Privacy Policy
Wolfbrook Property Management Privacy Policy
This Wolfbrook Privacy Policy sets out how Wolfbrook Property Management Limited (“we”, “us”, or “our”) collects, stores, uses and discloses your personal information in accordance with our privacy obligations under the Privacy Act 2020. It also sets out your rights to access, correct and delete personal information held about you by us. This Privacy Policy applies to any information we have collected from you and any further information we may collect.
In this Privacy Policy, when we say:
· "personal information", we mean identifiable information about you, such as your name, email address, address, telephone number and so on;
· “Wolfbrook Entity”, we mean Wolfbrook Ventures Holdings Limited or its related entities [1] from time to time, and “Wolfbrook Entity” means any one of these companies; and
· “you”, we mean you, the reader of this Privacy Policy.
By accessing our Privacy Policy and continuing to engagewith us, you agree to the terms of this Privacy Policy.
We may occasionally make changes to this Privacy Policy or alter our website functionality. Any updated Privacy Policy will be on ourwebsite. It is your responsibility to check this Privacy Policy periodically for changes.
By continuing to access our website or engage with us following notification of any changes to this Privacy Policy, you accept the changes to the Privacy Policy.
If you do not agree with any aspect of our Privacy Policy, please notify us immediately.
If you provide details of any other individuals (for example, your guarantor for a loan) to us, you confirm that you have their consent to provide us their personal information.
What information we collect, why we collect your information, and who we share your information with
What personal information is collected, by whom, and who else has access to that information, depends on your purposes and objectives for engaging us. We identify below the types of personal information that we may collect, the reasons for collection and who we mayshare your personal information with, based on your engagement with us.
Residential landlords/ property investors
If you engage with us to help you manage yourresidential property:
· We may collect your personal information,including your contact and identification details (e.g. name, email address, proof of identity); details of your property, evidence of title to the property/ proof of ownership; insurance details; your service instructions and preferences (e.g. preferred level of involvement, specific tenant requirements); and financial information (e.g. bank account details, tax details and IRD number, GST status, lending-related information).
· We collect this information so that we can contact you and verify your identity, and provide our property management services to you.
· We may share your personal information with third parties to the extent required to provide our services to you or to provide services you require, including, for example, your tenants, individuals who inquire about your property; mortgage advisors/brokers and lenders if yourequire lending; lawyers and conveyancers if you require legal services; local councils and regulatory authorities if you require consents; insurance providers (to manage claims); utility providers (to arrange utility services); tradespersons (to arrange repairs); third party consultants such as designers, builders, surveyors, real estate agents, and valuers (if required); the Tenancy Tribunal (if you are involved in a tenancy dispute); and government agencies such as Tenancy Services.
Residential tenants
If you engage with us to explore renting a residential property to live in:
· We may collect your personal information, including your contact and identification details (e.g. name, email address, proof of identity); and tenancy suitability information (e.g. incomeconfirmation, rental history, references and pet ownership).
· We collect this information so that we can contact you and verify your identity, and provide our services to you,including to assist you to select the right rental property, and provide property management services.
· We may share your personal information with third parties as needed, including the landlord/owner of the property; tradespersons (to arrange repairs); utility providers (to arrange utility services); Tenancy Services; and the Tenancy Tribunal (if applicable).
Additional terms about the purposes for collecting yourpersonal information and how we use it
We may share your personal information with other Wolfbrook Entities if we consider that this is necessary for the purposes for which theinformation was collected, or a directly related purpose.
We may also collect and share your information with other Wolfbrook Entities for the purposes of referring you to, and/or promoting, the services offered by those other Wolfbrook Entities (with your consent, you maybe contacted by us or another Wolfbrook Entity for these purposes). We may collect and share your informationwith another Wolfbrook Entity where you are engaging the services of another Wolfbrook Entity and we have information about you that is relevant to the services they are providing to you, to avoid you providing the same informationmultiple times.
As set out above, we may also collect and share your information with third parties if relevant to the purpose(s) for which you are engaging us. For example, if you require financing solutions for your property investment or development, we may share your information with lenders we have a relationship with and refer you to thefinancing and advisory services they provide.
We may collect and share your personal information (such asyour proof of identity and address) for AML purposes. We use a third-party provider, First AML, to store AML-related information. We may also use information that we collect about your computer and internet access to improve our website.
Except as otherwise stated in this PrivacyPolicy, we may also disclose personal information about you when we reasonably believe that disclosure is necessary to protect our rights, or to protect your safety or the safety of others, to comply with any applicable law, regulation, legal process or governmental request, to enforce our agreements, policies and terms, to protect the security or integrity of our website and our related services, if we are selling, assigning or transferring any of our assets or business, or if it is necessary and appropriate to facilitate the purpose for which your personal information was collected (or a directly related purpose).
If you do not provide us your information
Your provision of information to us is entirely voluntary. However, if you do not provide us the information we ask for, we may not be able to provide our services to you. For example, if you do not give us your contact details, we will not be able to send you details of properties that match your preferences, have a salesperson get in touch tofollow up, or ask you about your experience through surveys.
If you do not tell us about your preferences, we will not be able to tailor information to your needs, and we may send you more informationthan you require (or information that does not suit your needs).
If you do not provide us with other information we ask for (for example, financial information), we may not be able to provide our full suite of services to you.
How we collect information
We will mostly collect personal information from you by asking you directly. We may also obtain your personal information from another Wolfbrook Entity or a third party where relevant to the services we provide to you (to avoid you having to provide the same information multiple times), where you have indicated to another Wolfbrook Entity or third party that you are interested in our products or services or would like to hear from us, where you have authorised us to obtain a credit check from a credit reporting agency, and where otherwise allowed under the Privacy Act 2020.
Some information about your computer and internet access, and your preferences, may be collected by us through click tracking in relation to your use of our website, including the tracking of the content you access,and/or log files or third-party cookies.
Website tracking systems
When you visit our website, we track your access information, and ask you to install “cookies”. These are small text files placed on your computer to remember your website settings (such as which language you select).
Your web browser settings allow you to remove or disallow these cookies.
Information about access to our website may be sent to Google Analytics, and processed by Google to allow us to track use of ourwebsite. You can learn more about Google Analytics at http://tools.google.com/dlpage/gaoptout.
How we store your information
The personal information we collect is stored on ourservers. We may share your personal information with other Wolfbrook Entities via a third party customer relationship management (CRM) tool. We may also store your information in the Cloud or other types of networked or electronic storage, and engage third parties to perform data processing services or tracking services on our behalf.
We will take reasonable technical and organisational precautions to prevent the loss, misuse or unauthorised alteration of your personalinformation, and to ensure that third parties keep your information secure. However, due to the inherent security risksof email and the internet, we cannot guarantee the security of your personal information submitted over the internet.
Your personal information may be collected, stored and processed on servers located outside of New Zealand. As electronic or networked storage can beaccessed from various countries via an internet connection, it is not always practicable to know in which country your information may be accessed or held.
Our third-party providers based in countries outside New Zealand may not be required to protect your personal information in accordance with theprotections under the Privacy Act 2020. Wewill take all reasonable steps to ensure that those third parties do not accessor use your personal information for any purpose other than the data storageand data processing services they provide to us.
We will keep your personal information for as long as we are using it, or as required by applicable laws.
Your Rights
You have the right to ask for a copy of any personal information we hold about you, and to ask for it to be corrected if you think it is wrong.
You can find out more about your rights, and how to make a complaint, at www.privacy.org.nz.
Electronic marketing and unsubscribe option
As noted above, we may also share your information withother Wolfbrook Entities for the purposes of referring you to, and/orpromoting, services offered by those other Wolfbrook Entities that we consider you may benefit from. We or another Wolfbrook Entity may contact you about these services.
You can opt out or unsubscribe from our electronic communications by using the “Unsubscribe” option.
If you want us to stop contacting you, just let us know.
Contact Us
If you have a question, just ask.
pm@wolfbrook.co.nz
0800 90 90 30
Users Outside New Zealand
The information we collect may be processed in and transferred between your location and New Zealand. New Zealand may not have equivalent data protection laws to those in force in your location.
If you are based in Europe, you can find out more about yourdata privacy rights from your national Data Protection Agency, or the European Data Protection Board. The GDPR establishes a uniform data protection law across the European Economic Area (EEA) and aims to protect the privacy and use of EEA residents’ personal data in an increasingly digital world.
[1] An entity is related to another entity: 1) if one entityowns the other, either as a holding company or a subsidiary; 2) if the other entity(and its related companies) owns more than half of its shares; 3) if more thanhalf of the shares in each entity are held by members of the other; 4) if each entity’soperations are so closely integrated that their individual businesses cannot beclearly separated; 5) if there isanother entity to which both entities are related; or 6) if one or more personsindividually or collectively, directly or indirectly, whether by the legal orbeneficial ownership of shares, securities or other equity, the possession ofvoting power, by contract, trust, or otherwise: (i) constitute or has the powerto appoint or remove the majority of the members of the governing body of each entity;(ii) controls or has the power to control the affairs or policies of each entity;or (iii) owns more than half of the shares in each entity.
