- why we require and how we aim to use personal information;
- what types of personal information we might collect;
- when we will disclose personal information to others;
- how we hold and secure personal information;
- how you can access and seek correction of personal information we hold about you; and
- how you may make a complaint if you think we have breached our obligations.
Please note the Australian Privacy Principles do not apply to employee records. As a result, this statement does not apply to ALH Group's treatment of employee records where the treatment is directly related to a current or former employment relationship between ALH Group and an employee.
1. Compliance with the Privacy Legislation
2. Collection and Use of Personal Information
We will collect personal information from you directly and from your use of our products and services (including attendance at venues). We may collect information about you from others, such as our related bodies corporate or third party service providers or contractors. We may also collect information about you that is publically available, for example from media publications, social media, and the internet or made available by third parties.
ALH Group only collects and uses personal information that we consider necessary or desirable for us to carry out our many business functions or activities, including, without limitation, so we can:
- establish your identity to assess applications for certain products or services;
- administer our products and services;
- manage our relationship with you;
- develop and improve our products and services;
- contact you if we need to communicate something important to you;
- identify and let you know about our products or services we think might interest you;
- market the products and services of any of our related bodies corporate we think may interest you and enable those companies to market directly to you; and
- comply with legal requests.
If you are applying for employment or to become a contractor of ALH Group, ALH may collect personal information to assist in any assessment of your application and (if successful) engage you.
Indentifying details such as your name and address will only be collected and used where we consider we have a business reason to do so, such as providing products and services to you or a legal requirement.
We may also collect information about you because we are required to do so by law. There are laws that affect the gaming and liquor industry, such as Commonwealth Anti-Money Laundering and Counter Terrorism Financing legislation, which require certain personal information to be collected and used primarily to verify your identity.
In certain circumstances, if you do not provide us with your personal information, we may not be able to provide you with the products or services you want or let you know about other products or services from us or our related bodies corporate that you may be interested in.
3. Types of Personal Information Collected
ALH Group offers a diverse array of hospitality experiences including bistros, restaurants, sports bars, electronic gaming, accommodation and nightclubs, therefore the purpose and type of personal information which we may collect from you will vary depending upon the relationship you may have with us. For example, we may require certain information about you should you apply for employment, which is different from the information you supply if you are entering a competition or joining a loyalty program.
The most common situations where we may collect personal information from you include entry conditions, gaming procedures and regulations, loyalty programs, marketing and promotions, accommodation bookings, employment applications, social media and situations where the law requires.
The most common types of personal information we may collect include:
- identification information such as your name, address and date of birth;
- contact details such as email address and phone numbers; and
- financial details such as tax file number and bank details.
We may also collect and use copies of documents to confirm your personal information. Typically this will relate to your identity as verified by a drivers licence or passport.
ALH Group will only use or disclose personal information for the purpose which was either specified or reasonably apparent at the time of collection. We may also use or disclose it for other related purposes for which you would reasonably expect it to be used.
ALH Group does not generally disclose personal information to third parties except:
- where we consider that third party contractors appointed by ALH Group require access to personal information held by us to perform services or provide products for us or on our behalf;
- to related bodies corporate;
- to agents of ALH Group;
- where ALH Group is required or authorised by law; or
- with your consent.
Should third parties be given access to personal information, ALH Group requires that our contractors and agents are obliged to keep that personal information confidential and not to use or disclose it for any purpose other than performing services or providing products for us or on our behalf.
You consent to us disclosing your personal information to third parties as per the above. You can withdraw such consent at any time by informing us in writing that you withdraw your consent.
In certain circumstances, if you do withdraw such consent, we may not be able to provide you with the products or services you want or let you know about other products or services from us or our related bodies corporate that you may be interested in.
Generally, ALH Group uses systems located within Australia. However, from time to time we may send your information overseas to service or product providers or other third parties who operate or hold data outside Australia or its external territories. Where we do this, we take reasonable steps to ensure that appropriate data handling and security arrangements are in place.
Given ALH Group offers a diverse array of hospitality experiences, we would like to inform you of our products and services or the products and services of our related bodies corporate from time to time. ALH Group may use your personal information that we collected from you to send marketing or promotional material about our food and beverage offers, entertainment and events, competitions and promotions or membership and loyalty programs or to enable our related bodies corporate to directly market their products and services to you.
We or our related bodies corporate may conduct these marketing activities via email, telephone, SMS, social media or other means.
ALH Group will generally only send you marketing material on an ‘opt-in’ basis. If you no longer wish to receive the material, each time you are sent a marketing communication we will provide an easy opportunity for you to ‘opt-out’ or you may contact us and we will process your request as soon as practicable.
6. Web Site Users
ALH Group may collect "clickstream" information (this may include which areas of our websites you have accessed, the time and date of access, the type of browser software used) from your use of our websites. We may also store "cookie" information (such as user preferences relating to your use of our websites) on your computer. That information is used to customise and improve our websites, products and services.
ALH Group does not use "cookies" to retrieve information from your computer that was not originally sent by us. We do not allow or share third party access to "cookies" placed by our websites. If you do not want us to store "cookie" information on your computer, you can adjust the settings on your Internet browser to disable this feature. However, parts of our websites will not function if "cookies" have been disabled.
7. How we Hold and Secure Personal Information
ALH Group will take reasonable steps to protect the personal information it collects from misuse, interference and loss and unauthorised access, modification or disclosure.
There are a number of different ways we take care of your personal information. Electronic records of personal information are held on secure servers that are password encrypted or within controlled environments such as the back office of venues which are not accessible to the general public. Physical records of personal information are stored within a controlled environment such as the back office of venues which are not accessible to the general public. Our employees are required to maintain the confidentiality of any personal information held by ALH Group. All information that is stored by third parties on our behalf is covered by contractual arrangements designed to ensure information is held in substantially the same manner as detailed above.
Once your personal information is no longer needed by ALH Group and ALH Group is not legally bound to retain such information, we will ensure measures are taken to destroy or de-identify your personal information.
8. Seeking Access
You have the right to access personal information that ALH Group holds about you (except in the limited circumstances contained in the Act). We will provide access to your personal information within a reasonable period of time upon written request. For most requests, your information will be provided free of charge, however we may charge a reasonable fee if your request requires substantial effort on our part.
Requests for access should be made in writing to the relevant ALH venue or to The Privacy Officer at ALH Group Pty Ltd, Ground Floor 16-20 Claremont Street South Yarra VIC 3141.
9. Changing Information
It is your responsibility to ensure all personal information collected from you is accurate, up to date and complete. If you wish to change personal information that is inaccurate or out-of-date, you may write to the relevant ALH venue or the ALH Privacy Officer, at the address specified in paragraph 8 above and the record will be changed as soon as practicable.
If you wish to make a complaint about a breach of the Australian Privacy Principles or Act, please contact The Privacy Officer at the address specified in paragraph 8 above. If your complaint is not resolved by the Privacy Officer, or you do not wish to contact the Privacy Officer, you can make an application to the Office of the Australian Information Commissioner at GPO Box 5218, Sydney, NSW 2001.
11. Amendments to this Policy
12. Questions About Privacy
If you have any questions or concerns about ALH Group’s collection, use or disclosure of your personal information, please contact your local ALH venue or the ALH Privacy Officer at the address specified in paragraph 8 above.
For further information about privacy issues, please refer to the Office of the Australian Information Commissioner’s website at www.privacy.gov.au