Castray Capital Pty Ltd ABN 70 613 076 930, (Castray, we and us) is committed to protecting your personal information and privacy. This Privacy Policy explains how Castray collects and handles personal information in the course of its business operations including through its website at (website).

Castray is bound by the Privacy Act 1988 and the Australian Privacy Principles contained in the Privacy Act. Castray also complies with the Spam Act 2003 (Cth) and the Do Not Call Register Act 2006 (Cth).

Regardless of how personal information is provided (electronic, mail, face-to-face or any other manner), Castray strives to honour people’s privacy preferences in accordance with this Privacy Policy (as detailed below).

By providing personal information to us, you consent to us collecting, holding, using and disclosing that personal information in accordance with and for the purposes specified in this Privacy Policy and any other arrangements that apply between us. We may change our Privacy Policy from time to time by publishing changes to it on our website. We encourage you to check our website periodically to ensure that you are aware of our current Privacy Policy.

You are not required to provide personal information to us. However, if you do not provide us with all the information we request, we may not be able to provide you with our services, our services may be affected or we may not be able to respond to you

What kinds of personal information do we collect?

The types of personal information that Castray collects will depend on your dealings with us – whether as an employee, website user, service provider or as a result of your organisation’s relationship with us. The usual types of personal information that Castray collects includes:

  • your name, gender, date of birth, phone numbers, professional title, contact details (including email and postal address) and/or employer;
  • any other information you provide us in any form you may have submitted to us, or in other forms of interaction with you – for example, identification verification information, including photographic information from documents including your birth certificate, passport; driver’s licence, pension card, citizenship certificate, Medicare card and/or utilities notices;
  • information about your use of our websites, services and engagement generally with us;
  • your employment history, education, social background, financial position, income and financial plans;
  • regulatory accreditation information; and
  • your financial and tax information, including bank account or credit card information, assets, liabilities, share portfolios, credit history and/or references, tax file numbers and purpose of investment.

Castray will not ordinarily collect sensitive personal information about you unless it is strictly necessary for it to do so for the purpose of providing its services or is required by law. For the purpose of this Policy, ‘sensitive personal information’ includes information about your racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal
record, health information, genetic information, biometric information or biometric templates.

Castray usually collects personal information directly from you (i.e. when you contact or communicate with us and/or give us feedback directly (by phone, in person and/or by email), when you become a client, apply for employment, request our services and/or when you provide information via meetings or other communication methods).

Castray may also collect personal information about you from business parties and third parties, such as anyone you have authorised us to deal with on your behalf.

Why does Castray collect personal information?

We collect your personal information for the following purposes:

  • to enable you to access and use our services and website;
  • to keep in touch with you for business development and networking purposes;
  • to arrange and attend relevant events and/or support the delivery and distribution of our products;
  • to operate, protect, improve and optimise our business services;
  • to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
  • with your consent (if required by applicable law), to keep you up to date about our products and services and events we believe may be of interest to you;
  • to protect our rights and interests, comply with regulatory and/or legal obligations (for example, the anti-money laundering and counter-terrorism laws, the Corporations Act and applicable taxation laws), resolve any complaints or disputes, and enforce our agreements with third parties;
  • sending marketing and promotional material and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting;
  • responding to questions and obtaining feedback;
  • internal reporting; and
  • to consider and process employment applications or carry out employment obligations.

To whom do we disclose your personal information (including overseas)?

We may disclose personal information for the purposes described in this privacy policy to:

  • our employees, contractors, advisers and related companies in the Castray Group,
  • third party suppliers, service providers and distributors;
  • payment systems operators (e.g. banks, stockbrokers, merchants receiving card payments);
  • anyone to whom our assets or businesses (or any part of them) are transferred;
  • specific third parties authorised by you to receive information held by us; and/or
  • other persons, including banks, stockbrokers, share registrars, custodians, auditors, insurers, third party administrators, government agencies, regulatory bodies and law enforcement agencies, pursuant to a lawful process or as required or authorised by law.

We may disclose personal information outside of Australia to contractors, advisers and our related companies in the Castray Group and service providers who are located outside of Australia including, for
example, cloud services providers, banks and security registrars. Before disclosing any personal information to an overseas recipient, Castray will take reasonable steps to ensure the overseas recipient is bound by a substantially similar privacy regime or you otherwise consent to the overseas disclosure or
the disclosure is required or authorised by law.

Security of your personal information?

We respect the personal information you have entrusted to us and we have a responsibility to manage and take reasonable steps to protect the personal information that we hold about you from misuse, interference or loss and from unauthorised access, modification and/or disclosure.

We may hold your personal information in either electronic or hard copy (paper) form. We may retain your personal information in our computer systems and databases, and in our physical files.

Castray uses technologies and processes such as access control procedures, network firewalls, encryption, password protected databases and physical security measures to protect your personal information. However, the confidentiality of any communication by email cannot be guaranteed and we
are not responsible for the security of information transmitted via the internet.

We keep your personal information for only as long as is necessary for the purpose for which we collected it or where otherwise required or authorised by applicable legal obligations, in accordance with our applicable policies.

What happens if personal information security is breached?

We implement corrective plans if our security measures are breached or your personal information is lost or inadvertently accessed by an unauthorised person. All privacy breaches that have resulted in or are likely to result in serious harm to you are ‘eligible data breaches’ which must be reported by Castray to the Office of the Australian Information Commissioner and to you.

Access to and correction of your personal information

You have the right to access the personal information that we hold about you and you can also ask us to correct your personal information by contacting our Privacy Officer (details below). The Privacy Officer will promptly investigate your privacy enquiry and provide you with appropriate answers where required.

We may first need to verify your identity before giving access or correcting your information.

Castray will give access to your personal information (unless an exception in the Privacy Act applies) and we will make the requested changes (unless we do not agree that the information is incorrect). If we refuse to give you access to all or part of the information you have requested or to make the corrections
you have requested, we will write to you and explain why.

Castray may charge you its reasonable costs associated with providing you with access to your personal information.

Direct marketing

We and/or our business partners may send you direct marketing communications and information about our services. This may take the form of emails, SMS, mail or other forms of communication, in accordance with the Privacy Act and the SPAM Act 2003 (Cth). You may opt-out of receiving marketing or other materials from us by contacting us using the details set out below or by using the opt-out facilities provided (e.g. an unsubscribe link).

Links to other websites

The Castray website may contain links to other sites. Other sites may also have links to the Castray website. In either case, Castray is not responsible for the content, privacy practices or business practices of any website or company except its own.

Use of Cookies

We collect information about you when you use and access our website through our use of cookies.

Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but our website may not work as intended if you do so.

While we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer, the name of your internet service provider, the
website from which you visit us, the websites you actually visit, and the date and length of your visit.

We may also use ‘cookies’ or other similar tracking technologies on our website as follows:

  • first party/session cookies to support our website functions such as page navigation and access to secure areas of the website. The website cannot function properly without these cookies.
  • track your website usage and remember your preferences; and
  • to personalise content and advertisements, to provide social media features and/or to analyse our traffic.

We also share information about your use of our site with our social media, advertising and analytics partners who may combine it with other information that you have provided to them or that they have collected from your use of their services.

Complaints and questions

If you have questions about how Castray handles your personal information, or if you have a complaint about Castray’s information handling practices, you can contact the Castray’s Privacy Officer (details below).

In particular, if you wish to make a complaint about how Castray has handled your personal information, you should put your complaint in writing to our Privacy Officer.

Castray will acknowledge receipt of your complaint, verify your identity and will investigate and respond within a reasonable time of receiving a complaint from you. If you are not satisfied with the decision, you can contact us to discuss your concerns. If the complaint is unresolved, you can contact the Office of the Australian Information Commission (OAIC) to make a complaint. Contact details can be found at the OAIC’s website:

Contact details for our Privacy Officers

Margot Huxley
Castray Capital Pty Ltd
Telephone: +61 3 6220 3600

Adam Bold
CRS Certus
Telephone: +61 3 9663 4456

Additional information

Further information on privacy in Australia may be obtained by visiting the website of the OAIC at: We regularly review the OAIC website to keep informed of issues and developments in privacy law and changing legal obligations.

This policy is effective: July 2018