Provided by: The Punting Superstore Pty Ltd
Previous Version: N/A
Last Update: 01st June 2020
When collecting and processing your personal data, The Punting Superstore Pty Ltd t/a Motzza undertakes to protect and respect your privacy.
Please carefully read what follows to understand our position and practices concerning your personal data and the way in which we process it.
THE DATA THAT WE MAY COLLECT CONCERNING YOU
In the context of our Contract, we may gather and process the following data concerning you:
- Email address Surname and forename
- Phone number
- Phone number
- Skype identifiers
- Website address
- Registration date
- Bank account
- Company name
- Category and target market
HOW DO WE USE YOUR PERSONAL DATA?
- Respect of our contractual obligations: We will use your data to fulfil our obligations stemming from any Contract concluded between you and us, and to provide you with the information and services that you request from us. In the context of the contract and to ensure its proper performance, we will also use your data to inform you of the changes made to our services and /or products and the development of our contractual relationship.
- Legal obligations:As a regulated entity, we are bound to comply with the applicable directives provided by any pertinent regulatory body and we have obligations under applicable legislation, including the law on games of chance and betting, and the legislation to combat money laundering and fraud. We will therefore use your data to conduct appropriate and necessary investigations and to fulfil our legal and regulatory obligations and duties, including to ensure our compliance (if applicable) with:
- the requirements of any applicable law in matters of gambling, betting and games of chance;
- the directives of any competent regulator;
- the requirements of applicable legislation in matters of the prevention of money laundering, fraud, financing of terrorism, corruption, tax evasion, the supply of financial or other services to persons who could be subject to economic or commercial sanctions, including (where applicable) in respect to excluded customers; and
- all other laws, regulations, directives, codes of practice, circulars, ordinances, notifications or requests which could apply;
Legitimate interests: We will also use your data in certain cases on the basis of our legitimate interests, mainly to;
- protect ourselves against fraud and ensure the physical and IT security of our firm;
- ensure the management of any litigation that arises between us or with third parties.
When we use your data on the basis of our legitimate interest, we will conduct a balancing test to weigh up our interests in using your personal data against your interests as a citizen and your rights in application of laws on data protection. The result of this balancing test will determine whether we can use your personal data in the manner described in this confidentiality policy. We will always act in a reasonable way and fully take into account your interests when conducting this balancing test.
HOW LONG WILL WE KEEP YOUR DATA?
When your data is no longer necessary for the aforesaid purposes, we will delete it within the time limits indicated below.
All information will generally be deleted within 10 years as of the date of our last positive interaction with you. We may keep your personal data during a maximum period of 10 years, in order to retain information that we may need for legal and regulatory purposes.
THE SHARING OF YOUR DATA
We may share your personal data with any member of Punting Superstore Pty Ltd, that is to say our subsidiaries, our ultimate parent company and its subsidiaries.
We will only share your data with:
- commercial partners, suppliers and subcontractors for the performance of any contract that we conclude with them or you;
- members of Punting Superstore Pty Ltd , third-party suppliers and service providers for the purposes listed in the section HOW DO WE USE YOUR PERSONAL DATA? above;
- third-party suppliers and service providers insofar as they assist Punting Superstore Pty Ltd in its legal/regulatory obligations, for instance service providers in the combat against money laundering, the prevention of fraud, auditing, etc. ;
- selected third parties so that they may contact you with information on the services that they provide, when you have expressly consented to your personal data being shared for these purposes;
- suppliers of analysis tools and search engines who help us improve and optimise our website and other selected third parties;
- other operators of games of chance, banks, credit card companies, ESP (defined below) and appropriate agencies with the aim of investigating and protecting ourselves against the activities of minors and fraudulent, criminal or suspicious acts (or other activities which we are required to investigate and against which we must protect ourselves in application of the law, regulations or directives) or if we have reasons to believe that you have been involved such activities; and our regulators, bodies responsible for applying the law or preventing fraud and our legal advisers, the courts of law, the services of independent arbitration that may be applicable, sports governing bodies, organisations ensuring the integrity of betting and any other authorised body, with the aim of investigating any real or suspected criminal activity or other regulatory or legal issues, etc.
We will share your personal data with third parties:
- in the event that we contemplate selling or buying a firm or assets, in which case we will disclose your personal data to any vendor or potential buyer of this firm or these assets; in the case of insolvency (for instance bankruptcy or liquidation) of Punting Superstore Pty Ltd, or a person responsible for processing or one of the group’s entities if we, or practically all our assets, are acquired by a third party, in which case the personal data that we hold on our customers will be part of the transferred assets; in order to have respected or to apply the conditions of use of our website; to protect our rights, our assets and our security, and those of our staff, customers or other persons. This includes the exchange of information with other companies and organisations (including, without this list being exhaustive, other gambling operators and the local police or other local bodies in charge of applying the law) for the purpose of the security of staff and customers, prevention of criminality, protection against fraud and reduction in the credit risk; and
- if we have the obligation to disclose or share your personal data to comply with any legal, regulatory or other obligation for the prevention or detection of fraud or criminality.
WHERE DO WE STORE YOUR PERSONAL DATA?
In order to ensure fair and transparent processing, we will adopt, taking into account our processing activities, appropriate procedures for processing personal data, which will include implementing technical and organisational measures taking into account the prejudice that may be suffered, and which correct inaccuracies identified in the processed personal data, in such a way that the risk of errors is minimised and that your personal data is processed fairly and securely.
All the information with which you provide us is stored on our secure servers. If you have given us (or if you have chosen) a password that allows you to access certain parts of our site, you are responsible for the confidentiality of this password. We ask you not to share this password with anyone at all.
Unfortunately, the transmission of information via the Internet is not totally secure. Although we do our best to protect your personal data, we are not able to guarantee the security of your data transmitted to our website; any transmission is at your own risk. When we have received your information, we will use strict procedures and security systems to endeavour to prevent any unauthorised access.
It may happen occasionally that suppliers of services, members of Punting Superstore Pty Ltd and organisations with which we work are located outside the Australia Economic Area in countries that do not have the same standards for protecting personal data as Australia. However, we will always make every reasonable effort to ensure that sufficient measures of protection are in place to protect your personal data. We will also ensure that our service providers conclude compliant processing agreements with us in order to ensure that your personal data is processed in compliance with applicable legislation on data protection.
The laws in matters of personal data protection grant you a certain number of rights in respect to the manner in which we process your personal data. These rights are set out in detail below. You can contact us using the contact details given on our website to exercise one of these rights, and we will reply to any request received from you within 28 working days as of the date of the request.
NUMBER DESCRIPTION OF THE RIGHT
- Right 1 The right to access personal data that we hold concerning you.
- Right 2 The right to ask us to rectify inaccurate personal data that we hold concerning you.
- Right 3 The right to ask us to delete personal data that we hold concerning you. This right only applies when (for instance) we no longer need to use the personal data to achieve the objective for which we collected it, or when you withdraw your consent if we use your personal data on the basis of your consent, or when you oppose the manner in which we process your data (in compliance with right 6 below).
- Right 4 In certain circumstances, the right to limit our processing of the personal data that we hold concerning you. This right only applies when (for instance) you dispute the accuracy of the personal data that we hold or when you have the right to request us to delete the personal data, but prefer that our processing be limited, or when we no longer need to use the personal data to achieve the objective for which we collected it, but you need this data to deal with legal proceedings.
- Right 5 In certain circumstances, the right to receive personal data with which you have provided us, in a widely used, machine-readable structured format. You also have the right to request us to transfer this personal data to another organisation, at your request.
- Right 6 The right for you to oppose the processing of personal data that we hold concerning you when the processing of this data is necessary for the purposes of our legitimate interests, unless we are able to prove that there exist legitimate and compelling reasons for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.
- Right 7 The right not to be subject to a decision based solely on automated processing, including profiling, producing legal effects on you or significantly affecting you in a similar way.
- Right 8 The right to withdraw your consent, when we rely on this for using your personal data (for instance to send you advertisements concerning our products and services).
If have any concerns regarding the processing of your personal data or if you are not satisfied with our reply to any request by you relating to your rights, you also have the right to file a complaint with our control authority: Our Company Solicitor