Privacy Policy

SANDHURST CLUB PRIVACY POLICY (JULY 2024)

Background

Sandhurst Club Limited (ABN 61 083 181 364), Sandhurst Holdings (Australia) Limited (ABN 88 083 189 655) and its related entities are committed to the protection of personal and sensitive information and ensuring compliance with all relevant privacy laws and regulations.

Please take a moment to read our Privacy Policy as it explains how we manage personal information. The policy explains how we collect, hold, use and disclose your personal information, and how we maintain the quality and security of your personal information. It also describes your rights in relation to your personal information and your choices about our collection and use of such information.

The Privacy Policy is published on the Sandhurst Club website and may be updated from time to time at Sandhurst’s discretion. By continuing to use the website, or otherwise continuing to deal with Sandhurst, you accept the Privacy Policy as it applies from time to time.

Key Definitions

In this document:

  • “APPs” means the Australian Privacy Principles set out in the Privacy Act 1988 (Cth)(Privacy Act)
  • “Privacy Act “means the Privacy Act 1988 (Cth)
  • ‘’Sandhurst or Sandhurst Club” includes Sandhurst Club Limited, Sandhurst Holdings (Australia) Limited and their related bodies corporate.
  • “Website” means our website located at www.sandhurst.com.au

The Privacy Act and the Australian Privacy Principles regulate how we collect, store, provide access to, use, and disclose personal information. Sandhurst is committed to complying with these obligations.

Object of Policy

Sandhurst is committed to:

  • taking reasonable steps to implement practices, procedures and systems that will ensure compliance with the Privacy Act and APPs
  • having a clearly expressed and up-to-date Privacy Policy detailing how we manage personal information and manage related enquiries and complaints.; and
  • taking reasonable steps to make our Privacy Policy available on our website or in hard copy format as requested.

What is “Personal Information”

“Personal Information” includes information or an opinion about an identified or reasonably identifiable, individual whether the information or opinion is true or not, and whether the information or opinion is in a material form or not.

“Sensitive Information” includes information about your health, racial or ethnic origin, political opinions or philosophical beliefs, criminal record, religious beliefs or sexual orientation.

The types of Personal Information that Sandhurst collects from an individual will depend on the circumstances in which the information is collected. Generally, the types of Personal Information that Sandhurst collects include:

  • name
  • date of birth
  • gender
  • your address, telephone number and email address
  • financial details such as credit card details or bank account details
  • drivers license or passport details
  • member account transaction information
  • golf tee times, handicaps and golflink number
  • property information such as house plans
  • if you are an employee or contractor, Sandhurst will also collect information relevant to the application for employment, including qualifications, licences, resume, bank details, tax information, contact details and reference information.

Sandhurst may also hold other kinds of personal information as permitted or required by law or other personal information that we notify you of, at or about the time of collection. Including information required to be kept by Sandhurst for the purpose of fulfilling our role as a member club including:

  • register of members in accordance with the Corporations Act 2001 (Cth)
  • information received about you from external bodies such as Golf Australia

How we collect personal information

Generally, we collect personal information from you directly and from your use of our products and services. For example, Sandhurst may collect your personal information:

  • when making an enquiry regarding membership
  • when seeking feedback on Sandhurst activities or from customer satisfaction surveys
  • from telephone calls
  • when you purchase a property located in the Sandhurst Club estate and become a resident shareholder member
  • when you register as a tenant of a property located in the Sandhurst Club estate
  • when you register as a golf member or resident member
  • when you purchase a golf share and become a golf member
  • when you use or update your details on your member account via our website or member app
  • through direct contact with you online
  • when accessing our website or social media sites

There may be occasions when Sandhurst collects your personal information from someone other than you, for example:

  • from other organisations e.g. Golf Australia or the PGA
  • a publicly maintained record or other publicly available sources of information including social media and other platforms
  • through recruitment processes or references if applying for a role with Sandhurst
  • anyone who is authorised to act on your behalf
  • golf club references when seeking a golf membership.

Generally, Sandhurst will only collect your personal information from sources other than you if it is unreasonable or impractical to collect that information from you.

Purposes for which Sandhurst collects, holds uses and discloses information

Generally, we will collect and use your personal information for one or more of the following reasons:

  • to establish your identity to assess applications you have made
  • managing our relationship with you
  • providing golf, hospitality, health club or other club services to you;
  • complying with any legal requirements
  • providing you with information about other services that we, our related entities and other organisations that we have affiliations with offer, that may be of interest to you;
  • providing you with promotional information about us, our related entities and other organisations that we have affiliations with;
  • analysing our services and customer needs with a view to developing new and/or improved services.
  • For inclusion in member databases

Any member lists or databases that are made available to members will require you to “opt-in” to allow the publication of your personal information.

FAILURE TO PROVIDE INFORMATION

If the personal information you provide to us is incomplete and/or inaccurate, or you choose not to identify yourself we may be unable to provide you with membership or certain services or benefits, that you, are seeking.

Information Collected when you visit our website or social media platforms

When you access our website or engage with us on social media, we collect additional personal information about you including:

  • your IP (Internet Protocol) address
  • your location when accessing the website
  • the date, month, year and time you accessed our site or social media platform
  • the pages you accessed and the type of browser or software used

Our website uses cookies. The main purpose of cookies is to identify users and prepare customised web pages. Cookies do not identify you personally, but they may link back to a database record about you. We use cookies to monitor the usage of our website and to create a personal record of when you visit our website and what pages you view so that we may serve you more effectively.

USE AND DISCLOSURE

Generally, we only use and disclose personal information about you for the purposes for which it was collected. We may however disclose personal information about you to:

  • Service providers, who assist us in operating our business. These service providers would enforce their own privacy policy and may not be required to comply with ours; or
  • Other service providers, who provide the various services you have requested and we have arranged; or
  • Related entities to advise you of special offers and promotions; or
  • Corporate partners and other organisations we have strategic business affiliations or alliances with to market their products and services to you where we consider these products and services may be of interest to you; or
  • Government and regulatory authorities and other organisations, as required or authorised by law.

How we hold and secure your Personal Information

We store your personal information in different ways, including in paper and in electronic forms. The security of your personal information is important to us. We take all reasonable measures to ensure that your personal information is stored safely to protect it from misuse, loss, unauthorised access, modification, or disclosure, including electronic and physical security measures. Your personal information will be retained in accordance with applicable legislation after which it will be destroyed or de-identified.

TRANSFER OF INFORMATION OVERSEAS

Some of our service providers may be located overseas or may store information (including your personal information) that we provide to them overseas. Therefore, the personal information you provide to us may be held overseas. Sandhurst takes reasonable steps to ensure that any such overseas information recipients do not hold, use or disclose your personal information in a way that is inconsistent with the Privacy Act and the Australian Privacy Principles.

Your information may also be stored on computer servers located outside of Australia that are operated by our suppliers.

How to Access Your Personal Information

Sandhurst endeavours to keep accurate records of your personal information. You have the right to access personal information that we hold about you. Upon making a written request to the Privacy Officer you will be provided access to your personal information where reasonable within 30 days.

If, upon receiving access to your personal information or at any other time, you believe the personal information we hold about you is inaccurate, incomplete, or out of date, please notify the Privacy Officer. We will take reasonable steps to correct the information so that it is accurate, complete, and up to date.

If Sandhurst refuses your request to access or correct your personal information Sandhurst will provide you with written reasons for the refusal and details of the complaint mechanism. If you are dissatisfied with Sandhurst’s refusal you may make a complaint to Sandhurst in writing or to the Office of the Australian Information Commissioner.

FEEDBACK, COMPLAINTS AND CONCERNS

Any queries or concerns about our Privacy Policy or how we handle your personal information will be treated seriously and dealt with promptly and in a confidential manner. We will respond to any concern or complaint submitted in writing within 14 days of Sandhurst receiving the complaint. All concerns are to be addressed to the Privacy Officer at:

Sandhurst Club
75 Sandhurst Boulevard
Sandhurst VIC 3977 Australia

E: club@sandhurst.com
P: 03 8787 7011