Privacy Policy

1. Introduction

Wise Fox Consulting Group Pty Ltd ("Wise Fox", "we", "our" or "us") is committed to protecting the privacy and confidentiality of the personal information we collect, hold, use and disclose in the course of providing our conveyancing and related professional services.

This Privacy Policy explains how we manage personal information in accordance with the Privacy Act 1988 (Cth) ("Privacy Act") and the Australian Privacy Principles ("APPs").

As a reporting entity under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) ("AML/CTF Act"), we are also required to collect, verify, use, retain and, where required by law, disclose certain personal information to comply with our legal obligations relating to customer due diligence, ongoing customer due diligence, record keeping and reporting.

This Privacy Policy explains:

• the kinds of personal information we collect and hold;
• how we collect and hold personal information;
• the purposes for which we collect, use and disclose personal information;
• how we protect and store personal information;
• how you may request access to or correction of your personal information;
• how you may make a privacy complaint; and
• how we will deal with any privacy complaint.

By engaging our services or otherwise providing personal information to us, you acknowledge that your personal information will be handled in accordance with this Privacy Policy and applicable Australian privacy laws.

2. What Personal Information We Collect

The types of personal information we collect will depend on the nature of the services we provide and our legal obligations. We only collect personal information that is reasonably necessary for our business functions and activities or as otherwise required or authorised by law.

Identity and Contact Information

• full name;
• date of birth;
• residential, postal and business address;
• telephone number;
• email address; and
• occupation.

Identity Verification Information

To comply with our obligations under the AML/CTF Act and other applicable laws, we may collect information used to verify your identity, including:

• details or copies of government-issued identification documents, including Australian or foreign passports, Australian driver licences, proof of age cards, Medicare cards where appropriate, birth certificates, citizenship certificates and other permitted identity documents;
• electronic identity verification results; and
• visa or residency information where relevant.

Property and Transaction Information

• property ownership information;
• property transaction details;
• settlement information;
• mortgage and finance information;
• bank account details for settlement purposes;
• rates and land tax information; and
• other information relating to your conveyancing transaction.

Business and Entity Information

Where we act for a company, trust, partnership, association or other entity, we may collect information relating to directors, company officers, trustees, partners, beneficiaries, beneficial owners, persons acting on behalf of the entity and persons authorised to provide instructions.

Financial Information

Where required by law or reasonably necessary for our services, we may collect information relating to the source of funds, source of wealth, payment information and other financial information relevant to your transaction or required for AML/CTF compliance.

Other Personal Information

We may also collect correspondence, information contained in documents you provide, records of communications, information required to respond to enquiries or complaints, and other personal information voluntarily provided or authorised or required by law.

Where lawful and reasonably necessary, we may also collect sensitive information. We will only collect sensitive information with your consent or where authorised or required by law.

3. How We Collect Personal Information

We generally collect personal information directly from you when you engage us, complete client forms, provide instructions or identity documents, communicate with us, or provide information during the course of your matter.

Where permitted or required by law, we may also collect personal information from third parties, including:

• Australia Post Digital ID and other electronic identity verification providers;
• PEXA and other electronic conveyancing platforms;
• government departments, agencies and public registers;
• financial institutions;
• your solicitor, accountant, mortgage broker, real estate agent or other professional advisers;
• your authorised representative or attorney;
• companies, trusts or other entities for which you act; and
• other persons or organisations where authorised or required by law.

Where reasonable and practicable, we will collect personal information directly from you.

4. Purposes of Collection, Use and Disclosure

We collect, use and disclose personal information only where reasonably necessary for, or directly related to, our business functions and activities, or as otherwise required or authorised by law.

Provision of Conveyancing and Related Services

• to provide conveyancing and property transaction services;
• to act on your behalf in property settlements and related matters;
• to communicate with you and other parties involved in your transaction;
• to prepare, review and lodge legal and property-related documents; and
• to manage and administer your matter.

Identity Verification and AML/CTF Compliance

• to verify your identity and the identity of related parties;
• to comply with AML/CTF obligations;
• to conduct customer due diligence, enhanced customer due diligence and ongoing customer due diligence;
• to assess and manage money laundering, terrorism financing and other financial crime risks;
• to comply with sanctions screening and other regulatory requirements; and
• to retain records required under applicable legislation.

Legal and Regulatory Compliance

• to comply with applicable laws, regulations, court orders and regulatory requirements;
• to respond to lawful requests from government agencies, regulators or law enforcement bodies, including AUSTRAC; and
• to maintain statutory records.

Administration, Communication and Risk Management

We may use personal information to manage our business operations, maintain records, process payments and settlement transactions, store and secure information, communicate with you, respond to enquiries or complaints, improve our services, manage risk, and conduct compliance reviews and quality assurance activities.

5. Disclosure of Personal Information

We may disclose personal information where reasonably necessary for the purposes for which it was collected, or as otherwise required or authorised by law.

Recipients may include:

• identity verification providers, PEXA and other settlement platforms;
• IT, cloud, document management and practice management providers;
• professional advisers, consultants, auditors and contractors;
• AUSTRAC and other government, regulatory, law enforcement, court or tribunal bodies;
• land titles and property-related authorities;
• banks, lenders, mortgage brokers, real estate agents, solicitors, conveyancers and settlement participants;
• your authorised representatives, attorneys or agents; and
• other recipients where disclosure is required or authorised by law.

We do not ordinarily disclose personal information to overseas recipients. However, information may be stored or processed using cloud infrastructure operated by third-party providers in accordance with their system architecture.

6. Security and Storage of Personal Information

We take reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification or disclosure.

Safeguards may include secure electronic systems, password-protected databases, role-based access controls, secure document and practice management systems, encryption where available, restricted premises access, secure physical storage, staff training, confidentiality obligations and internal handling procedures.

In the event of an eligible data breach likely to result in serious harm, we will manage the incident in accordance with the Notifiable Data Breaches scheme, including notification where required.

7. Access and Correction of Personal Information

You may request access to the personal information we hold about you and ask us to correct information that is inaccurate, out-of-date, incomplete, irrelevant or misleading.

We will respond within a reasonable period. Access or correction may be refused where permitted or required by law. We may require identity verification before processing a request.

8. Privacy Complaints

Privacy complaints should be directed to our Privacy Officer. Please provide sufficient detail so that we can investigate and respond appropriately.

We will acknowledge and investigate the complaint and provide a written response. We will endeavour to respond within 30 days. If you are not satisfied with our response, you may have the right to lodge a complaint with the Office of the Australian Information Commissioner.

9. Changes to this Privacy Policy and Contact Details

We may update this Privacy Policy from time to time to reflect changes in legal obligations, business operations or privacy practices. Changes take effect when the updated policy is made available or otherwise notified.