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OUR SECRET SPOT – PRIVACY POLICY

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LLDB PTY. LTD. T/A OUR SECRET SPOT – PRIVACY POLICY

 

Overview

This Privacy Policy describes how LLDB Pty Ltd ACN 167 397 168 (“Our Secret Spot”, “us” ,”its”, “we”, “our”) and its related entities, collect, hold, use and disclose personal information consistent with the Privacy Act 1988 (Cth) (“Act”) as amended by the Privacy Amendment (Enhancing Privacy Protection) Act 2012 (Cth) (“Amendment Act”) and the Australian Privacy Principles found in that Act.

This Privacy Policy is also a notification to individuals of the matters required to be notified by the Australian Privacy Principles.

1. Who Is Our Secret Spot?

Our Secret Spot a swingers club that that provides a high end venue for singles and couples. In order to perform our functions and deliver these services, we need to collect, use and disclose your personal information.

Our Secret Spot is firmly committed to protecting the privacy and confidentiality of personal information and to maintaining various physical, electronic and procedural safeguards to protect personal information in our care.

By providing personal information to us (either directly or allowing another person to do so on your behalf), you agree that this Privacy Policy will apply to how we handle your personal information and you consent to us collecting, using and disclosing your personal information as detailed in this Privacy Policy.

If you do not agree with any part of this Privacy Policy, you must not provide your personal information to us. If you do not provide us with your personal information, or if you withdraw a consent that you have given under this Privacy Policy, this may affect our ability to provide services to you or negatively impact the services we can provide to you.

 

2. What Personal Information Does Our Secret Spot Collect?

Personal information has the meaning given under the Privacy Act 1988 (Cth), being information or an opinion about an identified individual, or an individual who is reasonably identifiable:

• whether the information or opinion is true or not; and
• whether the information or opinion is recorded in a material form or not.

The type of personal information Our Secret Spot collects is the information required to facilitate and manage of our business.

Generally, this includes:

• name/s;
• contact details (e.g. residential & postal address, email address, telephone number(s), facsimile number);
• where you sign up for an account on our Online Members Area platform, profile data including your username and password for the platform, profile picture, and content you post, send, receive and share through our platform;
• where you apply for a role with us, occupation and employer information;
• financial information (e.g. credit/debit card number, security number, expiry date or other billing information);
• passport or driver licence details;
• our loyalty program; and
• other details relevant to the management of our business.

 

We also collect information that is required for use in our business activities and those of our related entities, including video surveillance footage used for security purposes, and other relevant personal information you may elect to provide to us.

 

In some circumstances, we may collect personal information from you which may be regarded as sensitive information under the Privacy Act 1988 (Cth). Sensitive information includes (without limitation):

• racial or ethnic origin;
• philosophical or religious beliefs or affiliations;
• sexual preferences or practices;
• criminal record;
• membership of political, professional or trade associations;
• biometric and genetic information;
• financial information;
• and health information and genetic information.

 

We will only collect sensitive information in compliance with the Privacy Act 1988 (Cth), with your consent and where it is reasonably necessary for, or directly related to one or more of its functions or activities, unless it is otherwise required or authorised to do so by law.

 

In providing your sensitive information, you consent to us in using and disclosing your sensitive information for the purpose for which it was collected, unless you subsequently withdraw your consent or consent for it to be used for another purpose.

3. How Does Our Secret Spot Collect Personal Information?

Where practical, we collect personal information directly from you when we deal with you in person, by telephone, letter, facsimile, email or when you visit our website.

However, we may also collect your personal information when you:

• purchase or make enquiries about products or services;
• complete a form, such as registering for an account on our Online Members Area platform;
• attend our events;
• enter competitions or register for promotions;
• request brochures or other information;
• subscribe to receive our marketing materials (e.g. e-newsletters);
• apply for a job or work experience.

 

Unless you choose to do so under a pseudonym or anonymously, we may also collect your personal information (other than sensitive information) when you complete surveys or provide us with feedback.

 

In some circumstances, it may be necessary for us to collect personal information about you from a third party. This includes where a person makes a booking and or purchase of tickets on your behalf. Where this occurs, we will rely on the authority of the person making the booking and or the purchase to act on behalf of the person who the booking and or purchase of the tickets is made for.

 

By providing your personal information to us, either directly or through a family member, friend or other agent or representative in connection with the booking, purchase of tickets or related service, you will be deemed to have consented to your personal information being collected, used and disclosed in accordance with this Privacy Policy.

 

Where you make a booking and or purchase of tickets on behalf of another person, you agree you have obtained the consent of the other person for us to collect, use and disclose the other person’s personal information in accordance with this Privacy Policy and that you have otherwise made the other person aware of this Privacy Policy.

 

You should let us know immediately if you become aware that your personal information has been provided by another person without your consent or if you did not obtain consent before providing another person’s personal information.

4. How Does Our Secret Spot Hold And Secure Personal Information?

Personal information collected by us is held, stored and managed on a secure online storage database by a third-party data storage provider.

 

We have implemented a range of physical, electronic and managerial security procedures and measures to prevent the misuse, interference, loss, unauthorised access, modification or disclosure of your personal information including:

• secure encryption technologies;
• firewalls and intrusion detection systems;
• virus protection back-ups;
• restricted access; and
• regular server vulnerability and penetration testing.

 

Personal information received by Our Secret Spot may only be accessed by our authorised employees and contractors who may require access in connection with the purposes described in this Privacy Policy.

We regularly review our security technologies and strives to protect any personal information provided to us.

We will destroy or de-identify personal information once we no longer require it for our business purposes, or as required by law.

We are not responsible for any third party’s actions or their security controls with respect to information that third parties may collect or process via their websites, services or otherwise.

5. How Does Our Secret Spot Use And Disclose Personal Information?

Where you contact us in relation to a booking or query, the primary purpose for which we collect your personal information is to provide you with advice and/or to assist you with booking and/or purchase of any related products and services.

If you do not provide us with your personal information, we may not be able to provide you with our products or service.

 

However, the purpose for collection may differ depending on the particular circumstances as disclosed in this Privacy Policy (e.g. collection of your personal information for the purpose of your participation in a competition, provision of feedback, etc).

 

By continuing to use our products and services and/or by providing us with personal information (or allowing another person to do so on your behalf), you consent to us in using and disclosing your personal information for the purpose for which it was collected, and, where permitted by your local data protection laws, for any related secondary purpose which it believes you would reasonably expect.

 

The secondary purposes for which we collect, uses and discloses personal information include:

• providing you with services and tools you choose to use (e.g. saving personal information to allow for pre-population of online forms);
• identification of fraud or error;
• regulatory reporting and compliance;
• developing and improving our products and services;
• servicing relationships with you by, among other things, creating and maintaining a customer profile to enable our brands to service you better or presenting options on our website we think may interest you based on your browsing and preferences;
• involving you in market research, gauging customer satisfaction and seeking feedback regarding our relationship with you and/or the services provided;
• to facilitate participation in our loyalty programs;
• for research and analysis in relation to our business and services, including but not limited to trends and preferences in products and services and use of its website;
• internal accounting and administration;
• to comply with legal obligations and any applicable laws; and
• other purposes as authorised or required by law.

 

Online Members Area

 

We collect, hold, use and disclose your personal information for the purposes of enabling you to access and use our software, including to provide you with a login.

 

We may access and review private messages between users on our platform when necessary for the purposes of investigating complaints or suspected non-compliant with our Online Members Area Terms and Conditions available here: (link) (including our Community Guidelines available here: (link). This allows us to look into potential misuse of the platform, enforce our policies, and ensure users are adhering to the rules and guidelines.

 

Promotional/marketing materials

 

We may also use your personal information to send you targeted marketing activities relating to our products and services (and those of third parties) that we think may interest you, unless you have requested not to receive such information.

 

These may include but are not limited to mail outs, electronic marketing (including online targeted marketing), notifications and telephone calls. We will only use your personal information to send electronic marketing materials to you (i.e. e-newsletters, email, SMS, MSM and iM) if you have opted-in to receive them.

 

You can subscribe to receive e-newsletters and other electronic promotional/marketing materials by following the relevant links on our website or requesting one of its consultants to do so for you.

 

Should you no longer wish to receive promotional/marketing material from us, participate in market research or receive other types of communication from it, you may contact and advise us by referring to point 9 of this Privacy Policy: ‘Feedback / Complaints / Contact’.

 

You can unsubscribe from receiving electronic marketing materials by following the unsubscribe prompt in your email, SMS, MSM, iM or other form of electronic marketing.

6. Is Personal Information Disclosed To Third Parties?

We will only disclose personal information (excluding sensitive information) to third parties where it is necessary as part of our business, where we have your consent, or where permitted by law.

• We may disclose your personal information (excluding sensitive information) to third parties such as: our contractors, suppliers and service providers;
• in each of the circumstances set out in point 5: ‘How does Our Secret Spot use and disclose personal information?’;
• suppliers of IT based solutions that assist in providing products and services to you (e.g. external data hosting providers);
• publishers, printers and distributors of marketing material;
• event organisers;
• marketing, market research, research and analysis and communications agencies;
• mailing houses, freight services, courier services; and
• external business advisers (such as lawyers, accountants, auditors and recruitment consultants);
• our related entities and brands;
• a prospective purchaser, in connection with a merger, acquisition, reorganisation or sale of Our Secret Spot, or any of its related entities, or of assets of Our Secret Spot or any of its related entities;
• a person making your booking and or purchase on your behalf, where you are booking and or purchasing made on your behalf by another person;
• a person who can verify to us that they have a relationship with you, where you are not contactable, the person correctly answers its required security questions and the request is, in its opinion, in your interest (e.g. where the person is concerned for your welfare or needs to undertake action on your behalf due to unforeseen circumstances);
• as required or authorised by applicable law, and to comply with its legal obligations including applicable privacy/data protection laws;
• health law to comply with its legal obligations and any applicable government requirements;
• government agencies and public authorities, to comply with a valid and authorised request, including a court order or other valid legal process;
• various regulatory bodies and law enforcement officials and agencies, including to protect against fraud and for related security purposes; and
• enforcement agencies where we suspect that unlawful activity has been or may be engaged in and the personal information is a necessary part of its investigation or reporting of the matter (e.g. prevention, detection, investigation, prosecution or punishment of criminal offences).

 

We will only disclose sensitive information with your consent or where permitted by law. This means that we may disclose sensitive information to:

• our employees, contractors and/or related entities;
• IT service providers, data storage, web-hosting and server providers;
• professional advisors;
• a prospective purchaser, in connection with a merger, acquisition, reorganisation or sale of Our Secret Spot, or any of its related entities, or of assets of Our Secret Spot or any of its related entities;
• courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
• third parties to collect and process data, such as analytics providers and cookies; and
• any other third parties as required or permitted by law, such as where we receive a subpoena.

 

By continuing to use our services and/or by providing us with your personal information (or allowing another person to do so on your behalf), you consent to that personal information being processed, transferred and/or disclosed by it for the purpose for which it was collected and for any related secondary purpose which we believe you would reasonably expect.

 

Please note that where this Privacy Policy uses the word ‘disclose’, this includes to transfer, share (including verbally and in writing), send, or otherwise make available or accessible your personal information to another person or entity.

 

Other than the above, we will not disclose your personal information without your consent unless it reasonably believe that disclosure is necessary to lessen or prevent a threat to life, health or safety of an individual or to public health or safety.

Social Media Integrations

Our website and mobile applications may use social media features and widgets such as “Like” and “Share” buttons/widgets) (“SM Features”). These are provided and operated by third party companies (e.g. Facebook) and either hosted by a third party or hosted directly on our website or mobile application.

 

SM Features may collect information such as the page you are visiting on our website/mobile application, your IP address, and may set cookies to enable the SM Feature to function properly.

 

If you are logged into your account with the third party company, then the third party may be able to link information about your visit to and use of our website or mobile applications to your social media account with them. Similarly, your interactions with the SM Features may be recorded by the third party.

 

In addition, the third party company may send our information in line with their policies, such as your name, profile picture, gender, friend lists and any other information you have chosen to make available, and we may share information with the third party company for the purposes of serving targeted marketing to you via the third party social media platform. You can manage the sharing of information and opt out from targeted marketing via your privacy settings for the third party social media platform.

 

Your interactions with these SM Features are governed by the privacy policy of the third party company providing them. For more information about the data practices of these third party companies, and to find out more about what data is collected about you and how the third party uses such data, please refer to their privacy policy directly.

IP Addresses

When you access our website, use any of its mobile applications or open electronic correspondence or communications from us, our servers may record data regarding your device and the network you are using to connect with it, including your IP address.

 

We may use IP addresses for system administration, investigation of security issues and compiling anonymised data regarding usage of its website and/or mobile applications. We may also link IP addresses to other personal information it holds about you and use it for the purposes described above (e.g. to better tailor its marketing and advertising materials, provided you have opted in to receive electronic marketing).

Linked Sites

Our website may contain links to third party websites over which we have no control. We are not responsible for the privacy practices or the content of such websites.

We encourage you to read the privacy policies of any linked third party websites you visit as their privacy policy and practices may differ from this Privacy Policy.

7. Is Personal Information Transferred Overseas?

We may disclose your personal information to certain overseas recipients, as set out below. By providing your personal information to us for the purpose of booking and otherwise purchase of our tickets and related products and services for you, you consent to our disclosure of your personal information to these overseas recipients for that purpose.

 

Third party service providers located overseas

 

We may also disclose your personal information to third parties located overseas for the purpose of performing services for us, including the storage and processing of such information.

 

Generally, we will only disclose your personal information to these overseas recipients in connection with facilitation of your booking and or purchase to enable the performance of administrative and technical services by them on our behalf.

 

We may use key service providers and deal with organisations located overseas. We will only disclose your personal information overseas in accordance with the Australian Privacy Principles.

However, if at any time you have any specific questions about where or to whom your personal information will be sent, please contact us by referring to point 10: ‘Feedback / Complaints / Contact’.

 

8. Access To And Correction Of Personal Information

You are entitled to access any personal information we may hold about you in accordance with the Privacy Act 1988 (Cth).

 

Where personal information held is not accurate, complete or up-to-date or the information is irrelevant or misleading, you may ask us to correct that personal information, and it will respond to your request within a reasonable time.

 

We reserve the right to confirm the identity of the person seeking access or correction to personal information before complying with such a request.

 

We also reserve the right to deny you access for any reason permitted under applicable law. If we deny access or correction, we will provide you with written reasons for such denial unless it is unreasonable to do so and will note your request and the denial of same in its records.

 

If you wish to access or seek correction of any personal information held by us please contact us by referring to point 10:‘Feedback / Complaints / Contact’.

9. Feedback / Complaints / Contact

If you have any enquiries, comments or complaints about this Privacy Policy or our handling of your personal information, please contact our Privacy Officer in writing as follows:

 

Attention: Privacy Officer

Our Secret Spot

Post: 191 Parramatta Road, Annandale, NSW 2038

Phone: 0478 131 769

 

Our Privacy Officer will respond to any enquiries or complaints promptly in an attempt to resolve it in a timely manner.

 

If the complaint remains unresolved, you have the option of notifying the Office of the Australian Information Commissioner (OAIC). Contact details can be found at OAIC’s website: www.oaic.gov.au

 

10. Changes To Our Policy

We may amend this Privacy Policy from time to time.

 

If we make a change to this Privacy Policy, the revised version will be posted on the website as soon as practicable. It is your responsibility, and Our Secret Spot encourages you, to check the website from time to time in order to determine whether there have been any changes.

 

(Last update 8th August 2024)

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