Metropolis Fremantle takes privacy very seriously and is committed to protecting patrons' personal information. We are bound by the Privacy Act 1988 (Cth) regarding the manner in which we handle personal information and, wherever possible, aim to exceed the standards of privacy protection required under the Act.
This document sets out our information handling policies to ensure that you are aware of, and understand, what types of information we collect about you, the purposes for which it is used and persons to whom, if any, it is disclosed.

How we collect your information
Generally, there are only four circumstances in which we collect personal information about you:
- when you apply for membership to our Metropolis Fremantle Loyalty Card ("MFLC");
- when our club photographer takes a photo of you inside our club;
- when we scan your driver's licence, or other I.D., when you enter our club; and
- when you are within view of the CCTV security surveillance cameras located on our premises.
From time-to-time, there may be other occasions on which we collect information about you via other means; for example, if your friend hires a function room for a surprise birthday party for you.

Kinds of information we hold
The type of information we hold about you depends on the purpose for which it was collected. For example:
- if you are a MLFC member - we will hold information provided by you on your MLFC application form and any details relating to your account, such as transaction histories;
- if our club photographer has taken a picture of you - we will hold a photograph of you along with any details you may have provided to the photographer, such as your name;
- if we have scanned your ID upon entering our venue - we will hold the information shown on your ID;
- if you have walked within view of our CCTV security surveillance cameras - we will hold footage of you within our club.
We may hold other information about you that we have received or generated in the course of our day-to-day business activities, such as correspondence from you, account information and billing statements.

How we use your information
We use your personal information for the following purposes:
- to provide you with entertainment services and products;
- for internal purposes, such as procedural assessments, risk management, product and service reviews, staff training and accounting; and
- to keep you informed of upcoming events, products and other promotions.
If we have scanned your I.D. upon entry, your information is only used for two purposes.
Firstly, your information is used to ensure that we provide you with a safe and secure entertainment venue. By scanning I.D.s, we are able to strongly deter individuals who intend to engage in inappropriate or illegal activities from entering our club. Scanned I.D. information is used to identify any individuals engaging in such activities, to ban those persons from re-entering our club and to take any other action that we believe is appropriate in the circumstances, such as reporting incidents to the Police.
Secondly, we may use your name and contact details to keep you informed of upcoming events, products and other promotions.
You can request to have your scanned I.D. information removed at any time (see further below).

How we disclose your information
We only disclose your personal information to third parties in very limited circumstances and only if it is necessary for the conduct of our business. We do not, under any circumstances, sell or otherwise trade in your personal information.
Organisations to which we may disclose your personal information include professional service providers (eg. solicitors, accountants and business advisors) and to contractors to whom we out-source certain functions (eg. mailing houses and electronic network administrators). Wherever possible, we impose strict contractual conditions on service providers and contractors to ensure that they handle your information in accordance with the privacy standards set out in the Privacy Act 1988 (Cth).
We may also disclose your personal information where it is expressly permitted under the Privacy Act; for example, where we are legally required to do so.
If we have scanned your I.D. upon entry, we will not disclose this personal information to any third party under any circumstance unless it is to the Police following a specific request to do so by them.

How we secure your information
We hold all of your personal information in a secure manner to ensure that it is protected from unauthorised access, modification or disclosure.
Physical security measures are taken to protect all hardcopy records such as paper documents and CCTV video tapes; for example, access to them is limited and storage cabinets are locked.
Electronic records, including records containing personal information obtained from scanning I.D.s, are protected by username and password access and firewalls. Access to the electronic records is strictly limited to those staff whose tasks require access, such as senior managers and security officers.
When records containing personal information are no longer needed, we ensure those records are destroyed securely; for example, we shred paper records and degauss (ie. demagnetise) electronic records so that information contained in them cannot be retrieved.

Complaints
If you are not satisfied with how we handle your personal information, you can lodge a complaint in writing with our Privacy Officer. Your complaint will be treated as confidential. Our Privacy Officer will contact you within 14 days to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in an appropriate manner with which you are satisfied. You may contact our Privacy Officer to enquire about the progress, or any other aspect, of your complaint at any time.
If you are not happy with how we have resolved your complaint, you are entitled to lodge a complaint with the Federal Privacy Commissioner. However, under s.40(1A) of the Privacy Act, you can only lodge a complaint with the Commissioner if you have first lodged your complaint with us. This is so that we have an opportunity to resolve your concern directly before it is raised with the Commissioner. Information about how to lodge a complaint with the Commissioner is available from the Commissioner’s website at www.privacy.gov.au or by ringing the Commissioner’s information line on 1300 363 992.

Removing your information
If we have scanned your I.D. upon entering our venue or have posted a photo of you taken by our club photographer on our website, you may ask to have the information or photo removed by sending a written request to our Privacy Officer. You do not need to provide a reason for your request. Once our Privacy Officer has verified your identity, your information or photo will be deleted from our database or removed from our website.
If we have deleted your scanned I.D. information, it will not be used for any future purpose, including the sending of promotional materials. The only circumstance in which we may refuse to delete the information is if it is being used for the purpose of investigating inappropriate or unlawful activity that has taken place on or near our premises.
If we remove your picture from our website, it will be stored separately and will not be used for any purpose other than responding to any issues regarding its collection, presentation on or removal from the website.

Accessing your information
You may request access to the personal information we hold about you by sending a written request to our Privacy Officer. You do not need to provide a reason for your request. Once our Privacy Officer has verified your identity, we will provide you with a print-out of information we hold about you within 14 days. We do not charge any fees for providing access.
In rare circumstances, and only where it is permitted under the Privacy Act, we may not be able to provide you with access to your information. This may occur where, for example, we are required by law to withhold the information, it relates to legal proceedings or would affect negotiations we are holding with you. If we are unable to provide you with access, we will provide reasons for this and consider whether the use of an intermediary would be appropriate to provide you with an explanation of your personal information.

Correcting your information
If your personal information is out-of-date or incorrect, you may inform us of this in writing and we will correct it for you. In the unlikely event that we disagree about the accuracy of the information and are unable to change it, you may provide us with a statement indicating that you dispute its accuracy and we will associate the statement with your information in such a manner that it will be brought to the attention of each person who subsequently uses the information.

Promotional information
As outlined earlier in this policy, we may use your personal information to keep you informed of upcoming events, products and other promotions; for example, by sending you mail-outs. If you do not wish to receive promotional materials, you can ask to have your details removed from our promotions database by sending a written request to our Privacy Officer. Your details will be removed from the database and you will not be sent any further promotional materials.

Changes to this policy
Due to changing business circumstances, we may need to make changes to this policy from time to time. However, we will endeavour to ensure that any such changes do not reduce your overall level of privacy protection. Any amended or new policy will be published on our website. Any actions that we have taken before the changes will continue to be regulated by the privacy policy that existed before the changes were made.

Further information
If you have any queries or requests in relation to this policy, please contact our Privacy Officer:
- mail: 58 South Terrace, Fremantle WA 6160
- telephone: (08) 9336 1880
- email: privacy@metropolisfremantle.com.au.

This policy commenced/was last updated on: 6 September 2005.
Strathalbyn West Perth Pty Ltd ABN 27 076 973 852
t/a Metropolis Fremantle