Privacy Policy - The Rothmore Group

Effective date: 01/07/2026

The Rothmore Group Pty Ltd ("The Rothmore Group", "we", "our", or "us") is committed to protecting your privacy and handling your personal information in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs), and any applicable legal and regulatory obligations, including anti-money laundering and counter-terrorism financing laws where applicable.

This Privacy Policy explains how we collect, hold, use and disclose personal information when you interact with our website, advertisements, onboarding forms, verification processes, and services.

1. Information We Collect

We collect personal information directly from you, automatically through our website, and through third-party service providers where necessary.

1.1 Personal Information

This includes details provided when you enquire, book a consultation, request property information, complete onboarding, or engage our services:

  • Name

  • Email address

  • Phone number

  • Current address

  • Communication preferences

  • Suburb preferences

  • Property requirements or goals

  • Buyer brief information

  • Service preferences and investment objectives

1.2 Financial, Property & Supporting Information

When relevant to buyers advocacy, property advisory, property management, or related services, we may collect:

  • Budget, borrowing capacity, and financial position, if voluntarily provided

  • Finance status, including pre-approval information

  • Property ownership details

  • Property preferences and investment requirements

  • Supporting documents, such as pre-approval letters, rental statements, contracts, or other relevant documents if supplied

  • Information provided by your broker, conveyancer, accountant, financial adviser, property manager, or other authorised representative

1.3 Identification, AML/KYC & Compliance Information

Where required for compliance, onboarding, due diligence, or anti-money laundering and counter-terrorism financing purposes, we may collect, verify, use and disclose information relating to:

  • Identity verification

  • Know Your Customer checks

  • Anti-money laundering and counter-terrorism financing checks

  • Sanctions screening

  • Politically exposed person checks

  • Source of funds and source of wealth enquiries

  • Beneficial ownership and control information

  • Company, trust, SMSF, partnership or entity-related information

  • Director, trustee, shareholder, member, controller or authorised representative information

  • Electronic verification results, reference numbers, verification reports or compliance certificates

This may include requesting identification documents such as a driver licence, passport, Medicare card, proof of address, company extracts, trust deeds, SMSF documents, finance documents, bank statements, or other supporting documents where reasonably required.

Where possible, we may rely on verification certificates, reference numbers, or electronic verification results instead of retaining unnecessary copies of raw identification documents.

1.4 Website & Technical Data

We do not collect this information personally. It is collected automatically by our website platform, analytics tools, advertising platforms, and authorised third-party service providers when you interact with our website.

This may include:

  • IP address

  • Device type

  • Browser type and version

  • Approximate location

  • Pages visited and time spent on the site

  • Clicks, scroll behaviour, and navigation patterns

  • Cookies, pixels, tags, and tracking technologies

  • Session data, traffic analytics, and performance metrics

This information is used for website optimisation, security, analytics, advertising performance, and improving your experience on our platform.

2. How We Use Your Information

We use your information for the purposes set out below.

2.1 Service Delivery

We may use your information to:

  • Respond to enquiries

  • Provide buyers advocacy, property advisory, property management support, and related services

  • Assess your suitability for our services

  • Prepare property assessments, recommendations, reports, and buyer briefs

  • Source and review property opportunities

  • Schedule consultations and outline next steps

  • Coordinate with relevant third parties involved in your property journey

2.2 Communication

We may use your information to:

  • Send updates regarding your enquiry or active service

  • Provide relevant property opportunities

  • Send administrative and service-related emails

  • Request further documents or information

  • Provide onboarding instructions

  • Send marketing or promotional communications, only where permitted or with your consent

You may opt out of marketing communications at any time.

2.3 AML/KYC, Compliance & Due Diligence

We may use your information to comply with legal, regulatory, risk management, and internal compliance obligations, including:

  • Verifying your identity

  • Conducting AML/KYC checks

  • Conducting sanctions and politically exposed person screening

  • Assessing source of funds and source of wealth where required

  • Verifying beneficial ownership and control for companies, trusts, SMSFs or other entities

  • Conducting ongoing due diligence during the client relationship

  • Preventing fraud, financial crime, identity misuse, money laundering, terrorism financing, and other unlawful activity

  • Meeting record-keeping, reporting, audit, and compliance obligations

  • Responding to lawful requests from regulators, law enforcement, courts, tribunals or government authorities

If you are acting for a company, trust, SMSF or other entity, you confirm that you have authority to provide personal information relating to directors, trustees, shareholders, members, beneficial owners, controllers, beneficiaries, authorised representatives or other relevant individuals.

2.4 Website Improvement & Analytics

We may use website and technical data to:

  • Analyse user behaviour and traffic patterns

  • Improve website performance, layout, design, and security

  • Support advertising relevance and optimisation

  • Improve our forms, landing pages, campaigns, and client experience

3. Sharing & Disclosure of Information

We do not sell, rent, or trade your personal information.

We may disclose your information where reasonably required for our services, compliance obligations, business operations, or legal requirements.

3.1 Trusted Third-Party Partners

We may disclose your information to trusted third parties involved in providing or supporting our services, including:

  • Conveyancers

  • Solicitors

  • Mortgage brokers

  • Property managers

  • Developers and project partners

  • Real estate agents

  • Building and pest inspectors

  • Valuers

  • Accountants or financial advisers, where authorised

  • Insurance providers

  • Settlement-related service providers

  • Marketing, CRM, website, automation, and cloud service providers

These parties are expected to handle your information securely and in accordance with applicable privacy and confidentiality obligations.

3.2 AML/KYC & Verification Providers

Where required, we may disclose your information to third-party AML/KYC, identity verification, document verification, sanctions screening, politically exposed person screening, fraud prevention, or compliance service providers.

You may be required to complete an electronic verification link, upload identification documents directly to a third-party provider, or provide additional supporting documents for verification.

These providers may use your information to verify your identity, complete compliance checks, confirm document authenticity, assess risk, and provide verification results to us.

3.3 Legal, Regulatory & Government Authorities

We may disclose your information where required or authorised by law, including to:

  • AUSTRAC

  • Law enforcement agencies

  • Government departments

  • Regulators

  • Courts or tribunals

  • External auditors, legal advisers or compliance advisers

Where required by AML/CTF laws, we may also be required to make reports or provide information to AUSTRAC or other relevant authorities.

In certain circumstances, the law may prevent us from telling you that a report has been made, may be made, or that particular compliance action has been taken.

3.4 Internal Business Use

Your information may be shared internally for:

  • Administration

  • Client management

  • Compliance checks

  • Quality assurance

  • Training

  • Risk management

  • Service coordination

  • Record-keeping

4. AML/KYC Checks, Consent & Client Responsibilities

By making an enquiry, completing onboarding, signing an agreement, or engaging our services, you acknowledge and consent to The Rothmore Group collecting, using, verifying and disclosing your personal information for AML/KYC, identity verification, due diligence, compliance, and risk management purposes.

You agree to provide accurate, complete and current information when requested.

You may be required to provide:

  • Identification documents

  • Proof of address

  • Finance or pre-approval information

  • Source of funds or source of wealth information

  • Entity documents for companies, trusts, SMSFs, partnerships or other structures

  • Beneficial ownership or control information

  • Any other document reasonably required for compliance or due diligence

If you do not provide the required information, if we cannot complete verification, or if information provided is false, misleading, incomplete or inconsistent, we may be unable to provide services to you.

In these circumstances, we may:

  • Delay onboarding

  • Pause active sourcing

  • Refuse to act

  • Suspend services

  • Terminate the client relationship

  • Decline to proceed with a transaction

  • Take any other action required by law or our internal compliance procedures

5. Data Storage, Security & Retention

We store personal information securely using a combination of encrypted platforms, secure servers, restricted access controls, and industry-standard safeguards.

Our security measures may include:

  • Restricted internal access

  • Encrypted data transmission

  • Secure cloud infrastructure

  • Password-protected systems

  • Access controls

  • Internal compliance procedures

  • Regular monitoring and system protection

We retain your information only for as long as reasonably necessary to:

  • Deliver services

  • Comply with legal and regulatory obligations

  • Meet AML/CTF record-keeping requirements where applicable

  • Resolve disputes

  • Maintain accurate business records

  • Support audit, compliance, insurance, tax, accounting or legal requirements

When information is no longer required, we will take reasonable steps to securely destroy, delete, de-identify or anonymise it.

6. Cookies & Website Tracking

Our website uses cookies, pixels and similar technologies to:

  • Enhance user experience

  • Analyse site performance and behaviour

  • Improve security

  • Support marketing optimisation

  • Measure advertising performance

  • Improve website forms and campaigns

This may include tools such as Google Analytics, Meta Pixel, CRM tracking, advertising pixels, or other website analytics and optimisation tools.

You may adjust your browser settings to disable cookies. However, some website functionality may be limited if cookies are disabled.

7. Access, Corrections & Your Rights

Under Australian privacy law, you may have the right to:

  • Access the personal information we hold about you

  • Request correction of inaccurate, incomplete or outdated information

  • Request deletion of your information where legally permissible

  • Withdraw consent from marketing communications

  • Ask questions about how your information is collected, used or disclosed

To exercise these rights, please email us at admin@rothmoregroup.com.

We may require proof of identity before releasing or changing information to protect your privacy and prevent unauthorised access.

Please note that some information may need to be retained where required by law, regulation, AML/CTF obligations, dispute resolution, insurance, audit, tax or legitimate business record-keeping requirements.

8. Third-Party Websites

Our website may contain links to external websites for your convenience.

We are not responsible for the privacy practices, security, content or policies of third-party websites. We encourage you to review their privacy policies before providing personal information.

9. International Data Transfers

Some of our service providers may store or process data in countries outside Australia.

Where this occurs, we take reasonable steps to ensure your information is handled securely and in accordance with Australian privacy requirements where applicable.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect:

  • Legal or regulatory changes

  • AML/CTF compliance updates

  • Business updates

  • Technology or service provider changes

  • Improvements to our privacy and information handling practices

The latest version will be available on our website with the updated effective date.

11. Contact Us

If you have any questions or concerns about this Privacy Policy, how your information is managed, or how to exercise your privacy rights, please contact:

The Rothmore Group Pty Ltd

Phone: (02) 8416 0171

Email: admin@rothmoregroup.com