Privacy Policy

In plain language

• General enquiry: we only need your name, contact details and the property request you sent us. We do not ask for ID, finance documents or credit information for a general enquiry.
• Engaged buyer: when you sign a buyer's advocacy agreement, we collect what we need to act for you, identity verification, brief details, finance status indicators, and any documents required for offer, DD or settlement.
• What we don't do: we don't sell your data, we don't share it with vendors or selling agents without your permission, and we don't keep finance documents beyond the period we are required to.
• Privacy contact: [email protected]. For external escalation, OAIC: oaic.gov.au, 1300 363 992.

Introduction

This privacy policy explains how Bold Property Group handles personal information collected through enquiries, strategy sessions, buyer engagements, due diligence, settlement support and website use. We handle personal information in accordance with the Australian Privacy Act 1988 and the Australian Privacy Principles.

This Privacy Policy applies to all personal information we collect through our website, email communications, telephone interactions, and in-person meetings. By accessing our services or website, you consent to our collection and use of personal information as described in this policy.

When We Collect Financial Documents

We do not need detailed financial documents for a general enquiry. Finance documents, pre-approval letters, credit information or identity verification are only requested where they are needed for one of the following:

• Buyer engagement (signed buyer's advocacy agreement)
• Pre-qualification at the start of an engagement, to confirm purchasing capacity for the brief
• Submission of a property to a selling agent on your behalf (the agent will typically require evidence of capacity before opening private negotiations)
• Preparation of an offer or contract
• AML/CTF or other regulatory compliance checks
• Settlement coordination (where conveyancer or financier requires the document)

If you are not at one of these steps, you do not need to give us financial documents to receive a general response.

Information We Collect

The information we hold falls into two categories. Most information is held only while needed for the purpose for which it was collected.

Enquiry data (held for everyone who contacts us)

• Name, email address, phone number
• Property request submitted via our forms (asset type, location, budget band, timing, notes)
• Any correspondence we exchange

Engaged-client data (held only after a signed engagement)

• Date of birth and identification documents (for AML/CTF compliance, where required)
• Employment and income indicators (for pre-qualification purposes only)
• Mailing address and any additional contact details you provide

Property and Purchasing Information

• Property preferences (location, type, size, features, price range)
• Your investment timeline and urgency
• Previous property ownership history
• Current accommodation details
• Property search history on our website

Financial Information (engaged clients only, when needed)

• Borrowing capacity indicators and loan pre-approval letters, held securely, only when required for an active engagement step
• Indicative deposit position
• Credit information, only ever obtained through an approved third-party mortgage broker, only with your separate express written consent, and only where required for a specific engagement step
• Budget constraints stated in the brief

If you are an enquiry, not an engaged client, none of the above is collected.

Technical Information

• IP address and device information
• Browser type and version
• Pages visited and time spent on our website
• Cookies and similar tracking technologies

Communication Information

• Email communications and correspondence
• Telephone call records (date, duration, content summaries for service quality)
• Meeting notes and consultation records
• Feedback and survey responses

How We Collect Information

We collect personal information in several ways:

• Directly from you: Through inquiry forms, registration pages, consultation meetings, phone calls, and email communications
• Automatically: Through website analytics, cookies, and similar technologies
• From third parties: With your consent from mortgage brokers, banks, real estate agents, and conveyancers for verification and service delivery purposes
• Publicly available sources: Land registry information and public property data for valuation and market analysis

How We Use Your Information

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

Service Delivery

• Providing buyer's advocacy and property sourcing services
• Conducting property market research and analysis
• Preparing property recommendations and due diligence reports
• Coordinating with conveyancers, inspectors, and other service providers on your behalf
• Negotiating on your behalf within the scope of your engagement

Pre-qualification and Engagement

• Assessing your borrowing capacity and financial readiness
• Verifying your identity and AML/CTF compliance
• Determining engagement suitability and investment strategy

Communication

• Sending property alerts and market updates
• Responding to your inquiries and requests
• Providing service updates and transaction notifications
• Sending invoices and payment reminders

Legal and Regulatory Compliance

• Complying with Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) obligations
• Meeting tax and accounting requirements
• Responding to legal requests and court orders
• Maintaining service records for dispute resolution

Business Improvement

• Analyzing service usage and performance metrics
• Improving website functionality and user experience
• Conducting market research and client satisfaction surveys
• Training and quality assurance of our team

Marketing (with consent)

• Sending newsletters, market reports, and educational content
• Inviting feedback and testimonials
• Conducting promotional campaigns and special offers

Disclosure of Your Information

We do not sell, trade, or rent your personal information to third parties. However, we may share your information with the following parties in the course of providing our services:

Service Providers

• Conveyancing lawyers and legal advisors
• Licensed mortgage brokers and finance providers
• Property inspectors and valuers
• Building and pest inspectors
• Insurance brokers and providers

Other Professionals

• Real estate agents and property managers
• Accountants and bookkeepers (for fee processing only)
• Cloud-based data management and CRM service providers

Legal Requirements

We may disclose personal information when required by law, court order, or government authority. This includes AML/CTF reporting obligations, tax office inquiries, and law enforcement investigations. We will only disclose the minimum information necessary to comply with such obligations.

Consent

We will not disclose your information to any third party beyond those listed above without first obtaining your express written consent, except as required by law.

Data Security

The security of your personal information is a top priority for Bold Property Group. We implement comprehensive security measures to protect your data against unauthorized access, alteration, disclosure, or destruction. Our security practices are informed by leading international frameworks including ISO/IEC 27001 and ISO 9001 principles. We continuously review and improve our security posture in line with industry best practice.

Security Measures Include:

• Encryption of sensitive data in transit and at rest (AES-256 and TLS 1.2 or higher)
• Secure password authentication with industry-standard protocols
• Regular security audits and penetration testing
• Restricted access to personal information on a need-to-know basis
• Secure document management and file handling procedures
• Staff training and confidentiality agreements
• Regular backup and disaster recovery procedures
• Incident response and breach notification procedures

Despite these measures, no data transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security of your information. If you suspect a security breach, please contact us immediately at [email protected].

Breach Notification

If we become aware of a data breach that is likely to result in serious harm to any affected individual, we commit to:

• Containing and assessing the breach within 72 hours of detection
• Notifying affected individuals and the Office of the Australian Information Commissioner (OAIC) within 7 days of confirming a notifiable breach
• Providing affected individuals with a clear description of the breach, the information involved, the steps we are taking, and what they can do to protect themselves
• Documenting the incident, root cause, and remediation actions in our internal incident register

This timeline is shorter than the 30-day maximum allowed under the Privacy Act 1988 (Notifiable Data Breaches scheme), we believe affected individuals deserve a faster response than the legal minimum.

Data Retention

We retain personal information only for as long as necessary to provide our services, meet legal obligations, and resolve disputes. Retention periods vary depending on the type of information and legal requirements:

• Transactional records: Retained for 7 years (tax and AML/CTF compliance)
• Client service files: Retained for 3 years after engagement conclusion
• Marketing communications: Retained until you unsubscribe or withdraw consent
• Website analytics: Retained for 24 months

When information is no longer required, we securely destroy or anonymize it in accordance with our data destruction policy.

Your Rights under the Australian Privacy Act 1988

The Privacy Act 1988 (Cth) provides you with the following rights regarding your personal information:

Right of Access

You have the right to request access to the personal information we hold about you. We will provide this information within 30 days of your request, subject to legal exceptions.

Right to Correction

If you believe any personal information we hold about you is inaccurate, incomplete, or out of date, you can request correction. We will take reasonable steps to correct the information and notify affected parties where necessary.

Right to Complaint

If you believe we have breached the Australian Privacy Principles or your privacy rights, you can lodge a complaint with:

• Bold Property Group: [email protected]
• Office of the Australian Information Commissioner (OAIC): www.oaic.gov.au or 1300 363 992

Right to Opt-Out

You can opt out of receiving marketing communications from us at any time by unsubscribing from our mailing list or contacting us directly. This will not affect your access to essential service communications.

Right to Privacy Principle Compliance

You have the right to request that we comply with the Australian Privacy Principles. If we fail to do so, you may lodge a complaint with the OAIC.

Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to enhance your user experience and gather analytics data. Cookies are small data files stored on your device that help us remember your preferences and understand how you use our website.

Types of Cookies We Use:

• Essential cookies: Required for website functionality (login, navigation, security)
• Performance cookies: Collect anonymous data about how you use our site to improve service quality
• Functional cookies: Remember your preferences and previous interactions
• Marketing cookies: Track your online activity to deliver targeted advertising (only with consent)

You can control cookie settings through your browser preferences. Most browsers allow you to refuse cookies or alert you when cookies are being sent. However, blocking essential cookies may impair website functionality.

Third-Party Analytics

We currently use Google Analytics (GA4) to measure website traffic and basic engagement. This collects standard analytics signals (page views, referrer, anonymised IP, device type). We do not enable advertising-personalisation features by default. Visit policies.google.com/privacy to learn how Google handles its share of the data. We do not currently use third-party advertising trackers, retargeting pixels, or session-replay tools on the public site.

Links to External Websites

Our website contains links to external websites, including real estate portals, government agencies, and financial institutions. We are not responsible for the privacy practices of external websites. We recommend reviewing their privacy policies before providing personal information. This Privacy Policy applies only to information collected through Bold Property Group's website and services.

Children's Privacy

Bold Property Group's services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from minors. If we become aware that we have collected information from a child under 18, we will take steps to delete such information and terminate the child's account or service access immediately.

International Data Transfer

Currently, Bold Property Group operates within Australia. All data is stored on Australian-based servers and managed in compliance with Australian Privacy Principles. If we expand services internationally in the future, we will implement appropriate safeguards to protect your information in accordance with applicable laws in each jurisdiction.

Contact for Privacy Inquiries

If you have questions about this Privacy Policy, wish to access or correct your personal information, or have a privacy concern, please contact our Privacy Officer:

We respond to all privacy inquiries within 30 days. If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC): oaic.gov.au, 1300 363 992.