Privacy Policy

This Wolfbrook Privacy Policy sets out how Wolfbrook Property Group 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.

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 Property Group Limited or its related entities¹ 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 engage with 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 our website. 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.

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 may share your personal information with, based on your engagement with us.

Prospective homeowners

If you engage with us to explore purchasing a residential property to live in:

• We may collect your personal information, including your contact details (e.g. name, email address etc.; personal details (e.g. age group, gender, occupation); property and investment preferences; and financial information (e.g. income, savings, equity amount in existing property).

• We collect this information so that we can provide our services to you, including to contact you with property details; match you with suitable properties; and assist in your property purchase journey (including assisting you with obtaining funding).

• We may share your personal information with third parties who may assist on your property purchase journey, including mortgage advisors/brokers and lenders we have a relationship with; lawyers and conveyancers; local councils and regulatory authorities; insurance and utility providers; and third party consultants such as designers, builders, surveyors, real estate agents, and valuers.

Residential property investors

If you engage with us to explore purchasing a residential property to invest in:

• We may collect your personal information, including your contact and identification details (e.g. name, email address, proof of identity); property preferences and investment objectives; region; and financial information (e.g. budget, income, debts, savings, KiwiSaver, tax details, other lending-related information).

• We collect this information so that we can contact you and verify your identity, and provide our services to you, including to match you with suitable properties or developments based on your preferences and circumstances; consider whether you have sufficient resources to complete the investment; assist you with obtaining with funding for the investment (if required); and provide property management services.

• We may share your personal information with third parties who may assist on your property investment journey, including mortgage advisors/brokers and lenders we have a relationship with; lawyers and conveyancers; local councils and regulatory authorities; insurance and utility providers; and third party consultants such as designers, builders, surveyors, real estate agents, and valuers.

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. income confirmation, 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; Tenancy Services; and the Tenancy Tribunal (if applicable).

Commercial property investors

If you engage with us to explore purchasing or building/developing a commercial property to invest in:

• We may collect your personal information, including your contact and identification details (e.g. name, email address); and investment and ownership information (e.g. property preferences, source of funds, ownership/investment in other entities, development history).

• We collect this information so that we can contact you and verify your identity, and provide our services to you; including to assist with the funding for, purchase, development, or investment in commercial property, including design, consent, construction, and property management.

• We may share your personal information with mortgage advisors/brokers and lenders we have a relationship with; lawyers and conveyancers; local councils and regulatory authorities; insurance and utility providers; and third party consultants such as designers, builders, surveyors, real estate agents, and valuers.

Prospective borrowers

If you engage with us to explore mortgage broking or other lending-related services (including if you are a prospective homeowner, property developer or investor seeking lending):

• We may collect your personal information, including your contact and identification details (e.g. name, email address, proof of identity); personal details (e.g. age group, gender, occupation, marital status, number of dependants); financial information (e.g. budget, income, debts, savings, KiwiSaver, tax details, other lending-related information); and information about your lending objectives and preferences (e.g. desired loan amount, loan term, repayment preferences, risk profile).

• We collect this information so that we can contact you and verify your identity; assess your borrowing needs and financial position; provide you with mortgage advice and recommendations; prepare and submit loan applications on your behalf; liaise with lenders to obtain loan approvals; and assist you through to settlement and beyond (including refinancing or restructuring your lending in the future, if required).

• We may share your personal information with third parties who may assist in providing mortgage and related services to you, including lenders and financial institutions we have a relationship with; credit reporting agencies; lawyers and conveyancers; valuers; insurers (including mortgage protection, life, and property insurers); and other professional advisers or service providers as required to facilitate your lending application, settlement, or ongoing loan management.

Wholesale investors

If you engage with us to explore making an investment in a Wolfbrook Entity:

• We may collect the information set out in our application form and required under the Financial Markets Conduct Act 2013 ("FMCA") to determine qualification as a "wholesale investor" (Sch 1, cl 3); including your identification, proof of address, proof of funds, trust deeds, and anything else required to meet our obligations under the Anti-Money Laundering (AML) and Countering Financing of Terrorism Act 2009.

• We collect this information so that we can assist you on your investment, including to contact you; determine whether you qualify as a "wholesale investor" for the purposes of the FMCA; assess your eligibility/suitability for investment in a Wolfbrook Entity; assist you with obtaining with funding for the investment (if required); and manage the investment.

• We may share your personal information with lenders we have a commercial relationship with, if required.

Additional terms about the purposes of collecting your personal 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 the information 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 (you may be contacted by us or another Wolfbrook Entity for these purposes). We may collect and share your information with 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 information multiple 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 the financing and advisory services they provide.

We may collect and share your personal information (such as your 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 Privacy Policy, 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 to follow 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 information than 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, 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 our website. 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 our servers. 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 personal information, and to ensure that third parties keep your information secure. However, due to the inherent security risks of 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 be accessed 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 the protections under the Privacy Act 2020. We will take all reasonable steps to ensure that those third parties do not access or use your personal information for any purpose other than the data storage and 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 with other Wolfbrook Entities for the purposes of referring you to, and/or promoting, 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.

info@wolfbrook.co.nz 0800 925 925 10 Show Place, Addington, Christchurch, 8024, New Zealand

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 your data 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 entity owns 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 than half of the shares in each entity are held by members of the other; 4) if each entity's operations are so closely integrated that their individual businesses cannot be clearly separated; 5) if there is another entity to which both entities are related; or 6) if one or more persons individually or collectively, directly or indirectly, whether by the legal or beneficial ownership of shares, securities or other equity, the possession of voting power, by contract, trust, or otherwise: (i) constitute or has the power to 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.