PRIVACY POLICY

1. Royal Hotels Group and Privacy

Royal Hotels Group is one of Australia's leading hospitality groups. In operating our restaurants, bars, events, and related hospitality businesses, Royal Hotels Group collects and handles personal information. Royal Hotels Group understands the importance of protecting the privacy of an individual's personal information and being open and transparent in how we handle and deal with personal information. This privacy policy sets out how Royal Hotels Group aims to protect the privacy of your personal information, your rights in relation to your personal information managed by Royal Hotels Group, and how Royal Hotels Group collects, holds, uses, discloses, and otherwise manages your personal information. Royal Hotels Group will regularly review its policies and procedures regarding personal information and may therefore update and amend this privacy policy from time to time. Any updated privacy policy will be made available on our website (https://www.royaloakdoublebay.com.au/privacy-policy) or can otherwise be obtained by contacting us and requesting a copy.

2. Definitions

In this privacy policy:

(a) Privacy Act means the Privacy Act 1988 (Cth);

(b) Royal Hotels Group means Royal Hotels Group Admin Pty Ltd, trading as Royal Hotels Group, and the other entities as set out in Annexure A to this privacy policy;

(c) Royal Hotels Group Events means any public, corporate, private, or other events conducted or organised by Royal Hotels Group or any events sponsored by Royal Hotels Group;

(d) Royal Hotels Group Venue means the hotels, bars, and other venues operated by Royal Hotels Group;

(e) Together with Royal Hotels Group means Royal Hotels Group Admin Pty Ltd, ABN 14 160 354 718, trading as Royal Hotels Group; and

(g) We, us, our means Royal Hotels Group.

3. Compliance with Privacy Act

In collecting, holding, using, disclosing, and otherwise managing personal information, Royal Hotels Group will comply with the Privacy Act and the Australian Privacy Principles in the Privacy Act.

4. Collection of personal information

Under the Privacy Act, personal information is information or an opinion about an identified, or reasonably identifiable, individual. During the provision of our hospitality and related services or as a result of our other interactions or dealings with you, Royal Hotels Group may collect your personal information. Royal Hotels Group provides a diverse range of hospitality services and experiences. As a result, the kinds of personal information that Royal Hotels Group collects will vary depending on our particular interaction or dealing with you. However, generally speaking, the kinds of personal information Royal Hotels Group collects may include:

(a) contact and identification information such as your name, address, telephone number, and email address (for example, where you make a reservation at a Royal Hotels Group Venue or join one of our mailing lists);

(b) information regarding your ordering history, food or beverage, or other dining preferences, to assist us in providing a more customised dining experience;

(d) where you organise or conduct an event using Royal Hotels Group, information regarding the event, your guests, and any relevant requirements;

(e) information regarding your experience at a Royal Hotels Group Venue (for example, as part of our guest feedback activities or where you contact us with feedback); and

(f) where you apply for employment with Royal Hotels Group (in addition to contact and identification information detailed above), information relevant to us considering your application for employment, including information in relation to your CV, employment history, qualifications, and references.

Depending on the Royal Hotels Group Venue you visit, we may also collect identification information, such as driver's license or passport information. We generally collect this information because we are required to do so by law and/or for venue, patron, and employee security purposes. Specific information regarding the collection and handling of this type of personal information will be available at the relevant venue. Royal Hotels Group also collects CCTV footage at many of Royal Hotels Group Venues, including for venue, patron, and employee safety purposes. Details of suspected or actual illegal or improper conduct (including CCTV footage relating to that conduct) may be shared with relevant law enforcement or regulatory bodies. At some Royal Hotels Group Venues or Royal Hotels Group Events, we may also take photographs or other images or content (such as video or audio recordings). Where we do so, we will provide as much detail as possible regarding why the photographs, images, or other content are being taken and the purposes for which they are being used. By attending such a Royal Hotels Group Venue or Royal Hotels Group Event, you consent to us taking such photographs, images, or other content and using those photographs, images, or other content, including at the venue and on Royal Hotels Group websites and social media sites. Royal Hotels Group may also hold other kinds of personal information as permitted or required by law or other kinds of personal information that we notify you of at or about the time of collection. Generally, we do not collect sensitive information about individuals. Information about your health, racial or ethnic origin, political persuasions, criminal record, and religious or philosophical beliefs are all examples of sensitive information. There may be circumstances where Royal Hotels Group does collect sensitive information, for example where we need to collect health information regarding your allergies or in a medical emergency. If we do collect sensitive information about you, we will only do so with your consent or where we are required or authorised to do so by law.

5. Collection of personal information by Royal Hotels Group

Generally, Royal Hotels Group collects your personal information directly from you. For example, Royal Hotels Group may collect your personal information where:

you make a reservation for a Royal Hotels Group Venue or a Royal Hotels Group Event;
you join one of our mailing lists, fill out a survey, enter a promotion, request services, or otherwise provide us with your details;
you dine at or attend a Royal Hotels Group Venue;
you stay at any Royal Hotels Group Venue that provides accommodation services;
you organise an event with Royal Hotels Group or participate in or attend an event organised by Royal Hotels Group;
you sign up to or participate in any Royal Hotels Group loyalty program;
you provide feedback to us regarding your experience at a Royal Hotels Group Venue or your other interaction with Royal Hotels Group;
you post information to any of our social media sites;
you attend a Royal Hotels Group Event; or
you apply for or express an interest in employment with us.

We generally collect personal information directly from you. However, there may be occasions when Royal Hotels Group collects your personal information from someone other than you, for example from:

other entities within Royal Hotels Group;
our service providers or contractors (for example where we appoint a service provider/contractor to assist with conducting an event);
an information services provider; a publicly maintained record or other publicly available sources of information, including social media and similar websites; or a referee or previous employer where you apply for employment with Royal Hotels Group.

6. Purposes for which personal information is used

Generally speaking, Royal Hotels Group collects and uses personal information so that we can provide our hospitality services, interact with you in relation to our services and venues, and administer and manage our business and our venues. Some examples of the purposes for which Royal Hotels Group collects, holds, uses, and discloses your personal information include to:

take bookings for Royal Hotels Group Venues or Royal Hotels Group Events;
provide dining and other hospitality experiences at Royal Hotels Group Venues;
provide our event services to you;
manage and administer the provision of our services and our relationship with you;
maintain venue, patron and employee safety;
enable us to supply you with information you request from us;
conduct promotions, competitions, giveaways and events;
contact you to obtain your feedback regarding our products or services or to conduct other market research;
provide you with marketing information regarding Royal Hotels Group and our venues (as further detailed in paragraph 7 below);
analyse information we collect so that we can administer, support, and improve and develop our business and the products and services we offer, including by undertaking data analytics and related activities using your personal information;
comply with the obligations of Royal Hotels Group under any applicable laws; and
consider any application you make for employment with us.

In addition to the purposes listed above, Royal Hotels Group may use your personal information for other purposes which we notify you of when we collect the information and for other purposes permitted or required by law. Where personal information is used or disclosed, Royal Hotels Group takes reasonable steps in the circumstances to ensure it is relevant to the purpose for which it is to be used or disclosed. You are under no obligation to provide your personal information to Royal Hotels Group. However, without certain information from you, Royal Hotels Group may not be able to provide services or information to you or may be limited in how we can interact with you.

7. Direct marketing

In addition to the purposes outlined in paragraph 6 above, Royal Hotels Group may use and disclose your personal information in order to inform you of promotions, competitions, giveaways, events, products, or services that may be of interest to you. Where you make a booking at a particular Royal Hotels Group Venue or sign up for the mailing list of a particular Royal Hotels Group Venue, this may include sending you information about that Royal Hotels Group Venue or other Royal Hotels Group Venues, Royal Hotels Group Events, or services that may be of interest to you. In doing so, Royal Hotels Group may disclose your personal information to the companies within Royal Hotels Group or other entities with which Royal Hotels Group has a commercial relationship or arrangement for the purpose of the other entity contacting you for such direct marketing purposes. These communications may be sent using email, telephone, SMS, social media, or other similar forms of communication. If you do not wish to receive such communications, you can opt-out at any time by contacting Royal Hotels Group via the contact details set out in paragraph 14 of this privacy policy or through the opt-out mechanism contained in a marketing communication to you.

8. Disclosure of personal information

Royal Hotels Group discloses your personal information for the purpose for which Royal Hotels Group collects it. As a result, generally Royal Hotels Group will only disclose your personal information for a purpose described in this privacy policy. This may include disclosing your personal information to:

the companies or other entities within Royal Hotels Group;
our service providers and contractors and other third parties that provide products or services to us (including our technology service providers, data analytics service providers, bookings or reservation systems providers, event service providers, or other business or administration service providers);
Royal Hotels Group's auditors, tax, insurance, legal, or other professional advisors;
persons or entities considering acquiring an interest in Royal Hotels Group's business or assets; or
Royal Hotels Group's insurance providers.

Royal Hotels Group may also disclose your personal information for other purposes where we notify you of the disclosure at or about the time of collecting the information, with your consent or if the disclosure is required or authorized by law. Examples of disclosure that may be required or authorized by law include disclosure to law enforcement bodies, liquor and gaming regulators, or under Anti-Money Laundering and Counter-Terrorism Financing laws. If you post information or other content to public sections of our websites or to our social media sites, you acknowledge that the information or content may be viewed by the public and/or users of the relevant website or social media site.

9. Overseas disclosures

Some of the parties that Royal Hotels Group discloses your personal information to may be located outside Australia. We take reasonable steps to ensure that any such overseas recipients do not hold, use, or disclose your personal information in a way that is inconsistent with the obligations imposed under the Privacy Act and the Australian Privacy Principles in the Privacy Act.

10. Links to other websites

When you access our websites or other online services, we may provide as a convenience to you links to other websites, including sites operated by our partners, associates, or independent third parties. These links are provided as a convenience to you. Each website may have its own privacy practices, as described in that site's privacy policy. Those practices may be different than the practices described in this privacy policy, and we encourage you to read each website's privacy policy carefully before you use or submit information to that site. Additionally, to the extent that you follow a link to a website operated by an independent third party, please be aware that we exercise no authority or control over that third party and cannot and are not responsible for any information that you may submit to that site.

11. Cookies and website statistical information

Royal Hotels Group may collect statistical information when you access and use our websites and any online platforms available via our websites, by utilising features and technologies of your internet browser, including cookies and pixel tags. We use this information to analyse how our websites and other online services are being used and seek to improve our websites and other online services and provide more user-friendly and customised websites and online services. These features and technologies do not specifically identify you unless you expressly provide to us personally identifiable information. You may also elect to turn off the internet browser features that allow us to collect statistical information by selecting certain options on your browser. However, this may slow down or cause certain web pages to be inaccessible to you.

12. Security of personal information

Royal Hotels Group takes the security and protection of the personal information we hold seriously. We take steps reasonable in the circumstances to ensure that the personal information we hold is protected from misuse, interference, and loss and from unauthorized access, modification, or disclosure. Your personal information will be kept on databases held on servers kept in a physically and technologically secured environment, accessed only by authorized personnel or contractors. Where personal information is held in hard copy, it will be held in controlled, access-restricted premises which only authorized personnel or contractors will be permitted to access. Royal Hotels Group will destroy or de-identify personal information in circumstances where it is no longer required unless Royal Hotels Group is otherwise required or authorized by law to retain the information.

13. Access and correction

Royal Hotels Group takes steps reasonable in the circumstances to ensure personal information it holds is accurate, up-to-date, complete, relevant, and not misleading. In addition, under the Privacy Act, you have a right to seek access to and correction of your personal information that is collected and held by Royal Hotels Group. If at any time you would like to access or correct the personal information that Royal Hotels Group holds about you, or you would like more information on Royal Hotels Group's approach to privacy, please contact Royal Hotels Group Privacy Compliance Officer using the details set out in paragraph 14 below. Royal Hotels Group will grant access to the extent required or authorized by the Privacy Act or other law and take steps reasonable in the circumstances to correct personal information where necessary and appropriate. To obtain access to your personal information:

you will have to provide proof of identity to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected;
Royal Hotels Group requests that you be reasonably specific about the information you require; and
Royal Hotels Group may charge you a reasonable administration fee, which reflects and will not exceed the cost to Royal Hotels Group for providing access in accordance with your request.

Royal Hotels Group will endeavor to respond to your request to access or correct your personal information within 30 days from your request. If Royal Hotels Group refuses your request to access or correct your personal information, Royal Hotels Group will provide you with written reasons for the refusal and details of complaint mechanisms. If you are dissatisfied with Royal Hotels Group's refusal to grant access to, or correct, your personal information, you may make a complaint to the Office of the Australian Information Commissioner.

14. Contacting Royal Hotels Group

For further information or enquiries regarding your personal information or if you would like to opt-out of receiving any promotional or marketing communications or make a privacy complaint, please contact Royal Hotels Group's Privacy Compliance Officer using any of the following contact details:

Privacy Compliance Officer

Email: bookings@royaloakdoublebay.com.au Phone: (02) 9363 3935 Post: 28 Bay St, Double Bay NSW 2028

15. Privacy complaints

Please direct all privacy complaints to Royal Hotels Group's Privacy Compliance Officer. At all times, privacy complaints:

will be treated seriously;
will be dealt with promptly;
will be dealt with in a confidential manner; and
will not affect your existing obligations or affect the commercial arrangements between you and Royal Hotels Group.

Royal Hotels Group will acknowledge your complaint within 7 days of receipt and endeavor to resolve it within 30 days, unless Royal Hotels Group informs you otherwise and seeks your agreement in writing. Royal Hotels Group will commence an investigation into your complaint. You will be informed of the outcome of your complaint following completion of the investigation. In the event that you are dissatisfied with the outcome of your complaint or an extension to the time in which Royal Hotels Group will resolve it, you may refer the complaint to the Office of the Australian Information Commissioner.

Annexure A: Royal Hotels Group Entities

The Trustee for Royal Oak Hotel Double Bay Unit Trust #1 – ABN 97 256 096 146, Puruse Pty Ltd, trading as Royal Oak Hotel, Double Bay
The Trustee for Gregory Hills Hotel Unit Trust – ABN 20 634 672 553, JEJM Gregory Hills Pty Ltd, trading as Gregory Hills Hotel
Malovale Operating Pty Ltd – ABN 72 661 217 232, trading as Moss Vale Hotel