Wolfbrook Property Group Privacy Policy (Australia)

Wolfbrook Property Group (“we”, “us”, “our”) is committed to protecting the privacy of personal information we collect about individuals in Australia. This Privacy Policy explains how we handle personal information in accordance with the Privacy Act 1988 (Cth) (“Privacy Act”) and the Australian Privacy Principles (“APPs”).

Effective date: 06-06-2026

Last updated: 06-06-2026

Drafting note (delete before publishing): Square-bracketed text is a placeholder for you to complete. Every statement below should reflect what Wolfbrook Property Group actually does — a policy that overstates or misstates your practices is itself a compliance risk. Have an Australian privacy lawyer review before publishing.

1. About this policy and who it applies to

Wolfbrook Property Group is a New Zealand–based business that offers [products/services] to, and advertises to, individuals in Australia. Because we collect personal information from individuals in Australia, we treat ourselves as bound by the Australian Privacy Principles in respect of that information.

This policy applies to personal information we collect through:

our website(s) at [URL(s)];
our advertising and marketing activities directed at Australian audiences;
our dealings with you as a customer, supplier, tenant, or enquirer; and
any other interaction in which you provide personal information to us.
Drafting note (delete before publishing): If Wolfbrook also has a separate New Zealand policy, state clearly which one governs Australian customers, and keep the two consistent so you don’t make conflicting representations.

2. The kinds of personal information we collect and hold

“Personal information” means information or an opinion about an identified individual, or an individual who is reasonably identifiable. We may collect and hold:

Identity and contact details: name, email address, postal address, phone number.
Transaction information: records of products or services you have purchased or enquired about, and related correspondence.
Payment information: [describe — e.g. billing details processed by our third-party payment provider; we do not store full card numbers].
Marketing and preferences: your communication preferences and your responses to our marketing.
Technical and online information: IP address, device and browser information, and information collected via cookies and similar technologies (see Section 9).
[Any other categories — e.g. tenancy applications, employment applications, loyalty programs.]
Sensitive information. We do not generally collect “sensitive information” (such as health information, racial or ethnic origin, or political/religious beliefs). [If you do, state what, why, and that you collect it only with consent or as otherwise permitted under APP 3.]

3. How we collect personal information

We collect personal information:

Directly from you — when you make a purchase or enquiry, fill in a form, subscribe to communications, or contact us.
Automatically — through cookies and analytics tools when you use our website (see Section 9).
From third parties — such as [advertising platforms, analytics providers, referral partners], where you have provided information to them or consented to its sharing.
Where it is reasonable and practicable, we collect personal information directly from you. If we collect it from a third party, we will take reasonable steps to ensure you are made aware of the matters set out in this policy.

4. Why we collect, hold, use and disclose personal information

We collect, hold, use, and disclose personal information for purposes including:

providing our products and services to you and processing transactions;
responding to your enquiries and providing customer support;
direct marketing and advertising (see Section 6);
improving our website, products, and services;
meeting our legal and regulatory obligations; and
[other purposes specific to Wolfbrook Property Group].
We will only use or disclose your personal information for the purpose we collected it, for a directly related secondary purpose you would reasonably expect, or otherwise as permitted or required by law.

5. Who we disclose personal information to

We may disclose personal information to:

service providers who help us operate our business (e.g. hosting, IT, payment processing, delivery, analytics, advertising platforms);
professional advisers (e.g. accountants, lawyers); and
regulators, law enforcement, or others where required or authorised by law.
We do not sell your personal information.

6. Direct marketing

We may use your personal information to send you marketing communications about our products and services where you would reasonably expect this or where you have consented.

You can opt out at any time by:

using the unsubscribe link in any electronic marketing message; or
contacting us using the details in Section 12.
We will action opt-out requests promptly. Our electronic marketing complies with the Spam Act 2003 (Cth) (consent, identification, and a functional unsubscribe facility), and any telemarketing complies with the Do Not Call Register Act 2006 (Cth).

Drafting note (delete before publishing): Given Wolfbrook is advertising into Australia, this is one of the most operationally important sections. Make sure your actual consent collection, sender identification, and unsubscribe handling match what you say here.