Cascade Holdings WA Pty Ltd t/as Settlement Hub WA ABN 95 636 409 599 (we, us or our) is the entity responsible for collecting, using, and disclosing Personal Information under this Policy. This Policy explains how we handle Personal Information about individuals (you or your).

We are committed to protecting Personal Information in accordance with the Privacy Act, including the 13 APPs contained in Schedule 1 of the Privacy Act.

We are a licensed settlement agent operating in Western Australia. When we provide a designated service under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and associated rules (AML/CTF Laws), we may collect, use, disclose and retain Personal Information to undertake customer due diligence, assess and manage AML/CTF risk, monitor transactions, make reports and comply with our record-keeping and other legal obligations.

This Policy applies to Personal Information collected through our website, digital platforms, social media pages and settlement services, and through our dealings with clients, prospective clients, transaction participants, suppliers, contractors, job applicants and other individuals.

We may also provide separate collection notices at or before the time we collect Personal Information. A collection notice may provide further information about the particular purpose for which we collect Personal Information and any specific consequences if the information is not provided.

Personal Information is defined in clause 2. Examples may include a person’s name, address, telephone number, email address, date of birth, identification information, employment information, transaction records and communications with us.

Sensitive Information is defined in clause 2. Sensitive Information is a subset of Personal Information that is given a higher level of protection under the Privacy Act. We will only collect Sensitive Information where it is reasonably necessary for our functions or activities and where:

The kinds of Personal Information we collect will depend on our relationship with you, the nature of our functions and activities, and the circumstances in which the information is collected. The kinds of Personal Information we may collect include:

Depending on the nature of our relationship with you and our functions and activities, we may collect Sensitive Information, including:

We may collect photographs, video recordings where relevant to security, fraud prevention or identity verification. This information may constitute Personal Information where an individual is identified or reasonably identifiable and may constitute Sensitive Information in limited circumstances.

In connection with our settlement services, we may collect:

We may collect information used to establish the identity, legal capacity and authority of clients and other persons involved in a transaction. This may include identity documents, signatures, photographs, verification results, powers of attorney, grants of probate, letters of administration and company or trust authority documents.

For AML/CTF purposes, we may collect information about clients, representatives, beneficial owners and controlling persons; the nature and purpose of a transaction or business relationship; source of funds and, where appropriate, source of wealth; sanctions and politically exposed person screening; transaction activity; customer risk assessments; and customer due diligence and reporting records.

We will only collect Personal Information where the information is reasonably necessary for one, or more of our functions or activities. We will collect Personal Information by lawful and fair means.

We may collect Personal Information:

Where it is unreasonable or impracticable to collect Personal Information directly from an individual, we may collect it from a third party, including a representative, referrer, service provider, publicly available source or other person authorised to provide the information.

We may collect Personal Information from the other party to a transaction and their representative, real estate agents, legal practitioners, settlement agents, mortgage brokers, lenders, financial institutions, Landgate, RevenueWA, the Australian Taxation Office, local governments, water service providers, strata companies and managers, electronic lodgment network operators, identity verification providers, AML/CTF service providers and other transaction participants.

We may collect, hold, use and disclose Personal Information to:

If you do not provide Personal Information requested by us, we may be unable to accept instructions or continue to act, verify identity or authority, satisfy our legal obligations or complete a transaction or settlement.

We may use cookies, analytics tools and similar technologies to operate our website, understand website usage, improve user experience.

These technologies may collect information such as Internet Protocol addresses, browser and device information, pages visited, visit duration, website performance information and interactions with the website. You may disable cookies through your browser settings, although doing so may affect website functionality.

Our website uses services provided by WPMU DEV for website analytics, security and monitoring. These services may collect website traffic and technical information, including visits, unique visits, page views, average visit duration, bounce rates, website performance information, login activity and information concerning suspicious or potentially malicious activity. HonkyNut administers these services on our behalf as our website developer and manager.

Our website also uses Google reCAPTCHA to protect website forms against spam and abuse and Google Maps to display location information. Google may collect technical, device and usage information when those services operate. Google’s handling of that information is governed by its applicable privacy terms.

We do not currently use Meta Pixel or Microsoft Clarity.

If you access or interact with our website or services using a third-party platform, such as Google, Facebook or another social media or authentication platform, that platform may share Personal Information with us in accordance with your privacy settings, the platform’s terms and applicable laws.

Where practicable, you may deal with us anonymously or by using a pseudonym. However, this may not be possible where we are required or authorised by law, regulation, court order or tribunal order to deal with identified individuals, or where it is impracticable for us to deal with individuals who have not identified themselves.

We may verify the identity and authority of clients and other persons involved in a transaction to comply with settlement, land titles, electronic conveyancing, AML/CTF, fraud prevention and other legal or professional requirements.

Verification may involve:

Identity information may be disclosed to identity or document verification providers, electronic lodgment network operators, financial institutions, government bodies, regulators and other persons where reasonably necessary to verify identity or authority, complete a transaction, prevent fraud or comply with law.

Where verification involves biometric information or other Sensitive Information, we will obtain consent where required unless collection is otherwise required or authorised by law.

We may be unable to accept instructions, continue to act or complete a transaction if satisfactory evidence of identity or authority is not provided.

We will restrict access to identity information and verification evidence to personnel and service providers who require access for an authorised purpose, and will take reasonable technical and organisational measures to protect that information from misuse, interference, loss and unauthorised access, modification or disclosure.

We will retain identity information and verification evidence for the periods required or authorised under applicable settlement, land titles, electronic conveyancing, AML/CTF and other requirements. When no longer required or authorised to retain that information, we will take reasonable steps to destroy it securely or de-identify it.

We may collect government-related identifiers, including driver’s licence numbers, passport numbers and tax file numbers, where collection is required or authorised by law or is reasonably necessary to verify identity or complete a transaction. We will not adopt a government-related identifier as our own identifier and will use or disclose it only where permitted by law.

We may store Personal Information in Australia and overseas, including through cloud, hosting, software, IT support and data storage service providers.

Security of Personal Information is important to us. We store most Personal Information in computer systems and databases operated by either us or our third-party providers. Some Personal Information is recorded in paper files that we store securely.

We implement and take reasonable steps to establish and maintain practices, procedures, processes and security measures to protect your Personal Information from misuse, interference, loss and from unauthorised access, modification or disclosure. These steps may include physical, technical and organisational safeguards, access controls, secure storage systems, staff training and confidentiality obligations.

Where Personal Information is no longer required for any purpose for which it may be used or disclosed under the Privacy Act, and we are not required by law, regulation, court order or tribunal order to retain it, we will take reasonable steps to destroy or de-identify it.

We may use and disclose Personal Information:

We may disclose your Personal Information, where appropriate, to:

If the ownership or control of all or part of our business changes, your Personal Information may be disclosed to our advisers and any prospective or actual purchasers, transferees or assignees and their advisers. Personal Information may also be transferred as part of the business or assets.

If we receive unsolicited Personal Information, we will determine whether we could have collected the information under the Privacy Act. If we could not have collected the information and the information is not contained in a Commonwealth record, we will take reasonable steps to destroy or de-identify it where lawful and reasonable to do so.

We may collect, use and disclose bank account details, payment instructions and related communications to receive, hold or disburse funds, complete settlement and prevent fraud. We may verify payment instructions through telephone calls, secure portals, electronic conveyancing systems, financial institutions or other verification procedures. We may delay or decline to act on an instruction where its authenticity cannot be verified or fraud, impersonation or unauthorised account substitution is suspected.

Applicable laws may prevent us from confirming whether a report has been made, providing access to particular information or giving reasons for withholding information. Nothing in this Policy requires us to disclose information where doing so would be unlawful or would contravene an applicable secrecy or tipping-off prohibition.

Some of our service providers and their subcontractors may store or access Personal Information outside Australia.

Where we disclose Personal Information to an overseas recipient, we will take reasonable steps required by the Privacy Act to ensure that the recipient does not breach the APPs in relation to that information, unless an exception applies.

We retain Personal Information for as long as reasonably necessary and for the purposes for which it was collected, or for any related or permitted purpose, including to comply with legal, regulatory, tax, accounting, insurance, reporting, record-keeping and dispute resolution obligations.

We retain client, transaction, trust accounting, tax, verification-of-identity, electronic conveyancing and AML/CTF records for the periods required or authorised by applicable laws, regulatory requirements and electronic conveyancing participation rules. Different periods may apply to different records.

We may retain records for longer where reasonably necessary for an audit, investigation, complaint, insurance matter, dispute or legal claim.

Where Personal Information is no longer required, we will take reasonable steps to destroy or de-identify it, unless we are required or authorised by law to retain it.

If an employment application is unsuccessful, we may retain the applicant’s Personal Information for up to 12 months to consider them for other roles, subject to applicable legal and operational requirements.

You have certain rights in relation to your Personal Information that we hold about you. We will respond to all requests we receive from individuals wishing to exercise their rights in accordance with the law.

You may request access to Personal Information we hold about you by contacting us using the details set out below.

We may require evidence of identity before providing access. We aim to respond to access and correction requests within 30 days.

We will not charge a fee for making an access request. We may charge a reasonable fee for giving access to Personal Information, where permitted by the Privacy Act.

We may refuse access where permitted by the Privacy Act, including where providing access would have an unreasonable impact on another person’s privacy, would be unlawful, would prejudice enforcement-related activities or would contravene an applicable secrecy or tipping-off restriction.

If we refuse to correct Personal Information, you may request that we associate a statement with the information recording that you consider it to be inaccurate, out of date, incomplete, irrelevant or misleading. We will take reasonable steps to associate that statement where required by the Privacy Act.

If you believe that Personal Information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, you may request correction by contacting us.

We will take reasonable steps to correct Personal Information where required by the Privacy Act.

If you believe we have breached the Privacy Act or the APPs, you may contact us using the details set out below. We may require proof of identity and further information to investigate the complaint. We aim to acknowledge and respond to your privacy complaints within 30 days. If further time is required, we will notify you. If you are not satisfied with our response, you may contact the OAIC at www.oaic.gov.au or 1300 363 992.

We may use software or third-party tools to assist with identity verification, document authentication, fraud detection, sanctions screening, politically exposed person screening, AML/CTF risk assessment and transaction administration.

These tools may generate matches, alerts, scores or recommendations for review by authorised personnel.

Material decisions about whether we accept or continue an engagement are not made solely by automated means and are subject to review by authorised personnel.

If we use a computer program to make, or substantially and directly assist in making, a decision that could reasonably be expected to significantly affect an individual’s rights or interests, we will include the information required by applicable privacy laws in this Policy.

If we become aware of a suspected or actual data breach involving Personal Information, we will assess the incident in accordance with the Privacy Act and take reasonable steps to contain, investigate and remediate the incident.

Where required by the Privacy Act, we will notify affected individuals and the OAIC of an eligible data breach. Where notification is required, we will prepare and provide the required statement in accordance with the Privacy Act.

We may update this Policy from time to time. The current version will be available at www.settlementhubwa.com.au or may be obtained by contacting us.

If you have any questions, comments, requests or complaints, please contact us at: