- (a) the kinds of personal information we collect and hold;
- (b) how we collect and hold your personal information;
- (c) how you may access your personal information held by us and have it corrected;
- (d) how you may complain about the way we deal with your personal information, and how we will deal with your complaint;
- (e) whether we will disclose your personal information to overseas recipients, and if so, the likely location(s) of those recipients.
2. Website use
3. Collection of personal information
Draftstars only collects personal information for purposes which are directly related to its functions or activities, and only when it is necessary for, or directly related to, such purposes.
Opening a Draftstars Account
To open a Draftstars Account, we require the following personal information from you:
- contact details (i.e. name, residential and email address, and telephone number);
- date of birth;
- preferences that you have submitted (i.e. preferred username);
- financial information (i.e. bank account, credit card details); and
- other identity verification information (i.e. driver’s licence number, copy of driver’s licence, occupation, certified copies of personal information).
Allowing you to use our Services
We collect the following activity information from you when you engage with our Website or otherwise use our services:
- information about the devices used to access our products and services;
- the channel from which you accessed the Website;
- your responses to promotions, functions, giveaways and competitions;
- information about your utilisation and activity on our Website; and
- your wagering history and information.
4. Legal requirements
We record all telephone conversations you make with us (including all queries and disputes) for the purpose of security, investigations and for the purpose of complying with our licence requirements and the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth)and the Anti-Money Laundering and Counter-Terrorism Financing Rules 2007 (Cth)(collectively, the AML/CTF Act
We collect, use and disclose personal information of beneficial owners, their agents and connected third parties of our customers for compliance with the AML/CTF Act.
5. Sensitive information
Draftstars will not collect sensitive information such as racial or ethnic origins, political opinions, criminal record, health information, religious and spiritual beliefs and sexual preferences or practices unless required by law (i.e. to maintain the integrity of our products and services and to maintain security).
The AML/CTF Act may require us to collect sensitive information (for example, to verify your identity) and we may collect this from third parties. You will not be informed we have collected the sensitive information under this purpose only.
6. Collection purposes
Draftstars will collect your personal information in order to:
- set-up an account with us and to allow you to access and make use of our Website;
- allow you to participate in the products and services offered, to administer your account;
- maintain our accounts and records;
- identify you as a member for security purposes and to comply with our legal obligations;
- monitor Website usage levels and the quality of the service we provide;
- inform you, from time-to-time, about products and services that we consider may interest you and for related purposes;
- create aggregate data about customers through demographic profiling and statistical analysis of the database for market research and developing our products and services;
- market and advertise Draftstars’ offers and promotions, including conducting research and promotions;
- enable our related bodies corporate to market their products and services directly to you;
- enable third party business partners and sponsors to market their products and services to you from time-to-time; and
- comply with Draftstars’ legal obligations including in relation to customer identity verification and reporting obligations imposed by the AML/CTF Act, its licensing obligations under the Racing and Betting Act 1983 (NT) and other applicable laws for taking appropriate action if Draftstars has reason to suspect that unlawful activity or misconduct of a serious nature has been, is being, or may be engaged in, that relates to our functions and activities.
Telephone calls and betting data relating to users will be recorded and may be actively monitored for the purposes set out above.
7. How will Draftstars collect and hold personal information
Draftstars will ordinarily collect your personal information directly from you, primarily through your use of the website or over the telephone. We may also collect personal information from others, for example our related companies, with whom we partner to offer you a wide range of services and rewards, or our through agents or affiliates whom we engage to undertake marketing activities.
Draftstars may also collect personal information from job applicants, our employees and individuals associated with our business partners and service providers. Usually this information is limited to name and contact details and the other information we need for the purpose of processing a job application and managing our business relationships.
Draftstars will collect your personal information by any of the following methods:
- directly from the individual via telephone, electronic form, Post Office, in person, hard copy form. For example, when you are completing your identify verification process or for a general enquiry;
- from third parties such as related bodies corporate, business partners and affiliates such as Google, credit reporting bodies, the Australian Securities and Investments Commission and other service providers;
- from other third parties including Australian sports / racing controlling bodies to enquire or assess suspiciousactivity on the Website;
- from publicly available sources of information;
- from our records of how you use and access Draftstars’ products and services.
If you choose not to provide certain information about you, we may not be able to provide you with the products or services, or the level of service, with which we pride ourselves.
Draftstars uses “cookies” in order to provide you with a better experience. Cookies are pieces of data sent by a website to your computer and stored on the hard drive. They allow the website to identify and interact with your computer.
Draftstars and its Related Bodies Corporate
We may collect and disclose personal information to our related bodies corporate to:
- comply with the law, regulations and licence conditions applying to them;
- send you marketing material directly;
- for the commercial purposes of our associated entities, including the promotion of certain products and services and making certain products and services available to you; and
- analyse your wagering practices to tailor products and services to you.
How Draftstars will hold your personal information
Draftstars may store your information in hard copy or electronic format, or in storage facilities that we own and operate, or are owned and operated by third party service providers under contract.
8. Dealing with Draftstars anonymously
Where practicable, we will allow you to deal with us on an anonymous basis or using a pseudonym. However, if you do not provide Draftstars with the personal information we need, we may be unable to process your application to become a member, open an account for you, enable you to participate in the full range of services offered by Draftstars, provide you with the services you require, or process your job application.
9. Direct marketing and opting out
When registering an account with Draftstars, you may choose to receive promotional or marketing information from Draftstars (and its related bodies corporate) by selecting the appropriate option on the registration page. By opting-in to receive direct marketing material, Draftstars (and its related bodies corporate), may use your personal information to inform you about products or services or about promotional activities which Draftstars believes may be of interest or of benefit to you. Draftstars (and its related bodies corporate) may do this via email, SMS, MMS, telephone or mail.
If you no longer wish to receive marketing or promotional material from Draftstars at all or in any particular form, you may:
- simply select to opt-out (i.e. unsubscribe) of receiving any further marketing material at the bottom of the page of the marketing communication you have received; or
- contact our Compliance Manager at any time by email to support@Draftstars.com.au or phone on 1800 131 939 with your request with, which we will comply with as soon as practicable.
Note, we may also contact you in relation to the management and administration of your Draftstars account and provide you with service updates or announcements. These communications may occur via any of the modes of contact outlined above. Customers that have elected to opt-out of direct marketing communications will continue to receive service announcements, until such time that the customer informs Draftstars that it does not wish to receive these communications (this includes periods you are no longer using our products and services).
10. Disclosure of personal information
Draftstars only uses and discloses personal information for purposes that are related to the purposes for which we have collected the information, for purposes we have notified you of at the time we collect your information, for purposes we have notified you of at the time we collect the information, for where otherwise required or permitted by law.
For Draftstars members, applicants for membership or individuals we open an account for, this means we mainly use personal information for purposes connected with establishing and administering the membership (including the account) and providing services and products related betting, as outlined above
Draftstars will not share your personal information with other organisations or anyone else unless the disclosure is for one of the purposes outlined above.Accordingly, Draftstars may disclose your personal information to the following third parties:
- an authorised representative;
- Draftstars’ shareholders and commercial partners, including, but not limited to CrownBet, Fox Sports Australia, Crown Resorts and the Australian Football League, for the purposes of offering you a range of products and services;DraftDay Gaming Group Inc and its related bodies corporate (refer below for further information);
- Draftstars’ business partners and sponsors who may have offers of interest for you from time-to-time;
- credit reporting bodies to conduct a verification check or for debt related matters.
- external providers of services we use to operate our business and manage our business systems (i.e. advertising agencies, mailing houses, printers, call centres, IT consultants, market research analyst and providers of payment processing and identify verification services);
- government agencies responsible for enforcing the AML/CTF ACT and Draftstars’ licence obligations;
- Australian sports / racing controlling bodies to assist in their inquiries or notifying such bodies of any betting activity that may be unusual or suspicious and in accordance with agreements between Draftstars and the relevant body or approvals granted by the relevant body; or
- other parties in circumstances where you have provided us with your consent.
Draftstars will take all reasonable steps to ensure that any personal information which Draftstars discloses to a third party is protected by that party in accordance with the Privacy Act and under contractual arrangements.
11. Security of personal information
Draftstars will destroy or permanently de-identify personal information when it is no longer required for any purpose permitted under the APPs, including our legal or operational obligations. Draftstars holds personal information in electronic database owned and operated by Draftstars. Once Draftstars receives your transmission, Draftstars will take reasonable steps to protect your personal information from misuse, loss and unauthorised access, modification and disclosure including by using password protected systems and databases and Secure Socket Layer (“SSL”) technology.
Draftstars’ employees, agents and contractors are required to maintain the confidentiality of members’ personal information.
Draftstars takes reasonable measures to ensure that personal information which it collects is accurate, complete and current and also when it uses and discloses it, that it is relevant, having regard to the purpose for which it is being used or disclosed. We give you the opportunity to correct and update personal information at any time, and may contact you on a periodic basis to seek the most up-to-date information from you. We will correct your personal information if we are satisfied that it is accurate and needs to be corrected.
12. Access and correction of personal information
If a customer (or the beneficial owner, its agent or an authorised third party of our customer) requests access to the personal information (including recorded telephone calls) that Draftstars holds about them, or requests that it changes that personal information, Draftstars will allow access or make the changes unless it considers that there is a sound reason under the Privacy Act or other relevant law to withhold the information. Draftstars will endeavour to correct your Personal Information within 7 days, unless notified otherwise.
We may refuse a request for access in certain circumstances set out in the Privacy Act, including where:
- providing access would be unlawful;
- we are required or authorised to do so by or under an Australian law or court/ tribunal order; or
- where giving access would be likely to prejudice enforcement related activities by or on behalf of an enforcement body.
If we refuse your request or cannot give you access in the manner you have requested, we will do what we can to meet your requirements by other means. If we refuse access to your personal information, we will advise you in writing of the refusal, the reasons for the refusal, and the complaint mechanisms available to you.
If Draftstars does not agree to make requested changes to personal information, the individual may make a statement about the requested changes and Draftstars will attach this to the record.
For further information about how to request access or changes to the personal information held by Draftstars, contact support@Draftstars.com.au (further contact details are below).
13. Overseas disclosures
For the primary purpose of administrating your Draftstars account, allowing you to access our services (which are powered by a software provider based overseas) and compliance with our obligations under the AML/CTF Act, Draftstars will collect from, and disclose Personal Information to, DraftDay Gaming Group Inc (located in the United States of America and its related bodies corporate (located in Ireland, Malta, Romania and Gibraltar) when required for the stated purposes.
Draftstars will only disclose personal information to an overseas recipient if:
- we’ve taken reasonable steps to ensure the recipient does not breach the Privacy Act;
- contractual arrangements are in place to protect the security of your personal information;
- we have your express consent to disclose; or
- the provision of information is required by law or treaty or convention which Australia is a party.
Draftstars takes its obligations pursuant to the Privacy Act seriously. Individuals may complain about a suspected breach of the APPs by Draftstars by submitting your complaint in writing to Draftstars’ Privacy Manager, using the contact details below.
Any complaint should set out in as much detail as possible, all the relevant particulars relating to the complaint, including the suspected reason behind why Draftstars has allegedly breached the APPs.
Upon receiving a written complaint, Draftstars will acknowledge receipt of the complaint in writing within 7 days. Draftstars will investigate the matters described in the complaint and then provide a substantive written response within 28 days from the date the written complaint was received.
If your complaint is not resolved by the Privacy Manager, you can refer it to the Office of the Australian Information Commissioner (www.oaic.gov.au).
15. Contact details
1800 131 939