Privacy Policy

West HQ

West HQ Limited ACN 000 842 375 (Company, West HQ, we or us) recognises the importance of protecting the privacy and the rights of individuals concerning their personal information. This privacy policy tells you how we collect and manage your personal information.

We respect your rights to privacy under the Privacy Act 1988 (Cth) (Act), and we comply with all of the Act’s requirements in respect of the collection, management and disclosure of your personal information.

By using our website at https://westhq.com.au/ (Website), using our goods and/or services or by otherwise providing your personal information to us, you confirm your acceptance of the terms of this policy and consent to us handling your personal information in accordance with this policy.

Purpose

The purpose of this policy is to ensure that West HQ complies with the Act (including any amendments to the Act) and the Australian Privacy Principles (APP), which govern the way that APP entities must manage personal information. We are also required to collect your name, address, date of birth and other verification information under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).

When used in this policy, the term “personal information” has the meaning given to it in the Act. In general terms, it is any information that can be used to identify you personally. This may include your name, address, telephone number, email address, biometric information and profession or occupation. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.

Collection

What personal information do we collect and hold?

We may collect the following types of personal information:

• name;
• mailing or street address;
• email address;
• telephone number;
• age or birth date;
• profession, occupation or job title;
• photographs (including ID registration submitted for membership);
• details of the products and services you have purchased from us or which you have enquired about, together with any additional information necessary to deliver those products and services and to respond to your enquiries;
• any additional information relating to you that you provide to us directly or indirectly through the use of our websites or online presence, through our representatives or otherwise. This may include your IP address which will enable us to correlate that information with our membership database; and
• information you provide to us through our service centre or customer

For what purposes do we collect, hold, use and disclose your personal information?

We collect personal information about you so that we can perform our business activities and functions and to provide the best possible quality of customer service.

We collect, hold, use and disclose your personal information for the following purposes:

• to provide products and services to you and to send communications requested by you;
• to answer enquiries and provide information or advice about existing and new products or services;
• to provide you with access to protected areas of our website;
• to assess the performance and to improve the operation of the website;
• to conduct business processing functions including providing personal information to our related bodies corporate, contractors, service providers or other third parties;
• for secure access to facilities and events;
• to identify individuals who have been self-excluded from our premises;
• to prevent minors from accessing gaming machine areas and to assist with removing any minor from those areas;
• for the administrative, marketing (including direct marketing), planning, product or service development, quality control and research purposes of the Company, its related bodies corporate, contractors or service providers;
• to provide your updated personal information to our relevant bodies corporate, contractors or service providers;
• to keep your contact details up to date;
• to process and respond to any complaint made by you; and
• to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority of any country.

We encourage you to check our Website regularly for any updates to this policy. We may update this policy whenever we consider appropriate, for example, to reflect changes to the law or to our business.

How do we collect your personal information?

We collect your personal information directly from you unless it is unreasonable or impracticable to do so. When collecting personal information from you, we may collect in ways including:

• through your access and use of our website;
• upon entering our premises;
• during conversations between you and our representatives; or
• when you complete a membership application form or complete a

Whilst we strive to only collect personal information about you from you, there may be circumstances where it is unreasonable or impractical to do so. For example, it may be unreasonable or impractical to collect information from you when the information is provided by other members, or staff or the police.

We may also collect personal information from third parties including from third party companies such as credit reporting agencies, law enforcement agencies and other government entities.

Biometric Information

We utilise facial recognition technology to enhance our security procedures, to identify and remove individuals who have been self-excluded from our premises and to authenticate and verify customer identities in a secure manner. The collection of your faceprint is reasonably necessary for the activities and functions of West HQ. Without collecting your faceprint, West HQ cannot comply with its obligations under the self-exclusion scheme contained in section 45 of the Gaming Machines Regulation 2019 (NSW). A ‘faceprint’ is a digitally recorded representation of an individual’s face based on the location, size and shape of the individual’s facial features.

Facial Recognition Cameras

When you are at our premises, our designated security cameras will capture a photo of your face and then generate a faceprint of your face based on that photo. Your faceprint will then be compared against our database of individuals who have been self-excluded from our premises.

If your faceprint matches the faceprint of an individual in the database of persons who are identified as self-excluded from our premises, you will be refused entry or asked to leave. Your faceprint will be deleted shortly after confirming that it does not match the faceprint of any person contained in the database.

If you have been self-excluded from our premises, we will collect your faceprint from your photo held on file (e.g., from the photo on your self-exclusion documentation) and will hold a copy of that faceprint while you remain self-excluded from our premises.

ID Scanners

When entering our premises, a photo is also captured at the ticket verification kiosk and compared with the photograph presented on a photo identification card, digital driver’s licence or membership profile.

Unless you agree to the contrary, we will destroy the biometric template created during this process upon providing positive or negative identity verification.

Photographs of individuals (members, visitors and guests) are collected and stored as part of the entry requirements of the venue which is governed by the Registered Clubs Act 1976 (NSW).

Cookies

In some cases, we may also collect your personal information through the use of cookies. When you access our website, we may send a “cookie” (a small summary file containing a unique ID number) to your computer. This enables us to recognise your computer and greet you each time you visit our website without bothering you with a request to register. It also enables us to keep track of products or services you view so that, if you consent, we can send you news about those products or services. We also use cookies to measure traffic patterns, determine which areas of our website were visited and measure transaction patterns in the aggregate. We use this to research our users’ habits so that we can improve our online products and services. If you do not wish to receive cookies, you can set your browser so that your computer does not accept them.

We may log IP addresses (electronic addresses of computers connected to the internet) to analyse trends, administer the website, track users movements, and gather broad demographic information.

Information about third parties

If you provide us with personal information about a third party, in doing so you will be representing to us that you have that third party’s consent for us to collect and handle their personal information in accordance with this policy – and we will be collecting the information on that basis.

Job applicants, staff, contractors, suppliers and volunteers

We also collect personal information about job applicants, our staff, volunteers who work with us, and details of other people who come into contact with West HQ such as contractors and suppliers for the primary purpose of assessing and engaging or employing the person. West HQ also holds and uses such personal information for the managing the employment or engagement of such persons to meet its legal obligations.

What happens if we can’t collect your personal information?

 If you do not provide us with the personal information described above, the following may happen:

• we may not be able to provide the requested products or services to you, either to the same standard or at all;
• we may not be able to provide you with information about products and services that you may want, including information about discounts, sales or special promotions; or
• we may be unable to tailor the content of our websites to your preferences, and your experience of our websites may not be as enjoyable or useful.

Use and Disclosure

To whom may we disclose your information?

We only use and disclose your personal information for the purpose for which it was collected, or for a related purpose as permitted by the Act or for uses which you have given consent (which may be express or implied). Your personal information will not be shared, sold, rented or disclosed other than as described in this Privacy Policy.

We may disclose your personal information to:

• our employees, related bodies corporate, contractors or service providers for the purposes of operation of our website or our business, fulfilling requests by you, and to otherwise provide products and services to you including, without limitation, web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, debt collectors, and professional advisors such as accountants, solicitors, business advisors and consultants;
• suppliers and other third parties with whom we have commercial relationships, for business, marketing, and related purposes;
• any organisation for any authorised purpose with your express consent;
• anyone whom we are required or authorised by law to do so;
• relevant authorities when West HQ believes that unlawful or undesirable activity is being or has been conducted; or
• anyone authorised by you to receive your personal information (your consent may be express or implied, and can be withdrawn at any time).

Other than the above, we will generally only disclose your personal information (including sensitive information) to third parties on the basis that they agree with us to keep your information confidential (except where we are authorised or required by law to disclose the information). In addition, West HQ will otherwise only disclose personal information to a third party where West HQ has a belief that its use and/or disclosure is necessary:

• to lessen or prevent threats to an individual’s life, health or safety;
• to investigate any unlawful or undesirable activity or serious misconduct which is being or has been conducted;
• to assist enforcement bodies with their activities;
• to assist in locating a missing person;
• to establish, exercise or defend a legal or equitable claim; or
• for the purpose of confidential alternative dispute

You consent to us disclosing your personal information to the third parties listed above, and similar organisations who may in turn provide your information to other third parties. You can withdraw your consent at any time by informing us in writing (except where we are authorised or required by law to disclose the information).

We may combine or share any information that we collect from you with information collected by any of our related bodies corporate (within Australia).

Direct marketing materials

West HQ may send you direct marketing communications and information about our products and services that we consider may be of interest to you. We will send these communications in various forms, including: mail, SMS, and email, following applicable marketing laws, such as the Spam Act 2003 (Cth). You consent to us sending you those direct marketing communications by any of those methods. If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so. In addition, at any time you may opt-out of receiving marketing communications from us by contacting us (see details below) or by using opt-out facilities provided in the marketing communications. We will then ensure that we remove your name from our mailing list.

We do not provide your personal information to other organisations for direct marketing.

How can you access and correct your personal information?

You may request access to any personal information we hold about you at any time by contacting us (see details below). Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). We may charge you a fee to cover our administrative and other reasonable costs in providing this information to you. We will not charge for simply making the request and will not charge for making any corrections to your personal information.

There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.

If you believe that personal information, we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment, then we will add a note to the personal information stating that you disagree with it.

What is the process for complaining about a breach of privacy?

 If you believe that we have breached your privacy, please contact our Privacy Officer using the contact information below and provide details of the incident so that we can investigate it.

We request that you hand in written complaints about breaches of privacy so that we can be sure about its details. Our Privacy Officer deals with privacy complaints, and any complaints should be directed to our Privacy Officer using the contact details below. We will attempt to confirm as appropriate and necessary with you your understanding of the conduct relevant to the complaint and what you expect as an outcome. We will inform you whether we will conduct an investigation, the name, title, and contact details of the investigating officer and the estimated completion date for the investigation process.

After we have completed the investigation, we will advise you of the outcome in writing. You are welcome to respond. If we receive a response from you, we will assess it and advise if there have been changes.

Links

Our website may contain links to other websites operated by third parties. We make no representations or warranties concerning the privacy practices of any third-party website, and we are not responsible for the privacy policies or the content of any third-party website. Third-party websites are responsible for informing you about their privacy practices.

Changes to our privacy policy

We reserve the right to review and amend the privacy policy from time to time.

Overseas Disclosure

Generally, we will not disclose your personal information to overseas recipients except with your consent or where we are required or authorised to do so by law. Occasionally, we may disclose personal information to overseas recipients in the course of our business. Where we do disclose your personal information to overseas third parties, we will take such steps as are reasonable to ensure that your personal information is handled in accordance with the Act and this policy.

Data Breach

If a data breach or suspected data breach occurs, we will undertake a prompt investigation, which will include an assessment of whether the incident is likely to result in serious harm to any individuals. In such a situation we will comply with the requirements of the Act which may require notification to the Office of the Australian Information Commissioner (OAIC) and affected individuals. Please contact us if you have reason to believe or suspect that a data breach may have occurred, so that we can investigate and, if necessary, undertake appropriate containment, risk-mitigation and notification activities as required.

Contacting us

If you have any questions about this policy, any concerns or a complaint regarding the treatment of your privacy or a possible breach of your privacy, please use the contact link on our website or contact our Privacy Officer using the details set out below.

We will treat your requests or complaints confidentially. Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how we can solve them. We will aim to ensure that we resolve your complaint in a timely and appropriate manner.

Please contact our Privacy Officer at

Email: [email protected]

Post: West HQ Limited, 33 Railway Street, Rooty Hill, NSW, 2766

Tel: 9625 5500