Tabcorp Holdings Limited ABN 66 063 780 709 of 5 Bowen Crescent, Melbourne VIC 3004 (Tabcorp, we, us, our) is bound by the Privacy Act 1988 (Cth) (Privacy Act) and Australian Privacy Principles (APPs).
You can contact our Privacy Officer to discuss any privacy related queries you may have - email email@example.com or telephone +61 2 9218 1000.
Collection notice (APP 5)
1. How we collect your personal information
Generally we collect personal information 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:
- our share registry provider, Link Market Services Limited;
- other companies in the Tabcorp group (related bodies corporate);
- institutional investors (e.g. banks) that offer customers investment products incorporating Tabcorp shares;
- 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);
- government agencies in connection with court proceedings;
- State regulatory bodies to confirm whether you are a voluntarily self-excluded patron in Australia or any other country.
2. What we are legally required to collect?
We may be legally required to collect personal information under:
- the Corporations Act 2001 (Cth) (Corporations Act); and
- ASX Listing Rules and Settlement Operating Rules (ASX Rules).
We may also be required to collect personal information for the purposes of investigations conducted by law enforcement agencies like the Australian Federal Police, the Australian Crime Commission or the Australian Securities and Investments Commission.
3. Our main reasons for collecting your personal information
- To identify you.
- To administer and manage the ownership of Tabcorp shares (including entitlements to dividends, voting and title).
- To identify underlying beneficial owners of shares held by institutions (e.g. banks).
- To comply with our legal obligations, including under the AML/CTF Act, the Corporations Act and the ASX Rules.
- To manage, administer and control the quality of any product or service you request.
4. Our other reasons for collecting, holding, using and disclosing your personal information
- To develop and improve the products and services offered by the Tabcorp group.
- To market the products and services of our related bodies corporate, and to enable those companies to market directly to you.
- To assist you with enquiries or complaints.
- To assess whether you pose a risk to the businesses of the Tabcorp group.
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 issue or administer any Tabcorp shares you have applied for. You may also be unable to receive products and services provided by our related bodies corporate. For example:
- we may not be able to pay you dividends;
- we may not be able to send you important shareholder communications like proxy forms or annual reports;
- you may not be able to vote on resolutions at Tabcorp’s Annual General Meetings.
6. Disclosures to third parties
Generally we only give your personal information to:
- external providers of services we use to operate our business and manage our business systems (e.g. our share registry provider, advertising agencies, market research analysts, mailing houses, printers, call centres, IT consultants, and providers of client relationship, product development, payment processing and identity verification services);
- Tabcorp Wagering (Vic) Pty Ltd, TAB Limited, Luxbet Pty Ltd, Tabcorp Gaming Solutions Pty Ltd, Sky Channel Pty Ltd and our other related bodies corporate;
- government agencies responsible for enforcing the AML/CTF Act; and
- 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
9. Disclosing personal information overseas
Currently we do not disclose your personal information to recipients located outside Australia.
Tabcorp is 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 considered any information or opinion that identifies you personally.
- the kinds of personal information we collect and hold;
- how we collect and hold your personal information;
- our reasons for collecting, holding, using and disclosing personal information;
- how you may access your personal information held by us and have it corrected;
- how you may complain about the way we deal with your personal information, and how we will deal with your complaint; and
- whether we will disclose your personal information to overseas recipients, and if so the likely location(s) of those recipients.
II. Kinds of information we collect and hold
This depends on your dealings with us, and what is required by the laws and regulations applying to us.
To become a Tabcorp shareholder you need to provide your:
- name; and
- residential and email addresses.
We will also require copies of identification documents, such as:
- driver’s licence;
- birth certificate; and/or
- utility bills.
Once you have invested, we may collect:
- your bank account details;
- your security holder identification number;
- your instructions for delivery of shareholder communications;
- copies of any Power of Attorney you grant (or details of that Power of Attorney);
- your Tax File Number or ABN exemption; and
- copies of shareholder correspondence sent and received.
We also collect names and contact details of managers and key personnel at institutions (e.g. banks) which offer customers investment products incorporating Tabcorp shares.
2. Information from other Tabcorp companies
Our related bodies corporate may provide us with information about you such as:
- contact details;
- date of birth;
- copies of identification documents;
- lifestyle or betting frequency information; and
- recordings of telephone calls you have made to call centres that are managed by our related bodies corporate.
3. AML/CTF Act
Under the AML/CTF Act we may have to request further personal information from you (e.g. your occupation and/or your employer).
4. Online behaviour
We may collect information regarding your online behaviour, including:
- your responses to promotions, giveaways and competitions offered by us or our related bodies corporate;
- the time, date and URL of each request for a page from our web server; and
- information from your computer or device allowing us to: analyse trends, administer the Website, track web navigation, and gather broad demographic information for aggregated use.
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 any restricted areas of it.
III. How we collect and hold personal information
Section 1 of the Collection Notice tells you how we collect Personal Information.
Tabcorp takes reasonable precautions to protect the personal information it holds from:
- misuse, interference and loss; and
- 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. Documents verifying your identity and any 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 data storage 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:
- electronically verify your identity (including online);
- provide, manage and administer products and services and business systems (including mailing houses, printers, advertising agencies, postal services, call centres, IT technicians and providers of client relationship management (CRM) services);
- develop and market products and services (including market research analysts);
- assess risks under the AML/CTF Act;
- comply with Payment Card Industry Standards, and securely manage processing of your credit card payments and storage of your credit card details; and
- analyse trends and aggregated demographic information, and target your interests.
We may disclose your personal information to:
- regulators and law enforcement agencies; or
- respond to an enquiry from a government agency under State or Federal laws (e.g. about child support).
If the AML/CTF Act requires us to collect information about transactions on your betting account, we may disclose that information to other betting and gambling operators, book makers and government authorities. We will not tell you when your transactions are being monitored, or when we disclose any personal information obtained.
If there is an obligation on us or a related body corporate to record any of your telephone calls, we may disclose those recordings as required by the AML/CTF Act, law enforcement agencies, and regulators. We will not notify you when we make those disclosures.
3. Related corporations
We may disclose personal information to our related bodies corporate, including:
- Tabcorp Wagering (Vic) Pty Ltd;
- TAB Limited;
- Luxbet Pty Ltd;
- Keno (Qld) Pty Ltd;
- Keno (NSW) Pty Ltd;
- Tabcorp Investments No. 5 Pty Ltd;
- Tabcorp Gaming Solutions Pty Ltd;
- Sky Channel Pty Ltd; and
- other related bodies corporate as required from time to time,
so they can:
- comply with the laws, regulations and licence conditions applying to them; and
- send you marketing information directly.
We may also use and disclose your personal information to:
- let you know about upcoming events, promotions, and new products and services or other opportunities via direct mail, email, SMS, or MMS;
- enable our related bodies corporate to send you product and service information directly;
- identify your betting behaviour, habits and preferences; and
- 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: firstname.lastname@example.org). 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.
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: email@example.com
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.
In some circumstances we may not be able to grant you access to your personal information (for example, if the release of your personal information would have an unreasonable impact on the privacy of others). Please see the APPs for further information.
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: firstname.lastname@example.org
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 make your requested correction, you may request us to attach to your personal information 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 to request a correction, 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: email@example.com
To lodge a formal complaint, please send details to the Privacy Officer in writing. We will attempt to 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
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:
- we’ve taken reasonable steps to ensure that recipient does not breach the APPs (other than APP 1); or
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
- we have informed you of the disclosure and we have your express consent; or
- 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 record; or
- health information;
- you consent; or
- it is required or authorised by law.
We may request sensitive information where:
- you apply for a job with Tabcorp;
- you apply for self-exclusion from our venues; or
- you apply for a minimum bet exemption.
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?
- 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.
Requests for Information
As a result, Tabcorp cannot release customer information unless a customer consents to the release or it is legally compelled to do so.
From time to time Tabcorp receives subpoenas from law firms, or members of the public and other interested parties.
In order for Tabcorp to respond to the subpoena, the Tabcorp entity which is the subject of the subpoena must be correct. If the person of interest holds an account with a Tabcorp group entity it will be with one (or more) of:
- Tab Limited (the NSW licensee)
- Tabcorp Wagering Participant (Vic) Pty Ltd (the Victorian licensee)
- Tabcorp ACT Pty Ltd (the ACT licensee)
- Luxbet Pty Ltd (the NT licensee)
Due to privacy reasons, we are unable to disclose whether the person of interest holds an account with one or more of these entities.
Subpoenas should therefore be served on the appropriate company or, if the appropriate company is not known, all such entities. In the latter case, there is no need for separate subpoenas for each entity.
While correspondence regarding subpoenas should be sent to the following address, the subpoena itself should be served on each of the above entities.
The Proper Officer
Tabcorp Holdings Limited
c/o Regulatory Team
Level 31, 680 George Street
Sydney NSW 2000
Alternatively, please email any correspondence to firstname.lastname@example.org
Last updated: 24 October 2016