Privacy Policy

 Privacy Policy

 

1. General

 

This is the privacy policy of Frank Hudson trading as PremiumBet (ABN11759756784) (**Premiumbet, we, us**).

 

In carrying on business as a licensed on-line and telephone based wagering bookmaker, Premiumbet, collects personal information about people who:

• apply to become or are PremiumBet members;

• it opens PremiumBet accounts for;

• visit our website [www.premiumbet.com.au](www.premiumbet.com.au), or use our mobile phone or tablet applications (together the website);

• send us queries or information;

• provide services to us or on our behalf; or

• apply to become or are our employees.

 

When collecting, using and handling personal information, PremiumBet is required to comply with the Privacy Act 1988 (Cth) (**Privacy Act**) and is bound by the Australian Privacy Principles (**APPs**) set out in the Privacy Act.

 

Premiumbet is committed to ensuring that the personal information it collects is collected, used, disclosed and protected in accordance with the Privacy Act and this Privacy Policy.

 

In this Privacy Policy, ‘personal information’ (as defined in the Privacy Act) means information or an opinion about an identified individual, or an individual who is reasonably identifiable (whether the information is true or not, and whether it is recorded in any form or not).

 

2. Collection of personal information

 

The types of personal information we collect and how we collect it depends on the circumstances. If you apply to be, or are, a PremiumBet member, we collect personal information about you:

• if you wish to subscribe to PremiumBet newsletter;

• to process your application for PremiumBet membership;

• to open an account for you;

• to provide member services to you;

• to identify you as a member for security purposes and to comply with our legal obligations;

• to maintain and manage your betting account;

• to upgrade and enhance your experience when using our website;

• to tailor or develop information, services or products which we think may suit your needs;

• for marketing related purposes, including conducting research, conducting promotions, sending you newsletters and telling you (including via email, SMS or telephone) about products or services we think may be of interest to you); and

• to determine your liability to pay GST and other taxes where applicable.

 

The kinds of personal information that PremiumBet generally needs to collect about PremiumBet members and applicants for membership is:

• name

• residential address

• date of birth

• gender

• email address

• phone number(s)

• personally-submitted preferences

• bank account and debit card information

• financial information

• identity verification information

• recordings of all telephone calls and website activity

 

You must only provide accurate information that you are authorised to disclose in order to allow us to use your personal information in accordance with this Privacy Policy.

 

We will ordinarily collect your personal information directly from you, primarily through your use of the website or over the telephone. We may also collect personal information from others, for example our related companies, with whom we partner to offer you a wide range of services and rewards, or our through agents or affiliates whom we engage to undertake marketing activities.

 

We are required by law to collect some personal information about people who use our services. We are required to collect certain information (including identity verification information) under the Anti-Money Laundering and Counter Terrorism Act 2006 (Cth).

 

In order to verify the personal information you provide us we may use a document verification service. The document verification service involves a request to have the information you provide matched against official records and may involve use of secure third party systems and services.

 

We may also collect personal information from job applicants, our employees and individuals associated with our business partners and service providers. Usually this information is limited to name and contact details and the other information we need for the purpose of processing a job application and managing our business relationships.

 

3. Dealing with PremiumBet anonymously

 

Where practicable, we will allow you to deal with us on an anonymous basis or using a pseudonym. However, if you do not provide PremiumBet with the personal information we need, we may be unable to process your application to become a member, open an account for you, enable you to participate in the full range of services offered by Premiumbet, provide you with the services you require, or process your job application.

 

4. Notification about collection of personal information

 

When we collect personal information about you, we are required to take reasonable steps to ensure that you are aware of certain information relating to our collection, use, disclosure and handling of personal information. We generally do this by ensuring that a ‘collection statement’ is provided when the personal information is collected.

 

When you become a PremiumBet Member or use your account, and in other situations where you provide personal information to us, we may deem your provision of personal information to be consent to PremiumBet collecting, using and disclosing your personal information in accordance with the relevant collection statement.

 

5. Use and disclosure of personal information

 

Premiumbet only uses and discloses personal information for purposes that are related to the purposes for which we have collected the information, for purposes we have notified you of at the time we collect your information, for purposes we have notified you of at the time we collect the information, for where otherwise required or permitted by law. For PremiumBet members, applicants for membership or individuals we open an account for, this means we mainly use personal information for purposes connected with establishing and administering the membership (including the account) and providing services and products related to on-line and phone based wagering, as outlined above. We may also use and disclose your personal information to our related companies, including those overseas, with whom we partner to offer you a wide range of services and rewards. Information will only be shared with our related companies in accordance with all Australian laws, including the Privacy Act, and this Privacy Policy.

 

Premiumbet may use personal information to create aggregate data about PremiumBet members through demographic profiling and statistical analysis of it’s database, in order to allow for more efficient operation of PremiumBet business. We may provide the information derived from such profiling or analysis in de-identified form to potential and existing stakeholders.

 

Premiumbet may disclose your personal information:

• to our associated entities, agents and affiliates who undertake promotional and marketing activities on our behalf (including contacting you with special offers that may be of interest);

• to organisations that provide services (including IT, consultancy and advisory services) to us;

• to any particular third parties or classes of third parties that PremiumBet notifies you at the time of collecting your personal information that your personal information may be disclosed to;

• for taking appropriate action if we have reason to suspect that unlawful activity or misconduct of a serious nature in relation to our services has been, is being or may be engaged in;

• to protect and maintain the integrity of particular sports / racing codes, by assisting controlling bodies in their inquiries or notifying such bodies of any betting activity PremiumBet considers to be unusual or suspicious;

• where you have consented to the disclosure either expressly or by the circumstances and your conduct;

• where we consider disclosure is reasonably necessary to eliminate or minimise a risk to public health or safety,

• where we consider disclosure is reasonably necessary to investigate or deal with unlawful activity or serious misconduct;

• where we consider disclosure is reasonably necessary to locate missing persons;

• to establish or defend a legal claim; or

• where the disclosure is required or authorised by law.

 

Premiumbet will take all reasonable steps to ensure that any personal information which is disclosed to a third party is protected by that party in accordance with the Privacy Act and is used only for the purpose or purposes for which we supplied that information to them. Usually we do this by imposing contractual requirements on or seeking assurances from third parties as to their compliance with the Privacy Act.

 

Premiumbet does not disclose personal information to persons outside Australia.

 

Premiumbet stores data (including personal information) on secure back-up servers outside of Australia, predominantly for security purposes only. This data may be accessed offshore, but only ever in compliance with all Australian laws, including the Privacy Act, and in accordance with this Privacy Policy.

PremiumBet may disclose your Personal Information to Racing Victoria Limited (ACN 096 917 930) (**Racing Victoria**). Racing Victoria is the Principal Racing Authority responsible for governing thoroughbred racing in Victoria which includes administering and ensuring the integrity of the industry and supervising bookmakers, licensed and registered persons, its employees and betting transactions generally. PremiumBet is subject to the Club Bookmakers’ Licence Rules 2010 and the Rules of Racing (as amended from time to time) (**Rules**) and may disclose your Personal Information to Racing Victoria for the purpose of fulfilling its regulatory functions such as monitoring, investigating and enforcing the Rules. Racing Victoria will handle your Personal Information in accordance with its own privacy policy available at https://www.racingvictoria.com.au/privacy-policy. Please note that Racing Victoria may disclose your Personal Information and/or betting records to a third party in accordance with s 91E of the Racing Act 1958 (Vic), Racing Victoria’s privacy policy or as otherwise permitted by law. For example, Racing Victoria may disclose your Personal Information to a third-party service provider of Racing Victoria retained for the strict purpose of assisting Racing Victoria fulfill its regulatory functions (described above).

In addition to Racing Victoria, PremiumBet may disclose your personal information to other sports and racing controlling bodies, in order to fulfill regulatory obligations.

 

6. Direct marketing and opting out

 

From time to time we may use and disclose your personal information to inform you about PremiumBet (and its associated entities’) products or services or about promotional activities, which PremiumBet believes, may be of interest or of benefit to you. We may do this via email, SMS, telephone or mail.

 

If you no longer wish to receive marketing or promotional material from PremiumBet at all or in any particular form, you may contact us at any time by email to [email protected] with your request with which we will comply as soon as is practical. Where we send you commercial electronic messages for direct marketing purposes, each message will contain a functional means for you to opt-out of receiving such messages.

 

From time to time we may contact you in relation to the opening, management and administration of your PremiumBet account. These communications can be via any of the modes of contact recorded when you apply to open an account, register as a member or which we otherwise collect for the purposes of opening an account. Such communication is not affected by your opt-in or opt-out status for direct marketing communications.

 

7. Personal information and our website

 

In using the website you agree to be bound by the terms of this Privacy Policy. PremiumBet may review, change or update this Privacy Policy periodically and reserves the right to change the Privacy Policy at any time at its discretion by posting such changes on the website. We will publish our current Privacy Policy on the website and changes will take effect immediately at the time of publication. Your continued use of the website following publication will constitute your acceptance of those changes. You should review this Privacy Policy regularly and remain familiar with its terms.

 

This Privacy Policy will not apply to other websites which are linked to the website and over which PremiumBet has no control. PremiumBet is not responsible for, the use of, or the protection of information provided to, such websites.

 

You acknowledge that no data transmission over the Internet is totally secure. Accordingly, PremiumBet does not warrant the security of any information, which you transmit to it. Any information that you transmit to PremiumBet is transmitted at your own risk. You further acknowledge that Information posted on bulletin boards or communicated within a social media environment (for example, Facebook, Twitter, Chat Rooms) becomes public information. PremiumBet does not guarantee the security of this type of information.

 

Personal information has the potential to be collected when you use our website through the use of cookies. Cookies are pieces of data stored by your web browser on your hard drive which contain information relating to your use of the website. When you access the website, cookies may record details relating to your use of the website, including what pages you view from the website. PremiumBet uses cookies for the detection of fraud, statistical analysis, systems administration and internal management purposes only.

 

We may use third parties to serve ads on our website. The advertisers may employ cookies and action tags (also known as single pixel gifs or web beacons) to measure advertising effectiveness. Any information that these third parties collect via cookies and action tags is completely anonymous.

 

8. Management and security of personal information

 

Premiumbet will take all reasonable steps to ensure that the personal information, which it collects, uses or discloses, is correct and is stored in a secure environment that is accessed only by authorised persons.

 

Premiumbet will destroy or permanently de-identify personal information when it is no longer required for any purpose permitted under the APPs, including our legal or operational obligations. PremiumBet holds personal information in electronic database owned and operated by Premiumbet. Once PremiumBet receives your transmission, PremiumBet will take reasonable steps to protect your personal information from misuse, loss and unauthorised access, modification and disclosure including by using password protected systems and databases and Secure Socket Layer (“SSL”) technology.

 

Premiumbet’s employees, agents and contractors are required to maintain the confidentiality of members’ personal information.

Premiumbet takes reasonable measures to ensure that personal information which it collects is accurate, complete and current and also when it uses and discloses it, that it is relevant, having regard to the purpose for which it is being used or disclosed. We give you the opportunity to correct and update personal information at any time, and may contact you on a periodic basis to seek the most up-to-date information from you. We will correct your personal information if we are satisfied that it is accurate and needs to be corrected.

 

9. Personal information about children

 

Persons under the age of 18 (‘Children’) cannot become PremiumBet members and are excluded from access to our services. We will not accept their information for the purposes of opening a wagering account. It is however, ultimately the responsibility of parents or guardians to monitor their children’s Internet activities including where appropriate by using Internet screening software.

 

You are responsible for the security of and access to the website. You must log out of your account when you have completed your time on the website, and should not disclose your username, password or any account information to any other person.

 

10. Access to and correction of personal information

 

You may access personal information about you held by PremiumBet by following the “My Account” link on the website or by emailing PremiumBet Customer Service at [email protected]. To do so, you will need to provide evidence to confirm your identity before we can provide access. We will generally respond to all requests for access within 30 days of the request. If your request is particularly complex, or requires detailed searching of our records, there may be a cost to you in order for us to provide the information.

 

Details of your betting transactions can also be accessed via the “Bet History” section of the Member Services section of the website.

 

However, we may refuse a request for access in certain circumstances set out in the Privacy Act, including where:

• providing access would be unlawful;

• we are required or authorised to do so by or under an Australian law or court/ tribunal order; or

• where giving access would be likely to prejudice enforcement related activities by or on behalf of an enforcement body.

 

If we refuse your request or cannot give you access in the manner you have requested, we will do what we can to meet your requirements by other means. If we refuse access to your personal information, we will advise you in writing of the refusal, the reasons for the refusal, and the complaint mechanisms available to you.

 

If you believe that the personal information PremiumBet holds about you is inaccurate, incomplete or not current, please let us know and we will investigate and correct any inaccuracies if we are satisfied that a correction is required. Your personal information can be updated or corrected by you in the “Account Details” section of the website at any time after you log in. Subject to identity verification, personal information can also be updated or corrected by emailing PremiumBet Customer Service at [email protected]

 

11. Complaints and further information

 

If you believe your privacy has been interfered with and wish to make a complaint, please contact our Privacy Officer. The Privacy Officer will investigate your complaint and notify you of the outcome. If your complaint indicates that there has been an interference with your privacy by a person other than Premiumbet, the Privacy Officer may discuss your complaint with that other person in an attempt to resolve it.

 

If you are not satisfied with the outcome of your complaint or the way we handle it, you may make a complaint to the Office of the Australian Information Commissioner at oaic.gov.au/privacy/making-a-privacy-complaint.

 

If you have any queries, requests for access or correction or further information on our Privacy Policy, or if you have any concern about the handling of your personal information or wish to make a complaint, please contact management, whose contact details are as follows:

 

Email: i[email protected]

 

Further Information about privacy concerns or complaints in Australia can be found on the Office of the Australian Privacy Commissioner’s website at www.oaic.gov.au.

Managed Trading Services

 

Customers acknowledge that the PremiumBet platform is powered by technology provided by BetMakers, and BetMakers provides expert trading and customer liability management services (collectively Managed Trading Services) on behalf of PremiumBet.  Accordingly, PremiumBet will provide BetMakers such Customer data (including personal information) to the extent that is reasonably needed by BetMakers to host and maintain the PremiumBet platform and/or provide Managed Trading Services.  BetMakers performs the Managed Trading Services in accordance with the trading strategy determined by PremiumBet.  To preserve confidentiality over Customer Data, PremiumBet has entered into legally binding contract/s that obligate BetMakers (which is an ISO 27001 certified company – the international gold-standard for information security management systems) to maintain confidentiality over all Customer data which it receives.

 

For clarity, BetMakers is not entitled to disclose Customer data (including personal information) to third parties - including any other wagering operator to whom BetMakers provides Managed Trading Services.  That said, the Customer acknowledges that BetMakers' trading staff are entitled to utilise their general industry know-how and experience when providing Managed Trading Services to PremiumBet.  If, for example, a member of the trading staff is, by virtue of their experience (and/or their access to publicly available information), aware that a renowned customer is “sharp” on racing, such staff member is entitled to use that general know-how for the benefit of PremiumBet. The Customer acknowledges and accepts that it is not reasonable (or indeed possible) for BetMakers' trading staff members to ‘forget’ (or ignore) his/her know-how, drawn from years of experience, when providing risk and/or trading services for the benefit of PremiumBet.