1. Introduction
Rook Partners Capital Management Pty Limited (ABN 49 691 500 615, CAR 001319195) (“RPCM”, “we”, “us”, or “our”) is committed to protecting your privacy and handling your personal information in a transparent and secure manner.
RPCM is a corporate authorised representative of Bolt Capital Pty Ltd (ABN 37 636 202 223, AFSL 522572) (“Bolt Capital”) and provides financial services to wholesale clients only.
This Privacy Policy outlines how we collect, use, disclose and manage personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).
2. What Personal Information We Collect
We may collect personal information necessary to provide our services, including:
- Full name and contact details (email, phone, address)
- Date of birth and identification information
- Financial information (including investment preferences and capacity)
- Company or trust information (where applicable)
- Records of communications with us
- Website usage data (via cookies and analytics tools)
We only collect personal information that is reasonably necessary for our business functions and activities.
3. How We Collect Personal Information
We may collect personal information:
- Directly from you (e.g. via enquiries, forms, investor onboarding, or communications)
- Through our website (including contact forms and analytics tools)
- From third parties such as:
- Professional advisers (e.g. accountants, lawyers)
- Referrers or intermediaries
- Registry or administration service providers
- From publicly available sources, where appropriate
4. Why We Collect and Use Your Information
We collect and use your personal information to:
- Provide capital management and investment-related services
- Assess eligibility as a wholesale client
- Manage investor relationships and communications
- Administer investments, trusts and fund structures
- Comply with legal and regulatory obligations
- Improve our services and website experience
RPCM does not provide services to retail clients, and personal information is collected only in connection with wholesale client services.
5. Disclosure of Personal Information
We may disclose your personal information to:
- Bolt Capital Pty Ltd and related service providers
- Trustees, custodians, registry and fund administration providers
- Professional advisers (legal, accounting, tax)
- Technology and platform providers (including investor portals)
- Government and regulatory authorities where required by law
All third parties are required to handle personal information in accordance with applicable privacy laws.
6. Data Security
We take reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure. These measures include:
- Secure systems and access controls
- Encryption and secure data storage
- Use of reputable third-party service providers
- Internal policies and confidentiality obligations
7. Cookies and Website Analytics
Our website may use cookies and analytics tools to:
- Understand how users interact with our website
- Improve functionality and user experience
- Support marketing and performance insights
You can adjust your browser settings to refuse cookies; this may affect website functionality.
8. Access and Correction
You may request access to the personal information we hold about you and request corrections where necessary.
To do so, please contact us using the details below. We will respond within a reasonable timeframe.
9. Complaints
If you believe your privacy has been breached, you can contact us using the details below.
We will investigate your complaint and respond promptly. If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC).
10. Overseas Disclosure
In some cases, your personal information may be disclosed to service providers located overseas (for example, technology or data hosting providers).
Where this occurs, we take reasonable steps to ensure those providers comply with Australian privacy standards.
11. Changes to This Policy
We may update this Privacy Policy from time to time. The latest version will always be available on our website.
12. Contact Us
If you have any questions about this Privacy Policy or how your information is handled, please contact:
Rook Partners Capital Management Pty Limited
Email: investors@rookpartners.com
Phone: +61 2 8067 0855
Website: rookpartners.com
RPCM is authorised to provide financial services to wholesale clients only. This website and its content are not intended for retail clients.