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Privacy Policy

Lillywhite Hotel Group (LHG) respects your personal information and this Privacy Policy sets out the principles that we will follow in the management of your personal information collected. Personal information is generally defined as information or an opinion that can identify you personally. LHG has policies and procedures to ensure that all personal information, no matter how or where it is obtained, is handled sensitively, securely and in accordance with the Australian Privacy Principles.

This Privacy Policy explains:
• 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 LHG’s treatment of employee records where the treatment is directly related to a current or former
employment relationship between LHG and an employee.

1. Compliance with the Privacy Legislation

LHG is committed to protecting the privacy of individuals' personal information and is bound by the Australian Privacy Principals set out in the Privacy Act 1988 (Commonwealth) (“the Act ”). We will only collect, use or disclose personal information in accordance with the Act and our Privacy Policy.

2. Collection and Use of Personal Information
We will only collect personal information from you directly and from your use of our products and services (including attendance at venues).

LHG 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; and
• comply with legal requests.

Indentifying details such as your name and contact details will only be collected and used where we consider we have a business reason to do so, such asproviding products and services to you or a legal requirement.

We may also collect information about you because we are required to do so bylaw. There are laws that affect the gaming and liquor industry, such as

Commonwealth Anti-Money Laundering and Counter Terrorism Financinglegislation, which require certain personal information to be collected and usedprimarily 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 that you may be interested in.

3. Types of Personal Information Collected
LHG offers a diverse array of hospitality experiences including bistros, sports bars, electronic gaming, accommodation, loyalty membership and events 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 driver’s licence or passport.

4. Disclosure
LHG 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.
LHG does not generally disclose personal information to third parties except:

• where we consider that third party contractors appointed by LHG require access to personal information held by us to perform services or provide products for us or on our behalf (for example Maxgaming Qld Pty Ltd in respect of LHG Rewards);
• to agents acting on behalf of LHG;
• where LHG is required or authorised by law; or
• with your consent.

Should third parties be given access to personal information, LHG 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 that you may be interested in.

5. Marketing
Given LHG offers a diverse array of hospitality experiences, we would like to inform you of our products and services from time to time. LHG 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.
We may conduct these marketing activities via email, telephone, SMS, social media or other means.
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
LHG 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.

LHG 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
LHG 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 and head office 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 head office which are not accessible to the general public. Our employees are required to maintain the confidentiality of any personal information held by LHG. 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 LHG and LHG 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 LHG 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 LHG venue or to The Privacy Officer at LHG, PO Box 7591, Garbutt Qld

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 LHG venue or the LHG Privacy Officer, at the address specified in paragraph 8 above and the record will be changed as soon as practicable.

10. Complaints
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
LHG may amend this Privacy Policy from time to time at its discretion. For a copy of the most recent version of this policy, please refer to our website www.lillywhitehotelgroup.com.au or contact the LHG Privacy Officer