Belmont 16ft Sailing Club Ltd ACN 001 020 471 is committed to protecting the privacy of your personal information in accordance with Australian privacy laws.
When you engage us to provide you with any goods or services, communicate with us through email, text, by telephone, in writing, participate in any of our promotional activities, or use any of our other services, including our websites or any of our mobile device applications (‘Apps’), you agree to the use and disclosure of your personal information in the manner described in this policy.
- How and when we collect personal information;
- How we use and disclose personal information;
- How we keep personal information secure, accurate and up to date;
- How an individual can access and correct their personal information; and
- How we will facilitate or resolve a privacy complaint.
What Is Personal Information?
The Privacy Act 1988 (Cth) defines ‘personal information’ to mean information or an opinion, whether true or not and whether recorded in a material form or not, about an individual whose identity is reasonably identifiable, from information or opinion.
Types of Personal Information That We Collect
The kinds of personal information we may collect from you will depend on what type of interaction you have with us. Personal information we may collect from you includes among other things:
- Your contact information such as full name (first and last), e-mail address, current postal address, occupation, delivery address (if different to postal address) and phone numbers;
- Your date of birth;
- Proof of your date of birth (including, but not limited to, driver’s licence both digital and physical, passport, birth certificate);
- Transaction information – we collect transaction details related to your use of our services, including the type of services requested or utilised, order details, date and time services were provided, amounts charged and benefits received and your payment methods;
- Personal information you provide to us when you participate in a promotion, competition, promotional activity, survey, market research, subscribe to our mailing list;
- When a membership card is used in a gaming machine, swipe machine or at any of our restaurants, bars or point of sale outlets, the information is used to award ‘Membership Rewards’ and is cross referenced with our membership database. This information in a consolidated manner, is used to help make decisions on changing or improving our service offerings.
- your bank account details when we pay you any poker machine winnings by EFT;
- your records of communication with us;
- if you visit our website or use our App, your website and App usage information such as your IP address, dates and times of access, App features, pages viewed, or system activity;
- geolocation information – depending on your App settings or device permissions we may collect your precise or approximate location information as determined through data such as GPS, IP address and Wi-Fi, including when the App is running in the foreground (App open and onscreen) or background (App open but not onscreen) of your device.
- device information – information about the devices you use to access our services, including the hardware models, device IP address, operating systems and versions, software, file names and versions, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion information, and mobile network information.
How We Collect the Information
- When you apply for membership;
- Request to receive products or services;
- Purchasing products;
- Using credit card or EFTPOS for purchases;
- Using the Club’s Wi-Fi network;
- Event ticket purchases;
- Entering a competition or voting forum;
- Membership loyalty program;
- Using our App
- When you utilise our services with your membership card;
- When you complete a survey or questionnaire;
- Using the Clubsafe Self Exclusion Agreement.
When you engage in certain activities such as entering a contest or promotion, filling out a survey, filling out a form or sending us feedback, we may ask you to provide certain information. It is completely optional for you to engage in these activities.
The Club collects this information in order to:
- Identify you and process your membership application.
- Meet statutory requirements under the Registered Clubs Act, Anti–money Laundering and Counter Terrorism laws and other relevant legislation.
- Contact members to advertise and market events, activities, opportunities, offers and the goods and services provided by the Club (including by direct mail, Email, telephone, SMS and MMS); and including without limitation with respect to food and beverage, promotions, entertainment, wagering, gaming machines, gaming, sporting events and venue hire.
- Analyse usage of products and services offered by the Club.
- Provide you with goods or services you are receiving or utilising as offered by the Club and to offer and administer any benefits you subsequently become entitled to in relation to that product or service.
- Analyse website usage.
Under the Registered Clubs Act patrons visiting the Club must produce a recognised form of identification, i.e. passport, drivers’ licence (physical or digital) or proof of age card to gain entry to the premises. The Club uses terminals to gather this information and to protect the data collected, i.e. addresses of patrons. Scanning of licenses is optional and, if preferred, use of manual sign-in via the terminal is available for patrons once the form of identification has been sighted by an authorised officer of the Club.
The Purpose for Collecting Your Personal Information
We will generally only collect and use your personal information for the primary purposes of:
- our general business operations;
- creating and updating your membership record;
- verifying your identity;
- processing or facilitating payments for services;
- effectively providing you with our goods and services;
- performing internal operations necessary to provide our services, including to troubleshoot software bugs and operational problems, to conduct data analysis, testing and research, and to monitor and analyse usage and activity trends.
- perform research and analysis about your use of, interest in, our or others’ products, services, or content;
- communicating with you;
- responding to your inquiries or complaints;
- meeting our legal and regulatory obligations;
- conducting, improving and developing a relationship with you;
- direct marketing (such as providing you with information about our products and promotional notices and offers); and
- improving our websites or Apps.
Your personal information is only collected by lawful and fair means and where practicable, only from you or from a person acting or authorised to act on your behalf.
We will take reasonable steps to ensure that you are aware of:
- the likely use of the information;
- the right of access to the information;
- the identity and contact details of our employee/representative collecting your personal information;
- any law requiring collection of the information; and
- the main consequences of failure to provide your personal information.
How we may use and disclose your personal information
We may use your personal information for:
- the primary purposes for which it was collected, such as those described above;
- administering and responding to your enquiry or feedback about our products and/or services;
- conducting, and allowing you to participate in, a promotion, competition, promotional activity, survey, market research or customer behavioural activity;
- promoting and marketing our current and future products and services to you, informing you of upcoming events and special promotions and offers and analysing our products and services so as to improve and develop new products and services (but giving you the opportunity to opt out of such direct marketing);
- improving the operation of our websites and Apps.
We may disclose personal information we collect from you:
- to our related companies, suppliers, service providers, consultants, contractors or agents for the primary proposes for which it was collected or for other purposes directly related to the purpose for which the personal information is collected. For example, your name and telephone number may be disclosed to our supplier to enable that supplier to respond to your request for information about a product;
- for direct marketing by us, but giving you the opportunity to opt out of such direct marketing; We will include our contact details in any direct marketing;
- to relevant Federal, State, Territory medical, health and safety authorities (as required);
- where the law requires or authorises us to do so;
- to others that you have been informed of at the time any personal information is collected from you;
- with your consent (express or implied), to others.
We do not disclose your personal information for any secondary purposes unless your consent has been given or as required by law, and we will not sell or license any personal information that we collect from you.
Surveillance of Venues
We use video surveillance for security reasons. Details of suspected or actual illegal and/or undesirable activities on our premises may be shared with other clubs, law enforcement and regulatory bodies such as the Office of Liquor, Gaming and Racing and the Independent Liquor and Gaming Authority.
Persons who may be subject to surveillance are advised (signage at entry foyer) that their image may be recorded and any personal information will be destroyed or de-identified when it is no longer needed.
How We Hold and Store Information
We are committed to keeping your personal information secure and we will take all reasonable precautions to protect your personal information from unauthorised access, loss, release, misuse or alteration.
All information may be stored in hard copy documents but is generally stored electronically on software systems. Hard copy personal information is stored and archived for a period of seven (7) years.
We maintain physical security over paper and electronic data stores, such as locks and security systems. We also use computer and network security technologies such as firewalls, two factor authentication, intrusion prevention software, antivirus software, e-mail filtering and passwords to control and restrict access to authorised staff for approved purposes and to secure personal information from unauthorised access, modification, disclosure, misuse and loss.
We will destroy or permanently de-identify personal information if it is no longer needed for the purpose for which it was collected.
Whilst we take all reasonable steps to secure your personal information from loss, misuse and unauthorised access, you acknowledge that all activities in which you intentionally or unintentionally supply information to us carries an inherent risk of loss of, misuse of, or unauthorised access to such information.
We protect personal information through the use of secure databases that can only be accessed by authorised individuals. As a matter of course, employees, including those able to access personal information, are bound by the confidentiality clause in their employment contract as well as the confidentiality policy in the staff handbook.
Information That You May Disclose Publicly
When you post information on social media platforms associated with the Club and its venue, it is to be understood that this information is in the public domain and the Club is not a position to accept any responsibility for whom or why anyone might access the information.
Using our Website or App and Cookies
As with most websites and apps, when you visit our website or use an application on our website, or use our App, we may record anonymous information such as IP address, time, date, referring URL, pages accessed and documents downloaded type of browser and operating system.
We also use “cookies”. A cookie is a small file that stays on your computer or device until, depending on whether it is a sessional or persistent cookie, you turn your computer or device off or it expires. Cookies may collect and store your personal information. You may adjust your internet browser or device settings to disable cookies. If cookies are disabled you may still use our website or App, but the website or App may be limited in the use of some of the features.
Marketing and Opt Out
We may use your personal information for:
- promoting and marketing of our current and future products and services;
- informing you of upcoming events and special promotions and offers; and
- analysing our products and services to improve and develop new products and services.
We will only offer you products or services, where we reasonably believe that they could be of interest or benefit to you.
At the point we collect information from you, you may be asked to “opt in” to consent to us using or disclosing your personal information. You will generally be given the opportunity to “opt out” from receiving marketing communications from us. You may “opt out” from receiving these communications by clicking on an unsubscribe link at the end of an email, SMS or by contacting us with this request.
Accurate and up-to-date information
We take reasonable steps to ensure your personal information is accurate, up-to-date and not misleading by updating its records whenever true and correct changes to the data come to its attention.
If you believe your information is incorrect, incomplete or not current, you can request that we update this information by contacting our Privacy Officer. To contact our Privacy Officer please see contact details below.
We will correct information we hold about you if we discover, or you are able to show to a reasonable standard, the information is incorrect. If you seek correction and we disagree that the information is incorrect, we will provide you with its reasons for taking that view.
We disregard information that seems likely to be inaccurate or out-of-date by reason of the time that has elapsed since it was collected or by reason of any other information in our possession.
How an Individual Can Access Information about Themselves
We acknowledge that you have a general right of access to information concerning you, and to have inaccurate information corrected. You can access the personal information we hold about you by contacting our Privacy Officer. If access is refused to your personal information for reasons permitted by the Privacy Act, we will give you a notice explaining our decision to the extent practicable and your options.
To contact our Privacy Officer please see contact details below. If you make an access request, we may ask you to verify your identity and put your request in writing for security reasons. We may charge a reasonable administration fee to cover the costs of meeting your request. We will reply to your request for access within 30 days of notification by you.
Only where it practicable to do so, we may allow you the option not to identify yourself when dealing with us.
Collecting sensitive information
Transfer of ownership
Online Privacy Issues
When you visit our website our internet service provider makes a record of the visits and logs the following information for statistical purposes – the user’s server address, the user’s top-level domain name (eg: .com, .gov, .au, etc), the date and time of visit to the site, the pages accessed and documents downloaded, the previous site visited and the type of browser used. No attempt will be made by us to identify users or their browsing activities.
We may use ‘cookies’ to enhance the functionality of the website; however, cookies are not used to record any personal information (eg: name, address, e-mail address).
We may collect personal information if you send us a message or submit a request for further information regarding one of our products or services.
Cross Border Disclosure
Any personal or private information provided to us will not be transferred to and to our best knowledge, stored at a destination outside Australia. We do not have agreements or arrangements with overseas parties who utilise any personal or private information provided to us. We acknowledge the importance of protecting personal and private information and, as set out above we have taken reasonable steps to ensure all personal and private information is kept safe and secure.
The Club relies on the information provided by members to be accurate and current. The Club will take reasonable steps to ensure that the personal information it collects, uses or discloses is accurate, complete and up to date.
If you believe the personal information we hold on you is incorrect please advise us in writing by sending your letter or e-mail to the Privacy Officer using the details below. We will take reasonable steps to correct Club records appropriately and within a reasonable time frame except where the Privacy Act prohibits it or does not require it.
To change your name on the membership database, supporting documentation from a government source is required. Change of addresses can be done by notifying the Club at the e-mail address below or in person at our Front Desk.
Notifiable Data Breaches
The Notifiable Data Breaches (NDB) scheme under Part IIIC of the Privacy Act 1988 (Privacy Act) established requirements for entities in responding to data breaches. Entities have data breach notification obligations when a data breach is likely to result in serious harm to any individuals whose personal information is involved in the breach. Belmont 16ft Sailing Club Ltd understands and abides by these legal obligations on behalf of their members and non-members.
If a substantial data breach has or may have occurred (for example, your personal information was shared with unauthorised persons) we will notify you as soon as is practicable.
Security & Complaints
Belmont 16s is committed to ensuring the security of your personal information and we will take all reasonable precautions to protect this information from loss, misuse or altercation. Should you wish to lodge a complaint regarding the possible breach of the Australia Privacy Principles, please contact the Privacy Officer in writing. On receipt of your complaint a review will be conducted and findings will be communicated to you.
We have put in place an effective mechanism and procedure for you to contact us so that we can attempt to resolve issues or complaints should you have any concerns or complaints about the manner in which your personal information has been collected, used or disclosed by us. On any issues of privacy, feedback or complaints, you can contact the Club as follows:
By e-mail: email@example.com
By mail: The Privacy Officer
Belmont 16 Ft Sailing Club Ltd
The Parade (PO Box 484)
Belmont NSW 2280
By phone: 02 4945 0888 – ask for the Privacy Officer
If you believe the 16s has not adequately dealt with your complaint, you may complain to the Privacy Commissioner whose contact details are as follows:
Contact: Officer of the Australian Information Commissioner (OAIC)
Phone: 1300 363 992
Address: GPO Box 5218, NSW 2001
Changes to this Statement