Privacy Policy of Liverpool Catholic Club Limited and related entities
Issue Date: 26 March 2025
This policy sets out how Liverpool Catholic Club Limited and its related entities (“Club”, “we”, “us” or “our”) collect, use, disclose and hold “personal information”. “Personal information” means information or an opinion about an individual (who can reasonably be identified), whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not. Please note that the Club operates several intra-clubs and other businesses under different trading names and brands, including:
Those businesses’ operations are also covered by this policy, as explained in the FAQ section below. The Club also owns and operates Mercure Sydney Liverpool, as a Franchisee of the Accor Group. If you have any dealings with Mecure Sydney Liverpool, Accor Group’s privacy policy will apply to any personal information which Accor Group collects, uses, discloses and holds about you.
Accor Group’s privacy policy can be accessed here: all.accor.com/a/en/information/data-protection.html
This policy may be updated or revised by the Club at any time and without prior notice.
We are committed to complying with our obligations under the Privacy Act 1988 (Cth) “Privacy Act” by protecting the privacy and confidentiality of your personal information. When we collect, use, disclose, store, access or correct your personal information, our actions will comply with the Privacy Act and the Australian Privacy Principles. Where appropriate, we will handle your personal information relying on the employee records exemption and the related bodies corporate exemption in the Privacy Act.
We collect and hold a wide range of personal information, and in some cases sensitive information, including:
From time to time, we may collect additional information about you related to surveys, promotions and particular services or activities at or in connection with the Club. Wherever practicable, we will advise you of the information being collected about you and provide you with an opportunity to refuse the collection of that information.
Your personal information is collected as a result of your visits to, or dealings with, the Club. Information is collected by recording information that you provide to us, by electronic means, and by the observations of our staff. We collect personal information when you:
In general, if you contact us, we may keep a record of that correspondence. In most cases we will only collect personal information about you from you (or if you are under 15 years of age, from your parent or legal guardian). We may also collect your personal information from other sources if it is unreasonable or impractical for us to collect the information from you directly. For example, it may be unreasonable or impractical to collect information from you (or your parent or legal guardian if you are under 15 years of age) when the information is provided by other members, our staff or the Police.
We may also collect information about you from other clubs and industry bodies if you have excluded yourself from the Club’s premises, including in relation to ClubNSW’s “ClubSAFE” self-exclusion system. For more information about ClubSAFE, please go to www.clubsnsw.com.au.
When we collect information from you, we will take reasonable steps to notify you (or otherwise ensure that you are aware) of the following:
One way we notify you of the above is by making you aware of this policy. If you give us personal information about others, we expect that you will tell them about this policy.
As a registered club, we have a legal responsibility to collect certain information about our members and guests pursuant to legislation, including the Registered Clubs Act 1976 (NSW) (Registered Clubs Act), Corporations Act 2001 (Cth) (Corporations Act), Gaming Machines Act 2001 (NSW), Liquor Act 2007 (NSW), Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act) and Work Health and Safety Act 2011 (NSW).
For example, when a person applies for membership of the Club, we must collect details including their name and address. We must display that person’s name and proposed member number on the Club’s notice board before our Board is able to consider their application for membership. We may also be required to provide information under certain legislation to any member of the public who makes a request under certain legislation, including the Corporations Act.
Temporary members, guests of members and other visitors to the Club may be required to produce a recognised form of identification (such as a driver’s licence or passport) to gain entry into the licenced premises.
If you elect to use our electronic ID scanners, we will collect information from your ID at the time you enter the Club. More information about our electronic ID scanners appears in our Frequently Asked Questions section below.
We collect, hold, use and disclose your personal information to operate the Club at its various businesses, carry out certain activities, provide products and services to you, other members and guests and other members of the public, and comply with our legal obligations. The purpose of collecting your personal information is to undertake one or more of the following activities or functions:
If you don’t give the Club your personal information, you may not be able to become a member of the Club or use the Club’s services or facilities or access the Club’s premises.If you provide us with some but not all of the information sought, then, depending on the information withheld, we may be able to provide you with certain goods and services but only to a limited extent. You have the option of not identifying yourself, or of using a pseudonym, when dealing with us. However, this will be limited to enquiries of a very general nature and only over the telephone or by email. In most circumstances, you will be unable to deal with the Club anonymously or with a pseudonym because of our obligations under the Registered Clubs Act.
We use your personal information primarily to allow us to carry out the activities and functions listed above. We also use your personal information for secondary purposes (such as reporting and surveys) related to those activities and functions, or when permitted under the Privacy Act. If you have self-excluded yourself from the Club’s premises and nominated other clubs from which you also want to be excluded, we may disclose your personal information through Multi-Venue Self Exclusion (MVSE) to those clubs to the extent necessary to assist those clubs to comply with your self-exclusion.
Similarly, if we receive personal information about you from:
To the extent that the Club collects health information about you or your child, the Club will treat that information as confidential and only ever handle that health information in accordance with the Club’s policies, the Privacy Act and the Health Records and Information Privacy Act 2002 (NSW). The Club may also use the personal information we collect from you for direct marketing of products and services to you, including from third parties. Such products and services may include the provision of newsletters, competitions, announcements, campaigns or information about shows and entertainment at the Club or services offered by the Club.
You can refuse any direct marketing at any time by contacting our Privacy Officer (details can be found at the end of this policy) or by unsubscribing via the link on the LLC website or any other marketing communications.
We may use automated decision-making software to conduct analytics on your personal information to assist us to carry out activities and functions. For example, the Club may use targeted marketing software to identify what products or services may be of interest for you and send you information about those products or services, including any upcoming events or promotions. Similarly, the Club’s use of FRT is also a form of automated decision making.
There may be times when we may need to disclose your personal information to third parties that we engage to provide services to or in connection with the Club, including our related entities, our insurers, auditors, dispute resolution bodies, ClubsNSW, our sponsors, our legal and/or financial advisors and other members of the Club. Your personal information will only be disclosed to third parties for a purpose permitted by the Privacy Act and/or this policy and, where required, after obtaining your consent.
We may need to disclose your personal information to third parties for the purposes of allowing us to carry out the activities and functions mentioned in this policy. For example, from time to time, the Club engages external companies to send direct marketing information (usually via mail, email or SMS), carry out mail services, and provide IT storage and other services.
A third party will only receive your personal information from the Club where that information is necessary for that third party to provide services to or in connection with the Club and the Club will always require that the third party comply with the Privacy Act when dealing with your personal information. We will also disclose your personal information to third parties if we are required or authorised to do so by law, including to law enforcement agencies, the Office of the Australian Information Commissioner, the Australian Electoral Commission, the Department of Communities and Justice and the Australian Taxation Office.
The Club will never disclose health information about your child to a third party without your express consent, except in the event of a medical emergency or as otherwise permitted by law.
The Club operates several businesses which trade under different names and brands, including but not limited to LLC Venues, LCC Ice Rink, Pinnacle Fitness Club and the Laneway. These trading names and brands may change, and additional trading names and brands may be introduced, from time to time without notice to you.
The Club also operates a number of clubs and sub-clubs that form part of the Club, including Thurgoona Country Golf Club Resort. For the purposes of the Privacy Act, a sub-club’s collection, use, disclosure or storage of your personal information is the Club’s collection, use, disclosure or storage of your personal information. If a sub-club (being part of the Club) collects, uses, discloses or stores your personal information, it will comply with this policy when doing so.
The Club may have one or more related entities, also known as “related bodies corporate”. These related entities are separate legal entities to the Club but are related to the Club in some way (e.g. the Club owns the related entity, or the related entity owns the Club). The Privacy Act permits related entities to share personal information in certain circumstances. If an entity related to the Club collects, uses, discloses or stores your personal information, it will comply with this policy when doing so (unless that entity has its own privacy policy). Mercure Sydney Liverpool has its own privacy policy available here: www.accorhotels.com/security-certificate/index.en.shtml.
The Club’s primary concern is the safety and wellbeing of its staff, members and the broader community which it serves. In limited circumstances, the Club may need collect personal information from you about you or your child’s health in order to safely provide specific services to you or your child. For example, we may need to collect information about any relevant medical conditions you may have in order to assess whether you can safely participate in certain activities offered at the Pinnacle Fitness Club. Similarly, the Club may collect information about any allergies or other special dietary requirements that you have if you RSVP to attend a catered function at the Club.
The Club will only ever collect your health information from you directly (or if you are under 15 years of age, from your parent or legal guardian) and with your (or your parent or guardian’s) express consent. The Club recognises that health information is sensitive information and will only handle your health information in accordance with the Club’s policies, the Privacy Act and the Health Records an Information Privacy Act 2002 (NSW).
All venues operated by the Club are subject to video surveillance for security reasons, including to monitor the safety of members, guests and employees and to protect the Club’s assets. The recordings may be used in disciplinary proceedings and/or to investigate incidents and may be disclosed to our legal representatives, our insurers and law enforcements agencies. Some of the Club’s CCTV cameras also use facial recognition technology. This technology is only used to identify individuals who are suspended, banned or self-excluded from our premises (and where necessary, to add an individual to our database of suspended, banned and self-excluded individuals), as explained below.
When you are at the Club’s premises, your face will be analysed by the Club’s facial recognition technology. Designated security cameras located throughout the Club’s premises use facial recognition technology to collect and analyse the “face prints” of individuals.
A “face print” is a set of biometric characteristics (such as information about the relative location, size and shape of an individual’s facial features) which is used to uniquely identify an individual’s face and is expressed as a mathematical algorithm. When you are at the Club’s premises, the Club’s designated security cameras will capture an image of your face, analyse that image and then create a “face print” of your face based on that image. Your “face print” will be compared against a database maintained by the Club that contains the “face prints” of individuals who have been suspended, banned or self-excluded from the Club’s premises. If your “face print” matches the “face print” of an individual who has been suspended, banned or self-excluded from the Club’s premises, the Club’s staff will be alerted and steps will be taken to manually verify your identity and if necessary, to remove you from the Club’s premises or the gaming area of the Club’s premises (whichever the case may be).
If your “face print” does not match the “face print” of an individual who has been suspended, banned or self-excluded from part or all the Club’s premises, your “face print” will be deleted immediately (within seconds). For the purposes of enabling the “face print” matching referred to above, if an individual has been suspended, banned or self-excluded from the Club’s premises, the Club will collect a copy of that individual’s “face print” from a photo of that individual held by the Club (e.g. from the photo on the individual’s membership card or an image captured by our CCTV cameras) and will hold a copy of that “face print” in a separate secure database for so long as the individual is suspended, banned or self-excluded from all or part of the Club’s premises.
Practically, it is very difficult for the Club’s staff and security to remember the faces of every individual who has been excluded from the Club’s premises and to identify those persons from the many people who enter the Club’s premises on a daily basis. Whilst we still rely on staff and security to identify excluded individuals, people can enter despite our best endeavours.
To reduce safety risks related to excluded individuals entering the Club, the Club has implemented, the Club has implemented facial recognition technology at the Club’s premises to enhance the Club’s security procedures and assist the Club to identify and remove persons who have been suspended, banned or self-excluded from all of part of the Club’s premises. The Club does not use your “face print” for any other purposes.
The collection of your “face print” is reasonably necessary for the activities and functions of the Club and ensuring the safety of everyone at the Club. The Club will not store your “face print” unless you have been suspended, banned or self-excluded from all or part of the Club’s premises.
If you scan your driver’s licence with one of our electronic ID scanners, the scanner will extract your full name, address, signature and photograph and the expiry date from your licence. If you chose to scan your passport, our electronic ID scanners will take a complete copy of your passport as our software cannot extract the relevant information from a passport in the same way that it can from a driver’s licence.Our electronic ID scanners store data in a secure and password protected database.
Under the Registered Clubs Act, we are required to maintain a register of the name, address and signature of temporary members and guests over the age of 18 who enter the Club’s premises. This information must be retained by us for at least three years. We are also required to collect and retain some personal information for at least seven years in order to comply with our obligations under AML/CTF Act and its associated rules and regulations.
ID scanners are a secure way for the Club to collect information about persons entering the Club’s premises. ID scanners are also environmentally friendly in that they have helped the Club reduce its paper usage and storage of certain hardcopy records. The collection of personal and sensitive information of the individuals who choose to scan their identification is reasonably necessary for the activities and functions of the Club.
Yes, we collect the ID numbers of anyone who applies for membership with the Club. We are also required under regulation 107 of the Gaming Machines Regulation 2019 (NSW) to record certain information from a person’s ID when a person tries to redeem a gaming machine ticket which is for more than $5,000 or if the ticket is two or more days old, including non-members.
The Club has various security measures in place to protect your personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure.In the event that the Club’s security measures are compromised and your information is the subject of a data breach, the Club will comply with its obligations for responding to data breaches outlined in the Privacy Act. Upon becoming aware of a data breach, the Club will take urgent steps to contain the breach, mitigate any risk of harm and determine who may have been affected by the breach.
The Club will then assess the breach, including any potential for harm, and determine whether the breach is likely to result in serious harm to any person whose data was involved. If the Club has reasonable grounds to believe that the breach is likely to result in serious harm to you, the Club will notify you of the breach as soon as possible. The Club will also notify the Office of the Australian Information Commissioner (‘OAIC’) of the breach.
Following a breach, the Club will conduct a review of its security measures and implement any additional measures it considers necessary to enhance the security of your information.
The Club’s financial members can apply for a Pinnacle Rewards card which allows them to convert rewards points earned at the Club into funds which you can use to make payments via BPAY and at EFTPOS terminals in Australia.
In order to make this service available to you, we have partnered with a third-party financial services provider (Cuscal Ltd) and their authorised representative (Next Payments). If you apply for a Pinnacle Rewards card, you will enter into a separate contract with Cuscal and Next Payments and not with the Club. We will provide you with a copy of the relevant terms and condition for the Pinnacle Rewards program when you make your application. Those terms are also available on our website at liverpoolcatholic.gslsolutions.com.au. We strongly encourage you to read Cuscal and Next Payment’s privacy policies to understand how they will collect, hold and use your personal information.
We have no control over and are not responsible for your dealings with Cuscal and Next Payments, who will collect and handle your personal information pursuant to the terms of their own privacy policies. Our involvement is limited to providing your completed application (or cancellation) form to Next Payments and providing Next Payments with information concerning your points balance. We may collect information about whether you have a card and how many rewards points you convert onto your card but otherwise do not collect any information concerning your eftpos card, linked bank accounts and any payments you make using the any points you have converted into money.
The websites and social media pages operated by or in connection with us may collect personal information for the purposes outlined in this policy. Social media used by the Club may include but is not limited to Facebook, Instagram, Linkedin, Tic Tok and You Tube.
Any information collected by us as a result of your use of those websites and social media pages will be handled in accordance with this policy. Those websites and pages may also use cookies and contain hyperlinks to other websites and social media pages, including those operated by third parties. Any hyperlinks are provided for reference only. We do not have control over websites and pages operated by third parties and are not responsible for the content available on such websites or pages or the privacy practices of those third parties.
There will also be instances when dealing with the Club’s websites where you will be redirected to a third party’s website or platform. For example, you will be redirected to a third-party payment platform if you wish to make an online payment. Likewise, if you wish to make a reservation to dine at the Club via our website, you will be directed to a third-party platform to book your table and confirm any dietary or other special requirements which you may have.
Generally, we do not have control over these third-party providers and how they collect and handle any personal information that you provide to them. We also typically have limited access to the information they collect and hold. The Club does not accept any liability for the action of any such third-party providers. We strongly encourage you to read a third party’s privacy policy as it will likely contain provisions which are specific to the third-party’s activities and functions. For instance, a third-party payment platform provider will likely collect your billing and financial details and may disclose your financial information with your bank to verify your identity, to verify the information you have provided, to process your transaction and to advise us whether your payment has been successful.
You have a general right to access any personal information we hold about you. You can request access to the personal information we hold about you by contacting our Privacy Officer. We will not charge you for making the request. However, we may need to charge you for our time to answer your request. We will advise you in advance if there are to be any charges associated with complying with your request.
We will respond to your request within a reasonable timeframe (usually not more than 30 days). When you request access, we may need further information from you to verify your identity. There are a number of reasons why we may be unable to give you access to your personal information held by the Club. If we are not able to provide access, we will provide you with written reasons.
If you believe any of the personal information that we hold about you is incorrect or out of date, you can ask us to correct it and we will take reasonable steps to ensure that it is accurate, up-to-date, relevant and not misleading. To assist us to update your information, we may need you to provide us with evidence of your new details. If we refuse to correct your personal information, we will give you written reasons.
If you believe we have breached the Privacy Act or any of the Australian Privacy Principles, or if you have any issues about the Club’s collection, use, disclosure or storage of your personal information, please contact our Privacy Officer. When contacting our Privacy Officer, please give us enough details to be able to identify you, understand your issue or complaint so we are able to respond appropriately. We will respond to you within a reasonable timeframe (usually not more than 30 days). If you are unhappy with how we handle your issue or complaint, you are entitled to make a privacy complaint to the Office of the Australian Information Commissioner (OAIC).
You can contact the Privacy Officer by:
Phone: 02 8784 4878
Facsimile: 02 9821 3758
Email: privacy@liverpoolcatholic.com.au
Post: PO Box 305, Liverpool BC NSW 1871
Please visit the Office of the Australian Information Commissioner’s (OAIC) website at www.oaic.gov.au for contact details.
