Website Privacy Statement

About This Statement

Scarborough Group Ltd (“Scarborough Group”, “we”, “us”, “our”) recognises the importance of protecting the privacy and rights of individuals in relation to their personal information. We comply with the Privacy Act 2020 (New Zealand) in all dealings with personal information. This Privacy Statement explains what personal information we collect, why we collect it, where we collect it from, who we share it with, and your rights in relation to it.

1. What Personal Information We Collect

We may collect the following types of personal information about you:

Full name and date of birth
Contact details including address, phone number, and email address;
Property-related information including ownership details, property descriptions, and transaction history;
Comments or feedback you provide in relation to a property;
Identity verification documentation and financial information required under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT Act) when you are acting as a Vendor; and
Any other information you provide to us in the course of our business relationship.

2. How and Where We Collect Your Information‍

Direct Collection

We collect most personal information directly from you — for example, when you inquire about a property, engage us to list a property, or contact us by phone, email, or web form. When we collect information directly from you, we will take reasonable steps to make sure you are aware of:

The fact that we are collecting your information;
The purpose for which it is being collected;
Whether the provision of the information is voluntary or mandatory. Where collection is required by law (such as under the AML/CFT Act), we will tell you which law requires it;
The consequences of not providing the information, where relevant. For example, if we are unable to obtain the identity information required under the AML/CFT Act, we may be unable to proceed with the listing or transaction;
The intended recipients of your information; and
Your right to access and correct your personal information (see section 6 below).

Third-Party and Indirect Collection

In some circumstances we collect personal information about you from sources other than yourself. This may occur when:

Your professional advisers (such as lawyers or accountants) provide information in the course of a transaction;
We use our AML compliance provider, REALAML, to assist in verifying your identity as required under the AML/CFT Act;
We obtain publicly available information such as property ownership records from Land Information New Zealand (LINZ) or local council databases;
Our contracted service providers (such as photographers, maintenance contractors or other trade services) share relevant contact or property details with us in order to carry out their services;
Regulators or government agencies share information with us as authorised or required by law;
An existing client, business contact, or other third party refers you to us and provides your contact details or background information in the course of making that referral;
We acquire or use a Customer Relationship Management database (CRM) from a commercial provider that includes your personal information for the purpose of property sale or lease marketing or client prospecting; or
Any other third party provides information relevant to a property transaction in which you are involved.

Where we collect information about you from a third-party source, we will take reasonable steps to notify you of the matters listed above, as soon as reasonably practicable after collection, unless one of the following exceptions applies:

You have already been made aware of the collection — for example, because the disclosing agency (such as REALAML) has already provided you with notice;
The information was obtained from a publicly available source (such as LINZ records);
The collection is authorised or required by the AML/CFT Act or another New Zealand law, and notification would undermine the purpose of the collection; or
Notification is not reasonably practicable in the circumstances.

We will generally provide indirect collection notification by email or written notice at the earliest practicable opportunity.

3. Why We Collect Your Information (Purpose of Collection)

We collect your personal information for the following purposes:

To facilitate the sale, purchase, or leasing of property on behalf of our clients;
To meet our legal obligations under the AML/CFT Act and the Real Estate Agents Act 2008;
To communicate with you regarding properties, transactions, and our services;
To respond to your inquiries and provide you with feedback;
To maintain business records and comply with accounting, tax, and legal requirements; and
To keep you informed of relevant property market updates or services, where you have consented or where we have a legitimate business interest in doing so.

We will not use your information for any other purpose without your consent, or unless otherwise permitted by the Privacy Act 2020.

4. Who We Share Your Information With

We share personal information only to the extent necessary for the purposes described above. Recipients may include:

Your professional advisers, such as lawyers or accountants, involved in a transaction;
REALAML, our AML/CFT compliance provider;
Regulators and government agencies including the Real Estate Authority (REA), REINZ, DIA (Dept. of Internal Affairs) and the New Zealand Police FIU (as required under the AML/CFT Act), and any other body with which we are legally required to share your information;
Our contracted service providers involved in your transaction, such as photographers, virtual tour operators, and property marketing platforms; and
Any other party with your consent, or as otherwise permitted or required by law.

We may also disclose information where it is not in a form that identifies you, or where the disclosure is permitted under the Privacy Act 2020 or another applicable law.

5. How Long We Keep Your Information

We retain your personal information for as long as it is necessary for the purpose for which it was collected, or as required or permitted by law. In particular, AML/CFT legislation requires us to retain certain identity and transaction records for a minimum of five years and the REA upon property transactions for seven years. Where information is no longer required and no legal retention obligation applies, we will take reasonable steps to securely destroy or de-identify it.

6. How We Keep Your Information Safe

We store your personal information in encrypted electronic systems with restricted staff access. Any physical documents are stored securely. We take reasonable steps to protect your personal information from loss, unauthorised access, use, modification, or disclosure.

7. Your Rights — Access and Correction

You have the right under the Privacy Act 2020 to:

Request access to any personal information we hold about you; and
Ask us to correct that information if you believe it is inaccurate, incomplete, or misleading.

To make an access or correction request, or for any privacy-related inquiry, please contact us:

Email: keith@scarboroughgroup.co.nz (addressed to the Privacy Officer);
Phone: 027 2888813; or
Post: 8 Farnham Street, Parnell, Auckland 1151.

We will respond to your request in accordance with the timeframes required by the Privacy Act 2020.

8. Complaints

New Zealand

If you have a concern or complaint about how we have handled your personal information, we encourage you to contact us in the first instance at keith@scarboroughgroup.co.nz, addressed to the Privacy Officer. If you remain dissatisfied, you may lodge a complaint with the Office of the Privacy Commissioner:

Website: www.privacy.org.nz
Phone: 0800 803 909
Online complaint form available at privacy.org.nz

Australian Clients

If you are an Australian resident and have a query or complaint about our collection, use, or storage of your personal information (including under the Privacy Act 1988 (Cth) or the Credit Reporting Privacy Code), please contact keith@scarboroughgroup.co.nz, addressed to the Privacy Officer. If you are dissatisfied with our handling of your complaint, you may contact:

Office of the Australian Information Commissioner — GPO Box 5218, Sydney NSW 2001 | Tel: 1300 363 992 | enquiries@oaic.gov.au
Australian Financial Complaints Authority (AFCA) — www.afca.org.au

9. Changes to This Statement

We may update this Privacy Statement from time to time to reflect changes in the law or our practices. The current version will always be available on our website or on request. This statement was last updated in May 2026 to incorporate the requirements of IPP 3A introduced by the Privacy Amendment Act 2025.

10. Contact Us

If you have any questions or concerns about this Privacy Statement or our privacy practices, please contact us at:

Email: Ulrik@scarboroughgroup.co.nz

Address: 8 Farnham Street, Parnell, Auckland 1052

Phone: +64 21 622 276

Last Updated: 29/08/2026

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