Introduction

This Privacy Policy is for clients of 12Follow Pty Ltd (ABN 19 136 345 536) (12Follow, we, us, our). 12Follow is an Australian registered company. 12Follow owns and operates the website, www.12Follow.com.au(the Website or the Websites).
12Follow is bound by the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs). You can contact our Privacy Officer to discuss any privacy related queries you may have – email help@12Follow.com.au or telephone +612 49158685.
PRIVACY POLICY (PP) 12Follow is committed to implementing practices, procedures and systems that:

  1. ensure we comply with the APPs (and any APP code applying to us); and
  2. allow us to deal with your enquiries and complaints concerning compliance with the APPs (or any APP code applying to us).

This Privacy Policy is to be read in conjunction with the 12Follow Terms and Conditions provided at https://www.12Follow.com.au/#terms-and-conditions.

1. ABOUT THIS POLICY

Under the Privacy Act, ‘personal information’ is generally considered any information or opinion that identifies you personally. This Privacy Policy explains how we manage your personal information, including:

  1. the kinds of personal information we collect and hold;
  2. how we collect and hold your personal information;
  3. our reasons for collecting, holding, using and disclosing personal information;
  4. how you may access your personal information held by us and have it corrected;
  5. how you may complain about the way we deal with your personal information, and how we will deal with your complaint; and
  6. whether we will disclose your personal information to overseas recipients, and if so the likely location(s) of those recipients.

By accessing and/or using 12Follow’s Website, our products or services or by otherwise providing us with your personal information, you confirm that you have read and agree to this Privacy Policy and consent to the management of your personal information as described in this Privacy Policy.
We may make changes to this Privacy Policy as required at any time. If we do, we’ll notify you by posting the updated version of the Privacy Policy on the Website at
https://www.12Follow.com.au/#privacy-policy, with the date of the changes. By continuing to use our Website and/or our services or by continuing to provide us with your personal information after these changes have been published on our Website, you confirm your acceptance of these changes.

2. KINDS OF INFORMATION WE COLLECT AND HOLD

This depends on your dealings with us, and the requirements of the laws, regulations, licence conditions and betting rules applying to us.

2.1 Opening accounts
To open a 12Follow account we need your:

  1. name;
  2. residential and email addresses;
  3. date of birth; and
  4. telephone number.

We may ask for other details from you, such as:

  1. your credit card and/or bank account details (in order to allow you to purchase a 12Follow tipping service); and
  2. some lifestyle or betting frequency information for the purposes of monitoring your service activity.

2.2 Claiming prizes and website enquiries
If you win a prize, or apply for an unclaimed prize or dispute a decision we make, we will collect your personal information including your name, email address, residential address and contact phone number.

2.3 Information from other 12Follow related companies
Our related bodies corporate may provide us with information about you such as:

  1. contact details;
  2. date of birth;
  3. copies of identification documents;
  4. lifestyle or betting frequency information; and
  5. recordings of telephone calls you have made to our call centre/s.

2.5 Online behaviour
We may collect information regarding your online behaviour, including:

  1. your responses to promotions, giveaways and competitions;
  2. the time, date and URL of each request for a page from our web server (including the times that you login to any accounts to ensure the security of your account and to verify that the person operating the account is you); and
  3. information from your computer or device allowing us to: analyse trends, administer our Websites, track your web navigation, and gather broad demographic information for aggregated use.

To do this we may use cookies (pieces of data sent by a website to your computer and stored on the hard drive). Cookies allow the Website to identify and interact with your computer. You can set your browser to accept or reject all cookies, or notify you when a cookie is sent. If you reject cookies or delete our cookies, you may still use our Websites, but may not have access to “account holder only” areas.

3. HOW WE COLLECT AND HOLD PERSONAL INFORMATION

3.1. How we collect your personal information
We usually collect your personal information directly from you by telephone, in person or online through our Website. However, we may collect information from a third party if it isn’t reasonable or practicable to collect it from you. For example, we may collect information from:

  1. other companies related to 12Follow, such as TopBetta Pty Ltd and/or TopTippa Pty Ltd.

We may collect your personal information in a variety of ways, for example, when you visit or use our Websites and/or services, when you register for, and log into, an account on our Website, when you sign up to join a mailing list or to receive newsletters, when you enter to participate in competitions or surveys or when you contact us.

4. HOW DO WE SECURE YOUR PERSONAL INFORMATION

12Follow takes reasonable precautions in the circumstances to protect the personal information it holds from:

  1. misuse, interference and loss; and
  2. unauthorised access, modification or disclosure.

These include protection of passwords using industry standard encryption; measures to preserve system security and prevent unauthorised access; and back-up systems to prevent accidental or malicious loss of data. Any paper copies are stored in locked cabinets or restricted access archive rooms. We may use third party data storage providers to store personal information electronically. We take reasonable steps to ensure this information is held as securely as information stored on our own equipment.
Documents verifying your identity and any credit card information you send us will be stored in a secure database with limited ¬access requiring a password or other unique identifier.
Unfortunately, there is always risk involved in sending information through any channel over the Internet and while we aim to use our best efforts to secure and protect your personal information, we cannot guarantee the “perfect security” of any information you transmit or provide to us. You send information over the Internet entirely at your own risk.

5. HOW WE USE AND DISCLOSE PERSONAL INFORMATION

5.1 Our main reasons for collecting your personal information

  1. To provide you with our services and products.
  2. To manage, administer and control the quality of the products and services we provide to you and otherwise conduct our business, for example, to enforce our terms of service or process payment fees and transactions.
  3. To register you for an account on our Website and to assist in the management of your account (for example, sending password reminders).
  4. To market our products and services to you, such as to send you email newsletters.
  5. To enable our related bodies corporate and selected third party partners to send you product and service information that we believe may of interest to you.
  6. To conduct analysis on our Website’s usage, for example to monitor Website use and traffic.
  7. To contact you or respond to your queries, comments and feedback.

 

5.2 Our other reasons for collecting, holding, using and disclosing your personal information

To notify you if you have won a competition, promotion or prize.

  1. To develop and improve our services.
  2. To develop and improve our products.
  3. To ensure the optimum level of security surrounding any account you may hold with 12Follow.
  4. To assist you with your complaints and enquiries.
  5. To assess whether you pose a risk to our business or the businesses of our wider corporate group.
  6. To protect our rights and property of any other 12Follow customer.

5.3 Public Relations
If you win a major prize, we may give your details to external publicity businesses for reasonable promotional activities. By entering into a promotion with one our 12Follow related companies, you will be consenting to this use of your personal information for this purpose.

5.4 Service providers
We may disclose personal information to third party service providers, contractors, suppliers, vendors or organisations that assist us in the management and operation of our business and the provision of services to you, in order to:

  1. provide, manage and administer our products and services and business systems (including mailing houses, printers, advertising agencies, postal services, call centres, providers of customer relationship management (CRM) services, providers of fraud detection services and IT technicians);
  2. operate, maintain and manage our Website and customer database (including, website hosting services and information storage services)
  3. develop and market our products and services (including market research analysts);
  4. comply with Payment Card Industry Standards, and securely manage processing of your credit card payments and storage of your credit card details; and
  5. analyse trends and aggregated demographic information, and target your interests.

5.5 Government bodies/regulators/industry bodies/venues
We may be required to disclose your personal information to (without limitation):

  1. government or regulatory bodies and agencies, gambling regulators, law enforcement agencies or courts of law, if required or authorised to do so by law, for example, in response to a subpoena or legal order, to investigate, prevent or take action regarding suspected illegal activities, fraud or potential threats or to exercise legal rights or defend against claims; and
  2. other organisations that coordinate a sport or racing code or are responsible for the integrity of a sport or racing code.

5.6 Related corporations
We may disclose personal information to our related bodies corporate, including (but not limited to):

  1. TopBetta Holdings Ltd;
  2. TopBetta Pty Ltd;
  3. 12Follow Pty Ltd;
  4. Operis Momentus Pty Ltd; and
  5. other related bodies corporate as required from time to time, so they can:
    1. comply with their obligations under laws, regulations, licence conditions and betting rules; and
    2. send you marketing information directly (see section 5.7).

5.7 Marketing
We may occasionally use and disclose your personal information to:

  1. identify your betting behaviour, habits and preferences;
  2. let you know about upcoming events, promotions and new products/ services or other opportunities, via direct mail, email, SMS, MMS and/or phone calls;
  3. send you product and service information on behalf of third parties; and
  4. enable our related bodies corporate and selected third party affiliates and business partners to send directly to you product and service information which may be of interest to you. From time to time, our affiliates and business partners may disclose your personal information to other third party advertising clients to provide you with further product and service information which may be of interest to you (unless you have indicated to us that you wish to opt out of receiving these communications).

By agreeing to the terms and conditions relating to your 12Follow service(s), you consent to receiving marketing material from us and from our third party partners and affiliates, but you may withdraw that consent at any time by emailing: help@12Follow.com.au and informing us that you wish to opt out.
Each time you are sent a marketing communication, you will be able to opt-out from future marketing communications. You can also opt-out from future marketing communications at any time (email: help@12Follow.com.au). We will promptly action any opt-out request.

5.8 Replacement providers
If we:

  1. transfer responsibility for providing a 12Follow product or service to another business; or
  2. stop providing a 12Follow product or service (or limit it), and another business continues to offer a similar product/service, we may disclose personal information to the other business so the product or service can continue to be provided to you. By agreeing to the terms and conditions for your 12Follow account(s), you consent to this disclosure, but you may withdraw that consent at any time – email: help@12Follow.com

5.9 Monitoring of 12Follow products, including emails
12Follow may monitor and maintain records of the transactions on your 12Follow account(s), including any emails you send to us.
You acknowledge and agree that we may use and disclose information collated during monitoring to third parties, including by releasing your personal information to law enforcement agencies, government authorities or any other regulatory authorities, as authorised or required by law. We will not tell you when we monitor your transactions or if we disclose any personal information obtained.

5.10 Monitoring and recording phone calls
We may monitor and record any telephone conversation with you for the purposes set out in this Privacy Policy. Any personal information that you provide during a recorded telephone call will be collected and managed by us in accordance with this Privacy Policy. We will notify you if your call is being recorded.
You acknowledge and agree to such recordings being made and agree that relevant recordings and details of your calls may be disclosed to law enforcement agencies, regulatory authorities and other authorities in the event of a dispute or as otherwise required or permitted in order to comply with our legal and regulatory obligations. We will not notify you of those disclosures. If you do not wish for your telephone call with 12Follow to be recorded, please notify the 12Follow telephone operator immediately, at the beginning of the telephone call.

5.11 Company sale or restructure
We may disclose your personal information to a buyer in the event of a merger, divestiture, restructuring, reorganisation, dissolution or any other form of sale or restructure of some or all of 12Follow’s assets or those of its holding companies in the circumstances where the personal information is held by 12Follow about its customers forms part of the assets transferred.

5.12 Overseas disclosure of personal information
We may disclose your personal information to overseas recipients such as affiliates or third parties who assist us in the management and conduct of our business or provide us with services. These overseas recipients may assist us in the processing, storage or analysis of your information, processing of credit card payments or provide technical or website support to us.
Where 12Follow discloses your personal information to overseas recipients, these recipients are most likely to be located in the United Kingdom and the United States of America. This list of countries is not exhaustive and may change from time to time.
Important Notice In the event that the processing of your personal information involves the disclosure of any information outside Australia, you acknowledge that, by providing us with your personal information, you consent to such overseas disclosure. By consenting to such disclosure, you acknowledge that:

  1. 12Follow will not be accountable under the Privacy Act 1988 (Cth) for any breach of your privacy by the overseas recipient, and
  2. you will not be able to seek redress under the Privacy Act 1988 (Cth) against 12Follow for any breach of your privacy by an overseas recipient.

Note: Countries outside of Australia may not always have the same or similar privacy and data protection laws and in some cases, foreign law may require us to disclose your personal information overseas, for example to an overseas law enforcement authority. Please be aware that you may not be able to seek redress for a breach of privacy in a country outside of Australia. However, where we do provide your personal information to third parties, 12Follow will take such steps as reasonable to ensure your information is used in accordance with this policy.

6. HOW CAN I ACCESS AND CORRECT MY PERSONAL INFORMATION?

6.1 Access
You have a right to ask for access to the personal information we hold about you. To make a request for access, please contact:
Privacy Officer Address: PO Box 33, Broadmeadow NSW 2292 Telephone: +612 49158685 Fax: +612 49622553 or Email: help@12Follow.com.au
Your personal information will usually be available within 30 days of your request. If there is a fee for accessing your personal information, we will confirm the amount before providing the information.
In some circumstances we may not be able to grant you access to your personal information (for example, if the release of your personal information would have an unreasonable impact on the privacy of others). Please see the APPs for further information. If one of these circumstances applies, we will provide you with a written explanation of the reasons for the refusal, unless it would be unreasonable to do so.

6.2 Corrections
You have a right to ask us to correct the personal information we hold about you. To make a request for the correction of your personal information, please contact the Privacy Officer at:
12Follow Address: PO Box 33, Broadmeadow NSW 2292 Telephone: +612 49158685 or Email: help@12Follow.com
Once we receive your request for correction, we will endeavour to respond to that request within 30 days of receiving your request. It is not always possible to remove or modify information in our databases, but we will take reasonable steps to correct your personal information to ensure that it is accurate, up-to-date, complete, relevant and not misleading. If we decline to make your requested correction, you may request us to attach to your personal information a statement that it is inaccurate, out-of-date, incomplete, irrelevant or misleading.
If we disclose the information to a third party before correcting it, you may request us to notify the third party of the correction we’ve made. We will not charge you to request a correction, for making a correction or for associating a statement with a record.

7. MAKING COMPLAINTS

If you have a concern about how we have handled your personal information, please let us know so we can fix the problem. You can contact us at:
Privacy Officer Address: PO Box 33, Broadmeadow NSW 2292 Telephone: +612 49158685 Fax: +612 49622553 or Email: help@12follow.com.au
To lodge a formal complaint, please send details of your complaint to the Privacy Officer in writing using the address or email address listed above. We will investigate your complaint and attempt to respond within a reasonable time, usually within 30 days.
If your complaint is not resolved by the Privacy Officer, you may be able take it to an external dispute resolution scheme. The Privacy Officer will give you details of the relevant scheme. If your complaint is not resolved by our Privacy Officer or an external dispute resolution scheme, you can refer it to the Office of the Australian Information Commissioner at www.oaic.gov.au.

8. SENSITIVE INFORMATION

We won’t collect sensitive information, such as your:

  1. racial or ethnic origins;
  2. political opinions;
  3. religious or philosophical beliefs;
  4. membership of a political association, professional or trade association or a trade union;
  5. criminal record; or
  6. health information; unless:
    1. you consent to our collection of such information; or
    2. it is required or authorised by law.

9. THIRD PARTY LINKS

Our Website may contain links to or from, other third party websites. These other websites are not subject to this Privacy Policy or our privacy practices and procedures and we are not responsible for the content or privacy practices of these third party websites. This Privacy Policy applies solely to the management of personal information through the 12Follow Website and services. We encourage you to read the privacy policies of these third party websites or contact these websites directly for further information about their privacy processes.

10. HOW LONG CAN 12FOLLOW KEEP MY PERSONAL INFORMATION?

If 12Follow:

  1. no longer needs to use or disclose your personal information for any purpose that is authorised under the Australian privacy laws; and
  2. is not otherwise legally required to retain that information, then it will take reasonable steps to destroy the personal information or ensure it is de-identified.

11. CONTACT US

If you have any other questions or comments about our privacy practices or this Privacy Policy, please contact our Privacy Officer at:
Address: PO Box 33, Broadmeadow NSW 2292 Telephone: +612 49158685 Fax: +612 49622553 or Email: help@12Follow.com.au

Last Updated: 27 October 2016