NEDS PRIVACY POLICY 1. PRIVACY ACT 1988 (CTH) AND THE AUSTRALIAN PRIVACY PRINCIPLES

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1 NEDS PRIVACY POLICY 1. PRIVACY ACT 1988 (CTH) AND THE AUSTRALIAN PRIVACY PRINCIPLES 1.1 NEDS.COM.AU PTY LTD ACN ( NEDS ) is bound by the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs) issued under the Privacy Act. 1.2 NEDS is an Australian registered company which holds a bookmaking and betting licence granted by the Northern Territory Racing Commission. NEDS owns and operates the website, and all associated websites (the Websites). 1.3 NEDS 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). 1.4 You can contact our Privacy Officer to discuss any privacy related queries you may have by privacy@neds.com or telephone ABOUT THIS POLICY 2.1 This Privacy Policy apply to anyone accessing and using the Websites, including but not limited to clients of NEDS. 2.2 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. 2.3 By accessing and/or using NEDS s Website, opening a Betting Account with Neds and/or using 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. 2.4 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 with the date of the changes.

2 2.5 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. 3. KINDS OF INFORMATION WE COLLECT AND HOLD 3.1 This depends on your dealings with us, and the requirements of the laws, regulations, licence conditions and betting rules applying to us. 3.2 Opening accounts To open a NEDS account we need your: 1. name; 2. residential and addresses; 3. date of birth; and 4. telephone number. We may also ask for copies of documents confirming your identity, such as: 1. driver s licence; 2. passport; 3. birth certificate; and/or 4. utility bills 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 withdraw or deposit funds into your account); and 2. some lifestyle or betting frequency information for the purposes of monitoring your betting activity. 3.3 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, address, residential address and contact phone number. 3.4 Information from other NEDS 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.

3 3.5 Anti-Money Laundering/Counter-Terrorism Financing Act 2006 (Cth) In order for NEDS to comply with its obligations under the Anti-Money Laundering/Counter- Terrorism Financing Act 2006 (Cth) (the AML/CTF Act), we may have to: 1. request further personal information from you (e.g. confirmation of your account transactions, your occupation and/or your employer in order to verify your identity); or 2. collect information about you and your transactions on any accounts, including any you send to us, bets you make and any deposits or withdrawals of funds you make in relation to your account; and 3. report certain activity/transactions undertaken by you to external parties. 3.6 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. 4. HOW WE COLLECT AND HOLD PERSONAL INFORMATION 4.1. 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. third parties, such as VEDA, that assist us in verifying your identity or which help us to assess your risk to our business under the AML/CTF Act). 2. other companies related to NEDS 3. to the extent relevant, any State/Territory regulatory bodies to confirm whether you are a voluntarily self-excluded patron in Australia or any other country.

4 4.2 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. 5. HOW DO WE SECURE YOUR PERSONAL INFORMATION? 5.1 NEDS 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. 5.2 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. 5.3 Documents verifying your identity and any credit card information you send us will be stored in a secure database. 5.4 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 security of any information you transmit or provide to us. You send information over the Internet entirely at your own risk. 6. HOW WE USE AND DISCLOSE PERSONAL INFORMATION 6.1 Our main reasons for collecting your personal information 1. To identify you and verify your age and identity. 2. To provide you with our services and products. 3. 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. 4. To register you for an account on our Website and to assist in the management of your account (for example, sending password reminders). 5. To market our products and services to you, such as to send you newsletters. 6. To enable our related bodies corporate and selected third party partners to send you product and service information that we believe may be of interest to you. 7. To conduct analysis on our Website s usage, for example to monitor Website use and traffic. 8. To contact you or respond to your queries, comments and feedback.

5 9. To comply with our legal, regulatory and licensing obligations, including: a) to the State/Territory racing controlling bodies (including thoroughbred, harness and greyhound) under our State/Territory Race Fields Approvals and legislation and our approvals and permits with those bodies; b) to authorised sports controlling bodies (domestic and international) in accordance with integrity agreements and other arrangements with these bodies; and c) under the AML/CTF Act and the rules, legislation and terms and conditions that apply to our gambling licences; 10. To operate self-exclusion, pre-commitment limit, deposit limits and minimum bet exemption programs. 11. For any other purpose for which you provided the information. 6.2 Our other reasons for collecting, holding, using and disclosing your personal information may include: 1. To notify you if you have won a competition, promotion or prize 2. To develop and improve our services. 3. To develop and improve our products. 4. To ensure the optimum level of security surrounding any account you may hold with NEDS. 5. To assist you with your complaints and enquiries. 6. To assess whether you pose a risk to our business or the businesses of our wider corporate group. 7. To protect our rights and property of any other NEDS customer. 6.3 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 NEDS related companies, you will be consenting to this use of your personal information for this purpose. 6.4 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. electronically verify your identity and age (including online) for example, disclosure to third party ID verification service providers such as VEDA; 2. provide, manage and administer our products and services and business systems (including mailing houses, printers, advertising agencies, postal services, call centres,

6 providers of customer relationship management (CRM) services, providers of fraud detection services and IT technicians); 3. operate, maintain and manage our Website and customer database (including, website hosting services and information storage services) 4. develop and market our products and services (including market research analysts); 5. assess risks and comply with our reporting obligations under the AML/CTF Act; 6. comply with Payment Card Industry Standards, and securely manage processing of your credit card payments and storage of your credit card details; and 7. analyse trends and aggregated demographic information, and target your interests. 6.5 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 (such as the police or those responsible for enforcing the AML/CTF Act) 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; 2. respond to an enquiry from a government agency under State or Federal laws (e.g. about child support); 3. gambling regulators, for example, the Northern Territory Racing Commission, to comply with our notification, regulatory, integrity and compliance obligations under our gambling licences; 4. the State/Territory racing controlling bodies (including thoroughbred, harness and greyhound) under the terms and conditions specified in the State/Territory Race Fields approvals and permits granted to NEDS, or agreements entered into with NEDS, by these racing controlling bodies, for example, in response to an integrity request; 5. authorised sports controlling bodies (domestic and international) under the terms and conditions of a sports product fee and integrity agreement; 6. other organisations that coordinate a sport or racing code or are responsible for the integrity of a sport or racing code; and 7. owners/managers/operators of retail agencies and venues from which you have excluded yourself. 6.6 Related corporations We may disclose personal information to our related bodies corporate, as required from time to time, so they can:

7 a) comply with their obligations under laws, regulations, licence conditions and betting rules; and b) send you marketing information directly (see section 6.7). 6.7 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, , 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 (unless you have indicated to us that you wish to opt out of receiving these communications) By agreeing to the terms and conditions for your NEDS account(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 ing: and informing us that you wish to opt out or by clicking on the unsubscribe link on the marketing material . 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 by contacting us as privacy@neds.com). We will promptly action any opt-out request. 6.8 Replacement service providers If NEDS assigns or transfers its business to a third party, and/or transfer responsibility for providing a NEDS product or service to that third party, 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 NEDS account(s), you consent to this disclosure, but you may withdraw that consent at any time by ing: privacy@neds.com 6.9 Monitoring of betting accounts, including s In accordance with our obligations under our gambling licences, gambling legislation generally and the AML/CTF Act, we may monitor and maintain records of the transactions on your NEDS account(s), including any s 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 AUSTRAC or other law enforcement agencies, government authorities or any other regulatory authorities, as authorised or required by law or to comply with our obligations under our gambling licences, gambling legislation or the AML/CTF Act We will not tell you when we monitor your transactions or if we disclose any personal information obtained to AUSTRAC.

8 6.10 Monitoring and recording phone calls We may monitor and record any telephone conversation with you for the purposes set out in this Privacy Policy or in order to comply with our obligations under our gambling licences, gambling legislation generally or the AML/CTF Act 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, for example, our obligations under gambling legislation or the AML/CTF Act. We will not notify you of those disclosures Subject to the mandatory requirement to record telephone calls related to the processing of gambling transactions, if you do not wish for other telephone calls with NEDS to be recorded, please notify the NEDS telephone operator immediately, at the beginning of the telephone call Company sale or restructure 6.11 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 NEDS s assets or those of its holding companies in the circumstances where the personal information is held by NEDS about its customers forms part of the assets transferred Overseas disclosure of personal information We may disclose your personal information to overseas recipients such as operators of internet servers, affiliates or other third parties who assist us in the management and conduct of our business or provide us with information/data management 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 NEDS 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. NEDS will not be accountable under the Privacy Act 1988 (Cth) for any breach of your privacy by the overseas recipient, and

9 2. you will not be able to seek redress under the Privacy Act 1988 (Cth) against NEDS 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, NEDS will take such steps as reasonable to ensure your information is used in accordance with this policy. 7. HOW CAN I ACCESS AND CORRECT MY PERSONAL INFORMATION? 7.1 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: Address: Neds Privacy Officer, PO Box 3321, Newstead QLD privacy@neds.com 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. 7.2 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: Address: Neds Privacy Officer, PO Box 3321, Newstead QLD privacy@neds.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.

10 7.2.4 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. 8. MAKING COMPLAINTS 8.1 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: Address: Neds Privacy Officer, PO Box 3321, Newstead QLD privacy@neds.com 8.2 To lodge a formal complaint, please send details of your complaint to the Privacy Officer in writing using the address or address listed above. We will investigate your complaint and attempt to respond within a reasonable time, usually within 30 days. 8.3 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 9. SENSITIVE INFORMATION 9.1 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; or 3. it is needed in order to provide our problem gambling assistance services, for example: a) to assist in the management of your self-exclusion or voluntary pre-commitment election, or to remove you from a self-exclusion program (which generally requires a copy of a report from a registered gambling counsellor or voluntary pre-commitment election); or

11 b) it is needed to enact special features on your NEDS account(s) (e.g. Minimum Bet Exemptions or deposit limits). 4. The AML/CTF Act may require us to collect certain sensitive information (for example, Know Your Customer information in order to verify your identity), and we may collect this from third parties. In some circumstances, in compliance with our legal and regulatory obligations under the AML/CTF Act, we may not be permitted to inform you that we have collected the sensitive information. 5. The information we collect for these purposes will be stored securely in an AML/CTF Risk Register and in some circumstances, we may not be permitted to provide you with access to this information. In these circumstances, we will provide you with reasons for the refusal for access, unless it would be unreasonable or in breach of our legal obligations to do so. If we consider that you pose a high risk to our business, we may disclose sensitive information about you to government authorities and may use the sensitive information as grounds to stop providing our services to you. We may freeze your account without warning and without telling you we are relying on sensitive information to do so. 10. THIRD PARTY LINKS 10.1 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 NEDS 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. 11. HOW LONG WILL NEDS KEEP MY PERSONAL INFORMATION? 11.1 NEDS will only retain your personal information for so long as it is legally required to do so If NEDS: 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 deidentified. 12. STATEMENT OF NOTIFIABLE MATTERS - CREDIT REPORTING 12.1 In some instances, NEDS may offer you a short-term credit facility / deferred settlement facility as part of placing bets through your Account This Statement of Notifiable Matters contains important information relating to credit reporting, as required under the Privacy Act 1988 and the Credit Reporting Privacy Code.

12 12.3 Credit Information Credit information refers to all information that relates to your credit, including repayment and default information. We collect your credit information in order to provide credit services to you. For more information about the types of credit information that we collect, please refer to our Privacy Policy Credit Reporting Bodies and your Credit Information A credit reporting body is a body permitted to provide certain entities with information about the credit worthiness of an individual. If you apply for credit from us, we may receive a credit report containing your credit information from a credit reporting body. In certain circumstances, we may disclose credit information about you to a credit reporting body. The credit information that we disclose to or receive from a credit reporting body is used for the purposes of determining your eligibility for credit. The credit reporting bodies used by us are Veda and Dun & Bradstreet For further information about the credit information that these organisations hold on you, or for a copy of their credit reporting policy, please refer to their respective websites at or If our credit reporting bodies change, we will notify you by updating this statement Credit reporting bodies may use your personal information in reports that they provide to credit providers (including us) to assist them to assess your credit worthiness If you fail to meet your payment obligations in relation to consumer credit, or if you commit a serious credit infringement, we may be entitled to disclose this information to a credit reporting body Some credit reporting bodies offer pre-selection services to credit providers for direct marketing purposes. In this scenario, credit reporting bodies may use the credit information of individuals disclosed by credit providers to establish lists of individuals that fit a credit provider s marketing criteria. Credit providers can then use this personal information to directly market to those individuals You may request that a credit reporting body not use your personal information for that purpose by contacting them using the details provided above If you believe that you have been, or are likely to be, a victim of fraud, you may request that the credit reporting body not use or disclose your credit reporting information. You should make this request directly to Veda or Dun & Bradstreet using their contact details provided above.