Privacy Policy
Last Updated: July 2026
Thank you for placing your trust in Cochrane Livestock & Property Group Pty Ltd ACN 695
473 502 as trustee for Bellsware Trust (individually and collectively “we”, “us”, as the
context requires). This Privacy Policy describes how we collect, hold, use, and disclose
your information and explains the choices that you have regarding how we use your
personal information.
This Privacy Policy applies to all dealings we have with individuals, including property
vendors, livestock vendors, purchasers, prospective purchasers, clients, contractors,
suppliers, service providers, website users and prospective employees.
We are committed to protecting your personal information. By submitting your personal
information to us, or by using our services, you acknowledge and consent to us using your
personal information in accordance with this Privacy Policy.
This Privacy Policy is intended to enhance the transparency of our operations, to notify
you of your rights and our obligations, and to provide you with information regarding:
1. the kinds of personal information which we collect and hold;
2. how we collect, hold, use, and disclose personal information;
3. the purposes for which we collect, hold, use, and disclose personal information;
4. how you may access personal information that is held by us and seek correction
of such information;
5. how you may complain about a breach of the Australian Privacy Principles (“APP”)
or registered APP code (if any) that binds us and how we will deal with such
complaints;
6. whether we are likely to disclose personal information to overseas recipients; and
7. if we are likely to disclose personal information to overseas recipients, the
countries in which such recipients are likely to be located.
This Privacy Policy sets out how we comply with our obligations under the Privacy
Act 1988 (Cth) (“Act”).
Acknowledgement
We acknowledge that we must take reasonable steps when handling personal
information.Whilst we cannot warrant that this Privacy Policy will be followed in every instance, we
will endeavour to follow this Privacy Policy. Similarly, while we cannot warrant that loss,
misuse or alteration of information will never occur, we will take all reasonable steps to
prevent these things from occurring.
We have taken reasonable steps to endeavour to comply with the APP and the Act, some
examples are noted below.
1. Implementation of this Privacy Policy.
2. Staff training and education.
3. Use of checklists to ensure that all APP are complied with.
4. Clear and transparent procedures regarding the handling of complaints and
disclosure of information.
If you require a hardcopy of this Privacy Policy, please contact our Privacy Officer on the
details below and we will provide you with a copy.
The kinds of personal information which we will collect and hold
Collection of personal information
It is our usual practice to collect personal information directly from the subject individual
or their authorised representative(s).
Personal information means information or an opinion (including information or an
opinion forming part of a database), whether true or not, and whether recorded in a
material form, about an individual whose identity is apparent, or can reasonably be
ascertained, from the information or opinion.
Some examples of the personal information we might collect include (but are not limited
to):
1. your name;
2. your contact details (such as telephone numbers, addresses (residential and
business), and email addresses etc.);
3. 4. 5. 6. your age or date of birth;
your occupation and employment details (current and former);
personal identification documentation (including government related identifiers);
details relating to your use of our services;7. property details, including property addresses, title particulars, agency
appointment details, inspection records and transaction information;
8. livestock sale information, including details relating to livestock transactions,
consignments, transport arrangements and sale proceeds;
9. information relating to buyers, sellers, prospective buyers and prospective sellers,
including their purchasing or selling requirements;
10. payment details, trust account information (where applicable), commission
records and settlement payment instructions;
11. banking details;
12. browser session details and approximate (not specific) geo-locations;
13. client survey information;
Collection of sensitive information
‘Sensitive information’ generally means information or an opinion about an individual’s:
1. racial or ethnic origin; or
2. political opinions; or
3. membership of a political association; or
4. religious beliefs or affiliations; or
5. philosophical beliefs; or
6. membership of a professional or trade association; or
7. membership of a trade union; or
8. sexual orientation or practices; or
9. criminal record (that is also personal information); or
10. health, genetic, or biometric information about an individual.
It is not our practice to collect sensitive information but if we need to do so, we will
endeavour to obtain your consent at or before the time of collection.
Where we have received unsolicited sensitive information (whether or not incidental to
our collection of personal information):
1. we will notify you, verify your identity, and provide you with the particulars of that
sensitive information;2. (unless you consent or agree otherwise) we will not use that sensitive information
(subject to a ‘permitted general situation’); and
3. we will destroy, redact, or pseudonymise that sensitive information.
We may collect and use sensitive information about you where a ‘permitted general
situation’ (as that term is defined in section 16A of the Act) exists in relation to that
sensitive information.
Identification
You may choose to interact with us using a pseudonym and/or not identify yourself.
In circumstances where we are required to do so, or are authorised by law, a court or
tribunal to ask for your identification, we will request your personal information.
Further, it is likely that it will be impractical for us to interact with you without some form
of identification, and therefore we will request identification details from you at the
beginning of each transaction.
If you do not consent to the collection of your personal information, in accordance with
this Privacy Policy, we may not be able to assist you with the provision of certain services.
How we will collect and hold your personal information
We only collect and hold personal information by lawful and fair means.
There are several ways we may collect your personal information, including when you:
1. 2. 3. 4. 5. 6. 7. 8. visit, or submit information through, our website;
attend one of our property inspections, livestock inspections, auctions or sales;
request a market appraisal or agency appointment;
execute or negotiate an agency appointment, contract of sale or other transaction
documentation;
apply with us for a position of employment or as a contractor;
deal with us face-to-face, in writing (by letter, facsimile, or email), or by telephone;
participate in any of our events, promotions, or surveys, or subscribe to any of
our publications; or
submit an application, quotation, purchase order, or service request to us.How we will collect personal information (other than sensitive information) from
third parties or indirectly
In some circumstances, we may collect and hold personal information that has been
collected from a third party (such as an associated entity, service provider, or contractor)
or a publicly available source.
This will likely occur in instances where:
1. you have consented to this collection; or
2. you would reasonably expect us to collect your personal information in this way
and it is necessary for us to collect this information for a specific or business
purpose (such as investigation of a complaint).
We may also collect personal information about you from third parties and other sources
including:
1. your nominated representative (including spouses, professional service
providers, or agents);
2. information that is in the public domain (where it is reasonably apparent this
information is not publicly available as a result of a data leak, privacy breach, or
otherwise made available in bad faith);
3. solicitors, conveyancers, mortgage brokers, financiers, valuers, building and pest
inspectors, stock agents and transport providers involved in a transaction;
4. government authorities, land title registries and other publicly available property
or livestock records.
How we hold your personal information
We will take steps to hold personal information in a manner which is secure and
protected from unauthorised access.
Your personal information may be held in either a physical form or in electronic form on
our IT system.
We also use cloud-based software systems to assist us in providing our services,
including customer relationship management software (such as Rex Software), together
with email, accounting and document management systems.
Where stored in electronic form on our IT system, we will take steps to protect the
information against modification, disclosure, or misuse by including such things asphysical restrictions, password protections, internal and external firewalls, and anti-virus
software.
We will also endeavour to ensure that our service providers have protection for electronic
IT systems and other necessary restrictions.
We will endeavour to ensure our staff are trained with respect to the security of the
personal information we hold, and we will restrict any access where necessary.
We retain personal information only for as long as reasonably necessary for the purposes
for which it was collected, to comply with our legal obligations (including applicable real
estate agency, trust accounting, taxation and record keeping obligations), to resolve
disputes and to enforce our legal rights.
In the event we hold personal information that is unsolicited, and we were not permitted
to collect it, the personal information will be destroyed, redacted, or pseudonymised as
soon as practicable.
If we collect personal information about you from someone else, we will advise you as
soon as practicable that this information has been collected and the circumstances
which surround the collection.
If we collect personal information (including sensitive information) that is unsolicited,
and we were not permitted to collect it, we will pseudonymise that personal information
and insofar as possible, remove records of the sensitive information from our systems as
soon as reasonably practicable.
Log Files
Our website follows a standard procedure of using log files. These files log visitors when
they visit websites. The information collected by log files include internet protocol (IP)
addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring
or exit pages, and possibly the number of clicks.
These are not linked to any information that is personally identifiable. The purpose of the
information is for analysing trends, administering the site, tracking users' movement on
the website, and gathering demographic information.
Cookies, tracking pixels, and the collection of personal information via social media
and our website
When you visit our website, we may collect information through cookies and similar
technologies provided by our website provider, Squarespace.Cookies are small text files stored on your device which assist us to operate, maintain
and improve our website. The cookies used by our website may collect information such
as your browser type, device information, website usage information and the pages you
visit.
Depending on the type of cookie used, cookies may remain active for periods ranging
from approximately 30 minutes up to 2 years.
You may disable cookies through your browser settings. However, doing so may affect the
functionality of our website.
Our website also contains links to our Facebook and Instagram pages. If you interact with
us through these platforms, the privacy policies of those platforms will apply to the
collection and handling of your personal information by those platforms.
Artificial intelligence
We are committed to protecting the privacy and confidentiality of client information. This
extends to our responsible use of Artificial Intelligence (AI) technologies and maintaining
confidentiality, data, and personal information.
We make use of AI tools and products to support efficiency and creativity in areas such
as market research, content generation, and strategic analysis. Our primary use for AI is
as an internal support tool to enhance our work and services.
Our priority is to balance innovation with trust when employing AI in practice.How we use AI
We do not upload or disclose client-specific, user-specific, or personal information into
AI tools.
Any material that we use within AI platforms is de-identified, anonymised, generalised,
or hypothetical in nature. If an AI tool has generated personal information about you
(whether true or untrue), we will notify you and obtain your consent.
No confidential client data is ever made publicly available, shared outside our
organisation, or used in a way that would compromise our intellectual property or yours,
or that of your privacy.
AI governance and security
Access to client data is limited to authorised personnel and handled in accordance with
our internal data security protocols. All final outputs are reviewed and approved by our
team or service providers before being shared with clients or made publicly available.
We continually monitor developments in AI technology. We adjust our processes for
ongoing compliance with security best practice, and to ensure our ethical duties and
standards are maintained.
Hiring and recruitment
If you apply for a position with us, we may also collect information about your experience,
character, qualifications, and screening checks (including background, health,
references, directorship, financial probity, identity, eligibility to work, vocational
suitability, and criminal record checks). Sensitive information will only be collected with
your consent.
We collect, use, and disclose your personal information to assess your application,
conduct screening checks and consider and contact you about positions available. Your
personal information may be exchanged with academic institutions, recruiters,
screening check providers, health service providers, professional and trade associations,
law enforcement agencies, referees, and your current and previous employers.
We may not be able to further consider you for positions with us without your personal
information.The purposes for which we collect and hold personal information
We collect, hold and use personal information in connection with the provision of our real
estate and livestock agency services. This includes marketing property and livestock,
arranging inspections, appraisals and agency appointments, facilitating negotiations and
sales, preparing and administering contracts and other transaction documents,
communicating with buyers, sellers and other parties involved in transactions, receiving
and disbursing monies where authorised, and complying with our legal and regulatory
obligations.
We may use your personal information for the following business activities, including:
1. internal management purposes;
2. administering accounts;
3. managing relationships with our clients;
4. dealing with complaints;
5. providing you with services;
6. facilitating product and service reviews;
7. business development and marketing purposes (including direct marketing);
8. sales and billing;
9. insurance purposes;
10. collecting overdue payments;
11. complying with legal requirements;
12. establishing, exercising, or defending a legal or equitable claim; and
13. training and recruitment.
We may also collect personal information (including sensitive information) for both the
primary purposes specified herein and purposes other than the primary purposes,
including the purpose of direct marketing.
The purposes for which we use and disclose personal information
We will endeavour to only use and disclose personal information for the primary
purposes noted above in relation to the business activities of our group.In addition, we may also use and disclose personal information (including sensitive
information) for both the primary purposes specified herein and purposes other than the
primary purposes, including the purpose of direct marketing.
Depending upon the services we provide, we may disclose your personal information to
persons or organisations involved in the relevant transaction, including:
1. buyers and sellers;
2. other real estate agencies or co-agents;
3. solicitors, conveyancers and settlement agents;
4. mortgage brokers and financiers;
5. valuers, surveyors, building and pest inspectors;
6. stock agents, livestock transport providers and livestock service providers;
7. our accountants, auditors and professional advisers;
8. government authorities and regulators; and
9. our technology service providers, including customer relationship management
software providers (such as Rex Software), document management providers and
IT service providers.
Unless one or more of the below scenarios has occurred, we will take necessary steps to
prevent personal information from being given to government agencies or other
organisations.
10. You have provided your consent.
11. You would reasonably expect that your information would be so disclosed.
12. We have informed you that your personal information will be provided to a third
party.
13. We are required by law to provide your personal information to a government
agency or other organisation.
14. The disclosure of the information will prevent a serious threat to somebody’s life
or health.
15. The disclosure of the information reasonably necessary for the enforcement of
criminal law.Further we will endeavour to only disclose personal information for the purpose in which
it was collected, unless disclosure is reasonably necessary to:
1. 2. 3. 4. 5. 6. 7. assist in locating a missing person;
lessen or prevent a serious threat to life, health or safety;
take appropriate action with suspected unlawful activity or serious misconduct;
facilitate or assist with diplomatic or consular functions or activities;
assist certain defence force activities outside Australia;
establish or exercise a defined legal or equitable claim; or
facilitate or assist confidential alternative dispute resolution activities.
Direct Marketing
Where permitted by law, we may use your personal information for direct marketing
purposes (including sending newsletters, marketing emails, and SMS communications)
to provide you with information regarding our services, properties, livestock sales, market
updates or other information which we reasonably believe may be of interest to you.
In any event you will be provided with an opt out option with respect to direct marketing,
should you wish to be excluded from direct marketing.
If you do not elect to ‘opt out’ to receiving direct marketing material from us, you consent
to us using personal information (other than sensitive information) provided to us for
direct marketing purposes.
We may however use sensitive information for direct marketing purposes if you provide
your consent to do so.
You may opt out of our direct marketing services at any time by notifying our Privacy
Officer (contact details overleaf). If you opt out you will no longer receive direct marketing
material from us.
We will also record this information on our opt out register.
Direct Marketing and Third Parties
We may also from time to time, if we have received your consent, provide your personal
information to a third party for the purposes of direct marketing.
You may at any time request the source of the personal information that has been
disclosed.Government related identifiers
We will endeavour not to use or disclose a government related identifier, unless:
1. the use or disclosure of the identifier is reasonably necessary for us to verify your
identity for the purposes of our business activities; or
2. the use or disclosure of the identifier is reasonably necessary for us to fulfil our
obligations to an agency or a State or Territory authority; or
3. the use or disclosure of the identifier is required or authorised by or under an
Australian law or a court or tribunal order; or
4. a permitted general situation (as that term is defined in the Act) exists in relation
to the use or disclosure of the identifier; or
5. we reasonably believe that the use or disclosure of the identifier is reasonably
necessary for one or more enforcement related activities conducted by, or on
behalf of, an enforcement body.
How you may access your personal information
You are entitled to access your personal information held in our possession.
We will endeavour to respond to your request for personal information within a
reasonable time period or as soon as practicable in a manner as requested by you. We
will normally respond within thirty (30) days.
You can make a request for access by sending an email or letter addressed to our Privacy
Officer, the details of which are as follows.
The Privacy Officer
Address: 261 Goomong Road, Kandanga QLD 4570
Telephone 0456 667 954
Email: admin@clpgroup.au
With any request that is made we will need to authenticate your identity to ensure the
correct person is requesting the information.
We will not charge you for making the request, however, if reasonable we may charge you
with the costs associated with your request.You will only be granted access to your personal information where we are permitted or
required by law to grant access. We are unable to provide you with access that is
unlawful.
Further we are not required to, and will not, give access to personal information to the
extent that:
1. we reasonably believe that giving access would pose a serious threat to the life,
health, or safety of any individual, or to public health or public safety; or
2. giving access would have an unreasonable impact on the privacy of
other individuals; or
3. the request for access is frivolous or vexatious; or
4. the information relates to existing or anticipated legal proceedings and the
information would not be accessible in normal discovery procedures; or
5. giving access would reveal the intentions of us in relation to negotiations and this
disclosure would prejudice those negotiations; or
6. denying access is required or authorised by or under an Australian law or a court
or tribunal order; or
7. we have reason to suspect that unlawful activity, or misconduct of a serious
nature, that relates to our business activities has been, or may be engaged in; or
8. giving access would be likely to prejudice the taking of appropriate action in
relation to the matter; or
9. giving access would be likely to prejudice one or more enforcement related
activities conducted by, or on behalf of, an enforcement body; or
10. giving access would reveal evaluative information generated within us in
connection with a commercially sensitive decision-making process.
If we refuse access to the information, written notice will be provided to you setting out:
1. 2. 3. the reasons for the refusal (except to the extent that, having regard to the grounds
for the refusal, it would be unreasonable to do so);
the mechanisms available to complain about the refusal; and
any other matter prescribed by the regulations.Correction
Should we hold personal information, and it is inaccurate, out of date, incomplete,
irrelevant, or misleading, or incorrect you have the right to make us aware of this fact and
request that it be corrected.
If you would like to make a request to correct your information, please contact our Privacy
Officer.
In assessing your request, we need to be satisfied that the information is inaccurate, out
of date, incomplete, irrelevant, or misleading. We will then take all reasonable steps to
ensure that it is accurate, up-to-date, complete, and not misleading.
It is our normal policy to resolve any correction requests within thirty (30) days. If we
require further time, we will notify you in writing and seek your consent.
Should we refuse to correct your personal information written notice will be provided to
you setting out:
1. the reasons for the refusal (except to the extent that, having regard to the grounds
for the refusal, it would be unreasonable to do so); and
2. the mechanisms available to complain about the refusal; and
3. any other matter prescribed by the regulations.
We will endeavour to notify any relevant third parties of the correct personal information
where necessary and required.
Notifiable Data Breaches
A Notifiable Data Breach is an event where access to your personal data has been gained
and there is a risk of serious harm, or it is suspected that there is a serious risk to you.
In the event of a Notifiable Data Breach, we will notify you. Examples of Notifiable Data
Beaches include:
1. loss or theft of physical devices (such as laptops and storage devices) or paper
records that contain personal information;
2. unauthorised access to personal information by an employee; and
3. inadvertent disclosure of personal information due to ‘human error’ (e.g. an email
sent to the wrong person).Complaints
If you wish to make a complaint about a failure of us to comply with our obligations in
relation to the Act or the APP please raise this with our Privacy Officer.
We will provide you with a receipt of acknowledgment as soon as practicable.
We will then endeavour to respond to your complaint and attempt to resolve the issues
within thirty (30) days.
In dealing with your complaint, we may need to consult another credit provider or third
party.
If you are not satisfied with the process of making a complaint to our Privacy Officer, you
may make a complaint to the Information Commissioner, the details of which are below.
Office of the Australian Information Commissioner (OAIC)
Address: GPO Box 5288, Sydney NSW 2001
Telephone: 1300 363 992
Facsimile: (02) 6123 5145
Information Commissioner
The Information Commissioner can decline to investigate a complaint on several grounds
including, among other things, where the complaint wasn’t made at first to us.
For more information about privacy in general, you can visit the Australian Information
Commissioner’s website: https://www.oaic.gov.au/.
Disclosure to overseas recipients
We may choose to, if permitted by law, share or disclose your personal information
with recipients outside of Australia.
We are required to notify you with a list of any countries which personal information may
be transmitted to or disclosed where it is practical for us to do so.
It is not our practice to share or disclose personal information overseas.
If you have any queries regarding this Privacy Policy or wish to find out more regarding any
of our other policies, please contact our Privacy Officer on the details listed above.Security
We take all reasonable steps to keep secure any information which we hold about you.
Personal information may be stored both electronically on our computer system, and in
hard-copy form. Firewalls, password protection, multi-factor authentication (where
implemented), anti-virus software, email filtering, access controls and other reasonable
technical and organisational safeguards are used to protect our electronic information.
Third-party websites
Our website may contain links to websites operated by third parties. We are not
responsible for the privacy practices, policies or content of those websites. We
encourage you to review the privacy policy of any third-party website before providing
your personal information.
Changes to this Privacy Policy
We will update this Privacy Policy from time to time. We therefore recommend that you
read it each time you visit our website. If you do not agree with this Privacy Policy at any
time, please do not continue to use our website. If you do continue to use our website,
you are deemed to have accepted the terms of this Privacy Policy as they appear at the time of use.