Todd & Co Website Privacy Policy

1. Who we are

In this policy, “Todd & Co Realty”, “we”, “us” and “our” means:

Todd Realty Limited T/A Todd & Co Realty

Licensed Real Estate Agent REAA 2008

46 Don Street, Invercargill

155 Palmerston Street, Riverton

Phone: 03 218 7124

Email: admin@toddco.nz

Website: toddco.nz

“Personal information” means information about an identifiable individual.

“You” means any individual whose personal information we collect or hold. This may include clients, customers, prospective clients, property owners, vendors, purchasers, landlords, tenants, prospective tenants, guarantors, referees, contractors, representatives, trustees, directors, shareholders, beneficial owners, authorised persons, website users and people who make enquiries with us.

If you provide us with personal information about another person, you must ensure you are authorised to do so and that the person is aware their information may be provided to and handled by Todd & Co Realty in accordance with this policy.

2. What personal information we collect

The personal information we collect will depend on your relationship with us and the services involved. It may include:

your name, address, email address, phone number and other contact details;
property ownership, property interest, enquiry and viewing history;
details about a property you own, occupy, manage, wish to sell, purchase, lease, rent or have appraised;
information provided through open home registers, private viewing bookings and property enquiries;
appraisal requests, market estimate requests and communications with our team;
identification information, including copies or details of identity documents where required;
date of birth, occupation, source of funds, source of wealth, beneficial ownership, trust, company or entity information where required for AML/CFT or other compliance purposes;
information contained in agency agreements, sale and purchase agreements, leases, tenancy agreements, management agreements and related documents;
information about offers, negotiations, transactions, finance conditions, settlement, chattels and property-related instructions;
tenancy application information, including rental history, employment information, income information, references, identification, credit check information and emergency contact details;
property management information, including rent, arrears, maintenance requests, inspection records, complaints, breaches, tribunal matters and communications with landlords, tenants, tradespeople and contractors;
commercial leasing or management information, including lease terms, rent reviews, renewals, outgoings, compliance matters and tenant/landlord communications;
rural, lifestyle, commercial or business-related information relevant to a transaction or service;
payment, invoicing, trust account and debt collection information;
information you provide when subscribing to newsletters, market updates, campaigns, competitions or marketing communications;
website, online enquiry, digital advertising and analytics information, including IP address, device information, browser type, pages visited, links clicked and cookie information;
records of communications with us, including emails, phone calls, messages, online forms and notes of conversations;
any other information reasonably required for our real estate, property management, commercial, rural, compliance, marketing or business purposes.

We generally only collect personal information where it is reasonably necessary for our services, business functions or legal obligations.

3. How we collect personal information

Direct collection

We may collect personal information directly from you when you:

contact us by phone, email, website, social media, text message or in person;
visit or use our website;
attend an open home, private viewing, auction, meeting or event;
make an enquiry about a property or service;
request an appraisal, market estimate or property information;
enter into an agency agreement, management agreement, lease, tenancy agreement or sale and purchase agreement;
submit an offer or participate in negotiations;
apply for a rental property;
provide identification or AML/CFT information;
subscribe to updates, newsletters or marketing;
complete a form, register, survey or online lead form;
otherwise deal with Todd & Co Realty.

Indirect collection

We may also collect personal information about you from someone else where this is permitted by the Privacy Act 2020.

This may include information collected from:

vendors, purchasers, landlords, tenants, prospective tenants or other parties involved in a property matter;
your authorised representatives, including solicitors, accountants, advisers, trustees, directors or family members;
referees, employers, previous landlords, previous property managers or tenancy references;
other real estate agencies or property professionals;
councils, government agencies, public registers, rating databases, property records, land records, Companies Office records and other publicly available sources;
property data providers, valuation data providers, property portals and listing platforms;
AML/CFT, identity verification, screening and compliance providers;
credit reporting agencies, tenancy database providers and debt collection agencies;
banks, insurers, valuers, building inspectors, contractors, tradespeople and service providers;
website, CRM, marketing, advertising, analytics, email and IT providers;
social media platforms, online advertising platforms and third-party lead generation tools;
any other source where collection is lawful and reasonably necessary for the services we provide.

From 1 May 2026, where we collect personal information about you indirectly, we will take reasonable steps to make sure you are aware that we have collected it, why we collected it, who may receive it, who holds it, whether collection is required or authorised by law, and your rights to access and correct it, unless an exception under the Privacy Act 2020 applies.

We may provide this information through this Privacy Policy, short privacy notices, forms, open home registers, email communications, website notices, application forms, agreements, direct communications or other reasonable means.

4. Why we collect personal information

We may collect, use and hold personal information for purposes connected with our real estate, property management and business services, including to:

respond to enquiries and communicate with you;
provide real estate advice, appraisals, market estimates and property information;
list, market, sell, purchase, lease, rent, appraise or manage property;
arrange and manage open homes, private viewings, inspections, auctions and property appointments;
record attendance at properties and interest in listings;
report to vendors, landlords or clients about property interest, feedback, enquiries, offers and related matters;
prepare, negotiate, manage and administer agency agreements, sale and purchase agreements, leases, tenancy agreements, property management agreements, disclosure documents and related records;
assess offers, applications, references, suitability and instructions;
manage tenancies, leases, rent reviews, renewals, inspections, maintenance, repairs, arrears, complaints, breaches, disputes and tribunal matters;
manage commercial, rural, lifestyle and residential property matters;
verify identity and complete customer due diligence, enhanced due diligence and other AML/CFT requirements;
comply with legal, regulatory, tax, trust accounting, audit, insurance and record-keeping obligations;
communicate with solicitors, advisers, councils, banks, insurers, contractors, tradespeople and other relevant parties;
invoice, collect money, manage trust account obligations and recover debts;
send property alerts, market updates, newsletters, event invitations, advertising or other marketing communications where permitted;
improve our services, website, systems, marketing, training, quality assurance and client experience;
analyse website use, advertising performance and enquiry trends;
protect the safety, security, rights, property and interests of our clients, customers, staff, contractors and the public;
respond to complaints, disputes, legal claims, regulator requests or law enforcement requests;
carry out any other lawful purpose connected with our business that you authorise or that we tell you about.

If you do not provide information we reasonably require, or if the information provided is incomplete or inaccurate, we may be unable to provide services to you, may be limited in how we can assist, or may be unable to meet legal or regulatory obligations.

5. AML/CFT and identity verification

As a real estate agency, we may be required to collect and verify personal information under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 and related regulations.

This may include collecting information about identity, address, date of birth, beneficial ownership, source of funds, source of wealth, trusts, companies, entities, authorised persons, politically exposed persons and other compliance matters.

We may collect this information directly from you or indirectly from authorised representatives, public registers, Companies Office records, electronic verification providers, AML/CFT providers, solicitors, advisers, other parties to a transaction or other lawful sources.

We may use third-party providers to help verify identity, complete AML/CFT checks, screen information and securely store compliance records.

Where AML/CFT or another law requires us to collect or retain information, we may not be able to delete it on request until the relevant legal retention period has passed.

6. Who we may disclose personal information to

We may disclose personal information where reasonably necessary for the purposes set out in this policy, where authorised by you, or where required or permitted by law.

This may include disclosure to:

vendors, purchasers, landlords, tenants, prospective tenants and other parties involved in a property transaction, tenancy, lease or management matter;
our salespeople, property managers, employees, contractors and authorised representatives;
solicitors, accountants, advisers, banks, insurers, valuers, building inspectors, surveyors, consultants and other professional advisers;
councils, government agencies, regulators, courts, tribunals, the Real Estate Authority, Tenancy Services, the Tenancy Tribunal, Police or other law enforcement agencies;
AML/CFT, identity verification, screening and compliance providers;
credit reporting agencies, tenancy database providers, debt collection agencies and referees where relevant;
tradespeople, maintenance contractors, service providers, inspectors and compliance providers;
website, CRM, cloud storage, email, IT, software, data, payment, trust accounting, property management and business system providers;
property portals, advertising platforms, marketing providers, print providers, photographers, videographers and sign companies where relevant to marketing a property or service;
related or associated service providers that support our business operations;
other parties where disclosure is authorised by you, necessary for the service being provided, or required or permitted by law.

We do not sell personal information.

Where a third-party provider holds or processes information on our behalf, we take reasonable steps to ensure that provider handles the information appropriately. Where information is disclosed to another party for that party’s own purposes, that party will be responsible for its own handling of the information under the Privacy Act 2020.

7. Marketing communications

We may use your personal information to contact you about properties, services, market updates, events, newsletters or information that may be relevant to you.

You can unsubscribe from email marketing at any time by using the unsubscribe link in our emails, if available, or by contacting us at admin@toddco.nz.

We may still contact you where necessary for non-marketing purposes, including in relation to a current enquiry, property matter, agreement, tenancy, lease, transaction, compliance matter or legal obligation.

8. Website, cookies, analytics and online advertising

When you visit our website or interact with our online content, we may collect information using cookies, pixels, analytics tools and similar technologies.

This may include information about your device, browser, IP address, pages visited, links clicked, enquiry forms submitted, referring websites and interactions with our advertising or emails.

We may use this information to:

operate and improve our website;
understand how people use our website and services;
measure advertising and marketing performance;
personalise or improve online content;
show relevant advertising or property information;
maintain website security and performance.

We may use third-party tools and platforms such as Google, Meta/Facebook, Instagram, LinkedIn, YouTube, email marketing tools, CRM systems, property software and analytics providers. These providers may collect information directly through their own technologies and may handle that information under their own privacy policies.

You can usually disable or manage cookies through your browser settings. If you disable cookies, some parts of our website may not work as intended.

9. Third-party websites and platforms

Our website, emails, advertisements or social media pages may contain links to third-party websites, platforms, forms or services.

Those third parties are responsible for their own privacy practices. We encourage you to review their privacy policies before providing personal information to them.

We are not responsible for the content, security or privacy practices of third-party websites or platforms.

10. Storage, security and retention

We may hold personal information electronically or in hard copy, including through secure internal systems, cloud storage, CRM systems, property management systems, email systems, website platforms, trust accounting systems, AML/CFT systems and other service providers.

We take reasonable steps to protect personal information from loss, unauthorised access, use, disclosure, alteration or destruction.

No method of transmission over the internet or electronic storage is completely secure. While we take reasonable steps to protect information, we cannot guarantee the security of information transmitted to us online.

We keep personal information only for as long as reasonably necessary for the purposes for which it was collected, including to meet legal, regulatory, AML/CFT, tax, trust accounting, insurance, audit, dispute resolution and business record-keeping requirements.

Where we no longer need to retain personal information, we will take reasonable steps to securely delete, destroy or anonymise it.

11. Disclosure outside New Zealand

Some of our service providers, software providers, cloud storage providers or technology platforms may store or process information outside New Zealand.

Where personal information is disclosed or stored outside New Zealand, we will take reasonable steps to ensure it is protected in a way that is consistent with the Privacy Act 2020, unless another exception or lawful basis applies.

12. Accessing or correcting your personal information

You have the right to ask us what personal information we hold about you. You also have the right to ask us to correct it if you think it is wrong.

To request access to or correction of your personal information, please contact:

Todd & Co Realty

46 Don Street, Invercargill

155 Palmerston Street, Riverton

Phone: 03 218 7124

Email: admin@toddco.nz

We may need to verify your identity before responding to a request.

In some circumstances, we may refuse a request for access or correction where the Privacy Act 2020 allows us to do so. If we refuse a request, we will explain why, unless we are legally prevented from doing so.

We may also refuse to delete information where we are required or permitted to retain it for legal, regulatory, compliance, business, dispute resolution or record-keeping reasons.

13. Privacy complaints

If you are concerned about how we have handled your personal information, please contact us first so we can look into it and try to resolve the matter.

Email: admin@toddco.nz

Phone: 03 218 7124

You can also contact the Office of the Privacy Commissioner on 0800 803 909 or through its website.

14. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in law, technology, our systems or our business practices.

This is the current version, available on our website.

Last reviewed: May 2026