This Privacy Policy applies to all personal information collected by Racing Victoria Limited (ACN 096 917 930) trading as Best Bets (Best Bets) in the operation of its Best Bets website.

This Privacy Policy will be reviewed regularly, and may be updated from time to time and published on Best Bets' website - www.bestbets.com/web/privacy (Website). Any changes to this Privacy Policy will become effective once published on the Website.

Part A: Accessing the Website

This Privacy Policy only applies to the personal information collected by Best Bets.

The Website contains links to Club and industry related websites (set out in Part G), amongst others. Please note that these Club and industry related websites have their own privacy policies and are not subject to this Privacy Policy.

The purpose of this Privacy Policy is to outline:

Best Bets will only collect personal information or sensitive information that it reasonably requires in order to carry out its functions and activities. This Privacy Policy applies to all personal information collected by Best Bets, whether Best Bets has asked for the information or not.

Best Bets abides by the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth) (Privacy Act). Further information in relation to Best Bets' Privacy Policy can be obtained by contacting its Privacy Officer.

Part B: How to contact us about privacy

Your privacy is very important to us. For that reason, please read the following details carefully and contact the Best Bets Privacy Officer if you have any questions.

Best Bets Privacy Officer contact details:

Address: 400 Epsom Road, Flemington, Victoria, 3031
Telephone: (03) 9258 4258
Email: privacyofficer@racingvictoria.net.au

Complaints

If you are concerned about a possible interference with your privacy, please contact the Privacy Officer and Best Bets will investigate the matter. Complaints to Best Bets must be made in writing. If you do not receive a response within 30 days or your concern is not resolved to your satisfaction, you can refer the matter to the Office of the Australian Information Commissioner (OAIC).

Before you can lodge a complaint with the OAIC, you will generally need to complain directly to Best Bets. Details on how to lodge a complaint with OAIC are set out on the OAIC's website at http://www.oaic.gov.au/privacy/making-a-privacy-complaint.

The OAIC can also be contacted on 1300 363 992.

For further information in relation to 'Access to Personal Information and Correction' please refer to Part F below.

Part C: Best Bets' Purpose and Collection of Information

Best Bets' collects information about you to enable it to perform its business activities and functions and to provide the best possible quality of customer service.

Best Bets' functions and activities include:

Personal Information

Personal information is information or an opinion about an identified individual or an individual who is reasonably identifiable, whether true or not, and whether recorded in a material form or not. Personal information includes information such as:

Best Bets will not collect personal information unless collection of such information is reasonably necessary to enable Best Bets to carry out one or more of its functions and/or activities.

Solicited Information

Best Bets holds and uses personal information about its customers. Typically this information includes a person's name, email address, mobile number, date of birth, gender, post code or any other required information.

This information is needed to maintain Best Bets' records in a format that identifies the person. These records are held by Best Bets for the purposes of enabling Best Bets to carry out its functions and activities.

Information is collected from the individual unless it is unreasonable or impracticable to do so.

Best Bets may collect personal information from an individual in the course of an individual's visit to the Website where that individual inputs personal information, which includes but is not limited to situations, where an individual:

Please note that comments posted on the Website that are therefore published on the Website and accessible to the public, may contain your name and be displayed in search results on external world wide web search engines.

An individual may have the option of interacting on the Website on an anonymous basis. Please note that Best Bets will place, use and read cookies and action tags from the computers of individuals that access the Website and record information about those computers, devices and browsers, which enables Best Bets to tell when a person uses a Website and also helps customise an individual's Website experience. If an individual does not wish to receive cookies, it is that individual's responsibility to set his or her browser to provide that the computer does not accept the cookies.

The purposes for which Best Bets collects personal information include:

Sensitive Information

Sensitive information is a subset of personal information that is generally afforded a higher level of privacy protection. Examples include information about an individual's:

Best Bets will not collect sensitive information unless the individual has consented to the collection of that information or the collection is required or authorised by law.

Part D: How information is held by Best Bets and who has access to it

Best Bets has commercially reasonable processes in place to ensure the security of an individual's personal information, including encryption of all data when it is transferred to Best Bets' service providers and limitations on access to personal information within Best Bets.

Only certain Best Bets employees, being those required to have access to personal information so that Best Bets is able to carry out its functions and activities will have access to information held by Best Bets, in order to protect the information from:

(a) misuse, interference and loss; and

(b) unauthorised access, modification or disclosure.

Authorised Best Bets employees will require a password to access Best Bets' database, where the information is held.

If Best Bets no longer requires any information for any purpose for which the information may be used or disclosed in accordance with this Privacy Policy, Best Bets will take such steps as are reasonable in the circumstances to destroy the information or to ensure that the information is de-identified.

Part E: Use and Disclosure of Personal Information

Best Bets may use or disclose personal information for the purpose for which it was collected and for other purposes permitted by the Privacy Act, including where:

It is not likely that Best Bets will disclose information to overseas recipients.

Best Bets may disclose your personal information to third parties for the following purposes:

When personal information is disclosed to third parties, appropriate care is taken to ensure the information is protected from misuse.

Direct marketing

Best Bets may disclose personal information (not sensitive information) to third parties for the purposes of direct marketing services related to the thoroughbred racing industry. An individual will be able to opt-out of direct marketing at any time if he or she chooses, by selecting the unsubscribe or opt out function at the bottom of a communication or in the absence of such a function by notifying the Privacy Officer in writing to privacyofficer@racingvictoria.net.au.

Best Bets will not use or disclose personal information about an individual for the purpose of direct marketing, unless:

Disclosure

Best Bets may disclose personal information to any third party engaged as service and content providers who may be required to assist in the operation of the Website.

Best Bets will only disclose personal information to an unrelated third party (being a party not related to the thoroughbred racing industry) with the individual's consent.

Transfer out of Australia

Website: not applicable - the Website is hosted in Australia.

Journalism

Where applicable, the collection and handling of personal information collected by Best Bets in its role as a media organisation in the course of journalism/provision of the news service, is not covered under this Privacy Policy. Personal information collected in the course of journalism activities will be handled in accordance with the Australian Press Council's Privacy Standards.

Part F: Access to Personal Information and Correction

A person can access his or her own personal information by contacting the Best Bets Privacy Officer. The Best Bets Privacy Officer will respond within a reasonable period after the request is made. In order to access your personal information, you will be required to provide proof of identity.

In some circumstances, a fee may apply.

Best Bets will endeavour to take reasonable steps to ensure that the information it holds is accurate, up to date and complete. If the information held by Best Bets is inaccurate, incomplete or not up to date, the individual may request that Best Bets corrects the information.

There are some circumstances in which Best Bets is entitled to deny a person access to information, in part or full. These include, amongst others, circumstances where:

If any request for access to information is to be denied in part or full or not provided in the manner requested by an individual, Best Bets will give the individual a written notice, setting out, amongst others, the reasons for the refusal except to the extent that, having regard to the grounds for the refusal, it would be unreasonable to do so.

Part G: Club, Betting Partner and Affiliate websites

The Website contains links to other websites, including the following, which have their own privacy policies. Users that visit these websites should refer to their separate privacy policies. As stated above in Part A, only the Website is subject to this Privacy Policy.

Clubs (and industry related organisations):

Racing.com - www.racing.com Country Racing Victoria - www.countryracing.com.au Melbourne Racing Club - www.mrc.racing.com Racing Victoria - www.rv.racing.com Victoria Racing Club - www.vrc.net.au