Privacy policy

Castlerock Property Group is committed to providing quality services to you and this policy outlines our ongoing obligations to you in respect of how we manage your Personal Information.

This privacy policy sets out how Castlerock Property Pty Ltd and Associated Entities(Castlerock, we, our) aims to protect the privacy of your personal information, your rights in relation to your personal information managed by Castlerock, and the way Castlerock will collect, hold, use, disclose and otherwise manage personal information about you.

We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The APPs govern the way in which we collect, use, disclose, store, secure, and dispose of your Personal Information. A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at


Collection of personal information

For the purposes of the Privacy Act, personal information is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual whose identity is apparent or can reasonably be ascertained, from the information or opinion.

The kinds of personal information that Castlerock collects will vary depending on the type and nature of Castlerock's dealings with you. For example:

(a)   where you invest in a fund or other product of Castlerock, we may collect information such as your name, residential and business address, date of birth, contact details (such as email and phone numbers), tax file number, Australian Business Number, tax identification number, bank account details, tax, and financial statements, employment details and details regarding your financial or accounting advisors;

(b)   where you register to receive information from us or submit queries to us regarding our funds or other products or development or other project that we are involved in, we may collect information such as your name, email address, phone number (including any mobile phone number) or other contact details, together with details of the particular query submitted information requested; and

(c)   where you have entered into an agreement (including a license or lease), we may collect information such as your name, residential or business address, contact details (such as email and phone numbers), Australian Business Number, and bank account details.

If we collect your tax file number (TFN), we will handle your TFN in accordance with the Privacy Act and the Privacy (Tax File Number) Rule 2015 (Cth).

Castlerockmayalsocollectotherkindsofpersonal information about you, forexamplewhereCastlerockis required to collect certain kinds of personal information about you for Castlerock to undertake identification and verification processes in accordance with the Anti-MoneyLaundering and Counter-Terrorism Financing Act 2006 (Cth) or any other relevant laws.

We may also be required to ask about your tax residency status under taxation information sharing agreements that the Australian Government has in place with other countries. For example, a tax treaty between Australia and the United States formed under US law (ForeignAccount Tax Compliance Act) requires Castlerock to ask account holders of some types of products whether they are US citizens or US tax residents when they open their product. If you are a tax resident of another country, the relevant treaty or law may require us to collect your relevant foreign tax identification number.

Sensitive Information

Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union, or other professional body, criminal record or health information.

Castlerock will not generally collect or hold sensitive information about you unless Castlerock is required to do so by law. Sensitive information includes information about your race, political or religious beliefs, sexual preferences, criminal convictions, membership of professional or trade associations or unions, or health information.

How Castlerock collects personal information

Castlerock may collect personal information about you in a range of circumstances, such as:

(a)   where you apply to invest in Castlerock’s funds or other products;

(b)   as part of Castlerock’s administration of any investment you make in Castlerock’s funds or other products;

(c)   where you request information from Castlerock or submit queries to Castlerock regardingCastlerock or Castlerock’s funds or other products;

(d)   where you enter into an agreement in relation to a property operated or managed by Castlerock;

(e)   where you register to receive information or submit queries to us regarding a development or other project that we are involved in; or

(f)    where you submit information to Castlerock via Castlerock’s website or other online services.

Generally, Castlerock will collect personal information directly from you. However, there may be circumstances where Castlerock collects your personal information from third parties. For example, where you apply to invest in Castlerock’s funds or other products, Castlerock may collect personal information regarding you from any registry services provider or fund administrator appointed by Castlerock in respect of the relevant fund or product.

Castlerock may also collect personal information about you as a result of Castlerock monitoring your investments in the relevant fund or product through Castlerock viewing the bank accounts for the relevant fund or product held in the name of an external custodian (including Castlerock viewing details regarding transactions processed through such bank accounts in respect of your investments in the relevant fund or product).

Use of your personal information

Castlerock collects, holds, uses, and discloses personal information about you for purposes relating toCastlerock’s business and operations, including for the purposes of:

(a)   providing you with information and responding to queries regarding the funds and other products or services of Castlerock;

providing you with information and responding to queries about the developments or 

(a)   other projects that we are involved in or any building or property that we operate or manage;

(b)   processing your application for investments in the funds or other products or services of Castlerock;

(c)   processing your application or agreement for license or lease in one of the properties operated or managed by Castlerock;

(d)   establishing your investment in a fund or other product or service of Castlerock; and

(e)   administering your investment in a fund or other product or service of Castlerock.

In addition to the purposes set out above, Castlerock may collect, hold, use and disclose your personal information to inform you of products, services, or offers of Castlerock which may be of interest to you. Where you are an investor in a fund or other product of Castlerock, this may include providing you with direct marketing information regarding the other funds or products of Castlerock.

If you do not want to receive this information or do not want Castlerock to use or disclose your personal information for direct marketing purposes, you can opt out at any time by contactingCastlerock.

You are under no obligation to provide your personal information to Castlerock. However, without receiving certain information from you, Castlerock may not be able to provide services to you, may not be able to process any application by you for investment in Castlerock’s funds or other products, or may be limited in the information or response to queries that we are able to provide to you.

Disclosures of personal information by Castlerock

Castlerockmay discloses your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers, or subcontractors insofar as reasonably necessary for the purposes set out in this Policy. Personal information is only supplied to a third party when it is required for the delivery of our services.


(a)   your financial advisers or other professional advisers;

(b)   related companies of Castlerock (such as subsidiaries or holding companies of Castlerock);

(c)   any registry service provider, fund administrator, or other similar service provider appointed by Castlerock in relation to Castlerock’s funds or other products;

(d)   any other third-party service provider which Castlerock may engage to provide custody, administration, technology, auditing, mailing, printing, or other services (including email direct marketing service providers);

(e)   Government authorities where required to by law; and

(f)    Castlerock’s professional advisers (including legal and accounting firms, auditors, consultants, and other advisers).

Castlerock does not currently disclose personal information to recipients located overseas or have established plans to do so. If Castlerock is likely to disclose personal information to other recipients located overseas, Castlerock will update this privacy policy regarding the likely disclosures (including, if it is practicable to do so, the countries in which such overseas recipients are likely to be located).

Security of your personal information

Castlerock may hold your personal information in both hard copy and electronic forms. Castlerock will take reasonable steps to ensure that the personal information Castlerock holds is protected against misuse, loss, unauthorized access, modification, or disclosure. Personal information is held on secure servers operated by a third party or in storage located in controlled, access restricted environments. Castlerock’s employees are required to maintain the confidentiality of any personal information held by Castlerock. Personal information may also, in certain circumstances, be held on behalf of Castlerock in hard copy or electronic forms by Castlerock’s service providers (such as offsite document storage providers, electronic data storage providers, or registry service providers). Castlerock enters into agreements with such service providers which impose confidentiality and privacy obligations on the service provider.

Access and correction of personal information

Castlerocktakesstepsreasonableinthecircumstancestoensurethatthepersonalinformationitcollects holds, uses, and discloses about an individual is accurate, complete, up-to-date, relevant, and not misleading.

Youhavetheright torequestaccesstothepersonalinformationCastlerockcollectsandholdsaboutyou. You alsohavetherighttorequestcorrectionofthepersonalinformationCastlerockcollectsandholdsaboutyou.

Ifatanytimeyouwouldliketorequestaccesstoor corrects the personal information about you that Castlerock collects and holds you can contact us using any of the below contact details:

Castlerock Property

Level 30,140 William Street

Melbourne, Victoria, 3000

Phone (03) 8639 9100


Where Castlerock outsources registry functions for the relevant fund or product to a service provider, any request for access to or correction of the personal information held by that service provider may need to be provided to the relevant service provider.

Castlerockwillseektorespondtorequestsforaccesstoorcorrectionofpersonalinformationwithin30daysof the date of the request.

If Castlerock refuses any request for access to or correction of personal information held by Castlerock, written reasons for that refusal will be provided by Castlerock.

In some circumstances, a fee may be charged for the cost of providing you with access to personal information (for example where providing access requires a detailed retrieval of personal information). Such fee will not exceed the cost to Castlerock of providing access.

Privacy complaints

If you believe that Castlerock has not dealt with your personal information in a manner that complies with the Privacy Act or the Australian Privacy Principles or has any other complaint regarding how Castlerock has dealt with your personal information, you can make a privacy complaint to Castlerock.

Privacy complaints should be made to Castlerock in writing using the contact details set out below. Upon receipt of your complaint, Castlerock will commence an investigation into your complaint. At all times, privacy complaints:

q  will be treated seriously;

q  will be dealt with promptly;

q  will be dealt with in a confidential manner; and

q  will not affect your existing obligations or affect the commercial arrangements between you and Castlerock.


In the event you are dissatisfied with the outcome of your complaint, you may refer the complaint to the office of the Australian Information Commissioner.

Changes to Privacy Policy

Castlerock will regularly review and update our practices and procedures regarding the management of personal information. As a result, this policy may be updated from time to time. Where Castlerock updates this policy, Castlerock will make the updated policy available, including on our website.


When you visit our website

When you visit Castlerock’s website ( Castlerock may collect certain information such as browser type, operating system, website visited immediately before coming to our site. This information is used in an aggregated manner to analyze how people use our site, such that we can improve our service.


Castlerock may from time to time use cookies on our website. Cookies are very small files that a website uses to identify you when you come back to the site and to store details about your use of the site. Cookies are not malicious programs that access or damage your computer. Most web browsers automatically accept cookies but you can choose to reject cookies by changing your browser settings. However, this may prevent you from taking full advantage of our website. Our website may from time to time use cookies to analyses website traffic and help us provide a better website visitor experience

Third party sites

Castlerock’s site may from time to time have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third-party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that Castlerock is not responsible for the privacy practices of other such websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects personally identifiable information.

How to contact us

For further information or inquiries regarding your personal information or to request access to or correction of personal information or to make a privacy complaint, please contact Castlerock using any of the following contact details:

Castlerock Property

Level 30,140 William Street

Melbourne, Victoria, 3000

Phone (03) 8639 9100