Privacy Policy


About this policy

Version as at December, 2017

The Privacy Act 1988 requires entities such as Federal Group to have a privacy policy. This Privacy Policy outlines the personal information handling practices of Federal Group.
This Policy is written in simple language. The specific legal obligations of Federal Group when collecting and handling your personal information are outlined in the Privacy Act 1988 and in particular in the Australian Privacy Principles in that Act. We will update this Privacy Policy when our information handling practices change. Updates will be published on our website(s).

Overview

Federal Group is a privately owned family company which operates significant tourism, hospitality, retail, casino and gaming assets in Tasmania, a gaming technology and software company in Queensland, and a national sensitive freight company.

We recognise that the scope and scale of our company means that we touch many lives. As a family business, this is not something that we ever take lightly.

Our vision for the future is to be Australia’s most respected service business through an unwavering commitment to our principles. We believe that earning the respect of our employees, our customers, our industry partners and our communities will ultimately ensure the long-term success of our company.

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

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.

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

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:

  • MACq01

Janala P/L

(ABN 24 003 672 839) trade as:

  • COPE Sensitive Freight

Mulawa Management P/L

(ABN 24 009 598 896) – Corporate

Technology Services Group P/L

(ABN 13 097 238 358) – Group IT

Odyssey Gaming Limited

(ABN 48 074 735 452)

Collection of your personal information

At all times we try to only collect the information we need for the particular function or activity we are carrying out.

The main way we collect personal information about you is when you give it to us.  For example, we collect personal information where required to provide accommodation, certain entertainment, gaming services, customer club membership or promotional activities.  Such personal information may comprise of one or more of the following:

  • Your name, address, date of birth contact details;
  • Credit card details;
  • Government issue photo identification reference number;
  • Business name;
  • Video or surveillance footage;
  • Your customer reference number or loyalty card number;
  • Whether you have taken up some of our other offerings, such as membership of our clubs and loyalty programs, and our mobile applications;
  • Any rewards and redemption details applicable to your membership of our loyalty programs;
  • Your stated or likely preferences, for example whether you may be interested in particular products or promotions; or
  • Information about your opinions and what you like.

We will also collect information that you provide us when signing up to mailing lists and registering for our events, or when submitting feedback on your experience with our websites.

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

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.

Indirect collection

There may be occasions when we collect personal information about you from a third party. For example, we 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 we have 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 our products and services that may interest them; or
  • Other parties who may have introduced you to one or more of our businesses.

Further, in the course of handling and resolving a complaint, data breach, review or an investigation we may collect personal information (including sensitive information) about you indirectly from publically available sources or from third parties such as:

  • Your authorised representative, if you have one; or
  • Applicants, complainants, respondents to a complaint, investigation, application or data breach notification or the third parties’ employees and witnesses.

Anonymity

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.

Third party sites and services

Our websites, products, applications, and services may contain links to third-party websites, products, and services.  Our products and services may also use or offer products or services from third parties. These websites may store information across multiple countries.

Information collected by third parties, that may include such things as location data or contact details, is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.

At the time of publication our Service Providers include:

Analytics:

  • Google Analytics, Moz Pro
  • TravelClick’s EMC

Gaming Products:

  • Metropolis Gaming Systems
  • Astute Business Intelligence
  • TRACE Intuitive Customer Engagement

Hosting Services:

  • Microsoft Azure
  • OneDrive

Human Resource Applications:

  • PageUp

Online Bookings:

  • Book a Restaurant / OpenTable
  • com
  • CTrip
  • DIMMI
  • Eventbrite
  • Expedia
  • Flight Centre
  • Hooroo
  • Luxury Lodges of Australia
  • QANTAS Frequent Flyer
  • Secure Pay
  • Stripe Secure Payments
  • Ticketmaster
  • Travel Click’s iHotelier
  • And other 3rd party online booking websites from time to time.

Survey / Campaign Management:

  • Mail Chimp
  • Market Metrix
  • Quantum Market Research
  • Revinate
  • Roy Morgan Audiences
  • Survey Monkey

Social Media:

  • You Tube, Twitter and Facebook, Instagram, Trip Advisor, LinkedIn

Other:

  • Debt Collectors, Guest internet- www.freehotelwifi.com.au

Information we collect automatically

Whenever you visit or interact with any of our websites, we as well as any third party service providers may use a variety of technologies that automatically or passively collect information about how our websites are accessed and used [‘Usage Information’].  Usage Information may include, in part, browser type, operating system, the page served, the time and the preceding page views.  This statistical data provides us with information about the use of our websites, such as how many visitors visit a specific page, how long they stay on that page, and which hyperlinks, if any, they ‘click’ on.  Usage Information is non-identifying, but if we are to associate it with you as a specific and identifiable person, we then treat is information as Personal Information.

We may also automatically collect your IP address or other unique identifier [‘Device Identifier’] for the computer, mobile device, technology or other device [collectively, ‘Device’] you use to access our websites.  A Device Identifier is a number that is automatically assigned to your Device when you access a website or its servers, and our computers identify your Device by its Device Identifier.

The technologies used on our websites to collect Usage Information, including Device Identifiers, may include:

Cookies

Cookies are data files place on a Device when it is used to visit our websites.  We may place cookies or similar files on your Device for security purposes, to facilitate site navigation and to personalise your experience while visit our websites.  Cookies allow us to collect technical and navigational information, such as browser preferences.  However, please be aware that some features of our websites may not function properly or may be slower if you refuse cookies.

Pixels

Small graphic images or other web programming code called pixels, may be include in our websites and email messages.  Pixels or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the websites, to monitor how users navigate the websites, to count how many emails that were sent were actually opened or to determine whether content sent was actually viewed.

Third party web analytics services

Federal Group uses a number of Google products to better understand visitation and assess interactions with our websites.  We use Google Analytics, which is a web analysis service provided by Google Inc which uses cookies to help analyse how users use our websites. The information generated by the cookie about your use of our websites (such as IP address, the URL visited, the date and time the page was viewed) will be transmitted and stored by Google on servers globally.  Google will use this information to monitor your use of our websites, compiling reports on website activity for us and provide other services related to website activity, and internet usage.  Google may use the data collected to contextualise and personalise the ads on its own advertising network, and may transfer this information to third parties where required by law, or where such third parties process information on Google’s behalf.  For more information about Google’s privacy policy in respect of Google Analytics, please refer to https://www.google.com.au/intl/en_au/policies/privacy/?fg=1

You can opt out of Google Analytics at any time without affecting how you interact with our websites by installing a small app within your browser via this link https://tools.google.com/dlpage/gaoptout.

Social networking services

We use social networking services such as Twitter, Facebook and YouTube to communicate with the public about our work. When you communicate with us using these services we may collect your personal information, but we only use it to help us to communicate with you and the public. The social networking service will also handle your personal information for its own purposes. These services have their own privacy policies. You can access the privacy policies for Twitter, Facebook and YouTube (a Google company) on their websites.

Your consent is important

Federal Group may require your consent to use and/or disclose your information in particular ways.  Your consent may either be inferred or expressed.

Inferred Consent is

  • By an existing relationship you have with our properties or businesses, or
  • Where there is a reasonable expectation of you receiving commercial electronic messages from us, or
  • Where you have published a work related email that is accessible to the public or a section of the public.

Expressed consent is for example:

  • By filing out a form, ticking a box on a web site, over the phone, face-to-face, swapping business cards, or
  • As long you are aware that you may receive a commercial electronic message from us.

If you no longer want to receive our offers, information on our services and other promotional activities you can ‘opt-out’, or ‘unsubscribe’ from any of our commercial electronic messaging such email, SMS, MMS or IM, or contact us directly.

Collection of images

From time to time Federal Group will hold events where images are likely to be taken for various promotion, electronic publications and surveillance purposes.

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 such things as 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.

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 Liquor and Gaming Commission.

Children’s privacy

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.

If Federal Group becomes aware that personal information that has been collected relates to a child without the consent of a parent or guardian, we 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.

Federal Group will also meet the requirements of any other legislation that protects children.

Disclosure

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 on to third parties for their marketing purposes.

Disclosure to service providers

Federal Group uses a number of service providers to whom we disclose personal information. These include providers that host our website servers, manage our IT and manage our human resources information.

To protect the personal information we disclose we:

  • Enter into a contract or MOU which requires the service provider to only use or disclose the information for the purposes of the contract or MOU; and
  • Include special privacy requirements in the contract or MOU, where necessary.

Disclosure of sensitive information

We only disclose your sensitive information for the purposes for which you gave it to us or for directly related purposes you would reasonably expect or if you agree, for example, to handle a complaint, or where we respond to a distress call or you request participation in certain tour activities.

Disclosure of 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.

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.

Quality of personal information

To ensure that the personal information we collect is accurate, up-to-date and complete we:

  • Record information in a consistent format;
  • Where necessary, confirm the accuracy of information we collect from a third party or a public source;
  • Promptly add updated or new personal information to existing records; and
  • Regularly audit our contact lists to check their accuracy.

We also review the quality of personal information before we use or disclose it.

Storage and security of personal 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.

We will retain your personal information for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

Accessing and correcting your personal information

Under the Privacy Act (Australian Privacy Principles 12 and 13) you have the right to ask for access to personal information that we hold about you, and ask that we correct that personal information. You can ask for access or correction by contacting us and we must respond within 30 days. If you ask, we must give you access to your personal information, and take reasonable steps to correct it if we consider it is incorrect, unless there is a law that allows or requires us not to.

We will ask you to verify your identity before we give you access to your information or correct it, and we will try to make the process as simple as possible. If we refuse to give you access to, or correct, your personal information, we must notify you in writing setting out the reasons.

If we make a correction and we have disclosed the incorrect information to others, you can ask us to tell them about the correction. We must do so unless there is a valid reason not to.

If we refuse to correct your personal information, you can ask us to associate with it (for example, attach or link) a statement that you believe the information is incorrect and why.

How to make a complaint

If you wish to complain to us about how we have handled your personal information you should do so in writing. If you need help lodging a complaint, you can contact us.

If we receive a complaint from you about how we have handled your personal information we will determine what (if any) action we should take to resolve the complaint.

We will tell you promptly that we have received your complaint and then respond to the complaint within 30 days.

If you are not satisfied with our response you may ask for a review by a more senior Privacy Officer within the Federal Group (if that has not already happened), or you can access an external dispute resolution service, or apply to the Office of the Australian Information Commissioner (OAIC) to have your complaint heard and determined. The Privacy Commissioner may be contacted at: www.oaic.gov.au, or email: enquiries@oaic.gov.au

We may give a copy of the complaint or application to the Office of the Australian Information Commissioner, or other regulatory body or law enforcement agency as required by law.

How to contact us

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

Email:
privacyofficer@federalgroup.com.au

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

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 websites.  Any changes to our Privacy Policy shall be deemed to take place on the date the changes are posted on our websites.