1. About This Policy

This Privacy Policy explains how Hartles & Co collects, holds, uses, and discloses personal information through this website (Website), in accordance with the Privacy Act 2020.

This Website is operated independently of Lugton's Limited's own website and systems. Hartles & Co is part of Lugton's Limited, which is legally responsible for personal information collected via this Website; however, Lugton's Limited does not operate or manage this Website day to day, so all privacy enquiries and requests relating to it should be directed to Hartles & Co using the contact details in Section 9.

2. Information We Collect

We may collect personal information that you provide to us directly, including:

• your name, email address, phone number, and any details you enter when you submit an enquiry, request a property appraisal, register interest in a listing, or contact us through the Website;

• information you provide when subscribing to updates, newsletters, or market reports; and

• any other information you choose to share with us through the Website.

We may also automatically collect limited technical information when you visit the Website, such as:

• the date and time of your visit;

• your IP address and approximate network location;

• the pages you view and the referring website (if any);

• your device and browser type; and

• search terms used to find the Website.
  
  

3. How We Use Your Information

We use the personal information we collect to:

• respond to your enquiries and requests (including appraisal requests and listing enquiries);

• connect you with the relevant Hartles & Co agent or salesperson to progress a sale, purchase, or property management matter;

• send you marketing communications, such as new listings or market updates, where you have opted in (you can unsubscribe at any time);

• understand how the Website is used, so we can improve it; and

• meet our legal and regulatory obligations, including under the Real Estate Agents Act 2008.
  
  

4. Disclosure of Your Information

Because real estate agency work must be carried out by licensed individuals under Lugton's Limited's REAA licence, we may share your information with:

• Hartles & Co agents, salespeople, and branch managers, and relevant Lugton's Limited support staff, so they can assist with your enquiry;

• service providers who help us run the Website and our business (for example, website hosting, email/CRM platforms, and analytics providers), who are only permitted to use your information to provide that service to us; and

• any party where we are required to do so by law, or with your consent.

We do not sell your personal information to third parties.

5. Overseas Disclosure

Some of the service providers we use (for example, cloud hosting, email marketing, or analytics platforms) may store or process information on servers located outside New Zealand. Where this occurs, we take reasonable steps to ensure your information continues to be protected in a manner consistent with the Privacy Act 2020.

6. Cookies and Analytics

This Website may use cookies and similar technologies to support functionality and to help us understand how visitors use the site, including through tools such as [Google Analytics, Meta]. You can set your browser to refuse cookies, though parts of the Website may not work as intended if you do.

7. Data Security and Retention

We take reasonable steps to keep the personal information we hold secure, accurate, and up to date, and to protect it against loss, unauthorised access, use, or disclosure. We retain personal information only for as long as necessary to fulfil the purpose for which it was collected, or as required by law.

8. Your Rights

Under the Privacy Act 2020, you have the right to ask us what personal information we hold about you, and to request a correction if any of it is wrong. To make a request, contact us using the details in Section 9. We will respond within the timeframe required by law and may need to verify your identity first.

If you believe we have mishandled your personal information, you can raise this with us directly, or contact the Office of the Privacy Commissioner at privacy.org.nz.

9. Contact Us

For any privacy questions, requests, or concerns relating to this Website, please contact:

Hartles & Co Richard.Hartles@lugtons.co.nz

10. Changes to This Policy

We may update this Privacy Policy from time to time. The current version will always be available on this Website.