1. PURPOSE

The purpose of this Privacy Policy is to outline:

VTRIMB abides by the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth) (Privacy Act). Further information in relation to VTRIMB's Privacy Policy can be obtained by contacting VTRIMB's Privacy Officer (please refer below for contact details).

This Privacy Policy will be reviewed regularly and may be updated from time to time and published on the relevant Website (as defined in section 9 below).

2. SCOPE

This Privacy Policy applies to all personal information collected by Victorian Thoroughbred Racing IMB Pty Limited (ABN 55 643 473 376) when trading as:

(together, VTRIMB).

VTRIMB is a wholly owned subsidiary of Racing Victoria Limited ACN 096 917 930 (Racing Victoria). VTRIMB will only collect personal information or sensitive information that is reasonably necessary for, or directly related to, one of its functions or activities. This Privacy Policy applies to all personal information collected by VTRIMB, whether VTRIMB has asked for the information or not.

3. VTRIMB'S FUNCTIONS AND ACTIVITIES

VTRIMB's functions and activities include:

4. COLLECTION OF INFORMATION

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:

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

We are generally exempt from the Privacy Act when we handle employee records, and this Privacy Policy does not apply to that information. However, where State or Territory health privacy legislation applies, we are still required to protect the privacy of employee health information. This Privacy Policy will apply in those circumstances.

Solicited Information

VTRIMB holds and uses personal information about its suppliers, customers, Website users and subscribers. Typically, this information includes a person's name, email address, phone number, address, date of birth, gender and any other required information.

This information is needed to maintain VTRIMB's records in a format that identifies the person. These records are held by VTRIMB for the purposes of enabling VTRIMB to:

VTRIMB collects personal information only by lawful and fair means. Information is collected from the individual unless it is unreasonable or impracticable to do so. This is generally directly from an individual in the course of their visit to the Website and includes but is not limited to, situations where an individual inputs personal information to:

VTRIMB may otherwise collect information directly from you, from third parties and/or publicly available sources, including but not limited to the following:

Unsolicited Information

If VTRIMB receives personal information about an individual in circumstances where it did not solicit the information, VTRIMB will (within a reasonable period after receiving the information) determine whether or not it would have been entitled to collect such information having regard to its functions and activities. If VTRIMB determines that it is not entitled to such information, VTRIMB will destroy the information or ensure that the information is de-identified.

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:

VTRIMB 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.

What if you don't provide us with your personal information?

The nature of the business carried on by VTRIMB means that, generally, it is not possible for us to provide services to you anonymously. However, in some circumstances, we allow individuals the option of not identifying themselves, or of using a pseudonym, when dealing with us, for example, where you write to a VTRIMB publication or where you post on the Website.

5. HOW INFORMATION IS HELD BY VTRIMB

VTRIMB 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 VTRIMB. There are limitations on access to information within VTRIMB.

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

  1. misuse, interference and loss; and
  2. unauthorised access, modification or disclosure.

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

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

6. USE AND DISCLOSURE OF PERSONAL INFORMATION

For what purpose may VTRIMB use and/or disclose my personal information?

VTRIMB 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:

Except in limited circumstances, including those described below (refer to section "Cross-border Processing and Disclosure of Personal Information"), it is not likely that VTRIMB will disclose information to overseas recipients.

VTRIMB 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.

Who may VTRIMB share my personal information with?

Personal information collected by VTRIMB shall be disclosed to Racing Victoria. Please refer to Racing Victoria's Privacy Policy available at https://www.racingvictoria.com.au/privacy-policy for details regarding how Racing Victoria manages your personal information.

Personal information collected by VTRIMB may also be disclosed to third parties. For example, personal information may be disclosed to:

Cross-border Processing and Disclosure of Personal Information

VTRIMB may process and/or disclose your personal information overseas, including in the United States, the European Union (including the United Kingdom), Singapore and Hong Kong in the following situations:

In each case, we will comply with the requirements of the Privacy Act that apply to cross border disclosures of personal information.

Journalism

Where applicable, the collection and handling of personal information collected by VTRIMB in its role as a media organisation in the course of journalism, photography or provision of the news service (Journalism Activities), 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 which are available here: http://www.presscouncil.org.au/privacy-principles/.

Direct marketing

VTRIMB 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 notifying VTRIMB's CustomerFirst Department (details below) in writing.

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

CustomerFirst can be contacted as follows:

Name: Racing Victoria - CustomerFirst
Address: 400 Epsom Road, Flemington, Victoria, 3031
Email: information@racingvictoria.net.au
Fax: (03) 9258 4326
Phone: 1300 139 401

7. ACCESS TO PERSONAL INFORMATION AND CORRECTION

A person can access his or her own personal information by contacting VTRIMB's Privacy Officer. VTRIMB's Privacy Officer will respond within a reasonable period after the request is made.

In some circumstances, a fee may apply.

VTRIMB 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 VTRIMB is inaccurate, incomplete or not up to date, the individual may request that VTRIMB correct the information.

There are some circumstances in which VTRIMB 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, VTRIMB 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.

8. DATA AND SECURITY

We hold personal information in a number of ways, including in hard copy documents, electronic databases, email contact lists, and in paper files held in drawers and cabinets. Paper files may also be archived in boxes and stored offsite in secure facilities. We take reasonable steps to:

You can help us keep your information up to date, by letting us know about any changes to your details, such as your address, email address or phone number.

The steps we take to secure the personal information we hold include website protection measures (such as firewalls and anti-virus software), security restrictions on access to our computer systems (such as login and password protection), controlled access to our corporate premises, policies on document storage and security, personnel security, staff training and workplace policies.

9. VTRIMB WEBSITES

VTRIMB operates various websites to which this Privacy Policy applies as follows:

https://www.racing.com
https://www.bestbets.com
https://www.winningpost.com.au
https://photos.racing.com
https://licensedphotos.racing.com

(Website).

The Website may also contain links to other websites, including the following, which have their own privacy policies. Individuals that visit these websites should refer to their separate privacy policies.

Collection and Purpose (including Cookies)

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

In addition, VTRIMB also places, uses and reads cookies and advertising identifiers for mobile devices from an individual who visits the Website computer. This includes through its use of a third party service, Google Analytics, which may also provide VTRIMB with information about you, such as your IP address, location, gender, age bracket, language and interests based on your interaction with Google platforms. If you would like more information regarding how Google uses data, please visit www.google.com/policies/privacy/partners/ (as amended by Google from time to time).

The use of cookies, advertising identifiers for mobile devices and Google Analytics enables VTRIMB to:

The purposes for which VTRIMB collects personal information from users of its Website include:

If a person does not wish to receive cookies, you may set your browser to either prompt or refuse cookies.

Disclosure

Customarily, VTRIMB only discloses personal information collected via the Website to its service providers who assist in the operation of the Websites. VTRIMB will only disclose personal information to an unrelated third party with the individual's consent, in accordance with this Privacy Policy or otherwise in accordance with the Privacy Act.

10. ADDITIONAL RIGHTS - EUROPEAN UNION AND UNITED KINGDOM RESIDENTS

If you are located in the European Union or the United Kingdom 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 VTRIMB 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, 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 VTRIMB 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. For example, it is necessary for VTRIMB to comply with its legal obligations.

The right to object to processing - you have the right to object to VTRIMB's processing of your personal data, under certain conditions.

The right to data portability - you have the right to request that VTRIMB 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 an e-News service to which you have previously opted-in, you can do so by using the unsubscribe tool.

11. HOW TO CONTACT US ABOUT PRIVACY

Your privacy is very important to us. Please contact VTRIMB's Privacy Officer via one of the following if you have any questions: Mail: Racing Victoria Privacy Officer, Racing Victoria, 400 Epsom Road, Flemington, Victoria, 3031
Telephone: 1300 139 401
Email: privacyofficer@racingvictoria.net.au

If you are concerned about a possible interference with your privacy, please contact VTRIMB's Privacy Officer and VTRIMB will investigate the matter. Complaints to VTRIMB 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 VTRIMB. Details on how to lodge a complaint with OAIC are set out on the OAIC's website here.

The OAIC can also be contacted on 1300 363 992.