Privacy & Data Protection Policy

IRPSX Pty Ltd trading as Bet Right is committed to protecting and respecting your privacy and your right to fair and just processing of your Personal Information and how it is being used. This Privacy & Data Protection Policy is intended to help you better understand how Bet Right collects, holds, uses, processes, and in certain circumstances, discloses your Personal Information and describes your choices regarding these actions. Bet Right  is aware of the importance of how Personal Information is handled and wishes to assure you that Bet Right  observes all applicable Australian privacy and data protection laws, including the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

Personal information has the meaning given to it under the Privacy Act 1988 (Cth), being information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not. This includes, for example, your name, address, email address, phone number, date of birth, financial information, location data, and device or online identifiers.

Please read the Privacy & Data Protection Policy carefully to get a clear understanding of how Bet Right collects, uses, processes, stores, discloses, protects, or otherwise handles your Personal Information and data in accordance with your access and use of the Bet Right website.

Our Privacy Management Framework

This Privacy & Data Protection Policy forms part of our privacy management framework. We regularly review and update our privacy practices to ensure ongoing compliance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

Compliance Commitment:

We have implemented practices, procedures and systems to ensure compliance with the Australian Privacy Principles, including:

• A designated Privacy Officer responsible for overseeing privacy compliance and handling inquiries and complaints
• Privacy policies and procedures that are regularly reviewed and updated
• Privacy training programs for all staff who handle personal information
• Privacy impact assessments for new projects and systems that involve material new collection, use or disclosure of personal information
• Regular internal audits of privacy practices and security measures
• Privacy by design principles embedded in system development and business processes
• Data breach response procedures compliant with the Notifiable Data Breaches scheme
• Clear procedures for handling access and correction requests
• Mechanisms for individuals to make inquiries or complaints about our privacy practices
• Regular monitoring and review of compliance with this Privacy & Data Protection Policy and the APPs

Availability of This Policy

This Privacy & Data Protection Policy is available free of charge on our website at www.betright.com.au. If you require this policy in a different format (for example, in large print, an accessible digital format, or a printed copy), please contact our Privacy Officer at privacy@betright.com.au and we will take reasonable steps to provide it in the form requested as soon as practicable.

What Information We Collect and Why

When registering on or otherwise accessing and using the Bet Right website, as appropriate, you may be asked to enter your name, email address, phone number or other details to help you with your experience.

Sensitive Information

Bet Right does not routinely collect sensitive information as defined under the Privacy Act 1988 (Cth), including racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sexual orientation, or criminal records.

We may collect the following sensitive information in limited circumstances:

• Health-related information: where you participate in our responsible gambling program, we may collect information about gambling behaviour that may indicate mental health concerns or financial hardship. We will only collect this information with your express consent or where required or authorised by law, and will handle it with additional security measures and restrict access to authorised personnel on a need-to-know basis.
• Financial information: we collect financial information as required to comply with our obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth). Collection of this information is authorised by law.
• Biometric information: we collect biometric information (including facial geometry and liveness detection data) during the identity verification process for new account registrations. This information is used solely for the purpose of verifying your identity as required under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth). Collection of this information is required by law. Biometric information is handled by our identity verification service provider and is not retained by Bet Right beyond the period necessary to complete verification, subject to the provider’s contractual obligations to Bet Right.

We will not use or disclose sensitive information for any purpose other than the purpose for which it was collected, and will not collect more than is reasonably necessary for that purpose. Where we collect personal information for the purposes of complying with our obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), we collect only the information reasonably necessary for that purpose, having regard to the nature of the transaction and our customer due diligence obligations.

We collect the following types of personal information:

• Identity information (name, date of birth, address, gender, government-issued identification details)
• Contact information (email, phone number, postal address)
• Financial information (debit card number, bank account information, transaction history)
• Location data (GPS location, IP address)
• Website usage and behavioural data (browsing patterns, preferences, interaction with content, pages viewed, date and time of visits)
• Device and technical information (IP address, browser type, device identifiers, login details, device or browser settings)
• Betting activities and behavioural data (betting history, wagering patterns, interactions with the website and marketing messages)
• Communication records (correspondence with our customer service team, feedback, support requests)
• Social media information (information you share on our services such as on community features or share with us through social media sites)
• Tax-related information (to determine liability for goods and services tax and other taxes where applicable)
• Screening information (information from screening against sanction watchlists as required by law)
• Source of funds information (to comply with anti-money laundering obligations)

How We Collect Your Information

We collect personal information directly from you when you:

• Register for an account
• Use our website or mobile applications
• Contact our customer service
• Participate in promotions or surveys
• Subscribe to communications
• Interact with our content and features

We may also collect information from third parties, including:

• Identity verification service providers (DVS gateway)
• Credit reporting bodies (where permitted by law)
• Publicly available sources
• Social media platforms (if you connect your accounts)
• Racing and sporting bodies
• Other betting and wagering service providers (with your consent)
• Payment processors and financial institutions
• Feedback and complaint mechanisms (including from regulators or other appropriate sources)
• Job applications (if you apply for employment with us)

We may also generate new personal information through analysis based on other personal information we hold.

We will only collect personal information by lawful and fair means and not in an unreasonably intrusive way.

Anonymity and Pseudonymity

Where practicable, we will give you the option to interact with us anonymously or using a pseudonym. However, for most of our services this is not practicable because:

• We are required by law to verify your identity (Anti-Money Laundering and Counter-Terrorism Financing Act 2006)
• State and Territory gambling legislation requires identity verification
• We need to identify you to provide betting and wagering services
• We must maintain transaction records for tax and regulatory purposes

You may interact with us anonymously for:

• General website browsing (before account creation)
• General inquiries via our contact form
• Feedback about our services

If you wish to remain anonymous or use a pseudonym, please let us know when contacting us at privacy@betright.com.au.

Consequences of Not Providing Information

If you choose not to provide certain personal information, we may not be able to:

• Verify your identity as required under Australian law
• Provide you with our betting and wagering information services
• Comply with our legal obligations under anti-money laundering and responsible gambling laws
• Respond to your inquiries or provide customer support
• Process transactions or maintain your account

Some information collection is mandatory under:

• Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act)
• State and Territory gambling legislation
• Tax reporting obligations
• Responsible gambling requirements

Note: In limited circumstances involving AML/CTF investigations, we may be prohibited by law from notifying you that we are collecting or have collected certain personal information about you, where doing so would or could reasonably be expected to prejudice an investigation under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).

Identity Verification

We are required by law to verify your identity.

Identity Verification Process:

We will use identity verification services to confirm your identity and ensure compliance with relevant laws.

To assist us in verifying your identity, we will disclose your personal information (including your name, address and date of birth) to third parties including:

• The Document Verification Service (DVS) (a facility developed, operated, and maintained by the Attorney-General's Department)
• Electronic verification services and Credit Reporting Bodies (CRBs) who may use the information supplied to assess whether it matches what they hold about you

Your consent:
We will obtain your express consent before using the DVS. You can withdraw consent, but this may prevent us from providing services to you.

If you do not wish us to disclose your personal information to a CRB, please contact our Privacy Officer at privacy@betright.com.au to discuss.

DVS Privacy:
The DVS checks if your document details match records held by issuing agencies. The DVS does not store your documents. For more information, visit: www.idmatch.gov.au or www.ag.gov.au/national-security/identity-security/identity-verification-services

Use and Disclosure of Government Identifiers

We may collect government identifiers such as driver's license numbers, passport numbers, and Medicare numbers solely for the purpose of identity verification as required by law.

We will not:

• Use government identifiers as our primary means of identifying you
• Disclose government identifiers unless required or authorized by law
• Adopt a government identifier as our own identifier for you

We maintain strict controls over access to government identifiers and store them separately from other personal information where practicable.

Collection, Use and Disclosure of Information

The primary purpose for which Bet Right  collects your Personal Information for subsequent use and disclosure is to provide you with betting and wagering information and data services including data analytical tools tailored to your specific circumstances, preferences and online and mobile behaviour. Providing such services will include publishing and communicating to you new information and data, using the mostconvenient and accessible form, manner and medium which means using your contact and communications details.

Bet Right  collects and may hold information from you including Personal Information when you access, register, sign up for our newsletter, blog or other forms, manner or medium of communication, respond to a survey or marketing communication, access or use the website, or use certain other features made available on the website.

Our registration process will include using your Personal Information to verify your identity to comply with our obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act). We may do this by accessing the Australian government Document Verification Service (DVS) using a gateway service provider. The DVS checks if the information on your identity documents matches the original records held by issuing agencies. We will obtain your express consent to use the DVS. You can obtain further information about the operation and management of the DVS hub on the Attorney-General's Department website.

Bet Right  may use and disclose the information collected from you including Personal Information for purposes other than the primary purpose stated above (secondary purposes):

• To comply with our legal and statutory obligations including customer identity verification, customer due diligence, ongoing monitoring and reporting obligations imposed by the AML/CTF Act
• Disclosure as mandated by Commonwealth, states, territories laws, regulations and licences
• Disclosure as required by legal contracts entered into by us to provide you with betting and wagering information and data services including agreements with declared events and contingencies (sporting and racing) governing bodies and equivalent
• To understand your wants and needs and behaviour so as to be able to personalise your individual user experience and how you access and use the website and mobile apps, and to allow Bet Right to deliver the type of content and product offerings in which you are most interested
• To improve the website in order to better serve you
• To allow Bet Right to create better service when responding to your requests or inquiries
• To conduct research using data analytics techniques including machine learning, AI to create anonymised customer profiles in order to create and provide better customer service and UX experience
• To administer a contest, promotion, survey, marketing, or other site feature
• To send periodic emails, texts messages or other media regarding your use of our website including direct marketing
• To send periodic emails, texts messages or other media regarding the operations of our parent corporation, BetTube Corporation Ltd
• To allow bookmakers and affiliates, associated publishers (online and mobile) and other data publishers for which you may be associated with or have a transactional or membership relationship, to use it for operational purposes and, with your consent, marketing, and promotional purposes
• To display content and advertising (including in relation to bookmakers, race, sports and Esports events) that is customised to your interests, preferences and experiences. This includes online and mobile targeted marketing, data and audience matching against third-party platform databases, and market segmentation activities based on your betting behaviour, browsing patterns, and account history.
• To respond to enquiries and complaints from you and to establish, exercise or defend any legal claims
• To administer our business operations, including our safer gambling program and risk and liability management
• For taking appropriate action in relation to suspected unlawful activity, fraud or misconduct or otherwise to ensure the safety and security of its services
• To protect and maintain the integrity of particular sports/racing codes by assisting Australian sports/racing controlling bodies in their inquiries, or notifying such bodies of any betting activity we consider to be unusual or suspicious
• To the extent that the information is included in a job application, to assess and process that application and for other recruitment purposes

Use of Automated Technologies: To support the purposes outlined above, we may use automated technologies, including artificial intelligence (AI) tools. For instance, these tools may assist in generating and managing responses when you contact us, analysing betting patterns, and personalising your experience.

Automated Decision-Making and Profiling

We use automated processing and profiling techniques including machine learning and AI to:

• Personalize your user experience
• Recommend content and betting options
• Detect unusual account activity or potential fraud
• Assess compliance with responsible gambling measures
• Deliver targeted marketing
• Create anonymized customer profiles for service improvement

How profiling works: We build profiles of customers based on data including account activity, betting history, browsing behaviour, transaction patterns, and interactions with our communications. These profiles are used to place customers into audience segments, which in turn determine the content, offers, and marketing communications you receive. Profiling does not result in any decision that legally affects you or similarly significantly affects you without human review being available.

If you have questions about how profiling may be affecting your experience, contact privacy@betright.com.au.

AI agent processing: We may also use AI agent technologies within third-party analytics and engagement platforms that can autonomously query, analyse and surface insights from your personal information on a continuous basis. Where AI agent outputs influence decisions about your account or experience, those decisions remain subject to our automated decision-making governance, including your right to request human review. To request human review, contact privacy@betright.com.au  with 'Automated Decision Review' in the subject line.

Solely Automated Decisions: Some decisions about your account may be made solely through automated processing, including:

• Account verification checks
• Transaction monitoring for fraud prevention
• Responsible gambling triggers and limits
• Suspicious activity alerts

You have the right to:

• Request human review of automated decisions that significantly affect you
• Express your point of view about the decision
• Contest the decision

To request human review, contact privacy@betright.com.au with "Automated Decision Review" in the subject line.

Direct Marketing and Your Rights

We may use your personal information to send you direct marketing about our services and those of our parent company BetTube Corporation Ltd, and selected partners.

You have the right to:

• Opt out of direct marketing at any time by:
  • Clicking 'unsubscribe' in any email
  • Replying 'STOP' to SMS messages
  • Contacting us at privacy@betright.com.au
  • Updating your preferences in your account settings
• Request that we do not disclose your information to third parties for their direct marketing purposes

We will action your opt-out request within 5 business days at no cost to you. Even if you opt out of marketing, we may still send you important account and service-related communications.

What marketing you might receive:

• Promotional offers and bonuses
• Information about new features and services
• Racing and sporting event information
• Partner offers (with your consent)
• Newsletters and blog updates

How we determine what to send you: We use your personal information including betting history, preferences, and behavior to tailor marketing communications that we believe will be relevant to you.

Third-Party Marketing: We will not disclose your information to third parties for their direct marketing purposes without your express consent. If you have consented and later change your mind, contact privacy@betright.com.au.

Marketing to Excluded Customers: If you have self-excluded from gambling services, we will suppress all promotional marketing related to betting and wagering. You may still receive:

• Account administration communications
• Responsible gambling information
• Legal and regulatory notices

Where you have self-excluded, we will also suspend behavioural profiling of your account for targeted marketing purposes for the duration of your exclusion. This suspension extends to any AI agent technologies operating within third-party platforms that access your account data for profiling or marketing purposes. Profiling necessary for responsible gambling monitoring, fraud prevention, and legal compliance obligations will continue.

Account Service Communications: From time to time, we may contact you in relation to the opening, service, management and administration of your account. These communications can be via any of the modes of contact recorded when you applied to open an account, registered as a Client or which we (or our related bodies corporate) otherwise collect for the purposes of opening and maintaining an account. Suchcommunication is not affected by your opt-in or opt-out status for direct marketing communications.

Use of Cookies and Tracking Technologies

Bet Right  uses cookies which are small files that a site or its service provider transfers to your computer's hard drive through your Web browser (if you allow) that enables the site's or service provider's systems to recognize your browser and capture and remember certain information.

Types of Cookies We Use:

• Essential cookies (required for site functionality)
• Performance cookies (site analytics and performance monitoring)
• Functional cookies (remember your preferences and settings)
• Targeting cookies (personalized advertising and content)

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.

We Use Cookies To:

• Understand and save user's preferences for future visits
• Keep track of advertisements
• Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future
• Provide personalized content and recommendations

Analytics and Advertising Technologies

We use third-party analytics and advertising services, which may include Google Analytics, Meta (Facebook) Pixel, and similar platforms. These services may:

• collect data about your interactions with our website and mobile applications;
• match that data against their own user databases to enable targeted advertising, retargeting, and lookalike audience campaigns; and
• use cookies, pixels, and similar tracking technologies to measure advertising effectiveness and deliver personalised advertising to you on third-party platforms.

Where we use third-party analytics providers, those providers may engage generative artificial intelligence sub-processors, including large language model providers such as OpenAI, Google and Anthropic, to deliver AI-powered features and autonomous data analysis capabilities. Your personal information may be processed by those sub-processors on a continuous basis in accordance with the data processing agreements between us and the relevant analytics provider, and subject to the overseas disclosure provisions of this Privacy & Data Protection Policy.

Where these services involve the disclosure of your Personal Information to overseas recipients, the disclosures in the Overseas Disclosure section of this policy apply.

You can opt out of interest-based advertising delivered through these platforms by adjusting your settings directly with those platforms or visiting www.youronlinechoices.com.au.

Managing Cookies

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser (e.g., Safari, Chrome, Internet Explorer, Firefox) settings. Each browser is a little different, so look at your browser's Help menu to learn the correct way to modify your cookies.

If you disable cookies, some features will be disabled. It won't affect the user experience significantly but may make your site experience less efficient and some of our services will not function properly.

Cookie preferences: Where our website uses a cookie consent tool or preference centre, you may manage your preferences for non-essential cookies through that tool at any time. Essential cookies cannot be disabled as they are necessary for the website to function.

Targeting cookies: Targeting cookies track your browsing activity on our website and, through third-party advertising services, across other websites and platforms. This information is used to build a profile of your interests and to deliver advertising relevant to you, including on third-party platforms such as social media sites. These cookies are placed by our third-party advertising partners, who may combine this information with other data they hold about you.

Do Not Track: Some browsers transmit Do Not Track signals to websites. Our website does not currently alter its data collection practices in response to Do Not Track signals. You can manage your cookie preferences using the mechanisms described above.

For more information about how to manage cookies and online tracking, visit www.youronlinechoices.com.au.

Third Party Disclosure

We may disclose your Personal Information to the following categories of recipients for the purposes described in this Privacy & Data Protection Policy, or as otherwise permitted or required under Australian law:

• regulators, law enforcement agencies, and other government bodies, as required by Commonwealth, state, or territory laws, regulations, or licence conditions;

• the Australian Transaction Reports and Analysis Centre (AUSTRAC), as required by our obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), including for the purposes of reporting, monitoring, and compliance with customer due diligence obligations;

• declared events and contingencies (sporting and racing) governing bodies and equivalent bodies, as required by legal contracts entered into by us to provide you with betting and wagering information and data services;

• Australian sports and racing controlling bodies, for the purpose of protecting and maintaining the integrity of particular sports and racing codes, including to assist in their inquiries or to notify them of betting activity we consider unusual or suspicious; 

• associates and related bodies corporate of Bet Right, including our parent corporation BetTube Corporation Ltd;

• professional researchers, incudng thos ewith expertise in computing, algorithmic analysis, machine learning, AI, and recommendation engine development;

• bookmakers and thier affiliates;

• associated online and mobile publishers; and

• other data publishers with whom you have a transactional or membership relationship.

Where we dislcose your Personal Information to bookmakers, affiliates, associated publishers, or data publishers, that disclosure may inckude behavioural data such as betting history, browsing patterns, and audience segment classifications, for the purpose of delivering targeted marketing and promotional content.  Where such discosure is for marketing purposes, we will only make it wiht your consent.

You may withdraw your consent for this type of disclosure at any time by contacting privacy@betright.com.au. 

Before disclosing your Personal Information to any third party, Bet Right will take resonable steps to ensure that the recipient is bound by obligations to handle your Personal Information in a manner consistent with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth), or is otherwise subject to a law or binding scheme that provides comparable protections. These steps will ordinarily incude requiring therecipient to enter into a written agreement with Bet Right that:

• restricts the use of your Perosnal Infomation to the purposes for which it was disclosed;

• prohibits onward disclosure without Bet Right's prior written consent;

• requires the recipient to assist Bet Right in responding to any access, correction, or complaint request you make; and

• requires the recipient to notify Bet Right promptly upon becoming aware of any actual or suspected data breach affecting your Personal Information. 

Overseas Disclosure of Personal Information

Bet Right may contract with service providers, professional advisers, and other third parties who are based outside Australia. In connection with providing you with our services, we may disclose your Personal Information to overseas recipients in countries including, but not limited to:

• the United States of America;
• the United Kingdom;
• the European Union (EU);
• Singapore;
• India;
• Japan;
• Canada;
• France;
• Netherlands;
• Indonesia; and
• other countries in which our technology, hosting, and data analytics service providers operate.

Bet Right is committed to taking reasonable steps to ensure that overseas recipients handle your Personal Information in a manner consistent with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth), including by seeking to incorporate appropriate data protection obligations into its agreements with overseas recipients over time.

However, it is not practicable in all cases for us to ensure that every overseas recipient is currently bound by obligations comparable to the APPs prior to disclosure. Accordingly, by using our services and agreeing to this Privacy & Data Protection Policy, you expressly consent to the disclosure of your Personal Information to overseas recipients in the countries listed above on the following basis, of which you should be aware:

• the overseas recipient may not be subject to privacy obligations comparable to the APPs under the Privacy Act 1988 (Cth);
• if the overseas recipient mishandles your Personal Information, you may not be able to seek redress under the Privacy Act 1988 (Cth) or through the Office of the Australian Information Commissioner (OAIC); and
• Bet Right will not be accountable under the APPs for any act or practice of the overseas recipient in relation to your Personal Information following disclosure.

If you do not consent to the disclosure of your Personal Information to overseas recipients on this basis, please do not use our services or website and contact us at privacy@betright.com.au.

If you wish to obtain further information about the countries to which we may disclose your Personal Information, please contact us at privacy@betright.com.au.

Protection of Information

Your Personal Information is held on secure systems and is accessible only by persons with authorised access rights who are required to maintain confidentiality. Bet Right implements appropriate technical and organisational security measures when Personal Information is collected, submitted, or accessed, to protect it against unauthorised access, disclosure, alteration, or loss.

In the event of a data breach that is likely to result in serious harm to you, Bet Right will comply with its obligations under the Notifiable Data Breaches (NDB) scheme in Part IIIC of the Privacy Act 1988 (Cth), including notifying you and the OAIC as required.

Where a data breach involves personal information that is subject to secrecy provisions under the AML/CTF Act, our obligation to notify you of the breach may be limited. In those circumstances, we will comply with the Notifiable Data Breaches scheme only to the extent that doing so is not inconsistent with our obligations under the AML/CTF Act, including the prohibition on disclosing information that could prejudice an investigation. We may, in those circumstances, notify the OAIC without notifying you directly.

Employee Confidentiality: Our employees, agents and contractors are required to maintain the confidentiality of Clients' Personal Information and trading behaviour.

Your Responsibility:

• Remember to always log out of your account when you have completed your time on the website. This is particularly important if you share a computer with another person.
• You are responsible for the security of and access to your own computer, mobile device or any other handset used to access the website.
• You are solely responsible for maintaining the secrecy of your username, password and any account information.

Public Information: Information posted on bulletin boards or communicated within a social media environment (for example, Facebook, Twitter, Chat Rooms, community feeds) becomes public information. We cannot guarantee the security of this type of disclosed information.

Data Retention

Bet Right retains your Perosnla Information for as long as is necessary for the purposes for whoch it was collected, or as required or auhtorised by law, including:

• for the duration of your customer relationship with us and for a reasonable period thereafter, for the purpose of dispute resolution, enforcement of our terms and conditions, and legitimate business administration;
• for a minimum of seven (7) years following the end of your customer relationship with us, in respect of customer due diligence (CDD) records - including identity verification records - created or obtained under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth); and
• for such a period as required by applicable taxation legislation in respect of financial transaction records. 

Where Bet Right holds Personal Information that is no longer required for any purpose permitted under the Australian Privacy Principles (APPs) and is not subject to a mandatory retention obligation, Bet Right will take reasonable steps to destroy or permanently de-identify that information in accordance with APP 11.2.

Certain categories of Personal Information are subject to permanent retention obligations under applicable law and licence conditions. These categories include transaction and betting records, monthly activity statements issued to clients, deposit limit and voluntary pre-commitment records, self-exclusion and Bet Stop compliance records, regulatory and legal correspondence, complaint and access request records, and privacy governance records. Where permanent retention applies, Bet Right will periodically review whether de-identification of older records is practicable and permissible without compromising regulatory utility, consistent with APP 11.2 of the Privacy Act 1988 (Cth).

For all other Personal Information that is no longer required for any purpose permitted under the Australian Privacy Principles (APPs) and is not subject to a mandatory retention obligation, Bet Right will take reasonable steps to destroy or permanently de-identify that information in accordance with APP 11.2.

Deletion Requests: If you believe Bet Right holds Personal Information about you that should no longer be retained, you may request deletion by contacting privacy@betright.com.au. All deletion requests will eb assessed against our obligations under this Privacy & Data Protection Policy and applicable law. Bet Right will not action a deletion request where doing so would require destruction of records that are subject to a mandatory retention obligation, including CDD records retained under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).  Where a deletion request is received but cannot be fully actioned due to a mandatory retention obligation, we will notify you of the extent to whcih the request can be actioned and the legal basis for retaining the remaining records. 

Your Consent and Choices

By using our services, you consent to the collection, use, and disclosure of your personal information as described in this Privacy & Data Protection Policy.

Specific Consents:

You can manage your consent preferences for:

• Marketing communications from Bet Right
• Marketing communications from BetTube Corporation Ltd
• Sharing information with third-party bookmakers for their marketing
• Participation in data analytics and profiling for personalized experiences
• Social media integration and data sharing
• Overseas disclosure of your Personal Information under APP 8.2(b) of the Privacy Act 1988 (Cth) — that is, your consent to the disclosure of your Personal Information to overseas recipients who may not be bound by obligations comparable to the Australian Privacy Principles, as described in the Overseas Disclosure section of this policy. Note: if you withdraw this consent, Bet Right may be unable to provide its services to you, as some service delivery functions require disclosure to overseas recipients. Please contact privacy@betright.com.au before withdrawing this consent to understand the effect on your account.

Managing Your Consents: You can update your consent preferences at any time by:

• Logging into your account settings
• Contacting privacy@betright.com.au
• Using opt-out mechanisms in communications

Withdrawing consent may limit our ability to provide certain services to you. We will inform you of any such limitations before processing your withdrawal.

Your Rights to Access and Correct Your Information

Right to Access

You have the right to request access to the personal information we hold about you.

To request access:

• Follow the "Your Account" link on the website after logging in
• Email privacy@betright.com.au with your request
• Contact us on the Customer Service hotline on 1300 238 670
• Provide proof of identity (e.g., driver's license, passport)
• Specify what information you wish to access

We will respond to your request within 30 days and provide access within a reasonable timeframe (usually 14-30 days). We will give you access to your personal information in the manner requested if that is reasonable and practicable.

We may charge a reasonable fee to cover the cost of providing access, which we will advise you of before processing your request. We will not charge for making the request.

We may refuse access in certain circumstances permitted by the Privacy Act, including where:

• Providing access would pose a serious threat to life, health or safety
• Providing access would have an unreasonable impact on others' privacy
• The request is frivolous or vexatious
• Legal proceedings are in progress or anticipated
• Providing access would be unlawful
• Denying access is required or authorized by law
• Providing access would prejudice law enforcement activities

If we refuse access, 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 for such reasons, we will provide you with written reasons and information about how to complain.

Limitations on Access — AML/CTF Act

There are circumstances in which we are legally prohibited from providing you with access to your personal information, or from explaining why we have refused access.

Specifically, under section 123 of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), we are prohibited from disclosing information that would or could reasonably be expected to prejudice an AML/CTF investigation (the tipping off prohibition). Where an access request relates to personal information that is subject to this prohibition:

• we will not provide access to that information; and
• we will not be able to provide you with reasons for the refusal, to the extent that doing so would itself constitute tipping off.

In these circumstances, our written refusal notice will inform you that access has been refused and that you may make a complaint about our decision, but will not explain the specific basis for refusal.

This does not affect your right to make a complaint to the Office of the Australian Information Commissioner (OAIC) about the refusal of access.

Right to Correction

You have the right to request correction of personal information we hold about you if you believe it is inaccurate, out-of-date, incomplete, irrelevant or misleading.

We take reasonable measures to ensure that personal information which we collect is accurate, complete and current and also when we use and disclose it, that it is relevant, having regard to the purpose for which it is being used or disclosed. We will take reasonable measures to correct personal information if we are satisfied that it should be corrected. We may contact you on a periodic basis to seek the most up to date information from you.

To request correction:

• Update your information in the "Your Account - Account Details" section of the website at any time after you log in
• Email privacy@betright.com.au
• Call our Customer Service hotline on 1300 238 670 (subject to identity verification)
• Specify what information you believe is incorrect
• Provide evidence supporting the correction

We will respond within 30 days and make corrections within a reasonable timeframe if we agree the information is incorrect.

If we refuse to correct information, we will:

• Provide written reasons for our refusal
• Allow you to request that we associate a statement with the information claiming it is inaccurate
• Inform you of your right to complain to the OAIC

If we correct information that we have previously disclosed to third parties, you may request that we notify those third parties of the correction, and we will take reasonable steps to do so unless it is impracticable or unlawful.

Viewing Your Betting History: Details of your betting transactions can be found in the "Bet History" section of your account after you log in.

Children's Privacy

Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children under 18. If you are under 18, please do not provide any personal information to us.

If we become aware that we have collected personal information from a child under 18, we will take steps to delete that information as soon as practicable.

Parents or guardians who believe we may have collected information from a child under 18 should contact us immediately at privacy@betright.com.au.

Third Party Links

Occasionally, at our discretion, Bet Right  may include or offer third party products or services on the website. These third-party sites have separate and independent privacy policies. Bet Right  therefore has no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of the site and welcome any feedback about these sites.

Business Transfers

In the event that Bet Right  is involved in a merger, acquisition, sale of assets, bankruptcy, or other business transfer, your personal information may be transferred as part of that transaction.

We will:

• Notify you via email and/or prominent notice on our website before your information is transferred
• Ensure the recipient is bound by privacy obligations at least as protective as this Privacy & Data Protection Policy
• Give you the opportunity to opt out where practicable

The recipient will be entitled to use your personal information in accordance with this Privacy & Data Protection Policy (or a substantially similar policy).

Making a Complaint or Inquiry

If you have questions about how we handle your personal information or concerns about our privacy practices, you have the right to make an inquiry or complaint.

Privacy Inquiries

If you have general questions about:

• How we collect, use or disclose your personal information
• Your privacy rights under this Privacy & Data Protection Policy
• How to access or correct your personal information
• Our privacy practices generally

Contact our Privacy Officer:
 Email: privacy@betright.com.au 
 Subject: Privacy Inquiry

We will respond to privacy inquiries as promptly as possible, typically within 7-10 business days.

Privacy Complaints

If you believe we have breached the Australian Privacy Principles or this Privacy & Data Protection Policy, you can make a formal complaint.

Step 1: Complain to Us

Contact:
 Privacy Officer
 Bet Right 
 Email: privacy@betright.com.au 
 Subject: Privacy Complaint

Include:

• Your contact details
• Details of your complaint
• What outcome you are seeking

Our Response Process:

• We will acknowledge your complaint within 7 business days
• We will investigate and respond within 30 days
• If we need more time, we will inform you in writing and provide reasons
• We will provide a written response explaining our decision and any action taken
• We will consider any complaints fairly and aim to resolve them as quickly as possible

Step 2: External Complaint

If you are unsatisfied with our response, you can lodge a complaint with:

Office of the Australian Information Commissioner (OAIC)
 Website: www.oaic.gov.au 
 Phone: 1300 363 992

 Email: enquiries@oaic.gov.au 
 Post: GPO Box 5218, Sydney NSW 2001

The OAIC can investigate your complaint and make determinations about whether we have breached the Privacy Act.

You also have the right to make a complaint to the OAIC at any time. However, the OAIC may encourage you to attempt to resolve the complaint with us first.

Further Disclaimer

Bet Right  has taken all reasonable care in producing and publishing information contained on this website and will endeavour to do so regularly. Although considerable care has been taken in preparing and maintaining the information and materials contained on this Website, it is provided on an "as is" basis, without warranty of any kind, either express or implied, with respect to the accuracy or completeness of the information. Material on this site may still contain technical or other inaccuracies, omissions, or typographical errors, for which Bet Right assumes no responsibility. Bet Right  does not warrant or make any representations regarding the use, validity, accuracy, completeness or reliability of any claims, statements or information on this site. In using this Website, you agree that under no circumstances, including, but not limited to, negligence, shall Bet Right be liable for any direct, indirect, special, incidental, consequential, or other damages, including but not limited to, indirect, incidental, special, punitive or consequential damages and loss of profits, opportunities or information, loss of programs, loss of data, loss of use of computer or other systems, whether or not advised of the possibility of damage, arising from your use, or inability to use, the material on this site. Furthermore, you may not modify or reproduce in any form, electronic or otherwise, any information on this site, except for personal use unless you have obtained Bet Right’s express written permission.

Changes to This Privacy & Data Protection Policy

We may update this Privacy & Data Protection Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes to this Privacy & Data Protection Policy, we will:

• Update the "Last Updated" date at the top of this policy
• Publish the current Privacy & Data Protection Policy on our website
• Notify you via email or prominent notice on our website
• Obtain your consent where required by law
• Implement changes from the time of publishing

We encourage you to review this Privacy & Data Protection Policy periodically and remain familiar with its terms to stay informed about how we protect your information.

Related Policies and Documents

This Privacy & Data Protection Policy should be read in conjunction with:

• Terms and Conditions
• Responsible Gambling Policy
• Website Terms of Use

These documents are available at www.betright.com.au or by request to privacy@betright.com.au.

Contacting Us

If there are any questions regarding this Privacy & Data Protection Policy you may contact us:

General Privacy Inquiries:
Email: privacy@betright.com.au 
Subject: Privacy Inquiry

Access Requests:
Email: privacy@betright.com.au 
Access Request - [Your Name]

Correction Requests:
Email: privacy@betright.com.au 
Subject: Correction Request - [Your Name]

Privacy Complaints:
Email: privacy@betright.com.au 
Subject: Privacy Complaint - [Your Name]

Data Breach Notifications:
Email: privacy@betright.com.au 
Subject: Data Breach Report

Opt-Out Requests:
Email: privacy@betright.com.au 
Subject: Opt-Out Request

Automated Decision Review:
Email: privacy@betright.com.au 
Subject: Automated Decision Review

Response Times:

• Acknowledgment: 7 business days
• Full response: 30 days
• Urgent matters: 48-72 hours

Privacy Officer:
Bet Right 
Attention: Privacy Officer
Email: privacy@betright.com.au 
 

For all privacy-related inquiries, complaints, or requests for access or correction, please use the contact details above.

Version: 2.4

Date: 28.4.2026

Revision History