Tabcorp Media (SKY Channel & 2KY) Privacy Policy

TABCORP MEDIA (SKY CHANNEL & 2KY) - COLLECTION NOTICE AND PRIVACY POLICY

Sky Channel Pty Ltd ABN 77 009 136 010 of 79 Frenchs' Forest Road, Frenchs' Forest, New South Wales (Sky Racing) and 2KY Broadcasters Pty Limited ABN 54 000 820 057 of 495 Harris Street, Ultimo, New South Wales (Sky Sports Radio) (each Sky, we, us, our) is bound by the Privacy Act 1988 (Cth) (Privacy Act) and Australian Privacy Principles (APPs).

You can contact our Privacy Officer about privacy issues - email privacy@tabcorp.com.au or telephone + 61 2 9452 8400 (Sky Racing) or +61 2 9218 1000.

COLLECTION NOTICE (APP 5)

1. How we collect your personal information

Generally we collect directly from you (either online, by mail or over the telephone).  Where it isn't reasonable or practicable to collect information from you, we may collect it from a third party.  For example, we may collect personal information from:

(a) our related bodies corporate (e.g. TAB Limited or Tabcorp Wagering Manager (Vic) Pty Ltd);
(b) providers of subscription television services that carry our channels (e.g. Foxtel); and
(c) third parties that can help assess your risk to our business under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/ CTF Act).
We may use cookies to collect information from your computer.  Cookies are pieces of data sent by a website to your computer and stored on the hard drive.  They allow the website to identify and interact with your computer.

2. What we are legally required to collect

We may be required to collect personal information under:
(a) the AML/ CTF Act;
(b) any licences applying to our related bodies corporate; and
(c) our related bodies corporate State Race Fields Approvals.
We may also be required to collect personal information by law enforcement agencies like the Australian Federal Police,the Australian Crime Commission and the Australian Securities and Investment Commission.


3. Our main reasons for collecting your personal information

(a) To identify you.
(b) To manage, administer and control the quality of our products and services.
(c) To market our products and services to you.
(d) To comply with our legal obligations, including:
• under the AML/ CTF Act and any licences or betting rules applying to our related bodies corporate;
• to State racing controlling bodies (including thoroughbred, harness and greyhound); and
• to authorised sports controlling bodies (domestic and international).

4. Our other reasons for collecting, holding, using and disclosing your personal information
(a) To develop and improve our products and services.
(b) To assist you with enquiries or complaints.
(c) To identify your behaviour or habits so we can better target our communications, products and services.
(d) To enable our related bodies corporate to market their products and services to you.
(e) To assess whether you pose a risk to our business or the businesses of our related bodies corporate.
5. What happens if we don't collect your personal information?

Unfortunately, if we cannot collect your personal information we may not be able to provide our products and services to you.  For example:

(a) we can't subscribe you to the Sky Racing Media Centre without having our basic contact details; and
(b) if we cannot verify your identity, we may not be able to accept advertising from you.
6. Disclosures to third parties

Generally we only give your personal information to:
(a) external providers of services we use to operate our business and manage our business systems (e.g. advertising agencies, market research analysts, mailing houses, printers, call centres, IT consultants, and providers of  product development, payment processing and identity verification services);
(b) Tabcorp Holdings Limited, Tabcorp Wagering (Vic) Pty Ltd, TAB Limited, Luxbet Pty Ltd and our other related bodies corporate;
(c) regulatory authorities and bodies that control or coordinate a racing code or sport, or are responsible for the integrity of a racing code or sport;
(d) government agencies responsible for enforcing the AML/CTF Act; and
(e) our employees and contractors, but only as needed to perform their jobs (they have obligations to treat the personal information they access as confidential).
7. Access and correction

The Privacy Policy tells you how you may access the personal information we hold about you and request its correction - see section V.

 

8. Complaints

The Privacy Policy tells you how you may complain about a breach by us of the APPs or any APP code applying to us, and explains how we will deal with your complaint - see section VI.

9. Disclosing personal information overseas


Currently we do not disclose your personal information to recipients located outside Australia.


PRIVACY POLICY

Sky Racing and Sky Sports Radio are committed to implementing practices, procedures and systems that:
• ensure we comply with the APPs (and any APP code applying to us); and
• allow us to deal with your enquiries and complaints regarding compliance with the APPs (or any APP code applying to us).

I. ABOUT THIS POLICY

Under the Privacy Act, 'personal information' is generally any information or opinions that identify you personally.

This Privacy Policy explains how we manage your personal information, including:
(a) the kinds of personal information we collect and hold;
(b) how we collect and hold your personal information;
(c) our reasons for collecting, holding, using and disclosing personal information;
(d) how you may access your personal information held by us and have it corrected;
(e) how you may complain about the way we deal with your personal information, and how we will deal with you complain; and
(f) whether we will disclose your personal information to overseas recipients, and if so the likely location(s) of those recipients.
By using the website at www.skyracing.com.au (Website) you accept this Privacy Policy. We may change this Privacy Policy as required at any time.  If we do, we'll post the updated version on the Website with the date of the changes.

II. KINDS OF INFORMATION WE COLLECT AND HOLD

This depends on your dealings with us, and what is required by the laws, regulations and licence conditions applying to us.

1. Online
When you subscribe to our media services, send feedback via the Website, or apply to advertise with us, we will ask for your:
• name;
• residential and email addresses; and
• telephone number.

We may also collect your:
• TAB or Luxbet account number (where required); and
• fax number.
2. AML/ CTF Act
Under the AML/ CTF Act we may have to:
• request further personal information from you; and
• retain the content of any email you send us.
3. Online behaviour
We may collect:
• your responses to promotions, giveaways and competitions;
• the time, date and URL of each request for a page from our web server, plus information on the browser software being used to make the request; and
• information from your computer or device allowing us to: analyse trends, administer the Website,  target your interests (by tracking your web navigation), and gather broad demographic information for aggregated use. 
To do this we may use cookies (pieces of data sent by a website to your computer and stored on the hard drive).  Cookies allow the website to identify and interact with your computer. We do not use cookies to retrieve information that was not originally sent by us to you in a cookie.

You can set your browser to accept or reject all cookies, or notify you when a cookie is sent.  If you reject cookies or delete our cookies, you may still use the Website, but may not have access to "account holder only" areas of it.

III. HOW WE COLLECT AND HOLD PERSONAL INFORMATION

Section 1 of the Collection Notice tells you how we collect Personal Information.

Sky takes reasonable precautions to protect the personal information it holds from:
(a)  misuse, interference and loss; and
(b) unauthorised access, modification or disclosure

These include: protection of passwords using industry standard encryption, measures to preserve system security and prevent unauthorised access, and back-up systems to prevent accidental or malicious loss of data.  Any paper copies are stored in locked cabinets or restricted access archive rooms.  Any identity documents or credit card information we collect will be stored in a secure database with limited access requiring a password or other unique identifier.

We may use third party providers to store personal information electronically.  We take reasonable steps to ensure this information is held as securely as information stored on our own equipment.

Unfortunately we cannot remove all risks involved in sending information through any channel over the Internet.  You send information over the Internet entirely at your own risk.

IV. HOW WE USE AND DISCLOSE PERSONAL INFORMATION

Sections 3 and 4 of the Collection Notice tell you the purposes for which we collect, hold, use and disclose personal information. Information about specific uses and disclosures is below.

1. Service providers
We disclose personal information to external service providers that assist us to:
(a) electronically verify your identity (including online);
(b) provide, manage and administer our products and services (including mailing houses, printers, advertising agencies, postal services, call centres and market research analysts);
(c) develop and market our products and services;
(d) assess risks under the AML /CTF Act; and
(e) comply with Payment Card Industry Standards, and securely manage processing of your credit card payments and storage of your credit card details.

2. Regulators/ industry bodies
We may disclose your personal information to:
(a) government authorities and law enforcement agencies;
(b) respond to an enquiry from a government agency under State or Federal laws (e.g. about child support);
(c) authorised sports controlling bodies (domestic and international);
(d) other organisations that coordinate a racing code or sport or are responsible for the integrity of a racing code or sport.
3. Related corporations
We may disclose personal information to our related bodies corporate, including:
• Tabcorp Holdings Limited;
• Tabcorp Wagering Manager (Vic) Pty Ltd;
• TAB Limited;
• Luxbet Pty Ltd; and
• other related bodies corporate as required from time to time,

so they can:
(a) comply with the laws, regulations and licence conditions applying to them; and
(b) send you marketing information directly.
4. Marketing

We also collect, hold, use and disclose your personal information for marketing purposes, in particular, to:
(a) let you know about upcoming events, promotions, and new products and services or other opportunities via direct mail, email, SMS, or MMS;
(b) enable our related bodies corporate to send you product and service information directly;
(c) identify your behaviour, habits and preferences; and
(d) send you product and service information on behalf of third parties.

Each time you are sent a marketing communication, you will have the option of opting-out from future marketing communications.  You can also opt-out from future marketing communications at any time (email: privacy@tabcorp.com.au).  We will promptly action any opt-out request.

V. HOW CAN I ACCESS AND CORRECT MY PERSONAL INFORMATION?

We will take reasonable steps to ensure the personal information we hold about you is accurate, up-to-date and complete.  Please let us know if there's a change to any of the details you have provided to us.

1. Access

You have a right to ask for access to the personal information we hold about you.  Please contact the Privacy Officer at:
Tabcorp, GPO Box 4168, Sydney NSW 2001
Telephone: +61 2 9218 1000; e-mail:  privacy@tabcorp.com.au
Your personal information will usually be available within 30 days of your request.  If there is a fee for accessing your personal information, we will confirm the amount before providing the information.
We may not give access to your personal information if the APPs do not require us to (e.g. because it would have an unreasonable impact on the privacy of others).

2. Corrections

You have a right to ask us to correct the personal information we hold about you.  Please contact the Privacy Officer at:
Tabcorp, GPO Box 4168, Sydney NSW 2001
Telephone: +61 2 9218 1000; e-mail:  privacy@tabcorp.com.au
It is not always possible to remove or modify information in our databases, but we will take reasonable steps to correct your personal information so it is accurate, up-to-date, complete, relevant and not misleading.  
If we decline to correct your personal information, you may request us to attach a statement that it is inaccurate, out-of-date, incomplete, irrelevant or misleading.   If we disclosed the information to a third party before correcting it, you may request us to notify the third party of the correction we've made.
We will not charge you for a correction request, for making a correction or for attaching a statement.
VI. MAKING COMPLAINTS

If you have a concern about how we have handled your personal information, please let us know so we can fix the problem. You can contact us at:
Privacy Officer
Tabcorp, GPO Box 4168, Sydney NSW 2001
Telephone: +61 2 9218 1000; e-mail:  privacy@tabcorp.com.au

To lodge a formal complaint, please send details to the Privacy Officer in writing.  We will respond within a reasonable time - usually 30 days.
If your complaint is not resolved by the Privacy Officer and concerns credit-related personal information, you may be able take it to an external dispute resolution scheme.  The Privacy Officer will give you details of the relevant scheme.
If your complaint is not resolved by our Privacy Officer or an external dispute resolution scheme, you can refer it to the Office of the Australian Information Commissioner. The contact details are:
Office of the Australian Information Commissioner
GPO Box 2999
Canberra ACT 2601, Australia
Phone: 1300 363 992
Fax: 02 9284 9666
www.oaic.gov.au
VII. DISCLOSURE OF PERSONAL INFORMATION OVERSEAS

Currently we do not disclose your personal information to recipients located outside Australia.  We will only disclose personal information to an overseas recipient if:
(a) we've taken reasonable steps to ensure that recipient does not breach the APPs (other than APP 1); or
(b) we reasonably believe that:
• a law or scheme in the country of the recipient includes requirements that are substantially similar to the requirements of the APPs; and
• you can take action to enforce that law or scheme; or
(c)  we have informed you of the disclosure and we have your express consent; or
(d) the APPs otherwise allow it.
VIII. SENSITIVE INFORMATION
We won't collect sensitive information, such as your:
• racial or ethnic origins;
• political opinions;
• religious or philosophical beliefs;
• sexual preferences or practices;
• criminal records; or
• health information;
unless:
(a) you consent; or
(b) it is required or authorised by law .

The AML / CTF Act may require us to collect sensitive information (for example, to verify your identity), and we may collect this from third parties.  The information will be stored securely in an AML / CTF Risk Register, and you will not have access to it.  You will not be informed that we have collected the sensitive information.
IX. HOW LONG CAN TABCORP KEEP MY PERSONAL INFORMATION?

If Tabcorp:
• no longer needs to use or disclose your personal information for any purpose that is authorised under the APPs; and
• is not legally required to retain that information,
then it will take reasonable steps to destroy the personal information or ensure it is de-identified.

Last updated: 12 March 2014

Additional Privacy Information

If you are interested in obtaining additional information of privacy, you can visit the Office of the Privacy Commissioner at www.privacy.gov.au


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