pub+ PRIVACY COLLECTION NOTICE
Effective date: 28 May 2024
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Australian Leisure and Hospitality Group Pty Limited (ACN 067 391 511) (ALH) is part of Endeavour Group Limited (ACN 159 767 843) (referred to in this notice as ‘we’, ‘our’ or ‘us’) and operates the pub+ app and loyalty program (pub+).
pub+ allows its members to earn benefits when they transact at ALH venues. pub+ Play is an optional feature within pub+ that, if activated, allows members to earn benefits when they engage in gaming on Electronic Gaming Machines at ALH venues. When we refer to “pub+” in this Collection notice, we mean both pub+ and pub+ Play unless stated otherwise.
When you join and take part in pub+, you trust us with your personal information. We value your privacy and are committed to protecting your personal information. This Collection notice will help you understand how we collect, use and share your personal information so you can make informed choices.
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We usually collect the following personal information relating to pub+ members:
your name, address, contact details, date of birth, loyalty number, nominated ALH venue location and details about your ALH transactions;
your gaming activity when you engage in gaming on an Electronic Gaming Machine at an ALH venue (for example your turnover, wins, losses, and deposits);
where we infer personal information about you based on your interactions with us (for example, your preferences and/or purchasing behaviours); and
other information which can reasonably identify you (for example if you enter information in an open text field).
We also collect information via our website or app on mobile devices which may sometimes be considered personal information, for example the current location of your device and IP address, as allowed by your device permissions and cookies. You can learn about how we use cookies in our Privacy Policy.
We may collect this personal information directly from you or from another source, including:
when you sign up to pub+ or when you set up pub+ Play on your pub+ account;
when someone provides your information on your behalf, for example where they submit an enquiry or request for assistance;
from regulators, government agencies and/or enforcement bodies where permitted by law; and
from our commercial partners who provide products and/or services, benefits, promotions or rewards to pub+ members.
If you provide personal information to us about someone else, you must have:
obtained consent from the individual for us to collect their information;
informed the individual that you are providing their information to us and why; and
let them know about this Collection notice and our Privacy Policy.
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We collect, store and use your personal information so that we can:
a) operate pub+ including setting up and managing your pub+ account, setting up and managing pub+ Play on your pub+ account, generate points and supply rewards;
b) supervise, monitor, and where appropriate, take action in relation to suspected unlawful or unsafe activity, fraud, misconduct or otherwise to ensure the integrity and safe use of our products and/or services;
c) investigate and respond to member enquiries and complaints and/or record your feedback;
d) determine your eligibility to participate in pub+, including to identify if you are excluded, or have otherwise been restricted, from using any of our products or services;
e) exercise or defend any legal claims;
f) promote relevant products, services and personalised offers and other benefits to pub+ members via the pub+ app and/or direct marketing or personalised advertising;
g) enable points to gift card and points to cash (SA and QLD only);
h) generate insights in order to better understand your preferences and interests, tailor your experience and enhance the products and services supplied to you;
i) communicate with you (including via direct mail, mobile, email, SMS, push notifications and/or in-app messages) regarding matters that relate to your pub+ membership or otherwise in accordance with your direct marketing preferences (see further details below);
j) improve the pub+ website and mobile application experience, bug remediation and management of crash logs;
k) conduct investigations in cases of fraud or data security risks; and
l) comply with our obligations under applicable laws, including the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), Gaming Machines Act 2001 (NSW), Gaming Machine Act 1991 (Qld), Gambling Regulation Act 2003 (Vic), Gaming Machines Act 1992 (SA), Gaming Machine Act 1995 (NT) or Gaming Control Act 1993 (Tas), any applicable regulation, instrument or subordinate legislation made under those laws (as applicable from time to time), including obligations to identify you and understand your behaviour where required/appropriate.
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When you sign up to pub+, you may opt in to receive direct marketing from us, including pub+ marketing communications, offers and updates.
You are in control of the direct marketing communications you receive from us and can opt out or manage your marketing preferences at any time by:
following the relevant opt-out or unsubscribe instructions in the relevant marketing message;
updating your marketing preferences in your preference centre, which is accessible in the pub+ mobile application; and/or
sending your request to us at privacysupport@edg.com.au.
In the event you out of receiving any or all direct marketing communications, we may still communicate with you if required by law, or to provide you with important information relating to the pub+ loyalty program (for example, information regarding your membership and/or material updates to the pub+ Terms & Conditions and/or Privacy Policy).
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We may share your personal (including sensitive) information about you with third parties such as:
a) service providers who help us run our business and pub+. These include partners who offer promotions and/or rewards, IT services, fraud detection, food and beverage ordering platforms and gaming technology providers;b) enforcement bodies, regulators and government authorities; and
c) any other third parties as may be needed for any of the purposes described in this Collection notice, our Privacy Policy and/or as otherwise authorised or required by law.
In limited circumstances, ALH may disclose your personal information to third parties located outside of Australia. When we do this, we take steps to require our service providers to handle your personal information safely, and in a way that meets Australian privacy laws.
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We otherwise use, disclose and handle your personal information in accordance with our Privacy Policy available at https://www.alhgroup.com.au/privacy
Our Privacy Policy sets out information about:
a) how you may access and seek correction of your personal information held by us;
b) how you may raise a privacy concern with us and how it will be dealt with; and
c) any disclosures of your personal information to overseas entities and, if so, the countries in which such overseas entities are likely to be located.
If you have any questions or complaints about this privacy collection notice or relating to a privacy matter, please contact our Privacy Officer via one of the following options:
a) Mail: Privacy Officer, Endeavour Group Limited, Level 1, 26 Waterloo Street SURRY HILLS NSW 2010
b) Telephone: 1300 780 674
c) Email: privacysupport@edg.com.au