1. Who we are
Parker Hadley Pty Ltd ABN 91 639 336 431, trading as Parker Hadley Buyers Agents (Parker Hadley, we, us or our), provides buyer’s agency services for owner-occupiers in Sydney and investment-property clients nationally.
This policy applies to personal information handled through our website, enquiries, bookings, client onboarding, buyer’s agency services, marketing and AML/CTF customer due diligence.
2. Personal information we collect
The information we collect depends on how you interact with us and the service we provide. It may include:
- contact details such as your name, email address, telephone number and residential address;
- date of birth and identity information where required;
- information provided through website forms, fact finds, Calendly bookings and client onboarding;
- property-buying objectives, budget, finance and borrowing information, timing, preferred locations and property requirements;
- property-search, inspection, due-diligence, price-assessment, negotiation, auction and purchase information;
- information about people involved in your purchase, such as a partner, solicitor, conveyancer, mortgage broker, accountant or other adviser;
- communications and engagement records;
- marketing preferences, consent evidence and unsubscribe records; and
- website technical and security information such as IP address, request information and security logs generated in operating and protecting our website.
3. AML/CTF customer due diligence
Parker Hadley is an AML/CTF reporting entity for relevant buyer’s agency services. We collect and handle personal information to identify and verify customers and relevant persons, assess and manage money-laundering, terrorism-financing and proliferation-financing risks, carry out customer due diligence, and meet applicable recordkeeping and reporting obligations.
Depending on the customer and transaction, AML/CTF information may include:
- full legal name, date of birth and residential address;
- identity-document details and verification results;
- information about persons acting on behalf of a customer, beneficial owners, controllers, companies, trusts, trustees or other relevant persons;
- politically exposed person, targeted financial sanctions and adverse-media screening results;
- source-of-funds or source-of-wealth information where required; and
- other information reasonably required under AML/CTF law and Parker Hadley’s AML/CTF program.
Depending on the verification method, Securexchange may collect a facial image or other sensitive information needed for identity verification. Where a particular electronic verification method requires specific notice, consent or an alternative verification pathway, that process is presented through Securexchange on Parker Hadley’s behalf and retained as part of the AML/CDD record.
Parker Hadley uses Securexchange by InfoTrack as its primary AML/CTF customer-due-diligence and identity-verification system. Parker Hadley does not routinely retain copies or images of passports, driver licences or similar identity documents in Pipedrive, Microsoft 365 or ordinary email where Securexchange is being used for the verification.
Securexchange may use automated identity-verification and screening tools to produce verification or screening results. Those results inform our customer-due-diligence process. Parker Hadley reviews relevant outcomes when deciding whether it can commence or continue a service.
4. How we collect personal information
We generally collect personal information directly from you when you contact us, submit a website form, request a resource, book through Calendly, complete a fact find, engage us, communicate with us during a property purchase, or complete AML/CTF customer due diligence.
We may also collect relevant information from your authorised representatives and advisers, referral sources, local buyer’s agents working with Parker Hadley, selling agents, solicitors or conveyancers, mortgage brokers, property managers, inspectors, public records and property-information sources.
Where AML/CTF law requires us to identify another person connected with a customer or transaction, such as a beneficial owner, controller, trustee or person acting on behalf of a customer, we may collect that person’s information from the customer or another authorised source. We take reasonable steps to ensure the person is made aware of the relevant privacy information unless doing so would be inconsistent with law or could prejudice an investigation.
5. Why we collect, use and disclose personal information
We collect, hold, use and disclose personal information for purposes reasonably connected with our business and legal obligations, including to:
- respond to enquiries and arrange meetings;
- understand a prospective client’s circumstances and requirements;
- provide and administer buyer’s agency services;
- search for, assess and inspect properties and conduct due diligence;
- prepare price assessments, negotiate, bid at auction and assist with property purchases;
- coordinate a purchase with people authorised to act for or assist our client;
- manage client records, communications, invoicing and business administration;
- meet licensing, insurance, legal, accounting, regulatory and AML/CTF obligations;
- operate and secure our website and business systems;
- record and respect marketing preferences and unsubscribe requests; and
- send ongoing email marketing where we have a recorded consent basis or are otherwise permitted to do so under Australian law.
Information collected specifically for AML/CTF compliance is not used simply because it may be useful for unrelated marketing.
6. Who we may share information with
Where authorised by the client, or where permitted or required by law, we may disclose relevant information to:
- Parker Hadley personnel and authorised contractors;
- local buyer’s agents involved in an investment-property purchase;
- selling agents and agencies;
- solicitors, conveyancers, mortgage brokers, lenders, accountants and other professional advisers;
- building, pest, strata and other due-diligence providers;
- property managers;
- technology, hosting, email, CRM, form and scheduling providers;
- InfoTrack/Securexchange and providers involved in AML/CTF verification and screening;
- insurers, auditors, legal advisers and cyber/security advisers where needed; and
- AUSTRAC, courts, regulators, government bodies or law-enforcement bodies where required or authorised by law.
We limit disclosures to information reasonably necessary for the relevant purpose. Strategically sensitive information such as a client’s maximum purchase price, negotiation ceiling, finance limit or motivation is not disclosed to a seller, vendor or selling agent without the client’s specific instruction, unless disclosure is required by law.
7. Technology providers and overseas handling
Our main technology providers are Microsoft 365, Pipedrive, Calendly, WordPress/Gravity Forms, Cloudflare and Securexchange by InfoTrack.
- Pipedrive: Parker Hadley’s account data region is Australia.
- Microsoft 365: Parker Hadley’s tenant data location for Exchange Online, SharePoint and OneDrive is Australia.
- Securexchange by InfoTrack: Parker Hadley’s current AML/CDD configuration is Australia-only. Securexchange retains the relevant AML/CDD record and can provide it to Parker Hadley in PDF form if required.
- Calendly: user and invitee data is stored in United States-based data centres.
- Cloudflare: Parker Hadley uses Cloudflare for website hosting/security and delivery. Cloudflare operates a global network and states that website traffic metadata may be processed in its main data centres in the United States and Europe.
Some global providers may use overseas support personnel or subprocessors as part of providing their services. Where the Privacy Act applies, Parker Hadley takes reasonable steps required by Australian privacy law in relation to overseas handling or disclosure.
8. Direct marketing
Providing contact details, making an enquiry, booking a call or requesting a resource does not, by itself, subscribe you to ongoing Parker Hadley marketing.
For ongoing Parker Hadley email marketing, our default business rule is recorded express opt-in. If you opt in, we may send property insights, market updates, newsletters and information about Parker Hadley services. You can unsubscribe at any time using the unsubscribe facility in the email or by contacting us.
Commercial electronic messages will identify Parker Hadley and provide a functional unsubscribe facility where required. We retain marketing consent and suppression records as reasonably necessary to demonstrate consent and respect opt-outs.
9. The Sydney Property Buyer’s 101-Point Checklist
If you request The Sydney Property Buyer’s 101-Point Checklist, we use the first name and email address supplied on the form to send the requested checklist. Requesting the checklist does not subscribe you to ongoing Parker Hadley marketing.
If you separately select the optional marketing checkbox, we will also use your details for the marketing described at the point of collection until you unsubscribe or otherwise withdraw that consent.
10. Website cookies and technology
As at the effective date of this policy, parkerhadley.com.au does not use website analytics tags, advertising pixels, remarketing tags, session-recording tools, embedded maps or video, social-feed widgets, externally hosted fonts or other optional third-party tracking technology.
The website and Cloudflare may use essential or security-related cookies, technical logs and network information needed to host, operate, protect and deliver the website. Calendly is a separate booking service and may use cookies and similar technologies on its own booking pages in accordance with its privacy settings.
If Parker Hadley introduces analytics, advertising pixels or other material tracking technology in future, we will review and update the relevant privacy disclosures and controls before or when that technology is introduced.
11. Security
We take reasonable steps appropriate to the size and nature of our business and the information involved to protect personal information against misuse, interference, loss and unauthorised access, modification or disclosure.
Our controls include multi-factor authentication on our core business systems, individual and least-privilege access, strong unique passwords, supported and patched software, device security, backup and recovery arrangements, security or administrator logging where available, established service providers, and minimising unnecessary duplication of identity and other sensitive information.
No internet transmission, cloud service or electronic storage system can be guaranteed to be completely secure. If a data incident occurs, we assess and respond to it under our incident procedure and applicable law, including the Notifiable Data Breaches scheme where it applies.
12. How long we keep information
We retain information for as long as reasonably required for the purpose for which it is held and to meet legal, regulatory, licensing, insurance, accounting, dispute-management and evidentiary requirements.
- Gravity Forms entries for people who do not become clients are deleted from the website after 90 days. Relevant information may already be retained in Pipedrive or Microsoft 365 where there is a legitimate business reason to keep it.
- Where a person becomes a client, relevant information may be retained as part of the client and transaction record. WordPress is not used as the primary client record system.
- NSW licensing law requires specified licensee records relating to transactions and the licensed business to be retained for at least three years after they are made.
- AML/CTF customer-due-diligence records generally must be retained for seven years after the relevant business relationship ends, or for the applicable period after an occasional transaction.
- Marketing consent and unsubscribe/suppression records may be retained for as long as reasonably necessary to demonstrate consent and ensure an opt-out is respected.
- Other personal information that is no longer reasonably required is deleted, de-identified or otherwise managed in accordance with applicable law and legitimate business requirements.
13. Access and correction
You can ask to access personal information we hold about you or ask us to correct information you believe is inaccurate, out of date, incomplete, irrelevant or misleading. We may need to verify your identity before providing access or making a correction.
Where the Privacy Act applies, we deal with access and correction requests in accordance with the Act, including any permitted exceptions. AML/CTF records may also be subject to secrecy, tipping-off and other legal restrictions that affect what can lawfully be disclosed.
Requests should be directed to the Parker Hadley Privacy Contact using the details in section 16.
14. Anonymity and pseudonyms
You can generally browse our website without identifying yourself. We need identifying or contact information where it is impracticable to deal with you anonymously, including when you ask us to contact you, engage our services or where AML/CTF or other laws require us to identify or verify a person.
15. Government-related identifiers
Where we collect government-related identifiers or identification-document information, we use and disclose them only where permitted or required by law. We do not adopt government identifiers as Parker Hadley’s own identifiers.
16. Privacy enquiries and complaints
Privacy Contact — Director
Parker Hadley Buyers Agents
1 Nagurra Place
Rozelle NSW 2039
Australia
Phone: 1300 438 438
Email: [email protected]
We will acknowledge a privacy complaint promptly and aim to provide a substantive response within 30 days. Where the Privacy Act applies to the matter and you are not satisfied with our response, you may be able to complain to the Office of the Australian Information Commissioner (OAIC).
17. Changes to this policy
We may update this Privacy Policy when our information-handling practices, service providers or legal obligations change. The current version will be published on parkerhadley.com.au with its effective date.