Privacy Policy

Who does this policy apply to and what does it cover

This policy sets out how Serbian Centre Club Limited and its related entities (“Club”, “we”, “us” or “our”) collect, use, disclose and hold “personal information”. “Personal information” means information or an opinion about an individual (who can reasonably be identified), whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not.

This policy may be updated or revised by the Club at any time and without prior notice.

What is our privacy commitment

We are committed to complying with our obligations under the Privacy Act 1988 (Cth) “Privacy Act” by protecting the privacy and confidentiality of your personal information. When we collect, use, disclose, store, access or correct your personal information, our actions will comply with the Privacy Act and the Australian Privacy Principles. Where appropriate, we will handle your personal information relying on the employee records exemption and the related bodies corporate exemption in the Privacy Act.

What kinds of personal information does the Club collect and hold

We collect and hold a wide range of personal information, and in some cases sensitive information, including:

• your personal details, including your full name, residential address, email address, contact number, date of birth, gender, occupation and religion.
• your passport number when scanning your passport to apply for membership, or renew your membership, with us.
• your signature.
• information related to your entry to the Club’s premises.
• a photo of you for your membership card.
• CCTV footage of you on the Club’s premises.
• a copy of your biometric “faceprint” derived from videos or images of you and any metadata associated with the Club’s use of facial recognition technology, to assist the Club to:
o identify individuals who have been suspended, banned or self-excluded from all or part of the Club’s premises.
o comply with requests we receive from time to time from enforcement bodies (such as the Police) and regulatory authorities (such as AUSTRAC) to identify and report certain individuals; and
o comply with the Club’s obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act).

• if you choose to scan your driver’s licence or passport with one of our electronic ID scanners when entering the Club:
– your name, address, signature, photograph and expiry date will be extracted from your driver’s licence by ID scanner software.
– A copy of your passport when you scan your passport.
(You have the option to not have your ID scanned and for the required information to be manually inputted by one of our staff into our sign-in technology).
• details of your membership of the Club, including any positions held by you at the Club or any complaints made by you or against you in connection with the Club.
• information about what goods or services you buy or receive from the Club.
• details of your activities at or in connection with the Club, including your participation in social, sporting or other organised activities.
• health information, including any medical conditions you may disclose to us to enable us to provide goods or services or access to our facilities to you.
• the name and contact details of your next of kin.
• information connected to your use of our gaming machines (including your player activity statements and prizes you receive) and, where required by law, the identifying numbers of the ID you present when redeeming a gaming machine ticket.
• information about you related to a liquor or gaming self-exclusion or banning order about you from yourself, other clubs, ClubsNSW Multi-Venue Self-Exclusion (MVSE), BetSafe, a Liquor Accord or Liquor & Gaming NSW.
• things you say or do (or things said about you) in connection with an incident or disciplinary proceedings at or in connection with the Club.
• bank account details and credit card details (where you have applied for a direct debit or other financial arrangements with the Club).
• information related to your use of our Wi-Fi from any of your personal devices.
• information about your use of our websites and social media pages, including your IP address, and any information collected by cookies as a result of your use of our websites and social media pages.
• licence plate numbers of any vehicles which enter the Club’s carpark (this information is stored separately to
information which the Club holds about individuals);
• if you apply for a job with us, the information in your resume and other information that you or your referees provide to us and notes of our interactions with you and/or others in relation to your prospective employment.

From time to time, we may collect additional information about you related to surveys, promotions and particular services or activities at or in connection with the Club. Wherever practicable, we will advise you of the information being collected about you and provide you with an opportunity to refuse the collection of that information.

How do we collect your personal information

Your personal information is collected as a result of your visits to, or dealings with, the Club. Information is collected by recording information that you provide to us, by electronic means, and by the observations of our staff. We collect personal information when you:
• enter, visit or deal with the Club;
• apply for, or renew, your membership of the Club and our related entities or request to use our services;
• apply for or use your membership card or other issued cards at or in connection with the Club;
• purchase goods or services from us;
• apply for a direct debit or other financial arrangement with the Club;
• fail to make a payment you are required to make to the Club or our related entities;
• use our gaming machines or request to be excluded from using our gaming machines;
• engage in conduct which the Club reasonably believes may contravene the AML/CTF Act;
• enter into a gaming self-exclusion agreement with us or otherwise participate in a gaming self-exclusion program and nominate to exclude yourself from all or part of our premises;
• have been reported to us by an enforcement body or regulatory authority as a person we are required to identify, monitor and/or report to them (such as a person wanted by the Police).
• access or use our Wi-Fi from any of your personal devices;
• book or attend a function or show at a venue we operate;
• plan an event to be held with us;
• participate in activities offered by the Club, including competitions and promotions;
• visit one of the websites or social media pages operated by the Club (including the Club’s Facebook, Instagram, Linkedin, You Tube and Tik Tok accounts).
• are suspended, banned or removed from any part of the Club’s premises.
• are involved in, witness or are connected to an incident or disciplinary proceedings at or in connection with the Club; and/or
• receive or request sponsorship through programs such as ClubGRANTS.
• apply for, or renew, your membership of one or more of the Club’s sub-clubs or participate in the activities of those sub-clubs.
• Participate in events where photography, filming or videoing takes place.
• Apply for or renew your membership with the gym or one of the sporting facilities owned and run by the Club.
• Apply for a job with us.

In general, if you contact us, we may keep a record of that correspondence. In most cases we will only collect personal information about you from you or from your parent or legal guardian. We may also collect your personal information from other sources if it is unreasonable or impractical for us to collect the information from you directly. For example, it may be unreasonable or impractical to collect information from you when the information is provided by other members, our staff or the Police.

We may also collect information about you from:
• other clubs and industry bodies if you have excluded yourself from all or part of the Club’s premises, including in relation to ClubNSW’s “ClubSAFE” self-exclusion system. For more information about ClubSAFE, please go to www.clubsnsw.com.au.
• an enforcement body or regulatory authority where the enforcement body or regulatory authority (whichever the case may be) has asked us to identify you.

How am I notified that my personal information is being collected

When we collect information from you, we will take reasonable steps to notify you (or otherwise ensure that you are aware) of the following:
• our identity and contact details.
• the facts and circumstances of the collection.
• details of any laws that require or authorise the collection.
• the purposes of the collection.
• the consequences if we do not collect the information.
• that this policy contains information about how you can access or correct your information or make a complaint about the Club; and
• whether we are likely to disclose the information overseas (and, if so, to which countries).

One way we notify you of the above is by making you aware of this policy.

If you give us personal information about others, we expect that you will tell them about this policy.

The Club is required by law to collect personal information

As a registered club, we have a legal responsibility to collect certain information about our members and guests pursuant to legislation, including the Registered Clubs Act 1976 (NSW) (Registered Clubs Act), Corporations Act 2001 (Cth) (Corporations Act), Gaming Machines Act 2001 (NSW), Liquor Act 2007 (NSW), AML/CTF Act and Work Health and Safety Act 2011 (NSW).

For example, when a person applies for membership of the Club, we must collect details including their name and address. We must display that person’s name and proposed member number on the Club’s notice board before our Board is able to consider their application for membership. We may also be required to provide information under certain legislation to any member of the public who makes a request under certain legislation, including the Corporations Act.

Temporary members, guests of members and other visitors to the Club may be required to produce a recognised form of identification (such as a driver’s licence or passport) to gain entry into the licenced premises.

If you elect to use our electronic ID scanners, we will collect information from your ID using our ID scanning software, as described in our Frequently Asked Questions section below. Otherwise, if you prefer not to use our scanners, our staff can manually collect the necessary information from your ID.

Why does the Club collect, hold, use and disclose your personal information

We collect, hold, use and disclose your personal information to operate the Club at its various businesses, carry out certain activities, provide products and services to you, other members and guests and other members of the public, and comply with our legal obligations. The purpose of collecting your personal information is to undertake one or more of the following activities or functions:
• consider applications and renewals of membership;
• identify who comes to the Club’s premises and verify their details, including age and address;
• identify individuals who have been suspended, banned or self-excluded from all or part of the Club’s premises;
• identify, monitor and report individuals who are suspected of breaching the AML/CTF Act;
• identify, monitor and report any individuals that an enforcement body or regulatory authority has asked us to identify, monitor and/or report;
• create registers and display information as required by the Registered Clubs Act;
• provide a safe environment for you, other members and guests and our staff;
• provide services to you, other members and guests;
• carry out accounting, financial, legal and administrative functions and comply with our reporting requirements;
• operate the golf course and sports complex (including the gymnasium and ice rink);
• maintain and improve the functionality of our websites and apps;
• provide Wi-Fi at the Club;
• provide an events management service;
• operate functions at our venues;
• carry out competitions and promotions;
• perform gaming operations;
• publish and distribute newsletters;
• carry out marketing (including direct marketing);
• offer and manage sponsorships including by supporting community sports and social events;
• provide ticketing services;
• offer dining options and other entertainment, including shows;
• operate the Club’s sub-clubs, including publishing contact details of committee members;
• facilitate or assist the Club’s related entity’s provision of services to you;
• conduct elections of the Board;
• investigate an incident or conduct disciplinary proceedings at or in connection with the Club;
• resolve a complaint;
• assess an applicant’s suitability for employment; and
• maintain a social record of the Club and its community, including sharing photographs of activities and functions and the Club via the Club’s website and social media pages;
• promote the objects of the Club;
• improve our services and increase membership of the Club.

If you are unwilling to provide your personal information

If you don’t give the Club your personal information, you may not be able to become a member of the Club or use the Club’s services or facilities or access the Club’s premises.

If you provide us with some but not all of the information sought, then, depending on the information withheld, we may be able to provide you with certain goods and services but only to a limited extent.

You have the option of not identifying yourself, or of using a pseudonym, when dealing with us. However, this will typically be limited to enquiries of a very general nature and only over the telephone through one of our websites or by email.

In most circumstances, you will be unable to deal with the Club anonymously or with a pseudonym because of our obligations under the Registered Clubs Act.

Using your personal information

We use your personal information primarily to allow us to carry out the activities and functions listed above. We also use your personal information for secondary purposes (such as reporting and surveys) related to those activities and functions, or when permitted under the Privacy Act.

The Club may collect, use, store and disclose your personal information to ensure compliance with our legal obligations under the AML/CTF Act and to comply with any requests and directions we receive from enforcement bodies and regulatory authorities.

If you have self-excluded yourself from all or part of the Club’s premises and nominated other clubs from which you also want to be excluded, we may disclose your personal information through Multi-Venue Self Exclusion (MVSE) to those clubs to the extent necessary to assist those clubs to comply with your self-exclusion.

Similarly, if we receive personal information about you from:
• a multi-venue self-exclusion program operator (such as Bet Safe), we may use the information we receive to the extent necessary to assist you and the provider to comply with your self-exclusion.
• an enforcement body or regulatory authority, we may use the information we receive to the extent necessary to comply with any directions which are given to us by the enforcement body or regulatory authority (for example, to identify a missing person or person wanted by the Police).

If the Club is required to collect information about you, your information will be stored in a separate database of “Persons of Interest”.

Where required, we may disclose relevant information to AUSTRAC. This may occur, for example, where certain types of transactions, or transactions above a certain value, occur or where we otherwise reasonably suspect that an activity or matter that is reportable under the AML/CTF Act has occurred. To the extent that the Club collects health information about you or your child, the Club will treat that information as confidential and only ever handle that health information in accordance with the Club’s policies, the Privacy Act and the Health Records and Information Privacy Act 2002 (NSW).

The Club may also use the personal information we collect from you for direct marketing of products and services to you, including from third parties. Such products and services may include the provision of newsletters, competitions, announcements, campaigns or information about shows and entertainment at the Club or services offered by the Club.

You can refuse any direct marketing at any time by contacting our Privacy Officer (details can be found at the end of this policy) or by unsubscribing via the link on any marketing communications received.

We may use automated decision-making software to conduct analytics on your personal information to assist us to carry out activities and functions. For example, the Club may use targeted marketing software to identify what products or services may be of interest for you and send you information about those products or services, including any upcoming events or promotions. Similarly, the Club’s use of facial recognition technology is also a form of automated decision making.

Disclosing of personal information

There may be times when we may need to disclose your personal information to third parties that we engage to provide services to or in connection with the Club, including our related entities, our insurers, auditors, dispute resolution bodies, ClubsNSW, our sponsors, our legal and/or financial advisors and other members of the Club. Your personal information will only be disclosed to third parties for a purpose permitted by the Privacy Act and/or this policy and, where required, after obtaining your consent.

We may need to disclose your personal information to third parties for the purposes of allowing us to carry out the activities and functions mentioned in this policy. For example, from time to time, the Club engages external companies to send direct marketing information (usually via mail, email or SMS), carry out mail services, and provide IT storage and other services.

A third party will only receive your personal information from the Club where that information is necessary for that third party to provide services to or in connection with the Club and the Club will always require that the third party comply with the Privacy Act when dealing with your personal information.

We will also disclose your personal information to third parties if we are required or authorised to do so by law, including to law enforcement agencies, Austrac, the Office of the Australian Information Commissioner, the Australian Electoral Commission, the Department of Communities and Justice, the Australian Taxation Office and other enforcement bodies and regulatory authorities.

The Club will never disclose health information about your child to a third party without your express consent, except in the event of a medical emergency or as otherwise permitted by law.