[Last Updated: 21 April 2021]
1. General
1.1 This is the privacy policy (Privacy Policy) of Moneyball Australia Pty Ltd (ACN 602 304 901) (Moneyball, moneyball.com.au, our, we, us).
1.2. Moneyball is subject to the Privacy Act 1988 (Cth) (Privacy Act) which includes the Australian Privacy Principles (APP).
1.3. This Privacy Policy sets out how Moneyball collects, uses, discloses and manages Personal Information (PI). In carrying on business as an online wagering bookmaker Moneyball collects PI about people who;
1.3.1. apply to become or are Moneyball members;
1.3.2. visit our website moneyball.com.au or use our mobile phone sites or applications (together the website);
1.3.3. send us queries or information;
1.3.4. provide services to us or on our behalf;
1.3.5. apply to become or are our employees;
1.3.6. otherwise deals with us.
1.4. When collecting, using and handling PI, Moneyball is required to comply with the Privacy Act and is bound by the APP.
1.5. Moneyball is committed to ensuring that customer PI is collected, used, disclosed and protected in accordance with the Privacy Act and this Privacy Policy.
1.6. In this Privacy Policy, 'PI' means information or an opinion about an identified individual, or an individual who is reasonably identifiable (whether the information is true or not, and whether it is recorded in any form or not). Reference to Moneyball includes any of its employees, agents, directors, officers, parents and subsidiaries.
2. Collection of PI
2.1. The kinds of PI that Moneyball generally needs to collect about its members and applicants for membership includes;
2.1.1. name
2.1.2. residential address
2.1.3. date of birth
2.1.4. gender
2.1.5. email address
2.1.6. phone number(s)
2.1.7. personally-submitted preferences
2.1.8. bank account and credit card information
2.1.9. financial information
2.1.10. identity verification information
2.1.11. recordings of all app, website activity and emails, which includes but is not limited to IP address, location data, sessions and other online activities
2.2. The types of PI we collect and how we collect it depends on the circumstances. If you apply to be, or are, a Moneyball member, we collect PI about you;
2.2.1. if you wish to subscribe to Moneyball’s newsletter;
2.2.2. to process your application for Moneyball membership;
2.2.3. to provide member services to you;
2.2.4. to identify you as a member for security purposes and to comply with our legal obligations;
2.2.5. to maintain and manage your betting account;
2.2.6. to upgrade and enhance your experience when using our website;
2.2.7. to tailor or develop information, services or products which we think may suit your needs
2.2.8. for marketing related purposes, including conducting research, conducting promotions, sending you newsletters and telling you (including via email, SMS or telephone) about products or services we think may be of interest to you);
2.2.9. to comply with our legal, regulatory and licensing obligations under various laws including but not limited to the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), and its corresponding rules, and the Racing and Betting Act 1983. We are required to collect and keep certain information (including identity verification and transactional information) under the aforementioned legislation;
2.2.10. to receive and process payments; and
2.2.11. to respond to queries and complaints from you and to establish or defend any legal claims.
2.3. We will ordinarily collect your PI directly from you, primarily through your use of the website or app. We may also collect PI indirectly, for example through agents, third party service providers or affiliates we engage to undertake marketing activities.
2.4. We are also permitted to collect your PI from you when you email, engage in live chat or when you share information or engage with us with us via other social applications, services or websites. We may also collect your PI from publicly available sources of information, including third parties from whom we may acquire lists.
2.5. We may also collect PI from job applicants, our employees and individuals associated with our business partners and service providers. Usually, this information is limited to name and contact details and the other information we need for the purpose of managing the employment or business relationship.
2.6. By accepting our terms and conditions upon registration you have given consent for Moneyball to disclose your name, residential address and date of birth to a credit reporting agency and ask the credit reporting agency to provide an assessment of whether the PI so provided matches (in whole or in part) PI contained in a credit information file in the possession or control of the credit reporting agency to assist in verifying your identity for the purposes of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006.
2.7. Please note that our obligation under the aforementioned legislation supersedes your rights to be forgotten. Any credit reporting agency may prepare and provide Moneyball with such an assessment and may use your PI including the names, residential addresses and dates of birth contained in credit information files of you and other individuals for the purposes of preparing such an assessment.
3. Cookies, Pixels & App Events
3.1 PI may also be collected by cookies, tracking pixels, app events or via other similar technologies when you use our website & mobile application. Cookies, pixels and events are pieces of data stored by your web browser on your hard drive or device which contain information relating to your use of the website or app. When you access the website or application we may record details relating to your session, including but not limited to the pages you view, your session duration and activities. Moneyball uses the cookies, events and tracking pixels to detect fraud, for statistical analysis, system administration, marketing and for internal management purposes. We may also use third-parties to advertise our products and services. These companies may use cookies, events, pixels, tags or beacons to measure their advertising effectiveness. Any information that they collect in this manner is completely anonymous.
4. Notification and Collection of PI
4.1. When we collect PI about you, we are required to take reasonable steps to ensure that you are aware of certain information relating to our collection, use, disclosure and handling of PI. We do this by issuing a Collection Statement on signup when the PI is collected.
4.2. When you become a Moneyball Member, and in other situations where you provide PI to us, we may deem your provision of PI to be consent to Moneyball collecting, using and disclosing your PI in accordance with the relevant collection statement.
5. Use and Disclosure of PI
5.1. The customer acknowledges and consents to Moneyball’s collection, retention, access and use of customer PI in the manner set out in this Privacy Policy. The customer further consents to Moneyball to do such background and personal investigations and searches as deemed necessary in order to satisfy itself as to the identity and standing of the customer.
5.2. Moneyball only uses and discloses PI for purposes that are related to the reason for which we have collected the information. For Moneyball members and applicants for membership, this means we mainly use PI for purposes connected with establishing and administering the membership and providing services and products related to wagering in the manner which Moneyball provides its services.
5.3. Moneyball may use PI to create aggregate data about its members through demographic profiling and statistical analysis of its database, in order to allow for more efficient operation of Moneyball’s business. We may provide the information derived from such profiling or analysis in de-identified form to potential and existing stakeholders.
5.4. Moneyball may collect, hold, use and disclose your PI for the following purposes;
5.4.1. Provide Moneyball products and services which includes but is not limited to administration, settlements, wagering, payments processing, improve our services and products, conduct checks for fraud, resolve disputes, promote markets and products to you, and use for any lawful purpose.
5.5. Moneyball may disclose your PI;
5.5.1. to our agents, affiliates and related group companies who undertake promotional and marketing activities on our behalf (including contacting you with special offers that may be of interest);
5.5.2. to organisations that provide services (including IT, consultancy and advisory services) to us;
5.5.3. to any particular third parties or classes of third parties that Moneyball notifies you at the time of collecting your PI that your PI may be disclosed to;
5.5.4. for the purpose of verifying your identity using third party identity verification services which may include capture, retention and use of official identification documents and biometric security data or information;
5.5.5. for taking appropriate action if we have reason to suspect that unlawful activity or misconduct of a serious nature in relation to our services has been, is being or may be engaged in;
5.5.6. to protect and maintain the integrity of particular sports / racing codes, by assisting controlling bodies in their inquiries or notifying such bodies of any betting activity Moneyball considers to be unusual or suspicious;
5.5.7. where you have consented to the disclosure either expressly or by the circumstances and your conduct;
5.5.8. where we consider disclosure is reasonably necessary to eliminate or minimise a risk to public health or safety which includes any responsible gambling issues;
5.5.9. where we consider disclosure is reasonably necessary to investigate or deal with unlawful activity or serious misconduct;
5.5.10. where we consider disclosure is reasonably necessary to locate missing persons;
to establish or defend a legal claim; or where the disclosure or use is required or authorised by law.
5.6. Moneyball may disclose PI overseas, including to its parent company and related body corporate, and to third party service providers. Third party service providers within Australia, may disclose or keep PI in servers, or transfer PI and make use of service providers outside of Australia.
5.7. Moneyball will take all reasonable steps to ensure that any PI which is disclosed to a third party is protected by that party in accordance with the Privacy Act and is used only for the purpose or purposes for which we supplied that information to them.
5.8. Usually we do this by imposing contractual requirements on satisfying ourselves or seeking assurances from third parties as to their compliance with the Privacy Act or comparable international privacy legislation and/or regulations.
5.9. For information about Moneyball's use and disclosure of credit-related information, you should refer to Moneyball's credit-related information policy below.
6. Direct marketing and opting out
6.1. When registering as a Moneyball member, you may choose to receive promotional or marketing information from Moneyball by selecting the appropriate option on the registration page. If you do, from time to time we may use your PI to inform you about Moneyball's products or services or about promotional activities, which Moneyball believes, may be of interest or of benefit to you. We may do this via email, SMS, push notifications, in app banners,or mail.
6.2. If you no longer wish to receive marketing or promotional material from Moneyball at all or in any particular form, you may contact us at any time by email at support@moneyball.com.au with your request with which we will comply as soon as is practical. Where we send you commercial electronic messages for direct marketing purposes, each message will contain a functional means for you to opt-out of receiving such messages.
6.3. From time to time we may contact you in relation to the management and administration of your Moneyball account. These communications can be via any of the modes of contact recorded when registering as a Member. Such communication is not affected by your opt-in or opt-out status for direct marketing communications.
7. PI and our app/website
7.1. In using the app/website you agree to be bound by the terms of this Privacy Policy. Moneyball may review, change or update this Privacy Policy periodically and reserves the right to change the Privacy Policy at any time at its discretion by posting such changes on the app/website. We will publish our current Privacy Policy in the help centre (accessible via the website & application) and changes will take effect immediately at the time of publication. Your continued use of the app/website following publication will constitute your acceptance of those changes. You should review this Privacy Policy regularly and remain familiar with its terms.
7.2. This Privacy Policy will not apply to other websites which are linked to the website and over which Moneyball has no control. Moneyball is not responsible for the use of, or the protection of information provided to such websites.
7.3. You acknowledge that no data transmission over the internet or via an application is totally secure. Accordingly, Moneyball does not warrant the security of any information, which you transmit to it. Any information that you transmit to Moneyball is transmitted at your own risk. You further acknowledge that information posted online on bulletin boards or communicated within a social media environment (for example, Facebook, Twitter, Chat Rooms), or via community chat becomes public information. Moneyball does not guarantee the security of this type of information.
7.4. PI has the potential to be collected when you use our app/website through the use of cookies, tracking pixels, app events, or through the use of other similar technologies.
8. Management and security of PI
8.1. Moneyball will take all reasonable steps to ensure that the PI which it collects, uses or discloses, is correct and is stored in a secure environment that is accessed only by authorised persons.
8.2. Subject to our legal obligations under AML/CTF legislation and rules, and by the operation of general law, Moneyball will destroy or permanently de-identify PI when it is no longer required for any purpose permitted under the APPs. Moneyball holds PI in electronic databases managed and/or operated by Moneyball or third party service providers and may send PI to third parties in Australia or overseas. When practicable, Moneyball will seek to de-identify/anonymise PI when sent to/routing through third party service providers.
8.3. Once Moneyball receives your transmission, Moneyball will take reasonable steps to protect your PI from misuse, loss and unauthorised access, modification and disclosure including by using password protected systems and databases and Secure Socket Layer ("SSL") technology.
8.4. Moneyball’s employees, agents and contractors are required to maintain the confidentiality of members' PI.
8.5. Moneyball takes reasonable measures to ensure that the PI which it collects is accurate, complete and current and also when it uses and discloses it, that it is relevant, having regard to the purpose for which it is being used or disclosed. We give you the opportunity to correct and update PI at any time, and may contact you on a periodic basis to seek the most up-to-date information from you
9. PI about children
9.1. Persons under the age of 18 (‘Children’) cannot become Moneyball members and are excluded from access to our services. We will not accept their information for the purposes of opening a wagering account. It is however ultimately the responsibility of parents or guardians to monitor their children’s internet activities including where appropriate.
9.2. You are responsible for the security of and access to the app/website. You must log out of your account when you have completed your time on the website, and should not disclose your username, password or any account information to any other person.
10. Access to and correction of PI
10.1. You may access PI about you held by Moneyball by viewing your account details in the application or by contacting us at support@moneyball.com.au. To do so, you will need to provide evidence to confirm your identity before we can provide access. We will generally respond to all requests for access within 30 days of the request. If your request is particularly complex, or requires detailed searching of our records, there may be a cost to you in order for us to provide the information.
10.2. Details of your betting transactions, deposits and withdrawals can also be accessed in your Moneyball account in our app.
10.3. However, we may refuse a request for access in certain circumstances set out in the Privacy Act, including where;
10.3.1. providing access would be unlawful;
10.3.2. we are required or authorised to do so by or under an Australian law or court/ tribunal order; or
10.3.3. where giving access would be likely to prejudice enforcement related activities by or on behalf of an enforcement body.
10.4. If we refuse your request or cannot give you access in the manner you have requested, we will do what we can to meet your requirements by other means. If we refuse access to your PI, we will advise you in writing of the refusal, the reasons for the refusal, and the complaint mechanisms available to you.
10.5. If you believe that the PI Moneyball holds about you is inaccurate, incomplete or not current, please let us know and we will investigate and correct any inaccuracies if we are satisfied that a correction is required. Your PI can be updated or corrected by you in the account details section of the website at any time after you log in. If there are any details you wish to update which you cannot please contact support@moneyball.com.au.
11. Credit information
11.1. Moneyball may previously have collected or may collect credit information from you in order to provide credit services or to verify your identity. Credit information includes;
11.1.1. identity information, consumer credit liability information, repayment history information, credit default and repayment information, employment details and history, court proceedings and insolvency information, and other publicly available information.
11.2. Moneyball may disclose credit information to;
11.2.1. credit reporting bodies, associated organisations within the Moneyball group or contracted to Moneyball, debt collection agencies and lawyers, law enforcement agencies and regulators, or any person/entities authorised by law.
12. Complaints and further information
12.1. If you believe your privacy has been interfered with and wish to make a complaint, please contact our compliance officer. The compliance officer will investigate your complaint and notify you of the outcome. If your complaint indicates that there has been an interference with your privacy by a person other than Moneyball, the compliance officer may discuss your complaint with that other person in an attempt to resolve it.
12.2. If you are not satisfied with the outcome of your complaint or the way we handle it, you may make a complaint to the Office of the Australian Information Commissioner directly at OAIC Complaint.
12.3. If you have any queries, requests for access or correction or further information on our Privacy Policy, or if you have any concern about the handling of your PI or wish to make a complaint, please contact complaints@moneyball.com.au.
12.4. Further Information about privacy concerns or complaints in Australia can be found on the Office of the Australian Privacy Commissioner's website at www.oaic.gov.au.
13. Changes to the Privacy Policy
13.1. The Privacy Policy may be updated from time to time and changes to the policy will come into effect immediately upon publishing on our website. You should review this Privacy Policy regularly to remain familiar with its terms.
Contact Details:
If you have any queries please contact us at support@moneyball.com.au, or contact the Compliance Officer at compliance@moneyball.com.au.
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