Privacy Policy

Privacy Policy – Doxa Community Club

1. Introduction

At Doxa Community Club, which includes our venues Central Point and Clocks at Flinders, we are committed to protecting your privacy and handling your personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). This policy outlines the types of personal information we collect, how we collect it, and how we use, store, and protect it. We also explain our use of Facial Recognition Technology (FRT) to enhance safety, comply with self-exclusion programs, and support harm minimisation initiatives.

2. Collection of Personal Information

We collect personal information to provide you with services, manage our customer base, and enhance your experience. The types of information we may collect include:

• Personal Identifiers: Name, address, date of birth, contact details (phone number, email, etc.).
• Facial Recognition (FRT): Facial features captured by FRT systems when you enter specific areas of our venues (only used for self-exclusion compliance and operational insights, as detailed below).

This information is collected in various ways, including in-person, through our website, via electronic communication, and during telephone interactions. We aim to collect this information directly from you.

3. Purpose of Facial Recognition Technology (FRT)

To enhance safety, ensure compliance with self-exclusion programs, and support harm minimisation initiatives, Doxa Community Club uses Facial Recognition Technology (FRT) at specific entry points of our venues. The use of FRT is compliant with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), and is designed to:

• Self-Exclusion Compliance: Identify individuals who have voluntarily enrolled in self-exclusion programs or received formal ban notices.
• Operational Insights: Gather anonymous and aggregate data for improving venue operations, such as crowd density management and service offerings.

4. How Data Is Collected

FRT works by analysing the facial features of individuals entering the venue. This analysis occurs in temporary memory and is only used to identify matches against pre-defined databases, such as lists of self-excluded or banned patrons. Importantly:

• No biometric data is stored or retained.
• If no match is found, the data is automatically purged from memory in real-time.
• Data is only retained if there is a match, but even then, no biometric template is stored.

5. How Data Is Stored

• Temporary Memory Only: Facial data processed by FRT is stored temporarily for the sole purpose of real-time analysis. Once processed, the data is deleted.
• Anonymous Analytics: We may store anonymised, aggregate data such as people counts, gender demographics, and approximate age ranges for operational purposes. This data cannot be linked to any individual or facial profile.

6. How Data Is Used

• Self-Exclusion Compliance: FRT assists in identifying individuals enrolled in self-exclusion programs or who have been banned from gambling.
• Operational Insights: We may use anonymous and aggregate data to improve venue operations and customer experience. This data contains no personal or identifiable information.

7. Privacy and Compliance

Our use of FRT is governed by the Privacy Act 1988 (Cth) and APPs. We take the following steps to protect your privacy:

• Transparency: We display clear signage at entry points to inform patrons of the use of FRT.
• Security: We use secure methods to protect the information we collect, and access is restricted to authorised personnel only.
• Compliance: All data handling practices adhere to the highest standards of security, necessity, and proportionality.

8. Your Rights and Transparency

We are committed to ensuring you understand how your personal data is used. You have the right to:

• Request information about the data we collect.
• Ask questions about FRT and how it operates.
• Request more details about how anonymised data is used and managed.

If you have any questions or concerns, please contact us via the details provided below.

9. Use of Your Personal Information

We use your personal information for the following purposes:

• To provide you with the services you request.
• To send you communications regarding promotions, events, and services offered by Doxa Community Club through the Doxa Rewards Loyalty Program. You can opt out of receiving these communications at any time.
• To ensure security, compliance, and management of our venues.
• To analyse and improve the operation of our venues, including anonymous data used for operational insights.

10. Disclosure of Personal Information

We do not disclose your personal information to third parties for marketing purposes without your consent. We may disclose information if:

• Required by law or a court order.
• Our contracted agents and service providers have been informed of the importance we place on protecting your privacy and their role in helping us to do this, and they undertake to maintain the confidentiality of your personal information. Any use of your personal information by them will be subject to the Privacy Act and the Principles.

11. How We Store and Protect Your Information

Your personal information is securely stored in electronic systems protected by restricted access, passwords, and secure firewalls. Access is limited to authorised personnel only.

12. How Long We Keep Your Information

We retain written information for approximately 18 months, primarily for auditing purposes. After that, it is destroyed. Computer records are stored securely for a longer period for legal and financial purposes. You can request to remove your details from our records at any time.

13. Access and Correction of Your Information

You can request access to your personal information at any time. If you believe any information is incorrect, please contact us, and we will update it.

14. External Links and Cookies

Our website may contain links to other sites. We are not responsible for the privacy practices of external websites. Additionally, some third parties may collect information through cookies and other tracking technologies when you interact with our site. Further, we are not responsible for the operation of websites accessed via links from this website (although we would appreciate your advice on links to websites that are inoperative or that you find have inappropriate links elsewhere).

15. Complaints and Concerns

If you have any concerns about how we handle your personal information, please contact us on (03) 9046 8230. We take your privacy seriously and will address any issues promptly.