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10:52:58 am • 4 March 202610:52:58 am
  • 09 215 7434
  • info@silorealestate.co.nz

    • Privacy, Confidentiality & Data Protection Policy

    Silo Real Estate NZ Limited

    NZBN: 9429052859694
    Company Number: 9342231
    Real Estate Agency Licence Number (REA): 20199249

    Principal:
    Connor Ryan
    Connor@silorealestate.co.nz
    Mobile: 021 228 1977

    General Enquiries & Privacy Contact:
    info@silorealestate.co.nz
    Last Updated: 18.02.2026

    1. Our Commitment

    Silo Real Estate NZ Limited (“Silo”, “we”, “us”, “our”) operates as a licensed real estate agency in New Zealand and is committed to maintaining the highest standards of privacy, confidentiality and professional conduct.

    We recognise that property transactions involve highly sensitive personal and financial information. We treat that information with strict confidence and in accordance with New Zealand law and regulatory standards.

    This policy outlines how we collect, manage, store and protect personal information.

    2. Regulatory Framework

    Silo Real Estate NZ Limited operates in accordance with:

    • The Privacy Act 2020
    • The Real Estate Agents Act 2008
    • The Real Estate Agents (Professional Conduct and Client Care) Rules 2012
    • The Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT)
    • The Unsolicited Electronic Messages Act 2007

    We adhere to guidance issued by the:

    • Real Estate Authority (REA) – https://www.rea.govt.nz
    • REA Professional Conduct & Client Care Rules – https://www.rea.govt.nz/real-estate-professionals/the-professional-conduct-and-client-care-rules/
    • Office of the Privacy Commissioner (OPC) – https://www.privacy.org.nz

    These frameworks establish strict obligations regarding confidentiality, disclosure, fiduciary duties and handling of client information.

    3. Information We Collect

    In the course of providing agency services, we may collect:

    3.1 Vendors and Property Owners

    • Full legal name and contact details
    • Residential address
    • Identification documents (passport, driver licence)
    • Proof of address
    • Bank account details
    • Trust or company documentation
    • Property ownership records
    • Financial disclosures required for agency agreements
    • AML/CFT due diligence documentation

    3.2 Purchasers

    • Name and contact details
    • Proof of identity
    • Source of funds information (AML requirements)
    • Sale and purchase documentation
    • Property search criteria

    3.3 Website & Digital Interaction

    • IP address
    • Device and browser information
    • Cookies and analytics data
    • Online enquiry submissions

    We collect only information that is necessary to perform our agency duties and comply with statutory obligations.

    4. Purpose of Collection

    Personal information is collected and used for the purposes of:

    • Marketing and selling property
    • Facilitating and negotiating transactions
    • Entering into and managing agency agreements
    • Conducting customer due diligence under AML/CFT legislation
    • Meeting obligations under the Real Estate Agents Act 2008
    • Maintaining regulatory compliance with the REA
    • Record keeping and audit requirements
    • Communicating with legal advisers, lenders and professional consultants
    • Improving service delivery and marketing performance

    We do not use personal information for unrelated purposes without consent unless required by law.

    5. Confidentiality & Professional Duties

    As a licensed agency (REA Licence No. 20199249), Silo is bound by strict confidentiality obligations under:

    • The Real Estate Agents Act 2008
    • The Professional Conduct and Client Care Rules 2012
    • Common law fiduciary duties

    Information obtained during the course of an agency relationship will remain confidential except where:

    • Disclosure is required by law;
    • Disclosure is necessary to complete a transaction;
    • Disclosure is authorised by the client; or
    • Disclosure is required for AML/CFT compliance.

    All staff, contractors and licensees engaged by Silo are subject to confidentiality obligations.

    6. Disclosure of Information

    Personal information may be disclosed to:

    • Lawyers and conveyancers
    • Financial institutions and mortgage brokers
    • Valuers, building inspectors and consultants
    • AML/CFT verification providers
    • The Real Estate Authority
    • Government or regulatory agencies where legally required

    We do not sell or trade personal information.

    7. AML/CFT Compliance

    Under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009, we are legally required to:

    • Verify identity
    • Conduct customer due diligence
    • Retain identification documentation
    • Report suspicious transactions

    Failure to provide required information may prevent us from acting on your behalf.

    8. Data Storage & Security

    We implement reasonable administrative, technical and physical safeguards to protect personal information from:

    • Loss
    • Unauthorised access
    • Misuse
    • Disclosure
    • Alteration

    Information may be stored securely in cloud-based systems with restricted access controls. Records are retained in accordance with statutory retention obligations under real estate, AML/CFT and taxation legislation.

    9. Access & Correction Rights

    Under the Privacy Act 2020, you have the right to:

    • Request access to personal information held about you
    • Request correction of inaccurate information

    Requests should be directed to:
    Privacy Officer
    Silo Real Estate NZ Limited
    Email: info@silorealestate.co.nz

    You may also contact the Principal directly:
    Connor Ryan
    Connor@silorealestate.co.nz
    021 228 1977

    We will respond within the statutory timeframe.

    10. Data Breach Notification

    If a privacy breach occurs that is likely to cause serious harm, we will notify affected individuals and the Office of the Privacy Commissioner in accordance with Part 6 of the Privacy Act 2020.

    11. Complaints

    Privacy concerns or complaints should be directed to:
    info@silorealestate.co.nz

    If not resolved, you may contact:
    Office of the Privacy Commissioner
    https://www.privacy.org.nz

    Real Estate Authority
    https://www.rea.govt.nz

    Vendor Privacy Notice

    (Supplement to the Above Policy)

    This Vendor Privacy Notice applies specifically to property owners who engage Silo Real Estate NZ Limited under an Agency Agreement.

    1. Vendor Information Collected

    When acting for a vendor, we may collect:

    • Personal contact details
    • Ownership documentation (including LINZ records)
    • Bank account details for settlement proceeds
    • Mortgage information (where required)
    • Trust or company documentation
    • Marketing approvals and instructions

    2. Marketing Disclosure

    In marketing your property, we may publish:

    • Property address
    • Photographs and video
    • Floor plans
    • Property specifications
    • Council records (where publicly available)

    We will not publish personal financial information or sensitive data.

    3. Disclosure to Purchasers

    During a transaction, we may disclose:

    • Property documentation
    • Disclosure statements required under law
    • Information necessary to facilitate a sale

    We will not disclose confidential motivations or financial thresholds without your express consent.

    4. Retention of Records

    Agency and transaction records are retained in accordance with:

    • The Real Estate Agents Act 2008
    • AML/CFT legislation
    • Taxation and audit requirements

    12. Website Cookies & Marketing Communications

    Our website may use cookies and analytics tools to enhance user experience and monitor performance. You may disable cookies in your browser settings.

    Marketing communications are sent only where consent has been provided or where permitted by law. You may unsubscribe at any time.

    13. Policy Updates

    We may update this policy periodically. The most current version will always be published on our website.

    PART VI — AML/CFT & Identity Verification (DVS) Policy

    1. AML/CFT Compliance Framework

    Silo Real Estate NZ Limited is a reporting entity under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT Act).

    As part of our statutory obligations, we are required to:

    • Conduct Customer Due Diligence (CDD)
    • Verify the identity of clients
    • Verify beneficial owners and effective controllers
    • Verify persons acting on behalf of clients
    • Obtain and retain identity documentation
    • Monitor and report suspicious activities

    These obligations apply prior to entering into an agency relationship or facilitating a property transaction.

    2. Use of Department of Internal Affairs (DIA) DVS eVerification

    Silo Real Estate NZ Limited uses the New Zealand Department of Internal Affairs (DIA) Data Verification Service (DVS) to perform electronic identity verification (eVerification).

    We use DVS for:

    • Verifying identity documents (e.g. New Zealand passport, driver licence)
    • Confirming identity details provided by vendors and purchasers
    • Verifying beneficial owners and effective controllers of companies and trusts
    • Complying with AML/CFT identity verification requirements prior to listing or sale

    DVS allows us to securely verify identity information against official government records in real time.

    3. Legal Basis for Collection

    We collect and verify identity information under our legal obligations pursuant to:

    • Sections 11–31 of the AML/CFT Act 2009 (Customer Due Diligence)
    • AML/CFT (Definitions) Regulations 2011
    • AML/CFT Code of Practice (Real Estate Sector)

    We are legally required to verify:

    • The identity of vendors before listing property
    • Beneficial owners (those who own or control 25% or more of an entity)
    • Effective controllers of trusts or companies
    • Persons acting on behalf of another individual

    Failure to comply with these obligations may result in significant civil penalties for the agency.

    4. Individual Rights in Relation to DVS Verification

    Under the Privacy Act 2020, individuals have the right to:

    • Be informed that their identity information is being collected and verified
    • Request access to personal information we hold
    • Request correction of inaccurate information
    • Refuse consent to electronic verification via DVS

    Requests for access or correction may be directed to:

    info@silorealestate.co.nz

    You may also contact the Principal:

    Connor Ryan
    Connor@silorealestate.co.nz
    021 228 1977

    5. Consequences of Declining DVS Consent

    If an individual declines to consent to identity verification via DVS:

    • We may be unable to complete electronic verification;
    • Property listing or transaction processes may be delayed;
    • We may be legally prohibited from acting until identity is verified.

    Alternative Methods

    If consent for DVS eVerification is declined, we are willing to consider alternative verification methods, including:

    • Certified copies of identity documents
    • In-person verification
    • Verification via trusted referees
    • Additional documentation as required under AML/CFT guidelines

    However, alternative verification methods may require additional time and documentation.

    We cannot proceed with listing or transaction facilitation until satisfactory identity verification is completed in accordance with AML/CFT requirements.

    6. Data Storage & Retention

    Identity verification information obtained through DVS or alternative methods:

    • Is used solely for AML/CFT compliance purposes
    • Is securely stored
    • Is retained for the statutory period required under the AML/CFT Act (minimum 5 years following the end of the business relationship)

    We do not use DVS data for marketing purposes.

    7. Complaints & Further Information

    If you have concerns regarding:

    • Our AML/CFT processes
    • Identity verification procedures
    • Use of DVS
    • Handling of personal information

    You may contact:

    Privacy Officer
    info@silorealestate.co.nz

    If your concern is not resolved, you may contact:

    Department of Internal Affairs (AML/CFT Supervisor)
    https://www.dia.govt.nz

    Office of the Privacy Commissioner
    https://www.privacy.org.nz

    Real Estate Authority
    https://www.rea.govt.nz