PRIVACY POLICY

MULGRAVE COUNTRY CLUB'S PRIVACY POLICY

The Mulgrave Country Club is subject to the provisions of the Privacy Act of 1988. The Act contains 10 national privacy principles that set the standard for the processing of personal information. The Club is committed to protecting the privacy of the personal information of its members, visitors and employees. Any personal information you provide to the Club (such as name, address, date of birth and contact details), including information collected as a result of placing a Membership Card into a gaming machine or other Club machine that is linked to a player tracking system (other than an ATM) that may provide you with benefits or services, will be protected.

Clubs generally do not disclose personal information to the relevant authorities if they reasonably believe that there is a threat to the life, health or safety of an individual, or public health or safety. If the Club has no reason to suspect that the illegal activity has been, is being or may be engaged in, personal information may be used or disclosed as a necessary part of any investigation and reporting to the person concerned or authority.

The Club may disclose your information to third parties who provide services to the Club under contract. These contracts require third parties to keep your personal information confidential and secure. Your personal information, including information about you as a result of placing your Membership Card into a gaming machine or other club machine (other than an ATM machine), may be used by the club for marketing purposes to improve our services and to provide you with up-to-date information about those services, any new related services and game promotions, and if you do not wish to receive information about services and game promotions, the club will remove your name from the mailing list upon request.

You have the right to access any personal information that the Club may hold about you, including the right to correct your information. Clubs generally do not charge you a fee for accessing your personal information.

Members hereby and absolutely indemnify the Club, its employees and agents from any claims arising out of negligence, breach of contract, breach of law or statutory duty. This release was released during the initial membership period and during any other membership periods. Without limiting the generality of the foregoing, the Member hereby and absolutely indemnifies the Club, its employees and agents from any claim arising out of bodily injury to the Club, its employees or agents in the Clubhouse or the relevant Clubhouse premises, including any claim for bodily injury arising out of the negligence of the Club, its employees or agents or any other person using the Club Premises or the negligence of any other person using the Club Premises, and the Member hereby confirms that his/her use of the Club Premises and all facilities is entirely at his/her risk. This version applies to the current membership year and all subsequent membership years (regardless of whether the membership category has changed).

 

Facial Recognition Technology (FRT) Policy:

Purpose of Facial Recognition Technology: Our venue uses Facial Recognition Technology (FRT) to enhance safety, ensure compliance with self-exclusion programs, and support harm minimisation initiatives. The use of FRT is strictly aligned with the principles of privacy, transparency, and compliance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

How Data Is Collected FRT analyses facial features of individuals entering specific areas of our venue. 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.

How Data Is Stored Temporary Memory Only: All facial data processed by FRT is held in temporary memory for the sole purpose of conducting real-time comparisons. This data is not stored in any database or retained after processing.

Anonymous Analytics: We may store aggregate, anonymised data for operational insights, such as people counts, gender demographics, and approximate age ranges. This data is fully anonymised and cannot be linked to any individual or facial profile.

How Data Is Used Self-Exclusion Compliance: FRT is used to assist in identifying individuals who have voluntarily enrolled in self-exclusion programs or have received formal ban notices.

Operational Insights: Anonymous and aggregate data may be used to optimise venue operations, such as managing crowd density and enhancing service offerings. This data contains no personal or identifiable information.

Privacy and Compliance: Our use of FRT complies with the Privacy Act 1988 (Cth) and the Australian Privacy Principles. We ensure that all data handling practices meet the highest standards of security, necessity, and proportionality. 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 in this privacy policy and upon request. All data collected and processed is limited to what is necessary to achieve specific safety and compliance objectives.

Transparency and Your Rights: Our venue is committed to transparency regarding the use of FRT. If you have questions about how FRT operates or your rights under the Privacy Act, please contact us using the details provided below. You have the right to understand how FRT is used and the purposes for which data is processed. You may also request additional details about how anonymous data is managed.

 

If you need any further information, please contact the office at 9582 4600.