Privacy Policy

What personal information we collect

The personal information we collect depends on the nature of your relationship with Cygnet West and the services or interactions involved.

Where lawful and practicable, you may choose to deal with us anonymously or using a pseudonym. However, this may not be possible where we need to identify you to provide services, manage a property matter, complete a transaction, meet legal obligations or conduct customer due diligence.

Depending on the circumstances, we may collect and hold:

• Contact and identification details: such as your name, address, email address, telephone number, role, organisation and authorised representative details.
• Identity verification information: such as identification document details, verification results, beneficial ownership information, politically exposed person status and other information required for customer due diligence, sanctions screening or AML/CTF compliance.
• Financial and transaction information: such as payment details, banking information, invoicing records, financial capacity information or other information relevant to a property transaction, tenancy, engagement or service.
• Property and engagement information: such as details of properties you own, occupy, manage, lease, buy, sell or are interested in, together with related valuation, transaction, tenancy, inspection or service information.
• Communications and interaction records: such as correspondence, enquiries, forms, meeting notes, call records, complaints, feedback and service history.
• Website and digital information: such as cookie data, analytics information, device information and usage data collected when you interact with our website or digital platforms.
• Sensitive information: such as biometric information for identity verification, where required or permitted by law, or other sensitive information where you consent or where collection is otherwise permitted.
• Publicly available information: such as information from property, land title, corporate or professional registers, public websites, property portals, social media or other publicly accessible sources where relevant to our services or legal obligations.

How we use personal information

We use personal information where it is reasonably necessary for our business activities, where you have consented, or where the law permits or requires us to do so.

We may use personal information to:

• respond to enquiries and provide property, valuation, advisory, leasing, sales, asset management and related services;
• manage relationships with clients, customers, suppliers, tenants, landlords, buyers, sellers, agents, contractors and other stakeholders;
• prepare proposals, agreements, valuation reports, transaction documents, tenancy records, service records and related communications;
• support inspections, site access, meetings, property management, leasing, sales, advisory and transaction processes;
• verify identity, assess customer risk, conduct sanctions screening, identify beneficial owners and meet customer due diligence obligations;
• manage payments, invoices, supplier arrangements, complaints, disputes and business records;
• protect our people, clients, premises, systems and records, including through security, cyber security, fraud prevention and incident response activities;
• comply with legal, regulatory, professional, audit, insurance, record keeping and reporting obligations;
• manage and improve our services, systems, governance, risk management, training, reporting and business operations; and
• send relevant Cygnet West updates, invitations, market insights and service information where permitted by law.

Direct marketing and digital communications

We may use your contact details to send relevant Cygnet West updates, event invitations, market insights and information about services that may be of interest to you. You may opt out of direct marketing at any time by using an unsubscribe function or contacting us.

We may use cookies, pixels and similar technologies on our website and digital platforms to understand website activity, improve user experience and support relevant communications. You can manage cookies through your browser settings, noting this may affect some website features. 

AML/CTF verification

Where required for anti-money laundering and counter-terrorism financing compliance, we may collect and use personal information, and in limited circumstances sensitive information, to verify identity, assess customer risk, identify beneficial owners and meet customer due diligence obligations.

If requested information is not provided, we may be unable to onboard you, provide services, or proceed with a transaction where identity verification or other due diligence is required.

We may use trusted technology providers, including First AML Pty Ltd, to help collect and verify identity information on our behalf. Where biometric information is requested, it will only be collected where permitted by law and handled for the relevant verification purpose.

AML/CTF information may be disclosed to regulators, law enforcement agencies, courts or other bodies where required or authorised by law. Where service providers use cloud or cross-border support arrangements, personal information may be stored or accessed outside Australia.

We may disclose personal information to third parties where reasonably necessary for the purposes set out in this policy or where required or authorised by law.

• entities within the Cygnet West group where necessary for business operations;
• clients, counterparties, landlords, tenants, buyers, sellers or other parties involved in a transaction or engagement;
• professional advisers and service providers, including lawyers, conveyancers, valuers, consultants, contractors, IT providers, payment processors and identity verification providers;
• government, regulatory, law enforcement or dispute resolution bodies, including where reporting is required by law;
• financial institutions, insurers, auditors and other parties supporting our business operations; and
• a purchaser or proposed purchaser of all or part of our business.

Overseas disclosure

We may disclose personal information to overseas service providers where reasonably necessary for our operations, including where cloud or support arrangements involve access or storage outside Australia. Where we do so, we take reasonable steps to ensure the information is handled consistently with applicable privacy requirements.

We collect personal information directly from you where possible. We may also collect information from other sources where it is relevant to our services, business activities or legal obligations.

• From you: for example, when you contact us, engage our services, complete a form, attend an inspection or meeting, provide identification documents, use our website or otherwise interact with us.
• From third parties: such as clients, agents, counterparties, property portals, advisers, referees, financial institutions, government bodies, public registers, identity verification providers and other service providers.
• From public or digital sources: such as land title or corporate registers, public websites, social media platforms, analytics tools and cookie technologies used on our digital platforms.

If you provide personal information about another person, please ensure you have authority to do so and that the person is aware their information may be handled in accordance with this Privacy Policy.

We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure. These measures may include access controls, secure systems, monitoring, staff training and physical security safeguards.

• Retention: we retain personal information for as long as reasonably necessary for the purpose for which it was collected, or as required by law.
• Destruction or de-identification: when personal information is no longer required, we take reasonable steps to destroy or de-identify it, unless we are required to keep it.

We maintain procedures to identify, assess, and respond to data breaches. Where a data breach is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner in accordance with the Notifiable Data Breaches scheme.

We may update this Privacy Policy from time to time to reflect changes to our business practices, services, systems or legal obligations. The current version will be made available on our website. Where changes are material, we will take reasonable steps to bring them to your attention.

Access and correction requests

You may ask us to provide access to personal information we hold about you, or to correct information you believe is inaccurate, incomplete, out of date or misleading.

To help us assess your request, we may ask you to verify your identity and provide enough detail for us to locate the relevant information. For complex or detailed requests, we may ask you to complete an access request form.

There is no fee for making a request. However, reasonable administrative charges may apply for access in accordance with applicable law. If a charge applies, we will advise you before proceeding.

We aim to respond to access and correction requests within 30 days. If we require more time, we will let you know.

In some circumstances, we may not be required or permitted to provide access to all information requested or make a requested correction. If this occurs, we will explain our reasons where it is reasonable to do so. If we do not agree to correct information, you may ask us to attach a statement noting that you consider the information to be inaccurate, incomplete, out of date or misleading.

Privacy complaints and enquiries

If you have a question, concern or complaint about how we handle personal information, please contact us using the details in this Privacy Policy.

We will review the matter, make reasonable enquiries where required, and seek to respond within a reasonable timeframe. If you are not satisfied with our response, you may be able to refer the matter to the Office of the Australian Information Commissioner or another relevant regulator.

Company Secretary
Phone: 08 6375 6004
Address: Level 26, 197 St Georges Terrace, Perth WA 6000
Email: [email protected]