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 Racing and Wagering Commission of the Northern Territory. 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, and those from other jurisdictions including the General Data Protection Regulation (EU) 2016/679 (GDPR).
You are welcomed to contact us at email: legal@betright.com.au.
2. Privacy
Personal Information is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Personal Information/data under the GDPR refers to any information that can be associated with a specific person and can be used to identify that person, directly or indirectly, in particular by reference to an identifier such as a name, address, e-mail address, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person and other required information you provide.
Please read the Directive carefully 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. For the purposes of the GDPR, Bet Right is the data controller responsible for your Personal Information.
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, gender, sex or preferred identity, or other details to help you with your experience. Bet Right does not collect or process your genetic, physiological, mental, racial or ethnic origin, or cultural Personal Information, political opinions, religious or philosophical beliefs, trade union memberships, data concerning health or data concerning a natural person’s sex life or sexual orientation.
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 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.
You will be given an 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;
(iii) scraped data about you from third parties who publish your data to public domain including discussion forums, social media and other websites; and
(iv) other publicly available data.
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 and harm minimisation) 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 explained in the Rule Book. Further to wagering services contract, 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 fresh 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, use or otherwise surf 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 you, your wants and needs, 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 website/webpages 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, 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, texts messages or other media regarding your order or other products and services including direct marketing;
- to allow bookmakers and affiliates, associated publishers (online and mobile) and other data publishers for which you may be associated with or has a transactional or membership relationship, to use it for operational purposes and, with your consent, marketing and promotional purposes; and
- 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 market segmentation activities.
On this basis, you agree and consent to us using and disclosing your Personal Information.
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.
2.8. Use and disclosure of health information
As a licensed sports bookmaker, Bet Right has obligations to comply with legislation, regulations and licensing requirements with regards to responsible gambling and harm minimisation for gamblers which may require the use and disclosure of your personal health Information and other data.
2.9. Use and disclosure of information – general
We do not share your personal information to third parties outside the Bet Right Group for marketing purposes. But we will share datasets which are anonymised with third parties for the purpose of data analyses towards clients profiling and segmentation aimed at personalised UX and responsible gambling.
We do share your personal data with other companies in the Bet Right Group 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.
Entities with whom your Personal Information and other data are disclosed include:
(i) associates and affiliates of Bet Right;
(ii) professional researchers including those with computing, algorithmic, machine learning, AI and recommendation engine expertise;
(iii) bookmakers and affiliates;
(iv) associated publishers (online and mobile); and
(v) other data publishers.
On this basis, you agree and consent to us disclosing your Personal Information to entities above based in Australia and overseas.
2.10. Retention
We will only retain your Personal Information and other data only for the period of time necessary to fulfill the purposes for which they are collected.
We are required to retain your Personal Information and other data for a period of time even after you are no longer Bet Right’s client. The reasons why we retain your information include:
(i) to comply with legislation, regulations and licensing requirements, eg the AML Act and data protection;
(ii) to proceed with or defend against legal claims in legal proceedings within the relevant limitation periods; and
(iii) to comply with contractual obligations and rights.
2.11. 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.
Please consult the Office of the Australian Information Commissioner (OAIC) at https://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 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 an organisation or agency holds is lost or subjected to unauthorised access or disclosure. For example, when:
(i) a device with a client’s personal information is lost or stolen
(ii) a database with personal information is hacked
(iii) 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.
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 youself, 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 Racing and Wagering Commission of the Northern Territory 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.
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 (like Chrome, Internet Explorer) 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 users experience but may make your site experience less efficient and some of our services will not function properly.
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 affiliates of Bet Right;
(iv) professional researchers including those with computing, algorithmic, machine learning, AI, and recommendation engine expertise;
(v) bookmakers and affiliates;
(vi) associated publishers (online and mobile); and
(vii) other data publishers.
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.
On this basis, you agree and consent to us disclosing your Personal Information to overseas recipients.
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.
7. 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 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 permission.
Version: 1:1
Date: 03.07.2024
Revision History
| Version | Date | Author | Changes |
| 1.0 | 19.12.2020 | LRGC | First version of policy |
| 1.1 | 03.07.2024 | LRGC | Updated references to Racing and Wagering Commission |