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Security report for cromwell.com.au

Cromwell Funds Management · Real Estate · Australia

Medium risk. 6 critical or high findings in Security headers, GDPR outside view and 1 other check.

Security score

65/100

Risk levelMedium

0–100, higher is better. How it is calculated

Cromwell Funds Management is a well-established Australian property investment management company offering a diversified suite of funds including unlisted property trusts, ASX-listed REITs, and international securities. The company targets investors and financial advisers seeking income-producing commercial property investments. The website reflects a mature digital presence with professional design, clear navigation, and comprehensive content tailored to its audience. Technically, the site is built on WordPress with modern analytics and marketing integrations, optimized for mobile and accessibility. Security posture is strong with HTTPS, CAPTCHA-protected forms, and no visible vulnerabilities, though some security headers could be improved. Privacy compliance is evident with clear policies and consent mechanisms. Overall, Cromwell demonstrates high business credibility and digital maturity.

Scanned

NIS2 and GDPR posture

GDPR outside view
58/ 100 · Medium
Checks completed
7of 7

NIS2 Art. 21(2)

  1. (a) Risk analysis and security policies: Not visible from outside
  2. (b) Incident handling: One indicator
  3. (c) Business continuity, backups and crisis management: Not visible from outside
  4. (d) Supply chain security: Not visible from outside
  5. (e) Secure acquisition, development and maintenance, including vulnerability handling: Partly checked
  6. (f) Assessing the effectiveness of security measures: Not visible from outside
  7. (g) Cyber hygiene and security training: Not visible from outside
  8. (h) Cryptography and encryption: Partly checked
  9. (i) HR security, access control and asset management: One indicator
  10. (j) Multi-factor authentication and secured communications: Not visible from outside

This scan rated NIS2 with an earlier keyword method that is no longer shown; rescan for the per-article view. Risk management, continuity, supply chain, training, MFA, management oversight (Art. 20) and incident reporting (Art. 23) need internal evidence, and Guard cannot tell whether NIS2 applies to this organisation.

GDPR is indicative only, based on publicly visible signals: Articles 7, 12, 13 and 32 of Regulation (EU) 2016/679 and Article 5(3) of the ePrivacy Directive. Not a certification or legal assessment.

Priority findings

6 findings rated critical or high. Fix these first.

  1. Security headers

    Security headers are instructions your web server sends to every visitor’s browser. Missing ones leave visitors more exposed to attacks such as clickjacking and injected scripts.

    • High

      Missing Strict-Transport-Security header

      Forces HTTPS connections

      What to do: Add "Strict-Transport-Security: max-age=31536000; includeSubDomains; preload"

      • CWE-319
      • OWASP A04:2025
      • ASVS V3.4.1
    • High

      Missing X-Frame-Options header

      Prevents clickjacking attacks

      What to do: Add "X-Frame-Options: DENY" or "X-Frame-Options: SAMEORIGIN"

    • High

      Missing Content-Security-Policy header

      Controls resources the browser is allowed to load

      What to do: Implement a Content-Security-Policy appropriate for your application

      • ASVS V3.4.3
      • OWASP Secure Headers: OWASP Secure Headers Project recommends Content-Security-Policy: default-src 'self'; form-action 'self'; base-uri 'self'; object-src 'none';…

  2. GDPR outside view

    These are the privacy signals visitors and data protection authorities look for under GDPR.

    • High

      No Cookie Policy found

      GDPR requires clear information about cookie usage

      What to do: Add a dedicated cookie policy explaining cookie usage and purposes

    • High

      No Cookie Consent Banner found

      GDPR requires explicit consent for non-essential cookies

      What to do: Implement a cookie consent banner that appears on first visit

Need hands-on remediation? Email guard@offseq.com

Keep watching cromwell.com.au

This scan found 24 issues across 6 checks. Monitoring re-runs those checks daily, emails you when something material changes and records each fix, so you can show progress.

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  • TLS certificates and expiry
  • DNS records
  • SPF, DKIM and DMARC
  • Security headers
  • GDPR and NIS2 posture
  • Exposed services
  • Third-party trackers
  • Security score drift

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Results by check

Each check with its score, findings and the evidence it collected.

How this score is calculated

The security score runs 0–100, higher is better. It is the plain average of the security checks that completed in this scan, each counted equally. A check that could not run is left out: it counts neither as a pass nor as a fail.

Counted in this score

SSL/TLS
75
Security headers
15
Email security
75
DNS health
65
Network security
100
GDPR outside view
58
Average
65

Not counted

  • NIS2 outside view: Re-weights evidence from the TLS, email, DNS, network and hygiene checks, so counting it would count that evidence twice. Shown on its own.
  • OffSeq Observations: An AI reading of the site, useful context but not reproducible evidence. Shown on its own.

Findings that cap the score at 49

Each of these is serious on its own, so while any is present the site cannot rate better than high risk, however good the other checks are.

  • The certificate is not trusted by browsers
  • The website is not served over HTTPS
  • A database, remote desktop, file-sharing or Telnet service is reachable from the internet
  • The page loads a script from a compromised source
  • The domain registration has expired
  • SPF authorises every server to send mail as the domain

Partial scans

When the site blocks Guard or most checks cannot run, the score covers only the checks that ran (usually DNS and email), is capped at 75 and is shown as partial, without a risk level.

Risk levels

  • Critical0–25
  • High26–49
  • Medium50–75
  • Low76–100

Technical appendix

Business context, site observations and technical notes gathered during the scan, and the standards behind each reference.

Business context

Business profile

Cromwell holds a strong market position in the Australian real estate investment sector, leveraging diversified investment products to appeal to a broad investor base. The business model focuses on wealth building through property acquisition and management, supported by a professional team and transparent communications. The company maintains a global partnership ecosystem with regional sites across Asia Pacific and Europe, enhancing its market reach. Revenue streams likely include fund management fees and advisory services. The website's content and structure indicate a focus on investor education and engagement, supporting growth and trust.

Security posture

The website exhibits a mature security posture with enforced HTTPS, use of CAPTCHA on forms to prevent automated abuse, and integration of reputable analytics and tracking tools with integrity attributes. However, explicit security headers such as Content-Security-Policy, X-Frame-Options, and X-Content-Type-Options are not visibly set, representing an area for enhancement. No exposed sensitive data or vulnerable libraries were detected. Incident response and vulnerability disclosure information are not publicly available, which is common but could be improved for transparency. Overall, the site balances security with usability effectively.

Recommendations

  1. Implement Content-Security-Policy header to mitigate XSS and data injection risks.
  2. Add X-Frame-Options header to prevent clickjacking attacks.
  3. Add X-Content-Type-Options header to prevent MIME sniffing vulnerabilities.
  4. Publish a vulnerability disclosure policy or security.txt file to improve transparency.
  5. Regularly review third-party scripts and update dependencies to minimize security risks.

Contact details published on the site

Addresses
Legal name
Cromwell Funds Management
Site observations

Automated reading of the public site. Ratings are indicative.

Business

Company
Cromwell Funds Management
Description
At Cromwell Funds Management (CFM), we aim to build investor wealth through the careful selection, acquisition and management of real income-producing commercial properties and portfolios. Our suite of funds offers access to unlisted property trusts, ASX-listed Real Estate Investment Trusts (A-REITs) and internationally listed small cap securities, providing different methods of investing in commercial property and diversifying your portfolio.
Key services
unlisted property trusts, ASX-listed Real Estate Investment Trusts, internationally listed small cap securities, investment advisory
Content quality
excellent
Branding
consistent

Technology

Stack
WordPress, Gravity Forms, Google Analytics, Google Tag Manager, Facebook Pixel, Microsoft Web Tracking
Frameworks
Bootstrap (implied by navbar classes), Yoast SEO
Platforms
WordPress CMS
Performance
moderate
Mobile
good
Accessibility
good
SEO
excellent

Security

Observed score
85/100
Good practices seen
  • HTTPS enforced
  • CAPTCHA on forms
  • No exposed sensitive data in HTML
  • Use of modern analytics and tracking scripts with integrity attributes

Analytics and tracking

Services
Google Analytics, Google Tag Manager, Facebook Pixel, LinkedIn Insight Tag, Microsoft Web Tracking
Tracking level
moderate
Privacy practices
good

Advertising

Tracking pixels
Facebook Pixel, LinkedIn Insight Tag, Microsoft Web Tracking
Marketing tools
Gravity Forms
Transparency
good

Site quality

Design
excellent
User experience
excellent
Content relevance
excellent
Navigation
excellent
Professionalism
excellent
Trustworthiness
high

Key observations

  1. Website is professionally designed and well maintained.
  2. Content is comprehensive and targeted at property investors and advisers.
  3. Multiple secure contact methods including forms with CAPTCHA.
  4. Use of modern analytics and marketing tools with privacy considerations.
  5. No signs of malicious or suspicious activity.
  6. WHOIS data is privacy protected but consistent with legitimate business practice.
Technical notes

Notes

The website is powered by WordPress CMS with Gravity Forms for data collection and integrates multiple analytics and marketing tools including Google Analytics, Google Tag Manager, Facebook Pixel, LinkedIn Insight Tag, and Microsoft Web Tracking. The site uses modern frontend technologies and is optimized for mobile devices with responsive design. Performance is moderate, with potential improvements in caching and asset optimization. SEO is well implemented with Yoast SEO plugin and structured data (JSON-LD) for enhanced search engine understanding. Accessibility features are present but could be further audited for compliance. Hosting provider details are not explicitly identified.
Standards and sources

Reference chips under each finding point to the standard, regulation or specification the finding relates to. They are taken from the official datasets below and mapped conservatively: a finding with no defensible link shows none. NIS2 and GDPR references mark where a finding is relevant evidence, not a compliance verdict. Implementing Regulation (EU) 2024/2690 binds digital infrastructure and digital service providers; for other entities it is the most detailed public reading of the Article 21 measures. WCAG, EN 301 549, European Accessibility Act and Web Accessibility Directive references name the requirement an automated accessibility rule relates to; they are not a conformance verdict.

Retrieved 2026-10-25

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