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Overview

Casino Canberra Limited and all its related bodies corporate (Casino Canberra) are committed to conducting business in a manner which is safe, ethical, professional and compliant with the law.

This Privacy Policy:

• sets out how Casino Canberra will comply with its obligations under the Australian Privacy Principles and the Privacy Act 1988 (Cth)(Privacy Act);
• describes the purposes for which Casino Canberra may collect, use and disclose personal information[1]. Subject to any applicable exceptions, it applies whenever Casino Canberra receives personal information about you, either directly or indirectly, through the use of Casino Canberra products or services, or through our business activity; and
• covers how you can communicate with Casino Canberra in relation to personal information that Casino Canberra may hold about you (including how you can ask Casino Canberra to correct your personal information and the means to make a complaint if you have a concern about how Casino Canberra has managed your personal information).

Collection of personal information

Casino Canberra will only collect personal information by lawful and fair means, and this information will only be used for the purposes it is collected.

The type of personal information collected by Casino Canberra about you will depend on our interaction with you. For example, more information may be required from you where you are applying to join our membership rewards program, than is required for the purposes of you entering a promotion.

Collection from you

It is Casino Canberra’s usual practice to collect personal information directly from you (for example, when products and services are used, or when you are entering into an arrangement with Casino Canberra).

Collection from third parties or public sources

In some instances, Casino Canberra may collect personal information about you from third parties or publicly available sources. For example:

• information about you from websites;
• credit reporting bodies (if we request information about your credit history); and
• other Casinos.

Collecting sensitive information

Casino Canberra will not usually collect sensitive information[2] about individuals.

However, information of this nature may be collected where:

• we are required to do so under a law that applies to our business;
• we have obtained an individual’s consent to do so;
• we are otherwise permitted by law to do so;
• an individual applies for a job with Casino Canberra; or
• an individual uses our gambling properties, and we are required to do this under laws that apply to our business (for example, a record of criminal offences).

Collecting information required by law

Casino Canberra also collects personal information where we are required to do so by an Australian law or court or tribunal order. For example, pursuant to:

• the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth);
• the Casino Control Act 2006 (ACT); and
• the Gambling and Racing Control Act 1999 (ACT) and Gambling and Racing Control (Code of Practice) Regulation 2002 (ACT) (Code of Practice); and
• the Public Health Act 1997 (ACT) and any relevant public health directions issued thereunder.

Use of personal information

Casino Canberra may use your personal information to keep you informed about our products and services, and the products and services of third parties with whom Casino Canberra has a relationship (where they are relevant to your continued use of those products and services).

Information about the way and frequency with which you use our products and services may be used by Casino Canberra for purposes of quality control and to develop and improve the products and services that we are able to offer.

Casino Canberra may collect and hold your personal information (and share that information with related body corporates) for reasons including:

• to identify you;
• the provision of requested products or services and benefits gained in relation to that product or service;
• management and administration of ongoing products and services;
• assessing your employment suitability;
• obtaining credit reports from a credit reporting agency to assess applications for credit or a cheque cashing facility;
• to assist Casino Canberra in adhering to responsible gambling policies and other regulatory requirements;
• for contact tracing purposes; and
• to fulfil our legal obligations under legislation such as that stated in the section headed “Collecting information required by law” above.

Marketing

Casino Canberra may collect and use personal information to promote and market third party’s or our own products and services, promotions and upcoming events (including, for example, by way of direct mail, telemarketing, targeted digital advertising, SMS, MMS messages, and notifications and alerts to your mobile device).

Casino Canberra will only send you such marketing information if:

• you have indicated your consent to receiving such information;
• such information is related to the purpose for which Casino Canberra originally collected the personal information; or
• when otherwise permitted to do so under relevant laws.

Casino Canberra will send marketing information (subject to paragraph 3.5) to keep you informed of our products and services, promotions, special offers and the like.

You may opt out of receiving direct marketing communications by following the directions in our direct marketing material. For example, by using the unsubscribe facility in our email correspondence, the opt-out facility for SMS messages, or at any time by contacting us (see contact information below).

Casino Canberra may use external service providers to assist us in these marketing activities.

Security

Casino Canberra may collect and use personal information about you for security purposes, including:

• collecting information from your passport, driver’s licence or other identification document/card when you enter the premises or undertake particular transactions; or
• using information from your passport, driver’s licence or other identification document/card, to match with personal information we hold about you.

Casino Canberra’s premises are subject to CCTV surveillance for security reasons. Casino Canberra may collect your personal information through these means.

Details of suspected or actual illegal and undesirable activities and other security-related information may be shared with other casinos, law enforcement bodies and regulatory bodies such as the casino regulator in the Australian Capital Territory (ACT Gambling and Racing Commission). This may include both disclosure of your personal information by us, and the receipt of your personal information by us.

Information collected from your electronic devices

When you visit the Casino Canberra website, or use our other online resources, we may use cookies, single pixels tags and similar tracking technologies, including a range of tools provided by third parties such as Facebook and Google, to collect or receive information and then use that information to:

• provide better online experiences;
• deliver more relevant and targeted advertising; and
• develop reports on matters such as usage trends and visitation data. These reports may then be shared with third party marketing partners.

The information collected and used may include your Internet Protocol (IP) address; domain name; browser type; date and time of your request; your internet service provider, mobile carrier, or data services provider; and your online behaviour, such as information on the pages you visit, links you click, features you use, how and when you interact with the services, the content, images and advertisements you select.

If you use a mobile device to access our websites or online resources, we may collect information about your device, such as your device ID and device type, as well as usage information about your device and your use of our mobile websites and other mobile resources.

Most internet browsers and mobile devices can be set to inform you when tracking technologies are being used or sent to your device. They also provide you with the option of refusing the use of tracking technologies, however, this may negatively impact the display or function of certain areas or features of our services.

Disclosure of personal information

As required by law or for enforcement purposes

• Casino Canberra may disclose personal information where:
• required, or authorised, to do so by or under law[3]; or
• disclosure is reasonably required to enforce the law, or for enforcement related activities[4] conducted by or on behalf of an enforcement body[5].

Laws which may necessitate this type of information sharing include:

• Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth);
• the Public Health Act (ACT) and any relevant public health directions issued thereunder;
• Casino Control Act 2006 (ACT);
• Gambling and Racing Control Act 1999 (ACT) and Gambling and Racing Control (Code of Practice) Regulation 2002 (ACT) (Code of Practice); and
• Income Tax Assessment Act 1997 (Cth).
• In particular, Casino Canberra may share your personal information with the ACT Gambling and Racing Commission under the Casino Control Act 2006 and the Code of Practice in fulfilment of its obligations under those laws.

Sharing information with other organisations

Casino Canberra may disclose personal information to another organisation for particular purposes that are important to help us operate our business.

We will not sell your personal information to organisations outside Casino Canberra.

Casino Canberra will only give another organisation access to your personal information when:

• the other organisation is providing services to us that help us to operate our business or to provide a product or service to you;
• there is another business reason for us to provide your personal information to that organisation; or
• we are required or permitted by law to provide your personal information to that organisation.
• Where practical, Casino Canberra requires these organisations to agree to this Privacy Policy, meet strict conditions on the use of personal information, and to comply with the Australian Privacy Principles in the use, storage and disclosure of personal information.

The organisations with whom we may share your personal information include those that assist us:

• to provide, manage or administer the products and services that we offer. This includes service providers (such as mail house providers, printers and advertising agencies), postal services, call-centres, customer research agencies and our advisers;
• to maintain, review, and develop our business systems, procedures and infrastructure, including testing or upgrading our computer software;
• with reviews of our business operations and structure; and
• with developing and planning new products and services.

Casino Canberra may share personal information with another organisation in relation to potential or threatened legal proceedings or disputes (whether between you and that organisation or between us and that organisation), including for the purposes of gaining legal advice, or to take action considered appropriate in relation to suspected unlawful activity or serious misconduct, including investigating any such alleged activity.

Casino Canberra may also share personal information with an organisation where we have obtained the individual’s consent.

Disclosing your personal information overseas

For international guests, we may share your personal information overseas with your agents and/or representatives (including, but not limited to your tour operator or arranger and their representatives) in your country of origin. In addition, we may share your personal information to conduct credit or other background checks, including with other casinos and credit rating and other reporting agencies in other jurisdictions.

Your personal information may also be accessed and used by our service providers located outside Australia who assist us to send marketing communications to you.

When we disclose personal information overseas we will take reasonable steps to ensure that the overseas entity complies with the Australian Privacy Principles, unless an exception applies under those principles such that we are not required to do so. We will take reasonable steps to put in place suitable confidentiality protections in relation to personal information we provide to an overseas entity.

Security of personal information

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Casino Canberra will take reasonable steps to protect your personal information and monitor that it is accurate, up-to-date and, when that personal information is used or disclosed, relevant to the purpose for which the information is being used or disclosed.

Your personal information is held on secure servers or in storage located in controlled environments.

Casino Canberra employees and service providers are required to maintain the confidentiality of any personal information held by us.

Access to and correction of personal information

You may request details of the personal information that Casino Canberra holds about you by contacting our Privacy Officer (refer section 8 below).

A copy of your personal information will generally be made available to you within 30 days unless there is an exception which applies under the Privacy Act[6]. We may also require personal identification from you before providing you with any requested details.

If we intend to charge you a fee for us to find the information you have requested, we will inform you of this cost before we provide the information to you.

If you find that any personal information we hold about you is inaccurate, incomplete or out-of-date, please contact our Privacy Officer. It may take up to 30 days to update our records.

Making a privacy complaint

Should you wish to complain about a breach of the Privacy Act by Casino Canberra, please submit the complaint, in writing, to our Privacy Officer (refer section 8 below).

Any complaint should set out in as much detail as possible, all the relevant particulars relating to the complaint, including why you say that Casino Canberra has breached the Privacy Act.

Upon receiving a written complaint, Casino Canberra will acknowledge receipt of the complaint in writing within 7 days.

Casino Canberra will investigate the matters described in the complaint and then provide a substantive written response within 30 days from the date the written complaint was received by Casino Canberra.

How to contact Casino Canberra

If you have a question in relation to your personal information or this Policy, or wish to lodge a complaint, please contact us using the details below:

Privacy officer

Crown Casino Canberra Buffet Palace

Casino Canberra Limited
PO Box 262
Civic Square ACT 2608

or

Email: compliance@casinocanberra.com.au
Attention: Privacy Officer

Administration of this Policy

The Compliance Manager/ In-house Legal Counsel is responsible for maintaining this Policy.

Casino Canberra reserves the right to amend this Policy or any part of it from time to time. To notify you of this, we will place the revised Policy on our website[7] and you should periodically review this Policy on the website.

In addition, this Policy will be reviewed annually.

Any amendments to this Policy will be approved by the Chief Executive Officer.

Key terms used in document

In this document:

Enforcement body includes (among others):

• the Australian Federal Police;
• the Australian Crime Commission;
• the Australian Prudential Regulation Authority;
• the Australian Securities and Investment Commission; and
• a police force or service of a State or Territory;

Enforcement related activity means:

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• the prevention, detection, investigation, prosecution or punishment of criminal offences; or breaches of a law imposing a penalty or sanction;
• the conduct of surveillance activities, intelligence gathering activities or monitoring activities;
• the conduct of protective or custodial activities;
• the enforcement of laws relating to the confiscation of the proceeds of crime;
• the protection of the public revenue;
• the prevention, detection, investigation or remedying of misconduct of a serious nature, or other conduct prescribed by the regulations; or
• the preparation for, or conduct of, proceedings before any court or tribunal, or the implementation of court/tribunal orders;

Personal information means information or an opinion about an identified individual or an individual who is reasonably identifiable. This may include (without limitation) an individual’s name, postal or email address, telephone number, driver’s license, date of birth, image and financial details; and

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Sensitive information is a subset of personal information and includes information about an individual’s:

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• racial or ethnic origin;
• political opinions;
• membership of a political association;
• religious beliefs or affiliations;
• philosophical beliefs;
• membership of a professional or trade association;
• membership of a trade union;
• sexual preferences or practices,
• criminal record; or
• health.

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[1] Refer to section 10 below for a definition of personal information.
[2] Refer to section 10 below for a definition of sensitive information.
[3] This may include disclosures, where authorised by law, to government agencies such as the Australian Taxation Office, Centrelink and the Child Support Agencies.
[4] Refer to section 10 below for a definition of enforcement related activities.
[5] Refer to section 10 below for a definition of enforcement body.
[6] See, for example, Australian Privacy Principles at paragraph 12.3
[7] At www.casinocanberra.com.au