonable steps to contain and remediate the breach.

No system is completely secure. While we take every reasonable precaution, we cannot guarantee the absolute security of your personal information.

10. Data Retention

We retain personal information for as long as necessary to fulfil the purposes for which it was collected, and for as long as required or permitted by applicable law.

Expression of interest and waitlist data is retained for the duration of your registration and for a reasonable period afterwards, unless you request earlier deletion.

Order, transaction and delivery records are retained for a minimum of seven years in accordance with tax, financial and warranty obligations.

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

11. Children

Our website and services are directed at adults and are not intended for use by persons under the age of 18. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information without appropriate consent, please contact us and we will take steps to delete it.

12. Access, Correction and Your Rights

Under the Privacy Act, you have the right to:

Access your personal information — You may request a copy of the personal information we hold about you. We will respond within 30 days. A reasonable fee may apply where the request is complex or requires substantial retrieval effort.

Correct your personal information — If information we hold is inaccurate, incomplete, out of date or misleading, you may request that we correct it. We will act on correction requests promptly.

Complain — If you believe we have handled your personal information in breach of the Australian Privacy Principles, you may lodge a complaint with us (see Section 13).

To make an access or correction request, please contact our Privacy Officer using the details in Section 14.

13. Complaints

If you have a complaint about our handling of your personal information, please contact our Privacy Officer in writing. We will acknowledge your complaint within five business days and respond substantively within 30 days.

If you are not satisfied with our response, you may escalate your complaint to the Office of the Australian Information Commissioner:

Office of the Australian Information Commissioner (OAIC) www.oaic.gov.au 1300 363 992 GPO Box 5218, Sydney NSW 2001

14. Third-Party Websites

Our website may contain links to third-party websites, including the websites of Fraser & Partners, M2CO and Haavn Management. This Privacy Policy applies to HAAVN only. We are not responsible for the privacy practices of any third-party website and encourage you to read their privacy policies independently.