ABOUT THIS POLICY 

We do everything we can to maintain your trust. Our staff are employed on the basis that they will protect information about you. This is our personal standard. Under law, your rights to privacy are also protected. The National Privacy Principles, the Privacy Act 1988 (Cth) and general law place strict requirements on us to treat certain information collected as confidential. 

WHAT PERSONAL INFORMATION DO WE COLLECT?

We may collect the following information from you:

• your full name, date of birth and contact details, such as address, email address and phone number;
• products purchased and spend.
• other information you may supply to us.

This information is collected in various ways, including in-person, via identification provided (e.g. driver licence, passport) and when processing cheques and/or EFT, and for verification purposes, through our website, via electronic communication, and during telephone interactions. We aim to collect this information directly from you.

PURPOSE OF FACIAL RECOGNITION TECHNOLOGY (FRT)

Our venue uses Facial Recognition Technology (FRT) to enhance safety, ensure compliance with self-exclusion programs, and support harm minimisation initiatives. The use of FRT is strictly aligned with the principles of privacy, transparency, and compliance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). 

How data is collected 

FRT analyses facial features of individuals entering specific areas of our venue. This analysis is conducted in temporary memory and only for the purpose of identifying matches against predefined databases, such as self-excluded individuals or banned patrons.

No biometric data is stored or retained after the analysis. If no match is found, the data is automatically purged from memory in real-time.

At no point is the facial data linked to an individual’s identity unless a match occurs, and even in those cases, no biometric template is retained by our systems.

How data is stored

Temporary Memory Only: 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.

Anonymous Analytics: We may store aggregate, anonymised data for operational insights, such as people counts, gender demographics, and approximate age ranges. This data is fully anonymised and cannot be linked to any individual or facial profile.

How data is used

Self-Exclusion Compliance: FRT is used to assist in identifying individuals who have voluntarily enrolled in self-exclusion programs or have received formal ban notices.

Operational Insights: Anonymous and aggregate data may be used to optimise venue operations, such as managing crowd density and enhancing service offerings. This data contains no personal or identifiable information.

Privacy and Compliance

Our use of FRT complies with the Privacy Act 1988 (Cth) and the Australian Privacy Principles. We ensure that all data handling practices meet the highest standards of security, necessity, and proportionality.

Individuals are informed about the use of FRT through clearly visible signage at venue entry points. Additional information about the use of FRT is available in this privacy policy and upon request.

All data collected and processed is limited to what is necessary to achieve specific safety and compliance objectives.

Transparency and your rights

Our venue is committed to transparency regarding the use of FRT. If you have questions about how FRT operates or your rights under the Privacy Act, please contact us using the details provided below.

You have the right to understand how FRT is used and the purposes for which data is processed. You may also request additional details about how anonymous data is managed.

WHY DO WE COLLECT, USE AND DISCLOSE PERSONAL INFORMATION?

We use the collected information to customise our services and plan product development so that we can provide you with relevant consumer information and notify you of products and special offers that may be of interest to you. It is also collected so that we may provide value-added services and offers.

We also collect, use and disclose personal information to comply with legal requirements and obligations, including those which may relate to our licenses, such as reporting to regulators (e.g. VGCCC, AUSTRAC) and enforcement bodies.

We may disclose information we hold to our directors, officers, employees and other related companies within our corporate group for marketing purposes.

We may also disclose information to service providers, contractors who help us provide services or trading parties. These third parties provide services such as SMS, EDM and mail out and are subject to our approval.

We do not sell or trade your personal information.

PROMOTIONAL COMMUNICATIONS

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.

PERSONAL INFORMATION ACCESS

You may review, change or delete personal information related to you in person at the hotel.

We will try to ensure that all information we collect, use or disclose about you in accordance with this Privacy Policy is accurate, complete and up-to-date.

SECURITY

We understand the importance of your personal information and have appropriate procedures in place to safeguard and secure the information we collect to prevent unauthorised access or disclosure, maintain data accuracy and ensure the appropriate use of information.

GENERAL

By using the Lower Plenty Hotel Membership Rewards Program, you are consenting to the collection of information by the Lower Plenty Hotel in accordance with this Privacy Policy.

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.

PRIVACY RIGHTS

If you believe that our organisation has breached your privacy rights in any way, or you would like to discuss any issues about our privacy policy please contact Lower Plenty management in writing, details below:

Post: 4 Main Road, Lower Plenty VIC 3093

Tel: (03) 9435 1722

E-mail: info@lowerplentyhotel.com.au