About Winning Edge Investments

PRIVACY POLICY

This is the policy of Horseracing Professionals Pty Ltd (ACN 167 910 705) trading as Winning Edge Investments of Level 1, 22-28 Edgeworth David Avenue, Hornsby, New South Wales, 2077, Australia (Winning Edge or our or we) for dealing with your personal information (Privacy Policy).

Our business and the purpose of collection

We are in the business of providing horse racing and sport betting information, analysis, education, ratings and tips. We collect personal information primarily to provide products and services to you (Purpose).

In particular, we collect your personal information so that we can carry out the following actions:

to provide you with products, services and information that you have requested from us;
to communicate with you, including about products, services and events which might interest you;
to provide you with information or advice;
process payments by you to us for our services;
to create accounts, tax invoices or receipts;
to provide your personal information to third parties that assist us in providing and/or delivering the goods or services you or they have requested;
to consider and respond to feedback from you;
to comply with laws or regulations or to comply with any directions given by regulators or authorities.

We may disclose additional purposes for collection of your personal information in collection statements at the point of collection.

Personal information we collect

When used in this policy, “personal information” has the meaning:

given to that term in the Privacy Act 1988 (Cth); AND
given to “personal data” in the Global Data Protection Regulation (EU) 2016.679 (GDPR)

We may collect the following types of personal information from you:

name;
residential or business address;
email address;
post code;
financial and payment information;
gender;
age and date of birth;
signature;
telephone number.

We do not knowingly collect personal information of minors under 18 years of age.

Sensitive information

Sensitive information is information about you that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs or affiliations, membership of a professional or trade association, membership of a trade union, details of health, disability, sexual orientation or criminal record.

It is our policy to only collect your sensitive information where it is reasonably necessary for our functions or activities and either you have expressly consented or we are required or authorised under law to do so.

How we collect your personal information

Collection of your personal information can occur through the following interactions:

when you communicate with us directly (by email, telephone, direct mail or any other means);
when we interact with you during the course of providing you with the products or services; and/or
when you visit our website and social media pages, or access or contribute to digital platforms and applications managed by us (Online Platforms).

Cookies and IP Address

We collect your IP address and may use temporary (session) cookies or permanent cookies when you access our Online Platforms. This allows us to recognise your browser and track the web pages you have visited.

You can switch off cookies by adjusting the settings on your web browser.

How we hold your personal information

We may hold your personal information in either electronic or hard copy form.

If you provide information to us electronically we retain this information in our computer systems and databases. If you provide information to us in hard copy (paper) this information is normally retained in our files and a copy is made to our electronic files.

Security

We use industry standard security measures to safeguard and protect your information.

Where we become aware of any breach to our security systems that breaches or is likely to result in a breach of your rights or freedoms with respect to your personal information, we will notify you and any supervisory authority as required.

If we are unable to collect your personal information

If we are unable to collect your personal information, some or all of the following may occur:

we may be unable to provide products and services to you;
we may be unable to communicate with you to provide information about products or services that you have procured from us, or may intend to procure in the future;
we may be unable to tailor the content of our marketing communications to suit your preferences;
your experience when interacting with us may be delayed or not as efficient as you may expect.

Disclosure of your personal information

Your personal information may be disclosed in connection with any Purpose to any of the following:

our employees, contractors or service providers, to the extent reasonably necessary to fulfil our obligations to you;
our business advisors, including lawyers, accountants or other professional service providers, to the extent reasonably required;
suppliers, clients and other third parties with whom we have commercial relationships, for business, payment processing, delivery, marketing and related purposes;
to a third party in the event of a merger, acquisition, divestment or sale of our business, noting that your personal information will be treated as a saleable asset of our business;
if required by law (including the Privacy Act and GDPR), to any person authorised by such law.

Overseas disclosure of personal information

We may disclose your personal information to third parties and service providers located overseas in connection with any Purpose, including to overseas cloud computing hosts. We take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information.

Links

Links from our Online Platforms to third party websites that we do not operate or control are provided for your convenience. We are not responsible for the privacy or security practices of websites that are not covered by this Privacy Policy. Third party websites should have their own privacy and security policies which we encourage you to read before supplying any personal information to them.

Direct Marketing

We may contact you with direct marketing communications and information about products or services offered by us or our partners via telephone, email, SMS, or regular mail.

If you have indicated a preference for a method of communication, we will endeavour to use that method wherever practical to do so.

You may opt out of receiving marketing communications at any time by responding via the channel in which you received the marketing communication, or by contacting us (see contact information below). You can unsubscribe from emails by clicking the unsubscribe link on the footer of the email communication you have received.

Opting “In” or “Out”

By clicking “I Agree” or any other button indicating your acceptance of this Privacy Policy, you expressly consent to the collection and use of your personal information in accordance with this Privacy Policy.

An individual may opt to not have us collect their personal information. This may prevent us from offering them some or all of our services and may terminate their access to some or all of the services they access with or through us. They will be aware of this when the privacy principles apply to us:

- - - Opt In. Where the individual will have the right to choose to have information collected and/or receive information from us; or
    - Opt Out. Where relevant, the individual will have the right to choose to exclude himself or herself from some or all collection of information and/or receiving information from us.

If an individual believes that they have received information from us that they did not opt in or out to receive, they should contact us on the contact details set out at the end of this privacy policy.

How you may access your information

You may access your personal information held by Winning Edge by making a request to us via our Site.

Correction of your personal information

If you would like us to update or amend your personal information, please contact us on the contact details set out at the end of this Privacy Policy and we will make the requested amendments.

We may ask you to verify your identity to ensure that personal information we hold is not improperly accessed.

Right to be forgotten

In the event that you decide that you no longer want us to hold your personal information, you may notify us in writing on the contact details set out at the end of this Privacy Policy of your desire for us to delete your personal information on record. We will use our best endeavours and comply with all legal requirements within a reasonable timeframe to delete your personal information, unless we are required by law to retain such information.

GDPR

If you are:

A resident of the European Union accessing our Online Platforms or receiving our Services in Australia; or
accessing our Online Platforms or receiving our Services from within the European Union,

then in addition to our obligations under the Privacy Act, we are required to comply with the GDPR with respect to your Personal Information.

Any reference to “personal information” in this Privacy Policy is also a reference to “personal data” (as defined under the GDPR).

Winning Edge takes the security and privacy of your Personal Information seriously and has prepared this Privacy Policy and taken measures to collect, process and hold all Personal Information in compliance with both the Privacy Act and GDPR regardless of the user. Therefore, no additional terms for GDPR users are required.

Complaints and Requests

If you feel your privacy has been breached or you wish to make a request in relation to your personal information, please contact us using the following contact information setting out the circumstances and reasons for your complaint or request:

Privacy Officer

Address: Level 1, 22-28 Edgeworth David Avenue, Hornsby, New South Wales, 2077

Email: Email us using the 'Contact Us' form at www.winningedgeinvestments.com