Privacy Policy

We are committed to protecting your privacy. This policy explains what information we collect, why we collect it, and how we use and protect it.

Wiser Property Advisory (trading name of Eric Le Tran Property Pty Ltd, ABN 92 665 570 721, ACN 665 570 721) respects your privacy and is committed to handling your personal information responsibly, transparently, and in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). As a business regulated under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act), we also have specific legal obligations to collect, verify, retain, and in some cases report certain information and this policy explains how those obligations affect your privacy.

1. Who We Are

Wiser Property Advisory is a licensed buyer's agency operating in New South Wales. We provide property sourcing, negotiation, due diligence, auction bidding and advisory services to residential property purchasers, including individuals, companies, trusts and self-managed superannuation funds (SMSFs).

We are a reporting entity enrolled with the Australian Transaction Reports and Analysis Centre (AUSTRAC) under the AML/CTF Act. This means we are legally required to identify our clients, verify their identity, and comply with ongoing obligations designed to detect and prevent money laundering and terrorism financing.

2. What Personal Information We Collect

Depending on the nature of your engagement with us, we may collect the following categories of personal information:

Identity information

Full legal name, date of birth, residential address, contact details (phone and email), and occupation.

Identity verification data

Government-issued document details (such as driver licence, passport or Medicare card), biometric verification results, and Document Verification Service (DVS) outcomes. This information is collected and processed through AML Assured, our AUSTRAC-compliant identity verification platform.

Financial information

Source of funds declarations, bank account details, purchase budget, and fee payment and invoice records.

Entity information

For clients purchasing through a company, trust or SMSF: company names, ACNs, ABNs, trust deeds, ASIC extracts, SMSF documentation, beneficial ownership details, and director and trustee information.

Transaction information

Property purchase details, negotiation records, contract details, and correspondence relating to your purchase.

Marketing and enquiry information

Contact form submissions, email enquiries, and referral source details for prospective clients.

3. How We Collect It

We collect personal information:

1. Directly from you — through our Buyer Agency Agreement, onboarding forms, email, phone, and meetings.
2. Through AML Assured — our identity verification platform, when you complete identity verification as part of onboarding.
3. From third parties — such as your conveyancer, solicitor, mortgage broker, or selling agents, where relevant to your purchase and with your knowledge.
4. From publicly available sources — such as ASIC extracts, title searches, and sanctions or politically exposed person (PEP) screening databases, where required for our AML/CTF obligations.

Where practicable, we collect personal information directly from you. If we collect information about you from a third party, this is generally because it is necessary for us to verify your identity or act on your behalf in a property transaction.

4. Why We Collect It

We collect, hold, use and disclose your personal information for the following purposes:

1. To provide our buyer's agency services, including property sourcing, negotiation, due diligence, and auction bidding on your behalf.
2. To verify your identity and meet our Customer Due Diligence (CDD) and, where applicable, Enhanced Due Diligence (EDD) obligations.
3. To comply with our legal obligations under the AML/CTF Act, including ongoing monitoring of our business relationship with you and reporting to AUSTRAC where required.
4. To manage our engagement with you, including invoicing, communications, and record keeping.
5. To meet our obligations under real estate licensing and other applicable law.
6. For marketing purposes, where you have consented to receive communications from us.

Legislative basis for AML/CTF collection

As an AUSTRAC-enrolled reporting entity, we are required by the AML/CTF Act and associated Rules to collect and verify identity information before, or in limited circumstances shortly after, commencing to provide services to you. This is a legal obligation, not a discretionary business choice — we cannot provide services to a client whose identity we have not verified in accordance with our AML/CTF Program. Where your risk profile requires it, we may be required to collect additional information about your source of funds and source of wealth as part of Enhanced Due Diligence.

Dealing with us anonymously or under a pseudonym

Because we are legally required to verify your identity under the AML/CTF Act, we are not able to provide our core services anonymously or under a pseudonym. You may contact us anonymously for general enquiries that do not involve engaging our services — for example, general questions about our services before deciding whether to engage us.

How to opt out of marketing communications

You may opt out of receiving direct marketing communications from us at any time by replying “unsubscribe” to any marketing email, or by contacting our Privacy Officer using the details in Section 10. We will action opt-out requests promptly. Opting out of marketing does not affect communications necessary for the delivery of our services or our legal obligations to you.

5. Who We Share It With

We do not sell your personal information. We share personal information only where necessary to deliver our services, meet our legal obligations, or with your consent. The table below sets out who we may share information with and why.

Where we rely on a third party (such as a conveyancer) to conduct aspects of Customer Due Diligence on our behalf, this occurs under a documented reliance arrangement consistent with sections 37A and 38 of the AML/CTF Act.

Cross-border disclosure of personal information

Some of the digital tools we use to deliver our services may store or process personal information outside Australia:

1. Google Workspace (our document storage and business email platform) may store or process information on servers located in the United States, depending on our current subscription settings. We do not currently have an Australia-only data residency configuration in place.
2. AML Assured (our AML/CTF verification platform) stores core compliance data on servers located in Australia. However, AML Assured engages third-party identity verification, sanctions, PEP, and adverse media screening providers to perform aspects of these checks, and some of these specialist providers may hold or process data outside Australia. We do not currently have visibility of the specific countries involved and recommend contacting AML Assured directly if this detail is required.
3. General AI assistants, such as Claude (developed by Anthropic) and ChatGPT (developed by OpenAI), are services operated by United States-based companies. Where we use these tools in a way that involves your personal information, that information may be processed on servers located in the United States or other countries in which those providers operate.

Where your personal information is handled by an overseas recipient, we take reasonable steps, to the extent legally practicable, to ensure that recipient does not breach the Australian Privacy Principles in relation to your information. We do not otherwise disclose personal information to overseas recipients.

Automated decision-making

We do not currently use artificial intelligence or other computer programs to make automated decisions about you that could reasonably be expected to significantly affect your rights or interests. Where we use AI tools or AML Assured's screening and risk-scoring outputs in connection with your engagement, a member of our team reviews that output before it informs any decision affecting your engagement with us. If this changes, we will update this policy to reflect the kinds of personal information used and the kinds of decisions involved, consistent with the automated decision-making transparency requirements introduced into the Privacy Act, which commence on 10 December 2026.

6. AUSTRAC Reporting

As an AUSTRAC-enrolled reporting entity, we are legally required in certain circumstances to report information about our clients or their transactions to AUSTRAC. This may include Suspicious Matter Reports (SMRs), where we form a reasonable suspicion relevant to money laundering, terrorism financing, or certain other matters, and Threshold Transaction Reports (TTRs), for transactions involving physical currency above the applicable threshold.

This means that if we make a report to AUSTRAC about you, we are legally unable to tell you that we have done so, and you should not interpret silence on this matter as confirmation that no report has been made.

7. How We Store and Protect Your Information

We take reasonable steps to protect the personal information we hold from misuse, interference, loss, unauthorised access, modification, or disclosure. These steps include:

1. Storing identity verification data within AML Assured, a dedicated, security-audited AML/CTF compliance platform.
2. Storing other client records within access-controlled Google Workspace and Monday.com environments.
3. Restricting access to personal information to team members who require it to perform their role.
4. Maintaining role-based training so that staff understand their obligations in handling client information.
5. Using secure, reputable third-party providers who are contractually and/or legally bound to protect information they process on our behalf.

No method of electronic storage or transmission is completely secure. While we take reasonable steps to protect your personal information, we cannot guarantee absolute security.

Data breach notification

If we experience a data breach involving your personal information that is likely to result in serious harm, we will comply with our obligations under the Notifiable Data Breaches (NDB) scheme in Part IIIC of the Privacy Act, including notifying affected individuals and the Office of the Australian Information Commissioner (OAIC) where required.

8. How Long We Keep It

We retain personal information for as long as necessary to fulfil the purposes for which it was collected, and to meet our legal obligations.

Because this retention period is a legal requirement rather than a business choice, we are unable to delete or de-identify AML/CTF-related records during the mandatory retention period, even if you request deletion. Other categories of information not subject to this mandatory retention (such as general marketing enquiries) may be deleted earlier, in accordance with our internal record-keeping practices.

9. Your Privacy Rights

You have the right to:

1. Access the personal information we hold about you, subject to any legal exceptions.
2. Request correction of personal information you believe is inaccurate, out of date, incomplete, irrelevant or misleading.
3. Make a complaint if you believe we have mishandled your personal information.

Please note that your right to access or correct information, and any request for deletion, is subject to our mandatory record-keeping obligations under the AML/CTF Act described in Section 8. We will always tell you if we are unable to action a request for this reason, unless doing so would itself breach the tipping-off prohibition described in Section 6.

Making a complaint

If you have a concern about how we have handled your personal information, please contact our Privacy Officer using the details in Section 10. We aim to acknowledge complaints within 5 business days and provide a substantive response within 30 days. If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

10. Contact Us

If you have any questions about this Privacy Policy, or wish to exercise any of your privacy rights, please contact our Privacy Officer:

11. Updates to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, our services, or legal and regulatory requirements. The current version number and date of last update are shown in the footer of this document and will be reflected on our website. We encourage you to review this policy periodically.

This Privacy Policy is Version 1.2, dated 24 August 2026. It replaces Version 1.1 dated 24 August 2026.