Privacy Policy
Swift Bet Australia Pty Ltd (ACN 652 566 955)
Privacy Policy
Published: 20th February 2023
1. General
1.1. This is the privacy policy of Swift Bet Australia Pty Ltd (ACN 652 566 955) (**swiftbet**). swiftbet is required to comply with the Privacy Act 1988 (Cth) (**Privacy Act**) and is bound by the Australian Privacy Principles (**APPs**) set out in the Privacy Act.
1.2. In this Privacy Policy, Personal Information (as defined in the Privacy Act) 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 a material form or not) (Personal Information).
1.3. In carrying on business as a licensed corporate bookmaker, swiftbet collects Personal Information about people who:
apply to become or are swiftbet members;
open swiftbet accounts;
visit swiftbet’s website www.swiftbet.com.au, or use swiftbet’s mobile phone or tablet applications (together, the *Website**);
send swiftbet queries or information;
provide services to swiftbet or on our behalf;
apply to become or are swiftbet’s employees; and
are individuals or companies associated with swiftbet’s business partners and service providers.
1.4. swiftbet is committed to ensuring that the personal information it collects is collected, used, disclosed and protected in accordance with the Privacy Act and this Privacy Policy.
2. Collection of Personal Information
2.1. The types of Personal Information swiftbet collects and how Personal Information is collected depends on the circumstances. If you apply to be, or are, a swiftbet member, swiftbet will collect Personal Information about you:
if you wish to subscribe to swiftbet’s newsletter;
to process your application for swiftbet membership;
to open an account for you;
to provide member services to you;
to identify you as a member for security purposes and to comply with our legal and statutory obligations, including obligations imposed on swiftbet by the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (*AML/CTF Act**), and regulatory requirements;
to maintain and manage your betting account;
to upgrade and enhance your experience when using the website;
to tailor or develop information, services or products which swiftbet thinks may suit your needs;
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 swiftbet thinks may be of interest to you); and
to determine your liability to pay GST and other taxes where applicable.
2.2. The kinds of Personal Information that swiftbet generally needs to collect about its members and applicants for membership is:
full name;
residential address;
date of birth;
gender;
email address;
phone number(s);
personally-submitted preferences;
bank account and credit card information;
financial information;
identity verification information; and
recordings of all telephone calls and website activity.
2.3. You must only provide accurate information that you are authorised to disclose to allow swiftbet to use your Personal Information in accordance with this Privacy Policy.
2.4. swiftbet will ordinarily collect your Personal Information directly from you, primarily through your use of the website or over the telephone or otherwise, at on-course venues. swiftbet may also collect Personal Information from others, for example swiftbet’s related bodies corporate, companies with which swiftbet partners with to offer you a wide range of services and rewards, or through agents or affiliates with whom swiftbet engages to undertake marketing activities.
2.5. To verify the Personal Information you provide to swiftbet, swiftbet may use a document verification service. This service involves a request to have the information you provide matched against official records and may involve use of secure third-party systems and services.
3. Dealing with swiftbet anonymously
3.1. Where appropriate, swiftbet will allow you to deal with it on an anonymous basis or using a pseudonym. If you, however, do not provide swiftbet with the Personal Information swiftbet needs, swiftbet may be unable to process your application to become a member, open an account for you, enable you to participate in the full range of services offered by swiftbet, provide you with the services you require, process your job application, or enter into arrangements with you or your company.
4. Notification about collection of Personal Information
4.1. When swiftbet collects Personal Information about you, swiftbet is required to take reasonable steps to ensure that you are aware of certain information relating to collection, use, disclosure and handling of Personal Information. swiftbet generally does this by ensuring that a ‘privacy collection statement’ is provided when the Personal Information is collected.
4.2. When you become a swiftbet member or use your account, and in other situations where you provide Personal Information to swiftbet, swiftbet may deem your provision of Personal Information to be consent to swiftbet collecting, using and disclosing your Personal Information in accordance with the relevant privacy collection statement, the Privacy Act and the APPs.
5. Use and disclosure of Personal Information
5.1. swiftbet only uses and discloses Personal Information for which swiftbet has collected the information as set out above in section 2 of this Privacy Policy, for purposes that you are notified of at the time swiftbet collects your information, or for where otherwise required or permitted by law.
5.2. For swiftbet members and applicants for membership, swiftbet mainly uses Personal Information for purposes connected with establishing and administering the membership (including the account) and providing services and products at on-course venues, on-line and phone based wagering, as outlined above. Personal Information will only be shared with swiftbet’s related bodies corporate in accordance with all Australian laws, including the Privacy Act, the APPs and this Privacy Policy.
5.3. swiftbet may use Personal Information to create aggregate data about swiftbet’s members through demographic profiling and statistical analysis of its database, to allow for more efficient operation of the swiftbet business. swiftbet may provide the information derived from such profiling or analysis in de-identified form to potential and existing stakeholders.
5.4. swiftbet may disclose your Personal Information, where appropriate and in accordance with legal and regulatory requirements:
to swiftbet’s related bodies corporate, associated entities, agents and affiliates who undertake promotional and marketing activities on our behalf (including contacting you with special offers that may be of interest);
to organisations that provide services (including IT, consultancy and advisory services) to swiftbet;
to any particular third parties or classes of third parties that swiftbet notifies you at the time of collecting your Personal Information that your Personal Information may be disclosed to;
for taking appropriate action if swiftbet has reason to suspect that unlawful activity or serious misconduct in relation to swiftbet’s services has occurred or will occur;
to protect and maintain the integrity of sports/racing codes, by assisting controlling bodies, law enforcement and governmental agencies in their inquiries or notifying such bodies of any betting activity swiftbet considers to be unusual or suspicious as required;
where you have consented to the disclosure either expressly or by the circumstances and your conduct;
where swiftbet considers disclosure is necessary to eliminate or minimise a risk to public health or safety;
to establish or defend a legal claim; and
where the disclosure is otherwise required by law.
for legal and regulatory purposes (as set on in Clause 2.1.).
to potential purchasers of swiftbet’s business or some or all of swiftbet’s assets.
5.5. swiftbet may disclose your Personal Information to Racing Victoria Limited (ACN 096 917 930) (**Racing Victoria**). Racing Victoria is the Principal Racing Authority responsible for governing thoroughbred racing in Victoria which includes administering and ensuring the integrity of the industry and supervising bookmakers, licensed and registered persons, its
employees and betting transactions generally. swiftbet is subject to the Club Bookmakers’ Licence Rules 2010 and the Rules of Racing (as amended from time to time) (**Rules**) and may disclose your Personal Information to Racing Victoria for the purpose of fulfilling its regulatory functions such as monitoring, investigating and enforcing the Rules. Racing Victoria will handle your Personal Information in accordance with its own privacy policy available at https://www.racingvictoria.com.au/privacy-policy. Please note that Racing Victoria may disclose your Personal Information and/or betting records to a third party in accordance with s 91E of the Racing Act 1958 (Vic), Racing Victoria’s privacy policy or as otherwise permitted by law. For example, Racing Victoria may disclose your Personal Information to a third-party service provider of Racing Victoria retained for the strict purpose of assisting Racing Victoria fulfill its regulatory functions (described above).
5.6. In addition to Racing Victoria, swiftbet may disclose your personal information to other sports and racing controlling bodies, in order to fulfill regulatory obligations.
5.7. swiftbet will take all reasonable steps to ensure that any Personal Information which is disclosed to a third party is protected by that party in accordance with the Privacy Act and APPs, and is used only for the purpose(s) for which swiftbet supplied that information to that party. Usually, this is done by imposing contractual requirements on or seeking assurances from third parties as to their compliance with the Privacy Act and APPs.
5.8 We may also collect, use and disclose your Personal Information for secondary purposes related to the primary purpose including in circumstances where you may reasonably expect such collection, use or disclosure and/or for purposes including (but not limited to) trading, risk management, integrity, compliance, minimum bet laws and/or other related purposes including purposes reasonably required by applicable Principal Racing Authorities (Secondary Purposes). You acknowledge We can provide your Personal Information to BetMakers (the provider of our platform technology and/or managed trading services) - who can also use and disclose your Personal Information for these purposes (including Secondary Purposes). Further, We may collect information from BetMakers, other service providers, regulators, racing bodies, sporting bodies and other third parties associated with our products and services. Collection of such information may include information aggregated by a third party.
6. Direct marketing and opting out
6.1. From time to time, swiftbet may use and disclose your Personal Information to inform you about swiftbet’s (and its associated entities’) products or services or about promotional activities, which swiftbet believes may be of interest to you. swiftbet may do this at on-course venues, via email, SMS, telephone or mail.
6.2. If you no longer wish to receive marketing or promotional material from swiftbet at all or in any particular form, you may contact us at any time by email to support@swiftbet.com.au with your request, with which will be actioned as soon as is practicable. Where swiftbet sends 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, swiftbet may contact you in relation to the opening, management and administration of your swiftbet account. These communications can be via any of the modes of contact recorded when you apply to open an account, register as a member or which swiftbet otherwise collects for the purposes of opening an account. Such communications will not be affected by your opt-in or opt-out status for direct marketing communications.
7. Personal Information and swiftbet’s website
7.1. In using the website, you agree to be bound by the terms of this Privacy Policy. swiftbet 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 website. swiftbet will publish the current Privacy Policy on the website and provide reasonable notice tp users before changes take effect. Your continued use of the website following this period of notice will constitute your acceptance of those changes. You should review this Privacy Policy regularly and remain familiar with its terms.
7.2. You are responsible for the security of and access to the 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.
7.3. This Privacy Policy will not apply to third-party websites which are linked to the website and over which swiftbet has no control. You acknowledge that swiftbet is not responsible for, the use of, or the protection of information provided to, such third-party websites.
7.4. You acknowledge that information posted on bulletin boards or communicated within swiftbet’s social media platforms may become public information.
7.5. Information has the potential to be collected when you use our website using cookies. Cookies are pieces of data stored by your web browser on your hard drive which contain information relating to your use of the website. When you access the website, cookies may record details relating to your use of the website, including what pages you view from the website. swiftbet uses cookies for the detection of fraud, statistical analysis, systems administration and internal management purposes only.
7.6. swiftbet may use third parties to serve advertisements on its website. The advertisers may employ cookies and action tags (also known as single pixel gifs or web beacons) to measure advertising effectiveness. Any information that these third parties collect via cookies and action tags is completely anonymous.
8. Management and security of data and information
8.1. swiftbet will take all reasonable steps to ensure that data or information transmitted by you to it is stored in a secure environment that is accessed only by authorised persons, however, you acknowledge that any data or information that you transmit to swiftbet is transmitted at your own risk.
8.2. swiftbet may use cloud storage to store the personal information we hold about you. The
cloud storage and the IT servers may be located outside Australia.
8.3. swiftbet may disclose your personal information to overseas entities that provide support
functions to us. You may obtain more information about these entities by contacting us.
8.4. swiftbet will destroy or permanently de-identify Personal Information when it is no longer required for any purpose permitted under the Privacy Act and APPs, including swiftbet’s legal or operational obligations. swiftbet holds Personal Information in electronic database(s) owned and operated by swiftbet. Once swiftbet receives your Personal Information , swiftbet will take reasonable steps to safeguard your Personal Information from misuse, loss, unauthorised access, modification and disclosure including by using password protected systems and databases and Secure Socket Layer technology.
8.5. swiftbet’s employees, agents and contractors are required to maintain the confidentiality of members’ personal information.
8.6. swiftbet takes reasonable measures to ensure that Personal Information 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. swiftbet will give you the opportunity to correct and update Personal Information at any time and may contact you on a periodic basis to seek the most current information from you. swiftbet will correct your Personal Information if it is satisfied that it is accurate and needs to be corrected.
9. Prohibited persons
9.1. Persons under the age of eighteen (18) are prohibited from becoming members and will be denied access to our services. swiftbet will not accept their Personal Information for the purposes of opening a wagering account.
9.2. Persons who self-exclude from membership of swiftbet and/or receiving products, services and communications from swiftbet (in accordance with swiftbet’s Responsible Gambling Code of Conduct and Responsible Gambling Policy), or where swiftbet is otherwise directed to exclude a person by a law enforcement agency or regulatory authority, these persons will have their Personal Information recorded that indicate the status of that person’s exclusion to ensure no marketing communications or other offers are sent to that person.
9.3. Notwithstanding clause 9.2, swiftbet may be required to contact you directly for the sole
purpose of conducting a welfare check (including, but not limited to, after a person has self-
excluded) in accordance with its Responsible Gambling Policy.
10. Access to and correction of Personal Information
10.1. You may access your Personal Information held by swiftbet by following the “My Account” link on the website or by emailing swiftbet at support@swiftbet.com.au. To do so, you will need to provide evidence to confirm your identity before swiftbet can provide access. swiftbet will respond to all requests for access within a reasonable timeframe of the request, generally not exceeding thirty (30) days. If your request is particularly complex or requires detailed searching of swiftbet’s records, there may be a cost to you for swiftbet to provide the information.
10.2. Details of your betting transactions can also be accessed via the ‘Bet History’ section of the Member Services section of the website.
10.3. swiftbet may, however, refuse a request for access in certain circumstances set out in the Privacy Act and APPs, including (but not limited to) where:
* swiftbet has reason to suspect unlawful activity or misconduct of a serious nature may occur as a result of provision of access;
* swiftbet has reason to believe giving access would pose a serious threat to life, health or safety of an individual, or to public health or public safety;
* swiftbet is required or authorised to do so under an Australian law or court/tribunal order;
* the request is frivolous or vexatious; and
* giving access would be likely to prejudice enforcement related activities by or on behalf of an enforcement body.
10.4. If swiftbet refuses your request or cannot give you access in the manner you have requested, swiftbet will do what it can to meet your requirements by other means. If swiftbet refuses access to your Personal Information, swiftbet 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 Personal Information swiftbet holds about you is inaccurate, incomplete or not current, please let swiftbet know and it will investigate and correct any inaccuracies if so satisfied that a correction is required. Your Personal Information can be updated or corrected by you in the “Account Details” section of the website at any time after you log in.
Subject to identity verification, personal information can also be updated or corrected by emailing swiftbet at support@swiftbet.com.au.
11. Complaints and further information
11.1. If you believe your privacy has been interfered with and wish to make a complaint, please contact swiftbet’s Privacy Officer. The Privacy 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 swiftbet, the Privacy Officer may discuss your complaint with that other person to resolve it. The Privacy Officer can be contacted via email at support@swiftbet.com.au.
11.2. If you are not satisfied with the outcome of your complaint or the way swiftbet handles it, you may make a complaint to the Office of the Australian Information Commissioner at https://www.oaic.gov.au/privacy/privacy-complaints.
11.3. If you have any queries, requests for access or correction or further information on this Privacy Policy, or if you have any concern about the handling of your Personal Information or wish to make a complaint, please contact management, whose contact details are as follows:
Email: support@swiftbet.com.au