Privacy Policy

About this policy

Capital Legal Pty Ltd (ABN 97 163 390 145) operates the SettleHQ platform. In this policy, the words “SettleHQ”, “we”, “us”, and “our” refer to Capital Legal Pty Ltd trading as SettleHQ.

This policy explains how we collect, use, store, share, and protect personal information when you use the SettleHQ website (settlehq.com.au), the SettleHQ comparison and matching service, and any related services we provide. It applies to information collected from you in person, by phone, by email, or through our website.

We are committed to handling personal information in accordance with the Australian Privacy Act 1988 (Cth) and the thirteen Australian Privacy Principles set out in that Act.

Two Roles One Operator

Capital Legal Pty Ltd is a law firm regulated under the Legal Profession Uniform Law (WA), and SettleHQ is the comparison and matching platform we operate. When we hold information for the purpose of providing legal services to you (for example, a contract review), that information is also subject to legal professional privilege and the additional obligations of a legal services provider. When we hold information for the purpose of operating the SettleHQ comparison platform, the obligations in this policy apply.

1. What information we collect

We only collect personal information that is reasonably necessary for the services we provide. The information we
collect depends on how you interact with us.

1.1 Information you give us directly

When you use the SettleHQ comparison service, contact us, request a contract review, or sign up with one of our
partner firms, we may collect:

• Your full name and any preferred name
• Your contact details: email address, phone number, postal address
• Information about your property transaction, including property type, suburb and postcode, sale price
  (where relevant), settlement date, transaction stage, and whether you are buying, selling, or both
• Special circumstances or preferences relevant to matching you with a suitable settlement firm, for example
  off-the-plan purchases, strata, or specialist requirements
• Any information you choose to share with us in messages, contact form submissions, or phone calls
• If you upload a contract or other document for review, the contents of that document

1.2 Information we collect automatically

When you visit our website, we collect technical information automatically through cookies and similar
technologies. This includes:

• Your IP address and approximate location (city or region)
• Your device type, browser, and operating system
• Pages you visit on our website, the time and duration of your visit, and the pages you came from and went to
• Information about how you use our comparison tool, including answers you provide and selections you
  make during the matching flow

More detail about cookies and how to control them is in Section 7.

1.3 Information we receive from third parties

From time to time, we may receive information about you from:

• Our partner settlement firms, for example where they update us on the status of an enquiry you have made
• Publicly available sources, for example public property records or company registers, where relevant to verifying transaction details
• Service providers we use to deliver the SettleHQ platform (analytics, marketing, communications)

1.4 Information we generally do not collect

We do not ask for, and you should not provide:

• Tax file numbers
• Government-issued identification numbers (driver’s licence, passport), unless specifically required for a contract review or other legal services engagement
• Bank account or credit card details. SettleHQ does not charge buyers or sellers, and you should not share financial account information through the website
• Sensitive information as defined in the Privacy Act (including health, religion, political opinion, sexual orientation), unless directly relevant to a legal matter you have asked us to assist with

2. Why we collect your information

We collect personal information for the following purposes:

2.1 To provide the SettleHQ comparison and matching service

• To understand your transaction and match you with suitable partner settlement firms
• To pass relevant information to a partner firm you have selected, so they can contact you and provide a quote or service
• To facilitate communication between you and the partner firm during the engagement process

2.2 To respond to your enquiries

• To answer questions you submit through our contact form, by email, or by phone
• To provide information about settlement, conveyancing, or related topics where you have asked

2.3 To provide legal services

• Where you engage Capital Legal Pty Ltd directly for legal services (such as a contract review), to provide those services and meet our professional obligations
• To comply with the Legal Profession Uniform Law (WA), the Solicitors’ Conduct Rules, and other regulatory obligations that apply to legal practitioners

2.4 To improve our service

• To analyse how people use our website and comparison tool, so we can improve it
• To test and evaluate new features
• To understand which marketing and content efforts are working

2.5 To send marketing communications

If you have provided your contact details and have not opted out, we may send you:

• Newsletters with information about settlement, property, and related topics
• Updates about SettleHQ services, partner firms, or new features
• Occasional promotional content we think you would find useful

You can unsubscribe at any time using the link in any marketing email, or by contacting us.
Unsubscribing from marketing does not stop transactional communications (for example, emails confirming an enquiry or providing information you have specifically requested).

2.6 To meet legal and regulatory obligations

• To comply with our obligations under the Privacy Act 1988, the Spam Act 2003, the Legal Profession Uniform Law (WA), and other applicable laws
• To respond to lawful requests from courts, regulators, or law enforcement
• To detect, prevent, and respond to fraud, security incidents, or misuse of our service

3. How and when we share your information

We treat your personal information carefully. We share it only where necessary to provide the service you have asked for,
where you have given consent, or where the law requires or permits it.

Most important: sharing with partner firms

When you use the SettleHQ comparison tool and select a partner firm to contact or sign up with,
we share the information you have provided with that firm so they can respond to your enquiry.
Once we share your information with a partner firm, that firm becomes a separate controller of that information
and is bound by their own privacy policy. We strongly encourage you to read the privacy policy of any firm you engage.

3.1 Partner settlement firms

When you complete the comparison flow and either contact or sign up with a partner firm, we share with that firm
the information you have provided through the matching process. This includes your name, contact details, and
the information about your transaction relevant to providing you with a quote or service.

We share information only with the specific firm you have selected. We do not auction, sell, or distribute your
information across our partner panel.

Each partner firm is independently responsible for handling your information in accordance with their own privacy
policy and applicable law. Once your information has been shared, we cannot control how the partner firm uses it.
You can ask a partner firm to stop contacting you at any time by contacting them directly.

3.2 Service providers

We use third-party service providers to help us run the SettleHQ platform. These providers may have access to
personal information only to the extent needed to perform their function, and they are contractually required to
handle that information securely and in accordance with the Privacy Act. The categories of provider we use include:

• Website hosting and infrastructure: the platforms that run our website and store data
• Email and communications: the platforms we use to send transactional emails and marketing
• Analytics: tools that help us understand how people use our website (for example, Google Analytics)
• Customer relationship management: the systems we use to manage enquiries and partner communications
• Document storage: secure storage for any documents you upload (for example, contracts for review)

3.3 Professional and regulatory obligations

Where we are providing legal services, we may share information:

• With other legal practitioners we engage to assist on a matter (for example, counsel)
• With courts, tribunals, or regulators where required by law or by professional obligation
• With our professional indemnity insurer or legal regulator where necessary to manage a complaint, claim, or audit

3.4 Where you ask us to

We will share your information with anyone you ask us to, for example a real estate agent or finance broker you
have nominated as part of your transaction. We will only do this on your direction.

3.5 Business transfers

If SettleHQ is sold, merged with another business, or otherwise transferred, we may share your information with
the new owner. If this happens, we will give you reasonable notice and your information will continue to be
subject to a privacy policy that is at least as protective as this one.

3.6 When the law requires it

We may share information without your consent where we are required or authorised to do so by Australian law,
for example in response to a court order, subpoena, or lawful request from a regulator or law enforcement agency.

4. How we store and protect your information

4.1 Where your information is stored

All personal information we hold is stored on servers located in Australia. We do not transfer your personal
information overseas. Where we use service providers to help operate the platform, those providers are required
to process and store data within Australia in connection with our service.

4.2 Security measures

We take reasonable steps to protect personal information from misuse, interference, loss, unauthorised access,
modification, or disclosure. These measures include:

• Encrypted connections (HTTPS) for all data transmitted to and from our website
• Encrypted storage for sensitive information including any documents uploaded for review
• Access controls limiting which staff can see what information, on a need-to-know basis
• Regular review of our security practices and provider arrangements
• Staff training on privacy and confidentiality obligations, including the additional obligations that apply to staff handling legal matters

No system is completely secure. While we take security seriously, we cannot guarantee absolute security of any information transmitted over the internet.

4.3 How long we keep your information

We keep personal information only as long as we need it for the purposes set out in this policy, or as required by law. Specifically:

• Comparison enquiries: we retain your enquiry record for [seven years] from the date of submission, to allow us to respond to follow-up questions, audit our service, and meet legal record-keeping obligations
• Legal services records: where we have provided legal services to you, we retain client files for at least seven years from the conclusion of the matter, in line with the requirements of the Legal Profession Uniform Law (WA)
• Marketing contact details: we retain marketing list information until you unsubscribe, after which we keep a minimal record (your email address only) to ensure we do not contact you again
• Website analytics: we retain website analytics information for up to 26 months in line with default Google Analytics retention settings

After the relevant retention period, we either delete your information or de-identify it so it can no longer be linked to you.

5. Your rights and choices

You have a number of rights in relation to the personal information we hold about you.
We will help you exercise these rights at no cost (except in narrow circumstances explained below).

5.1 Access

You can ask us for a copy of the personal information we hold about you. We will respond within 30 days.
In most cases this is free; if your request is unusually complex or repetitive, we may charge a reasonable fee
to cover our cost of producing the information, and we will tell you about any fee before we proceed.

5.2 Correction

If any information we hold about you is wrong, out of date, incomplete, irrelevant, or misleading,
you can ask us to correct it. We will respond within 30 days. If we agree to make the correction, we will do so
at no cost. If we disagree, we will tell you why in writing and you can ask us to attach a statement of your view
to the relevant record.

5.3 Withdraw consent / unsubscribe

You can withdraw your consent for us to use your information for marketing purposes at any time.
The easiest way is to use the unsubscribe link in any marketing email. You can also email us at the address in Section 9.
Withdrawing marketing consent does not affect transactional communications related to enquiries you have made.

5.4 Delete your information

You can ask us to delete the personal information we hold about you. We will do so unless we are required to keep
it by law (for example, legal services records that must be retained under the Legal Profession Uniform Law) or
where we have a legitimate, lawful reason to keep it (for example, an active dispute).

5.5 Make a complaint

If you think we have mishandled your personal information, please contact us first using the details in Section 9.
We will investigate and respond within 30 days.

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

• Website: oaic.gov.au
• Phone: 1300 363 992
• Post: GPO Box 5288, Sydney NSW 2001

If your complaint relates to our work as a legal services provider rather than the SettleHQ platform,
you can also make a complaint to the Legal Services and Complaints Officer at the Legal Practice Board of Western Australia.

6. Data breaches

If we suspect a data breach has occurred and the breach is likely to result in serious harm to anyone whose
information we hold, we will:

• Investigate promptly and contain the breach
• Notify the affected individuals as soon as practicable, including a description of the breach, the kinds of information involved, and the steps they can take to protect themselves
• Notify the Office of the Australian Information Commissioner (OAIC) in line with the Notifiable Data Breaches scheme under Part IIIC of the Privacy Act 1988

Notification is made to affected individuals via email to the address we hold on file, or by another reasonable method if email is not practical.
We will continue to monitor and update affected individuals as the situation develops.

7. Cookies and tracking technologies

Our website uses cookies and similar technologies to help it work properly, to understand how visitors use the site,
and to support marketing efforts. A cookie is a small piece of data stored on your device by your browser.

7.1 Types of cookies we use

7.2 Managing cookies

Most browsers let you control cookies through their settings. You can:

• Block all cookies (this may stop our website from working properly)
• Block third-party cookies only (for example, Google Analytics, Meta)
• Delete cookies you have previously accepted

Helpful instructions for the most common browsers are available at allaboutcookies.org.au.

8. Information about children

SettleHQ is not directed at children. We do not knowingly collect personal information from anyone under 18 years old.
If you are under 18, please do not submit personal information through our website without the consent and supervision
of a parent or guardian.

If we become aware that we have collected information from a child under 18 without appropriate consent, we will delete that information promptly.

9. How to contact us

If you have a question about this policy, want to exercise one of your rights, or have a privacy concern, please contact us:

We aim to respond to all privacy queries within five business days, and to formal access, correction,
or complaint requests within 30 days as required by the Privacy Act.

10. Changes to this policy

We may update this policy from time to time. The most current version will always be available on our website at settlehq.com.au/privacy.

If we make material changes (for example, changes to the categories of information we collect, the parties we share it with,
or your rights under this policy) we will give you reasonable notice. Where we hold your contact details, we will email you.
We will also update the “last updated” date at the top of this policy.

If you continue to use SettleHQ after we have notified you of changes to this policy, you are taken to have accepted the updated policy.