Privacy Policy
INTRODUCTION
ThePillars Pty Ltd (ACN 677 200 592) trading as ThePillars (referred to as “we“, “us”. “ThePillars”, or “the Club”) is committed to protecting the privacy of our members and stakeholders. This policy outlines the principles and practices we follow in safeguarding the personal information you entrust to us.
SCOPE OF THIS POLICY
This policy covers the collection, use, storage, and disclosure of personal information as per the Privacy Act 1998 (Cth). For further details or complaints about the use of personal data, please contact us using the provided details at the end of this document.
In this policy ‘personal information’ refers to any information that can uniquely identify an individual.
HOW WE COLLECT INFORMATION
We collect personal information through various interactions, with you.
We collect your Personal Information when you:
- apply to become a member of the Club;
- visit and/or make a purchase from the Club;
- visit our social media accounts;
- signup to ThePillars newsletter
- download and use ThePillars mobile app;
- communicate directly with ThePillars either in person, online, on the phone or at the Club;
- visit one of our restaurants, bars or the health and wellness centre including accessing our services, or buying food or goods in store.
WHAT INFORMATION WE COLLECT
The personal information collected by ThePillars during your membership application includes, but is not limited to, your name, address, occupation, date of birth, proof of identity, and contact details.
Additionally, usage of your membership card within the Club, including promotions and transactions, is recorded and tracked. If you download our mobile app via the iTunes or Android stores and link it to Facebook, we automatically obtain the following information (if stored on Facebook): Date of Birth, Gender, Email, Phone Number, Number of Friends, and Relationship Status.
At or before the time of collection, ThePillars will, if reasonable in the circumstances, inform the individual of:
- the identity and contact details of ThePillars,
- the purposes for which the personal information is being collected,
- how to update details held in the membership record,
- any information required by law,
- any consequences of not providing the required information, and
- the location of an accessible copy of ThePillars' Privacy Policy.
All sensitive information is collected only with the individual’s consent or as required by law or permitted by the Privacy Act. ThePillars will not use or disclose your personal information for any other purpose without your consent, unless permitted under the Privacy Act.
Information Storage and Disclosure
Storage of Information
At ThePillars, we prioritise the security and confidentiality of the personal information we collect from our members and other stakeholders. All electronic personal data is stored securely on our computer systems, which are protected using current security technology. Physical copies of personal information are securely stored at our premises or at a secure off-site location. Any physical personal information is either safely archived for a period of seven years or securely destroyed if no longer needed.
Cross-Border Data Transfers and Storage
The storage and transfer of personal information to overseas jurisdictions (if any) will be conducted in compliance with Australian Privacy Principles (APPs), especially APP 8. Before any personal information is disclosed to overseas recipients, we take reasonable steps to ensure that these recipients do not breach the APPs. We either ensure these third parties comply with the APPs or, where applicable, we obtain explicit consent from individuals, making them aware that their information may not be protected under the APPs after its transfer.
We aim to maintain transparency with our members about our data practices, including any potential cross-border data transfers. Specific countries where personal information may be transferred will be listed in our Privacy Policy, providing our members with a clear understanding of where and how their information may be handled.
Responsibilities and Protections
The Pillars remains accountable for the management of the personal data it collects, ensuring compliance with all applicable privacy laws and regulations. Our commitment extends to ensuring that any third parties we engage also uphold these standards through rigorous contractual measures.
Use of Information
ThePillars will only use your personal information for the purpose for which it was provided (e.g., club membership application or visitor entry), other uses permitted by the Privacy Act, or uses for which you have consented. Direct marketing campaigns are only sent to members who have not opted out to receive marketing material.
ThePillars collects this information to:
- Identify and process membership applications,
- Meet statutory requirements under the Registered Clubs Act, Anti-Money Laundering and Counter-Terrorism laws, and other relevant legislation,
- Allow entry of temporary members or guests,
- Contact members to advertise and market events, activities, opportunities, offers, and the goods and services provided by the Club (including Mail, Email, SMS, and Push Notifications),
- Analyse the use of goods and services offered by the Club,
- Provide offers/information to users of specific areas of the Club, and
- Analyse application usage.
ThePillars will not use or disclose your personal information for any other purpose without your consent, unless permitted under the Privacy Act.
Temporary Members and Guests
To join ThePillars or become a temporary member or guest, you must provide the required personal information. All temporary guests visiting ThePillars must produce recognised identification (e.g., passport, driver's license, or proof of age card) to gain entry. ThePillars uses terminals to scan and gather information from these forms of identity and computer systems to protect the collected data (e.g., address). Manual sign-in via the terminals is available if preferred, once the appropriate identification has been sighted by an authorised officer of ThePillars.
Surveillance of Venues
ThePillars is subject to video and, at times, audio surveillance for security reasons. Details of suspected or actual illegal and/or undesirable activities on our premises may be shared with other clubs, law enforcement, and regulatory bodies such as the Office of Liquor, Gaming and Racing and the Independent Liquor and Gaming Authority.
Do Not Track (DNT)
We currently do not alter our data collection and usage practices in response to "Do Not Track" signals from web browsers, due to the lack of a consistent industry standard for compliance.
Right to Be Forgotten
You may request the deletion of your personal information from our records. Such requests must be submitted in writing using the contact details listed under ‘Contact Us’. We will process your request promptly in accordance with legal requirements, unless we are obligated to retain the information for legal reasons. Please note, requesting deletion of your personal information means you will no longer be able to access our services or make bookings via our online platforms.
Data Retention
We retain your personal information in our records to comply with legal obligations and to provide our services. On your request, personal information can be anonymised and retained in a de-identified form for business analysis and operations.
General Data Protection Regulation (GDPR)
For residents of the European Economic Area (EEA) or European Union (EU) using our services or accessing our platforms, we comply with the GDPR in addition to our obligations under the Australian Privacy Act. This policy serves as a comprehensive framework for managing your Personal Information (referred to as Personal Data under GDPR), ensuring the security and privacy of your data across all interactions, regardless of geographic location. No additional GDPR-specific terms are required due to our comprehensive privacy practices.
Correction of Information
The Privacy Act allows individuals to access and alter records containing their personal information. To change your name or address on our membership database, provide supporting documentation from a government source (e.g., Licence, Marriage Certificate). To alter other information (contact number, email address, marketing preferences, etc.), please contact ThePillars' reception, and your record will be updated immediately.
Complaints
If you wish to make a complaint about ThePillars' use of your personal information, please submit your complaint in writing, providing as much detail as possible. You can send your complaint via letter, email, or hand deliver it to ThePillars Privacy Officer. Contact details are as follows:
Address: 11 Barrack Street, Sydney, NSW 2000
Email address: memberships@thepillars.au
A representative will investigate the complaint and provide you with a written response upon completion of the investigation.