Privacy Policy

This Privacy Policy applies to personal information collected by a member of the Navarra Venues Group and its affiliates (“Navarra Venues”, “we”, “us” or “our”). Navarra Venues is an applicable organisation under the Privacy Act 1988, which governs the way private sector organisations collect, use, store, secure and disclose personal information.

This Privacy Policy explains:

how and when Navarra Venues collects personal information;
how Navarra Venues uses and discloses personal information;
how Navarra Venues keeps personal information secure, accurate and up to date;
how an individual can access and correct their personal information; and
how Navarra Venues will facilitate or resolve a privacy complaint.

We recommend that you read and understand this Privacy Policy and keep it for future reference. If you require any clarification, you can contact us using the details at the end of this document.

1. Personal Information Navarra Venues Collects

What is Personal Information?

Personal information is defined under the Privacy Act 1988 as information or an opinion, whether true or not, and whether recorded in a material form or not, about an individual whose identity is reasonably identifiable from the information or opinion.

Examples of personal information include your name, residential address, email address, phone number, payment details, photographs, video footage, opinions and preferences where they can identify you.

2. Sensitive Information Navarra Venues Collects

What is Sensitive Information?

Sensitive information is a subset of personal information. It includes information or an opinion about an individual’s racial or ethnic origin, political opinions, membership of a political organisation, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, health information, genetic information, biometric information used for automated biometric verification or identification, and biometric templates.

Collection of Sensitive Information

In general, we attempt to limit the sensitive information we collect. However, depending on the services you request from us, it may be necessary for us to collect certain sensitive information in order to provide our products or services to you.

The type of sensitive information we may collect will depend on the services provided to you by Navarra Venues and will be limited to the purpose for which it is collected.

We will not collect sensitive information from you without your consent.

We do not use sensitive information to send you Direct Marketing Communications without your consent.

Consent to Collection of Certain Types of Sensitive Information

We may collect certain types of sensitive information where you have consented to the collection of that information. We will obtain your consent at or around the time we collect the information.

The main types of sensitive information we may collect, if applicable, may relate to your:

age;
marital status;
gender;
special food or dietary requirements due to medical, cultural or religious reasons;
racial origin or religious beliefs, to the extent these are ascertainable; and
taste, trend and styling requirements.

We will only collect this information where it is necessary for, or incidental to, the purposes of collection set out in this Privacy Policy.

3. Collection of Personal Information Required by Navarra Venues

We will only collect personal information that is necessary for us to provide our products and services to you, manage our business, comply with our legal obligations and carry out the purposes set out in this Privacy Policy.

The type of information we may collect includes, but is not limited to:

your contact information, such as your full name, email address, postal address, delivery address and phone number;
your date of birth;
proof of your identity, including but not limited to a driver’s licence, passport or birth certificate;
any sensitive personal information listed in section 2;
emergency contact details, if applicable;
details required as part of a Navarra Venues contract;
details relating to your employment or previous employment, if applicable;
whether you participated in any activity or event organised by Navarra Venues;
photographs or video footage taken at our premises or at a Navarra Venues event off premises, which may include you;
your opinions, statements and endorsements collected personally or via surveys and questionnaires, including your views on the products and services offered by Navarra Venues;
payment or billing information, including bank account details, direct debit details, credit card details, billing address, repayment information and invoice details, where applicable;
information submitted through our website forms, including enquiry details, event requirements, venue preferences and any other information you choose to provide;
website usage information, including pages viewed, clicks, scrolling behaviour, device and browser information, referral sources and advertising campaign information; and
information relating to the source of your enquiry, including the webpage on which a form was submitted, referral information, campaign tracking parameters and other information that helps us understand how visitors find and use our website.

Where reasonable and practicable, we will collect your personal information directly from you. If we collect details about you from someone else, we will, whenever reasonably possible, make you aware that we have done this and explain the reason for it.

When you engage in certain activities, such as entering a contest or promotion, filling out a survey, submitting a form or sending us feedback, we may ask you to provide certain information. Some information may be mandatory and some may be optional.

If you do not provide mandatory information or any other information we require in order to provide our services to you, we may be unable to provide our services to you, or may be unable to provide them effectively.

4. Website Forms, QR Codes, Analytics, Cookies and Advertising Technologies

When you submit an enquiry, booking request, contact form or other online form through our website, we may collect the information you provide, including your name, contact details, event requirements and any other information you choose to submit.

We may also collect information relating to the source of your enquiry, including the webpage on which the form was submitted, referral information, campaign tracking parameters and other information that assists us in understanding how visitors find and use our website.

Some QR codes used by Navarra Venues may direct you to pages on our website. Scanning a QR code does not, by itself, provide us with your contact details. We will only collect your personal information if you choose to submit it, such as by completing a form on our website.

We use cookies and similar technologies to improve website functionality, analyse website performance, understand user behaviour, support our marketing activities and measure the effectiveness of our advertising campaigns.

These technologies may collect information including:

IP address and approximate geographic location;
device, browser and operating system information;
pages viewed and actions taken on our website;
clicks, scrolling behaviour and interactions with website content;
referral sources and websites visited before accessing our website;
advertising campaign information, including UTM parameters and click identifiers; and
interactions with website forms and enquiries.

We use services including Google Analytics, Microsoft Clarity, Meta Pixel, Google Ads and related technologies for analytics, advertising measurement, audience creation, remarketing, campaign optimisation and website improvement.

Microsoft Clarity may collect information about user interactions with our website, including clicks, scrolling behaviour, navigation patterns, heatmaps and session recordings. Sensitive form fields and personal information are masked where applicable.

We may use advertising technologies provided by Google, Meta and other advertising platforms to deliver relevant advertisements, measure advertising performance and show advertisements to users who have previously visited our website.

Information collected through these technologies may be linked to an enquiry where a visitor subsequently submits a form through our website.

You may manage your cookie preferences through our cookie consent banner or through your browser settings. Disabling certain cookies may affect the functionality of our website.

5. Use and Disclosure of Your Personal Information

We will only use or disclose your personal information for the primary purposes for which it was collected, for related purposes you would reasonably expect, where you have consented, or where permitted or required by law.

You consent to us using and disclosing your personal information to facilitate a purpose in connection with:

verifying your identity, including verification of your date of birth, if applicable;
facilitating contract requirements;
providing our products and services to you;
administering and managing our products and services, including charging, billing, payment authorisation, credit card verification, financial checks, fraud prevention and debt collection;
tailoring menus, events, functions, packages or services to your needs;
responding to enquiries, booking requests, customer service requests and complaints;
managing, administering and improving Navarra Venues;
communicating between related venues, entities and departments;
managing governance, administration, business systems and infrastructure;
facilitating medical assistance in the event of a medical emergency, or providing medical treatment as requested by you;
coordinating, managing and maintaining good order and security of Navarra Venues and our premises;
protecting the rights and safety of other parties on our premises;
investigating and reporting accidents or incidents that may have occurred on our premises;
improving our products and services, including contacting you about those improvements or asking you to participate in surveys;
marketing and promotional activities by us and our related bodies, including by direct mail, telemarketing, email, SMS and MMS messages;
offering you updates, content, products or services that may be of interest to you;
analysing marketing performance, including using referring websites, landing pages, campaign identifiers and tracking parameters;
understanding how customers engage with our website, advertising and enquiries;
complying with applicable laws; and
any other matters reasonably necessary for us to provide our products and services to you or operate our business.

We may also use or disclose your personal information without seeking additional consent:

where the use or disclosure is related to the primary purpose of collection and you would reasonably expect us to use or disclose the information for that purpose;
if we reasonably believe the use or disclosure is necessary to lessen or prevent a serious threat to an individual’s life, health or safety, or to public health or safety;
if we have reason to suspect unlawful activity has been, or is being, engaged in;
where required or authorised by law; or
where formally requested by a statutory or regulatory authority.

If we propose to use or disclose your personal information for a purpose other than those described in this Privacy Policy, we will seek your consent where required.

6. Organisations to Which We May Disclose Your Personal Information

We may disclose your personal information to other organisations where necessary for the goods or services we provide to you, for a purpose permitted by this Privacy Policy, or where required or authorised by law.

Examples of organisations and parties to whom your personal information may be disclosed include:

other member venues and reciprocal venues;
related entities and subsidiaries of Navarra Venues;
third parties, including trade suppliers, event suppliers and Navarra Venues sponsors;
contractors and agents who assist us in providing products and services to you;
professional advisers, including accountants, solicitors, insurers and auditors;
website hosting providers and technology service providers;
customer relationship management, marketing automation and email communication providers;
analytics and advertising service providers, including Google, Microsoft and Meta, where applicable;
payment processors and financial service providers;
regulatory authorities, law enforcement bodies or government agencies where required or authorised by law; and
offshore service providers, if applicable.

We take reasonable steps to ensure that these organisations and parties are aware of the need to handle your personal information in accordance with applicable privacy obligations.

7. Photographs and Closed Circuit Television

Closed circuit television cameras may be fitted throughout our venues and surrounding areas, including entry and exit points. CCTV is used as part of our security system and to help maintain the safety and security of guests, staff, contractors and visitors.

CCTV footage is stored for a minimum retention period of 14 days unless an incident is identified. If an incident is identified, footage may be archived and retained for a longer period, including for a minimum period of one year, or provided to a relevant authority such as police or Liquor & Gaming NSW where required or requested.

Where no incident has been identified, CCTV footage is generally deleted within 30 days after the retention period.

We may take photographs or video footage of you attending our premises or Navarra Venues events held off premises. We may wish to use this material for marketing, promotional and advertising purposes. Unless you advise us otherwise, you consent to the use of photographs or video footage that may include you for these purposes, without compensation.

8. Direct Marketing

You consent to us using your personal information, including any email address or phone number you provide to us, to send you information about our products, services, events, offers, updates or other direct marketing communications that we consider may be of interest to you.

We may send Direct Marketing Communications where you have consented to receive them, where it is within your reasonable expectations based on your transaction or communication with us, or where otherwise permitted by law.

If at any time you do not wish to receive further Direct Marketing Communications from us, you may unsubscribe using the unsubscribe facility included in the communication, or contact us using the details at the end of this document.

We will not use sensitive information to send you Direct Marketing Communications without your consent.

9. Venue Capacities at Navarra Venues

Please note that advertised venue capacities and guest numbers are subject to licensing and development consent requirements.

10. Cross-Border Disclosure

Any personal information that you provide to us may be transferred to, stored or processed outside Australia where we use overseas data hosting facilities, website hosting facilities, cloud-based systems, analytics platforms, advertising platforms, customer relationship management systems or other third-party service providers.

Personal information may also be processed by staff, contractors or third parties operating outside Australia who work for us, one of our suppliers, agents, partners or related companies.

By submitting your personal information to us, you consent to the disclosure, transfer, storage or processing of your personal information outside Australia. You understand and acknowledge that countries outside Australia may not always have the same privacy protection obligations as Australia.

However, we will take reasonable steps to ensure that your information is used by third parties securely and in accordance with this Privacy Policy.

If you do not agree to the transfer of your personal information outside Australia, please contact us using the details at the end of this document.

11. Data Quality and Security

We take reasonable steps to help ensure your personal information is safe. However, you will appreciate that we cannot guarantee the security of all transmissions or personal information, particularly where the Internet is involved.

We will take reasonable steps to:

make sure the personal information we collect, use or disclose is accurate, complete and up to date;
protect your personal information from misuse, loss, unauthorised access, modification or disclosure, both physically and through computer security methods; and
destroy or permanently de-identify personal information if it is no longer needed for the purpose for which it was collected, unless we are required or authorised by law to retain it.

The accuracy of personal information depends largely on the information you provide to us. We recommend that you:

let us know if there are any errors in your personal information; and
keep us up to date with changes to your personal information, such as your name, address, phone number or email address.

12. Access to and Correction of Your Personal Information

You are entitled to request access to any personal information relating to you that we hold, except in circumstances where access may be refused under applicable law.

You are also entitled to request correction of your personal information if it is inaccurate, out of date, incomplete, irrelevant or misleading.

If you would like to access or correct any personal information we hold about you, please contact us using the details at the end of this document.

13. Consent to This Privacy Policy

By visiting any of our venues, using our website, submitting an enquiry, using our products or services, or accepting the terms of any agreement that refers to this Privacy Policy, you agree to the terms of this Privacy Policy.

We reserve the right to modify this Privacy Policy as our business needs require. Your continued use of our products, services or website, or your continued dealings with us, will be taken as your agreement to the modified terms.

If you do not agree to our continued use of your personal information due to changes in this Privacy Policy, please contact us using the details at the end of this document.

14. Resolving Privacy Complaints

We have procedures in place to resolve privacy complaints. We will ensure that complaints are dealt with in a reasonably appropriate timeframe and in a manner that does not compromise the integrity or quality of any decision.

If you have any concerns or complaints about the manner in which we have collected, used, disclosed or stored your personal information, you can contact us using the details below.

In order to resolve a complaint, we will endeavour to:

liaise with you to identify and define the nature and cause of the complaint;
request that you provide the details of the complaint in writing;
keep you informed of the likely timeframe within which we will respond to your complaint;
inform you of the legislative basis, if any, of our decision in resolving the complaint; and
keep a record of the complaint and any action taken in a privacy register.

15. Contact Details

If you have any questions, concerns or complaints about this Privacy Policy or the way we handle your personal information, please contact us:

Email: [email protected]

Post: Navarra Enterprises Pty Ltd, Level 1, 36 James Craig Road, Rozelle NSW 2039, Australia