Legal

Privacy Policy

Last Updated

March 26, 2026

1. Application of this Policy

This Privacy Policy ("Policy") applies across all Rex Group websites, products, apps and services (each a "Service" and together the "Services"). The Services include the Rex Services, Rex Cirrus8 Services and Rex RealTrust Services described below.

The Rex Services are provided by Rex Software Pty Ltd (ACN 145 420 284) in Australia and Rex Labs Limited (Company Number 11241778) in the United Kingdom ("Rex Labs"). The Rex Services include the Rex website at: https://www.rexsoftware.com/ and the following Rex products and Services:

Real Estate CRM
Real Estate CRM Mobile App
Property Management
Real Estate Marketing
Real Estate Websites
Real Estate AI
Rex Reach

The Rex Cirrus8 Services are provided by CIR8 Pty. Ltd (ACN 610 625 173) and include the Rex Cirrus8 website https://cirrus8.com.au/ and Rex Cirrus8’s property management and accounting software Services.

The Rex RealTrust Services are provided by TRACC Pty Ltd (ACN 096 246 338) and include the Rex RealTrust website at: https://www.realtrust.au/ and Rex RealTrust’s trust accounting, property management, variable outgoings reconciliation and budgeting Services.

References to Rex Group in this Policy means each of the corporate entities above, as applicable to the relevant Service.

Use of the Services is subject to the Rex Group General Terms and Conditions at https://www.rexsoftware.com/legal/terms-conditions (the "Terms and Conditions"). Your contract for use of a Service (your "Contract") comprises your Proposal, any service-specific terms and conditions, this Privacy Policy and the Terms and Conditions. This Policy should be read in conjunction with the Terms and Conditions.

In the event of a conflict or inconsistency between this Policy and the Terms and Conditions, this Policy prevails in relation to the collection and processing of personal data. In all other respects, the Terms and Conditions prevail. This is consistent with the hierarchy of contract documents set out in the Terms and Conditions and in your Proposal.

When we say "you" or "your" we mean, depending on the context, you as a Member, a Contact or a Visitor, where:

"Member" means any person or entity that is registered with us to use the Services. For the avoidance of doubt, "Member" includes any person defined as a "Subscriber" or an "Invited User" in the Terms and Conditions.
"Contact" means a person about whom a Member has given us information or who a Member contacts using our Services. For example, if you are a Member, a person whose details are in your CRM would be considered a Contact.
"Visitor" means any person who visits any of the Rex Group websites.

When we say ‘personal data’ we mean identifiable information about a Member, a Contact or a Visitor. Examples include your name, email, address, telephone number, bank account details, payment information, support queries, community comments and so on. If you can’t be identified (for example, when personal data has been aggregated and anonymised) then this Policy doesn’t apply. Check out our Terms and Conditions at https://www.rexsoftware.com/legal/terms-conditions for more information on how we treat your other data.

If you are resident in the United Kingdom, the data processing terms in Section 11 of this Policy apply in respect of the processing of your personal data by Rex Group, in addition to the other provisions of this Policy.

We may need to update this Policy from time to time. Where a change is significant, we’ll make sure we let you know – usually by sending you an email.

2. Our principles of data protection

Our approach to data protection is built around four key principles. They’re at the heart of everything we do relating to personal data.

Transparency: We take a human approach to how we process personal data by being open, honest and transparent.
Enablement: We enable connections and efficient use of personal data to empower productivity and growth.
Security: We champion industry leading approaches to securing the personal data entrusted to us.
Stewardship: We accept the responsibility that comes with processing personal data.

3. How we collect your data

3.1 How we collect data for Members and Visitors

When you visit the Rex Group websites or use our Services, we collect personal data. The ways we collect it can be broadly categorised into the following:

Information you provide to us directly

When you visit or use some parts of the Rex Group websites and/or Services we might ask you to provide personal data to us. For example, we ask for your contact information when you sign up for a free trial, respond to a job application or an email offer, participate in community forums, join us on social media, take part in training and events, contact us with questions or request support.

If you purchase the Services, you may need to provide us with payment and billing information, such as your credit card details and billing address. In order to use certain parts of the Services, you also provide us with information about your Contacts, such as their names and email addresses. We use and process this information to provide the Services in accordance with your instructions.

If you don’t want to provide us with personal data, you don’t have to, but it might mean you can’t use some parts of the Rex Group websites or Services.

Information we collect automatically

We collect some information about you automatically when you visit the Rex Group websites or use our Services, like your IP address and device type. We also collect information when you navigate through our websites and Services, including what pages are looked at and what links are clicked on. This information is useful for us as it helps us get a better understanding of how you’re using our websites and Services so that we can continue to provide the best experience.

Some of this information is collected using cookies and similar tracking technologies. If you want to find out more about the types of cookies we use, why, and how you can control them, take a look at our cookie notice.

Information we get from third parties

The majority of information we collect, we collect directly from you. Sometimes we might collect personal data about you from other sources, such as publicly available materials or trusted third parties like our marketing and research partners. We use this information to supplement the personal data we already hold about you, in order to better inform, personalise and improve our Services, and to validate the personal data you provide.

Where we collect personal data, we’ll only process it:

to perform a contract with you, or
for the primary purpose of providing the Services, or for a related secondary purpose that you would reasonably expect (in accordance with the Australian Privacy Principles), or
where we have legitimate interests to process the personal data and they’re not overridden by your rights (for individuals in the United Kingdom, in accordance with UK Data Protection Laws), or
in accordance with a legal obligation, or
where we have your consent.

If we don’t collect your personal data, we may be unable to provide you with all our Services, and some functions and features on the Rex Group websites may not be available to you.

Your personal data remains your property and we will not use nor make available for use your personal data other than in accordance with this Privacy Policy. For the avoidance of doubt, the data licence granted to Rex Group under the Terms and Conditions does not override this Policy in relation to the processing of personal data. Where the Terms and Conditions grant Rex Group a licence to use Data (as defined in the Terms and Conditions), that licence is subject to this Policy to the extent the Data constitutes personal data.

Where you are a Member, Rex Group processes Contact data on your behalf and in accordance with your instructions (including the instructions set out in your Contract). You retain responsibility for compliance with applicable privacy laws in respect of any Contact data you provide to Rex Group or input into the Services, including ensuring that you have obtained any necessary consents. For individuals in the United Kingdom, the formal allocation of Data Controller and Data Processor roles is set out in Section 12 of this Policy.

3.2 How we collect data for Contacts

For purposes of this section, ‘you’ and ‘your’ refers to Contacts.

We collect and process personal data about you when Members use our Services and we process your personal data on their behalf. The ways we collect your data can be broadly categorised into the following:

Information we receive about you from Members

A Member may provide personal data about you to us when using the Services. For example, when a Member enters your name, number and email address into our website or service, adds notes about their engagement with you or uses the Services to send you an email. You may have the opportunity to update some of this information by electing to update or manage your preferences via emails sent or dashboards provided by a Member.

Information we collect automatically

We collect some information about you automatically when you interact with information (like emails) that Members send using our Services, or when you browse a Member’s website. This includes information like your IP address, device type and the way you interact with the email or website. Some of this information is collected using cookies and similar tracking technologies. If you want to find out more about the types of cookies we use, why, and how you can control them, take a look at our cookie notice.

Information we get from third parties

Sometimes we might collect personal data about you from other sources, like publicly available information and information from trusted third parties like our marketing and research partners or social media platforms. We make sure that any third parties are legally allowed to share your information with us. We use this information to help provide Services that let our Members give you a more relevant and effective service.

Our Members’ approach to privacy and security might be different to ours. If you’re someone who doesn’t have a relationship with us, and a Member has entered your personal data into the Rex Group websites or Services, you’ll want to contact that Member directly.

4. How we use your personal data

First and foremost, we use your personal data to operate the Rex Group websites and provide you with any Services you’ve requested, and to manage our relationship with you. We also use your personal data for the following purposes:

To communicate with you

This may include: providing you with information you’ve requested from us (like training or education materials) or information we are required to send to you; operational communications, like changes to the Rex Group websites and Services, security updates, or assistance with using the Rex Group websites and Services; marketing communications in accordance with your marketing preferences; and asking you for feedback or to take part in any research we are conducting (which we may engage a third party to assist with).

To support you

This may include assisting with the resolution of technical support issues or other issues relating to the websites or Services, whether by email, in-app support or otherwise.

To bill and collect money owed to us by you

This includes sending you emails, invoices, receipts, and alerting you if we need a different credit card number. We use third parties for secure credit card transaction processing, and those third parties collect billing information to track your orders and credit card payments.

To enhance the Rex Group websites and Services and develop new ones

For example, by tracking and monitoring your use of websites and Services and the personal information of Contacts so we can keep improving, or by carrying out technical analysis of the Rex Group websites and Services so that we can optimise your user experience and provide you with more efficient tools.

To protect

So that we can detect and prevent any fraudulent or malicious activity, and make sure that everyone is using the Rex Group websites and Services fairly and in accordance with our terms of use.

To market to you

In addition to sending you marketing communications, we may also use your personal data to display targeted advertising to you online – through our own websites and Services or through third party websites and their platforms. Electronic marketing communications will contain clear instructions describing how you can opt out of such communications.

To analyse, aggregate and report

We may use the personal data we collect about you, Contacts and other users of the Rex Group websites and Services (whether obtained directly or from third parties) to produce aggregated and anonymised analytics and reports, which we may share publicly or with third parties. We will not publish any information which is identifiable to any person or entity individually, that contains any client confidential information or intellectual property or is not otherwise combined with similar data of our other customers and clients.

We may use anonymised data for any legitimate business purpose, such as to improve our Services or for the purpose of our partnerships with trusted third parties.

To improve our Services

We may use information like your Contacts’ details and your engagement with them, so we can make more informed predictions, decisions, and products for our Members.

For example, we may use data from Member accounts to recommend better products or enable prediction tools to identify Contacts likely to purchase a property. We process data for our data analytics projects for the purpose of improving and enhancing our products and Services for our Members. In Australia, we do so on the basis that this is a related secondary purpose that you would reasonably expect given the nature of the Services. For individuals in the United Kingdom, we process this data in reliance on our legitimate business interests. We take the privacy of personal data seriously, and will continue to implement appropriate safeguards to protect personal data from misuse.

If you or your Contact prefers not to share this data, you can contact us at any time by email at the relevant email address listed at the end of this Policy.

For our data analytics projects

Our data analytics projects use data from Member accounts, including your personal data, to provide and improve the Services. We use information, like your email engagement history, provided to us by Members, so we can make more informed predictions, decisions, and products for our Members. If you’d rather us not to share this data, you can opt out of data analytics projects at any time by emailing us at the relevant email address listed at the end of this Policy.

AI-powered features

Certain Services include AI-powered features (including Rex AI, Rex AI+ and AI Admin) that process personal data to deliver functionality such as automated prospecting, predictive analytics, content generation, workflow automation and natural language CRM operations. Where we process personal data through AI-powered features, we do so on the basis of contract performance (to deliver the Services you have subscribed to). We may also process personal data through AI-powered features for the purpose of improving and enhancing the Services. In Australia, this is a related secondary purpose that you would reasonably expect given the nature of the Services. For individuals in the United Kingdom, we rely on our legitimate business interests in improving and enhancing our products and Services for our Members.

Some AI-powered features, including AI Admin, use large language models (LLMs) provided by third-party AI providers to process natural language instructions from CRM users. When a CRM user issues an instruction to AI Admin (for example, to update a contact record, draft an email, or retrieve information), the personal data required to fulfil that instruction may be processed by the LLM. This means that personal data held in the CRM — such as contact names, email addresses, phone numbers, property details, and transaction records — may be sent to the AI provider’s infrastructure for processing. The specific personal data accessed in any given interaction depends on the instruction issued by the CRM user.

AI-powered features are subject to the Reasonable Use Policy set out in clause 4.7 of the Terms and Conditions. Rex Group may monitor usage of AI-powered features to manage service delivery and cost of sale. We do not use personal data processed through AI-powered features to train general-purpose AI models outside the Rex Group Services without your consent. Our third-party AI providers are contractually prohibited from using personal data processed through the Services to train, fine-tune or improve their models.

Some AI-powered features may generate recommendations, suggestions or prioritisations based on personal data (for example, identifying contacts who may benefit from follow-up). Where such features produce outputs that could significantly affect a Contact, a CRM user reviews and approves the recommended action before it is executed. Rex Group does not use AI-powered features to make solely automated decisions that produce legal effects or similarly significant effects on individuals without meaningful human oversight. If you believe an automated decision has been made about you using AI-powered features, you have the right to request human intervention, to express your point of view, and to contest the decision. You can exercise these rights by contacting us at the relevant email address listed at the end of this Policy.

If you have questions about how AI-powered features process personal data, you can contact us at any time using the details set out at the end of this Policy.

5. How we can share your personal data

There will be times when we need to share your personal data with third parties. We will only disclose your personal data to:

other companies in the Rex group of companies;
third party service providers and partners who assist and enable us to use the personal data to, for example, support delivery of or provide functionality on the website or Services, or to market or promote to you;
regulators, law enforcement bodies, government agencies, courts or other third parties where we think it’s necessary to comply with applicable laws or regulations, or to exercise, establish or defend our legal rights;
an actual or potential buyer (and its agents and advisers) in connection with an actual or proposed purchase, merger or acquisition of any part of our business; and
other people where we have your consent.

In providing the Services, Rex Group engages specific third-party sub-processors who process personal data on our behalf. These include cloud data warehouse providers (such as Snowflake Inc.) for business intelligence and analytics purposes, and third-party AI providers for the processing of natural language instructions through AI-powered features. A current list of sub-processors, including their names, locations and the nature of their processing activities, is available at https://www.rexsoftware.com/legal/authorised-sub-processor-register or on request by contacting us at the relevant email address listed at the end of this Policy. We will notify Members of any material changes to our sub-processor list in accordance with the terms of their Contract.

6. International personal data transfers

When we share personal data, it may be transferred to, and processed in, countries other than the country you live in. The Services are hosted on Google Cloud Platform, with Australian customer data stored in Australian data centres and United Kingdom customer data stored in European Economic Area or United Kingdom data centres, unless otherwise agreed. These countries may have laws different to what you’re used to. Rest assured, where we disclose personal data to a third party in another country, we put safeguards in place to ensure your personal data remains protected.

For individuals in Australia, personal data may be disclosed to overseas recipients located in the United States, the European Union and the United Kingdom (for example, where we use cloud infrastructure or sub-processors based in those jurisdictions). Before disclosing personal data to an overseas recipient, Rex Group takes reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles in relation to that data. This may include entering into contractual arrangements that require the overseas recipient to handle personal data in a manner consistent with the APPs, or satisfying ourselves that the recipient is subject to laws or a binding scheme that is substantially similar to the APPs. If you would like further details about the countries in which our sub-processors are located, please contact us using the details set out in the Contact us section below.

For individuals in the UK, this means that your data may be transferred outside of the UK. In particular, personal data may be transferred to Australia for business intelligence and analytics processing in our data warehouse environment, and to jurisdictions including the United States for the purpose of processing natural language instructions through AI-powered features (where AI inference infrastructure may be located). Where your personal data is transferred outside the UK, it will only be transferred to countries that have been identified as providing adequate protection for UK data, or to a third party where we have approved transfer mechanisms in place to protect your personal data — specifically, by entering into the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses, as applicable. Rex Group conducts Transfer Impact Assessments to evaluate the level of data protection in each recipient country and implements supplementary safeguards where necessary, including encryption, access controls, and contractual protections. You may request a copy of the applicable transfer safeguards by contacting us using the details set out in the Contact us section below.

7. Sensitive Data

You agree not to input, maintain, copy or otherwise insert any "Sensitive Data" or any other information that might be considered of a sensitive, privileged or proprietary nature that might cause a loss of privacy or security to an individual or organisation if accessed or used by a third party (other than those entitled and authorised to do so). Sensitive Data includes (without limitation): passports, birth certificates, visas, national ID cards and drivers licences.

This obligation is incorporated by reference into the Terms and Conditions and is enforceable as a contractual obligation under your Contract.

8. Data security

Security is a priority for us when it comes to your personal data. We’re committed to protecting your personal data and have appropriate technical and organisational measures in place to make sure that happens.

Rex Group maintains security controls consistent with industry standards for cloud-hosted SaaS platforms, including: encryption of data in transit (TLS) and at rest; access controls based on the principle of least privilege, with role-based permissions and multi-factor authentication for administrative access; regular vulnerability assessments and penetration testing; logging and monitoring of access to personal data; and documented incident response procedures. We regularly review and update our security practices to address evolving threats.

For personal data processed within our cloud data warehouse for business intelligence purposes, additional safeguards include dedicated role-based access controls restricting access to authorised Rex Group personnel, audit logging of all data queries and access, and defined retention and deletion procedures. For personal data processed through AI-powered features, safeguards include encrypted communications between all system components, permission controls ensuring AI features respect existing CRM access permissions, input validation to prevent misuse, rate limiting and monitoring to detect anomalous usage, and secure logging of all AI interactions with restricted access to logs.

Payment related information and payment history (when stored on our servers) is always encrypted.

However, the Internet is not in itself a secure environment. Users should only enter, or instruct the importation of, data to the database within a secure environment. This means that your browser must support at least 128-bit encryption.

Rex Group stores personal data in the location Rex Group considers will give you the most efficient access from wherever in the world you may be. Access and storage controls via the Services are however subject to, and limited by, your Rex Group account security settings.

If access to a Service requires you to use a password, it is your responsibility to keep your password safe. Rex Group does not have access to your password and are therefore unable to access your personal data should you forget your password; you will need to follow the password reset process that is available upon login.

9. Data retention

How long we keep your personal data depends on what it is and whether we have an ongoing business need to retain it (for example, to provide you with Services or to comply with any laws). Our retention periods will vary depending on the type of data involved, but, generally, we’ll refer to these criteria in order to set the retention period:

whether we have a legal or contractual obligation;
whether we need the data to provide our Services;
whether our Members have the ability to access and delete the data within their accounts;
whether our Members would reasonably expect that we would retain the data until they remove it or until their accounts are closed.

When we no longer have an ongoing business need to retain we’ll make sure your data is deleted or anonymised or, if this is not possible (for example, because it’s been stored in backups), then we’ll securely store your data and isolate it from any further access until deletion / anonymisation is possible.

The following specific retention periods apply to data processed through our business intelligence and AI features:

Business intelligence data: Personal data held in our data warehouse for analytics purposes is retained for the duration of the Member’s Contract. Upon termination or expiry of the Contract, personal data is deleted from the data warehouse within 90 days unless a longer period is required by law. Historical data may be anonymised and retained for long-term trend analysis.
AI interaction logs: Logs of AI Admin interactions (including user prompts, data retrieved, and actions taken) are retained in Australia for 12 months for audit, support and operational monitoring purposes, after which they are deleted or anonymised.
LLM provider processing: Personal data sent to our third-party AI providers for inference processing is processed ephemerally and is not retained by the provider after the inference request is completed. Our AI providers are contractually required to delete input and output data upon completion of each request and are prohibited from using such data for any secondary purpose, including model training.

10. Your rights

It’s your personal data and you have certain rights relating to it. When it comes to marketing communications, you can ask us not to send you these at any time – just follow the unsubscribe instructions contained in the marketing communication, or send your request to the relevant email address listed at the end of this Policy.

You also have rights to:

know what personal data we hold about you, and to make sure it’s correct and up to date;
request a copy of your personal data, or ask us to restrict processing your personal data or delete it; and
object to our continued processing of your personal data.

In addition, you have the right to object specifically to the processing of your personal data by AI-powered features. If you exercise this right, Rex Group and the relevant Member will take reasonable steps to ensure your personal data is excluded from AI processing. To exercise this right, contact the Member who holds your data or contact Rex Group directly using the details set out at the end of this Policy. Please note that exercising this right may limit the ability of the Member to use certain AI-powered features in respect of your personal data.

These rights extend to personal data held in our business intelligence and analytics environment and to personal data processed through AI-powered features, including interaction logs. Where a valid erasure request is received, Rex Group will ensure deletion propagates to the data warehouse and to AI interaction logs within the applicable timeframes.

You can exercise these rights at any time by sending an email to us at the relevant email address listed at the end of this Policy.

If you are a Contact and a Member receives a request from you to correct, delete, amend, or give access to your personal data, and the Member believes the data is stored on the Rex Group websites or in a Service, the Member must notify us in writing within five (5) days via email to the relevant contact email address listed at the end of this Policy. We will acknowledge the request and provide an official response no later than thirty (30) calendar days after receiving it.

If you’re not happy with how we are processing your personal data, please let us know by emailing us. We will review and investigate your complaint, and try to get back to you within a reasonable time frame. You can also complain to your local data protection authority. They will be able to advise you how to submit a complaint.

11. Third party websites

The Services may contain links to third-party applications. Rex Group takes no responsibility for the privacy practices or content of these applications.

12. UK Data Processing

This Section 12 applies to Rex Group’s processing of your personal data if you are resident in the UK. This Section 12 supplements the other provisions of this Privacy Policy for UK residents, in compliance with UK Data Protection Laws.

In this Section 12, "UK Data Protection Laws" means the Data Protection Act 2018, the UK GDPR (Regulation (EU) 2016/679 of the European Parliament), the Privacy and Electronic Communications Directive (2002/58/EC) (as updated by Directive 2009/136/EC) and the Privacy and Electronic Communications Regulations 2003 (SI 2003/2426); in each case, to the extent in force and as such are updated, amended or replaced from time to time.

For the purpose of UK Data Protection Laws, as between you and Rex Group, you are the Data Controller and Rex Group is the Data Processor of the personal data that may be processed by Rex Group on your behalf in connection with the Services.

The personal data processing activities carried out by Rex Group in connection with provision of the Services are described in this Policy. Rex Group shall comply with the provisions and obligations imposed by UK Data Protection Laws at all times when processing your personal data in connection with the Services.

In relation to Rex Group’s processing of personal data of UK residents, Rex Group agrees to:

process your personal data only in accordance with your written instructions from time to time (including those set out in your Contract);
process your personal data only for the duration of your Contract with Rex Group in respect of the Services;
not process such personal data for any purpose other than in accordance with this Privacy Policy;
take reasonable steps to ensure the reliability of all its personnel who have access to such personal data, and ensure that any such personnel are committed to binding obligations of confidentiality with respect to such personal data;
implement and maintain technical and organisational measures and procedures to ensure an appropriate level of security for such personal data, including protecting such personal data against the risks of accidental, unlawful or unauthorised destruction, loss, alteration, disclosure, dissemination or access;
inform you within twenty-four (24) hours if any such personal data is (while within Rex Group’s or its subcontractors’ or affiliates’ possession or control) subject to a ‘personal data breach’ (as defined in the UK Data Protection Laws) or is lost or destroyed or becomes damaged, corrupted or unusable;
be liable for the acts and omissions of any third parties (including any subcontractors and affiliates) that process your personal data as if they were the acts and omissions of Rex Group;
not disclose any personal data other than as expressly provided for in your Contract or this Policy;
as you so direct, return or irretrievably delete all your personal data on termination or expiry of your Contract, and not make any further use of such personal data (except to the extent applicable law requires continued storage of the personal data by Rex Group and Rex Group has notified you accordingly);
maintain records of all processing operations under its responsibility that contain at least the minimum information required by the UK Data Protection Laws ("Data Processing Records");
upon demand by any governmental or regulatory body or authority with responsibility for monitoring or enforcing compliance with the UK Data Protection Laws ("DP Regulator"), make Data Processing Records available to the relevant DP Regulator;
provide to you and any DP Regulator all information and assistance necessary or desirable to demonstrate or ensure compliance with the obligations in this Section 12 and/or the UK Data Protection Laws; and
provide co-operation and assistance in relation to any request you make to exercise your rights under the UK Data Protection Laws in relation to your personal data.

13. How to contact us or make a complaint

We’re always keen to hear from you. If you’re curious about what personal data we hold about you, have a question or feedback for us on this Policy, the Rex Group websites or Services, you can contact us by email at the following email addresses:

In relation to the Rex website, products and Services: privacy@rexsoftware.com.au;
In relation to the Rex Cirrus8 website, products and Services: info@cirrus8.com.au; and
In relation to the Rex RealTrust website, products and Services: info@realtrust.net.au.

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If you wish to make a complaint about our processing of your personal data, you can make that complaint to us at the relevant email above or to the relevant data protection or privacy regulator:

Australia: the Office of the Australian Information Commissioner at: https://www.oaic.gov.au/privacy/privacy-complaints/lodge-a-privacy-complaint-with-us
United Kingdom: the Information Commissioner’s Office, the UK supervisory authority for data protection issues at www.ico.org.uk

March 2026

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