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We take privacy seriously and we are committed to ensuring that we comply with our obligations under the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

This Privacy Policy explains how we manage the personal information that is collected, used, disclosed, and stored about you.

We will review this Privacy Policy periodically and may update it. The current version will be available on our website. We recommend that you review it periodically.

Definition of personal information

Personal information means information or an opinion about an identified individual or an individual who is reasonably identifiable whether the information or opinion is true or not and whether the information or opinion is recorded in material form or not.

Information we collect and hold

The kinds of information we collect and hold includes: names, residential address, date of birth, gender, photographs or images, personally submitted preferences, bank account and debit card information, financial information, email address, and additional identify verification information.

How we collect and hold information

Where possible we collect information from you directly when you open a betting account with us or otherwise use our Platforms.

You can browse our Platforms without opening an account (and having to provide us with your personal information). However, if you wish to create or operate an account, you must provide us with certain personal information so that we can meet our licensing and regulatory requirements.

By choosing to provide us with personal information, you consent to us collecting and holding your personal information.

We collect information in accordance with our licensing and other legal requirements, and for the effective and efficient operation of our business.

The purpose which we collect, hold, use and disclose information

When we collect your personal information, we may use this information to:

provide you with the services you have requested, or meet the purpose for which the information was provided;

upgrade, enhance and personalise your experience within our Platform, and/or to tailor our information, services or products for you;

contact you for direct marketing or other promotional purposes;

create aggregated data about our clients, such as average age, gender, demographics and other statistics to allow for the more efficient operation of our platform;

investigate or verify your compliance with our terms and conditions, the law or to enforce our legitimate rights associated with this; and/or

determine your liability with respect to goods and services tax and other taxes.

We may disclose your personal information to third parties for the purposes of conducting our business including (but not limited to):

to enable us to provide our services to you;

to enable us to ensure that you comply with our terms and conditions;

to verify your identity and perform other obligations under our legislative requirements such as the AML/CTF Act;

for planning, research, promotion and marketing of our products and services;

to our contractors, technology providers and other external service providers associated with the operation of our platform (including the operation of our websites and apps), business and/or the provision of our services, including, without limitation, associated data centres, web hosting providers, payment service providers, identification verification service providers, professional advisors and consultants (including lawyers, accountants, tax advisors and auditors);

to government and regulatory authorities and other organisations as required and/or authorised by law or for the purposes of resolving customer complaints and investigations or otherwise permitted under the Privacy Act;

to law enforcement agencies to assist in the prevention of criminal activities;

to our associated companies/company group;

to employees, third party service and content providers, dealers and agents, affiliates and suppliers;

10.

to Australian racing/sports controlling bodies where such controlling bodies request information to protect and maintain the integrity of the racing/sports code or where we consider any betting activity to be suspicious or unusual;

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to a successor entity in the event of a business transition, such as a merger, corporate reorganisation or to a purchaser of part of or all of our assets

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in order to participate in activities with business partners and sponsors, who will be identified to you when the relevant personal information is collected;

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to the extent necessary to carry out the uses which are set out above;

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to co-operate with a judicial process, a law enforcement agency or sports and racing bodies necessary to protect and defend the rights or property of us and our platform; and/or

15.

to lessen or prevent unlawful activity or serious threats to individuals, public health or safety.

We collect your Personal Information for the primary purpose of providing our services to you. We may also collect, use and disclose your Personal Information for secondary purposes related to the primary purpose including in circumstances where you may reasonably expect such collection, use or disclosure and/or for purposes including (but not limited to) trading, risk management, integrity, compliance, minimum bet laws and/or other related purposes including purposes reasonably required by applicable Principal Racing Authorities (Secondary Purposes).

You acknowledge We can provide your Personal Information to Punterstech (the provider of our platform technology and/or managed trading services) - who can also use and disclose your Personal Information for these purposes (including Secondary Purposes). Further, we may collect information from Punterstech, other service providers, regulators, racing bodies, sporting bodies and other third parties associated with our products and services. Collection of such information may include information aggregated by a third party.

Should any personal information be transferred to a third-party, we will take reasonable steps to ensure that the information disclosed is managed by the third-party in accordance with Australian privacy laws.

Access of Information

Some of your personal information can be accessed in within our Platforms, including under My Account.

To otherwise request access to your personal information, you can contact us at [email protected].

Correction of information

Some of your personal information can be changed by you within our Platforms, including under My Account.

To otherwise seek the correction of your personal information, you can contact us at [email protected].

Complaints

If you have any complaints relating to privacy, you can contact us at [email protected]. We will endeavour to respond to your complaint within a reasonable timeframe.

If we do not respond to your complaint within 30 days, or if you are dissatisfied with our response to the complaint, you have the option to make a complaint to the Office of the Australian Privacy Commissioner. Further information is available at: https://www.oaic.gov.au/

Sharing of information overseas

Our operations are conducted within Australia. It is unlikely that we will disclose your personal information to overseas recipients.

In the event that overseas disclosure of your personal information is necessary for a genuine business purpose and/or by a third party, we will take reasonable steps to ensure your personal information is handled to the same standard as Australian privacy laws.