Privacy Policy

Boffo Real Estate Privacy Policy

Boffo Real Estate is bound by the Australian Privacy Principles (APPs) under the Privacy Act1988 (Cth) (Privacy Act). We take our obligations seriously and have adopted internal policies and procedures to ensure that all personal information is dealt with in accordance with the Privacy Act. Please take a moment to read our Privacy Policy as this Privacy Policy explains why we collect your personal information and how we manage it.

Please note that this policy may be updated from time to time, without notice to you, in order for us to comply with the Privacy Act or to improve our privacy practices. An up-to-date Privacy Policy will be published on our website.

In this policy, personal information means any information about you (whether true or not) which identifies you or from which your identity is reasonably identifiable.

1. Why do we collect personal information?

We collect and hold personal information about you where it is reasonably necessary for one of our functions or activities. For example, we may collect your personal information to:

• offer or provide you with our goods and services;
• communicate with you, including to email you tax invoices and receipts, notify you of changes to your rent, and provide you with information about your property;
• deal and transact with you, including to process payments, respond to any queries from you or to attend to your complaints;
• verify your identity and assess your suitability to rent a property;
• meet our legal obligations, including to enforce our contractual obligations;
• comply with our obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act), including conducting customer identification and verification procedures; and
• otherwise, to conduct and manage our business.

You are not obliged to provide us your personal information. You also have the option of not identifying yourself or of using a pseudonym when dealing with us. However, we may not be able to supply you the relevant goods or services where it is impracticable for us to deal with you anonymously or with you operating under a pseudonym, or where we are required under the AML/CTF Act to establish and verify your identity before providing certain services to you or the person you are acting on behalf of.

2. What kind of personal information do we collect?

For our clients, the types of information we may collect and hold from time to time may include:

• your name;
• addresses;
• contact details;
• date of birth;
• employment details including payslips;
• government related identifiers such as your driver's licence where it is reasonably necessary to verify your identity (for example, if you are a prospective tenant or a prospective purchaser engaging a proxy bidder in an auction), or where it is required to fulfil government transactions such as bond lodgement; and
• financial information, which includes bank account details, credit card information, or any other information required for our business and finance management.

For prospective and current employees, we collect information necessary for recruitment and employment, including qualifications, work history and references.

For suppliers and business contacts, we collect names, contact details and information relevant to our business relationship.

We may collect other personal information that you choose to disclose to us. If we determined that we are not permitted to collect that information, then we will destroy or de-identify it.

From 1 July 2026, we are a reporting entity under Australia’s Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) regime which means we are required to comply with the AML/CTF Act and the AML/CTF Rules. This impacts the types of personal information that we collect from individuals we engage with, how the information is collected and what it is used for. Section 6 below sets out more detailed information about how we handle personal information for AML/CTF purposes.

As at the date of this policy, we are not likely to collect sensitive information, unless required to do so to comply with our obligations under the AML/CTF Act. Sensitive information includes, among other things, criminal record, information about your racial or ethnic origin, political opinions, religious beliefs or affiliations, membership of a trade union or trade association, or sexual orientation, or health information. Where we collect sensitive information, we will do so only with your consent or as otherwise permitted by law.

3. How do we collect personal information?

We will only collect personal information by lawful and fair means. This means the method of collection will not be unreasonably intrusive, involve coercion or deception, or conducted without your knowledge. Sometimes, we may be permitted to collect personal information about you without your knowledge, for example, where it is necessary to undertake a fraud investigation.

We will generally collect personal information from you directly, for example, by way of forms, face to face meetings, interviews, business cards, telephone conversations. We may also collect personal information through our website and through applications (including job applications with us), and emails.

We may also collect personal information through recorded telephone calls. Telephone calls may be recorded for quality assurance, training, dispute resolution, and record-keeping purposes . If your call is being recorded, you will be notified at the commencement of the call. Call recordings are stored on our internal telephone system server as audio files for a period of seven (7) days, after which they are archived to our secure internal document management system. Call recordings are retained in accordance with our data retention obligations and are accessible only by authorised personnel.

Sometimes, we may collect your personal information from a third party, for example, through government agency, by referral, or through our business partners. Where this is the case, we will take such steps as are reasonable in the circumstances (if any) to notify you of such matters, including, for example, the fact that we have so collected your personal information, the purposes for which we collect your personal information, and how we handle or manage your personal information.

4. How we use and disclose your personal information?

4.1 General

We may use and disclose your personal information for the primary purpose for which it is collected, or for reasonably expected secondary purposes that are related to the primary purpose.

For example, we may use and disclose your personal information for the following primary purposes:

• fulfilling or enforcing our contractual obligations, for example, to process your application or maintenance requests, coordinate an auction, or otherwise act on your behalf where you have appointed us as your agent;
• delivering goods or services to you, such as to conduct appraisals of your property, or to market or list your property for sale where you have engaged us for these purposes;
• assessing your suitability to rent;
• communicating with you;
• complying with our legal and regulatory obligations, such as the requirements under the Residential Tenancies Act 1995 (SA), the AML/CTF Act and the AML/CTF Rules;
• verifying your identity; and
• conducting our business.

In addition, we may use and disclose your personal information for a secondary purpose that you would reasonably expect us to perform, for example:

• to facilitate communications between the vendor and prospective purchaser, or between the landlord and tenant;
• to negotiate on your behalf where you have appointed us to be your agent;
• to notify you of changes affecting your property;
• to improve the delivery of our services and customer experience; and
• to de-identify your personal information where your personal information is no longer required for any other purpose;

We may also disclose your personal information to our related body corporate in the Boffo Real Estate group, or to a third party to help us fulfil our contractual obligations. For example, we may disclose your personal information to the following third parties:

• the lessor or owner of the property that you are applying to rent;
• a tradesperson or technician, where you have lodged a maintenance request in respect of a rental property we manage;
• a government agency, for government-related activities such as lodging or managing your bond or verifying your identity;
• a national tenancy database to assess your suitability to rent; and
• a specialist consultant or auctioneer, who may perform functions on our behalf.

If we disclose your information to a third party, we will generally require the third party protect your information to the same extent that we do.

Sometimes, we may be required or authorised by law or a court or tribunal order to disclose or use your personal information. We may also be permitted to disclose your personal information for law enforcement related activities, or as permitted by the APPs.

We will otherwise only use or disclose your personal information for any other purposes with your consent.

4.2 Direct marketing

Like most businesses, marketing is important to our continued success. We believe we have a unique range of products and services that we provide to customers at a high standard. We therefore like to stay in touch with customers and let them know about new opportunities. We may provide you with information about new products, services and promotions either from us, or from third parties which may be of interest to you.

We will not disclose your personal information to third parties for marketing purposes without your consent.

You may opt out at any time if you no longer wish to receive commercial messages from us. You can make this request by contacting our Privacy Officer (contact information listed at the end of this policy).

4.3 Use of artificial intelligence (AI) and automation

We may use secure third-party AI-based tools and automated systems to support internal processes and provide our services, including customer communications and workflow management.

When using these tools and systems, we take reasonable steps to use reputable service providers that have strong data protection standards and ensure that the providers handle personal information consistently with the APPs and our obligations on confidentiality. In addition, we take reasonable steps to ensure that our AI service providers will host data in Australia and will not train their models on any information that we provide.

5. Management of personal information

We may hold or process personal information using secure third-party platforms, including our property management system, document management system, email system, customer relationship management software, cloud storage and AI-based tools (as described in section 4.3 above).

We will take reasonable steps to protect the security of your personal information. Our personnel are required to respect the confidentiality of personal information and the privacy of individuals.

We take reasonable steps to ensure the security of the information and only authorised persons are given access. We also take reasonable steps to protect personal information from misuse and loss and from unauthorised access, modification or disclosure.

Where we no longer require your personal information for any other purposes, we take reasonable steps to de-identify or securely destroy it, unless we are required by law to retain that information.

5.1 Notifiable Data Breaches

In the event of a data breach that is likely to result in serious harm to any individual whose personal information is involved, we will, to the extent consistent with our obligations under the AML/CTF Act (including secrecy and tipping off provisions), notify the affected individuals and the Office of the Australian Information Commissioner as soon as practicable, in accordance with Part IIIC of the Privacy Act (Notifiable Data Breaches scheme).

6. AML/CTF compliance

This section explains how we collect, handle and use personal information in connection with our AML/CTF compliance obligations.

6.1 Why we collect personal information

Given the nature of our business, which includes assisting the sale, purchase or transfer of real estate, we have assessed that such client engagements may reasonably involve the provision of a designated service under the AML/CTF Act. On that basis, we will undertake customer due diligence (CDD) on our clients where we reasonably suspect that such client engagement will involve the provision of a designated service.

We also collect information necessary for personnel due diligence (PDD) in relation to our current and prospective employees, contractors, and other personnel in accordance with our AML/CTF compliance obligations.

6.2 What information we collect

The personal information we collect for AML/CTF purposes may include identity and verification information, information about beneficial owners and controllers of entities, information relevant to sanctions and politically exposed person screening, and other information required to assess money laundering and terrorism financing risk.

In the context of PDD, we may collect identity and verification information, employment history, qualifications, and other information relevant to assessing whether personnel pose a risk of involvement in money laundering or terrorism financing.

We may also collect sensitive information for AML/CTF purposes, including biometric information for identity verification purposes, or whether you are a member of any political associations, professional or trade associations to verify your occupation or determine whether you are a politically exposed person. Where we collect sensitive information, we will do so only with your consent or as otherwise permitted by law.

6.3 How we collect information

We usually collect CDD information directly from you at the point of onboarding. We use a specialist third-party CDD platform to facilitate our customer due diligence and identity verification processes. We may also collect personal information about individuals other than our direct client (such as beneficial owners) from our client or from third-party sources where it is impracticable to collect it directly from the individual.

PDD information is usually collected directly from the relevant employee or contractor during onboarding or at periodic intervals as required by our AML/CTF program. We may also collect PDD information from third-party sources, such as referees or screening providers, where necessary to verify information provided or to complete required checks.

6.4 Disclosure

We may disclose personal information for AML/CTF purposes to AUSTRAC, law enforcement and regulatory bodies (where required or authorised by law, including for the submission of suspicious matter reports), and to third-party service providers engaged to assist with our CDD and PDD processes. We will not use or disclose personal information collected for AML/CTF purposes for an unrelated purpose unless an exception under the Privacy Act applies or we obtain your consent.

6.5 Information Retention

We retain AML/CTF records in accordance with our obligations under the AML/CTF Act and take reasonable steps to destroy or de-identify personal information once it is no longer required.

7. Cookies Policy

By using or accessing this website, you acknowledge and consent to Boffo Real Estate’ use of cookies in accordance with this policy. Please note that cookies and analytical information are generally not considered personal information as your identity is not reasonably ascertainable. Where we can reasonably ascertain your identity based on your cookies or online activities, we will treat that information as personal information in accordance with this policy.

This section helps to explain the occasions when and why cookies may be sent to visitors to the website. “Cookies” are text-only pieces of information that a website transfers to an individual’s hard drive or other website-browsing equipment for record-keeping purposes. Cookies allow the website to remember important information that will make your use of the site more convenient. A cookie will typically contain the name of the domain from which the cookie has come, the “lifetime” of the cookie, and a randomly generated unique number or other value. Certain cookies will be used on the site regardless of whether you are logged in to your account or not.

Like most websites, we use cookies for a variety of purposes in order to improve your online experience, for analytics and for marketing, but specifically we use cookies on the website for the following purposes:

1. Analytical Purposes: we use cookies to analyse user activity in order to improve the website.

2. Your Preferences: we use cookies to store certain user preferences on our website.

3. Marketing: we use cookies from third-party partners such as Google and Facebook for marketing purposes. These cookies allow us to display Boffo Real Estate promotional material to you on other sites you visit across the Internet. Boffo Real Estate may also share information about your behaviour on the website with third parties (including operators of third-party websites and/or social networking sites) in order to show you targeted advertisements and other content that has been customised for you.

4. Referral Tracking: we use cookies to associate user activity with the third party website that referred the user to our website, or to associate user activity that Boffo Real Estate referred to a third party website. These third party partner websites receive credit for the activity of users they refer to our website, or give Boffo Real Estate credit for the activity of users referred to such third party websites. We do not share any personal information or information about individual user activities with these partner entities.

Session cookies are temporary cookies that remain in the cookie file of your browser until you leave the Website.

Persistent cookies remain in the cookie file of your browser for much longer (though how long will depend on the lifetime of the specific cookie). When we use session cookies to track the total number of visitors to our website, this is done on an anonymous aggregate basis (as cookies do not in themselves carry any personal data). We may also employ cookies so that we remember your computer when it is used to return to the website to help customise your Boffo Real Estate web experience. We may associate personal information with a cookie file in those instances. Use the options in your web browser if you do not wish to receive a cookie or if you wish to set your browser to notify you when you receive a cookie. You can easily delete any cookies that have been installed in the cookie folder of your browser.

8. Disclosure to overseas recipients

We may disclose your personal information to overseas recipients in limited circumstances. We currently engage the services of an overseas service provider in the Philippines to undertake administrative tasks. We also utilise third-party AI-based tools which may involve the disclosure of personal information overseas. We have taken reasonable steps to ensure that the service provider complies with the APPs in relation to any personal information that may be accessible overseas.

If in future we engage additional overseas providers, we will update this Privacy Policy accordingly and will, where practicable, advise you of the countries in which any overseas recipients are likely to be located. We will ensure that any overseas disclosure of personal information complies with the requirements of the Privacy Act.

If you do not want us to disclose your information to overseas recipients, please let us know.

9. Accessing and correcting your personal information

Boffo Real Estate endeavours to ensure that the personal information it holds is accurate, complete and up-to-date. We encourage you to contact us to update any personal information that we hold about you.

You may contact our Privacy Officer (contact information listed below) to request access to the personal information that we hold about you and/or to make corrections to that information, at any time. On the rare occasions when we refuse access, we will provide you with a written notice stating our reasons for refusing access. We may seek to recover from you reasonable costs incurred for providing you with access to any of the personal information about you held by us.

Our obligation to provide access to personal information will be limited in circumstances where doing so would be inconsistent with secrecy or tipping off provisions under the AML/CTF Act.

We are not obliged to correct any of your personal information if we do not agree that it requires correction and may refuse to do so. If we refuse a correction request, we will provide you with a written notice stating our reasons for refusing.

We will respond to all requests for access to or correction of personal information within a reasonable time.

10. Resolving privacy concerns

If you would like a copy of Boffo Real Estate’s Privacy Policy in a particular form (e.g. accessible PDF) or access to your personal information, please contact our Privacy Officer at:

The Privacy Officer

Boffo Real Estate 78-80 North East Road, Walkerville SA 5081

Telephone: 08 8269 7711

Email: privacy@boffo.com.au

We take all complaints seriously and will attempt to respond to your complaint within a reasonable period. If you are dissatisfied with the way we handled your complaint, you may contact the Office of the Australian Information Commissioner:

Office of the Australian Information Commissioner

GPO Box 5288

Sydney NSW 2001

Telephone: 1300 363 992

Email: enquiries@oaic.gov.au

This document was last updated on 7th August 2026.