Privacy Policy


Introduction

Federal Group operates in the tourism and leisure industry and is recognised as Tasmania’s leading tourism, entertainment, accommodation and gambling services provider.

Protecting your privacy and the confidentiality of your personal information is fundamental to the way Federal Group does business.

Federal Group has a long history of handling personal information, including sensitive information, confidentially.  We value the ongoing trust you have in us to protect your privacy.

This Privacy Policy explains how Federal Group will manage and protect your personal information, including information that Federal Group collects during the course of providing a product or service to you and the information Federal Group holds after your product or service is terminated (where we are required to hold this information or it is necessary for our functions).

This Privacy Policy contains information about how you can access the information Federal Group holds about you, how you can ask Federal Group to correct your information, and how you can make a complaint if you have concerns about how Federal Group has managed your information.

Which Federal Group businesses does this Policy cover?

At the time of publication the Group consists of the following businesses each of which are bound by this Policy:

The Federal Hotels P/L

(ABN 45 004 108 249), trading as:

  • Federal Group, and
  • TixTas

Australian National Hotels P/L

(ABN 79 009 477 552), trading as:

  • Wrest Point Hotel Casino, and
  • Network Gaming

Tasmanian Country Club-Casino P/L

(ABN 25 009 516 189), trading as:

  • Country Club Tasmania,
  • Country Club Casino, and
  • Country Club Villas

Vantage Hotel Group P/L

(ABN 95 087 546 245), trading as:

  • 9/11 Bottleshops
  • Gasworks Cellar Door, Hobart
  • Brooker Inn, Lutana
  • Claremont Hotel, Claremont
  • Derwent Tavern, Bridgewater
  • Elwick Hotel, Glenorchy
  • Furners Hotel, Ulverstone
  • Hotel Federal, Wynyard
  • Hotel Tasmania, Launceston
  • Hotel Valern, Moonah
  • Mackeys Hotel, Latrobe
  • Molly Malones, Devonport
  • Newstead Hotel, Launceston; and
  • Waterfront Hotel, Bellerive

Federal East Coast Holdings P/L

(ABN 23 099 918 715) trading as:

  • Saffire Freycinet

Halsata P/L

(ABN 65 120 619 123) trading as:

  • The Henry Jones Art Hotel

Federal Holdings Tasmania P/L

(ABN 30 097 627 677) trading as:

  • MACq 01

Janala P/L

Mulawa Management P/L

(ABN 24 009 598 896) – Corporate

Technology Services Group P/L

(ABN 13 097 238 358) – Group IT

How do I contact Federal Group’s Privacy Officer?

If you have any questions or would like more information about this Privacy Policy you may contact the Federal Group Privacy Officer by email at:

privacyofficer@federalgroup.com.au

or write to:

The Privacy Officer, Federal Group, 410 Sandy Bay Rd, Sandy Bay,  TAS  7005

Our Privacy Framework

Federal Group is bound by the Privacy Act and the 13 Australian Privacy Principles (APPs) set out in that Act.  The APPs regulate the way that certain entities handle personal information.

The Privacy Act does not apply to the handling of information that does not relate to individuals – for instance information about corporations.

Federal Group recognises that your privacy is very important and that you have a right to control your personal information. We acknowledge that providing personal information to us is an act of trust and we take that trust seriously.

This policy will govern how Federal Group handles your personal information and safeguards your privacy.

Best Practice

Federal Group is committed to protecting your personal information and giving you choice in how it can be used.  We believe that our Privacy Policy represents industry best practice.

Federal Group is committed to complying with the Privacy Act for the responsible handling of your Personal Information. Furthermore, Federal Group will comply with any laws introduced to strengthen the protection of consumers’ privacy.

Collecting your Personal Information

Many of Federal Group’s operations allow you to interact with us anonymously, such as our bar, dining, entertainment, retail, tourism, conference and gaming facilities.  In the conduct of these operations we do not generally require you to provide your personal information in order to receive or participate in these services.

Your personal information is only collected with your consent.  The type of personal information that we collect from you will depend upon what dealings you have with us.  Federal Group only obtains your personal information where required to provide accommodation or certain entertainment, hotel or gaming services, or customer club membership or promotional activities.  Such personal information may comprise of one or more of the following: your name, address, contact details, date of birth, credit card details, government issue photo identification reference number, video footage (refer Video Surveillance), or information about your opinions and what you like.

Federal Group also collects your personal information if the law requires us to collect it.

If Federal Group does not collect your personal information, we may not be able to deal with you, or provide you with the requested product or service.

Collecting information from third parties

Federal Group may also collect information about you that is publicly available, including information from telephone directories, the electoral roll or other web sites.

There may be occasions when Federal Group collects personal information about you from a third party.  For example, Federal Group may collect personal information from:

  • credit reporting bodies if we request a report about your credit history;
  • other credit providers if we request information from them about the products they provide you;
  • organisations that Federal Group has an arrangement with to jointly offer products and/or has an alliance with to share information for marketing purposes to provide you with products or services and/or to promote a product or service;
  • marketing companies if we acquire contact information to tell people about Federal Group’s products and services that may interest them; and
  • other parties who may have introduced you to Federal Group.

Web Site Access

When you visit our web site, we may use an Internet browser feature called a “cookie”.  A cookie is a small data file that may be placed on the computer of a web user (usually in the browser software folder) the first time a computer visits a web site which operates cookies.  Cookies by themselves cannot be used to identify you personally.  They only identify your computer when you visit our site.  The information that we gain by using cookies provides us with statistics that can be used to analyse and improve our web site, products and services.  If you do not wish to receive any cookies you can set your browser to refuse cookies.  However, this may mean you are not able to take full advantage of our internet services.

Google Products

Federal Group uses a number of Google products to better understand visitation and assess interactions to its digital presentations.

Federal Group websites use Google Analytics, which is a web analysis service.  Federal Group has implemented the Google Analytics service across all our websites and digital presentations. All data provided by Google to Federal Group does not contain any customer personal information. We use the data collected to track and examine the use of all Federal Group websites, prepare reports on anonymous end user activities and share them with other Google services such as Adwords. Google may use the data collected to contextualize and personalize the ads on its own advertising network.

You can opt out of Google Analytics at any time without affecting how you interact with our digital presentations. For more information on opting out of being tracked by Google Analytics visit this Google Page (https://tools.google.com/dlpage/gaoptout).

Collecting sensitive information

Sensitive information is personal information about a person’s racial or ethnic origin, political opinion, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, genetic information or health information.

Federal Group will not collect, use or disclose sensitive information about you unless we need the information for one of our functions or activities and we have your consent (or we are legally required to do so).

For example, we may collect health information from you or your associate where we respond to a distress call or you request participation in certain tour activities.

Video Surveillance

We are committed to providing a secure environment for all visitors to our properties.  Our premises and their surroundings are under constant surveillance.  Surveillance video is only retained for a specified period of time except where its retention for a longer period is required to assist the investigation of unlawful, suspicious activities or defence of claims against Federal Group.  Details of suspected illegal and undesirable activities are shared with law enforcement bodies and regulatory bodies such as Tasmanian Gaming Commission.

Collection of images

From time to time Federal Group will hold events where images are likely to be taken for various purposes including but not limited to social media promotion, electronic publications and surveillance.  We will at all times ensure to provide as much detail as possible about what the image will be used for and who will be able to see it.  By entering a Federal Group event, customers:

  • consent to the recording of their image, likeness or voice by any means (including but not limited to video, audio and visual recordings by television cameras and photographers) (together ‘images’); and
  • consent to the use of the Images at the event, including display on vision screens throughout the event.

The use of cameras including mobile phones with camera interfacing is not permitted in the specified public areas of the event such as change Rooms and toilets.

Federal Group will use particular care in the handling the images and other personal information of children.  Depending on the age and ability of the child to understand our explanation about what is going to happen with their image and to make a truly informed choice, Federal Group will discuss these things with their parent or guardian first.  Federal Group will also meet the requirements of any other legislation that protects children.

Collection of photographs or video of people on the web

Federal Group will only collect images of identifiable individuals if it is reasonably necessary for one of our organisation’s functions or activities.  We will at all times ensure to provide as much detail as possible about what the image will be used for and who will be able to see it.

Federal Group will use particular care in the handling the images and other personal information of children.  Depending on the age and ability of the child to understand our explanation about what is going to happen with their image and to make a truly informed choice, Federal Group will discuss these things with their parent or guardian first.  Federal Group will also meet the requirements of any other legislation that protects children.

Collecting information required by law

Federal Group may collect information from you because we are required or authorised by an Australian law or court or tribunal order to collect that information.

 Security of Personal Information

We will make all reasonable endeavours to protect your personal information securely against unauthorised use and access. Your personal information will be recorded, amended and used only by authorised persons who are required to keep your information confidential.

Use and Disclosure of your Personal Information

Personal information is only used within Federal Group in the provision of services for which it was obtained and may be used to provide customers, through direct marketing, with knowledge of other services and promotions conducted by the Group.  Your personal information is not sold or passed to third parties for their marketing purposes.

Examples may include:

  • to consider your request for a product or service;
  • to enable Federal Group to provide a product or service;
  • to tell you about other products and services that may be of interest to you;
  • to manage accounts and perform other administrative and operational tasks (including risk management, systems development and testing, credit scoring, staff training, collect debts, and market or customer satisfaction research);
  • to consider any concerns or complaints you raise against Federal Group and/or to manage any legal action between you and Federal Group;
  • to prevent or investigate any actual or suspected fraud, unlawful activity or misconduct; and
  • as required by relevant laws, regulations, codes of practice and external payment systems.

 Sharing Information with Other Organisations

In some circumstances, we may disclose your information to our contractors and service providers, but only to the extent necessary to operate our business or provide you with the products and/or services you have requested. We require these organisations to undertake and meet the requirements of the Privacy legislation and agree to strict conditions governing how your personal information may be used.

While we will not use your information for any purpose without your consent, we reserve the right to use information in circumstances relating to the public interest. These circumstances may be related to:

  • a legal demand for the information from a law enforcement agency;
  • a public or individual health and safety issue; or
  • the protection of our rights and property, including the protection of the integrity of our operations.

Disclosing your personal information overseas

Federal Group may need to disclose your information to organisations located overseas.  From time to time we may choose to use online solutions located overseas to perform direct marketing, undertake surveys and store data.  Also, we only disclose your information to these overseas organisations when it is necessary for the services they provide to Federal Group.

At the time of publication our Service Providers include:

Hosting Services:

  • Microsoft Azure
  • OneDrive

Survey / Campaign Management:

  • Form stack
  • Mail Chimp
  • Market Metrix
  • Survey Monkey
  • Quantum Market Research
  • Revinate

Online Bookings:

  • Book a Restaurant / OpenTable
  • Luxury Lodges of Australia
  • QANTAS / Frequent Flyer
  • Secure Pay
  • Travel Click’s – iHotelier
  • Stripe Secure Payments
  • Restix

Human Resource Applications:

  • PageUp

Other:

  • Debt Collectors
  • Guest internet

When we disclose your information overseas, we are required to take measures to ensure your information is treated in accordance with the standards that apply in Australia.

Marketing and privacy

As part of Federal Group’s service to you, Federal Group may use personal information we have collected about you to identify a product or service that may benefit you.

You can contact us at any time if you do not want to receive marketing information from Federal Group (refer Resolving your concerns).

 Your Consent is important

Federal Group may require your consent to use and/or disclose your information in particular ways.

For instances, we need your consent if we need to use your information for a purpose that is not related to the purpose for which we collected your information in the first place.

Depending on the circumstances, this consent may be expressed (for example, you expressly agree to the specific use of your information by ticking a box) or implied by some action you take or do not take (for example, your agreement is implied by the fact that you have agreed to our service terms and conditions which contains information about the use or disclosure).

Opting out of marketing promotions

We want to communicate with you only if you want to hear from us. If you prefer not to receive direct marketing from our Federal Group properties, please let us know.  You can send us an email to Privacy Officer at privacyofficer@federalgroup.com.au.  Please be sure to include your full name, email address, mailing address, and specifically what information you do not want to receive. If you would like to update or correct your email address, mailing address or other contact information with us please contact us the same way. If you like, you may use one of the following statements in your message to us:

  • I prefer not to receive email advertisements, such as updates regarding products and services special promotions or upcoming events.
  • I prefer not to receive direct mail advertisements, regarding products and services, special promotions or upcoming events.

You may also click the designated unsubscribe link at the bottom of all email advertisements to be removed from future email updates.

Please note that any requests to remove or update your contact information may take up to ten business days from your email request.

Children’s privacy

We take children’s privacy seriously.

We will presume that a child aged under 15 does not have capacity to consent.

Where consent is required for Federal Group to handle the personal information of a child under the age of 18, Federal Group will need to determine on a case-by-case basis whether that child has the capacity to consent.  In some circumstances, it may be appropriate for a parent or guardian to consent on behalf of a young person, for example, if the child is young or lacks the maturity or understanding to do so themselves.

If Federal Group becomes aware that personal information that has been collected relates to a child without the consent of a parent or guardian, Federal Group will use reasonable efforts to:

  • delete that personal information from its files as soon as possible; and
  • ensure where deletion is not possible, that this personal information is not used further for any purpose, nor disclosed further to any third party.

Any parent or guardian with queries regarding our processing of personal information relating to their child should contact us (refer Resolving your concerns).

Managing your personal information

Federal Group protects your information

Federal Group protects your personal information from misuse and loss.  We also protect it from unauthorised access, modification and disclosure by ensuring that your personal information can only be accessed by people properly authorised to have access.

Federal Group may store your personal information in hardcopy documents or electronically.  Federal Group maintains physical security, such as locks and security systems over our paper and electronic data stores and premises.  Federal Group also maintains computer and network security.  For example, Federal Group uses firewalls (security measures for the internet) and other security measures such as identification codes and passwords to control access to computer systems.  Federal Group continually maintains and monitors its online security system to ensure that Federal Group’s online services are secure and that your personal information is appropriately protected when you use our products and services.

Protecting your privacy

You can help us to protect your privacy by observing our security requirements and contacting us immediately if your contact details change.

When you are issued with a membership card, we require you to keep your PIN, passwords or access codes confidential and secure at all times.

Access to and Correction of Personal Information

You are welcome to request details of personal information that we hold about you.  To do so, please contact our Privacy Officer by email at:

privacyofficer@federalgroup.com.au

or write to:

The Privacy Officer, Federal Group, 410 Sandy Bay Rd, Sandy Bay,  TAS  7005.

We will require personal identification to verify your identity before providing you with the information requested.  If you find that personal information we hold about you is inaccurate, incomplete or out-of-date, please contact our Privacy Officer.

We will normally be able to deal with your request within 30 days.  Depending on the complexity of your request, we may charge a fee to cover our costs for processing the request.

How do I request correction of my information?

If you believe that the personal information we hold is inaccurate, incomplete or out-of-date, you should contact us.

We will promptly update any personal information that is inaccurate, incomplete or out-of-date.  If we do not agree that your information is inaccurate, incomplete or out-of-date, we will write to you and tell you the reason(s) why we do not agree with you. We can also advise you the process you can follow if you are not satisfied with our response.

Resolving your concerns

You are entitled to complain if you believe that your privacy has been compromised or that Federal Group has breached the Privacy Act, or an applicable code.

If you have a privacy complaint, you can contact our Privacy Officer by email at:

privacyofficer@federalgroup.com.au

or write to:

The Privacy Officer, Federal Group, 410 Sandy Bay Rd, Sandy Bay,  TAS  7005.

 If your complaint is not satisfactorily resolved, you may escalate the matter by contacting the General Manager of the relevant business.

Managing your complaint

If you make a complaint, Federal Group will respond to you within 3 business days to let you know who is responsible for managing your complaint.  Federal Group will try to resolve your issue within 30 days.  When this is not possible, Federal Group will contact you within that time to let you know how long we will take to resolve your complaint.

Federal Group will investigate your complaint and where necessary, consult with other providers about your complaint.  Federal Group will make a decision about your complaint and write to you to explain our decision.

If your complaint is not satisfactorily resolved, you may access an external dispute resolution service or apply to the Office of the Australian Information Commissioner (OAIC) to have the complaint heard and determined.  When we write to you about our decision, we will explain how you may access an external dispute resolution scheme or make a complaint to the OAIC.

Changes in the Future

We reserve the right to change our Privacy Policy at any time.  All changes will be notified by posting an updated version of the Privacy Policy on our web site.  Any changes to our Privacy Policy shall be deemed to take place on the date the changes are posted on our web site.

Additional Information on Privacy

For further information about privacy issues and the protection of privacy, visit the Office of the Australian Information Commissioner web site at www.oaic.gov.au