The registered company Estal Nominees Pty Ltd ACN 007 290 691 which trades as Lower Plenty Hotel, (the Hotel, we, us) at 4 Main Road, Lower Plenty VIC 3093 (the Premises) values the privacy of its customers. This Privacy Policy describes the Hotel’s practices with regards to the information we collect about you.

This Privacy Policy addresses collection and use of personal and sensitive information at the Premises. It has been developed in accordance with the Privacy Act 1988 (Cth) (the PA) which sets out the overarching framework for privacy protection in Australia and includes the Australian Privacy Principles (APPs).

1. Personal and Sensitive Information we collect
   • (a) The Hotel collects information that identifies you, or could reasonably be used to identify you (Personal Information) including:
     • your name, date of birth and contact details (address, email and phone number).
     • records of products purchased and amount spent.
     • any other information you may provide to us.
   • (b) Personal information collected by the Hotel includes photographic and surveillance systems, and personal details in connection with membership of the Lower Plenty Hotel Membership Rewards Program.
   • (c) If we collect information that does not identify or reasonably identify you, that information is not Personal Information.
2. How We Collect Personal Information
   • (a) We may collect this information in several ways, including:
     • in person at the Premises.
     • from identification documents you provide (e.g., driver’s licence, passport).
     • when processing cheques or electronic payments such as EFT.
     • when you interact with us through our website, electronic communications, or telephone.
   • (b) Facial images of patrons and guests are captured via the Hotel’s electronic surveillance systems, when entering or moving within the Premises.
3. Use of Personal Information
   • (a) We may use Personal Information for the purposes for which it was collected, and in connection with those purposes. We may also use your personal information for any additional purposes to which you have expressly consented.
   • (b) We may use Personal Information for purposes including, but not limited to, the following:
     • assisting the Hotel in identifying BSEPs; and
     • to customise the services that we provide to you.
   • (c) We may store aggregate, anonymised data – such as people counts, gender demographics, and approximate age ranges – to generate operational insights and optimise the Hotel’s operations. This data cannot be linked to any individual or to any facial or biometric profiles.
   • (d) The Hotel will retain your personal information for such time period as is required or permitted, considering the purposes for which it was obtained and the requirements under any applicable law.
4. Disclosure of Personal Information
   • (a) We do not sell or trade your personal information.
   • (b) We may disclose Personal Information to the following parties:
     • upon request to third parties, including, but not limited to, Victoria Police, the Victorian Gambling & Casino Control Commission, and Liquor Control Victoria.
     • to our directors, officers, employees and other related companies within our corporate group for marketing purposes.
     • to our approved third-party service providers who assist us in delivering services, including SMS, electronic direct mail, and mail-outs.
   • (c) Personal information may also be disclosed to our staff in the event of an incident and recorded in the Hotel’s incident registry.
5. Use of Facial Recognition Technology
   
   • (a) The Hotel uses facial recognition technology (FRT) integrated with its existing electronic surveillance system to collect biometric images of individuals entering the Premises.
   • (b) The purpose of FRT is to assist the Hotel in specifically identifying banned or self-excluded individuals (BSEPs) and preventing their entry to the Premises in accordance with our obligations under the Gambling Regulation Act 2003.
   • (c) Clear signage is displayed at the entry to the Premises informing customers that FRT is in use and outlining the purpose for which it operates. By entering and remaining on the Premises you are consenting to the Hotel’s use of FRT and to the collection and handling of personal and sensitive information in accordance with this Privacy Policy.
   • (d) If you withhold consent or do not permit the collection of your information, we may be unable to provide you with our services or allow entry to the Premises.

6. Retention period
   • (a) All facial data processed by FRT is held in temporary memory for the sole purpose of conducting real-time comparisons. This data is not stored in any database or retained after processing.
7. Sensitive Information
   • (a) Where information collected is deemed sensitive personal information under the PA it will be dealt with as required by the PA and any other applicable legislation.
   • (b) Biometric data and biometric templates (Biometric Information) generated by FRT-enabled cameras is sensitive personal information.
   • (c) We use FRT to assist in identifying individuals who have voluntarily enrolled in self-exclusion programs or have received formal ban notices to ensure we meet our legal obligations under the GRA. The use of FRT is strictly aligned with the APPs and complies with the PA.
8. How FRT works
   • (a) FRT-enabled cameras compare the faces of individuals entering the Premises against an authorised and secured database containing only images of BSEPs.
   • (b) If a match is made, we are alerted to the fact that a BSEP is attempting to enter the Premises.
   • (c) Once a match is made or if no match is made the Biometric Information that is temporarily collected, for the sole purpose of detecting BSEPs, is automatically and permanently deleted.
9. Collection and storage of Biometric Information
   • (a) Biometric templates generated by FRT-enabled cameras is stored in temporary memory only for the sole purpose of conducting real-time comparisons with individuals entering the Premises to identify BSEPs. The templates are not stored in any database or retained after processing.
10. Transparency and your rights
    • (a) We are committed to transparency regarding the use of FRT. If you have any questions about how FRT operates or your rights as a patron under the Privacy Act, please contact us using the details provided below.
11. Promotional Communications
    • (a) We want to communicate with you only if you want to hear from us. If you prefer not to receive promotional information from us, please let us know by clicking on the unsubscribe link at the bottom of any of our email communications or visit us at the Hotel.
12. Updates to Privacy Policy
    • (a) We may change this Privacy Policy at any time. Any changes to this Privacy Policy will be effective from the time that the revised Privacy Policy is made available to patrons via our controlled websites and at the Premises.
13. Access to your Personal Information
    • (a) You may review, change or delete Personal Information related to you in person at the hotel.
    • (b) We will make all reasonable efforts to ensure that information we collect, use or disclose about you in accordance with this Privacy Policy is accurate, complete and up to date.
14. Security
    • (a) We understand the importance of Personal and Sensitive Information and take reasonable measures to protect Personal and Sensitive Information collected to prevent its unauthorised access or disclosure.
    • (b) With respect to Sensitive Information, the Hotel uses industry-standard encryption for data processing within temporary The systems employed are designed to immediately purge biometric data post-comparison.
15. General
    • (a) By using the Hotel facilities, services and/or membership programs, you are consenting to the collection of information by the Hotel in accordance with this Privacy Policy.
    • (b) Please note that we reserve our right to amend, remove or vary this policy without notice. You should check this page regularly to take notice of any changes we may have made to this policy.
16. Contacting Us
    • (a) We are responsible for the collection, use and disclosure of personal information under this Privacy Policy.
    • (b) If you have any questions or concerns about this Privacy Policy please contact us. Please do not include sensitive information such as credit card information when writing to us.
    • (c) The Hotel can be contacted as follows:
      • By Post: Lower Plenty Hotel, 4 Main Road, Lower Plenty VIC 3093 
      • By Telephone: (03) 9435 1722

17. Governing Law
    • (a) This Privacy Policy is governed by the laws of Australia, and the Privacy Act 1988 applies to this Privacy Policy.