Part A: Accessing the Website
- the kind of information that Best Bets may collect about you, how it is collected and how it is held by Best Bets;
- the purposes for which Best Bets collects, holds, uses and discloses personal information;
- how Best Bets may disclose that information;
- how an individual can access the information held about him or her and seek correction of such information (if required);
- when Best Bets may use an individual's information to contact them; and
- the protection of an individual's personal information.
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
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:
- production of a quality thoroughbred racing industry, tipping and betting publication and website;
- online subscription service;
- provision of news and information related to the thoroughbred racing industry including race form and tips;
- targeted promotion of industry related events, promotions and competitions;
- provision of aggregated data, industry related communications and a news service;
- advertising services; and
- hosting competitions and promotions.
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:
- an individual's name or address;
- an individual's date of birth; or
- information about an individual's opinions, likes and dislikes.
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.
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:
- registers to become a subscriber to Best Bets including to its race form, newsletters and/or communications;
- enters a competition or participates in a promotion;
- posts comments on the Website; or
- becomes an advertiser.
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:
- provision of an online subscription service;
- measure and improve the services and features of the Website in order to provide the individual with the best service experience possible on the Website;
- promoting the thoroughbred racing industry;
- conducting competitions and promotions; and
- providing services related to the thoroughbred racing industry such as publication, delivery or dissemination of industry related news.
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:
- racial or ethnic origin;
- health or medical information;
- membership of a political association, professional or trade association or trade union;
- criminal record; or
- genetic information.
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.
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:
- the individual has consented; or
- the individual would reasonably expect Best Bets to use or disclose the information for that other purpose, in circumstances where it is:
- (sensitive information) directly related to the purpose for which it was collected; or
- (personal information) related to the purpose for which it was collected;
- the information is provided to Best Bets' existing or potential business partners or joint venture entities;
- use or disclosure is authorised by law or a court/tribunal order; or
- Best Bets reasonably believes that use or disclosure of the information is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body, as defined in the Privacy Act.
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:
- to provide the service you wish to use;
- for research purposes relating to the thoroughbred racing industry;
- to customise and promote services and events related to the thoroughbred racing industry which may be of interest to you;
- if authorised or required by law;
- with your consent;
- as required for integrity purposes; and/or
- as otherwise required to enable Best Bets to fulfil it functions and activities as outlined in Part C.
When personal information is disclosed to third parties, appropriate care is taken to ensure the information is protected from misuse.
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 firstname.lastname@example.org.
Best Bets will not use or disclose personal information about an individual for the purpose of direct marketing, unless:
- Best Bets collected the information directly from the individual;
- the individual would reasonably expect Best Bets to use or disclose the personal information for that purpose; and
- the individual has not opted out of receiving direct marketing.
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.
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:
- Best Bets believes that giving access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety;
- giving access would have an unreasonable impact on the privacy of other individuals;
- the request for access is frivolous or vexatious;
- the information relates to existing or anticipated legal proceedings between Best Bets and the individual, and would not be accessible by the process of discovery in those proceedings;
- giving access would reveal evaluative information generated within Best Bets in connection with a commercially sensitive decision-making process;
- giving access would be likely to prejudice one or more enforcement related activities conducted by, or on behalf of an enforcement body;
- giving access would be unlawful (for example, if providing the information would amount to a breach of legal professional privilege or a breach of confidence); or
- denying access is required or authorised by or under an Australian law or a court/tribunal order.
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
Clubs (and industry related organisations):
Part H: ADDITIONAL RIGHTS - EUROPEAN UNION RESIDENTS
If you are located in the European Union you may have additional rights to those described above. Some of these rights will only apply in limited circumstances.
The right to erasure - you have the right to request that Best Bets erase your personal data, under certain conditions. This right only applies in limited circumstances and will not usually apply where it remains necessary for us to process your information for the purposes for which it was collected (for example, access to Best Bets online Racebooks and Proform), or if we are otherwise required by law to retain your information or your information is relevant to a legal dispute.
The right to restrict processing - you have the right to request that Best Bets restrict the processing of your personal data, under certain conditions. For example, these rights will not usually apply when we need to process your information to carry out our day-to-day business functions or where we have a legitimate interest in processing your information.
The right to object to processing - you have the right to object to Best Bets processing of your personal data, under certain conditions.
The right to data portability - you have the right to request that Best Bets transfer the data that we have collected to another organisation, or directly to you, under certain conditions.
Where we rely on your consent as the legal basis for processing your personal information you may withdraw your consent at any time. For example, where you have subscribed to communications from Best Bets or its commercial partners to which you have previously opted-in, you can do so by using the unsubscribe tool.