Report of Commissioner Initiated Investigation into Property Lovers and fastproperty.ai

Privacy Commissioner’s Foreword

Protecting individuals’ privacy is always important, but it is especially so for individuals and groups experiencing vulnerability and marginalisation. For such people, losing control over one’s personal information can exacerbate disempowerment and disenfranchisement. As a result, a driving factor in the initiation of proactive regulatory action for the Office of the Australian Information Commissioner (OAIC) will be where there is a risk of substantial harm to individuals and the community, especially to vulnerable people and groups.

In November 2024, I issued two determinations which dealt with the unfair collection of personal information of vulnerable individuals, such as those involved in court proceedings related to bankruptcy, divorce or deceased estates. Those determinations concerned entities, Master Wealth Control t/as DG Institute and Property Lovers, which had been scraping personal information from court lists and other sources to provide clients with a list of potentially motivated property sellers, in order to enable predatory sales practices.

A number of companies owned and operated by Ms Dominique Grubisa and associate Kevin Grubisa, including Master Wealth Control and Property Lovers, have in recent years been the subject of regulatory scrutiny arising out of allegations of misleading and unlawful conduct.

Grubisa-owned and -operated companies have been the subject of real and continuing consumer concern, and have also demonstrated a consistent trend of transposing problematic practices between and across corporate entities in order to respond to or avert regulatory intervention or restrictions. For this reason, the OAIC was particularly concerned to ensure that both the letter and the spirit of our November 2024 determinations were complied with. Our ensuing compliance activities identified the prospect that Property Lovers was continuing the acts and practice that had been the subject of our adverse findings under the rubric of a new online platform, fastproperty.ai. This report is of our investigation into Property Lovers and fastproperty.ai.

Establishing whether Property Lovers had ownership and control of fastproperty.ai was a complex task made more difficult by a lack of fulsome responses provided by the respondent to requests for information and documents. Ultimately, the investigation was able to establish that Property Lovers effectively controlled the fastproperty.ai platform, and indeed that Ms Grubisa herself had been directly involved in providing instructions on elements related to the platform.

As detailed below, our investigation was sufficient to satisfy me that Property Lovers Pty Ltd did not collect, use or disclose personal information in connection with the fastproperty.ai platform and did not contravene the Privacy Act.

Although the OAIC has not made any findings against Property Lovers or fastproperty.ai with respect to Privacy Act compliance, during the course of the investigation, the OAIC identified matters outside its jurisdiction which may point to contraventions of other legislation. While it is not the OAIC’s role to make findings about such matters, relevant information was referred to the relevant regulator.

Summary and background

In November 2024, the OAIC concluded investigations against two companies owned by or linked to Kevin and Dominque Grubisa, Master Wealth Control Pty Ltd t/a DG Institute (Master Wealth) and Property Lovers Pty Ltd (Property Lovers). Both companies provided products or courses to paying clients to assist them in the identification of real estate properties for development or other profitable resale. The OAIC’s investigations focussed on the collection and use of personal information by the entities, and concluded that the scraping of personal information to target vulnerable people was unlawful and had interfered with the privacy of individuals, in contravention of the Privacy Act 1988 (Privacy Act).

Two determinations were handed down on 22 November 2024, finding breaches of Australian Privacy Principles (APPs) 1.3, 3.5, 5 and 10.2, and including declarations that Master Wealth and Property Lovers must not continue or repeat the conduct identified in the determination and must cease the unfair collection of personal information, including of individuals in distressed situations.

Following the determinations, the OAIC made enquiries of Property Lovers to verify compliance with the declarations. In response, Property Lovers provided a statutory declaration, an independent IT services report, and screenshots from its website, which it submitted as evidence of compliance. No enquiries were made with Master Wealth, as that entity ceased operating around 10 February 2025, following the disqualification of its sole director.

During the course of monitoring compliance with the determination, the OAIC grew concerned that Property Lovers may be continuing to operate its services in contravention of the Privacy Act. Specifically, and with appreciation to an informant who provided key information, the OAIC became aware that Property Lovers may be offering its services under the wrapper of the ‘fastproperty.ai’ mobile/web application.

Fastproperty.ai is a research tool developed by and provided to Property Lovers’ clients and is a searchable map-based platform, with filters and overlays populated by property-related data feeds (fastproperty.ai). A promotional video appearing on the Property Lovers website demonstrated the operation of a map overlay feature which the narrator stated could identify ‘motivated sellers’ from properties ‘on court lists, mortgagee sales or even deceased estates.’ This suggested that Property Lovers could be continuing the conduct which was the subject of the Commissioner’s November 2024 adverse determination.

The OAIC opened an investigation into fastproperty.ai in April 2025. In response to notices, Property Lovers claimed that fastproperty.ai was an independent, licensed third-party software platform. However, the investigation concluded that Property Lovers had procured, instructed and funded its development, controlled its content and publicly asserted its ownership and associated intellectual property rights.

The investigation involved a comprehensive review of an extensive amount of information, including that compelled through production notices and in compulsory examination of key individuals. Ultimately, the investigation concluded that fastproperty.ai did not collect, use or disclose personal information. The Commissioner therefore closed the investigation but considered it was in the public interest to inform the community of the outcome and publish this summary report.

This report should not be taken as an endorsement of Property Lovers’ acts or practices or an assurance of its broader compliance with the APPs.

The investigation

In January 2025, the OAIC received complaints that Property Lovers was using fastproperty.ai as a means to identify ‘distressed’ properties, and potentially continuing practices identified in the prior determination, including the collection of personal information from court lists.

On 11 April 2025, the OAIC commenced an investigation into Property Lovers and the operation of fastproperty.ai, examining the same APPs and practices as considered in the prior determination.

Throughout the course of the investigation, the OAIC conducted compulsory examinations of three key individuals, including the sole director of Property Lovers, Mr Kevin Grubisa. A significant amount of investigative resource was invested in establishing who owned and operated fastproperty.ai and its relationship with Property Lovers and Mr Grubisa.

The OAIC issued 13 notices under s 44(1) of the Privacy Act to compel access to information and documents to inform its investigation. Investigators reviewed a range of sources of evidence, including:

• The source coding and underlying scripts of the fastproperty.ai website;
• Business records and other technical information provided from third parties involved in the development of the fastproperty.ai website and platform, including the platform’s user interface and underlying architecture;
• Social media content posted by the fastproperty.ai accounts, and ownership/registration details of those accounts;
• Information presented to users as part of the sign up and user registration process to the fastproperty.ai website;
• Public-facing material, videos and content on the Property Lovers and fastproperty.ai websites;
• Information provided by a key informant; and
• Other information and documents produced in response to notices issued under s 44(1) of the Privacy Act.

A key focus of the investigation was the threshold question of whether fastproperty.ai collected, used, disclosed, held or otherwise dealt with personal information.

Personal information is defined in the Privacy Act as:

information or an opinion about an identified individual, or an individual who is reasonably identifiable:

1. whether the information or opinion is true or not; and
2. whether the information or opinion is recorded in a material form or not.^[1]

Personal information is therefore information or an opinion about an identified individual, or an individual who is reasonably identifiable.

Information is ‘about’ an individual where there is a connection between the information and the individual. This is ultimately a question of fact, and will depend on the context and the circumstances of each particular case. Information will be ‘about’ someone where the person is the subject matter of the information or opinion.

Generally speaking, an individual is ‘identified’ or ‘reasonably identifiable’ when they are distinguishable from other persons. The key factor to consider is whether the information can be linked back to the specific person that it relates to.

Investigation findings

Consistent with its intended use as a means to enable users to identify target properties for profitable resale, fastproperty.ai offers a number of functions including:

• ‘AI-powered’ assistants (e.g., Buyer’s Agent, Property Analyst, Estimator);
• Deal feasibility calculators with renovation/flip analysis;
• Advanced suburb-level filters and insights;
• Heatmaps and overlays (e.g., flood, bushfire);
• Property comparison and investment scoring tools;
• Comparative market analysis and valuation tools;
• Construction and renovation costing estimates;
• ‘AI powered’ design and image recognition tools; and
• Automation of market scans, opportunity summaries, and due diligence workflows.

The data used to power the platform is supplied from various sources and includes:

• Geospatial visualisation data, including satellite imagery, street maps and geospatial data;
• Live searching of property listings, including access to searches across multiple real estate websites and links to real estate agency information; and
• Property and suburb data and overlays from third-party data research companies, which encompass categories such as property specifications, suburb profiles, zoning and development data and market activity.

These datapoints generally concern information about a locality or property only. Although in certain circumstances property data such as address information may constitute personal information, the investigation did not identify any such personal information in the inspection of the relevant materials.

A specific focus of the investigation was a feature offered by fastproperty.ai which, in the platform architecture, was labelled as the ‘potentially motivated’ map overlay (map overlay).  A promotional video appearing on the Property Lovers website demonstrated the operation of the map overlay feature which was asserted to identify properties ‘on court lists, mortgagee sales or even deceased estates.’ On its face the overlay appeared to purport to identify vendors in distressed situations, equipping users of the platform to target those potentially vulnerable sellers. The OAIC had concerns that the map overlay may be sourced from personal information scraped from court lists or deceased estates, as had been the previous practice of Property Lovers and which had been the subject of the Commissioner’s adverse determination.

On examination, Property Lovers conceded that prior to November 2024, the map overlay did draw on information scraped from court listings, but this practice changed after the Commissioner’s determination in November 2024. The investigation found that from November 2024 to November 2025, the map overlay was populated with information Property Lovers obtained from a third-party property research company (the research company).

One of the services offered by the research company is a weekly ‘Distressed Properties Report’, which is available on a monthly subscription, and was used by Property Lovers to identify properties for inclusion in the map overlay.

The Distressed Properties Report is compiled by the research company by running approximately 40 key search terms over all the major real estate listing portals. Such search terms include:

• ‘Mortgagee in possession’;
• ‘Distressed property for sale’;
• ‘Divorce’;
• ‘Forced property sale’;
• ‘Desperate vendor’;
• ‘Selling below cost/value’;
• ‘Deceased estate’;
• ‘Must sell’;
• ‘Price slashed’; and
• ‘Bank says sell’.

Listings that contain such terminology are then compiled in the Distressed Properties Report and provided to Property Lovers to inform the map overlay. The information compiled in the report was limited to the following datapoints extracted from public real estate listing portals:

• Address;
• Suburb;
• State;
• Postcode;
• Type (house, unit, etc);
• Number of beds;
• Listing price; and
• The listing heading.

During the course of the investigation, in November 2025, Property Lovers removed the map overlay from fastproperty.ai altogether.

Did Property Lovers collect, use or disclose personal information for the purposes of fastproperty.ai?

Property Lovers was responsible for the collection and use of information that powered fastproperty.ai, and the subsequent disclosure of that information to users of the platform as they navigated the various search features, filters and map overlays.

There is no evidence that the geospatial visualisation data, the live real estate listings or the property or suburb data used to power fastproperty.ai contained information or opinion about an identified individual, or an individual who was reasonably identifiable.

The only information collected, used or disclosed by fastproperty.ai, that may possibly constitute personal information, is the information contained in the map overlay, which was publicly promoted by Property Lovers as a tool to identify ‘distressed sellers’ and ‘motivated vendors’.

However, the information used to populate the map overlay was derived from a third-party Distressed Properties Report and was limited to information relating to a property’s address, suburb, state, postcode, type, number of beds, listing price and listing heading.

‘Address’, ‘suburb’, ‘state’ and ‘postcode’ details are information that identify the particular location of a property. ‘Type’ and ‘number of beds’ details are information that relates to the physical construction or composition of a property. ‘Listing price’ is information on the valuation of a property. None of this information constitutes information or opinion about an individual.

The ‘listing heading’ is a free text description of the property, primarily used for the purpose of attracting the attention of potential purchasers. The information displayed in this heading is variable and at the discretion of the vendor or selling agent. On occasion, listing headings will contain statements that identify the property as being sold as part of a deceased estate, or that the owner ‘must sell’ or is otherwise motivated to sell.

Although the owner of a property may be reasonably identifiable via a land title search and linked back to the property listing, the information contained in the listing heading is generic marketing language. This kind of information is not information or opinion about an individual, but rather about a commercial transaction.

A review of the listing headings within the datasets used by Property Lovers to populate the map overlay did not identify any examples where specific information or opinions about a vendor were disclosed or could be inferred. For example, listing headings within the dataset included:

• Amazing 3-bed apartment with great value in prime location, Motivated to Sell;
• PREMIER 2434m2 - MOTIVATED VENDOR - DON'T MISS OUT;
• Highly Motivated Seller - MUST SELL!;
• Motivated Vendor - Priced to Sell!;
• MOTIVATED OWNER- COME INSIDE-BE SURPRISED!;
• MOTIVATED OWNER OPEN TO OFFERS;
• Stunning Central Coast Property - Going to Auction and Motivated to Sell; and
• Motivated Vendor - Must Sell! Don't miss out on this unbeatable bargain!

While the Distressed Properties Report utilised key word searches such as ‘divorce’, which may suggest information or opinion about a person, no listing headings containing that word were located within the datasets used by Property Lovers to populate the map overlay.

Closure of investigation

Based on the information obtained through the investigation, the Commissioner was satisfied that Property Lovers did not collect, use or disclose personal information for the purposes of the map overlay, or the fastproperty.ai platform more broadly.

As Property Lovers did not collect, use or disclose personal information in the course of operating fastproperty.ai, it did not contravene the APPs.

The OAIC’s investigation has now been closed.

Publication of report and referral

The Privacy Act envisages circumstances in which it is in the public interest to disclose information acquired in the course of exercising powers such as making preliminary inquiries or undertaking an investigation. Section 33B of the Privacy Act enables the Commissioner to disclose information acquired in the course of exercising powers or performing functions or duties under the Privacy Act, if the Commissioner is satisfied that it is in the public interest to do so.

Having regard to the matters listed in s 33B(2), the Commissioner decided that publishing this report would be in the public interest. The Commissioner considered that allegations of non-compliance with public privacy determinations are a matter of public interest and concern. The Commissioner also took into account the level of media and community interest in the activities of Property Lovers and fastproperty.ai, including that the conduct has been subject of queries at senate estimates hearings and written correspondence from a member of parliament.

Additionally, investment decisions, particularly those that take place outside of the regulated scheme of financial advisory services, no matter how small, are important decisions for individual investors and the community at large. Investment decisions regarding real estate can impact both the vendor and purchaser, and have a wider implication for the property market in the context of publicly reported sale prices. In light of home ownership rates within the community and current concerns regarding housing affordability, transparency in respect of practices that impact this market and the broader economy is important.  Having considered all of these factors, the Commissioner formed the view that publication of a summary of the findings of this extensive investigation into practices relevant to the purchase of real estate within Australia is in the public interest.

During the course of the investigation, the OAIC received a number of reports relating to the acts and practices of Property Lovers. Whilst we have assessed each report carefully, some issues were outside the OAIC’s jurisdiction. The OAIC has concerns about the potential for ongoing harm to Australian consumers arising out of the claims that gave rise to this investigation, and, as such, the OAIC has provided details of these matters   to the appropriate regulator for consideration.

This report is limited to findings made under the Privacy Act and should not be interpreted as making findings in relation to any other legal or regulatory framework.

^[1] Section 6, Privacy Act 1988