Mulgrave Country Club (ABN 16 004 568 610) (otherwise referred to as MCC, the Club, we or us), acknowledges the importance of privacy and customer data security and takes seriously its obligations under the Privacy Act 1988 (Cth) (Privacy Act) and the associated Australian Privacy Principles (APPs) and any other applicable law.
This Privacy Policy describes the way in which we deal with the information and data you provide to us as a result of your membership with MCC, your use of our sporting facilities, your use of our Website (Website) and our mobile app (App), or whenever we otherwise deal with you. We are committed to ensuring that the information we collect about you is protected and is used, stored and disclosed in accordance with law and this Privacy Policy.
When you provide personal information to us, we may deem your provision of personal information to be consent to MCC collecting, using and disclosing your personal information:
This Privacy Policy will not apply to third-party Websites or apps which are linked to MCC’s Website and the App over which we have no control. We strongly recommend reviewing the relevant third-party privacy policy before using any linked website or app.
Personal information is information or an opinion from which it is possible to determine the identity of an individual.
The kind of personal information that we collect from you depends on the nature of your dealings with us. It may include, but is not limited to:
We are required by law to collect some personal information about people who use our services. We are required to collect certain information (including identity verification information) under the Anti-Money Laundering and Counter Terrorism Act 2006 (Cth).
In order to verify the personal information you provide us we may use a verification service which involves a request to have the information you provide matched against official records and may involve use of secure third-party systems and services.
We may also collect personal information 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 processing a job application and managing our business relationships.
MCC may take (or may arrange another person to take) photographs and electronic images of you whilst in venue or facility. By attending a venue or facility, you acknowledge and agree that such photographs and other images are owned by MCC and MCC may use them for promotional, legal or other purposes without your further consent being necessary.
Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, sexual preferences, criminal record, health information, biometric information.
Under certain circumstances, MCC may need to collect sensitive information about you. If we collect your sensitive information, we will only do so only with your consent, or as otherwise required or authorised by law. We take appropriate measures to protect the security of this information.
We collect your personal information directly from you including when you:
Depending on the circumstances, some types of information will be required to be provided to us and some information might be optional. If you do not provide some or all of the information requested, or remain anonymous or use a pseudonym, this may affect MCC’s ability to communicate with you or provide the requested products or services. By not providing requested information, you may jeopardise your ability to participate in programs or services or otherwise interact with MCC. If it is impracticable for MCC to deal with you as a result of you not providing the requested information or consent, MCC may refuse to do so.
MCC may collect personal information regarding a person from a third party where it is unreasonable or impractical to collect that information from the person directly. MCC may collect personal information regarding a child from the parent or other responsible from the person directly. We may collect personal information regarding a child from the parent or other responsible person associated with that child. In many circumstances, MCC collects information from other third parties (in accordance with the privacy policies of such third parties). Examples of such third parties could include, without limitation, the Tabcorp Group, government and law enforcement bodies.
We may use your personal information and data together with other information for the purposes of:
We will only disclose personal information to business partners, authorities and successors in title to our business and suppliers that are engaged to process such information on our behalf for the following purposes:
While you are at the MCC venue, your movements may be subject to video and audio monitoring and recording by security and surveillance systems, including CCTV and facial recognition technology for the purpose of:
The use of FRT is strictly aligned with the principles of privacy, transparency, and compliance with the Privacy Act and the APPs.
FRT analyses facial features of individuals entering specific areas within our venues. This analysis is conducted in temporary memory and only for the purpose of identifying matches against predefined databases, such as self-excluded individuals or banned patrons.
No biometric data is stored or retained after the analysis. If no match is found, the data is automatically purged from memory in real-time.
At no point is the facial data linked to an individual’s identity unless a match occurs, and even in those cases, no biometric template is retained by our systems.
Individuals are informed about the use of FRT through clearly visible signage at venue entry points. Additional information about the use of FRT is available upon request.
All data collected and processed is limited to what is necessary to achieve specific safety and compliance objectives.
We collect data about you in the use of our Website and our App and what your preferences may be. This enables us to recognise you as a repeat customer. In better recognising you and your online preferences, we can provide you a more user friendly and tailored experience with us online that is less key stroke intensive.
We may use cookies action tags (also known as single-pixel gifs or web beacons) and other analytics tools such as Google Analytics (GA4) as a means of collecting information from a web server, following a customer’s use of the Website or the App. This includes using your personal information to market our products and services to you – and to show you advertisements. If you register with us or if you continue to use the Website or the App, you agree to our use of cookies, action tags and other analytical tools.
The OAIC defines cookies as being “…small data files transferred onto computers or devices by Websites for record-keeping purposes and to improve your Website and App user experience.” Cookies contain information that is transferred to your computer’s hard drive.
Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving the user experience. Cookies may tell us, for example, whether you have visited the Website or the App before or whether you are a new visitor. Cookies may also help your browser remember your preferences such as text sizes, location or sign-in information. They can also help us to ensure that adverts you see online are more relevant to you and your interests. Cookies help us to improve the Website and the App and to deliver a better and more personalised service. Some of the cookies we use are essential for the Website and the App to operate. There are two broad categories of cookies:
Cookies can remain on your computer or mobile device for different periods of time. Some cookies are temporary (called “session cookies”), meaning that they exist only while your browser is open. These are deleted automatically once you close your browser. Other cookies are persistent (called “permanent cookies”), meaning that they survive after your browser is closed. They can be used by the Website or the App to recognise your device.
Action tags are a form of visitor identification technology which counts visitors who have come to the Website after being exposed to an advertisement on a third-party site. We do not use this technology to access your personal information and it is only used to compile aggregated statistics about visitors who come to the Website to gauge effectiveness of our ads.
The information collected about you using action tags will not ordinarily be your personal information, because you will not be identified or reasonably identifiable to us from it.
To eliminate spam attacks, analyse the effectiveness of our Website and the App, and to distinguish you from a bot, we may use analytical tools such as Google Analytics 4 (GA4) to collect data about how you interact with our Website and the App, including:
The use of analytical tools such as GA4 does not provide us with access to IP addresses or persistent devices IDs. While IP addresses may be used transiently by Google for location processing, they are not stored, visible, or accessible to use.
We may use third parties to place advertisements on the Website or the App. These companies may employ cookies and action tags (also known as single-pixel gifs or web beacons) to measure advertising effectiveness. We ensure that any third parties placing advertisements on our Website are only those who keep any information collected via cookies and action tags completely anonymous.
Different web browsers have different settings and features that you can use to help control your personal information online. Common options include deciding whether to accept cookies and how long to allow them to stay on your device. Many browsers allow you to view in private mode, which usually means your browsing history won’t be saved to your device, but it doesn’t mean the browser will automatically block all tracking of your activities online.
If you want to delete any cookies already stored on your computer or stop the cookies that keep track of your browsing patterns on the Website you can do so by deleting your existing cookies and/or altering your browser’s privacy settings to block cookies (the process you follow will differ from browser to browser). If you would like more information on how to do this, please visit http://www.allaboutcookies.org/. Please note that deleting our cookies or disabling our future cookies means that you may not be able to access certain areas or features of the Website. Please note however, that some data may still be collected separately by analytical tools, even though you may have set your browser preferences to reject all cookies.
Given that the internet is a global environment, using the internet to collect and process personal data necessarily involves the transmission of data internationally. Usually, all our storage of personal information is local and is not transferred overseas, with limited exceptions.
However, such a transfer of data (and any other overseas transfer of personal information that were to occur in the future) does not take place unless we reasonably believe that:
Information posted on bulletin boards or communicated within a social media environment (e.g. Facebook, Twitter, Instagram, Reddit, WhatsApp and general chat rooms) and any chat room spaces on the Website or App (if provided) becomes public information, including within private direct messaging. We cannot guarantee the security of this type of disclosed information.
If you’re under 18, you should only use our services with involvement of a parent or guardian. For their protection, we ask anyone under 18 years of age to not attempt to register with MCC as a member or otherwise provide us with any personal information without the consent of a parent or legal guardian. It is, however, ultimately the responsibility of parents or guardians to monitor their children’s activities.
On occasion, we may use and disclose your personal information to inform you about MCC products, services, or promotional MCC offers or activities, which we believe may interest or benefit you. We may do this via email, SMS, telephone, mail or notification on your mobile device if you have provided consent for us to do so.
If you have indicated your consent to receive such direct marketing (such as selecting this option on sign-up) (“opt-in”), you may withdraw this consent at any time by accessing the “settings” options in your account.
Alternatively, you may contact us directly using the contact details provided on the “Contact Us” page on the Website (by email at Information@MulgraveCC.com.au or by our support line at 03 9582 4600). You may also follow the “opt-out” prompts displayed on commercial electronic messages from us.
We may also contact you in relation to the opening, service, management and administration of your MCC membership. These communications can be via any of the modes of contact recorded when you signed up, or when you otherwise update your contact preferences, or which we otherwise collect for the purposes of opening and maintaining your membership. Such communication is separate from any and all marketing communications and is not affected by your “opt-in” or “opt-out” status for direct marketing communications.
We will take all reasonable steps to ensure that your information is kept secure and protected at all times. We will take all reasonable steps to ensure that the personal information, which we collect, use or disclose, is correct and is stored in a secure environment that is accessed only by authorised persons.
We hold personal information physically in paper-based forms, and in an electronic database owned and operated by us. We take reasonable steps to protect the security of the personal information that we hold from both internal and external threats by ensuring that our physical storages and database are subject to strict standards of maintenance, security and compliance. Once received, we will take reasonable steps to protect your personal information from misuse, loss and unauthorised access, modification and disclosure including by implementing the following security and monitoring controls:
We will take reasonable steps to destroy or permanently de-identify the personal information we hold when it is no longer required for any purpose permitted under the APPs, including our legal or operational obligations. Legal obligations including under the Anti Money Laundering and Counter Terrorism Financing Act 2006 (Cth) require retention of certain personal information for a minimum 7 years. If you believe we hold personal information about you that we should no longer hold, you may request deletion of your personal information by contacting us at the details below. Any requests made for the deletion of personal information will be reviewed in accordance with this policy.
We will take all reasonable steps to ensure that personal information we collect is accurate, complete and up to date. You are entitled to access and correct the information held about you. This can be done by using the contact details provided on the “Contact Us” page on the Website or App (by email at Information@MulgraveCC.com.au or by our support line at 03 9582 4600).
In using our sporting facilities, venues, our Website and our App, you agree to be bound by the terms of this Privacy Policy. We may review, change or update this Privacy Policy periodically and we reserve the right to change the Privacy Policy at any time at our discretion by posting such changes on the Website. This Privacy Policy is specifically designed to evolve to follow any legislative and other legal or policy changes, which may impact our collection and management of your information under this Privacy Policy. We will publish our current Privacy Policy on the Website and any changes will take effect immediately at the time of publication. Your continued use of our facilities, venues, Website, and App following publication will constitute your acceptance of those changes. You should review this Privacy Policy regularly and remain familiar with its terms.
To the extent that this Privacy Policy exceeds the minimum obligations of MCC under Commonwealth and state legislation, this Privacy Policy serves as a documentation of our voluntarily self-imposed standards. While we are determined to meet those standards as best we can, to the extent permitted by law, MCC is not liable if it does not adhere to any of these voluntarily self-imposed standards for any loss, liability, costs, expense or damage arising as a result of MCC failing to meet any of the voluntarily self-imposed standards in this Privacy Policy.
If you have any queries, requests for access or correction, or complaints relating to the handling of your personal information which has not been or you feel cannot be appropriately handled by Customer Service, please contact:
Compliance Officer
Address: Corner of Wellington
and Jells Roads
Wheelers Hill, Vic. 3150
Tel: 03 9582 4600
Email: Information@MulgraveCC.com.au
Further information about privacy concerns or complaints in Australia may be found on the Office of the Australian Privacy Commissioner’s (OAIC) Website at www.oaic.gov.au.
Version: 1.0
Effective date: 11 February 2026
