1. Introduction
This Privacy Policy (Privacy Policy or Policy) outlines how your information is collected, used and
disclosed when you access or use our Website and Services as defined in our website terms and
conditions (Terms). This information is collected, used and disclosed in accordance with the Privacy
Act 1988 (Cth) (Privacy Act).
This Privacy Policy is incorporated by reference into our Terms. Any capitalised terms not defined in
this Policy are defined in the Terms. You agree to comply with all Terms when accessing or using our
Website and Services, including this Privacy Policy.
Our payment processing is handled by Stripe. The Stripe Privacy Policy applies in relation to any
Personal Information collected, stored and processed on Stripe servers. We may also use this Personal
Information for the purposes as set out in this Policy and in accordance with the terms set out in this
Policy.
2. What information do we collect and how is it collected?
We collect Personal Information, as defined in the Privacy Act (including Sensitive Information as
defined in the Privacy Act), when you access or use our Website and Services.
2.1. Personal Information provided by you
We collect information that you provide to us via use of our Website and Services as well as through
any other means used to contact us.
The kinds of Personal Information we collect include your contact information such as your name, email
address, address, date of birth, account password/login credentials, membership tier, purchase history,
referral data and phone or mobile number.
We reserve the right to maintain, store and use any information or data where we reasonably believe
that such action is required to comply with any legal or regulatory obligations, to prevent criminal or
other unlawful activity whether immediate or in the future, or where we have a legitimate business
reason to do so, including collection of amounts owed, resolving disputes, enforcing our Terms or for
record keeping integrity.
2.2. Automatically collected Personal Information
We automatically record information from your device and its software when you access our Website
and Services, including your IP address, browser and device type, internet service provider, mobile
phone carrier, platform type, the website from which you came and the website to which you are going
when you leave our Website, date and time stamp and cookies that may uniquely identify your browser
or account.
When accessing our Website or Services using a mobile device, we may also receive and collect
identification numbers associated with your device, mobile carrier, device type and manufacturer, and,
if enabled, geographical location data (including GPS). Please note that some of the information we
collect, for example an IP address, can sometimes be used to approximate a device’s location.
2.3. Personal Information collected via cookies
Our Website may use small pieces of data called cookies to identify a user who engages with our
Website and to compile records of a user’s history of engaging with our Website. Cookies are stored
by a users’ browser while the user browses a website. Cookies do not usually contain information that
personally identifies a person, but each time the user visits the website, the browser sends the cookie
data back to the server to notify the system of the user’s previous activity. If you wish to disable cookies,
you may do so through your browser settings, however, please be aware that if you choose to do this,
some functionality of our Website will not be available to you.
The Stripe platform is governed by its own Cookie Policy. We bear no responsibility for how Stripe uses
your data for cookies. If you are concerned with any use and storage of your data for cookies by Stripe,
please contact Stripe Support directly.
2.4. Personal Information collected via Google Analytics
We use Google Analytics, which allows us to anonymously track the use of our Website and Services
by recording the number of users who have visited, the number of pages viewed, navigation patterns,
what systems users have and the date and time of visits through cookies. This information is collected
for statistical purposes only and cannot be used to identify you.
We may use a range of services and functions offered by Google Analytics. We also use Google
Analytics to partner with third parties and advertise online. Our third-party partner may use technologies
such as cookies and third-party Tracking Technologies to gather information about your activities on
our Website and other sites in order to provide you advertising based on your browsing activities and
interests.
Please see this link for how your data is collected and this link Google Analytics data tracking.
2.5. Personal Information collected via Meta Pixels
We may use Meta Pixel (formerly Facebook Pixel). Meta Pixel collects data through cookies about
actions you make on our Website, such as viewing a page or clicking on a specific link. This helps us
track conversions from Facebook advertisements, optimise advertisements for users, and build targeted
audiences for advertisements. See clause 2.3 above for more information about our use of cookies.
We may use a range of services and functions offered by Meta Business Tools. Please note we are not
liable for the way Meta uses your information and it is your responsibility to familiarise yourself with the
Meta terms. You can access Meta Business Tools Terms here.
2.6. Third Party Payment Processor
We use third party payment processors and gateways to process payments made to us in the provision
of our Services. All Personal Information, including any financial information such as credit card
numbers, is collected and used directly by our third party payment processors and gateways as set out
on our Website, whose use of your personal information is governed by their own terms and conditions
and privacy policy. We do not store or retain any sensitive financial/billing information (being credit card
numbers, bank account details, etc.), obtained in connection with processing such payments.
2.7. Anonymity and the use of pseudonyms
When we collect your Personal Information, as far as reasonably practicable, you are permitted to
interact and/or contact us anonymously or by using a pseudonym except where:
(a) we are required or authorised by a law or a court or tribunal order to deal with identified individuals;
or
(b) it is impracticable for us to deal with individuals who have not identified themselves.
3. For what purposes do we collect and use Personal
Information?
3.1. Use of Personal Information
We collect your Personal Information as outlined in this Privacy Policy for the purposes described below:
(a) for provision of the Services which shall include without limitation fulfilling your Orders;
(b) for communication with you and to provide messaging and/or communications to you in association
with the functions and features of the Website;
(c) for communicating to you any announcements and updates, updated terms, conditions and policies,
security alerts, technical notices, support and administrative messages;
(d) for announcing the winner of our draw via social media;
(e) to verify an entrants age to determine trade promotion eligibility;
(f) for analysis, monitoring, development and improvement of our Website and Services, including
other products or services;
(g) for security purposes, including to protect the Website and our property from abuse, fraud,
malicious, unauthorised access or potentially illegal activities, and to protect our rights, safety and
property and that of our other users;
(h) for sending marketing communications to you, including notifying you of promotional or advertising
offers, contests and rewards, upcoming events and other news about products and services offered
by us and use of our Website and Services;
(i) to comply with relevant laws and regulations where applicable; and
(j) for the performance of other functions described at the time of collection or as consented to in
relation to our Website and Services.
4. How do we store and protect your information?
4.1. Storage of Personal Information
We take reasonable steps to protect your Personal Information in accordance with this Privacy Policy.
The Personal Information we collect from you is transferred and stored electronically via a secured SSL
connection, in secured Stripe servers, subject to change as required by Stripe (if such information is
held on the Stripe system) or in password-protected servers located worldwide in locations such as
Canada, New Zealand, United States, United Kingdom, Singapore, Ireland, Germany, France,
Netherlands, Sweden, Denmark, Finland, Belgium, Italy, Spain, Portugal, Norway, Czech Republic,
Austria, Switzerland, Malaysia and Australia. You agree and consent to us storing your Personal
Information on such servers.
4.2. Who can access your Personal Information?
Your Personal Information is accessible to our employees, contractors and our third-party service
providers such as our Website host and technical support providers. We may also store your Personal
Information in password-protected email databases for the purpose of sending out communications and
marketing emails in accordance with this Privacy Policy.
Please note that no method of electronic transmission or storage is 100% secure and we cannot
guarantee the absolute security of your Personal Information. Transmission of Personal Information
over the Internet is at your own risk, and you should only enter, or instruct the entering of, Personal
Information to the Website within a secure environment. It is your responsibility to ensure that you keep
your Personal Information safe, including keeping your software up to date to prevent security breaches.
We reserve the right to maintain and store any information or data where, we reasonably believe, in our
sole discretion, that such action is required to comply with any legal or regulatory obligations, to prevent
criminal or other unlawful activity whether immediate or in the future, or where we have a legitimate
business reason to do so, including collection of amounts owed, resolving disputes, enforcing our Terms
or for record keeping integrity.
We destroy or de-identify your Personal Information when it is no longer needed for the purposes
outlined in this Policy, subject to our legal obligations to retain certain records for longer periods under
applicable laws. However, we may also be required to keep some of your personal information for
specified periods of time, for example under certain laws relating to corporations, money laundering,
and financial reporting legislation.
5. To whom your Personal Information is disclosed?
Your Personal Information may be disclosed to individuals and companies, for the purposes described
in this Policy, as outlined below:
5.1. Prize Hub Rewards Club Pty Ltd and Related Bodies Corporate
Your Personal Information may be accessed by us, including our directors, employees, officers and
contractors. You consent to us providing your Personal Information, including Sensitive Information to
our Related Bodies Corporate (as defined in the Corporations Act 2001 (Cth)).
5.2. Parties required by law
Your Personal Information may be disclosed by us to any party to whom we are required by law to
provide your Personal Information and to any party to whom disclosure is permitted under the Australian
Privacy Principles, or where we reasonably believe that disclosure is required to comply with any court
orders, subpoenas, or other legal process or investigation including by tax authorities, if such disclosure
is required by law. Where possible and appropriate, we will notify you if we are required by law to
disclose your Personal Information.
5.3. Direct marketing
You agree and expressly and indefinitely consent to us using or disclosing Personal Information (other
than Sensitive Information) to keep you informed about our products and services and other products
and services that we consider may be of interest to you. For this purpose, disclosure may be made to
our third-party service providers. We may communicate with you via phone, email, social media, SMS,
or regular mail. If you have indicated a preference for a method of communication, we will endeavour
to use that method wherever practical to do so.
You can opt-out of direct marketing communication activities undertaken by us at any time by clicking
the “unsubscribe” or “opt-out” link on email communications from us, replying ‘Stop’ to a promotional
SMS or by contacting us by phone or email.
5.4. Other third parties
We may share your Personal Information with third parties if it is reasonably related to the provision of
our Services. The third parties that we may share your Personal Information with includes delivery
partners, consultants, contractors, credit agencies, debt collection agencies, RandomDraws.com,
Affiliate WP, Beny and other service providers that perform services on our behalf. Such services we
procure may include fulfilling our Orders, identifying and disseminating advertisements, enforcement of
our Terms, providing fraud detection and prevention services, processing payments or providing
analytics services. We may also share your Personal Information with our business partners who offer
goods or services to you jointly with us (for example, contests or promotions).
We may share your Personal Information where we have reason to believe that doing so is necessary
to identify, contact or bring legal action against anyone damaging, injuring, or interfering (intentionally
or unintentionally) with our rights or property, users, or anyone else who could be harmed by such
activities.
We may also share your Personal Information with third parties with your consent in a separate
agreement, in connection with any company transaction (such as a merger, sale of assets or shares,
reorganisation, financing, change of control or acquisition of all or a portion of our business by another
company or third party) or in the event of bankruptcy, dissolution, divestiture or any related or similar
proceedings.
Note that we reserve the right to share your Personal Information with other third parties where, in our
sole discretion, it is required to:
(a) investigate and defend ourselves against any third party claims or allegations;
(b) protect against harm to the rights, property or safety of us, our users or the public as required or
permitted by law; and
(c) detect, prevent or otherwise address criminal (including fraud or stalking), security or technical
issues.
5.5. Overseas disclosure
Please note that some of the parties listed above to whom your Personal Information may be disclosed,
may be located overseas, including countries such as Malaysia, Singapore, and the United States.
We use reasonable steps to ensure that these parties are either governed by substantially similar,
accessible and enforceable laws to the Australian Privacy Principles or adhere to the Australian Privacy
Principles, however to the maximum extent permitted by law, we are not liable for the privacy practices
of such parties.
Please note that the transfer of your Personal Information to such overseas parties may pose risks to
the security of your Personal Information as these countries may not have been issued with an
adequacy decision as set out in the GDPR (if applicable) or have appropriate safeguards in place,
however by providing your Personal Information to us, you acknowledge and consent to disclosure of
Personal Information to such overseas recipients.
6. Third party websites and social media
Our Website may, from time to time, contain links to and from websites which are owned or operated
by other parties. You acknowledge and agree that we have no control over, and shall not be liable for,
the privacy practices or content of these third party websites and we do not make any representation
about the privacy practices of, any third-party websites, whether or not linked from or transferred from
our Website. You are responsible for checking the privacy policy of any such third party websites and
applications so that you can be informed of how they will handle Personal Information.
We run pages on a number of social media platforms, including Facebook, Instagram, X (formerly
Twitter), LinkedIn, YouTube and TikTok (Social Media Platforms). By accessing, interacting with and
using our social media pages, you agree to the terms and privacy policy of those Social Media
Platforms. You acknowledge and agree that these Social Media Platforms may collect your information
and that the privacy practices of those Social Media Platforms are not controlled by us and that we hold
no responsibility for such privacy practices.
Social Media Platforms also allow public access to your public social media profile, which may include
your username, age range, country/language, list of friends or other information that you make publicly
available, and you understand that such information may therefore be accessible by us if you interact
with its social media pages.
We may from time to time, have access to statistics regarding the number of views, navigation patterns,
posts that you like, comment on or share and any user interactions with our social media pages and
may use such information for the purpose of its marketing and promotion strategies.
7. How can you access or update your Personal Information?
At any time, you may request access to Personal Information we hold about you. We may refuse to
provide access if the law allows us to do so, in which case we will provide reasons for our decision as
required by law.
We take reasonable steps to keep your Personal Information accurate, complete and up to date. If, at
any time, you discover that information held about you is incorrect, you may contact us to have the
information deleted or corrected.
You may request access to the information we hold about you, or request that we delete, update or
correct any Personal Information we hold about you, by setting out your request in writing and sending
it to us in accordance with paragraph 10.
We will process your request as soon as reasonably practicable, provided we are not otherwise
prevented from doing so on legal grounds. If we are unable to meet your request, we will let you know
why.
8. How can you make a complaint about our privacy
practices?
You may submit a written complaint about how we handle your Personal Information to our Privacy
Officer via the details below. If you are not satisfied with our handling of your complaint or we have not
replied to you within a reasonable period of time, then you are entitled to make a complaint to the Office
of the Australian Information Commissioner or, if you are in the EU, a data protection authority or
supervisory authority.
9. Amendments
We reserve the right to amend this Privacy Policy from time to time with reasonable notice to you. While
we endeavour to notify you as soon as reasonably possible of any changes to our Policies by email or
by a notice on our Website, it is your responsibility to keep up to date with any changes or amendments
by checking this page prior to using our Website and Services. This page contains our most accurate
and up to date version of our Privacy Policy.
10. Contact us
All requests for access or corrections to your Personal Information and complaints should be directed
to our Privacy Officer. If submitting a complaint, please provide our Privacy Officer with full details of
your complaint and any supporting documentation:
(a) by contact form at www.prizehubrc.com;
(b) by e-mail at support@prizehubrc.com, or
(c) by letter to The Privacy Officer, 14 The Strand, Colonel Light Gardens SA 5041.
If you are not satisfied with our handling of your complaint or we have not replied to you within a
reasonable period of time, then you are entitled to make a complaint to the Office of the Australian
Information Commissioner.
