How we collect, hold, use and protect the personal information of the people we deal with, and what you can do about it.
Walker Surman Group Pty Ltd (ABN 84 700 165 368), trading as Hunter Property Buyers, is a licensed buyers agency operating in Newcastle and the Hunter region of New South Wales (Corporation Licence No. 10159621). In this Policy, “we”, “us” and “our” mean Hunter Property Buyers.
We take the privacy of the people we deal with seriously. This Policy explains what personal information we collect, why we collect it, how we hold and protect it, who we share it with, and how you can access it, correct it or make a complaint.
This Policy is written in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). We comply with the APPs in full.
Separately, we are a reporting entity under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth). That Act requires us to verify the identity of our clients and to keep those records for seven years.
If you have any question about this Policy, or you want to access, correct or complain about the handling of your personal information, contact our Privacy Officer:
The information we collect depends on your relationship with us. We only collect what is reasonably necessary for our functions as a buyers agency and to meet our legal obligations.
Sensitive information. We do not generally collect sensitive information as that term is defined in the Privacy Act. If a matter requires it, we will only collect it with your consent and only where it is reasonably necessary.
Government identifiers. We collect government-issued identifiers such as your driver licence number only where we are required or authorised by law to do so, principally under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth). We do not use government identifiers as our own identifier for you.
Wherever it is reasonable and practicable, we collect personal information directly from you. This happens when you:
We may also collect personal information from third parties, including from an electronic identity verification service acting on our behalf, from your mortgage broker, accountant, conveyancer or solicitor where you have asked them to deal with us, from selling agents in the course of a negotiation, and from publicly available sources such as land title records, planning portals and property data providers.
If we collect information about you from someone else, we will take reasonable steps to make you aware of that collection and of this Policy, unless an exception under the Privacy Act applies.
We collect, hold and use personal information for the following purposes:
If you choose not to provide the information we ask for, we may not be able to act for you. In the case of identity verification, we are prohibited by law from providing a designated service to you until customer due diligence is complete.
We do not sell your personal information. We disclose it only where it is necessary for the purposes set out above, where you have consented, or where we are required or authorised by law. We may disclose your information to:
Some of the technology platforms we use to run our business are operated by companies located outside Australia, or store data on servers located outside Australia. This means your personal information may be stored in, or accessed from, an overseas country.
Australian Privacy Principle 8 requires us to tell you about this before we disclose your information overseas, and to take reasonable steps to ensure that any overseas recipient handles your information in a way that is consistent with the Australian Privacy Principles.
| Platform | What it holds | Where stored | Overseas disclosure |
|---|---|---|---|
| Customer relationship management platform (GoHighLevel) | All client records, onboarding forms, buyer briefs, matter and transaction history, enquiry and lead information, contact details, communications, and marketing emails and SMS. GoHighLevel is our sole CRM platform. | United States | Yes |
| Accounting and invoicing platform | Accounting records, invoicing and client billing details. | United States | Yes |
| Email and document storage platform | Email correspondence and client document storage. | Australia, with support and engineering access that may occur from overseas | Limited |
| AMLTranche (identity verification) | Identity verification and customer due diligence records. | Australia (AWS Sydney, ap-southeast-2) | No |
We also use internal planning and knowledge management tools that are hosted overseas. We do not store client personal information in those tools, and they are not used to hold buyer briefs, identity documents or transaction records.
We describe these platforms by function rather than by name so that this Policy stays accurate if we change providers. If you would like to know which specific providers we use, contact our Privacy Officer and we will tell you.
The overseas country in which your personal information is most likely to be stored or accessed is the United States of America. Some providers also operate global support and infrastructure teams, which may mean information is accessed from other countries from time to time. Where we become aware of an additional country in which your information will be held, we will update this Policy.
Before engaging any provider that holds personal information overseas, and on an ongoing basis, we take reasonable steps to protect your information, including:
Please note that if you consent to your information being disclosed to an overseas recipient, or where an exception under Australian Privacy Principle 8.2 applies, we may not be accountable under the Privacy Act for how that recipient handles your information, and you may not be able to seek redress under the Privacy Act. We will always tell you if we intend to rely on your consent for an overseas disclosure.
Changes to the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) took effect on 1 July 2026. From that date, certain real estate services are regulated by AUSTRAC, and a business providing those services must verify a client’s identity before the service can be provided. We are required to do this by law, and we do it openly.
AML/CTF laws exist to stop criminals using legitimate businesses and transactions — property among them — to conceal the proceeds of crime or to fund terrorism. Property transactions involve large sums and multiple parties, which is why the sector was brought into the regime.
We have engaged AMLTranche, an Australian compliance provider, to carry out identity verification on our behalf and to hold the resulting records. AMLTranche stores this information in Australia. See section 7.
Before we can provide a regulated service, we must complete a process called customer due diligence. In practice that means confirming who you are, establishing who ultimately owns or controls any company, trust or fund involved in the purchase, and taking further steps where a client or a transaction carries a higher level of risk.
Depending on the structure you are buying in and the nature of the transaction, we or AMLTranche may ask you for:
We use this information to meet our legal obligations, confirm your identity, assess risk and satisfy ourselves that the transaction is legitimate. It also forms the compliance records we are required to keep and supports any reporting we are obliged to make to AUSTRAC. We collect only what is reasonably necessary for those purposes.
Where your identity can be confirmed electronically, our preference is to retain the verification result rather than a copy of your identity document. Guidance from the Office of the Australian Information Commissioner is that a business should not keep copies of full identity documents for AML/CTF record-keeping purposes unless another law requires it.
We will be unable to act for you, or to keep acting, until it is. Completing customer due diligence is a legal precondition to providing a regulated real estate service, so this is not a matter of discretion on our part.
Records created for AML/CTF purposes are kept for seven years from the end of our relationship with you, as the Act requires, and are then securely destroyed or de-identified. See section 12.
We may send you market updates, property insights, newsletters and information about our services by email or SMS. We only do this where you have opted in, or where you are an existing client and would reasonably expect to receive it.
Every marketing email and SMS we send contains a simple unsubscribe mechanism. You can also opt out at any time by contacting our Privacy Officer using the details in section 2. We will action your request promptly and at no cost to you.
Opting out of marketing does not stop us contacting you about a live search, an active transaction, or anything we are required to tell you by law.
We do not use or disclose your personal information for the direct marketing purposes of any other organisation.
Our website may use cookies and similar technologies to remember your preferences, understand how the site is used, and measure the performance of our advertising. This may include analytics and advertising tools operated by third parties such as Google and Meta, which may set their own cookies and may hold the resulting information overseas.
Most browsers let you refuse or delete cookies. If you disable cookies, some parts of our website may not work as intended.
Our website may contain links to third party websites. We are not responsible for the privacy practices of those websites and we encourage you to read their privacy policies.
We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure. These steps include:
No system is completely secure. While we take these steps seriously, we cannot guarantee the security of information transmitted to us over the internet.
We keep personal information only for as long as we need it for the purpose it was collected, or for as long as the law requires, whichever is longer.
Once we no longer need information and no legal obligation requires us to keep it, we destroy it securely or de-identify it.
You have the right to ask for access to the personal information we hold about you, and to ask us to correct it if it is inaccurate, out of date, incomplete, irrelevant or misleading.
To make a request, contact our Privacy Officer using the details in section 2. We may ask you to verify your identity before we release information. We will respond within a reasonable period, and in most cases within 30 days.
We do not charge for making a request. We may charge a reasonable cost-based fee for giving access to a large volume of information, and we will tell you what that fee is before we proceed.
There are limited circumstances in which we may refuse access or correction — for example, where giving access would have an unreasonable impact on someone else’s privacy, or where the law prohibits it. If we refuse, we will tell you why in writing and explain how you can complain.
We maintain a data breach response plan. If we suspect a breach has occurred, we will contain it, assess it and determine whether it is likely to result in serious harm.
Where a breach is an eligible data breach under the Notifiable Data Breaches scheme, we will notify you and the Office of the Australian Information Commissioner as soon as practicable, and tell you what has happened and what steps you can take.
If you believe we have breached the Australian Privacy Principles or mishandled your personal information, please tell us first. Contact our Privacy Officer using the details in section 2, setting out what happened and what outcome you are seeking.
We will acknowledge your complaint within 5 business days, investigate it, and give you a written response within 30 days. If we need longer, we will tell you why and keep you updated.
If you are not satisfied with our response, you can refer the matter to the Office of the Australian Information Commissioner:
Complaints about our conduct as a licensed agent, rather than about privacy, can be directed to NSW Fair Trading.
We review this Policy at least annually and update it whenever our systems, service providers or legal obligations change. The current version is always the one published on this website.
Where a change materially affects how we handle your personal information, we will take reasonable steps to notify you.
Luca Surman, Licensee in Charge, handles every privacy request, correction and complaint personally.
Hunter Property Buyers is a trading name of Walker Surman Group Pty Ltd, ABN 84 700 165 368, Corporation Licence No. 10159621.