Our commitment to your privacy
Australian Pacing Gold Ltd (“us”, “we”, or “APG”) complies with privacy laws that apply to our business and seeks to adopt best practice for the management of personal information.
What is personal information?
“Personal information” means any information or opinion, whether true or not, and whether recorded in a material form or not, about an identified individual or an individual who is reasonably identifiable. In general terms, this includes information or an opinion that personally identifies you either directly (e.g. your name) or indirectly.
What personal information do we collect and hold?
We collect and hold personal information which you have either consented to us receiving or that which is reasonably necessary to fulfil our activities and functions as a business. We will only collect personal information from you directly unless it is both reasonable and fair to receive this from a secondary source.
We collect and hold the following kinds of information:
- Personal details – such as your name, postal and/or email addresses, and telephone numbers. In specific circumstances we may also collect a person’s age.
- Details of horses currently owned, bred, raised, sold, purchased, including the horse’s pedigree.
- Details of your participation in any of APG’s auctions or sales.
- Details of your participation in any APG Race Series
- Any prizes you have received or won in connection with any of our activities, including social media competitions or events sponsored or hosted by us.
- Depending on your dealings with us, we may collect and hold other information. For example, payment or account information that you may use when making sustaining payments.
- Your stated or likely preferences or any feedback or comments. for example, whether you may be interested in participating in events, activities or promotions hosted or sponsored by us.
- APG is a member of, or signatory to, various bodies and codes of conduct which impose rules on the welfare and sale of bloodstock. These rules may require us to collect additional personal information to those listed above and may require us to verify your identity by collecting copies of your identity documents.
In the event such identity documents contain ‘sensitive information’ (for example race, religion, or medical information) or ‘government identifier’, this sensitive information will only be used to fulfil our obligations under such rules and no other purpose. We will only use or disclose such identifiers where it is reasonably necessary to verify your identity, or as required or permitted by law.
Where possible, sensitive information will not be collected and will otherwise be deleted where practicable once any obligations under any rules have been fulfilled.
How do we collect and hold your information?
We collect personal information from you when:
- You provide your details to us. For example, by filling in a form to participate in an auction or sale of a yearling, or to verify your identity.
- You communicate with us online.
- You participate in our competitions, promotions, testimonial, surveys or other offerings.
- You deal with us in another way involving a need for personal information to be provided such as when you make a purchase, inquiry, or bring a claim against us.
- We may also collect personal information about you by using data from other sources and analysing this data together with information we already hold about you to learn more about your likely preferences and interests. When you visit our websites, social media pages or our other online presence, we may collect information about you using technology, for example ‘cookies’.
Personal information we hold is generally stored in computer systems. These may be operated by us or by our service providers. In all cases, we have rigorous information security requirements aimed at eliminating risks of unauthorised access to, and loss, misuse or wrongful alteration of, personal information.
Why we collect, use, hold and disclose your personal information
We primary collect, use and hold your personal information to facilitate our business activities, services related to these activities, and to improve on the services and delivery of services we offer. For example:
- From time to time your personal details may need to be passed on to third party companies and consultants who perform parts of our service delivery, such as couriers, technical partners (providing us services such as email, web hosting, data storage and backup), email marketing companies and legal or other professional consultants, some of whom may be located outside of Australia.
- To assist in investigating your complaints or enquiries.
- To announce winners of races, competitions and/or prizes, and previous winners of the same;
- To report any information to a relevant body when required to do so under a relevant rule (such as reporting the details of a buyer and seller to Racing NSW under their Code of Practice).
Security and destruction of data
We take all reasonable steps to store your personal information securely. Personal information is destroyed securely when no longer required by us.
Sharing of your personal information overseas
When holding your personal information, we store our data with backup and hosting services located within Australia. In the event the services we use change so that your personal information would no longer be held in Australia we will seek your consent except where the recipient country has equivalent (or greater) privacy laws and protections to that of Australia and that would apply to your personal information.
Access and correction of your personal information
If you wish to access or have an enquiry about your personal information, or how we handle privacy matters generally, please contact our team by email: Email: firstname.lastname@example.org
We may require proof of identity before giving you access to your personal information. We may charge an administration fee ($25) for giving access to your personal information if your request requires substantial effort on our part.
What are the consequences of not providing Personal Data?
You are not required to provide all Personal Data identified in this Statement to use our Sites or to interact with us offline, but certain functionalities will not be available if you do not provide certain Personal Data. If you do not provide certain Personal Data, we may not be able to respond to your request, perform a transaction with you, provide certain incentives or rebates, or provide you with marketing that we believe you would find valuable.
If you wish to complain about the privacy rules that bind us, please contact us in writing using the above details. We may request further details from you so we may adequately understand or address your concerns. We may also discuss your complaint with our staff, our service providers or our professional advisors as appropriate.
APG will investigate the matter and attempt to resolve it in a timely way and inform you in writing about the outcome of the investigation. If our APG does not resolve your complaint to your satisfaction and no other complaint resolution procedures are agreed or required by law, your complaint may be referred to the Privacy Commissioner for further investigation.
Other privacy terms and limits of this policy
Depending on your dealings with us, there may be additional privacy notices and terms relevant to you. Such additional terms are contained within our various contractual documents, such as our auction terms.
More information about privacy law and privacy principles is available from the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au
Last update of this policy: [September] 2023.