Privacy Policy

This is the Privacy Policy of PuntNow Pty Ltd trading as PuntNow (hereinafter "PuntNow"). PuntNow is subject to the Privacy Act 1988 (Cth) (hereinafter referred to as "the Privacy Act"). All internet wagers placed through this platform are subject to monitoring and may be scrutinized by Racing Victoria

General Provisions

1. By using the PuntNow's platform and wagering channels, including the websites located at www.puntnow.com.au and m.puntnow.com.au (the "PuntNow Platform"), you agree to the Privacy Policy as set out below.
2. This Privacy Policy is in addition to, and should be read in conjunction with, PuntNow's General Terms & Conditions and Wagering Rules. PuntNow will review this Privacy Policy periodically and reserves the right to modify parts of this policy at any time and at its sole discretion. Changes hereto will take immediate effect upon the publication of the amended Privacy Policy on the PuntNow Platform. We recommend that you review this Privacy Policy periodically as your continued use of the PuntNow Platform will constitute acceptance of the terms of this Privacy Policy as amended.
3. This Privacy Policy will not apply to any third-party websites which are linked to the PuntNow Platform and over which PuntNow has no control.
4. In this Privacy Policy, a reference to the "Australian Privacy Principles" means the Australian Privacy Principles for the Fair Handling of Personal Information.

Personal Information

1. 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.
2. The types of Personal Information PuntNow may collect from you include:
   • Name
   • Home address
   • Date of Birth
   • Gender
   • Photographs or images
   • Personally submitted preferences
   • Bank account and Debit card information
   • Financial information
   • Email address
   • Additional identity verification information.

Collection

1. You are welcome to browse the PuntNow Platform without ever providing us with your Personal Information. However, if you wish to complete any banking or wagering transactions, 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.
2. PuntNow collects Personal Information as is required for the reasonable operation of our business as a licensed wagering provider. We will only collect such information as is necessary to identify you and for your own security and the maintenance of your account.
3. 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.
4. Any Personal Information that we collect can be viewed in the 'Profile' tab of the 'My Account' section of the PuntNow Platform.

Disclosure

1. When we collect your Personal Information, we may use this information to:
   • Provide you with the services you have requested, or meet the purpose for which the information was provided;
   • Upgrade, enhance and personalise your experience within the PuntNow Platform, and/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 the more efficient operation of the PuntNow Platform;
   • Investigate or verify your compliance with our General Terms and Conditions and our Wagering Rules or to enforce our legitimate rights associated with this, or to investigate or verify your compliance with wagering and other laws; or
   • Determine your liability with respect to Goods and Services Tax and other taxes.
2. By choosing to provide Personal Information, you consent to our using your Personal Information in the manner set out above.
3. PuntNow does not give, sell, rent, share, or trade any Personal Information regarding our Customers to third-parties, except where you have consented to its disclosure ether expressly or impliedly by way of your conduct or the circumstances surrounding your provision of the Personal Information, or for any of the following purposes:
   • To enable PuntNow to perform its obligations to the Customer under the PuntNow General Terms & Conditions and/or Wagering Rules;
   • To enable PuntNow to ensure that the Customer performs their obligations under the PuntNow General Terms & Conditions and/or Wagering Rules;
   • To a credit reporting agency or otherwise to verify a Customer's identity;
   • For planning, research, promotion and marketing of our products and services;
   • To PuntNow' contractors, and other external service providers associated with the operation of the PuntNow Platform, the PuntNow business and/or the provision of its services, including, without limitation, associated data centres, web hosting providers, payment service providers, identification verification service providers, professional advisors and consultants;
   • To government and regulatory authorities and other organisations as required and/or or authorised by law or otherwise permitted under the Privacy Act;
   • 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;
   • 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 PuntNow's assets
   • In order to participate in activities with business partners and sponsors, who will be identified to you when the relevant Personal Information is collected;
   • To the extent necessary to carry out the uses which are set out above;
   • To co-operate with a judicial process or a law enforcement agency, necessary to protect and defend the rights or property of PuntNow, the PuntNow Platform; or
   • To lessen or prevent unlawful activity or serious threats to individuals, public health or safety.
4. Should any Personal Information be transferred to a third-party, PuntNow will use reasonable endeavours to ensure that the information disclosed is protected by said third-party under contractual arrangements and in accordance with the Privacy Act.
5. All PuntNow employees are subject to confidentiality agreements in respect of the personal details of PuntNow Customers and trading habits.
6. PuntNow may disclose your personal information to Racing Victoria Limited (ACN 096917930) (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. PuntNow is subjcet 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 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 provided of Racing Victoria retained for the strict purpose of assisting Racing Victoria fulfill its regulatory functions (described above)

Identity & Document Verification Service

1. You hereby confirm that the Personal Information you provided when registering your account is true and correct and that you are authorised to disclose said information.
2. PuntNow may engage a third-party to provide identity verification services in order to more efficiently and comprehensively verify the identity of PuntNow Customers.
3. This Personal Information collected from you may be used for the purpose of verifying your identity and it may be supplied to any third-party engaged by PuntNow to provide such identity verification services. You hereby consent to this disclosure and use of your Personal Information.
4. The process of verifying your identity may involve checking your personal information against third-party and government databases and/or credit headers.

Cookies

1. Personal Information may also be collected by cookies when you use the PuntNow Platform. When you access the PuntNow Platform, cookies may record details relating to your use of the PuntNow Platform.
2. PuntNow does not use cookies to track your Personal Information and uses them for internal management purposes only.
3. We may use third-parties to serve ads to the PuntNow Platform. These companies may employ cookies and action tags, single pixel gifs or web beacons in order to measure advertising effectiveness. Any information that these third-parties collect via cookies and action tags is completely anonymous.

Data Security

1. You acknowledge that no data transmission over the internet is completely secure. Accordingly, PuntNow does not warrant the security of any information you transmit to it and any such transmitted information to PuntNow is done so at your own risk. Notwithstanding these risks, PuntNow will take reasonable steps to protect Personal Information from misuse, loss and any unauthorised access, modification and disclosure.
2. Your information is unlikely to be disclosed to any entity that is outside Australia. PuntNow's core operations are conducted within Australia. Where overseas transmission of information is necessary for a genuine business purpose and/or by a third party, PuntNow will take reasonable steps to ensure that such information is handled to the same standard as Australian privacy laws.

Non-Personal Information

1. 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 PuntNow or for determining future marketing plans or upgrades to our website.
2. Apart from Personal Information and other information that we need collect in order to provide services to you, there may be data that does not personally identify you that is collected for the purpose of monitoring and improving our services. 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.
3. 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 & Corrections

1. 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 My Account section after logging on.
2. To otherwise request access or correction of your personal information, please contact us.

Consent

1. 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
   • Otherwise permitted under the Australian Privacy Principles.

Contact Details

1. If you have any queries or complaints relating to the handling of your Personal Information, please contact our Operations Manager at [email protected]
2. 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

1. PuntNow 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 PuntNow 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, PuntNow 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 PuntNow failing to meet any of the voluntarily self-imposed standards in this policy.