Directive on Surveillance, Privacy and Data (including Personal Information Use and Disclosure) Protection

1.    Introduction

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. Bet Right respects your right as an individual to your personal information as data and your informed choice on how that data is to be used and disclosed.

Bet Right is the wagering brand of IRPSX Pty Ltd, a sports bookmaker licensed by the Northern Territory Racing and Wagering Commission(NTRWC). As a licensed sports bookmaker, Bet Right has responsibilities and accountability to the Northern Territory government, and the Commonwealth and other states and territory governments and their agencies. In addition, Bet Right may also have obligations to third party entities with whom Bet Right are in commercial contractual relationships.

This Directive on Surveillance, Privacy and Data (including Personal Information Use and Disclosure) Protection (Directive) is intended to help you better understand how Bet Right collects, holds, uses, processes, and in certain circumstances, discloses your Personal Information and other data, and describes your choices regarding these actions. Bet Right is aware of the importance of how Personal Information and other data are 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).

2.  Privacy

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 this Directive carefully in conjunction with our Privacy & Data Protection Policy to get a clear understanding of how Bet Right collect, use, process, stores, discloses, protect or otherwise handle your Personal Information and data in accordance with your access and use of Bet Right website and mobile Apps. 

2.1. Personal Information

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

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.

- 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.

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.

Bet Right will also require photographic identification and proof of address documents (KYC/AML purposes) as well as banking and financial details and information (to set up a Betting Account and ascertain source of funds).

For KYC/AML and banking and financial purposes in relation to setting up the Betting Account, we may request Personal Information and other personal and financial information from third party entities providing verification and banking services including the Australian Government’s Document Verification Service (DVS), accessed via an approved gateway provider.  We will obtain your express consent before initiating any DVS check. Further information about the DVS is available at www.idmatch.gov.au. 

You will be given a User ID and asked to provide a username, password and personal identification number (PIN) on setting up a Betting Account.

 2.2 Data 

Bet Right collects data when you use our wagering services and betting products including the following:

• data on how you interact with our betting products and use our services;
• data about your online browsing behaviour on the Bet Right website and mobile Apps – please see section on Cookies for more details;
• data on the devices you used to access our Services (such as model, operating system, IP address, browser type, mobile device identifier);
• recording phone calls – we may monitor or record phone calls with you.

We might do this in order to:

(i) ensure we have carried out your instructions correctly;

(ii) resolve queries, issues and disputes;

(iii) comply with legislation and regulations, and licence requirements;

(iv) detect or prevent fraud or other crimes;

(v) improve our quality of service; and

(vi) train our staff.

2.3. Other Sources of Data

Bet Right also collects data about you from other sources including the following:

(i) data you shared online and on mobile apps, or otherwise made available on social media and other sites;

(ii) third parties who provide services and products to us as licensed sports bookmaker; and

(iii) data from publicly available sources.

2.4. Special Data

Bet Right offers wagering services and betting products and the data collected about you and your use and interaction with our services and products may also constitute health data (in the context of responsible gambling) as defined in the Privacy Act 1988 (Cth).

2.5. Purpose of collection

The primary purpose for which Bet Right collects your Personal Information for subsequent use and disclosure is to fulfil our obligations under the contract we signed with you to provide you with wagering services and betting products. The information and data collected, and the purpose, use and disclosure, are aimed to provide you with betting and wagering information and data services including data analytical tool tailored to your specific circumstances, preferences and online and mobile behaviour. Providing such services will include publishing and communicating to you information and data, tools using the most convenient 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.

2.6. Use of information

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 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 online and mobile, 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 client service requests or inquiries;
• to conduct research using data analytics techniques including machine learning and AI to create anonymised client profiles in order to create and provide better client service and UX experience;
• to administer a contest, promotion, survey, marketing or other site feature;
• to send periodic emails, text messages or other media regarding your use of our website, including direct marketing;
• to send periodic emails, text 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 with whom you 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, including through online and mobile targeted marketing, data and audience matching, and audience segment classifications against third-party platform databases, and market segmentation 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 our services; and
• 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.

2.7. Use and disclosure of information – compliance and integrity

As a licensed sports bookmaker, Bet Right has obligations to comply with legislation, regulations and licensing requirements which may require use and disclosure of your Personal Information and other data.

As a sports bookmaker and in order to provide you with wagering services and betting products, Bet Right has entered into agreements with governing bodies or equivalent that provide declared events and contingencies. These agreements will require Bet Right to use and disclose your personal Information and other data to the governing bodies in the interests of integrity in the declared events and contingencies.

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).As a licensed sports bookmaker, Bet Right has obligations to comply with legislation, regulations and licensing requirements which may require use and disclosure of your personal Information and other data.

2.8. Use and disclosure of health information

As a licensed sports bookmaker, Bet Right may use and disclose personal health information where required or authorised by law, including to comply with obligations relating to responsible gambling.

2.9. Use and disclosure of information – general

We may disclose your personal information to the following categories of recipients for the purposes described in this Directive, 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;

- 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;

We also share your personal data with associates and related bodies corporate of Bet Right, including our parent corporation BetTube Corporation Ltd, and with third parties that provide services to you on our behalf in line with the primary purpose, and with other third parties in the course of complying with our legislative, regulatory and licensing obligations.

Bet Right may contract with professionals, individuals, firms or companies, who are based overseas. Bet Right may disclose your Personal Information and other data with these persons based overseas.

Other entities to whom your Personal Information and other data may be disclosed include:

- professional researchers, including those with expertise in computing, algorithmic analysis, machine learning, AI, and recommendation engine development;

- bookmakers and their affiliates;

- associated online and mobile publishers; and

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

Where we disclose your Personal Information to bookmakers, affiliates, associated publishers, or data publishers, that disclosure may include behavioural data such as betting history, browsing patterns, and audience segment classifications, for the purpose of delivering targeted marketing and promotional content. Where such disclosure is for marketing purposes, we will only make it with your consent. You may withdraw 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 reasonable 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), or is otherwise subject to a law or binding scheme that provides comparable protections.

2.10. Automated Decision Making and Profiling

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

- personalise your user experience;

- recommend content and betting options;

- detect unusual account activity or potential fraud;

- assess compliance with responsible gambling measures;

- deliver targeted marketing; and

- create anonymised client profiles for service improvement.

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, and suspicious activity alerts.

You have the right to request human review of any automated decision that significantly affects you. To do so, contact privacy@betright.com.au  with "Automated Decision Review" in the subject line.

Where you have self-excluded from Bet Right's gambling services, behavioural profiling of your account for targeted marketing purposes will be suspended for the duration of your exclusion. Automated profiling necessary for responsible gambling monitoring, fraud prevention, and legal compliance obligations will continue during the exclusion period.

2.11. Retention

We retain your Personal Information and other data for as long as is necessary for the purposes for which it was collected, or as required or authorised by law, including:

- for the duration of your client relationship with us and for a reasonable period thereafter, for the purposes 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 client 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 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 permitted purpose 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 be assessed against our obligations under this Directive and applicable law. Bet Right will not action a deletion request where doing so would require destruction of records subject to a mandatory retention obligation, including CDD records retained under the AML/CTF Act. Where a deletion request cannot be fully actioned, we will notify you of the extent to which the request can be actioned and the legal basis for retaining the remaining records.

2.12. Rights and choices

Under the Privacy Act 1988 (Cth) and other Commonwealth, state and territories legislation, you have rights over your Personal Information and other data including the important right to choice.

These rights include:

- the right to access personal information we hold about you (subject to limited exceptions under the Privacy Act 1988 (Cth));

- the right to request correction of personal information that is inaccurate, out-of-date, incomplete, irrelevant or misleading;   

- the right to opt out of direct marketing communications at any time;

 - the right to request human review of automated decisions that significantly affect you; and 

 - the right to make a complaint about our privacy practices.

To exercise any of these rights, contact our Privacy Officer at privacy@betright.com.au. 

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 subject to this prohibition, we will not provide access to that information and will not be able to provide reasons for the refusal to the extent that doing so would itself constitute tipping off. This does not affect your right to make a complaint to the Office of the Australian Information Commissioner (OAIC) about the refusal of access.

Please consult the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au/privacy/your-privacy-rights.

3.  Data Protection

Your personal information is contained behind secure networks and is only accessible by a limited number of persons who have authorised access rights to such systems, and are required to keep the information confidential.

We implement a variety of security measures when a user enters, submits, or accesses their information to maintain the safety of your personal information.

We are also obligated under the Notifiable Data Breaches (NDB) scheme pursuant to the Privacy Act 1988 (Cth) to notify the affected individual and the OAIC when a data breach is likely to result in serious harm to an individual whose personal information is involved.

A data breach occurs when personal information we hold is lost or subjected to unauthorised access or disclosure. For example, when:

• a device with a client’s personal information is lost or stolen
• a database with personal information is hacked
• personal information is mistakenly given to the wrong person

The notification to individuals will include recommendations about the steps we have taken in response to the data breach.

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.

Your Responsibility

- Remember to always log out of your account when you have completed your session, particularly 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.Y

4. Surveillance/Monitoring

4.1.  Surveil/Monitor

You agree that Bet Right will conduct surveillance of Bet Right website, mobile Apps and platform including all transactions and monitor all wagering activities by the deployment of appropriate Bet Right and licensed third party technology.

4.2. Recording

You agree that Bet Right will make a recording of all telephone calls that take place between Bet Right and yourself, both incoming and outgoing. You consent to these recordings being made and you agree that the relevant recording(s) and/or any records of your transactions may be made available to the Northern Territory Racing and Wagering Commission (NTRWC) or any competent authority. All records of voice recordings will be securely retained by us in accordance with the Directive on Surveillance, Privacy and Data (including Personal Information Use and Disclosure) Protection.

4.3. Betting Account Investigation

You agree that Bet Right will be entitled to conduct an investigation into any suspected fraud, unlawful, illegal behaviour, abuse and misuse of your Betting Account, Bet Right Offers, products and services including the deployment of appropriate Bet Right and licensed third party technology.

5.  Cookies

5.1. Use of "cookies"

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 recognise your browser and capture and remember certain information. They are also used to help Bet Right understand your preferences based on previous or current site activity, which enables Bet Right to provide you with improved services. Bet Right also uses cookies to help compile aggregate data about site traffic and site interaction so that Bet Right can offer better site experiences and tools in the future.

Bet Right uses cookies to:

• understand and save user's preferences for future visits;
• keep track of advertisements; and
• compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. Bet Right may also use trusted third party services that track this information on Bet Right’s behalf.

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 (personalised advertising and content)

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. Where these services involve disclosure of your Personal Information to overseas recipients, the Overseas Disclosure section of this Directive applies.

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.

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, (eg. 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’s experience significantly but may make your site experience less efficient and some of our services will not function properly.

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.

6. Third Party

6.1. Third party links

Occasionally, at Bet Right’s 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, Bet Right seeks to protect the integrity of the site and welcome any feedback about these sites.

6.2. Third Party Disclosure

We may disclose your Personal Information to the following organisations for the purposes described above (as well as otherwise permitted or required under Australian law):

(i) disclosure to regulators and other government bodies as mandated by Commonwealth, state and territory laws, regulations and licences;

(ii) disclosure to governing bodies (sporting and racing) and equivalent required by legal contracts entered into by us to provide you with betting and wagering information and data services;

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

(iv) professional researchers including those with computing, algorithmic, machine learning, AI, and recommendation engine expertise;

(v) bookmakers and affiliates;

(vi) associated online and mobile publishers ; and

(vii) other data publishers with whom you have a transactional or membership relationship.

Bet Right may contract with professionals, individuals, firms or companies, who are based overseas. Bet Right may disclose your Personal Information to these persons based overseas.

6.3. Overseas Disclosure

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;

- 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). However, in some cases it may not be practicable 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 Directive, you expressly consent to the disclosure of your Personal Information to overseas recipients on the following basis:

- the overseas recipient may not be subject to privacy obligations comparable to the APPs;

- 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 OAIC; and

- Bet Right will not be accountable under the APPs for any act or practice of the overseas recipient 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 and contact us at privacy@betright.com.au.

6.3. Warranty on Third Party

Bet Right does not sell, trade, or otherwise transfer to outside parties your personally identifiable information unless Bet Right provides you with advance notice. This does not include website hosting partners and other parties who assist in operating the website, conducting Bet Right’s business, or servicing you, so long as those parties agree to keep this information confidential. Bet Right may also release your information when it is appropriate to comply with the law, enforce site policies, or protect Bet Right’s or others' rights, property, or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

Before disclosing your Personal Information to any third party, Bet Right will take reasonable steps to ensure that the recipient is subject to appropriate data handling obligations, including ordinarily requiring the recipient to enter into a written agreement that:

- restricts use of your Personal Information to the purposes for which it was disclosed;

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

 - requires the recipient to maintain reasonable security measures appropriate to the sensitivity of the information;

- 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.

7.  Making a Complaint or Enquiry

privacy practices, you have the right to make an inquiry or complaint.

Step 1 — Complain to Us

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

We will acknowledge your complaint within 7 business days and respond within 30 days.

Step 2 — External Complaint

If you are unsatisfied with our response, you may 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.

8.  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, they are 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 website 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 website. 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, punitive or consequential damages, including but not limited to loss of profits, opportunities or information, loss of programs, loss of data, or loss of use of computer or other systems, whether or not advised of the possibility of such damage, arising from your use of, or inability to use, the material on this website.

Furthermore, you may not modify or reproduce in any form, electronic or otherwise, any information on this website, except for personal use, unless you have obtained Bet Right's express written permission.

9.  Changes to this Directive

We may update this Directive from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will update the version number and date at the top of this document and publish the current version on our website. We encourage you to review this Directive periodically.

Version: 1.4

Date: 24.03.2026

Revision History