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SmartB Privacy Policy
When accessing the SmartB website or app, or interacting with us in any other way, you are trusting us with your personal data. We treat our responsibility in relation to personal data very seriously, and comply with the Privacy Act 1988 and other relevant Privacy frameworks. This Privacy Policy describes what information we collect, why we collect it, how it is used and your choices regarding your information.
This Privacy Policy applies to SmartB website, apps, events and other services we operate under the SmartB brand. For simplicity, we refer to all of these as our “Services” in this Privacy Policy. The SmartB website and all related sites, applications, services and tools are the property of Better Business Register Pty Ltd ACN 621 591 026. ‘We’, ‘Us’, ‘Ours’, ‘the Company’ therefore refers to SmartB and Better Business Register Pty Ltd.
This Privacy Policy applies from January 17, 2022 (“Effective date”).
Introduction
You accept this Privacy Policy when you sign up for, access, or use our products, services, content, features, technologies or functions offered on our website and all related sites, applications, and services (collectively “Services”). This Privacy Policy is intended to govern the use of SmartB Services by users (including, without limitation those who use the SmartB Services in the course of their trade or business) unless otherwise agreed through contract. We may amend this Privacy Policy at any time by posting a revised version on our website. The revised version will be effective as of the published effective date. We will provide you with a notice of the updated policy by emailing our current user base. You will be considered as having expressly consented to all amendments to this Privacy Policy if you continue to use our Services use after the policy update and will be legally bound by the new updated Policy. If you do not accept any Changes to the Policy, you should stop using our Services immediately.
Some services may require their own unique privacy policy. If a service has its own privacy policy, then that policy, not this Privacy Policy, applies.
What is Personal Information and why do we collect it?
We collect personal information to provide SmartB Services and for our business operations. If you choose not to provide the information we request from you, we may not be able to provide you with the services you require. We describe the main types of personal information we collect and the main reasons why we collect that information below.
Registration Information
This is the information you provide to us when you register for or acquire our Service. This may include information you provide us to:
- create an account;
- become a subscriber;
- become an advertiser;
- post comments;
- receive a newsletter; or
- enter a competition.
Registration Information includes, for example, your name, email address, gender and birthday.
You are able to use some Company Services without providing any personal information, for example when browsing our services as a casual user.
Device Information
When you use SmartB Services, we collect information sent to us by your computer, mobile phone or other access device. The information sent to us includes data on the pages you access, your computer IP address, device identifiers, the type of operating system you’re using, your location, mobile network information, and standard web log data. Standard web log data includes the browser type you’re using and traffic to and from our site.
When you download or use our mobile applications, or access one of our mobile optimised sites, we may receive information about your location and your mobile device, including a unique identifier for your device. We may use this information to provide you with location-based services, such as advertising, search results, and other personalised content. Most mobile devices allow you to control or disable location services in the device’s settings menu. If you have questions about how to disable your device’s location services, we recommend you contact your mobile service carrier or the manufacture of your particular device.
Public Information and Posts
This includes comments or content that you post to the online platforms and the information about you that comes with those posts. This may include your name, user name, comments, likes, status, profile information and picture(s). Public Information and Posts are available to everyone who views our websites and may be displayed in search results on external search engines, even after you terminate your account with us.
Information from third party Social Media
If you access or login to our Services through a third party social media service or connect our platform to your social media profile, we may also include information from that social media service. This may include:
- your user name for that service;
- any information or content you have permitted the social media service to share with us (such as your profile picture(s), email address, followers or friends lists); and
- any other information you have made public (including other posts you make using your social media profile).
We do not collect your social media profile password. When you access our Services through your social media profile, or when you connect a Company Service to your social media profile, you authorise us to collect and handle your personal information in accordance with this Privacy Policy.
Activity Information
When you use our Services, we also collect information about your transactions and your activities. In addition, we may collect and store any information you provide us when you use our Services, including when you add information on a web form, add or update your account information, participate in community discussions, chats, or dispute resolutions, or when you otherwise correspond with us regarding SmartB Services.
If you use our Services to place or view bets with third party licensed betting operators, we may collect information relating to your bet history. We do not have access to any information you provide directly to the third party licensed betting operator such as any financial or banking information.
Information from Other Sources
Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances we may be provided with information by third parties. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.
We may supplement the information we collect about you with information from other sources. This may include information from publicly available sources (such as other published content) and data providers, as well as information from our business partners or related and affiliated companies in Australia or internationally. Our related companies include those listed on our platforms.
Information in relation to other persons who deal with us
When you apply for a job or contract with us we may collect information about you to help us decide whether to offer you the job or contract. For example, we may collect information about how to contact you, your education or work history, or other information included in your CV or résumé. We may collect this information from you, or from any recruitment consultant, your previous employers, or other referees. This Privacy Policy does not apply to our collection, use and disclosure of information:
- we hold about you once you become an employee;
- we keep after your employment relationship with us ends,
- where that collection, use or disclosure relates to your employee relationship with us and the records we hold about you as an employee.
We also collect personal information about our suppliers and individuals employed by our suppliers (including service and content providers), contractors, dealers, related companies, agents and corporate customers. We will explain why we are collecting this information and how we will use that information, unless it is obvious from the circumstances.
Sensitive Information
Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.
We do not collect any sensitive information from you. However, if we do collect it, it will be used by us only:
- For the primary purpose for which it was obtained
- For a secondary purpose that is directly related to the primary purpose
- With your consent; or where required or authorised by law.
How we use Cookies
When you access the SmartB Services, we (including companies we work with) may place “Cookies” on your computer or other device.
Cookies are small text files that are placed on your machine to help the site provide a better user experience. In general, cookies are used to retain user preferences, store information for things like shopping carts, and provide anonymised tracking data to third party applications like Google Analytics. As a rule, cookies will make your browsing experience better. However, you may prefer to disable cookies on this site and on others. The most effective way to do this is to disable cookies in your browser. We suggest consulting the Help section of your browser or taking a look at the About Cookies website which offers guidance for all modern browsers.
We use these technologies to:
- recognise you as a customer;
- customise the Oktion Services, content and advertising;
- measure promotional effectiveness;
- help ensure that your account security is not compromised;
- mitigate risk and prevent fraud; and
- promote trust and safety across the Oktion Services.
You are free to decline our Cookies if your browser or browser add-on permits, unless our Cookies are required to prevent fraud or ensure the security of websites we control. However, declining our Cookies may interfere with your use of the our Services.
How do we use your information?
We use the information we collect about you to provide our Services to you. As part of our service to you we may use your personal information:
- To operate, maintain, and improve our Services;
- To respond to comments and questions and provide customer service;
- To send information including confirmations, technical notices, updates, security alerts, and support and administrative messages;
- To communicate about promotions, upcoming events, and other news about our Services or other products and services offered by us and our selected partners;
- To link or combine user information with other personal information we get from third parties, to help understand your needs and provide you with better service;
- To develop, improve, and deliver marketing and advertising for the Services;
- To identify you as a user in our system and to build up information about you so we have a picture of you as a user (this is called profiling);
- To facilitate the creation of and secure your account including for identification and verification purposes;
- To personalise our Services and provide you with a tailored experiences;
- For statistical analysis, research and data analysis; and
- To comply with any regulatory requirements.
When we collect your information, we may explain that we will use and disclose your information in other ways. For example, if you win a competition, we may disclose your information to relevant regulatory authorities and publish your details in accordance with the competition terms.
We may also remove certain information or alter the information we collect about you so you can no longer be identified from that information. We do this so that we can use it or disclose it to third parties for other purposes.
Other ways we use your information
- To allow service and content providers to assist us in providing and managing the Company Services. We may make your information available to certain third party service and content providers who help us manage or provide the Company Services or provide Company with related services. This might include providers of cloud services, website hosting service providers, debt collection service providers and direct marketing service providers. These third parties may be located in a range of different countries including the United Kingdom and United States of America. Our agreements with these third party providers require them not to use your information except for the purpose for which your information was provided. We also require them to comply with relevant privacy laws.
- We may offer co-branded services, such as competitions or other promotions together with a third party ("Co-Branded Services"). When this happens, we may share the information you submit in connection with the Co-Branded Service with the third party, or with our service providers who assist us to host Co Branded Services. The third party’s use of your information will be governed by their own privacy policy. We will obtain your consent to share your personal information with the third party. If you do not provide this consent, you may not be able to access that co-branded service.
- From time to time, we may send you promotional materials or other information which we think may interest you. For example, we may send you an invitation to participate in various activities (such as customer surveys) or special offers.
- To protect the rights of Company and others. We may share your information with other third parties where we are lawfully entitled to do so. This includes when we have a reasonable basis to believe that sharing your information is necessary to:
- protect, enforce or defend the legal rights, privacy, safety, or property of Company, our related companies or their employees, agents and contractors (including enforcement of our agreements and our terms of use);
- protect the safety, privacy, and security of users of the Company Services or members of the public;
- protect against fraud or for risk management purposes;
- comply with the law or legal process in any country; or
- respond to requests from public and government authorities.
How do we protect your information?
We use reasonable measures to safeguard the personal information we hold about you from loss, theft and unauthorised use, disclosure or modification.
- We take reasonable steps to prevent unauthorised access to our online and computerised systems by using measures such as firewalls, data encryption, virus detection methods, and password restricted access.
- At our business premises, we may engage security personnel and use ID cards to restrict access to those premises.
- We train our staff to handle your information in accordance with this Privacy Policy and applicable privacy laws.
- We take reasonable steps to ensure that third parties who store or assist us to store your personal information adopt appropriate security measures.
Your Rights
We want you to be in control of your information, so we want to remind you of the following options and tools available to you:
- Access / Update tools in the service. Account settings can help you access, rectify or remove information that you provided to us and that’s associated with your account directly within SmartB platform.
- Device permissions. Mobile platforms can have permission systems for specific types of device data and notifications, such as phone contacts, pictures, location services, push notifications and advertising identifiers. You can change your settings on your device to either consent or oppose the collection or processing of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose functionality.
- Uninstall.You can stop all information collection by an app by uninstalling it using the standard uninstall process for your device. Remember that uninstalling an app does NOT close your account. To close your account, please use the corresponding functionality on the service.
- Account closure You can close your account by using the corresponding functionality directly on the SmartB platform.
We also want you to be aware of your privacy rights. Here are a few key points to remember:
- Reviewing your information. Applicable privacy laws may give you the right to review the personal information we keep about you (depending on the jurisdiction, this may be called right of access, right of portability, right to know or variations of those terms). You can exercise this right by submitting a request to SmartB.
- Updating your information. If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, object to or restrict its processing, please contact SmartB.
For your protection and the protection of all of our members, we may ask you to provide proof of identity before we can answer the above requests.
Keep in mind, we may reject requests, including if we are unable to authenticate you, if the request is unlawful or invalid, or if it may infringe on trade secrets or intellectual property or the privacy or other rights of someone else. If you wish to receive information relating to another member, such as a copy of any messages you received from them through our service, the other member will have to contact us to provide their written consent before the information is released. We may also ask them to provide proof of identity before we can answer the request.
Also, we may not be able to accommodate certain requests to object to or restrict the processing of personal information, notably where such requests would not allow us to provide our service to you anymore. For instance, we cannot provide our service if we do not have your date of birth and thus cannot ensure that you are 18 years of age or older.
Under the Privacy Act 1988 you have the right to lodge a complaint with The Office of the Australian Information Commissioner (OAIC).
If you have any queries or complaints about our Privacy Policy please contact us at:
SmartB
