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Privacy Policy Australia

1 WHO ARE WE?

Delaware North is part of the international Delaware North Group, with affiliated companies and
operations all around the world (collectively, the “Delaware North Group”).


For the purposes of this Privacy Policy, “Delaware North,” “we,” “us” and “our” refers to Delaware
North Companies International Ltd, Delaware North Companies Australia Pty Ltd, and other
Australian and New Zealand-incorporated companies which are part of the Delaware North Group.These companies include (without limitation) Delaware North Services Pty Ltd, AVS CateringAustralia Pty Limited, Delaware North Lizard Island Pty Ltd, Delaware North Marine Experience Pty Ltd, Delaware North Property Services Pty Ltd, Delaware North Australia Parks & Resorts Pty Ltd, Delaware North Retail Services Pty Ltd, Delaware North Venue Services Pty Ltd, Delaware NorthManagement Services Pty Ltd, Delaware North Food Services Pty Ltd, Delaware North CompaniesNZ Holdings No. 1 Pty Ltd, Delaware North Companies NZ Holdings No. 2 Pty Ltd, Delaware North Australia Leisure & Entertainment Pty Ltd, Delaware North Leisure & Entertainment Queensland Pty Ltd, Delaware North Leisure & Entertainment NSW Pty Ltd, Delaware North Leisure &Entertainment Victoria Pty Ltd, Delaware North Australia Gaming & Entertainment Pty Ltd, Delaware North Northern Territory Gaming & Entertainment Pty Ltd and Delaware North Darwin Casino Pty Ltd.

2 SCOPE AND YOUR CONSENT

This Privacy Policy describes Delaware North’s Personal Information handling practices and applies to each and every individual who uses our Website or our Services, as well as to our employees. In the course of our business we may need to gather and use certain Personal Information about you.This Privacy Policy tells you how we will use and process your Personal Information and the measures we have put in place to ensure its adequate protection. In addition, it explains how you can opt out of certain uses of your Personal Information and what rights and options you have in relation to how we use your Personal Information. References to “you” and “your” mean those individuals using our Website or Services, as well as our employees where applicable.By accepting the terms and conditions when making any booking through our Website or providing us with Personal Information, you will be deemed to have consented to us collecting, using, and disclosing your Personal Information (within and outside Australia) in accordance with this Privacy Policy.


If this Privacy Policy is not acceptable to you, please do not use our Website or use our Services.
Employees who do not agree with how we handle their Personal Information may choose to opt outby contacting us directly.

3 DEFINITIONS

For the purposes of our Privacy Policy:


Australian Privacy Principles means the Australian Privacy Principles set out in Schedule 1 of the
Privacy Act.


GDPR means the General Data Protection Regulation (EU 2016/679).


Personal Information has the meaning given under the Privacy Act, but generally includes
information or an opinion about an identified individual, or an individual who is reasonably
identifiable.


Privacy Act means the Privacy Act 1988 (Cth) including the Australian Privacy Principles and any
amendments to the Privacy Act or Australian Privacy Principles from time to time.


Privacy Policy means this document as amended from time to time.


Related Entities has the same meaning as under the Corporations Act 2001 (Cth).


Sensitive Information has the same meaning as under the Privacy Act, but generally includes
information or opinion (that is also personal information) about a person’s racial or ethnic origin,
political opinions, religion, philosophical beliefs, sexual preferences or practices, membership of a
political association, professional/trade association or trade union, or an individual’s criminal
record, health information, genetic information, biometric information (used for verification or
identification) and biometric templates.


Services means the services provided by us, including hospitality and food service management,
resort management and travel hospitality services.


Social Networking Sites means the social networking sites operated or utilised by us, including
Facebook, YouTube and Twitter.


Spam Act means the Spam Act 2003 (Cth).


Website means all websites operated or utilized by us, including (without
limitation): www.delawarenorth.com, www.lizardisland.com.au, www.mindilbeachcasinoresort.com.au, www.thelodgeblacktown.com.au


The meaning of any general language is not restricted by any accompanying example and the words
‘includes”, “including”, “such as”, “for example” or similar words are not words of limitation.

4 WHAT PERSONAL INFORMATION DO WE COLLECT AND WHY DO WE NEED IT?

4.1     General

To provide you with our Services, we need to collect Personal Information. We only collect Personal Information to the extent that it is reasonably necessary for one or more of our functions or activities and in accordance with this Privacy Policy. We review our data collection, storage, and processing practices to ensure that we only collect, store, and process the Personal Information needed in connection with the uses set out in this Privacy Policy.

If you do not provide us with your Personal Information as requested, or if the information is
incomplete or inaccurate, we may not be able to provide our Services to you or the standard and
quality of those Services may be compromised.

Depending on the nature of the Services we provide to you, the Personal Information we collect
may include, without limitation:

  • your name, email address, telephone numbers and address;
  • Sensitive Information, for example, if you advise us of any allergies, disabilities or medical
    issues;
  • Information you provide when you apply for a position with us;
  • bank and credit card details (including expiry dates);
  • information on your employer or a professional group to which you belong (e.g. you may
    disclose that to obtain a discount available to members of that group);
  • details of family members (e.g. if they are travelling with you);
  • your username and password if you register an account on our Website;
  • information associated with your Internet Protocol address;
  • your personal interests and preferred vacation/leisure destinations; and
  • information you provide if you book a special package at one of our resorts (e.g. a wedding,
    honeymoon, couples or ‘babymoon’ package).

4.2     Surveys

From time to time we may post surveys on our Website. The surveys may request demographic
information (such as age range, gender, areas of interest and familiarity with us or our products and services) and customer feedback. Participation in these requests is completely voluntary. With
each request, you will have the choice of whether or not to disclose information. Such survey
information will be used to improve the overall experience on our Websites.

5 HOW DO WE COLLECT THE PERSONAL INFORMATION?

5.1     General

We aim to collect Personal Information directly from you, unless it is unreasonable or impracticable to do so. Generally, we collect your Personal Information when you complete and submit a form, make inquiries or book with us. We may also collect Personal Information, without limitation:

  • from other members of the Delaware North Group;
  • from our service providers, including travel agents;
  • from debt collection agencies if you default in a payment to us;
  • through our Website and other Social Networking Sites;
  • from third parties;
  • from publicly available sources of information;
  • when we are required to do so by law; or
  • when you enter a competition or promotion with us, participate in a survey or register to
    receive information on us or any of our Services.

If at any time you supply Personal Information to us about any other person (e.g. another person
traveling with you or a photo you post on a Social Networking Site), you represent (and we accept
that information on the basis) that:

  1. without us taking any further steps as required by the Privacy Act or the GDPR, we may collect, use and disclose such Personal Information for the purposes set out in this Privacy Policy; and 
  2. you are authorized to provide us with such Personal Information and that the relevant person has consented to the disclosure to us.

5.2     Our Website

We collect aggregate information about you and your use of our Website whenever you visit us
online. This includes various forms of ‘click stream’ information, e.g. entry and exit points for our
Website, your IP address, site traffic statistics, page views, impressions, operating system and
browser type.


We also use third-party software that tracks access to our Website from affiliated websites and
purchases that result from this access. This aggregate information generally will not identify you.


We may collect, compile, store, publish, promote, report, sell, or otherwise disclose or use any and
all aggregated or de-identified information that does not contain Personal Information.

5.3     Job applications

If you apply online for a position with us, we will collect Personal Information from your resume,
accompanying application documentation and during any other parts of the recruitment process.
The Personal Information will be used only for considering your application for the posted position
(or other relevant positions). If you are successful, the information you provide (including Personal
Information) will form part of your employment records.

5.4     CCTV and other imaging

For security purposes, we have CCTV cameras and other similar imaging equipment in some of our locations and your image may be recorded. By entering one of these locations, you consent to us recording your image.

6 HOW DO WE USE YOUR PERSONAL INFORMATION?

6.1 Usage of Personal Information

In addition to any other purposes set out in this Privacy Policy, we may use the Personal Information we collect to:

  • process your inquiries;
  • provide our Services and other services, including the use of a third party service provider;
  • comply with our contractual and other legal obligations;
  • process payments;
  • process an application for a position with us;
  • respond to medical emergencies;
  • develop and improve our Services;
  • better understand the people that have an interest in our products and services so that we
    can identify others that might have similar interests;
  • share your information with vendors, partner entities, and others who help us operate our
    business or provide services on our behalf, including the production or transmission of
    marketing materials;
  • comply with our contractual and legal obligations and to protect and enforce our legal
    rights;
  • verify your identify and respond to your correspondence when you submit comments,
    questions or suggestions to our customer service department;
  • protect and defend our, or our employees’, users’ and clients’ rights or property including
    against fraudulent or unlawful use of our Website or Social Networking Sites;
  • to create a convenient and easy-to-use online reservation service or shopping process
    including an online “shopping cart” that allows you to track selected services or products
    and proceed through purchase; and
  • advise you of additional services, offers, or information which may be of interest to you.

6.2 Employee Personal Information: Collection, Use, and Disclosure

We collect, keep and handle employee personal information including contact details to enable us
to properly manage our business affairs and the employment of team members.
The purpose of collecting, keeping and handling employee contact details including your name and
email address is primarily to allow us to communicate with you as part of our engagement of you as an employee.


We collect and hold employee personal information including:

  • contact details such as your name and email address;
  • employee record information such as employee identification numbers;
  • information you provide to us at our request; and
  • when you use our website, your domain name, email address and information on what
    pages you access.

7 DISCLOSING PERSONAL INFORMATION

We will not disclose your Personal Information for a purpose other than those connected with the
primary purpose of collection, as set out in this Privacy Policy. Such purposes may include
disclosing your Personal Information to third parties in certain circumstances as follows:

  • if you agree to the disclosure;
  • for the purpose for which it was collected, e.g. to provide you with Services;
  • where you would reasonably be expected to consent to information of that kind being
    passed to a third party;
  • where disclosure is required or permitted by law, by court order or to investigate suspected
    fraud or other unlawful activity;
  • where it is required to be disclosed for audit purposes;
  • to the Delaware North Group for our internal business requirements;
  • as is necessary to process credit card payments or other purchasing or delivery systems;
  • if disclosure will prevent or lessen a serious or imminent threat to someone’s life or health;
  • in conjunction with the sale to a third party of a Delaware North Group entity or a portion of
    our assets;
  • where we believe disclosure is reasonably necessary for one or more enforcement related
    activities conducted by, or on behalf of, an enforcement body; and
  • disclosure of personal information about employees, including names and email
    addresses, to third-party service providers who may collect, hold, use, and disclose
    personal information of employees, including names and email addresses, in the provision
    of services to us. These services may include third-party service providers offering and
    providing employees with benefits and incentives via direct email correspondence with
    employees.

If you do not wish to receive direct email correspondence from third-party providers to offer or
provide you with employee benefits and incentives, you can elect not to, or opt out at any time to,
receiving such correspondence by contacting Human Resources with such a request. If you elect to
not, or opt out of, receiving this correspondence, then we may no longer be able to offer employees
benefits and incentives.

8 MARKETING

8.1     General

We do not use Sensitive Information for marketing purposes.
We may use and disclose our Personal Information (other than Sensitive Information) to provide you with information on offers, products and services offered by the Delaware North Group and you expressly consent to us doing so. We may also provide you with information on other products and services offered by Delaware North Group, its partners or affiliates.


You may elect not to receive direct marketing communications from us by following the opt out
instructions below. Please note that even if you have requested not to receive further direct
marketing communications, we may nevertheless continue to provide you with information about
changes to our terms and conditions for the supply of goods or services, questionnaires and other
factual information, as permitted under the Privacy Act and Spam Act.

8.2     Tracking Tools

‘Cookies’ are pieces of information stored within your computer’s or device’s internet browser that
automatically identify your browser to our server whenever you interact with our Website. We use
cookies to help us understand the content that you are shown while visiting our Website. We may
combine information which we obtain through the use of cookies with other information, including a unique identifier we have assigned to you, with information we obtain from third party sources.


We use browser-based cookies, users’ IP addresses and other technologies such as ‘pixel tags’,
‘web beacons,’ ‘clear GIFs’ or similar technologies to help us and third parties obtain information
about your visits to our Website, deliver online and mobile ads and content for us and others
specific to your interests, process your purchases or requests, or to analyse your visiting patterns,
measure the effectiveness of our and others’ advertising, monitor traffic patterns on our Website,
and to optimize and enhance your online experience on our Website.


You may customize your browser settings to notify you when a cookie is sent or to disable cookies
altogether. The ‘Help’ feature on your browser should include instructions on how to make these
adjustments.


If you block or otherwise disable cookies, certain features on our Website may not function properly
and you will not be able to hold selections in a shopping cart when you leave our Website without
checking out, or use any of our Services that require you to sign in. Some of the tracking we have
described may continue even if you disable or block cookies.

8.3     Interest-Based Online Ads

From time to time we may engage in interest-based advertising provided by third party vendors to
deliver advertisements and personalized content that may be of interest to you. Ads may be
delivered to you based on your online or mobile behaviour (on our Website and other websites),
your search activity, your geographic location or other information, not on the basis of the Personal
Information you have provided to us. For example, if you make a reservation on our Website, you
may later see our ad on another website or on mobile platforms. You may also see third-party ads
on our Website, other websites, or mobile apps, based on your visits to and activities on our
Website, other websites and mobile apps.

More information on interest-based advertising and opting out is available at https://www.aboutads.info

8.4     Opting out

If at any time you no longer wish to receive any additional marketing or survey material from us or
do not want your information disclosed for direct marketing or survey purposes, contact our Privacy Officer using the details in paragraph 15 below and we will remove your details from our marketing database.

9 STORAGE AND DISCLOSURE OF PERSONAL INFORMATION OFF-SHORE

As we are an international organisation, Personal Information you provide to us may be stored on
Delaware North Group members’ and/or its vendors’ servers in countries other than the jurisdiction in which your Personal Information was collected.


If you access another Delaware North website or a partner or service website (e.g. accommodation
bookings, airline) from our Website, you may be transferring to another country and to a website
over which we have no control and take no responsibility. If you provide Personal Information using another Delaware North website or a service website, you do so subject to the privacy laws (if any)in that jurisdiction.


Similarly, if you request us to assist you with other goods or services, we may disclose your
Personal Information to our agents, contractors, service providers and program partners who are
located overseas when arranging or making inquiries in respect of those goods or services.

While Delaware North has privacy rules in place to protect your Personal Information, the overseas recipient may not be subject to privacy obligations or to any principles similar to the Privacy Act or the Australian Privacy Principles. It is possible that information will be transferred to a jurisdiction where you will not be able to seek redress under the Privacy Act and that does not have an equivalent level of data protection as Australia. The overseas recipient may also be subject to a foreign law which could compel disclosure of Personal Information to a third party, for example, an overseas authority.


We will not be accountable for how these overseas recipients handle your personal information. By
providing your personal information to us, you consent to our disclosure of your Personal
Information to these overseas recipients.


If you have any concerns regarding the transfer of your personal information overseas, or if at any
time you wish to withdraw your consent, please contact our Privacy Officer using the details in
paragraph 15 below. However, please note that if you withdraw your consent we may not be able to
provide the Services you have requested in whole or in part or those Services may be compromised
or otherwise not function properly.

10 CONSIDERATIONS WHEN YOU SEND INFORMATION TO US ELECTRONICALLY

While we take such steps as are reasonable in the circumstances to protect your Personal
Information from misuse, loss, unauthorised access, modification or disclosure, including investing
in security software, no data transfer over the internet is 100% secure.


The open nature of the internet is such that information exchanged via the internet may be
accessed and used by people other than those for whom the data is intended. If you send us any
information, including (without limitation) Personal Information, it is sent at your own risk.


Please be aware that we provide links to third-party websites as a service to our users, and that we
are not responsible for the content or information collection practices of those pages. Please note
that these websites’ privacy policies may differ from our Privacy Policy. We encourage you to review and understand their privacy practices before providing them with information.


Similarly, if you access a partner or service website (e.g. hotel, airline) from our Website, you do so
and provide Personal Information in accordance with the terms and conditions, and the privacy
policy, under which the provider of that website operates.

11 CONSIDERATIONS WHEN YOU PARTICIPATE IN ON-LINE FORUMS

Our Website may have chat rooms, discussion boards, online forums and other interactive
technologies that allow individual comments and messages to be tied to a user’s name or e-mail
address.


Any information you post in such forums is public information and Delaware North cannot control what use third parties may make of Personal Information you share in such forums. You should exercise caution before disclosing any Personal Information on on-line forums.

12 EMPLOYEE BIOMETRIC DATA COLLECTION

We may collect, hold and handle your biometric information through finger vein scanning for the
purpose of authenticating your identity.


The purpose of collecting, keeping and handling your biometric information is primarily to enable
access to and exit from our buildings (and the locations at which our employees work) and to
capture your start and finishing times for time-keeping and payroll purposes. We will only collect,
keep and handle your biometric information provided with your consent for this purpose.


You may object, or revoke consent at any time, to the collection, keeping or handling of your
biometric information for the purpose of identity authentication by contacting Human Resources. If you object, or revoke consent, to the collection, keeping or handling of your biometric information for the purpose of identity authentication, then we may use other employee personal information, such as your employee identification number and your password for this purpose

13 SECURITY

We endeavour to keep our information systems and files secured from unauthorised access. Our
procedures to securely store Personal Information include electronic and physical security
measures, staff training and use of password protection software.


In the event of a security breach leading to accidental loss, disclosure or access to your Personal
Information, we will comply with all our Privacy Act obligations including notifying you of such
breach where required by law to do so.


When the Personal Information we collect is no longer required, we will remove or de-identify the
Personal Information as soon as reasonably possible. We may, however, retain Personal
Information for as long as is necessary to comply with any applicable law, for the prevention of
fraud, for insurance and governance purposes, in our IT back-up, for the collection of any monies
owed and to resolve disputes.

14 YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION

You may:

  • withdraw any consents given in relation to the handling by us of your Personal Information;
  • request access to your Personal Information;
  • request that we correct Personal Information that is inaccurate or out of date; or
  • request that we delete certain Personal Information,

by contacting our Privacy Officer using the details in paragraph 15 below. We will take reasonable
steps, consistent with our obligations under the Privacy Act and, where relevant, the GDPR, to
correct or delete that information if you so request. For security purposes, before we provide you
with any Personal Information, we will ask you to provide evidence of your identity.
You may request the source of any Personal Information we collect from a third party. We will
provide this at no cost, unless under the Privacy Act or other law there is a reason for this
information being withheld.
If you are located in a European Union Member State in which we offer goods or services, to the
extent we are subject to the GDPR, you may request that we transfer your Personal Information to
another organization.
If there is a reason under the Privacy Act or other law for us not to provide you with any of your
Personal Information, we will give you a written notice of refusal setting out the reasons for the
refusal (except to the extent it would be unreasonable or unlawful to do so) and advise you of the
mechanisms available to you to complain about the refusal.

15 CHANGES TO OUR PRIVACY POLICY

This document sets out our current Privacy Policy, last updated 30 December 2019.
We may change or update parts of this Privacy Policy in order to maintain our compliance with
applicable law and regulation or following an update to our internal practices. We will do this by
updating this Privacy Policy on https://www.delawarenorth.com/privacy-au/. You will not
necessarily be directly notified of such a change. Therefore, please ensure that you regularly check
this Privacy Policy so you are fully aware of any changes or updates.

16 CONTACT INFORMATION

16.1     When to contact us

You can contact us to:

  • withdraw any consents given in relation to the handling by us of your Personal Information;
  • request access to Your Personal Information;
  • request that we correct Personal Information that is inaccurate or out of date; or
  • request that we delete certain Personal Information

You should also contact us immediately if you believe:

  • someone has gained unauthorised access to your Personal Information;
  • your username or password have been compromised (in which case you should also
    immediately change your password);
  • you have a complaint in respect to the way we are dealing with your Personal Information;
    or
  • you believe we have breached our privacy obligations or your privacy rights in any way.

16.2     Contact details

If you would like further information on our Privacy Policy or if you have any concerns or complaints about the protection of the Personal Information you have given to us or that we have collected from others, please contact us by contacting our Privacy Officer at:

Attention: The Privacy Officer
Mail: Level 5, 380 Docklands Drive, Docklands VIC 3008
Email: pwitchen@delawarenorth.com

More information about our rights and our obligations in respect to privacy and information on
making a privacy complaint are available from the Office of the Australian Information
Commissioner at:

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