Privacy Policy

This is the privacy policy ("Privacy Policy") of PlayUp Interactive Pty Ltd (ABN 79602262644) trading as "BestBet".

BestBet is subject to the Privacy Act 1988 (Cth) ("Privacy Act").

BestBet is a member of the Credit and Investments Ombudsman (CIO) and is regulated by the Office of the Australian Privacy Commissioner (OAIC).

This Privacy Policy details how BestBet will handle and manage your personal information which it collects as a result of your account with or use of BestBet, your use of BestBet websites located at www.bestbet.com.au or m.bestbet.com.au or bestbet.mobi or any pages or websites under the 'BestBet' brand and any 'BestBet' mobile phone or tablet applications that are owned and/or operated by us (together, "the website") or by telephone or whenever BestBet otherwise deals with you. BestBet is committed to ensuring that the personal information collected about you is protected and is used, stored and disclosed in accordance with the Privacy Act and this Privacy Policy.

When collecting, using and managing personal information, BestBet is required to comply with the Privacy Act 1988 (Cth) (Privacy Act) and is bound by the Australian Privacy Principles (APPs) set out in the Privacy Act.

In this Privacy Policy, personal information (as defined in the Privacy Act) means information or an opinion about an identified individual, or an individual who is reasonably identifiable (whether the information is true or not, and whether it is recorded in any form or not).

If you are provided credit on your betting account, BestBet will collect credit-related information about you.

In using the service you agree to have read and irrevocably be bound by the terms of this Privacy Policy.

BestBet may review its Privacy Policy periodically and reserves the right to change the Privacy Policy at any time at its discretion by posting such changes on the website. Changes will be effected immediately when posted on the website. Your continued use of the service following posting will constitute your acceptance of those changes.

This Privacy Policy will not apply to websites which are linked to the website and over which BestBet has no control. In this Privacy Policy, a reference to "Australian Privacy Principles" (APPs) means the APPs contained in the Privacy Act.

Personal information

The kinds of Personal Information that BestBet generally collects from you and holds are:

• Name
• Home address
• Email
• Phone number
• Date of birth
• Gender
• Photographs or images
• Personally submitted preferences
• Bank account and credit card information
• Financial information.
• Other Identity verification information (i.e. email address, phone numbers)
• Information about applications for credit with BestBet or other credit providers, and the type and amount of credit applied for;
• Information about any aspect of your credit history;
• Credit-related information for any purpose relating to the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), and/or required under State or Territory legislation that regulates wagering.

How BestBet collects and holds your personal information

BestBet obtains your personal information from you or from credit reporting and credit reference agencies in Australia. The information is securely held off-site in a secure cloud environment with all necessary security features.

The purposes for which your personal information is collected, held and disclosed

BestBet will collect your Personal Information only by lawful means and not in an intrusive way for the purposes of operating its business as a licensed online wagering bookmaker, and also for the following purposes:

• to process your application to become a member of BestBet ("Member")
• to provide services to you as a Member
• to identify you as a Member for security purposes and to comply with our legal obligations
• to maintain your Member betting account
• to subscribe you to BestBet's weekly newsletter
• to upgrade and enhance your experience within the website or over the telephone, or to tailor or develop information, services or products to suit your needs which may include market research and conducting promotions
• to tell you about our products or services that we think may be of interest to you by communicating with you via email, SMS or telephone
• to create aggregate data about Members through demographic profiling, statistical analysis of the database to provide to potential and existing stakeholders, and to allow for more efficient operation of BestBet's business
• to determine Members' liability to pay goods and services tax and other taxes where applicable
• to comply with BestBet.com.au's legal and statutory obligations including in relation to customer identity verification and reporting obligations imposed by the Anti-Money Laundering and Counter Terrorism Act 2006(Cth) (AML/CTF Act) and the Northern Territory Racing Commission Racing and Betting Act 2011 (Racing and Betting Act) licensing obligations
• for taking appropriate action if BestBet has reason to suspect that unlawful activity or misconduct of a serious nature has been, is being or may be engaged in that relates to our functions and activities
• to establish, exercise or defend any legal claims;
• assess creditworthiness;
• provide to agents or debt collectors for the purpose of collecting overdue payments,
• to notify credit reporting bodies or other credit providers of a default or serious credit infringement; and
• assist or seek to assist you to avoid defaulting on repayment obligations.

Please note that Section 21G of the Privacy Act and obligation 16.1 of the CR Code prohibit BestBet from using or disclosing credit eligibility information except in specified circumstances. These include where the use is consumer related, where BestBet believes on reasonable grounds that the individual has committed a serious credit infringement and/or where BestBet is required or authorised to do so by or under an Australian law or a court/tribunal order. BestBet only uses or discloses credit eligibility information about an individual where it is entitled to do so under these provisions.

If BestBet refuses your application for credit and the refusal is based wholly or partly on credit eligibility information, BestBet will provide you with a written notice within a reasonable time stating that your application has been refused, the reason for the refusal and any other matter BestBet is required to bring to your attention under the Privacy Act and CR Code.

You may choose to deal with BestBet on an anonymous basis or to use a pseudonym unless it is not practicable for BestBet to deal with individuals who BestBet cannot identify or that BestBet is required by law to only deal with identified individuals (such as under the AML/CTF Act). Also, if you do not provide BestBet with the Personal Information we request, BestBet may be unable to process your application to become a Member, provide you with BestBet's services or respond to your enquiry or complaint.

By becoming a Member or otherwise choosing to provide BestBet with Personal Information you consent to BestBet collecting, using and disclosing your Personal Information for the above purposes.

How you may access and correct of your Personal Information

In order to ensure you have access to the most up-to-date information, you should consider requesting access to the information that credit-reporting bodies hold about you.

You may access the credit-related information that BestBet holds about you by contacting the Head of Credit on the details provided below. To do so, you will need to provide evidence to confirm your identity before BestBet can provide access. BestBet will respond to all requests for access as quickly as practicable, but in any event within a few days.

You may also access the Personal Information collected by BestBet by following the My Account link on the website or by contacting us on the Customer Service hotline on 1800 237 823.

You may also seek to access your Personal Information records held by BestBet by contacting the BestBet compliance officer as follows:

The Compliance Manager
PlayUp Interactive Pty Ltd
48 Epsom Raod
Zetland NSW 2017
Tel: 1800 237 823
Email: [email protected]

BestBet may refuse a request for access in certain circumstances set out in the Privacy Act, including where:

• providing access would be unlawful;
• BestBet is not satisfied as to the identity of the party making the request for access;
• BestBet is required or authorised to do so by or under an Australian law or court/ tribunal order; or
• where giving access would be likely to prejudice legal enforcement related activities by or on behalf of an enforcement body;
• BestBet is not satisfied as to the bona fides of the requested access.

If BestBet refuses your request, BestBet will notify you of the refusal in writing, the reasons for the refusal (unless it would be unreasonable to do so) and explain the complaint mechanisms available to you if you wish to take the matter further.

BestBet will take reasonable measures to correct credit-related information if BestBet is satisfied that it should be corrected. BestBet may contact you on a periodic basis to seek the most up-to-date information from you.

If you believe that the credit-related information BestBet holds about you is inaccurate, incomplete, irrelevant or misleading, or not current, please contact BestBet's Compliance Officer as follows:

The Compliance Manager
PlayUp Interactive Pty Ltd
48 Epsom Raod
Zetland NSW 2017
Tel: 1800 237 823
Email: [email protected]

If BestBet is satisfied that a correction is required, we will take reasonable steps to correct the information promptly.

In considering your request, BestBet may need to consult with a credit reporting body or other credit provider that held or holds the relevant information about you.

If BestBet corrects your information BestBet will confirm this in writing (and BestBet will also notify any credit reporting body or credit provider with whom BestBet has consulted in relation to the correction).

If BestBet is not satisfied that a correction is required, BestBet will confirm this in writing and explain why, including evidence showing that the information is correct.

If you are dissatisfied with BestBet's response to your request to correct the credit-related information that BestBet holds about you, you may make a complaint to BestBet's Head of Credit as per the procedure detailed below.

How you may complain about a breach of the Australian Privacy Principles or other privacy complaints

If you have any complaints relating to the handling of your Personal Information, please contact the BestBet Compliance Manager, whose contact details are as follows:

The Compliance Manager
PlayUp Interactive Pty Ltd
48 Epsom Raod
Zetland NSW 2017
Tel: 1800 237 823
Email: [email protected]

BestBet is a member of a recognised external dispute resolution (EDR) scheme, The Credit & Investments Ombudsman (C.I.O). This organisation offers an impartial dispute resolution scheme to assist consumers to resolve complaints with participating service providers such as ourselves.

If you have a complaint or disagree with our handling of credit-related information, you may refer the matter pursuant to the EDR scheme.

You may do this whether or not you have first contacted BestBet about the complaint. Contact details for BestBet's EDR Scheme are as follows:

Post: Credit & Investments Ombudsman (C.I.O) - Case Management
PO Box A252, Sydney South, 1235, NSW
Tel: 1800 138 422
Fax: (02) 9273 8440
Website: http://www.cio.org.au/

Further Information about privacy concerns or complaints in Australia can be found on the Office of the Australian Privacy Commissioner's website at www.oaic.gov.au.

Disclosure of Personal Information to overseas recipients

BestBet does not disclose Personal Information to overseas recipients, except and unless compelled to do so by law.

Disclosure to and by credit reporting bodies

BestBet exchanges credit-related information with credit reporting bodies (in particular Equifax Information Services and Equifax Pty Limited (formerly Veda Australia Pty Ltd)) and other credit providers.

Where BestBet discloses credit information to a credit reporting body under section 21D of the Privacy Act, BestBet makes a record of that disclosure.

BestBet would usually disclose the following credit-related information about you to Equifax:

• identification details;
• that you have applied for credit with BestBet;
• that BestBet is a current credit provider to you;
• whether you have met, or failed to meet, your repayment obligations to BestBet;
• details of you defaulting on a repayment (i.e. a repayment of more than $200 that is at least 60 days overdue) provided BestBet has notified you as required by the Privacy Act;
• you having paid any amount previously reported as being in default;
• BestBet's belief, on reasonable grounds, that you have committed a serious credit infringement; and
• details of credit that BestBet has provided to you being paid or otherwise terminated.

You can contact Equifax directly to request that they do not use credit reporting information about you for the purpose of pre-screening of direct marketing by a credit provider, or that they do not use or disclose credit reporting information about you if you believe on reasonable grounds that you have been or are likely to be a victim of fraud.

BestBet may exchange credit-related information with Equifax, other credit reporting bodies and other credit providers, as to the status of credit arrangements where you are in default with other credit providers.

Where BestBet is entitled to and does disclose default information about an individual to a credit reporting body under section 21D of the Privacy Act, and the amount of the overdue payment is thereafter paid, BestBet normally also discloses information to the credit report body about the amount paid by you.

Your Personal Information may be stored by Cookies

Personal Information may also be collected by cookies when you use the website. Cookies are pieces of data stored by your web browser on your hard drive which contain information relating to your use of the website.

When you access the website, cookies may record details relating to your use of the website, including what pages you view from the website. BestBet does not use cookies to track your Personal Information and uses them for internal management purposes only.

We may use third-parties to serve ads on our website. These companies may employ cookies and action tags (also known as single pixel gifs or web beacons) to measure advertising effectiveness. Any information that these third parties collect via cookies and action tags is completely anonymous.

Direct marketing and opting out

From time to time we may use your Personal Information to inform you about BestBet's products or services or about promotional activities which BestBet believes may be of interest or of benefit to you. We may do this via email, SMS, telephone or mail. When you opt-in to receive this marketing material you may receive marketing material from any business in the PlayUp Group.

If you no longer wish to receive marketing or promotional material from BestBet at all or in any particular form, you may contact us at any time by email to [email protected] with your request with which we will comply as soon as is practical.

From time to time we may contact you in relation to the management and administration of your BestBet account. These communications can be via any of the modes of contact recorded when registering as a Member. Such communication does not affect your opt-in or opt-out status for direct marketing communications.

Destruction of your Personal Information

BestBet will destroy or permanently de-identify the Personal Information we hold when it is no longer required for any purpose permitted under the APPs including our legal or operational obligations.

Disclosure of your personal Information to Third Parties

Personal Information collected by BestBet may be disclosed to a third party in the following circumstances:

• to associated entities, agents and affiliates who undertake promotional and marketing activities on our behalf (including contacting you with special offers that may be of interest);
• to organisations that provide services (including IT, consultancy and advisory services) to us;
• to any particular third parties or classes of third parties that BestBet notifies you at the time of collecting your personal information that your personal information may be disclosed to;
• for taking appropriate action if we have reason to suspect that unlawful activity or misconduct of a serious nature in relation to our services has been, is being or may be engaged in;
• to protect and maintain the integrity of particular sports / racing codes, by assisting controlling bodies in their inquiries or notifying such bodies of any betting activity BestBet considers to be unusual or suspicious;
• where you have consented to the disclosure either expressly or by the circumstances and your conduct;
• where BestBet considers disclosure is reasonably necessary to eliminate or minimise a risk to public health or safety,
• where BestBet considers disclosure is reasonably necessary to investigate or deal with unlawful activity or serious misconduct;
• where BestBet considers disclosure is reasonably necessary to locate missing persons;
• to establish or defend a legal claim; or
• where the disclosure is required or authorised by law.

BestBet will take all reasonable steps to ensure that any Personal Information which BestBet discloses to a third party is protected by that party in accordance with the Privacy Act.

Security of Personal Information

You acknowledge that no data transmission over the Internet is 100% secure.

Accordingly, BestBet does not warrant the security of any information which you transmit to it. Any information which you transmit to BestBet is transmitted at your own risk. However, once BestBet receives your transmission, BestBet will take reasonable steps to protect your Personal Information from misuse, loss and unauthorised access, modification and disclosure including by using password protected systems and databases and Secure Socket Layer ("SSL") technology.

BestBet's employees, agents and contractors are required to maintain the confidentiality of Members' Personal Information and trading behaviour at all times.

Information posted on bulletin boards or communicated within a social media environment (for example, Facebook, Twitter, Chat Rooms) becomes public information. BestBet cannot guarantee the security of this type of disclosed information.

BestBet takes seriously the responsibility to exclude children from access to our services. We will not accept their information for the purposes of opening a wagering account. It is however, ultimately the responsibility of parents or guardians to monitor their children's Internet activities including where appropriate by using Internet screening software.

Remember to always log out of your account when you have completed your time on the website.

This is particularly important if you share a computer with another person. You are responsible for the security of and access to your own computer, mobile device or any other handset used to access the website.

Ultimately, you are solely responsible for maintaining the secrecy of your username, password and any account information. Please be careful whenever using the Internet and our website.

Use of website

By using this website you agree to BestBet collecting and processing your Personal Information on the basis explained in this Privacy Policy.

Updates to this Privacy Policy

BestBet may review, change and update this Privacy Policy from time to time reflect BestBet's current practices and obligations. BestBet will publish our current Privacy Policy on our website at www.BestBet and the changes will take effect at the time of publishing. You should review this privacy policy regularly and remain familiar with its terms.

For a copy of our current Privacy Policy, please contact us at the contact details above.

Last updated: June 2018

Correction and Updating of Personal Information

Bestbet takes reasonable measures to ensure that Personal Information which it collects is accurate, complete and current and will make contact with you on a periodic basis to seek the most up to date information from you. If you believe that the Personal Information Bestbet holds about you is inaccurate, incomplete or not current, please let Bestbet know and we will correct it. The Personal Information collected can be changed by entering the Edit Account Details in the Account section after logging on. Details of your transaction history can be found in the All Bets and Open Bets areas of the website.

CONSENT

You consent to the use or disclosure of your Personal Information in conditions which are:

• set out in this privacy policy;
• relayed to you when any Personal Information is collected from you
• Or permitted under the National Privacy Principles.

For further Information about privacy issues in Australia, you can visit the website located at www.privacy.gov.au.

If you have any queries or complaints relating to the handling of your personal information, please contact Bestbet on 08 89146532 or [email protected]