Last updated: 24 June 2026
1. Introduction
This Privacy Policy applies to the Property Lions group of businesses, including:
WHT Group Pty Ltd trading as Property Lions (ABN 76 635 426 925); and
Property Lions Capital Pty Ltd (ABN 18 685 760 918).
In this Privacy Policy, “Property Lions”, “we”, “us” and “our” refers to WHT Group Pty Ltd trading as Property Lions, Property Lions Capital Pty Ltd and any other related entities, trading names, business divisions, service lines or businesses operated under the Property Lions umbrella from time to time, unless the context requires otherwise.
Property Lions is committed to protecting your privacy and handling personal information in an open, transparent and secure way. This Privacy Policy explains how we collect, hold, use, disclose and protect personal information in connection with our business, website, events, marketing activities and services.
Our contact details are:
Property Lions
Level 9, 123 Epping Road
Macquarie Park NSW 2113
Email: [email protected]
2. The Australian Privacy Principles
We manage personal information in accordance with the Privacy Act 1988 (Cth) (“Privacy Act”), the Australian Privacy Principles (“APPs”) and this Privacy Policy. The APPs regulate how personal information is collected, used, disclosed, stored, accessed and corrected by organisations covered by the Privacy Act.
3. How the Privacy Act Applies to Us (AML/CTF Regime)
From 1 July 2026, real estate professionals (including buyer’s agents and property syndicators) become reporting entities under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (“AML/CTF Act”).
From that date, the Privacy Act applies to the personal information we handle in connection with our AML/CTF obligations, regardless of our annual turnover and despite the small business exemption that may otherwise apply. We comply with the APPs when handling that information, and as a matter of policy, we apply APP-consistent practices across our handling of personal information generally.
4. What is Personal Information?
“Personal information” means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not and whether it is recorded in a material form or not. Examples include your name, contact details, identification information, financial information, transaction information and information about your dealings with us.
5. What Personal Information Do We Collect?
The kinds of personal information we collect and hold will depend on the nature of our relationship with you. This may include:
Your name, date of birth and contact details, including residential address, business address, postal address, phone number and email address;
Business, company, trust, SMSF or entity information, including officeholder, director, shareholder, trustee, beneficiary, investor, client or authorised representative details;
Identity verification information and documentation collected for customer due diligence (CDD) and KYC purposes under the AML/CTF Act;
Information about your property ownership, investment history, commercial property interests, acquisition criteria, transaction preferences and asset management requirements;
Information about your financial position, investment objectives, source of funds, asset and liability position, borrowing capacity, income, expenses, bank account details and other financial or commercial information relevant to our services;
Information contained in documents you provide to us, such as contracts, leases, information memoranda, due diligence documents, loan documents, bank statements, financial statements, trust deeds, company documents, asset schedules and correspondence;
Billing, payment and transaction information, including bank account or card details where required for agreed billing purposes;
Information about your use of our website, online forms, landing pages, email communications, events, webinars, advertisements and digital content;
Technical information such as IP address, device information, browser type, pages visited, website usage data, cookies, pixels and analytics information;
Communications between you and us, including emails, text messages, phone calls, meeting notes, social media messages and enquiry forms;
Information you provide when attending our events, workshops, webinars, consultations or meetings;
Feedback, survey responses, testimonials, preferences and marketing communication preferences; and
Any other information you provide to us or that we reasonably collect in connection with our business and services.
We may also collect sensitive information in limited circumstances, such as where you provide it to us voluntarily, where it is reasonably necessary for our services, or where collection is required or authorised by law. We will only collect sensitive information with your consent or where otherwise permitted by law.
6. How We Collect Personal Information
We usually collect personal information directly from you. This may occur when you:
Contact us by phone, email, text message, social media, online form or other communication channel;
Use our website, landing pages, online booking tools or digital platforms;
Enquire about, purchase, register for or receive our services;
Attend our meetings, events, workshops, webinars or consultations;
Complete client onboarding forms, questionnaires, surveys, due diligence forms or investment-related forms;
Provide documents or information to us in connection with a property transaction, advisory engagement, investment opportunity, asset management service, capital partner opportunity, syndication-related activity or education program;
Subscribe to our newsletters, updates, reports or marketing communications;
Interact with our advertisements, social media pages, digital content or remarketing campaigns; or
Otherwise communicate or deal with us.
We may also collect personal information from third parties where it is reasonable to do so, including:
Your authorised representatives, advisers, accountants, lawyers, finance brokers, lenders, agents, consultants or business partners;
Public registers, land title records, ASIC records, planning portals, property databases and other publicly available sources;
Real estate agents, vendors, purchasers, tenants, landlords, property managers, valuers, consultants and transaction counterparties;
Credit reporting, identity verification, fraud checking or due diligence service providers;
Marketing, advertising, analytics, lead generation or CRM platforms; and
Other persons or organisations you have authorised to provide information to us.
If you provide personal information about another person to us, you must ensure that you are authorised to do so and that the person has been made aware of this Privacy Policy.
7. Identity Verification and Data Minimisation under AML/CTF
As a reporting entity, we are required to verify the identity of our customers and conduct customer due diligence (CDD) under the AML/CTF Act. To do this we collect personal information such as your name, date of birth, residential address, and identification document details, and we may verify these against independent sources.
To protect your data security and adhere to data-minimisation principles, we do not retain copies of full identification documents (such as a physical driver licence or passport) for AML/CTF record-keeping purposes. Instead, we record only the essential textual details needed to evidence that verification was completed to meet our statutory record-keeping obligations, and we securely destroy or de-identify any full copies once they are no longer needed.
In some circumstances, we may be restricted by law from notifying you about how your information is handled (for example, where statutory “tipping off” restrictions under the AML/CTF Act apply regarding suspicious matters).
8. Why We Collect, Hold, Use and Disclose Personal Information
We collect, hold, use and disclose personal information for purposes connected with our business, including to:
Verify your identity and contact details (including for statutory AML/CTF purposes);
Assess whether our services are suitable for you;
Provide commercial property advisory, buyers agency, asset management, acquisition, due diligence, property syndication, consulting, education, investor relations, capital partner, and related services;
Understand your investment objectives, acquisition criteria, financial capacity and property requirements;
Assist with property searches, transaction analysis, negotiations, due diligence, settlement, asset management and reporting;
Communicate with you about enquiries, engagements, transactions, events, workshops, updates and services;
Prepare, review, store and manage documents, reports, proposals, contracts, correspondence, client files and transaction records;
Manage investor, client, capital partner and stakeholder communications;
Process payments, issue invoices, collect debts and manage accounts;
Conduct research, market analysis, business planning, service improvement and internal reporting;
Manage our client relationships, CRM systems, marketing databases and communication systems;
Send you information about our services, events, market updates, insights, opportunities, promotions and offers that may be relevant to you;
Conduct marketing, advertising, remarketing, website analytics and audience analysis;
Comply with our legal, regulatory, taxation, accounting, audit, insurance and compliance obligations (including AUSTRAC tracking);
Protect our legal rights, resolve disputes and manage business risk;
Detect, prevent and respond to fraud, misuse, cyber incidents, unlawful activity or security risks;
Manage our business systems, information technology, website, cloud storage and operational infrastructure; and
For any other purpose reasonably related to the above or otherwise notified to you at the time of collection.
9. Disclosure Between Property Lions Entities
We may share personal information between WHT Group Pty Ltd trading as Property Lions, Property Lions Capital Pty Ltd and any other related entities or businesses operating under the Property Lions umbrella.
We may do this for business administration, client management, service delivery, investor relations, property syndication activities, capital partner opportunities, property acquisition, asset management, due diligence, marketing, compliance, reporting and operational purposes. Where information is shared between Property Lions entities, we will handle that information in accordance with this Privacy Policy and applicable privacy laws.
10. Direct Marketing
We may use your personal information to send you information about our services, events, insights, reports, offers, opportunities and updates that may be relevant to you. We may contact you by email, phone, SMS, social media, online advertising or other communication channels, subject to applicable laws.
You may opt out of receiving direct marketing communications from us at any time by:
Using the unsubscribe function in our emails;
Replying STOP to SMS messages where that option is provided; or
Contacting us at [email protected].
We will not use sensitive information for direct marketing without your consent.
11. Cookies, Pixels and Analytics
Our website and digital platforms may use cookies, pixels, tags, analytics tools and similar technologies. Cookies are small files placed on your device to help websites remember information about your visit. Pixels and similar technologies may help us understand website activity, measure advertising performance and deliver relevant marketing.
We may use these technologies to operate and improve our website, remember your preferences, analyse website traffic, provide targeted remarketing, and measure campaign performance.
We may use third-party tools such as Google Analytics, Google Ads, Meta advertising tools, LinkedIn advertising, CRM platforms, and marketing automation platforms. Third-party providers collect or receive information from our website and elsewhere on the internet in accordance with their own privacy policies. You can adjust your browser settings to refuse cookies, though some parts of our website may not function properly as a result.
12. When We Disclose Personal Information
We may disclose personal information to third parties where reasonably necessary for our business and services, including to:
Our employees, contractors, offshore team members, consultants and related entities;
Your authorised representatives, advisers, lawyers, accountants, finance brokers, lenders or consultants;
Property agents, vendors, purchasers, tenants, landlords, property managers, valuers, town planners, builders, engineers, environmental consultants and other transaction participants;
Service providers who assist us with administration, client support, marketing, telemarketing, document preparation, due diligence, data entry, research, information technology, cyber security, accounting, billing, payment processing, debt recovery, website hosting, analytics and business operations;
Cloud storage, email, CRM, accounting, communication, marketing, project management and document management providers;
Event organisers, venues and webinar or workshop service providers;
Credit reporting, fraud checking, identity verification, due diligence or compliance service providers;
Professional advisers, including accountants, auditors, lawyers, insurers and risk advisers;
Government agencies, regulators, courts, tribunals, law enforcement bodies (including AUSTRAC and the OAIC) where required or authorised by law;
Organisations involved in a sale, merger, restructure, financing, transfer or potential transfer of all or part of our business or assets; and
Any other person or organisation with your consent or as otherwise permitted by law.
We do not sell personal information to third parties.
13. Overseas Disclosure and Offshore Team Members
Some of our trusted service providers and team members are located outside Australia. This includes offshore employees, contractors, consultants, virtual assistants, and cloud infrastructure providers who assist us with administration, document preparation, client support, research, marketing, data entry, and information technology.
The countries in which overseas recipients are likely to be located are the Philippines and India (members of our team and operations service providers) and the United States and the European Union (technology, cloud hosting, and analytics infrastructure providers).
Where we disclose personal information to overseas recipients, we take reasonable steps to ensure that those recipients handle personal information in a manner consistent with the Australian Privacy Principles. These steps include binding overseas recipients to confidentiality and privacy obligations through written agreements (such as data-processing terms), limiting data access on a need-to-know basis, and applying strict access controls.
You acknowledge that under the Privacy Act, where we disclose personal information to an overseas recipient, we may remain accountable for the recipient’s handling of that information under Section 16C of the Privacy Act, even where reasonable preventative steps have been taken.
14. Storage and Security of Personal Information
We hold personal information in both electronic and hard-copy form. Electronic data is stored across secure local systems, computer software, email platforms, networks, and reputable third-party cloud service providers (such as Google Workspace, Google Drive, and cloud CRM or accounting platforms). Hard-copy files are held at our offices or secure storage environments.
We take reasonable technical and organisational steps to protect personal information from misuse, interference, loss, and unauthorised access, modification, or disclosure. Security measures include:
Passwords, multi-factor authentication (MFA), and strict user access controls;
Restricting data access exclusively to authorised staff and certified contractors on a need-to-know basis;
Enterprise-grade cloud infrastructure, anti-virus programs, firewalls, and network filtering software;
Confidentiality mandates written into all employee and contractor agreements; and
Secure destruction or permanent de-identification of information when it is no longer required or statutory retention periods expire.
While no internet data transmission can be guaranteed 100% secure, we actively manage our parameters to protect information to the highest professional standards.
15. Retention of Personal Information
We retain personal information for as long as reasonably necessary for the purposes for which it was collected—including to deliver services, manage client interactions, resolve disputes, protect legal rights, and satisfy accounting, tax, insurance, and statutory compliance frameworks (such as the 7-year record-keeping requirements attached to the AML/CTF regime).
When personal information is no longer structurally required or legally mandated to be kept, we take definitive, reasonable steps to securely destroy, overwrite, or permanently de-identify the records.
16. Notifiable Data Breaches
If we suspect or become aware of a data breach involving personal information, we will initiate our internal data breach response procedures to contain and assess the incident promptly.
In accordance with the Notifiable Data Breaches (NDB) scheme under Part IIIC of the Privacy Act, where a breach is assessed as likely to result in serious harm to affected individuals, we will expeditiously notify the impacted individuals and the Office of the Australian Information Commissioner (OAIC). Our notifications will outline the nature of the breach, the specific information involved, and recommended remediation actions. Note that data breach handling processes will be managed concurrently with any corresponding AML/CTF reporting requirements or tipping-off limitations.
17. Artificial Intelligence, Automation and Software Tools
We use software, digital automation, analytics infrastructure, and artificial intelligence-assisted platforms to manage operational workflows, marketing campaigns, client databases, research tasks, and documentation reviews. Where these tools are deployed, we apply stringent configurations to ensure your data remains completely secure and handled in strict alignment with this policy.
Automated Decision-Making Transparency
From 10 December 2026, to ensure compliance with updated regulatory principles under the Privacy Act, if we utilize automated computer programs or algorithmic tools to make or substantially drive decisions that could reasonably be expected to significantly affect your rights, interests, or commercial engagements, we will explicitly detail the operational dynamics here. We do not currently use automated decision-making systems to execute legally binding or significant evaluations of individuals without strict human verification and oversight.
18. Access to Personal Information
You may request access to the personal information we hold about you by contacting our Privacy Officer at [email protected]. We process access requests within a reasonable timeframe and in compliance with the APPs.
We may require you to verify your identity before extracting records. In specific legal circumstances, we reserve the right to refuse access where permitted or mandated by law, including situations where providing access would:
Be inherently unlawful or violate statutory frameworks;
Infringe unreasonably on the privacy of another individual;
Prejudice a live investigation into unlawful activity or breach AML/CTF "tipping off" boundaries;
Expose highly sensitive, commercial decision-making parameters; or
Breach legal professional privilege or existing/anticipated court proceedings.
If an access request is denied, we will provide a comprehensive written notice detailing our legal grounds for refusal, unless prohibited by law. We do not charge fees for lodging an access request, though we may apply a reasonable charge to offset the direct retrieval cost of large, historical, or archived data sets.
19. Correction of Personal Information
We take systematic steps to ensure the personal data we hold is accurate, complete, up-to-date, relevant, and not misleading. If you believe any information we maintain requires amendment, please contact us at [email protected].
If we agree that the record is inaccurate, we will update it immediately. If we disagree with the requested alteration, you have the right to request that we append a visible statement to your file noting your view that the current data layout is inaccurate, incomplete, or out of date.
20. Anonymity and Pseudonymity
Where it is practical and legally permissible, you have the option to interact with us anonymously or via a pseudonym (for instance, making general service enquiries). However, given our operational environment, we cannot execute commercial real estate transactions, establish property syndication structures, process standard billing profiles, or meet statutory AML/CTF client onboarding requirements without definitively identifying you and verifying your legal credentials.
21. Third-Party Websites and Platforms
Our websites, portals, landing pages, and newsletters may contain links to independent third-party websites or external digital tools. Property Lions maintains no control or authority over the privacy policies, cyber security frameworks, or content systems deployed by third-party operators. We strongly encourage you to inspect the privacy terms of any external platforms before submitting personal data.
22. Social Media
If you actively engage with our profiles on social platforms (such as LinkedIn, Instagram, Facebook, or YouTube), we may log information that you voluntarily make available to us through those networks. All such interactions are simultaneously governed by the overarching privacy settings and platform terms of the respective social media networks.
23. Children
Our commercial advisory, syndication, and asset management lines are tailored exclusively for adults and corporate business clients. We do not knowingly or intentionally gather personal data from minors under the age of 18 without explicit parental or guardian verification. If we find that a minor's information has been collected inadvertently without appropriate approval, we will act to permanently erase or de-identify the files.
24. Privacy Complaints
If you possess concerns or wish to lodge a formal complaint regarding how your personal information has been captured, stored, shared, or managed, please reach out directly to us:
Email: [email protected]
Post: Privacy Officer, Property Lions, Level 9, 123 Epping Road, Macquarie Park NSW 2113
Please provide clear details regarding the nature of your concern so we can evaluate the matter thoroughly. We acknowledge and respond to all privacy complaints within a reasonable time frame. We may request additional context or identity validation to ensure a proper investigation. If you are dissatisfied with our internal resolution, you retain the right to elevate your matter to the Office of the Australian Information Commissioner (OAIC) at https://www.oaic.gov.au/.
25. Changes to this Privacy Policy
We reserve the right to revise this Privacy Policy periodically to reflect continuous updates within our group businesses, technological systems, or the broader Australian legal landscape. Any updated policy draft will be promptly uploaded to our primary web domain with a refreshed tracking date. Your ongoing use of our systems, properties, platforms, and advisory networks following a publication cycle indicates your structural acknowledgement of the amended terms.