PRIVACY STATEMENT

AsetraX (Assets Property Hub)
Operated by Kim Troy Gida Babion (Sole Trader)
NZBN: 9429053358769
Suite 16015, Level 1, 6 Johnsonville Road, Johnsonville, Wellington 6037, New Zealand
Email: aphadmin@assetspropertyhub.com
Phone: +64 27 338 4107

Last updated: May 2026

1. Introduction

This Privacy Statement explains how AsetraX (Assets Property Hub), operated by Kim Troy Gida Babion trading as AsetraX (“we”, “us”, “our”), collects, uses, stores, discloses, and protects personal information obtained through the Platform at https://assetspropertyhub.com/.

This statement applies to all users of the Platform, including users based in New Zealand and Australia.

We comply with the requirements of:

• the Privacy Act 2020 (NZ) and the Information Privacy Principles (IPPs) contained therein; and
• the Privacy Act 1988 (Cth) (AU) and the Australian Privacy Principles (APPs) contained therein.

Where there is a difference in the obligations imposed by NZ and AU law, we apply the higher standard. Where a provision of this statement refers specifically to one jurisdiction, it is noted accordingly.

If you have any questions about this statement or about how we handle your personal information, please contact us at aphadmin@assetspropertyhub.com.

2. Who This Statement Applies To

This statement applies to all individuals who interact with the AsetraX Platform, including:

• General visitors and registered Users browsing property listings
• Agents, Agencies, and Developers who register and purchase Memberships (“Listers”)
• Private landlords and property owners who register under the Agent account type to list properties directly (see Section 3.1 and our Terms and Conditions, Section 4.1)
• Affiliate Partners participating in the AsetraX Referral Program
• Any person who contacts us by phone, email, web form, or any other means

3. What Personal Information We Collect

We collect personal information that is reasonably necessary to provide our services. The categories of personal information we may collect are set out below.

3.1 Account Registration

• First and last name
• Email address
• Account username or alias
• User type (User, Agent, Agency, or Developer – note that private landlords and property owners register under the Agent type; see Terms and Conditions Section 4.1)
• IP address
• Date of registration

3.2 Contact and Enquiries

• First and last name
• Email address
• Phone number
• IP address
• The content of your message or enquiry
• Browsing and interaction activity on the Platform

Retention: 24 months from the date of last contact, after which data is deleted or anonymised unless retention is required by applicable law or for the resolution of an active dispute.

3.3 Membership and Payments

• First and last name
• Billing address
• Email address
• IP address
• Payment transaction reference

We do not store full card numbers. All card payment data is processed directly and securely by Stripe. PayPal transactions are handled directly by PayPal. We retain payment records for 84 months from the date of the transaction to meet our legal and tax obligations.

3.4 Property Listings (Listers Only)

• Business name and professional contact details
• Property information submitted as listing content
• Profile information including photo, biography, licence number (if applicable and self-reported), and agency affiliation

Note on licence numbers: Where a Lister voluntarily includes a real estate licence number or registration number on their profile, this information is self-reported and is not verified by AsetraX. See Terms and Conditions Section 7A.4 and Section 6A of this Privacy Statement for further detail.

Retention: Until the Membership is terminated or the listing is removed, whichever is earlier. Where retention is required for legal compliance purposes, records may be retained for up to 84 months.

3.5 Affiliate Program (Affiliate Partners Only)

• First and last name
• Email address
• Referral activity and commission records
• Payout details

Retention: Until participation in the Affiliate Program is terminated, plus 84 months thereafter for financial record-keeping purposes.

3.6 Newsletter and Marketing Communications

• First and last name
• Email address
• IP address
• Email engagement data (opens, clicks)

Retention: Until you unsubscribe from marketing communications, after which we retain a suppression record of your email address to ensure you are not re-added.

3.7 Website Analytics

• IP address (anonymised at collection)
• Browsing history and interaction data on the Platform
• Device and browser type

Retention: 26 months from collection, in line with Google Analytics’ default data retention settings.

3.8 Legal Compliance

• First and last name
• Physical address
• Email address

Retention: 84 months, or as required by applicable legislation including the Tax Administration Act 1994 (NZ), the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (NZ), the Taxation Administration Act 1953 (Cth) (AU), or any applicable court or tribunal order.

4. How We Collect Personal Information

We collect personal information in the following ways:

• Directly from you, when you register an account, purchase a Membership, submit a listing, complete a contact or enquiry form, subscribe to our newsletter, or participate in the Affiliate Program
• Automatically, through cookies, analytics tools, and server logs when you visit or interact with the Platform (see Section 11, Cookies)
• From third-party login providers, where you use social login (Google or Facebook) to register an account, we receive basic profile information from those providers in accordance with their own privacy policies
• From payment processors, Stripe and PayPal may share transaction-related information with us for the purposes of payment processing and record-keeping
• Via form security tools, Google reCAPTCHA collects device and behavioural data on our registration, login, affiliate signup, and contact forms to detect and prevent automated bot submissions

We will only collect personal information by lawful means and in a manner that is fair and not unreasonably intrusive, in accordance with IPP 4 (NZ) and APP 3 (AU).

5. Why We Collect and Use Personal Information

We collect and use personal information only for purposes that are lawful, specific, and directly related to our business operations.

We will not use your personal information for a purpose that is incompatible with the purpose for which it was collected without first obtaining your consent, or as otherwise permitted under the Privacy Act 2020 (NZ) or the Privacy Act 1988 (Cth).

6. Marketplace Data Flows, Property Enquiries

AsetraX operates as a property marketplace connecting prospective buyers, tenants, and investors (“Users”) with agents, agencies, developers, and private landlords/owners (“Listers”).

When you submit an enquiry about a property listing through the Platform, including via contact forms, callback requests, or direct messaging, your contact details (name, email address, and phone number) may be passed to the Lister associated with that listing for the purpose of responding to your enquiry. By submitting an enquiry, you consent to this disclosure.

Listers are independently responsible for handling your personal information once received. As a condition of their Membership, all Listers agree to handle User enquiry data in compliance with the Privacy Act 2020 (NZ) or the Privacy Act 1988 (Cth), as applicable to their jurisdiction. This obligation is set out in our Terms and Conditions, Section 7.5.

Important: AsetraX does not verify the licensing, credentials, or professional standing of any Lister. Lister profile labels (Agent, Agency, Developer) are self-reported. Users are encouraged to conduct independent due diligence before engaging any Lister. For further information, see Terms and Conditions Sections 7A (REAA 2008 Compliance and Licensing Disclaimer) and 7C (Buyer-Facing Transparency and Lister Identification).

AsetraX is not responsible for how Listers use or store personal information following receipt.

6A. Lister Licensing and Professional Data

Where a Lister chooses to include a real estate licence number, registration number, or other professional credential on their profile, AsetraX collects and displays this information as submitted by the Lister.

AsetraX does not verify, validate, or confirm the accuracy of any licensing or professional information provided by Listers. This data is self-reported and published on the Platform in good faith as provided by the member.

Users should not rely on licence numbers or professional labels displayed on the Platform as confirmation of a Lister’s current licensing status or professional standing. In New Zealand, independent licence verification can be conducted via the Real Estate Authority (REA) public register at https://www.rea.govt.nz/.

This reflects the position set out in Terms and Conditions Section 7A.2 (No Licence Verification) and Section 7A.4 (Profile Labelling).

Retention: Licensing data forms part of a Lister’s profile data and is retained in accordance with Section 3.4 of this Privacy Statement.

7. Sharing Personal Information with Third Parties

We only share or disclose personal information to third parties where necessary to operate the Platform, to fulfil our contractual obligations to you, or where required by law. We do not sell personal information to third parties.

Our current third-party processors are:

Where processors are located outside of New Zealand or Australia, we take reasonable steps to ensure those recipients handle personal information in a manner consistent with the IPPs and APPs, including by relying on contractual data protection commitments or the processor’s participation in recognised privacy or security frameworks.

We may also disclose personal information where required by law, court order, or regulatory authority, or in connection with the sale or transfer of our business (in which case we will notify you in advance where practicable).

8. Do Not Track and Global Privacy Control

Our Platform responds to and supports the Do Not Track (DNT) header request field. If you enable DNT in your browser, those preferences are communicated to us in the HTTP request header and we will not track your browsing behaviour for marketing or analytics purposes.

9. Data Security

We take appropriate technical and organisational security measures to protect personal information against unauthorised access, disclosure, alteration, loss, or destruction. These measures include access controls, encrypted data transmission (SSL/TLS), and regular security reviews.

While we take reasonable steps to protect your personal information, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security.

In the event of a privacy breach that we reasonably believe has caused or is likely to cause serious harm, we will notify the New Zealand Privacy Commissioner and affected individuals as required under the Privacy Act 2020 (NZ), and the Office of the Australian Information Commissioner and affected individuals as required under the Privacy Act 1988 (Cth), as applicable.

10. Your Privacy Rights

10.1 New Zealand Users

Under the Privacy Act 2020 (NZ), you have the right to:

• request access to the personal information we hold about you (IPP 6)
• request correction of personal information that is inaccurate, out of date, incomplete, irrelevant, or misleading (IPP 7)
• be informed about how we collect and use your personal information (IPP 3)
• have your personal information protected with reasonable security safeguards (IPP 5)

10.2 Australian Users

Under the Privacy Act 1988 (Cth) and the Australian Privacy Principles, you have the right to:

• request access to the personal information we hold about you (APP 12)
• request correction of personal information that is inaccurate, out of date, incomplete, irrelevant, or misleading (APP 13)
• be informed about how we collect, hold, use, and disclose your personal information (APP 1 and APP 5)
• make a complaint about a breach of the APPs (APP 1.2)
• request that we not use your personal information for direct marketing (APP 7)

10.3 How to Exercise Your Rights

To exercise any of the above rights, please contact us at:

Email: aphadmin@assetspropertyhub.com

Post: Suite 16015, Level 1, 6 Johnsonville Road, Johnsonville, Wellington 6037, New Zealand

Please clearly identify yourself and describe your request. We will respond within 20 working days for NZ requests (as required under the Privacy Act 2020) and within 30 days for AU requests (as required under the Privacy Act 1988). We will provide access or correction, or give reasons for any refusal, in accordance with the applicable legislation.

We will not charge a fee to handle access or correction requests unless the request is complex or requires significant resources, in which case we will notify you of any fee in advance.

11. Cookies

Our Platform uses cookies and similar tracking technologies to enhance your experience, analyse usage, and support marketing. For full details of the cookies we use and how to manage your preferences, please refer to our Cookie Policy at https://assetspropertyhub.com/asetrax-cookie-policy/.

We have a data processing agreement in place with Google for Google Analytics. Google may not use your data for any other Google services. Full IP address logging is disabled.

12. Children

Our Platform is not directed at children under the age of 18. We do not knowingly collect personal information from anyone under 18. If you believe we have inadvertently collected information from a minor, please contact us at aphadmin@assetspropertyhub.com and we will delete it promptly.

13. Third-Party Websites

This Privacy Statement does not apply to third-party websites linked from our Platform. We are not responsible for the privacy practices of those websites and recommend you review their privacy policies before providing any personal information.

14. Privacy Complaints

14.1 Contact Us First

If you have a concern about how we have handled your personal information, please contact us in the first instance at aphadmin@assetspropertyhub.com. We will acknowledge your complaint within 5 working days and endeavour to resolve it within 20 working days.

14.2 New Zealand

If you are not satisfied with our response, you may lodge a complaint with the Office of the Privacy Commissioner (NZ):

Website: https://www.privacy.org.nz/
Phone: 0800 803 909

14.3 Australia

If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC):

Website: https://www.oaic.gov.au/
Phone: 1300 363 992

15. Amendments to This Privacy Statement

We reserve the right to update this Privacy Statement at any time. The date at the top of this document reflects the most recent revision. We will notify you of material changes by email to your registered address and by posting a notice on the Platform. Your continued use of the Platform after the effective date of any update constitutes acceptance of the revised statement.

16. Contact Details

AsetraX (Assets Property Hub)
Kim Troy Gida Babion (Sole Trader)
NZBN: 9429053358769
Suite 16015, Level 1
6 Johnsonville Road
Johnsonville, Wellington 6037
New Zealand

Email: aphadmin@assetspropertyhub.com
Phone: +64 27 338 4107
Website: https://assetspropertyhub.com