Privacy policy

1. Background

Jumbo Interactive Limited (“Jumbo”) is committed to the protection of the Personal Information of individuals and is bound by:

• the Privacy Act 1988 (Cth), and the APPs contained therein;
• where applicable to a particular individual, GDPR; and
• any successor or related legislation as amended from time to time.

This Policy provides an overview of how Jumbo collects, stores, and uses your Personal Information, where applicable. This Policy also details how you can access and update your Personal Information or make a complaint.

This Policy applies to the Jumbo Interactive Corporate Site and Jumbo’s use of Personal Information collected by or through it. Additional privacy policies will apply to specific business operational units and geographic regions.

2. Definitions

APPs means the Australian Privacy Principles, as outlined in Schedule 1 of the Privacy Act 1988 (Cth);

Corporate Site means the website accessible at: https://www.jumbointeractive.com/

Data Subject means an identifiable or natural person that is subject to and protected by GDPR;

GDPR means the Data Protection Act 2018 (UK) and Regulation (EU) 2016/679 as applied therein;

Personal Information means any information or an opinion about an identified individual or an individual who can be reasonably identified from the information or opinion. Information or an opinion may be personal information regardless of whether it is true. For UK Data Subjects, Personal Information has the meaning prescribed by Article 4 of GDPR;

Privacy Laws means the Privacy Act 1988 (Cth), GDPR (where applicable), and any successor or related legislation that may apply from time to time;

3. What Personal Information do we collect

The Personal Information that Jumbo collects about you through the Corporate Site may include information in the following categories:

• Name;
• Mailing address;
• Email address;
• Telephone number;
• Personal Information collected by our use of Cookies (described below).

 

4. Why and how Jumbo collects Personal Information

Purpose of Collection

Personal Information is collected through the Corporate Site for the primary purpose of providing customers, clients and investors with information regarding the Jumbo Interactive business, its subsidiaries, and related parties, including providing information through interaction with a chatbot. Personal Information is also collected should you register your interest for a career at Jumbo in order, to facilitate and administer such expressions of interest.

For Data Subjects, the lawful bases for processing your Personal Information are that: you have given your consent to the processing for the above purposes; that the processing is necessary to take steps at your request prior to entering into a contract with you; and/or that the processing is necessary for compliance with a legal obligation to which we are subject, as applicable in the circumstance.

Means of Collection

Personal Information is collected from you in the following ways:

• By interacting with the Corporate Site;
• Through communications between you and us by correspondence (such as email, fax, letter, phone);
• By interacting with our Annual Report chatbot on the Corporate Site or any other site owned and operated by Jumbo or its subsidiaries;
• By third parties such as our affiliates, our suppliers, including lottery-based game suppliers, or your representatives;
• Through registering interest via the “Careers” page; and
• Through registering interest via the “Contact Us” facility.

5. Cookies

What are Cookies?

Our Corporate Site uses “Cookies”.

• Cookies are alphanumeric identifiers that are placed on your computer’s hard drive through your web browser.
• Cookies enable our system to recognise your browser and maintain your details.

Our Corporate Site uses both Functional and Non-Functional Cookies.

Functional Cookies are used to:

• Facilitate your ability to navigate through the Corporate Site;
• Ascertain whether the Corporate Site is operating effectively;
• Maintain confidentiality and security as you move through secure or password protected areas of the Corporate Site.

Non-Functional Cookies are used to:

• Personalise your experience when using our Corporate Site, by understanding your preferences and identifying the most relevant areas of the Corporate Site to your browsing session/s;
• Remember your log-in information and/or
• Compile statistics on the use of our Corporate Site, enabling Jumbo to better understand how to improve our Corporate site and services.

Most internet browsers are pre-set to accept Cookies. If you prefer not to receive them, you may adjust your browser to disable Cookies or ensure you are warned when they are used. Turning off Non-Functional Cookies may impair the operation of our Corporate Site and present you with a less convenient or navigable experience. Functional Cookies cannot be disabled, as they are required to be used to enable the Corporate Site to function.

We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve our site. Website usage data is captured using first and third-party cookies and other tracking technologies, we use this information for site optimisation, and fraud/security purposes. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.

Cookies do not routinely collect Personal Information as defined by the APPs. However, they may collect Personal Information as defined by GDPR (for example, IP addresses). Any Personal Information collected by our use of Cookies will be handled and treated in accordance with the provisions of this Privacy Policy.

6. Personal Information Security

Jumbo is committed to the protection of your Personal Information from unauthorized access. We use a range of security mechanisms and procedures to ensure a level of security appropriate to the risk to the Personal Information we hold about you.

Jumbo takes all reasonable efforts to ensure your Personal Information is stored securely both in electronic and physical forms. In addition, Jumbo maintains ongoing compliance with the ISO 27001:2022, adhering to and certified compliance with the security and privacy measures outlined therein.

Personal Information that is no longer required to be processed for the purposes for which it was collected will be destroyed, in accordance with and when required by applicable Privacy Laws.

7. Use and Disclosure of Personal Information

Your Personal Information may be used to:

• Verify your name, address and identity;
• Research and develop our services;
• Maintain and develop our business systems and infrastructure, including testing and upgrading of these systems;
• Communicate new products and services to you, by Jumbo and/or its lottery-based game suppliers for marketing purposes, including, the opportunity to take up special promotions and offers, only in a manner compliant with the Spam Act 2003 (Cth) and/or the Privacy and Electronic Communications (EC Directive) Regulations 2003 (EU) (as applicable);
• Consider you for employment;
• Address any query, feedback or complaints you may have; and
• Contact you for any other reason.,

Subject to Jumbo’s obligations under the Privacy Laws, Jumbo may disclose your Personal Information to:

• Our lottery-based game suppliers, their auditors, and/or their regulators;
• Your authorised representative (e.g. legal advisers) following receipt of your written authorisation to such disclosure;
• Unrelated third parties to enable outsourcing of relevant functions relating to the provision of lottery-based gaming and marketing products and services and only for the primary purpose of providing those functions; Professional advisers including but not limited to accountants, auditors and legal advisers;
• Courts, Government and regulatory authorities as required or authorised by law;
• Other third-parties located inside or outside Australia, whether internal or external, as further described in section 8;

8. Third-party and Cross Border Disclosures

Jumbo may share your Personal Information with third-parties falling within the categories below, for the purposes set out in section 7 above:

• Internal Third-Parties: Other companies and related entities within the Jumbo corporate group, based in Australia, the UK and/or Canada, who may provide Jumbo with services and/or undertake internal reporting on Jumbo’s behalf;
• External Third-Parties: Third-party and unrelated entities who act as data processors, situated within Australia, the UK/EU and/or the US, who may provide Jumbo with: IT and system administration services; professional advice (including but not limited to accountants, auditors and legal advisers); Courts, government or regulatory bodies as required or authorised by law.

Jumbo ensures that any third-parties described above are engaged subject to appropriate safeguards with respect to the receipt and disclosure of your Personal Information, specifically by:

• Conducting due diligence on proposed external third-parties to assess their data security competency and the adequacy of their proposed use;
• Ensuring that third-parties are engaged in a manner compliant with APPs 6 and 8;
• In relation to the Personal Information of Data Subjects: ensuring that third-parties are engaged on binding written terms containing the same obligations and maintaining the same rights required by Article 28 of the applied GDPR.

9. Access to Personal Information

You have the right under the APPs (APP 12) and GDPR (as applicable) to seek access to the Personal Information held by Jumbo about you. If you wish to exercise this right or any other right, if you believe that the information is incorrect, incomplete or out-of-date, you should address your request the Jumbo Interactive Privacy Officer nominated in Section 12.

All requests to access Personal Information should be made in writing or by email and addressed to the Privacy Officer. Jumbo shall respond to any such request within a reasonable period of time after the request is received. Jumbo will not charge you for making requests to access any information held about you, however, we reserve the right to undertake cost recovery for the provision of such information where it is permitted by law. We will notify you prior to undertaking work where costs are to be charged.

If there is a reason for not granting you access to your information, we will provide you with a written explanation of the reasons for the refusal and inform you of your further options.

For UK Data Subjects:

As provided by GDPR, you have additional rights in relation to your Personal Information over and above Australian-based individuals, including the right to erasure and the right to restrict the processing of your Personal Information. You may seek to exercise these additional rights by similarly contacting the Jumbo Interactive Privacy Officer.

10. Enquiries and Complaints

Information about the Privacy Act 1988 and the Australian Privacy Principles is available from the Office of the Australian Information Commissioner: https://www.oaic.gov.au/ or by telephone: 1300 363 992.

Information regarding the GDPR is available from the relevant Information Commissioner; for UK Data Subjects, this is the Information Commissioner’s Office (UK): https://ico.org.uk/ or by telephone: 0303 123 1113.

If you have a query regarding Jumbo’s management of your Personal Information, wish to correct information held by us or require further information, please contact us using the details listed in section 12. Jumbo shall respond to your correspondence within a reasonable period of time following receipt.

If you are not satisfied with the outcome of your complaint, you may refer your complaint to the Office of the Australian Information Commissioner or, for UK Data Subjects, the Information Commissioner’s Office.

11. Changes to the Privacy Policy

Jumbo reserves the right to make changes to this Privacy Policy. Any changes made to the Privacy Policy will be effected by Jumbo changing this Policy and such changes will become effective upon publication of the revised Privacy Policy. If we make any material or substantial changes to this Privacy Policy we will use reasonable endeavours to inform you by email or other agreed communications channels.

12. Jumbo Interactive Privacy Officer Contact Details

Attention: Privacy Officer, Jumbo Interactive Ltd

Postal address: PO Box 824, Toowong Qld 4066, Australia

Email: Email us

Phone: +61 7 3831 3705