Privacy Policy
General
This is the privacy policy (“Privacy Policy”) for BetEstate.com.au (“BetEstate”). BetEstate is subject to the Privacy Act 1988 (Cth) (“the Privacy Act”).
By using BetEstate’s websites, mobile sites and mobile applications including www.BetEstate and m.BetEstate (“the website”), you agree to the Privacy Policy as set out below. This Privacy Policy is in addition to and should be read in conjunction with BetEstate’s Betting Terms & Conditions.
BetEstate will review this Privacy Policy periodically and reserves the right to modify parts of this policy at any time and at its discretion. Changes will be affected immediately when posted on the website and we recommend you review these pages periodically for any updates as your continued use of the website will constitute acceptance of the terms of this Privacy Policy.
This Privacy Policy will not apply to websites which are linked to this website and over which BetEstate has no control. In this Privacy Policy, a reference to “Australian Privacy Principles” means the National Principles for the Fair Handling of Personal Information.
Personal Information
For the purposes of this Privacy Policy, Personal Information means information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.
The types of Personal Information BetEstate may collect from you include:
* Name, Home address, Date of Birth, Gender, Photographs or images, personally submitted preferences, Bank account and credit card information, Financial information, Email address, Additional identity verification information.
Collection
You are welcome to browse our website without ever providing us with your Personal Information. However, if you wish to deposit funds, place a bet and/or withdraw funds, you will, for legitimate reasons, be required to provide us with certain Personal Information so that we are aware of whom we are communicating with.
BetEstate will only collect such Personal Information as is required for the purpose of identifying you for your own security and maintaining your account in the reasonable operation of our business of a licensed online bookmaker.
The Personal Information we collect can be viewed in the Edit Account Details area of our website. If you do decide to provide us with Personal Information, we will retain that Personal Information. By choosing to provide Personal Information on our Website, you consent to our collecting and retaining that Personal Information. We will collect Personal Information in a lawful and fair way, and not in an unreasonably intrusive way.
Use and Disclosure
When we collect Personal Information on our website, we may use this information to:
* provide you with the services you have requested, or meet the purpose for which the information was submitted;
* upgrade, enhance and personalise your experience within the website, or tailor our information, services or products for you;
* contact you for direct marketing or other promotional purposes;
* create aggregate data about our clients, such as average age, gender, demographics and other statistics to allow for more – efficient operation of this website;
* determine your liability to Australian GST.
By choosing to provide Personal Information on our website, you consent to our using your Personal Information as set out above.
BetEstate does not give, sell, rent, share, or trade any Personal Information regarding our Clients to third parties, except as set out below.
Personal Information that you submit to our website may be disclosed to a third party:
* to enable BetEstate to perform its obligations to the Client under BetEstate’s Terms;
* to enable BetEstate to ensure that the Client performs their obligations under BetEstate Terms;
* to a credit reporting agency; to maintain a credit information file in relation to the Client; to carry out a credit assessment on the Client;
* for planning, research, promotion and marketing of our products and services, excluding identification information collected for identity verification purposes;
* to BetEstate’s contractors and external service providers associated with the operation of BetEstate’s business and provision of its services, including, without limitation, associated data centres, web hosting providers, payment service providers, identity verification service providers for identity verification purposes only, mailing houses, printers, call centres, IT consultants, professional advisors and consultants, government and regulatory authorities and other organisations as required or authorised by law or otherwise permitted under the Privacy Act. Identification information collected for identity verification purposes is not disclosed to advertising agencies, mailing houses, market research analysts, business partners or sponsors for marketing, advertising, profiling, market research or promotional purposes.;
* to law enforcement agencies to assist in the prevention of criminal activities;
* to Australian racing/sports controlling bodies where such controlling bodies request information to protect and maintain the integrity of the racing/sports code or where we consider any betting activity to be suspicious or unusual; and
* BetEstate may also disclose your personal information to Racing Victoria Limited (ACN 096 917 930) (Racing Victoria). Racing Victoria is the Principal Racing Authority responsible for governing thoroughbred racing in Victoria which includes administering and ensuring the integrity of the industry and supervising bookmakers, licensed and registered persons, its employees, and betting transactions generally. BetEstate is subject to the Club Bookmaker Licence Rules and the Rules of Racing (as amended from time to time) (Rules) and may disclose your personal information to Racing Victoria for the purpose of it fulfilling its regulatory functions such as monitoring, investigating and enforcing the Rules. Racing Victoria will handle your personal information in accordance with its own privacy policy available at https://www.racingvictoria.com.au/privacy-policy. Please note that Racing Victoria may disclose your personal information and/or betting records to a third party in accordance with section 91E of the Racing Act, Racing Victoria’s privacy policy, or as otherwise permitted by law. For example, Racing Victoria may disclose your personal information to a third-party service provider of Racing Victoria retained for the strict purpose of assisting Racing Victoria to fulfill its regulatory functions (described above).; and
* to a successor entity in the event of a business transition, such as a merger, corporate reorganisation or to a purchaser of part of or all of BetEstate’s assets, if we have informed you of the particular third party to whom it will be disclosed, at the time of collection;
* in order to participate in activities with business partners and sponsors, who will be identified to you when the relevant Personal Information is collected, excluding identification information collected for identity verification purposes;
* to the extent necessary to carry out the uses which are set out above;
* if the disclosure is required by law, permitted by the Australian Privacy Principles, necessary to co-operate with a judicial process or a law enforcement agency, necessary to protect and defend the rights or property of BetEstate, this site, or participating sites, or necessary to lessen or prevent unlawful activity or serious threats to individuals, public health or safety; where you have consented to its disclosure either expressly or by the circumstances and your conduct.
Should the information be transferred to a third party, BetEstate will use reasonable endeavours to ensure that the information disclosed is protected by the third party under contractual arrangements and in accordance with the Privacy Act.
* We may also collect, use and disclose your Personal Information for secondary purposes related to the primary purpose including in circumstances where you may reasonably expect such collection, use or disclosure and/or for purposes including (but not limited to) trading, risk management, integrity, compliance, minimum bet laws and/or other related purposes including purposes reasonably required by applicable Principal Racing Authorities (Secondary Purposes). You acknowledge We can provide your Personal Information to BetMakers (the provider of our platform technology and/or managed trading services) - who can also use and disclose your Personal Information these purposes (including Secondary Purposes). Further, We may collect information from Betmakers, other service providers, regulators, racing bodies, sporting bodes and other third parties associated with our products and services. Collection of such information may include information aggregated by a third party.
For clarity, the uses listed above do not apply to identification information collected for identity verification purposes where those uses would be inconsistent with the “Identity Verification” section of this Privacy Policy. Identification information collected for identity verification is not used for direct marketing, promotional activity, advertising, profiling, behavioural analysis, market research, or unrelated commercial purposes.
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. BetEstate 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.
Data-security
You acknowledge that no data transmission over the internet is completely secure. Accordingly, BetEstate does not warrant the security of any information you transmit to it and any such transmitted information to BetEstate is done so at your own risk. Notwithstanding these risks, BetEstate will take reasonable steps to protect Personal Information from misuse, loss, and unauthorised access, modification and disclosure.
Non-Personal Information
We may decide to use and disclose non-personal information relating to your account usage. For example, we may decide to disclose aggregate average data for statistical purposes to current or potential stakeholders in BetEstate or for determining future marketing plans or upgrades to our website.
Apart from mandatory information we need to provide our services to you, there may be data that does not personally identify you collected to monitor and improve our service. For example, when a web page is visited the URL of the page is recorded together with the time and date and the browser software being used.
Each time you log into your account on our website, our web server will issue you with a cookie to authenticate you as the account holder. Once you are logged into your account on our website, specific or aggregate information may be collected and logged for security purposes. For example, our server recognises your domain name, IP address and the pages that you visit. These logs may be used for the resolution of problems and disputes.
Access and Correction
We will take reasonable steps to ensure that the Personal Information we collect is accurate, complete and up to date. 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 area of the website.
Identity Verification
We use identity verification services to verify your identity and comply with applicable laws, regulatory requirements, account security obligations, fraud prevention requirements and anti-money laundering and counter-terrorism financing obligations.
To assist in verifying your identity, we may collect, use and disclose identification information, including your name, address, date of birth and identity document details.
This information may be checked against official record holder information using third-party identity verification systems and services. These may include our identity verification provider, FrankieOne, and other service providers involved in facilitating identity verification on our behalf.
Identification information collected for identity verification is used and disclosed only for identity verification and related legal, regulatory, audit and record-keeping purposes.
We do not use or disclose identification information collected for identity verification for:
• marketing or promotional purposes;
• advertising;
• profiling or behavioural analysis;
• offering goods or services;
• enabling another person or entity to offer, advertise or promote goods or services; or
• market research.
Before we collect, use or disclose your identification information for identity verification, we will obtain your express consent.
The general uses and disclosures of Personal Information described elsewhere in this Privacy Policy do not apply to identification information collected for identity verification to the extent those uses or disclosures would be inconsistent with this section.
Managed Trading Services
Customers acknowledge that the BETESTATE platform is powered by technology provided by BetMakers, and BetMakers provides expert trading and customer liability management services (collectively Managed Trading Services) on behalf of BETESTATE . Accordingly, BETESTATE will provide BetMakers such Customer data (including personal information) to the extent that is reasonably needed by BetMakers to host and maintain the BETESTATE platform and/or provide Managed Trading Services. BetMakers performs the Managed Trading Services in accordance with the trading strategy determined by BETESTATE. To preserve confidentiality over Customer Data, BETESTATE has entered into legally binding contract/s that obligate BetMakers (which is an ISO 27001 certified company – the international gold-standard for information security management systems) to maintain confidentiality over all Customer data which it receives.
For clarity, BetMakers is not entitled to disclose Customer data (including personal information) to third parties - including any other wagering operator to whom BetMakers provides Managed Trading Services. That said, the Customer acknowledges that BetMakers' trading staff are entitled to utilise their general industry know-how and experience when providing Managed Trading Services to BETESTATE. If, for example, a member of the trading staff is, by virtue of their experience (and/or their access to publicly available information), aware that a renowned customer is “sharp” on racing, such staff member is entitled to use that general know-how for the benefit of BETESTATE The Customer acknowledges and accepts that it is not reasonable (or indeed possible) for BetMakers' trading staff members to ‘forget’ (or ignore) his/her know-how, drawn from years of experience, when providing risk and/or trading services for the benefit of BETESTATE.
Consent
You consent to the use or disclosure of your Personal Information in circumstances which are:
* set out in this Privacy Policy;
* clearly explained to you at the time when the information is collected from you; or
* permitted under the Australian Privacy Principles.
Contact Details
If you have any queries, requests for access or correction or complaints relating to the handling of your personal information, please contact us at [[email protected]](mailto: [email protected]).
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.
Disclaimer
BetEstate and this Privacy Policy may be subject to applicable legislation, regulations and codes of practice. To the extent that this policy exceeds the minimum obligations of BetEstate under the Commonwealth and Territory legislation, this policy serves as a documentation of our voluntarily self-imposed standards.
While we are determined to meet those standards as best we can, to the extent permitted by law, BetEstate is not liable if it does not adhere to any of these voluntary self-imposed standards, for any loss, liability, costs, expense or damage arising as a result of BetEstate failing to meet any of the voluntarily self-imposed standards in this policy.