Last Updated: 22 June 2022
Buddybet Pty Ltd (ACN 617 859 953) of Suite 5, Brett Dixon House, Buntine Drive, Fannie Bay NT 0820, Australia (“Buddybet”, “we“, “us“, “our“) is committed to privacy protection.
By accessing www.buddybet.com (“Site”), the related mobile app, and any other features, services, tools, materials, or other services offered from time to time by Buddybet or its affiliate companies (collectively the “Platform”), you are trusting us with your information. We understand the importance of keeping personal information private and secure, and we are committed to ensuring the protection of your information.
- what personal information we may collect about you;
- how we collect and store your personal information;
- the purposes for which we collect, store, use and disclose your personal information;
- how we may disclose your personal information; and
- how you can update, manage, export and delete your personal information.
For users resident in Australia, we will treat all personal information in accordance with any and all obligations that are binding upon us under the Privacy Act 1988 (Aus) (“Australian Privacy Act”). The Australian Privacy Act sets out thirteen (13) key principles in relation to the collection and treatment of personal information, which are called the “Australian Privacy Principles”.
For users resident in New Zealand, we will treat all personal information in accordance with any and all obligations that are binding upon us under the Privacy Act 2020 (NZ) (“NZ Privacy Act”). The NZ Privacy Act sets out twelve (12) key principles in relation to the collection and treatment of personal information, which are called the “Information Privacy Principles”.
We require your knowledge and consent to collect, use and/or disclose your personal information, except as required or permitted by applicable law. You are under no obligation to provide us with your personal information. However, if you choose not to provide us with certain personal information, we will be unable to assist you in setting up an account to provide you with our services.
Except in specific circumstances, you may withdraw your consent to our use of your personal information at any time. All requests for withdrawal of consent must be directed to the Privacy Officer by email using the email address or by writing to us at our mailing address, provided below.
Collection of personal information
We want you to understand the types of personal information we collect as you use our Platform. We collect information to provide various services to all our users.
Initially when you open an account with us, the types of personal information we may collect from you includes:
- name and date of birth;
- residential and postal addresses;
- telephone numbers and email addresses;
- credit card and other financial information;
- driver’s licence information or other identification information;
- Information that identifies which phone contacts hold a Buddybet account, enabling you to follow them (if you request to synchronise your contacts); and
- any other information that you provide to us by you during your account creation process.
If you attest that you are a Politically Exposed Person (“PEP”), as defined in the Anti-Money Laundering and Counter Terrorism Financing Rules Instrument 2007 (Aus) or Anti-Money Laundering and Counter Financing of Terrorism Act 2009 (NZ) (as the case may be), or a family member or a close associate of a PEP, you will be required to provide additional information such as your source of funds, your source of wealth, the office or position of the PEP or PEP organization/institution name and, if you are a family member or close associate of a PEP, the nature of the relationship between the family member and close associate of the PEP. Such information is collected on behalf of the Australian Transaction Reports and Analysis Centre (AUSTRAC) or New Zealand Financial Intelligence Unit (as the case may be) and may be shared with other operators as part of enterprise level player monitoring.
In addition to the information we collect when you initially open an account, we also collect the following types of personal information about you:
- the content you post or publish on our Platform;
- information we receive from others when you use our Platform; information about the browsers and devices you use to access our Platform, which helps us provide features like automatic product updates. This information we collect includes unique identifiers, browser type and settings, device type and settings, operating system, mobile network information including carrier name and phone number, and application version number; information about your activity on our Platform, which we may use to do things like recommend a particular area of interest you might like. The activity information we collect may include:
- terms you search for;
- views and interactions with content and ads;
- with your express consent, voice and audio information when you use audio features on our Platform;
- wagering activity; and
- people with whom you communicate or share content.
So that we can adhere to our legal obligations, we will collect information about your location when you use our Platform. Your location can be determined with varying degrees of accuracy by:
- Global Position System (GPS);
- Internet Protocol (IP) address;
- sensor data from your device; or
- information about things near your device, such as Wi-Fi access points, cell towers, and Bluetooth enabled devices.
How we collect your personal information
Buddybet will only collect personal information that is necessary for us to conduct our business as a provider of online gambling and wagering services. We collect personal information about our users in various ways. For example, we collect information that you provide to us, information that we collect through your use of our Platform, and information that we collect from publicly available sources or third parties.
Information that you provide to us
We collect personal information that you provide to us about yourself when you:
- use our Platform, including (without limitation) when you:
- create a user account;
- add information to your user profile;
- add reviews, forum or chat room messages or comments in any elements of our Platform that permits user-generated content; or
- complete an online contact form to contact us;
- provide information to us by telephone; or
- send us an email or other communications.
In addition to the information you provide to us directly, we may collect personal information about your use of our Platform. This may include usage information, such as the time and duration of your use of the Platform and other information about your interaction with content offered on our Platform.
Our Platform may also collect Internet Protocol (IP) addresses. IP addresses are assigned to devices on the internet to uniquely identify them within the global network. Buddybet collects and manages IP addresses as part of the service of providing internet session management and for security purposes. We may also collect and use web log, computer and connection information for security purposes and to help prevent and detect any misuse of, or fraudulent activities involving, our Platform.
Information from third-party sources
We may acquire or receive information about you from publicly and commercially available sources, as permitted by law, which we may combine with other information we receive from or about you. For example, we may receive information about you from a social media site if you connect to our Platform through that site or from identity verification services, as required or authorised by law or regulation.
A cookie is a small amount of data, often including a unique identifier, that is sent by a web server to your web browser and stored on your hard drive to identify and interact more effectively with your device. There are two (2) types of cookies that may be used on our Platform: a persistent cookie and a session cookie. A persistent cookie is entered by your web browser into the “Cookies” folder on your device and remains in that folder after you close your browser, and may be used by your browser on subsequent visits to our Platform. A session cookie is held temporarily in your device’s memory and disappears after you close your browser or turn off your device. In some cases, cookies may collect and store personal information about you. Other similar files such as clear GIFs, web beacons and pixel tags work in the same way and we use the word ‘cookie’ in this policy to refer to all files that collect information in this way. Buddybet extends the same privacy protection to your personal information, whether gathered via cookies or from other sources.
- Session Management – cookies are essential to enable use of our Platform, they manage session information and enable you to navigate through the Platform.
- Fraud Prevention – cookies store information which helps us stop fraudulent use of the Platform.
- Functionality – cookies store information which enables us to remember your preferences. They are also used to improve your experience.
- Tracking – cookies enable us to store information about how users arrived on the Platform.
- Analysis – cookies allow us to recognise and count users of our products and to see how users move around our Platform. This helps us to improve the way the Platfrom works for you, by ensuring that you can find what you are looking for easily and to deliver adverts and information which are more relevant to you and your interests and to monitor the effectiveness of such adverts and information.
You can configure your internet browser to accept all cookies, reject all cookies or notify you when a cookie is sent. Please refer to your internet browser’s instructions to learn more about these functions. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. The ‘Help’ function within your browser should tell you how to restrict or block cookies. Alternatively, you may wish to visit http://www.allaboutcookies.org/ which contains comprehensive information on how to do this on a wide variety of browsers. Please note that, as the allaboutcookies.org website is not owned or operated by us, we are not responsible for any of the content on them. Please be aware, if you choose to decline cookies, you may not be able to fully experience the interactive features of this site.
Third party cookies
In some cases, third parties may place cookies through our Platform. For example:
How we hold information and who has access to it?
We have processes in place to ensure the security of your personal information. There are limitations on access to information within Buddybet.
Only certain Buddybet employees, being those required to have access to personal information so that we can carry out our services will have access to information held on a secure server..
Use of personal information
We collect, process and use information we collect from you via our Platform in order to:
- Provide our services and products – including the provision of betting and social media services, enabling you to connect with users on our Platform, and deposit and withdraw from your Buddybet account.
- Develop new services – we use the information on our we hold to help improve our existing services and to develop new services. For example, we use this information for customising the content/layout of our Platform for users and personalising our services for individual customers.
- Communicating with you – we use contact information, like your email address, to interact with you directly. For example, if you sign-up to receive marketing communications, we may send you information about our products, Platform, offers or competitions, or the products or services of our partners that we believe may be of interest to you, unless you have indicated that you do not wish to receive these materials.
- Protect us, our users and the public – we use your information to help improve the safety and reliability of our services. This includes detecting, preventing and responding to fraud, abuse, security risks and technical issues that could harm us, our users or the public.
- Measure performance – we use your information to keep track of how our business is performing, including, for example, to conduct analysis on our Platform’s usage or monitor usage and traffic.
- Legal and Regulatory Obligations – there may be times that we are bound by law, regulations, or contractual arrangements to use your information to verify your age and identity.
From time to time, we may also email our users with news, information and offers relating to our services or those of selected partners. Your personal information may also be collected so that we can promote and market products and services to you. This is to keep you informed of products, services, and special offers we believe you will find valuable and may continue after you cease use of our Platform. If you do not wish to receive any marketing communications from us, you may opt out of receiving those communications by updating your settings when you log into our Platform. . You may also opt out by clicking the “Unsubscribe” link in any marketing email that we may send to you. Alternatively, you can opt-out of receiving email marketing communications by contacting us at the contact information provided in the “How to contact us about privacy” section below. Please note that you may continue to receive transactional or account-related communications from us.
Disclosure of your information
In the course of our business, and for the purposes set out above, we may disclose your personal information to organisations outside Buddybet (including third parties located in Australia, USA, Canada, India or other foreign jurisdictions) who help us to operate our business. These organisations may carry out or provide:
- payment processing services;
- information technology services and advice;
- customised marketing and advertising services and advice;
- security services and advice;
- identity verification services;
- Platform and Site usage analysis; and/or
- social media integration services.
In addition, we may disclose your information to:
- our subsidiaries and affiliated companies;
- your authorised representatives or legal advisers (when requested by you to do so);
- credit-reporting and fraud-checking agencies;
- credit providers (for credit-related purposes such as creditworthiness, credit rating, credit provision and financing);
- our professional advisers, including our accountants, auditors and lawyers;
- government and regulatory authorities and other organisations (for example, sporting bodies), as required or authorised by law or regulation;
- a third-party in connection with a proposed or completed merger, acquisition or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Buddybet or as part of a corporate reorganization or other change in corporate control; and/or
- the police or other appropriate persons where your communication suggests possible illegal activity or harm to others.
Your personal information may be disclosed to these organisations or persons only for legitimate business purposes related to our Platform, or as otherwise required or permitted by applicable law, and we take reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations in relation to the protection of your personal information.
We may also disclose your personal information in other situations, with your consent.
People and accounts you share and communicate with
When you share and communicate using our Platform, you choose the audience for what you share. For example, when you post a bet, you select the audience for the bet, such as a group, all of your friends, the public, or a customized list of people. This may include users located outside of your country of residence.
Your network can also see actions you have taken on our Platform, including engagement with ads and sponsored content.
Public information can be seen by anyone on our Platform. This includes:
- your username;
- any information you share with a public audience;
- information in your public profile; and
- content you share on another user’s profile page or any other public forum.
You, other users, and we can provide access to, or send, public information to anyone, on or off our Platform, including in search results, or through tools and APIs. Public information can also be seen, accessed, reshared or downloaded through third-party services such as search engines, APIs, and offline media such as TV, and by apps, websites and other services that integrate with our Platform.
You can control your account visibility by editing your preferences in your Platform account settings.
How we store information and who has access to it
We are committed to maintaining the confidentiality of the information that you provide us and we will take all reasonable technical, administrative, physical and organizational measures to protect your personal information from unauthorised use or alteration. However, despite our safeguards and efforts to secure your information, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Platform is at your own risk. You should only access our Platform within a secure environment.
In our business, personal information may be stored both electronically (on our computer systems, servers and with our third-party website hosting vendors) and in hard-copy form. Firewalls, anti-virus software and email filters, as well as passwords, protect all of our electronic information. Likewise, we take all reasonable measures to ensure the security of hard-copy information; for example, we enforce limitations on access to information within Buddybet with only certain Buddybet employees having access to your information, where necessary to perform their job function.
Third party websites
How you can manage your information
Our Platform allows you to view, update and correct certain personal information on your account. Alternatively, you can contact us about accessing, updating, or correcting your information.
Access to your personal information
Subject to applicable law, you may have access to personal information that we hold about you. All requests for access to your personal information must be directed to the Privacy Officer by email using the email address or by writing to us at our postal address, provided below. We will respond to all requests for access to personal information as quickly as possible. Requests for a large amount of information, or information that is not currently in use, may require further time before a response can be given. We may charge you a fee for access if a cost is incurred by us in order to retrieve your information, but in no case will we charge you a fee for your application for access.
In some cases, we may refuse to give you access to personal information that we hold about you. This may include circumstances where giving you access would:
- be unlawful (for example, where a record that contains personal information about you is subject to a claim for legal professional privilege by one of our contractual counterparties);
- have an unreasonable impact on another person’s privacy; or
- interfere with, or otherwise prejudice, a law enforcement matter or other investigation of unlawful activity.
We may also refuse access where the personal information relates to existing or anticipated legal proceedings, and the information would not be accessible by the process of discover in those proceedings. If we refuse to give you access, we will provide you with reasons for our refusal.
Please note, we may request certain personal information for the purpose of verifying the identity of the individual seeking access to his or her personal information records.
Correcting your personal information
Buddybet will use reasonable efforts to ensure your personal information is up-to-date and accurate, but we ask that you update your information whenever your information is incomplete, out-of-date or otherwise changes. You may request that we amend any personal information about you that is held by us and that is inaccurate, incomplete or out of date if you request us to do so. If we disagree with your view about the accuracy, completeness or currency of a record of your personal information that is held by us, and you ask us to associate with that record a statement that you have a contrary view, we will take reasonable steps to do so.
It is extremely important that you keep your account information and other confidential account data protected and secure. Do not share your log-in information or leave your computer unattended when logged in to the Platform. Contact us immediately by email if you find believe your account information and/or other confidential data has been compromised.
Collection of personal information from minors
We do not knowingly solicit data from or market to persons under eighteen (18) years of age. By accessing and using our Platform, you represent that you are at least eighteen (18) years of age. If we learn that we have collected personal information from users who are less than eighteen (18) years of age, we will deactivate the users’ account and take reasonable steps to promptly delete such data from our records.
If you become aware of any data we may have collected from a person who is under the age of eighteen (18) years, please contact us at the contact information provided in the “How to contact us about privacy” section below.
How to contact us about privacy
Your privacy is very important to us. For that reason, if you have any questions about your privacy, you can ask us by reaching out to our Privacy Officer in the following ways:
- By Mail – Suite 5, Brett Dixon House, Buntine Drive, Fannie Bay NT 0820, Australia
- By Phone – 1800 577 291
- By Email – email@example.com
If you are concerned about a possible interference with your privacy, please contact us and we will investigate it. Complaints to us must be made in writing. If you do not receive a response within thirty (30) days or if your concern is not resolved to your satisfaction, you can refer the matter to the Office of the Australian Information Commissioner (“OAIC”), if you are resident in Australia, or to the Officer of the Privacy Commissioner (“OPC”), if you are resident in New Zealand.
You should be aware, that before you can lodge a complaint with the OAIC or the OPC (as applicable), you will usually need to raise your concerns directly with us first.