Privacy Policy

PRIVACY POLICY

INTRODUCTION
Club Willoughby is committed to protecting your privacy, keeping your information
safe, ensuring the security of your data, allowing you access to this privacy policy and
to your personal information.
The Club understands the importance of maintaining members’, guests and
employees’ trust and confidence. The Club shall ensure that the personal
information you provide to the Club is only used in a manner consistent with this
Privacy Policy.

OBJECTIVE
This Privacy Policy describes the purposes for which the Club may collect, use and
disclose your personal information and how it manages personal information held by
the Club. Personal information means information or an opinion about an identified
individual, or an individual who is reasonably identifiable:
a) whether the information or opinion is true or not.
b) whether the information or opinion is recorded in a material form or not.

PRIVACY COMMITMENT
We are committed to complying with our obligations under the Privacy Act 1988 (Cth)
(Privacy Act) by protecting the privacy and confidentiality of your personal
information.
When we collect, use, disclose, store, access or correct your personal information, our
actions will comply with the Privacy Act and the Australian Privacy Principles.
Where appropriate, we will handle your personal information relying on the
employee records exemption and the related bodies corporate exemption in the
Privacy Act.

PERSONAL INFORMATION
In general, we collect personal information so that we can perform our business
activities and functions and to provide best possible quality of customer service.
We also collect personal information to comply with statutory requirements under
legislation relating to registered clubs, liquor, gaming, anti-money laundering,
counterterrorism and other legislation which may apply to the Club.
What kinds of personal information does Club Willoughby collect and hold?
We may collect and hold a wide range of personal information, and in some cases
sensitive information, including but not limited to:
• your personal details, including your full name, residential address, email
address, contact number, date of birth, gender, and occupation.
• your signature.
• information related to your entry to Club premises.
• an image of your driver’s license or other identification if you choose to scan
your ID when entering the Club’s premises, including any information obtained
from that identification (you have the option not to have your ID scanned and
for the required information to be manually inputted into the Club’s sign-in
technology).
• details of your membership of the club, including any positions held by you at
the Club or any complaints made by you or against you in connection with Club
Willoughby.
• information about what goods or services you buy or receive from Club Willoughby.
• details of your activities at or in connection with Club Willoughby, including
your participation in social, sporting or other organised activities.
• the name and contact details of your next of kin.
• information connected to your use of our gaming machines (including your
player activity statements and any prizes you receive).
• information about you related to a liquor or gaming self-exclusion or
banning order about you from yourself, other licensed venues, MVSE, Bet
Safe, TAB, ClubsNSW, a Liquor Accord or Liquor & Gaming NSW.
• things you say or do (or things said about you) in connection with an
incident or potential disciplinary proceedings at or in connection with Club
Willoughby.
• your payment details, including your bank account details and credit card
details, where you have applied for a direct debit or other financial arrangement
with the Club Willoughby.
• information about your use of our websites and social media pages, including
your IP address, and any information collected by cookies as a result of your
use of our websites and social media pages.
• your location if you install and use the Club Willoughby App.
• information related to your use of our Wi-Fi from any of your personal devices.
• if you apply for a job with us, the information in your resume, information
about your qualifications, information about your immigration status and other
information that you or your referees provide to us and notes of our
interactions with you and/or others in relation to your prospective
employment.
From time to time, we may collect additional information about you related to
surveys, promotions and particular services or activities at or in connection with Club
Willoughby.
Wherever practicable, we will advise you of the information being collected about
you and provide you with an opportunity to refuse the collection of that
information.
How do we collect your personal information?
Your personal information is collected as a result of your visits to, or dealings with
Club Willoughby. Information is collected by recording information that you provide
to us, by electronic means, and by the observations of our staff.
We collect personal information when you:
• enter, visit, or deal with Club Willoughby.
• apply for, or renew, your membership of the Club Willoughby or request to use our services.
• use your membership card at or in connection with Club Willoughby.
• purchase goods or services from Club Willoughby.
• use our gaming machines or request to be excluded from using our gaming machines.
• enter into a liquor self-exclusion agreement with us, or otherwise participate
in a liquor self-exclusion program and nominate to exclude yourself from all
or part of our premises.
• install, access, or use the Club Willoughby App
• access or use our Wi-Fi from any of your personal devices.
• attend a function or show.
• plan an event to be held at Club Willoughby.
• apply for a direct debit or other financial arrangement with Club Willoughby.
• participate in activities offered by Club Willoughby, including competitions and promotions.
• visit one of the websites or social media pages operated by Club Willoughby.
• are suspended, banned, or removed from any part of Club Willoughby premises.
• receive or request sponsorship through programs such as Club Grants.
• participate in, witness or are connected to an incident or disciplinary
proceedings at or in connection with Club Willoughby.
• apply for, or renew, your membership of one or more of Club Willoughby sub
clubs or participate in the activities of those sub-clubs.
• apply for a job with us.
In general, if you contact us, we may keep a record of that correspondence. We may
also collect information about you from other clubs and industry bodies if you have
excluded yourself from there Club’s premises as part of a liquor or gaming self
exclusion agreement or program (including in relation to the TAB and “MVSE” self
exclusion systems).
Will I be notified that my personal information is being collected?
When we collect information from you, we will take reasonable steps to notify you
(or otherwise ensure that you are aware) of the following:
• our identity and contact details.
• the facts and circumstances of the collection.
• details of any laws that require or authorise the collection.
• the purposes of the collection.
• the consequences if we do not collect the information.
• that this policy contains information about how you can access or correct
your information or make a complaint about Club Willoughby.
• whether we are likely to disclose the information overseas (and, if so, to which countries).
One way we notify you of the above is by making you aware of this policy. If you give
us personal information about others, we expect that you will tell them about this
policy.
How do we use your personal information?
We collect, hold, use and disclose your personal information to operate Club
Willoughby, carry out certain activities, provide products and services to you, other
members and guests and other members of the public, and comply with our legal
obligations. We also use your personal information for secondary purposes related
to the above, or when permitted under the Privacy Act.
If you have self-excluded yourself from Club Willoughby premises and nominated
other Clubs or licensed premises from which you also want to be excluded, we may
disclose your personal information to the exclusion program operator (if any) and/or
to the clubs and licensed premises that you have nominated directly to the extent
necessary to assist those clubs and licensed premises to comply with your self
exclusion.
Club Willoughby may also use the personal information we collect from you for direct
marketing of products and services to you, including from third parties. Such
products and services may include the provision of newsletters, competitions,
announcements, campaigns, or information about shows and entertainment at Club
Willoughby or services offered by the Club.
You can refuse any direct marketing by opting out of direct marketing material at
Member Services, by updating your preferences on your account or by selecting
unsubscribe on any marketing emails from Club Willoughby.
Does Club Willoughby disclose my personal information to others?
There may be times when we may need to disclose your personal information to third
parties that we engage to provide services to or in connection with Club Willoughby,
including our related entities, our insurers, our sponsors, our legal or financial
advisers and other Club members.
Your personal information will only be disclosed to third parties for a purpose
permitted by the Privacy Act and/or this policy and, where required, after obtaining
your consent.
We may need to disclose your personal information to third parties for the purposes
of allowing us to carry out the activities and functions mentioned in this policy.
For example, from time to time, Club Willoughby engages external companies to
send direct marketing information (usually via email or SMS}, carry out mail services,
and provide IT storage and other services.
A third party will only receive your personal information from Club Willoughby where
that information is necessary for that third party to provide services to or in
connection with Club Willoughby and the Club will always require that the third party
comply with the Privacy Act when dealing with your personal information.
We will also disclose your personal information to third parties if we are required or
authorised to do so by law, including to law enforcement agencies, the Office of the
Australian Information Commissioner, the Australian Electoral Commission, the
Department of Communities and Justice and the Australian Taxation Office.

SCANNING YOUR IDENTIFICATION
Visitor Sign In
The Club’s electronic sign in system Circle Solutions utilised for the visitor sign in
procedure for Club Willoughby. The Clubs electronic sign-in system Circle Solutions
specialises in ‘Identification Data Capture’ for the Hospitality Industry and is
compliant with the Registered Clubs Act.
All data is maintained by Club Willoughby on a secure onsite server and personal
information provided may be used for marketing and promotional purposes.
This system does not record/retain any specific identification numbers, for example
your licence number. Photos are recorded only for the purpose of recognising those
that are excluded from the venue. The use of this system is a condition of entry.
The system only records the following information from your ID:
• Name.
• Address.
• Date of Birth.
• Signature Image.
• Photograph.
SURVEILLACE (CCTV)
In the interest of safety for our members, guests and visitors, Club Willoughby has
installed a network of CCTV cameras. The cameras are not intrusive and are carefully
managed and supervised. All surveillance data is maintained by Club Willoughby on
secure onsite servers. Data is collected and stored for a minimum of 30 days as
required by law.
Access to surveillance data is restricted to relevant management personnel and all
access to this data is automatically and securely logged for tracking purposes.
Relevant footage is provided to the Police or regulatory bodies such as Liquor &
Gaming NSW or the Independent Liquor & Gaming Authority upon specific and
documented requests and is subject to a procedure where the request is identified.

FACIAL RECOGNITION TECHNOLOGY
Club Willoughby utilises facial recognition technology to consolidate the Club’s
security systems and to assist the Club in identifying individuals who are suspended,
banned or self-excluded from our premises.
There are select security cameras that have been installed to use facial recognition
technology to collect and analyse digital biometric data of individuals entering
licensed gaming areas of the Club only. A person entering these designated areas will
have their image biometrically processed and compared against a database of
individuals who are suspended, banned, or self-excluded from our premises. Any
person not on the database as an excluded image will have their details erased
immediately and will not be held on any database anywhere.
If an individual’s face image matches an image on the database, our staff will be
alerted, and the individual will be removed from our premises. Club Willoughby will
store the images of those who have been suspended, banned or self-excluded from
our premises for such time until the suspension, ban or self-exclusion ceases.

ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
If you need to access your personal information that is held by Club Willoughby, you
will be required to make a request to the Club in writing, which can be given
physically to Club reception, sent by mail to the Club or by email to
kreeve@clubwilloughby.com.au
We will provide you with access to the information requested within a reasonable
period after the request is made, not exceeding 30 days.
We may charge you a reasonable fee for processing your request. We may decline a
request for access to your personal information if the Privacy Act prohibits it or does
not require us to provide access.
Club Willoughby encourages its members to update or correct personal information,
so that the information is accurate and up to date. You may lodge a request to correct
personal information that we hold about you if you believe it is inaccurate,
incomplete, out-of-date, irrelevant, or misleading, in which case please contact the
Club. This can be done via the Club reception, via mail or email. We will deal with
your request in accordance with the Privacy Act.

CHANGES TO THE PRIVACY POLICY
Club Willoughby reserves the right to make changes to this Privacy Policy from time
to time. We will publish any changes on the Club website or Deputy.
By continuing to use our products, services, and website or by continuing to provide
us with your personal information after these changes have been published, you
confirm your acceptance of these changes.

DATA BREACH
If a data breach or suspected data breach occurs, Club Willoughby will undertake a
prompt investigation, which will include an assessment of whether the incident is
likely to result in serious harm to any individuals. Pending the suspected data breach,
this investigation may be done in accordance with our Cyber Security Policy.
In such a situation we will comply with the requirements of the Privacy Act which may
require notification to the Office of the Australian Information Commissioner (OAIC)
and affected individuals

PRIVACY COMPLAINTS
If you wish to make a privacy complaint, please put your complaint in writing with as
much detail as possible and send it to us by letter or email using the details listed
below:
Chief Executive officer
Club Willoughby 26 Crabbes Avenue
North Willoughby NSW 2068
Email: kreeve@clubwilloughby.com.au
The CEO or another representative of the Club, will consider (and may investigate)
the complaint and provide you with a written response within a reasonable
timeframe (taking into consideration the nature of your complaint).
If you are unhappy with how we handle your issue or complaint, you are entitled to
make a privacy complaint to the Office of the Australian Information Commissioner.
Please visit the Office of the Australian Information Commissioner’s website for
contact details: https://www.oaic.gov.au/