Privacy Policy
Lodgedwell (we, us, our) is committed to protecting the privacy and security of the personal information we collect, hold and handle in the course of providing conveyancing and related services. This Privacy Policy explains what information we collect, why we collect it, how we use and disclose it, how we keep it secure, and how you can access or correct it or make a complaint.
Lodgedwell is a registered business name owned by Ferny Creek Pty Ltd (ACN 698 317 565) and used under licence by Willis Property Group Pty Ltd (ABN 36 659 238 721), a licensed conveyancing practice in Victoria. The conveyancing services offered under the Lodgedwell name are provided by Willis Property Group Pty Ltd. When you engage Lodgedwell, your contract is with that company, and it is that company that collects and holds the personal information described in this Policy and is accountable to you for it. The same company also operates under the business name Willis Conveyancing.
Ferny Creek Pty Ltd owns the Lodgedwell brand and supplies the technology platform through which our services are delivered. It does not provide conveyancing services, and it does not use your personal information for its own purposes. Section 7 explains the part it plays in handling your information.
We handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). From 1 July 2026, as a provider of “designated services” in connection with the sale, purchase and transfer of real property, we are also a reporting entity under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (the AML/CTF Act), as amended by the AML/CTF Amendment Act 2024. Some of the information we collect, and some of the disclosures we make, are required or authorised by that regime. This Policy explains how those obligations affect your personal information.
1. About Lodgedwell
Lodgedwell is the digital conveyancing service of Willis Property Group Pty Ltd. We act for clients across Victoria in residential purchases and sales, off-the-plan and commercial transactions, transfers, and rural and regional matters.
Our service is delivered primarily online. You will usually engage us, provide your instructions, verify your identity and sign your documents through our website and our online tools rather than in person, and your settlement will ordinarily occur electronically. This means that most of the personal information we hold about you is collected, transmitted and stored digitally. Sections 3, 7 and 13 explain what that means for your information. We are supported by offices in Ferny Creek, Melbourne CBD and Bendigo.
| Detail | Information |
|---|---|
| Brand | Lodgedwell (a registered business name) |
| Owner of the business name | Ferny Creek Pty Ltd (ACN 698 317 565) — licensor |
| Entity providing the service | Willis Property Group Pty Ltd — licensee, and the entity responsible for your personal information |
| Also operating as | Willis Conveyancing |
| Signing licensed conveyancer | Brandon Owens |
| ABN | 36 659 238 721 |
| Conveyancing licence no. | 001729L |
| AUSTRAC reporting entity | 214889624 |
| Privacy Officer | privacy@lodgedwell.com.au |
| Website | www.lodgedwell.com.au |
| Postal address | PO Box 35, Sassafras VIC 3787 |
| Telephone | 03 9071 3050 |
Our two brands
We operate under two names. Willis Conveyancing is a business name of Willis Property Group Pty Ltd. Lodgedwell is a business name owned by Ferny Creek Pty Ltd and licensed to Willis Property Group Pty Ltd. Whichever name you deal with us under, the practice acting for you is the same: Willis Property Group Pty Ltd, using the same systems, the same policies and the same personnel. Our conveyancing licence, our AUSTRAC reporting entity registration and our professional indemnity insurance attach to that company, not to a brand.
This means personal information collected under either name is collected and held by Willis Property Group Pty Ltd. If you have dealt with us under one name and later engage us under the other, we may hold a single client record covering both engagements. The licence of the Lodgedwell name does not transfer your information to Ferny Creek Pty Ltd or give it any right to use your information for its own purposes.
2. The information we collect
“Personal information” means information or an opinion about an identified individual, or an individual who is reasonably identifiable. The kinds of personal information we collect depend on the services we provide to you and our legal obligations. They typically include:
| Category | Examples |
|---|---|
| Enquiry and quote information | Your name, contact details, the property or suburb, the type and expected timing of your transaction, and anything else you tell us when you enquire, start our online forms, or use the tools on our website — including where you do not go on to instruct us. |
| Identity and contact details | Full name, former names and aliases, date of birth, residential and postal address, email address, telephone numbers. |
| Identity verification information | Government-issued identity documents (passport, driver licence, Medicare card, birth or citizenship certificate), document numbers and expiry dates, photographs taken during a verification of identity (VOI), and biometric or liveness check data captured by our verification provider. |
| Transaction information | Details of the property and the matter, contract details, deposit and settlement figures, source and destination of funds, financier and mortgage details, and bank account details for settlement. |
| Financial and tax information | Tax file number declarations where required (for example, foreign resident capital gains withholding / clearance certificates), GST status, and land tax and duty information. |
| AML/CTF and risk information | Information about beneficial ownership and control, the purpose and intended nature of the transaction, politically exposed person (PEP) status, sanctions screening results, source of funds and wealth information for higher-risk matters, and the risk rating our onboarding tools assign to your matter (see section 7). |
| Information about other people | Where you provide information about co-purchasers, vendors, guarantors, agents, trustees, beneficial owners or related parties, we collect that information as part of the matter. |
| Website, tool and technical data | IP address, browser and device information, pages viewed, how you interact with our online forms and client tools, and analytics and advertising data collected when you use our website (see section 13). |
Sensitive information
Some of the information we collect is “sensitive information” under the Privacy Act (for example, biometric information used for identity verification, or information that may reveal certain personal attributes). We collect sensitive information only where you have consented, or where the collection is required or authorised by or under an Australian law — including our AML/CTF identity verification obligations — and we apply additional care to protecting it.
3. How we collect your information
We collect personal information in a number of ways, including:
- directly from you — through the enquiry and onboarding forms on our website, through our online client intake and customer due diligence forms, when you upload documents to us, and when you communicate with us by phone, email, message or video call;
- through our digital onboarding tools — including electronic verification of identity (VOI), electronic signing services and any client portal we make available to you;
- through the workflow systems that connect those tools to our practice management system, which pass your information between them automatically (see section 7);
- from referral partners — where a mortgage broker, real estate agent, comparison service or other referrer passes your details to us so that we can contact you about your transaction;
- from third parties involved in your matter — such as real estate agents, the other party’s representatives, your financier or mortgage broker, accountants, financial advisers, and other conveyancers or solicitors;
- from government bodies, registries and search providers — such as Land Use Victoria, the State Revenue Office (SRO), local councils, water and other authorities, and title and property information search providers;
- from sanctions, PEP and adverse-media screening services we use to meet our AML/CTF obligations; and
- automatically, when you visit our website or use our online tools (see section 13).
Where it is reasonable and practicable, we collect personal information directly from you. Where we collect your information from a third party, or where you provide us with information about another person, we will (and you should) take reasonable steps to ensure the relevant individual is made aware of this Policy.
Your authority and consent to identity verification
When you provide information to us, you confirm that you are authorised to provide the personal information of any other person you give us (for example, co-purchasers, vendors, guarantors, trustees or beneficial owners). You also consent to your identity information being checked with the relevant document issuer or official record holder, through third-party verification systems, for the purpose of confirming your identity.
4. Why we collect, hold, use and disclose your information
We collect, hold, use and disclose personal information for purposes connected with providing our services and meeting our legal obligations, including to:
- respond to your enquiry, confirm our fixed fee and what it includes, and tell you what your transaction is likely to involve;
- act for you in your conveyancing or property transaction and provide related advice and services;
- verify your identity and the identity of other parties to a transaction;
- complete searches, prepare and lodge documents, and effect electronic settlement and lodgement;
- invoice you, process payments, and account for trust monies;
- meet our anti-money laundering and counter-terrorism financing obligations (see section 5);
- operate, support, secure, test and improve our website, online forms and client tools (see section 7);
- comply with our other legal, regulatory, professional and record-keeping obligations;
- manage our relationship with you, respond to your enquiries, and handle complaints; and
- with your consent or as otherwise permitted, send you information about our services (see section 12).
Where the law requires us to collect certain information and you do not provide it, we may be unable to act for you or to complete your transaction. In particular, if you do not provide the information we need to verify your identity and complete our customer due diligence, we are legally prohibited from providing the relevant designated service to you.
5. Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF)
From 1 July 2026, Willis Property Group Pty Ltd — including everything we do under the Lodgedwell name — is a reporting entity regulated by the Australian Transaction Reports and Analysis Centre (AUSTRAC) under the AML/CTF Act. This means we are required by law to identify and verify our clients, to monitor the matters we act on, to keep specific records, and to report certain matters to AUSTRAC. These obligations apply in addition to, and are separate from, our obligations under the Privacy Act.
Customer due diligence (CDD)
Before we provide a designated service — and on an ongoing basis throughout our relationship with you — we are required to carry out customer due diligence. Depending on the assessed level of risk, this may include collecting and verifying:
- your identity, using reliable and independent documents, data or electronic verification;
- the identity of any agent acting on your behalf, and their authority to act;
- where you are a company, trust or other entity — information about your structure, beneficial owners, and the individuals who control you;
- whether you, a beneficial owner or a related party is a politically exposed person (PEP) or is subject to sanctions; and
- for higher-risk matters, information about the source of your funds and source of wealth, and the purpose and intended nature of the transaction.
We apply a risk-based approach and may apply simplified, standard or enhanced due diligence depending on the circumstances of the matter. We are required to collect this information whether or not you consent, because its collection is required or authorised by or under an Australian law.
Ongoing monitoring
We are required to monitor our business relationship with you for the duration of a matter, including keeping the information we hold about you up to date and reviewing transactions for unusual or suspicious features. We may ask you for further information or clarification at any stage to meet this obligation.
Reporting to AUSTRAC and the prohibition on “tipping off”
The AML/CTF Act requires us to report certain matters to AUSTRAC, including:
- suspicious matter reports, where we form a relevant suspicion in connection with a transaction or a person;
- threshold transaction reports, for cash or certain other transactions at or above the prescribed reporting threshold; and
- other reports required from time to time under the AML/CTF Act and rules.
Where we are required to report a matter, or where we make enquiries to meet our AML/CTF obligations, the law restricts what we can tell you. In particular, it is a criminal offence for us to disclose that we have formed a suspicion, that we have made or may make a report to AUSTRAC, or to disclose related information, where doing so could prejudice an investigation (the “tipping off” prohibition). As a result, there may be circumstances in which we cannot tell you that your information has been, or may be, disclosed to AUSTRAC, and in which we cannot explain a delay or a decision to stop acting.
AUSTRAC may in turn share the information we report with law enforcement, revenue and other government agencies as permitted by law.
AML/CTF record-keeping
We are required to keep records relating to our customer due diligence, the matters we act on and our AML/CTF program for at least seven years after our relationship with you ends or a transaction is completed. This requirement applies even if you ask us to delete your information — we cannot delete records we are legally obliged to retain (see section 10).
6. Who we disclose your information to
We disclose personal information only where it is reasonably necessary for the purposes described in this Policy, or where the disclosure is required or authorised by law. We may disclose your information to:
| Recipient | Purpose of disclosure |
|---|---|
| Government registries and revenue bodies | Land Use Victoria, the State Revenue Office, local councils and authorities — for searches, lodgement, duty and land tax, and registration of dealings. |
| Electronic lodgement and settlement networks | PEXA and related Electronic Lodgement Network Operators — to effect electronic settlement, lodgement and the transfer of funds. |
| Other parties to the transaction | The other party and their conveyancer or solicitor, real estate agents, financiers, mortgage brokers, accountants and advisers — as required to progress the matter. |
| Service providers and contractors | Our practice management, identity verification (VOI), electronic signing, document, IT, hosting, integration and back-office providers — bound to protect your information and use it only for the services they provide to us. |
| Our brand and technology licensor | Ferny Creek Pty Ltd, which owns the Lodgedwell name and supplies and maintains the technology platform used to deliver our services. Its personnel may access personal information only as necessary to build, support, secure and maintain those systems, under a written agreement that requires them to protect it, restricts its use to that purpose, and prohibits any other use or disclosure. It is not permitted to use your information for its own purposes, including marketing. |
| AUSTRAC and regulators | AUSTRAC, and law enforcement, revenue or other agencies — where required or authorised under the AML/CTF Act or other law. |
| Professional and regulatory bodies | Our insurers, auditors, legal advisers and relevant regulators — where reasonably necessary. |
| Business transfers | In the event of a merger, acquisition or sale of assets, client information may be transferred as part of that transaction, subject to this Policy. |
We do not sell your personal information. We will not disclose your information for purposes unrelated to those described in this Policy unless you have consented or the disclosure is required or authorised by law.
Electronic settlement (PEXA and ELNOs)
Where your transaction settles electronically, your personal information is handled through an Electronic Lodgement Network (ELN). By proceeding with an electronic settlement, you consent to:
- disclosure of that personal information to PEXA or any other Electronic Lodgement Network Operator (ELNO), for use in connection with an Electronic Workspace;
- disclosure of that personal information to other participants in the ELN (including through mobile applications provided by PEXA), an Electronic Workspace, or a Conveyancing Transaction the subject of an Electronic Workspace;
- use and disclosure of that personal information by PEXA and the other participants in an Electronic Workspace or in a Conveyancing Transaction the subject of an Electronic Workspace;
- collection, use, handling and disclosure of that personal information at least to the extent necessary to enable PEXA to provide its services in accordance with its Participation Agreement; and
- disclosure of that personal information to a Registrar or Duty Authority.
For further information, please refer to the PEXA privacy policy, available at www.pexa.com.au/privacy-policy.
7. Our technology platform and automated tools
Lodgedwell is built on a connected set of online tools — intake and due diligence forms, identity verification, electronic signing, document generation, workflow automation and practice management software. Your information moves between these systems automatically so that we can act quickly and consistently.
The Lodgedwell name and the technology platform are both owned by Ferny Creek Pty Ltd and licensed to Willis Property Group Pty Ltd. Under that licence, Ferny Creek Pty Ltd handles personal information only on our instructions and only to build, host, support, secure and maintain the platform. It is required to protect your information to the standards that apply to us under the Privacy Act and the AML/CTF Act, to keep it confidential, and to return or securely destroy it if the licence ends. Records that we are legally required to keep remain under our control at all times, and we retain independent access to them.
Automated processing
Some steps in our process are automated. In particular, our tools may:
- route your matter, allocate tasks and generate correspondence and documents based on the answers you give in our forms;
- carry out electronic identity verification, including automated document authentication and facial or liveness comparison, through our verification provider; and
- apply a risk rating to your matter for AML/CTF customer due diligence purposes, based on factors such as the parties, the entity structure, the transaction type and screening results.
We do not make decisions that have a legal or similarly significant effect on you by automated means alone. Where an automated tool flags a matter — for example, by producing a high risk rating, an inconclusive identity check or a possible screening match — the outcome is reviewed by a person before we decide to request further information, decline to act, or stop acting. You can ask us about how an automated step in our process affected you by contacting our Privacy Officer, although in some cases the “tipping off” prohibition described in section 5 will limit what we are able to tell you.
If your identity cannot be verified electronically, we will offer you an alternative method of verification. Electronic verification is not the only way to satisfy our obligations, and you are not required to use it.
8. Overseas disclosure
Some of the service providers we use — for example, cloud hosting, identity verification, screening, analytics or software providers — may store or process information on servers located outside Australia, or may have related entities or support functions overseas. Where this occurs, we take reasonable steps to ensure those providers handle your information consistently with the APPs and under appropriate contractual protections. The countries in which your information may be handled can change as our providers change; if you would like current details, please contact our Privacy Officer.
9. How we keep your information secure
We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure. These steps include:
- access controls, multi-factor authentication and role-based permissions across our systems, limiting access to those who need it;
- encryption of information in transit and, where appropriate, at rest;
- use of reputable, security-assessed practice management, verification, signing and automation platforms;
- secure upload channels for identity and financial documents, rather than ordinary email, wherever we can offer them;
- contractual security and confidentiality obligations on our technology provider and other contractors;
- staff confidentiality obligations and training; and
- secure destruction or de-identification of information when it is no longer required and we are no longer legally obliged to keep it.
No method of transmission or storage is completely secure. While we work to protect your information, we cannot guarantee absolute security.
A note on payment and settlement details
Cyber fraud targeting property settlements is common. We will not change our bank account details by email during your matter. If you receive a message that appears to come from us asking you to send funds to a different account, do not act on it — telephone us on the number in this Policy to confirm before transferring any money.
Data breaches
We maintain procedures to identify, contain, assess and respond to data breaches. If we experience an eligible data breach that is likely to result in serious harm, we will notify the affected individuals and the Office of the Australian Information Commissioner (OAIC) as required under the Notifiable Data Breaches scheme in the Privacy Act.
10. How long we keep your information
We keep personal information only for as long as it is needed for the purposes described in this Policy, or for as long as we are required to keep it by law. Conveyancing and AML/CTF record-keeping obligations require us to retain many records for extended periods — in the case of AML/CTF records, for at least seven years after the relevant matter ends. Because of these obligations, we may be unable to delete some of your information even if you ask us to.
Where you make an enquiry or start a form but do not go on to instruct us, we keep the information you gave us for up to 12 months so that we can respond if you come back to us, and then delete or de-identify it. If you ask us to delete it sooner, we will do so.
When information is no longer required and we are no longer legally obliged to keep it, we take reasonable steps to securely destroy or de-identify it.
11. Accessing and correcting your information
You may request access to the personal information we hold about you, and ask us to correct it if it is inaccurate, out of date, incomplete, irrelevant or misleading. To make a request, please contact our Privacy Officer (see section 14). We may need to verify your identity before responding.
We will respond within a reasonable time. In limited circumstances we may decline a request — for example, where giving access would be unlawful, would prejudice an AML/CTF investigation, or where another exception under the Privacy Act applies. If we refuse, we will tell you why (to the extent we are legally able to) and how you can complain.
12. Direct marketing
If you have enquired about our services or been our client, we may contact you about our services, guides and updates. You can opt out at any time by using the unsubscribe facility in the message or by contacting us, and we will stop.
We may also use your contact details with advertising and social media platforms to show you or people like you our advertising, or to exclude you from campaigns that are not relevant. Where we do this, we provide the platform with a hashed (scrambled) version of your email address rather than the address itself. You can ask us not to include you by contacting our Privacy Officer, and you can generally control ad personalisation through the platform’s own settings.
We will not use sensitive information for direct marketing without your consent, and we do not use information collected for AML/CTF purposes for marketing.
13. Our website, cookies and analytics
The Lodgedwell website and online tools are hosted and maintained by Ferny Creek Pty Ltd on our behalf, but the information collected through them is collected for and held by Willis Property Group Pty Ltd, and this Policy applies to it.
When you visit our website or use our online tools, we may collect technical information such as your IP address, device and browser type, the pages you view and how you interact with our forms. We use cookies and similar technologies for three purposes:
- Essential — to operate the site, keep your session secure, and remember where you are up to in a form. These cannot be turned off without breaking the service.
- Analytics — to understand how the site is used so we can improve it.
- Advertising — to measure the performance of our campaigns and, on some third-party platforms, to show you our advertising after you leave our site.
You can control or disable cookies through your browser settings, and where we offer a cookie preference tool you can use it to decline non-essential cookies, although some features may not work properly if you do. Where our website uses third-party analytics or advertising services, those providers handle information in accordance with their own privacy terms.
14. Complaints and how to contact us
If you have a question about this Policy, or a concern or complaint about how we have handled your personal information, please contact our Privacy Officer:
Privacy Officer, Lodgedwell
Willis Property Group Pty Ltd (ABN 36 659 238 721)
Email: privacy@lodgedwell.com.au
Phone: 03 9071 3050
Post: PO Box 35, Sassafras VIC 3787
We will acknowledge your complaint promptly and aim to resolve it within a reasonable time. If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (OAIC):
Website: www.oaic.gov.au
Phone: 1300 363 992
15. Changes to this Policy
We may update this Policy from time to time to reflect changes in our practices or the law, including the commencement and ongoing operation of our AML/CTF obligations and the further amendments to the Privacy Act that take effect from December 2026. The current version will always be available on our website, and the effective date appears at the top of this document.