- “ProTippa”, “we”, “our” or “us” means Entertainment Associates Pty Ltd (“EAssociates”), a company incorporated in Australia (ACN 612 365 518), and with its registered office at Unit 6, 207 Bulwer Street, PERTH Western Australia 6000.
- “You”, “Your”, “Member” means any person using the Platform or the services of ProTippa.
- The “Platform” means any part of the ProTippa.com.au website, any other website or downloadable applications that we own (the “Platform”) (including, but not limited to, the ProTippa application) and/or any account on the Platform.
- “Bookmaker” means a third party betting service provider, agency or bookmaker with which ProTippa has entered into an arrangement or agreement.
- “Feeds” means odds, live content, content and commentaries provided instantaneously by a third party provider, including a Bookmaker.
- The identification information (‘ID’) means your name, residential address (‘address’) and date of birth, as provided to ProTippa upon applying for your ProTippa account. Members who do not provide full details up front may have their accounts suspended, without notice, pending an investigation to verify and confirm their identities.
- “Members” means people applying or that have a registered account on the Platform.
- ProTippa is bound by, and therefore, we are committed to complying with, the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (Privacy Act).
- The APPs are designed to protect the confidentiality of personal information and the privacy of individuals by regulating the way personal information is collected, used, disclosed and managed. Personal information is, generally speaking, information or an opinion relating to an identified, or reasonably identifiable, individual.
3. The reason why we collect personal information
- We collect personal information about our Members in the course of our activity to understand and meet their needs and to:
- conduct our business activities and provide services to Members, for example, to operate the Platform and to allow and assist you to register as a Member of ProTippa and sign up for an account;
- provide you with updates or information about our services, Feeds, the Platform, for example, if you sign up to our mailing list or newsletter;
- enable us to perform our obligations to you under ProTippa’s Terms and ensure that Member performs its obligations under ProTippa’s Terms;
- conduct analysis on our website and Platform and to improve the content of our website and the Platform, for example, by monitoring website usage and traffic;
- verify your age and identify, for example collecting information from credit reporting agencies such as Veda (see clause 8 below);
- otherwise meet our legal and regulatory obligations, for example, to comply with our obligations to verify your identity under the Anti-Money Laundering and Counter Terrorism Act 2006 (Cth); and
- for any other purpose you may reasonably expect.
- We could also collect this information for communicating with the Member, for example, to contact you to respond to your requests, questions or feedback.
- From time to time, we may occasionally use your personal information for the purposes of promoting and marketing our activities including, conducting competitions or promotions or to send you information or marketing materials about our services and services of other entities in the ProTippa corporate structure or in relation to our the products or services of our third party partners and suppliers such as information about, new services, updates to the Platforms or offers which we believe you may be interested in. This may include (but is not limited to), for example, information about our affiliate betting service providers or bookmakers (Bookmaker).
- If you do not wish to receive these marketing communications you can opt out by contacting us using the Contact Details set out below and informing us that you wish to opt out, or by logging onto your ProTippa account and changing your account preferences, or by clicking the “unsubscribe” link in any marketing email that we may send to you.
- Finally, your personal information may be used for planning, research, for example, to create aggregate data about Members through demographic profiling and statistical analysis of our database to optimise services, maintain a credit information file on you and carry out a credit assessment on you to comply with our commitment on gambling prevention.
4. Types of collected Personal Information
- Sometimes our activities require us to collect sensitive information. For more details, see the section ‘Sensitive information is subject to greater restrictions’, below.
- ProTippa also collects statistical information about visitors to our website for the purposes of monitoring traffic and activity on our website. Generally, this information is collected in aggregate and cannot be used to identify particular individuals but in some circumstances, it may include a visitor’s internet protocol address, which could be linked to the individual.
5. The way your personal information is collected
- Personal information may be collected by way of forms filled out by individuals (including via online forms, such as when you register as a Member for a ProTippa account) or by other communications with you including emails, telephone conversations, online user-generated content and market research, face-to-face meetings and interviews. Where necessary and with your consent, we supplement the information we receive from you with information from third party sources, such as your employer or third party verification services providers, for identification and verification purposes in relation to the Member’s ID.
- You may in some circumstances have the option of not identifying yourself or using a pseudonym when you deal with ProTippa. However, if you choose not to provide the information we need to fulfil your request for a specific service or to participate in our activities’ development, we may not be able to provide you with the requested service or we may not be able to allow you to participate in our activities.
6. Disclosure of personal information to other parties
- ProTippa may collect data relating to your betting tips and transactions with Bookmakers. You acknowledge and agree that ProTippa may collect, store and use this information for statistical purposes and/or marketing purposes including, but not limited to, for the purposes of disclosing this information to third parties as big data.
- We may also disclose your personal information if it is required or authorised by law, where disclosure is necessary to prevent a threat to life, health or safety, or where we are otherwise permitted by the Privacy Act, such as but not limited to, credit reporting agencies, courts of law, law enforcement agency to assist the prevention of criminal activities or in connection with an investigation, a successor entity in the event of a business restructuration, sale or reorganisation and regulatory bodies such as Australian racing/sports controlling bodies where such controlling bodies request information to protect and maintain the integrity of the racing/sports code.
- Should the information be transferred to a third party, we will use reasonable endeavours to ensure that the Member’s personal information disclosed is protected by the third party under contractual arrangements and in accordance with the Privacy Act.
- We will give the Member the option to opt out of being contacted for promotional purposes by us and any third parties.
7. Sensitive information is subject to greater restrictions
- Some of the information we collect may be ‘sensitive information’, including information or an opinion about an individual’s health, racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association or membership of a trade union that is also personal information, among other things.
- ProTippa may use and disclose your sensitive information for the primary purpose of collection, or for reasonably expected secondary purposes which are directly related to the primary purpose, or for purposes to which you have consented and in other circumstances authorised by the Privacy Act (e.g. where required or authorised by law to be disclosed, or where disclosure is necessary to prevent a threat to life, health or safety).
- If ProTippa received unsolicited information that could have been obtained via forms, it will be dealt with in accordance with the conditions of this Policy. In the event that the unsolicited information was qualified as sensitive, ProTippa would use its best endeavours to destroy or de-identify that information.
8. Credit reporting agency disclosure
- ProTippa may disclose your name, residential address and date of birth to a credit reporting agency for the purpose of obtaining an assessment of whether that personal information so disclosed matches (in whole or in part) the personal information held by the credit reporting agency. This process assists us in verifying your identity as required by the Anti-Money Laundering and Counter Terrorism Act 2006 (Cth).
- The credit reporting agency may prepare and provide us with such an assessment and may use your personal information including your name, residential addresses and date of birth as contained in any credit information file relating to you and other individuals for the purposes of preparing that assessment. If you disagree with having your identity verified by a credit reporting agency, please contact ProTippa Customer Service on 1800 007 238 so that we can discuss other options with you.
9. Security and management of personal information
- ProTippa will take reasonable steps to protect the personal information we hold from misuse and loss and from unauthorised access, modification or disclosure. The ways we do this include limiting physical access to our premises, limiting access to the information we collect about you (for instance, only those of our personnel who need your information to carry out our business activities are allowed access), requiring any third party providers to have acceptable security measures to keep personal information secure and putting in place physical, electronic, and procedural safeguards in line with industry standards.
- If ProTippa no longer requires your personal information or if you close your Member account and we are not legally required to retain it, ProTippa will take reasonable steps to destroy or permanently de-identify the personal information.
- ProTippa will generally only disclose personal information to an overseas recipient for the primary purpose which it has been collected for unless you have consented to ProTippa disclosing the personal information for another purpose or if it is reasonable to expect that such disclosure was necessary or required by law. For example, we may disclose your personal information to third parties located overseas which may assist us in the conduct of our business, for example, ProTippa may transfer your personal information to data and website hosting providers located overseas for the purposes of providing technical or website storage and/or support to us.
- In the event that ProTippa discloses your personal information to recipients outside of Australia, you acknowledge that, by providing us with your personal information, you consent to such overseas disclosure. By consenting to such disclosure, you agree and acknowledge that:
- ProTippa will not be accountable under the Privacy Act, for any breach of your privacy by the overseas recipient; and
- you will not be able to seek redress under the Privacy Act against ProTippa for any breach of your privacy by an overseas recipient.
- Please be aware that the transmission of information over the internet is never completely secure, and, while we endeavour to use our best efforts to secure and protect your personal information, we cannot guarantee “perfect security” of any information you transmit or provide to us.
10. Links from our website to other websites
- Our Platform may contain links to third party websites. We do not operate these websites and therefore are not responsible for the privacy practices or the collection or handling of personal information by the operators of these websites.
- We encourage you to read the privacy policies of these third party websites or contact these websites directly for further information about their privacy practices.
11. Accessing and correcting the information we hold about you
- Under the APPs of the Privacy Act, you may be able to obtain a copy of the personal information that we hold about you. The APPs provide some exceptions to your rights in this regard.
- To make a request to access this information, please contact us in writing using the Contact Details set out below. Once we receive your request, we will endeavor to respond to that request within a reasonable period after your request is made. We will require you to verify your identity and specify what information you require.
- We may charge a fee to cover the cost of verifying the application and locating, retrieving, reviewing and copying any material requested.
12. Updating your personal information
- We endeavour to ensure that the personal information we hold about you is accurate, complete and up-to-date. However, we can only rely on the accuracy of the personal information that you provide to us.
- You are entitled to request the correction of the personal information we hold about you. To make a request for correction, please contact ProTippa in writing at the Contact Details set out below, or on our Platform, if you believe that the information we hold about you requires correction or is out-of-date.
- We will endeavor to respond to your request within a reasonable period after your request is made.
- If you are concerned that we have not complied with your legal rights or applicable privacy laws, you may bring a complaint internally through our complaints process or you may decide to make a formal complaint with the Office of the Australian Information Commissioner (www.oaic.gov.au) (which is the regulator responsible for privacy in Australia).
- We will deal with complaints as follows:
Step 1: let us know
If you would like to make a complaint, you should let us know by contacting our Privacy Officer (see below for contact details) in writing and setting out the nature of your complaint.
Step 2: investigation of complaint
Your complaint will be investigated by our Privacy Officer. A response to your complaint will be provided in writing within a reasonable period.
Step 3: contact OAIC
We expect our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can also contact the Office of the Australian Information Commissioner (OAIC) as follows (Complaints must be made in writing):
||Director of Compliance
Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
14. Contact us
Address: Entertainment Associates
PO BOX 488
NORTH PERTH, 6906
Attention: The Privacy Officer
ProTippa will endeavour to respond to all complaints and correspondence promptly.