Last updated: 14 August 2026

1. About this policy

The Royal Apartments website at royalapartments.com.au is operated by Palumbo Pty Ltd (“Palumbo”, “we”, “us” or “our”), the developer of Royal Apartments.

We respect your privacy and are committed to handling personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

This policy explains how we collect, hold, use and disclose personal information associated with Royal Apartments and this website.

2. Personal information we collect

The personal information we collect may include:

• your name, address, telephone number and email address;

• information submitted through an enquiry, registration or appointment form;

• your apartment preferences, budget, purchasing timeframe and other property requirements;

• records of your communications and interactions with us, our sales representatives or marketing partners;

• information provided when visiting the Royal Apartments display suite, attending an event or requesting information;

• information connected with an expression of interest, reservation or proposed purchase;

• information received through property websites, advertising platforms, social media, referral partners or other third parties;

• your IP address, browser type, device information, approximate location, referring website, pages viewed and the date and time of your visit; and

• information collected through cookies, analytics tools, advertising pixels and similar technologies.

You may browse most areas of the Royal Apartments website without identifying yourself. However, we may be unable to respond to an enquiry, provide requested information or arrange an appointment if you do not provide certain details.

We do not generally seek to collect sensitive information. If sensitive information is required, we will only collect it with your consent or where permitted or required by law.

3. How we collect personal information

We generally collect personal information directly from you when you:

• submit an enquiry or registration form;

• request a brochure, price guide, floorplan or information pack;

• book or attend an appointment at the display suite;

• contact us by telephone, email, website, social media or in person;

• attend a Royal Apartments event;

• lodge an expression of interest or proceed with a property transaction; or

• otherwise interact with Palumbo, the Royal Apartments sales team or our representatives.

We may also collect information from:

• our appointed sales agents, project marketers and marketing agencies;

• property listing websites and lead-generation platforms;

• social media and digital advertising platforms;

• referral partners and professional advisers;

• publicly available sources; and

• cookies, analytics services and advertising technologies used on our website.

4. Why we collect and use personal information

We may collect, hold, use and disclose personal information to:

• respond to enquiries about Royal Apartments;

• provide brochures, pricing, floorplans, availability and other project information;

• arrange display suite appointments and follow-up communications;

• understand your property preferences and assist you in identifying suitable residences;

• administer expressions of interest, reservations and property transactions;

• maintain our customer relationship management system;

• send project news, availability updates, invitations and other marketing communications where permitted;

• measure and improve the performance of our website and advertising;

• personalise website content and digital advertising;

• conduct research, reporting and business analysis;

• maintain the security and functionality of our website and systems;

• manage our business relationships with suppliers, consultants and professional advisers;

• comply with legal, regulatory and contractual obligations; and

• protect our rights, property and legitimate business interests.

We may combine information collected through different channels where it relates to the same person or enquiry.

5. Disclosure of personal information

We may disclose personal information where reasonably necessary to:

• Palumbo employees and related entities;

• the Royal Apartments sales team, appointed sales agents and project marketers;

• marketing, advertising and communications agencies working on Royal Apartments;

• customer relationship management providers, including HubSpot;

• website hosting, information technology, cloud storage and security providers;

• analytics and advertising providers, including Google and Meta;

• property listing and lead-management platforms;

• consultants, contractors, professional advisers, insurers, auditors and financiers;

• government bodies, regulators, law-enforcement agencies or other parties where required or authorised by law; and

• another organisation as part of a proposed merger, acquisition, restructure or transfer of the Royal Apartments project or Palumbo’s business.

We do not sell or rent personal information to third parties.

6. Direct marketing

Where permitted by law, we may use your personal information to send you information about Royal Apartments, available residences, display suite appointments, events, project updates and related opportunities.

Communications may be sent by email, telephone, SMS, post or online advertising.

You can opt out at any time by:

• selecting the unsubscribe link in an email;

• following the opt-out instructions in an SMS;

• advising our team during a telephone call; or

• contacting the Palumbo Privacy Officer using the details below.

There is no charge for opting out. We may retain limited information on a suppression list to ensure we honour your request.

7. Cookies, analytics and advertising technologies

The Royal Apartments website may use cookies, tracking pixels and similar technologies to:

• operate and secure the website;

• remember preferences;

• understand how visitors find and use the website;

• measure enquiries and advertising performance;

• improve website content and functionality; and

• deliver or measure relevant advertising on other websites and platforms.

These technologies may collect information such as your IP address, device and browser details, general location, referring source, pages viewed and actions taken on the website.

Third-party services used may include Google Analytics, Google Ads, Meta advertising tools and HubSpot. These providers may combine information collected through our website with information they hold from other sources, subject to their own privacy policies.

You can manage or disable cookies through your browser settings and, where provided, the website’s cookie controls. Disabling some cookies may affect website functionality. You can also adjust advertising preferences through the relevant Google and Meta privacy settings.

8. Overseas disclosure and storage

Some service providers used in connection with Royal Apartments may store or process personal information outside Australia, including in the United States and other countries in which those providers or their subcontractors operate.

Where personal information is disclosed overseas, we will take reasonable steps to ensure it is handled in accordance with applicable Australian privacy requirements.

9. Security and retention

We take reasonable technical and organisational steps to protect personal information from misuse, interference, loss and unauthorised access, modification or disclosure.

Personal information may be held electronically or in physical records by Palumbo or our authorised service providers.

No internet transmission or electronic storage system is completely secure. While we take reasonable precautions, we cannot guarantee the security of information transmitted through the website.

We retain personal information only for as long as reasonably required for the purpose for which it was collected, to meet legal and business requirements or to resolve disputes. When information is no longer required, we will take reasonable steps to securely destroy or permanently de-identify it.

10. Automated tools

We may use automated tools to organise enquiries, segment audiences, measure engagement and assist our team in tailoring follow-up communications.

We do not currently use personal information to make solely automated decisions that could reasonably be expected to significantly affect an individual’s rights or interests. If this changes, we will update this policy and provide any information required by law.

11. Accessing or correcting your personal information

You may request access to personal information we hold about you or ask us to correct information that is inaccurate, incomplete or out of date.

To make a request, contact the Palumbo Privacy Officer using the details below. We may need to verify your identity before providing access or making a correction.

We will respond within a reasonable period. In some circumstances, access may be limited or refused where permitted by law. If this occurs, we will explain the reason for our decision where legally permitted.

12. Privacy complaints

If you believe we have breached your privacy or have concerns about how your personal information has been handled, please contact the Palumbo Privacy Officer.

Please provide sufficient information for us to understand and investigate your concern. We will acknowledge and investigate your complaint and aim to respond within a reasonable timeframe.

If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner at oaic.gov.au.

13. Third-party websites

The Royal Apartments website may contain links to external websites and services. We are not responsible for the privacy practices or content of those third parties. We recommend reviewing their privacy policies before providing personal information.

14. Changes to this policy

We may amend this Privacy Policy from time to time to reflect changes to our practices, technology or legal obligations.

The current version will be published on the Royal Apartments website and will show the date it was last updated.

15. Contact us

For privacy enquiries, access or correction requests, complaints or requests to opt out of direct marketing, contact:

The Privacy Officer
Palumbo Pty Ltd
55 Stanbel Road
Salisbury Plain SA 5109

Telephone: (08) 8209 6100
Email: info@palumbo.com.au