Suite 8/111 High Street
Prahran VIC 3181

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03 9522 8444

Privacy Policy

This Privacy Policy was last updated on 19 January 2023.

We recognise the trust you are placing in us through your dealings with us. We do everything we can to maintain that trust. This is our personal standard. Under law, your rights to privacy are protected. The national privacy principles, the privacy act and general law place strict requirements on us to treat certain information collected as confidential.

Hamton Group Pty Ltd ACN 608 437 609 (Hamton, we, us or our) has implemented this Privacy Policy to provide information about what kinds of Personal Information we may collect or hold, how we collect, hold, use, disclose and manage that Personal Information, choices you have regarding our use of that Personal Information, and your ability to access or correct that Personal Information. If you wish to make any inquiries regarding this Privacy Policy, you can contact us in any of the ways specified in paragraph 15.

From time to time, Hamton may be related to other companies and entities (related entities). This Privacy Policy applies to the use of your Personal Information by us and by those related entities. Those related entities may also have their own privacy policies which set out additional detail or differences in their privacy practices. To the extent that those privacy policies are inconsistent with this Privacy Policy, those privacy policies will prevail over this Privacy Policy in relation to the actions of those related entities. A reference in this Privacy Policy to Hamton, we, us or our is also a reference to those related entities.

"Personal Information" is information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual or an individual who is reasonably identifiable.

The types of Personal Information we may collect about an individual will depend upon the nature of our interaction with them. Personal Information that we collect may include (but is not limited to) the following:

  1. name
  2. contact details including telephone numbers (landline and/or mobile)
  3. address (including postal address)
  4. email address
  5. information you provide to us by completing and submitting applicable online registration forms (including but not limited to residency status and postcode)
  6. information you provide to us in relation to promotions or referral campaigns (including but not limited to your interests, how you heard about Hamton or one of our projects or developments, and your relationship to any other person that referred you to us or one of our projects or developments)
  7. age and/or date of birth
  8. if you are a supplier or service provider to us, we may also collect:
    1. payment details, such as your credit card or bank account details, and
    2. your Australian Business Number (ABN)
  9. if you apply for a job or position with us, we may also collect:
    1. occupation and employment details including employment status and any previous work experience, and
    2. information from or in connection with your resume or job application, and
  10. information from social media accounts and profiles.

We collect and record Personal Information about individuals such as:

  1. our customers, potential customers and their representatives
  2. our investors and shareholders
  3. our suppliers and potential suppliers and their representatives, directors, partners, proprietors and shareholders
  4. contractors and subcontractors and potential contractors and subcontractors and their representatives in relation to providing goods and services to us, and
  5. any other person who comes into contact with Hamton

We collect your Personal Information to allow us to conduct our business functions, to provide, market and sell our products and services and for the specified purposes set out in paragraph 6. In some circumstances the collection of Personal Information may be required by law.

We may collect your Personal Information in the course of providing you with goods or services, or:

  1. when you use or buy our products or services
  2. when you provide us, or you offer or apply to supply us, with goods or services
  3. when you provide information to us in any way (including by completing a form, disclosing information over the phone or via email, or providing us a business card)
  4. when you request information about us, our products or our services
  5. when you provide feedback to us
  6. when you visit or fill in a form on our Website (see paragraph 5)
  7. when you visit premises from which we operate
  8. when you (or your employer) provide that information to us in the course of conducting or administering our relationship with you, or when you are carrying out activities in connection with our operations
  9. when you submit a job application to us,
  10. when you otherwise contact us by telephone, fax, email, social media, post or in person, or
  11. where we are otherwise required or authorised by law to do so.

Generally, when providing our products and services, dealing with our personnel, or obtaining goods and services from our service providers, suppliers or contractors, we collect Personal Information directly from the relevant individual where reasonable and practicable.

We may also collect Personal Information about you from third parties and other sources such as:

  1. your nominated representatives (eg spouse, accountant, power of attorney, brokers and other professional advisors)
  2. third parties involved or associated with projects or developments we manage (such as Hamton Hostplus JVMV Pty Ltd in respect of the staged, mixed use development known as Moonee Valley Park, and our third party sales agents if you speak with those agents and indicate an interest in one of our projects or developments)
  3. third party software service providers who provide software and services that monitor website visits and online activity to report on sales leads and conversions from social channels, online ads, SEO efforts and referrals
  4. publicly available sources of information, or
  5. related entities, companies and businesses of Hamton,

but we will only collect your Personal Information in this way if it is unreasonable or impracticable to collect this information directly from you or if we are otherwise permitted to do so.

Although our provision of products and services generally does not require the collection of sensitive information, if the Personal Information we collect includes sensitive information, including health information, we will ask for your consent to collect sensitive information, unless the law allows us to collect it without your consent.

Where we engage with you multiple times over a short period in relation to the same matter, we may not provide you with a separate notice about privacy each time we engage with you.

If you choose not to provide your Personal Information to us for the purposes set out in this Privacy Policy, or if we do not or are unable to collect the Personal Information we require, we may not be able to provide you with requested information, products or services, or to effectively conduct our relationship with you.

Personal Information may be collected by us and by our third party service providers who assist us in operating our website at, including its subdomains and any other website we operate from time to time (collectively the Website).

We may use various technological methods from time to time to track the visiting patterns of individuals accessing our Website, including but not limited to the methods set out in this paragraph 5.

We use Google Analytics to help analyse how you use our Website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users' computers. The information generated is used to create reports about the use of our Website. Google will store this information.

If you do not want your Website visit data reported by Google Analytics, you can install the Google Analytics opt-out browser add-on. For more details on installing and uninstalling the add-on, please visit the Google Analytics opt-out page at

When you read, browse or download information from our Website, we or our internet service provider may also collect information such as the date, time and duration of a visit, the pages accessed, the IP address of your computer, the name of the domain from which you access the internet, the internet address of the website from which you linked directly to our site, and any information downloaded. This information may be used for purposes including statistical, reporting and website administration, maintenance and improvement purposes.

We may also use software provided by third parties that monitors website visitors' interactions with our Website, including from initial Website visit and registration (if applicable), properties looked at, how often a visitor returns to view those properties, and what platform visitors were directed to our Website from (e.g. social channels, online ads, SEO efforts or referrals), and that generates information about a specific visitor's propensity to purchase one of our properties. We may combine this with Personal Information we have collected about a Website visitor.

We use network advertisers to serve advertisements on unaffiliated websites or other media (e.g. social networking platforms). This enables us and network advertisers to target advertisements to you for products and services in which you might be interested. Ad network providers, advertisers, sponsors, and/or traffic measurement services may use pixels, cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs, and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These pixels, cookies and other technologies are governed by each entity’s specific privacy policy, not this Privacy Policy. We may provide these advertisers with information, including Personal Information, about you.

In accordance with applicable law, we may disclose certain information (such as your email address) to Facebook Custom Audiences (for more information on Facebook Custom Audiences click here or to opt-out, go to the Facebook ad preferences page) - so that we can better target ads and content to you and others with similar interests on other websites or media (Custom Audiences). We may also work with other ad networks and marketing platforms that enable us and other participants to target ads to Custom Audiences submitted by us and others. You may also control how Facebook and other ad networks display certain ads to you, as explained further in their respective privacy policies or by using the opt-outs described below.

Cookies may also be used for other purposes on our Website.

You may be able to opt out of many ad networks. For example, you may go to the Digital Advertising Alliance (DAA) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (NAI) Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members.

Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Website or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e. contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on a consumer choice website, your opt out may not be effective

Our Website may use 'cookies' from time to time. Cookies are small text files that are transferred to a user's computer hard drive by a website for the purpose of storing information about a user's identity, browser type or website visiting patterns. Cookies may be used on our Website to monitor web traffic, for example the time of visit, pages visited and some system information about the type of computer being used. We use this information to enhance the content and services offered on our Website.

Cookies are sometimes also used to collect information about what pages you visit and the type of software you are using. If you access our Website or click-through to our Website from a link in an email we send you, a cookie may be downloaded onto your computer's hard drive.

Cookies may also be used for other purposes on our Website.

You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences.

If you disable the use of cookies on your web browser or remove or reject specific cookies from our Website or linked sites then you may not be able to gain access to all of the content and facilities in those websites.

Some of the content on our Website may include applications made available by third parties, such as social media buttons or links that allow you to share content or links to our Website through the relevant third party platforms. These third party applications themselves may facilitate collection of information by those third parties, through your interaction with the applications and sometimes even if you do not interact directly with them. We are not responsible for the technical operation of these applications or the collection and use practices of the relevant third parties. Please visit the relevant third party websites to understand their privacy practices and options they may make available to you in relation to their collection of your Personal Information.

We use the Personal Information we collect about you for our business functions and activities, in order to operate our business efficiently, and to market our products and services for the benefit of our customers.

We may collect, hold and use your Personal Information:

  1. to identify and communicate with you
  2. to enable us to provide you with requested information, products or services
  3. to assist in providing you with relevant consumer information and to notify you of products and special offers that may be of interest to you, such as information and marketing about our projects and developments, or projects and developments we manage, market or promote that we think you may be interested in hearing about
  4. to manage our relationship with you and to contact you for follow up purposes
  5. to otherwise assist customers by providing them with information and support
  6. to collect and process payments
  7. to help us to manage and enhance products or services we provide to you
  8. to help us to manage and enhance goods and services we procure from our suppliers and subcontractors
  9. to personalise and customise your experiences on our Website
  10. to promote and market our products and services to you
  11. to provide you with information that we believe may be of interest to you or that you may be interested in receiving, including advertising material, regarding us, our projects/developments, and our business partners
  12. to conduct research for the purposes of improving existing products or services or creating new products or services
  13. to help us research the needs of our customers to enable us to market our products and services with a better understanding of your needs and the needs of customers generally
  14. to verify and update Personal Information held by us
  15. to protect you and us from fraud
  16. to provide for the safety and security of workers and onsite visitors
  17. to help us manage and improve our business operations
  18. for business support purposes including maintenance, backup and audit
  19. to process any job application submitted by you
  20. to respond to any queries or complaints you may have
  21. to investigate, review, mitigate risks associated with, and inform you of, a data or other security breach involving your personal information, or
  22. to comply with our statutory and legal obligations.

We may aggregate Personal Information for reporting, statistical and data analysis purposes, and for business, product and service improvement purposes. This allows us to better inform ourselves and anticipate our customers' preferences and requirements, and to monitor and improve the effectiveness of our business, products and services. We may also de-identify information for ongoing use and inclusion in such aggregated databases or reports.

We reserve the right at all times to monitor, review, retain, and/or disclose any information as necessary to satisfy any applicable law, but we have no obligation to monitor the use of the Website or to retain the content of any user session.

You consent to us using your Personal Information in the above ways and as set out in this Privacy Policy.

We may otherwise collect, use or disclose your Personal Information where the collection, use or disclosure is:

  1. in accordance with this Privacy Policy or any agreement you enter into with us
  2. required or authorised by law, including without limitation the Australian Privacy Principles under the Privacy Act 1988 (Cth), or
  3. for which you have otherwise provided your express or implied consent.

Hamton may disclose, or provide access to, your Personal Information to third parties in connection with the purposes described in paragraph 6. Depending on the circumstances and the nature of your engagement with us, we may disclose your Personal Information to our related entities, to third parties that provide products and services to us or through us, or to other third parties (such as your referee(s) in connection with a job application you have submitted).

We may also disclose your Personal Information to:

  1. any of Hamton's internal divisions, business units or departments
  2. third parties involved or associated with building, managing, promoting or selling properties in the developments or projects we develop, manage, market or promote, including without limitation 360 Property Group, Hamton Real Estate, Hamton Hostplus JVMV Pty Ltd, and Moonee Valley Racing Club Inc (in respect of the staged, mixed use development known as Moonee Valley Park), where you have contacted us about or expressed an interest in relation to a relevant project or development
  3. your nominated representatives
  4. other organisations or individuals who we engage to assist us in providing products and services to you
  5. professional service providers and advisors who perform functions on our behalf, such as lawyers
  6. representatives, agents or contractors who are appointed by us in the ordinary operation of our business to assist us in providing goods or services or administering our business (such as for data storage or processing, printing, mailing, marketing, planning and product or service development)
  7. third party advertising service providers and digital advertising platforms such as Meta (Facebook), in order to better understand our audience profiles, tailor advertising strategies and deliver ads to audiences more likely to be interested in receiving them
  8. banks, lenders, valuers, insurers, brokers, auditors, business consultants and IT service providers, and
  9. Government, regulatory authorities and other organisations as required or authorised by law.

We may disclose your Personal Information to any of Hamton's related entities for the purposes of facilitating our services to you and for any other purpose contemplated by this Privacy Policy.

We may also disclose your Personal Information to our Website host or software application providers in certain limited circumstances, for example when our Website experiences a technical problem or to ensure that it operates in an effective and secure manner.

As we continue to develop our business, we may buy, merge or partner with other companies or organisations, and in so doing, acquire customer Personal Information. In such transactions, Personal Information may be among the transferred assets. Similarly, in the event that a portion or substantially all of our business or assets are sold or transferred to a third party, we may also disclose certain information including your Personal Information to a purchaser or potential purchaser in connection with the sale or potential sale of us, our business or any of our assets, including in insolvency.

Generally, our IT servers are located in and store data onshore within Australia, and we do not send or disclose your Personal Information to overseas recipients (i.e. outside of Australia). However, in certain circumstances some of your Personal Information may from time to time be disclosed, transferred, stored, processed or used overseas by us, or by our third party service providers. This may happen if:

  1. we outsource certain activities overseas
  2. transactions, information, services or products have an overseas connection, or
  3. our computer systems including IT servers are located overseas.

You consent to the collection, use, storage, and processing of your Personal Information outside of Australia as set out in this Privacy Policy.

In particular, your Personal Information may be disclosed to third parties in countries in which those parties or their, or our, computer systems may be located from time to time, where it may be used for the purposes described in this Privacy Policy.

We may collect, use and disclose your Personal Information for other purposes not listed in this Privacy Policy. If we do so, we will make it known to you at the time we collect or use your Personal Information.

If you do not want to receive marketing information from us or if you want to stop receiving telemarketing, you can unsubscribe in any of the following ways:

  1. clicking on the 'Unsubscribe' or subscription preferences link in a direct marketing email that you have received from us , or
  2. contacting us using the contact details specified in paragraph 15.

If you provide your consent to receiving direct marketing from third parties, we will provide them with your Personal Information to enable them to identify opportunities and send information and advertising material to you. The Personal Information we provide may include your name and contact details, as well as other information relevant to the third party's goods or services. Our disclosure of such Personal Information may be for the purposes of enabling the relevant third party to direct market to you on their own behalf, not on our behalf. You can request that we stop sharing your information with third parties for these purposes at any time by contacting us using the details specified in paragraph 15.

To opt out of receiving direct marketing from third parties with whom we have already shared your Personal Information in accordance with this paragraph, you may need to contact those third parties directly if you'd like to no longer receive direct marketing from each of them.

We aim to keep your Personal Information secure. Any Personal Information that is collected via our Website or which is held on our computer systems is stored on servers located in Australia with access only available by password.

If we find that we no longer require or have no further need for your Personal Information we may de-identify it or remove it from our systems and destroy all record of it. However we may retain information in a form that does not allow you to be identified from that information, for example for ongoing data analysis.

You are generally entitled to access Personal Information that we hold about you. If you request access to your Personal Information, in ordinary circumstances we will give you full access to your Personal Information. Depending on the nature of the request, Hamton may charge for providing access to this information, however such charge will not be excessive. However, there may be some legal or administrative reasons to deny access. If we refuse your request to access your Personal Information, we will provide you with reasons for the refusal where we are required by law to give those reasons.

A request for access can be made by contacting Hamton in any of the ways specified in paragraph 15.

We take all reasonable steps to ensure that any Personal Information we collect and use is accurate, complete and up-to-date. To assist us in this, you need to provide true, accurate, current and complete information about yourself as requested, and properly update the information provided to us to keep it true, accurate, current and complete.

Please contact us in any of the ways specified in paragraph 15 if you believe that the Personal Information is inaccurate, incomplete or out of date, and we will use all reasonable efforts to correct the information.

It would assist us to ensure we properly understand your request, and allow us to respond more promptly, if requests are made in writing and include as much detail as possible.

If you feel that we have not respected your privacy or that we have conducted ourselves inconsistently with this Privacy Policy or breached your privacy rights in any way, please contact Hamton in any of the ways specified in paragraph 15 and advise us as soon as possible. We will consider or investigate your queries and privacy complaints within a reasonable period of time and we will generally endeavour to respond to your complaints within 14 days, though this will depend on the complexity of the complaint.

It would assist us to respond to your complaint promptly if it is made in writing. Please detail information relevant to your complaint.

We will notify you of the outcome of our investigation.

It is our intention to use our best endeavours to resolve any complaint to your satisfaction. However, if you are unhappy with our response, you may contact the Office of the Australian Information Commissioner who may investigate your complaint further.

We may, from time to time, review and update this Privacy Policy, including to take into account new laws, regulations, practices and technology. All Personal Information held by us will be governed by our most recent Privacy Policy, posted on our Website at: Any changes to this Privacy Policy may be advised to you by updating this page on our Website. We will aim to provide reasonable advance notice of such changes though this may not always be possible depending on the circumstances. We encourage you to check this page from time to time for any changes.

If you:

  1. have a query or concern about this Privacy Policy or our Personal Information handling processes
  2. wish to make a complaint in relation to a breach of your privacy
  3. would like to access your Personal Information held by us
  4. would like to update or correct your Personal Information held by us, or
  5. would like to opt out of direct marketing,

please contact our office in any of the following ways:

Email Address:
Mailing Address:PO Box 2022 Prahran VIC 3181
Phone: 03 9522 8444.


The information on this website is given for general information purposes only. It should not be relied on as a substitute for legal, financial, real estate or other expert advice and must not be relied on as a basis for any decision you make concerning any featured property. You must make your own enquiries to verify the information before acting on it; including material on property particulars. Some of the images contained on this website are indicative only. You must not rely on these images for any reason. The information is subject to change at any time without notice and to the extent permitted by law, is provided “as is” without representation or warranty of any kind as to the accuracy, completeness or suitability for a particular purpose.