Privacy Policy

POLICY STATEMENT

This Privacy Policy ("Policy") sets out the manner in which personal information is collected, used, stored, and disclosed by The Play Australian Games website ("we", "us", or "our") in connection with the operation of the digital platform accessible at https://playaustraliangames.com ("Website"). This Policy applies to all individuals who access or use the Website or any associated services, features, technologies, or communications offered by or on behalf of The Play Australian Games website under the trading name Play Australian Games.

This Policy is governed by the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs), and all other applicable legislation, including the Spam Act 2003 (Cth), the Competition and Consumer Act 2010 (Cth), and licensing and regulatory obligations applicable to authorised lottery operators in the Northern Territory of Australia. This Policy further reflects compliance with advertising and data collection requirements imposed by Google, Microsoft, Meta, and other applicable third-party platforms under their respective advertising terms and policies.

By accessing or using the Website, you acknowledge that you have read and understood this Policy and expressly consent to the collection, handling, storage, use, and disclosure of your personal information in accordance with its terms.

All requests, enquiries, or complaints relating to this Policy must be submitted in writing to: support@playaustraliangames.com

TABLE OF CONTENTS

1. INFORMATION WE COLLECT
2. PURPOSES FOR PROCESSING PERSONAL INFORMATION
3. LEGAL BASES FOR PROCESSING
4. DISCLOSURE OF PERSONAL INFORMATION
5. COOKIES AND TRACKING TECHNOLOGIES
6. DATA RETENTION
7. DATA SECURITY
8. USER ELIGIBILITY AND AGE VERIFICATION
9. YOUR RIGHTS UNDER AUSTRALIAN PRIVACY LAW
10. DO-NOT-TRACK AND COOKIE CONTROLS
11. CHANGES TO THIS POLICY
12. CONTACT DETAILS FOR PRIVACY ENQUIRIES

1. INFORMATION WE COLLECT

We collect personal information directly from you, and indirectly through your use of the Website and its associated technologies. The categories of information collected include:

Personal information that you voluntarily provide to us through account registration, identity verification, draw entry, customer support, communication preferences, or participation in promotional campaigns. This may include your full legal name, date of birth, residential address, email address, telephone number, user credentials (encrypted), verification documentation, payment references, transaction history, and communication records.

Technical and behavioural information that is automatically collected in connection with your access to the Website, including your IP address, device and browser type, operating system, page views, navigation paths, session durations, and interaction data. This information may be associated with your user account where required for fraud prevention, account integrity, compliance auditing, or platform optimisation.

We do not collect sensitive personal information (as defined under the Privacy Act 1988 (Cth)) except where required by law or regulatory condition, including for the purpose of age verification, identity validation, or compliance with licensing obligations imposed on gambling providers in Australia.

You are responsible for ensuring that all personal information provided is accurate, complete, and current. You must notify us of any changes to your personal information using the contact details provided in Section 12 of this Policy.

2. PURPOSES FOR PROCESSING PERSONAL INFORMATION

We process personal information strictly for lawful purposes connected with the operation of the Website and the provision of services offered by Play Australian Games. These purposes include:

• (a) the establishment, administration, and maintenance of your user account;
• (b) the processing of lottery entries and facilitation of lawful participation in government-authorised draws;
• (c) the verification of your identity and eligibility in accordance with regulatory requirements;
• (d) the execution of payments, withdrawals, and prize fulfilment;
• (e) the provision of customer support, technical assistance, and user communications;
• (f) the prevention, detection, and investigation of fraudulent, unauthorised, or unlawful conduct;
• (g) compliance with legal obligations imposed by Australian law, regulatory authorities, or licensing conditions;
• (h) the issuance of legally required notices, confirmations, and transaction records;
• (i) the generation of anonymised or aggregated data for internal governance, audit, and platform administration purposes;
• (j) the delivery of promotional materials or marketing communications, where permitted by law or consented to by you.

All processing of personal information is conducted in accordance with the Australian Privacy Principles and applicable data protection requirements, and is subject to internal controls designed to ensure data minimisation, accuracy, and purpose limitation. Personal information is not used for purposes unrelated to its original collection unless authorised by law or valid consent.

3. LEGAL BASES FOR PROCESSING

We process your personal information on the following legal bases, as applicable under the Privacy Act 1988 (Cth) and other relevant legislation:

• (a) Consent – Where you have given express consent to the collection and use of your personal information for specified purposes, including but not limited to receiving direct marketing or allowing cookie-based tracking. You may withdraw consent at any time by contacting support@playaustraliangames.com.
• (b) Contractual Necessity – Where processing is necessary to deliver services requested by you, including lottery entry management, account operations, prize allocation, and associated transactional services.
• (c) Legal Obligation – Where processing is required to comply with legal and regulatory duties, including those arising under anti-money laundering legislation, the Northern Territory licensing regime, and relevant consumer protection laws.
• (d) Legitimate Interests – Where processing is necessary to protect our legitimate operational, commercial, or legal interests, including platform security, service quality, fraud mitigation, and lawful risk management, provided such interests are not overridden by your privacy rights.

We do not process personal information without a valid legal basis. Where required by law, we will take reasonable steps to inform you of the basis relied upon prior to commencing processing.

4. DISCLOSURE OF PERSONAL INFORMATION

We may disclose personal information to third parties strictly as required for the lawful operation of the Website, performance of contractual obligations, compliance with legal duties, or in accordance with your express instructions.

Disclosure may occur to the following categories of recipients:

• (a) identity verification providers, credit reference agencies, or age verification services engaged to confirm user eligibility and regulatory compliance;
• (b) licensed payment processors, financial intermediaries, and reconciliation providers for the purpose of executing and confirming lawful transactions and withdrawals;
• (c) infrastructure hosting providers, cloud storage operators, and technical service vendors contracted to provide secure and scalable platform support;
• (d) analytics and advertising platform providers (including Google, Microsoft, Meta, and affiliate networks) for the purpose of campaign attribution, remarketing, conversion tracking, and compliance with advertising policies, subject to consent and applicable opt-out mechanisms;
• (e) regulatory authorities, law enforcement agencies, or governmental departments where required by warrant, subpoena, notice, or statutory reporting obligation;
• (f) auditors, legal counsel, compliance consultants, or dispute resolution bodies engaged to assist in the investigation or resolution of regulatory, legal, or contractual matters;
• (g) parties to any actual or proposed merger, acquisition, restructure, financing, or sale of assets, to the extent necessary to facilitate due diligence or operational succession.

All third-party recipients of personal information are bound by legally enforceable obligations of confidentiality, data protection, and purpose limitation. Personal information may not be used by third parties for any independent or unauthorised purpose.

We do not sell, rent, trade, or otherwise commercialise personal information to third parties for unrelated direct marketing or profiling purposes.

Where personal information is transferred outside Australia, we ensure that the overseas recipient is subject to equivalent privacy obligations, or that the transfer is otherwise permitted under the Privacy Act 1988 (Cth). Where required, we will obtain your express consent before any such international transfer occurs.

5. COOKIES AND TRACKING TECHNOLOGIES

The Website uses cookies and equivalent tracking technologies to facilitate secure account access, optimise performance, assess user engagement, and support lawful advertising and promotional campaigns.

Cookies are data files stored on your device that allow us to identify sessions, remember preferences, and deliver relevant content. Cookies may be classified as either strictly necessary (essential for functionality) or non-essential (used for performance, analytics, or marketing).

We deploy tracking technologies only in accordance with the Australian Privacy Principles, the Spam Act 2003 (Cth), and the consent and data use requirements of Google Ads, Microsoft Ads, Meta, and related third-party platforms. No non-essential cookies will be placed until you have provided affirmative consent through our cookie consent interface.

The following technologies are used on the Website:

You may manage your cookie preferences by:

• Responding to the cookie consent prompt displayed upon first access;
• Adjusting your browser settings to block or delete cookies; or
• Using opt-out tools provided by relevant advertising vendors.

Refusal of non-essential cookies will not restrict access to the Website, although certain personalised features may not be functional or fully optimised.

6. DATA RETENTION

We retain personal information only for as long as is reasonably necessary to fulfil the purposes for which it was collected, or as required to comply with applicable law, licensing obligations, audit requirements, or risk management processes.

Retention durations are determined by reference to the following factors:

• (a) operational necessity, including active account management, dispute resolution, and transaction fulfilment;
• (b) mandatory retention periods under financial services, taxation, and anti-money laundering (AML) and counter-terrorism financing (CTF) laws;
• (c) regulatory licence conditions imposed under the Northern Territory gambling regime;
• (d) statutory limitation periods relevant to contractual enforcement or legal claims;
• (e) documentation and recordkeeping obligations imposed by applicable authorities.

Upon account closure or termination, personal information will be retained only to the extent required for legal compliance, evidentiary integrity, or security monitoring. Once such retention is no longer required, the data will be securely deleted or irreversibly anonymised.

Backup data may be retained in encrypted storage environments for disaster recovery and compliance continuity. Access to archived data is strictly restricted and monitored.

Requests for deletion will be evaluated in accordance with the Privacy Act 1988 (Cth) and the criteria set out in Section 9 of this Policy.

7. DATA SECURITY

We implement and maintain comprehensive technical, administrative, and physical safeguards to protect personal information from loss, misuse, unauthorised access, alteration, or disclosure.

Security measures include:

• Encryption of data in transit using Transport Layer Security (TLS) protocols;
• Hosting infrastructure with segmented access zones, firewall protection, and secure authentication;
• Multi-factor authentication (MFA) and role-based access controls for administrative systems;
• Regular vulnerability assessments, penetration testing, and external security reviews;
• Continuous monitoring for suspicious activity, anomalies, or unauthorised attempts to access platform assets;
• Separation of user data from internal operations and third-party systems under a strict least-access policy.

Despite these measures, no system can be guaranteed as fully secure. Users are responsible for maintaining the confidentiality of their login credentials and must notify us immediately of any suspected unauthorised access to their account.

In the event of a data breach affecting personal information, we will take all steps required under the Notifiable Data Breaches scheme established by the Privacy Act 1988 (Cth), including mandatory notification to affected individuals and the Office of the Australian Information Commissioner (OAIC), where applicable.

8. USER ELIGIBILITY AND AGE VERIFICATION

Access to the Website and participation in any services offered by Play Australian Games is strictly limited to individuals who are eighteen (18) years of age or older.

This restriction is imposed to ensure compliance with applicable gambling legislation, age-based eligibility requirements, and responsible gaming obligations under Northern Territory licensing conditions.

We implement identity and age verification procedures during account creation and at any time deemed necessary for ongoing compliance. If a user is identified or reasonably suspected to be under the age of 18:

• (a) the user account will be immediately suspended or permanently terminated;
• (b) all personal information associated with the account will be erased or anonymised;
• (c) we may notify relevant regulatory or law enforcement authorities, as required by law.

We do not knowingly solicit, process, or retain personal information relating to minors. If you become aware of a minor using the Website or submitting personal information through any channel, you must immediately notify us at support@playaustraliangames.com.

9. YOUR RIGHTS UNDER AUSTRALIAN PRIVACY LAW

As an individual whose personal information is collected and processed by Play Australian Games, you may, subject to verification and legal limitations, exercise the following rights under the Privacy Act 1988 (Cth):

• (a) Right of Access – You may request confirmation of whether we hold personal information about you and obtain a copy of such information.
• (b) Right of Correction – You may request correction of any personal information that is inaccurate, incomplete, or outdated.
• (c) Right of Erasure – You may request deletion of your personal information where it is no longer required for any lawful purpose and no legal or regulatory obligation prevents erasure.
• (d) Right to Object – You may object to the use of your personal information for direct marketing or analytical profiling purposes.
• (e) Right to Restrict Processing – You may request that we temporarily suspend processing of your information under certain conditions.
• (f) Right to Withdraw Consent – Where processing is based on your prior consent (e.g., for marketing or non-essential cookies), you may withdraw such consent at any time.
• (g) Right to Data Portability – Where technically feasible, you may request a copy of your personal information in a structured, machine-readable format.

We may require you to verify your identity before acting on any such request to protect the security and integrity of your personal information. Requests must be submitted in writing to support@playaustraliangames.com. We will respond to all valid requests within thirty (30) calendar days unless an extension is legally permitted.

We may decline a request where:

• the information is required to comply with a legal obligation;
• the request is manifestly unfounded, repetitive, or excessive;
• disclosure would impact the privacy of others or breach applicable laws;
• the information must be retained for anti-money laundering (AML), counter-terrorism financing (CTF), licensing, taxation, or dispute resolution purposes.

If you are dissatisfied with our response, you may lodge a formal complaint with the Office of the Australian Information Commissioner (OAIC) via https://www.oaic.gov.au.

10. DO-NOT-TRACK AND COOKIE CONTROLS

Some web browsers and mobile applications allow users to transmit a “Do Not Track” (DNT) signal to indicate a preference to disable cross-site tracking.

At present, no legally binding or industry-wide standard for recognising DNT signals exists in Australia. Accordingly, the Website does not respond to DNT signals at this time.

We continue to monitor developments in Australian privacy law and may update our implementation of DNT recognition if required by law, guidance from the OAIC, or as mandated by platform policy.

Users may exercise control over tracking through the following measures:

• Adjusting consent preferences using our on-site cookie banner;
• Using browser controls to block, restrict, or delete cookies and tracking technologies;
• Employing opt-out mechanisms made available by advertising platforms (e.g., Google Ads Settings, Microsoft Advertising Opt-Out).

Refusing tracking cookies will not affect your ability to access the Website, but may limit the functionality or relevance of certain features.

11. CHANGES TO THIS POLICY

We may update or amend this Privacy Policy at any time to reflect changes in law, regulatory guidance, operational practices, platform functionality, or data processing activities.

Any changes will be published on the Website and identified by an updated “Last Updated” date at the top of this Policy. Where changes materially affect your rights or our obligations, we will provide additional notice by:

• publishing an announcement on the Website;
• sending an email notification to your registered contact address (where applicable); or
• using any other legally permitted method of communication.

You are responsible for reviewing this Policy periodically to ensure that you remain informed of how your personal information is handled.

Continued use of the Website after any amendment constitutes your acceptance of the revised Policy. If you do not agree to any change, you must immediately discontinue use of the Website and close your account.

12. CONTACT DETAILS FOR PRIVACY ENQUIRIES

All privacy-related enquiries, complaints, or data access requests must be submitted in writing to: support@playaustraliangames.com

Requests to access, correct, or delete personal information must be made using the contact details above. We may request identity verification before processing your request.

All valid requests will be assessed in accordance with our obligations under the Privacy Act 1988 (Cth). We will respond within thirty (30) calendar days or such additional time as may be permitted under law.

We may decline to act on a request where:

• compliance would contravene an Australian law or court order;
• the request is manifestly unfounded or excessive;
• deletion would impair rights or obligations under gambling licence conditions, AML/CTF regulations, or taxation law; or
• the information is required for evidentiary, compliance, or operational continuity purposes.

If you are dissatisfied with our response or believe your privacy rights have been infringed, you may escalate your concern to the Office of the Australian Information Commissioner (OAIC) by visiting: https://www.oaic.gov.au