This policy sets out the principles that Mulpha Australia Limited and its subsidiaries (Mulpha/we/us/our) adopt in the conduct of our business in order to protect your personal information. A number of our subsidiaries engage in activities under other brands. Mulpha is committed to providing you with exceptional service, and this includes protecting your privacy and being open and transparent about what we do with your personal information. In abiding with the Australian Privacy Principles and the Privacy Act 1988 (Cth), we take steps to ensure information about you, is not disclosed to or accessed by unauthorised persons.

This policy explains what kind of information we collect and hold; how and why we collect, hold and use it; and how and to whom we disclose that information. It also provides details about how you may access and seek correction of the personal information that we hold about you, and what you can do if you are not satisfied with how we have dealt with your personal information.

Personal information means any information about an individual from which that person can be reasonably identified. It does not include data where your identity has been removed or which is not associated with or linked to your personal information (anonymous data).

What personal information we obtain on you depends on the reason it is being collected, but may include your:

• Name
• Address
• Email address
• Telephone number
• CCTV image
• Photograph
• Video footage
• Internet Protocol (IP) address (when you visit our website)
• Card details (when making a payment to us)
• Financial details including sort code, bank account number and name on account (if you are providing services to us)
• Cookies (when you visit our website)
• Activity on our website, including the pages you visited, documents downloaded, and searches made, including whether you have accessed third party sites
• Correspondence with us
• WIFI at our centres
• Government identifiers (TFN)
• Nationality
• Country of birth
• Professional memberships
• Employee salary and due diligence data
• Police Checks to satisfy human resources requirements

As part of our recruitment processes for employees and contractors the personal information we obtain depends on the role and requirements but may include:

• Name
• Addresses
• Dates of birth
• Financial information
• Citizenship
• Employment references
• Regulatory accreditation and professional memberships
• Directorships
• Property ownership
• Identification documents.
• Government identifiers (such as TFN)
• Nationality
• Country of birth
• Family court orders
• Police Checks to satisfy human resources requirements .

Generally, we will seek consent from you in writing before we collect your sensitive information.

We only collect personal information about you that is necessary for us to carry on our business functions. The information we collect about you depends upon the nature of our dealings with you. Generally, we only collect personal information from you, unless it is not reasonable or practical to do so in which case, we may also collect personal information about you from third parties.

We may collect personal information which you give us, or that we collect independently, in one of the following ways:

• When you communicate with us by email or phone.
• When you make an enquiry about our properties, products or services, or visit our properties.
• When you access and interact with our website.
• When you access our WIFI.
• When you make a reservation with us or have an event with us.
• When you visit one of our events as a ticket holder or exhibitor.
• When an application is made by you or on your behalf to attend one of our events or take part in one of our activities
• When you have asked to receive information from us (such as event updates and mailing lists)
• When you enter a competition with us
• When you complete surveys that we use for research purposes, although you do not have to respond to them when we send them to you
• When you become a member of one of our clubs or provide your details for our mailing lists.
• When you purchase our services or products online.
• When you propose to provide or provide goods or services to us or our customers.
• When you receive goods or services from us or agree to receive goods or services from us.
• When you make an application to invest with us.
• When you make an application for finance from us.
• When you or another individual is injured during your interaction with us
• When you or another individual makes a complaint or where there has been a threat or damage to personal property.

We may collect information based on how you use our website. We use “cookies” and other data collection methods to collect information on website activity such as the number of visitors, the number of pages viewed and the internet advertisements which bring visitors to our website. This information is collected to analyse and improve our website, marketing campaigns and to record statistics on web traffic.

If you access your account with us online through a secure area of our website, we will collect your personal information using cookies. This is designed to track the use of our website and to allow our customers to effectively access their account information.  This information is collected for security purposes and to protect the integrity of account details.

We collect personal information about you from third parties such as:

• Our service providers. For example, when you make an enquiry about our properties, products or services to our service provider who assists us in providing our products or services to you.
• Booking agents. For example, when you enquire or make a reservation through a third-party booking agent to dine or stay with us, or have an event with us.
• Other goods or service providers, and our clients. For example, when you provide a trade or finance reference as part of entering into an agreement with us and you have agreed for your personal information to be shared with us.
• Your financial advisor, accountant, agent, or third-party intermediaries and you have agreed for your personal information to be shared with us.
• Someone that is appointed as your personal representative, attorney or legal representative.

Third parties to whom you have provided your personal information and consented for that information to be shared with us.

We only collect sensitive information if it is:

• Required by applicable laws or rules.
• Reasonably necessary for one or more of our business functions or activities, and we have your consent.
• Necessary to lessen or prevent a serious threat to life, health or safety.

We only use your personal information for:

• The reasons we collected it, that is where it is reasonably necessary for one or more of our business functions or activities (the primary purpose).
• A related secondary purpose that would be reasonably expected by you.
• The purposes set out in this policy.
• An activity or purpose to which you have consented.

We use your personal information so we can, amongst others:

• Establish and verify your identity.
• Provide, manage and administer the provision of our goods and services to you.
• Process a payment, including credit card payment.
• Assess your application for any financial product or finance (including where you have consented to act as a guarantor).
• Contact you and manage our relationship with you.
• Identify and tell you about other products or services that we think may be of interest to you (unless you tell us not).
• Conduct, manage and improve our business and our customers experience.
• Design, price and administer our products and services.
• Manage our risks and identify and investigate illegal activity, such as fraud, bribery or corruption; and
• Comply with our legal obligations such as under the such as under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act and AML/CTF Rules) and assist government and law enforcement agencies or regulators.

We may also collect, use and exchange your information in other ways where permitted by law.