EVT Group Privacy Policy

1 ) Summary of key points

This Privacy Policy applies to all EVT Group businesses in Australia and New Zealand, including our cinemas, hotels, resorts, the State Theatre, the Thredbo Alpine Resort, and our Cinebuzz and Priority Guest Rewards loyalty programs.

We believe in being transparent about how we handle your Personal Information, so have summarised the key features of our Privacy Policy in this section.  Our full policy is set out in detail below.

Consent and opting-out

When you provide us with and consent to our use of your Personal Information (for example, by agreeing to our terms and conditions), you consent to our collection and use of your Personal Information (which is information about you which identifies you, or which can be used to reasonably identify you) in accordance with this Privacy Policy. You can withdraw your consent at any time by contacting us. You can also opt-out from receiving any marketing communications from us or from our marketing partners, and from our use or disclosure of your Personal Information for marketing purposes.

If you do not provide your consent, or if you withdraw your consent to our use of your Personal Information, it may mean we are unable to provide you with the same services, offers, or discounts that we would otherwise be able to provide.

What Personal Information we collect

The Personal Information we collect about you may include your name, contact details, and billing information, but may also include information about the goods and services you buy from us, and how you interact with us (for example, how you access and use our websites or mobile applications).

How we collect your Personal Information

We collect Personal Information about you directly from you or by your use of our websites or mobile applications, from public sources, and in some cases from third party ticketing and event organisations.

How we use your Personal Information

Our policy is to use your Personal Information to deliver our products and services to you, to improve our services, and to market products and services to you. In some cases, we share your Personal Information with third parties who perform these activities or do so on our behalf.

Personal Information of employees and contractors

We collect, use, hold and disclose Personal Information of our employees and contractors in order to manage our employment or contracting relationships.

If employees or contractors choose not to provide Personal information to us, we may not be able to manage or administer our employment or contracting relationships, including paying salary, wages or other amounts or benefits to which employees or contractors may be entitled.

How and where we store your Personal Information

We take commercially reasonable steps to secure your Personal Information from unauthorised access, and to ensure the people we share your data with do the same.  Third parties to whom we send your data may be located in or operate data centres located in Australia or foreign countries including in the European Union, Hong Kong, India, Japan, The Philippines, New Zealand, Singapore, Sri Lanka, United Kingdom, or the United States of America.

Accessing, correcting, or deleting your Personal Information

You can request access to, correction, or deletion of your Personal Information or withdraw your consent to our use of your Personal Information by contacting us at privacy@evt.com.

2) The EVT Group

EVT Ltd and its related bodies corporate (the EVT Group) own, co-own, operate and/or manage a range of premier entertainment, hospitality, and leisure businesses, including:

(a) EVENT cinemas, Rialto cinemas, Moonlight cinemas, Greater Union cinemas, BCC Cinemas, and the State Theatre and Embassy Theatre;
(b) Cinebuzz On Demand streaming service;
(c) Rydges Hotels, QT Hotels and Resorts, Atura Hotels, Independent Collection by EVT and the Thredbo Alpine Resort;
(d) JUCY Snooze and LYLO; and
(e) loyalty programs, including Cinebuzz Rewards and Priority Guest Rewards.

The EVT Group understands and appreciates that you are concerned about your privacy and about the confidentiality and security of your Personal Information, and is committed to ensuring your Personal Information is protected.

3) This Privacy Policy and your consent

This Privacy Policy explains how we collect and handle your Personal Information in Australia and New Zealand.  Personal Information is information about you which identifies you or which can be used to reasonably identify you. When you consent to us using your Personal Information, you agree that we may use your Personal Information in accordance with this policy.  You can withdraw your consent at any time by contacting us.

If you do not provide consent, or if you withdraw your consent to our use of your Personal Information, it may mean we are unable to provide you with the same services or the same level of service that we would otherwise be able to provide. For example, we may not be able to provide you with personalised recommendations, or with exclusive or discounted offers.

From time to time, there may be specific and additional privacy provisions that apply to our collection and use of your Personal Information.  For example, Personal Information provided when participating in a promotion, entering a competition, subscribing to a newsletter, or participating in a survey may be subject to a different privacy policy or contractual terms. If there is any inconsistency between this Privacy Policy and those specific and additional provisions, the specific and additional provisions will prevail.

Section 11 of this Privacy Policy outlines specific provisions with respect to EVT Group’s collection, use, holding and disclosure of Personal Information of its employees and contractors (including employees of contractors providing services to the EVT Group) in order to manage its employment and contractor relationships. If there is any inconsistency between section 11 and the other terms of this Privacy Policy, section 11 will prevail.

4) Personal Information we collect

The types of Personal Information we collect depend on what services you use and products you acquire. It may include:

(a) identifying information, such as your name, gender and date of birth;
(b) contact information, such as your postal address, email address and telephone numbers;
(c) social media handles and other social media profile information that you make available to us or to the public;
(d) billing and financial information, such as credit card, bank account or other payment details;
(e) details of any products or services that you purchase from us or that we provide to you;
(f) information about how you use the products and services we provide, such as:
(i) your cinema or movie preferences; or
(ii) your accommodation, travel, and meal preferences;
(g) records of our communications with you, including any messages or enquiries you send us (either through the website or through other means);
(h) information about how you access and use our websites or mobile applications, such as your IP address and internet service provider, the web page you visit us from, web browser, navigation patterns on our websites, device identity and location, operating system, or device configuration; and
(i) additional information, including your image, collected via Closed Circuit Television (CCTV) systems used at venues we operate.

5) How Personal Information is collected and held

5.1 Personal Information
We collect Personal Information about you:
(a) when you purchase products or services from us at one of our venues or  through our websites or mobile applications (such as when you purchase movie or theatre tickets, book accommodation, or purchase Thredbo lift tickets online);
(b) when you sign up to become a member of one of our loyalty programs;
(c) when you submit feedback, a query or request to us;
(d) when you participate in a promotion, competition, or survey that we run;
(e) when you fill in forms on our website or at one of our venues;
(f) when you check-in at one of our hotels or resorts;
(g) when you sign-up to receive our emails, newsletters, information about our special offers, and/or any other promotional material;
(h) by tracking your use of our websites or mobile applications;
(i) through our CCTV systems at our venues;
(j) when you access or use Wi-Fi portals owned or operated by us;
(k) from public sources;
(l) from third parties who are entitled to disclose that information to us (including third party ticketing and events organisations such as Ticketmaster Australasia Pty Ltd); and
(m) when you apply for a job with us.

5.2 Sensitive information
Generally, we do not collect sensitive information. In rare circumstances, however, we may collect sensitive information about you, for example:
(a) if you engage in a high-risk leisure activity at a venue we operate and complete a medical release form;
(b) in the event you are involved in an accident, injury, or incident at one of our venues; and
(c) as required to comply with any law, regulation or Federal or State government order or direction including in respect of a pandemic, epidemic (including Covid-19) or a state of emergency.

Any use of sensitive information we collect from you may be subject to additional restrictions outside this policy.

5.3 CCTV and Live Snow WebCams

You may be recorded on CCTV cameras at EVT Group venues (including Live Snow WebCams at the Thredbo Alpine Resort). Footage from CCTV cameras and from Live Snow WebCams may be recorded and used if required for safety and / or security purposes, for research purposes, and for optimising the delivery of our products and services. Footage from the Live Snow WebCams is publicly available on the Thredbo website at www.thredbo.com.au, as well as a number of websites operated by third parties.

6) Purposes for which we use or disclose Personal Information

We use Personal Information that you provide to us:

(a) to help you access the services or acquire the goods the EVT Group provides;
(b) to provide you with information and offers in relation to goods and services offered by the EVT Group that may be of interest to you (including information and offers in relation to the EVT Group’s hotel, resort, cinema, theatre and ski resort businesses);
(c) to improve our products and services and tailor them to your interests;
(d) to determine your eligibility or suitability for any of our products or services;
(e) when you purchase a product through or view a product on our websites, to display to you offers of goods and services from third parties that may be appropriate to your interests;
(f) by providing it to our payment processing provider so they can:
(i) improve the payment processing services they provide to us and to you, including by developing fraud detection and prevention tools;
(ii) monitor, prevent, and detect fraudulent payment transactions;
(iii) comply with legal or regulatory obligations applicable to the payment processing services they provide, including applicable anti-money laundering and identity verification obligations, or to assist law enforcement agencies by responding to requests for information;
(iv) analyse, develop and improve their products and services;
(v) perform data analysis; and
(vi) de-identify and aggregate payment transaction data for the purpose of statistical analysis of payments by region or industry;
(g) to modify advertising (including re-marketing) shown on our websites so that it is customised or more relevant to your interests, characteristics or general location;
(h) to answer your feedback, queries and requests;
(i) to comply with our legal and regulatory obligations in respect of your Personal Information (including your sensitive information) under any law, regulation or Federal or State government order or direction including in respect of a pandemic, epidemic (including COVID-19) or a state of emergency;
(j) to develop and improve our existing products and services and create new products and services (including by carrying out market analysis and research);
(k) to monitor use of our products and services (including our websites);
(l) to improve customer service and our customer relationships;
(m) to assess, maintain, upgrade and improve our products and services;
(n) to carry out education and training programs for our staff;
(o) to manage and resolve any legal or commercial complaints or issues;
(p) to process applications for a job with us;
(q) to carry out planning and forecasting activities and other internal business processes; and
(r) for marketing purposes in accordance with part 8 below, and to keep you informed about our activities and promotional offers, including by sending out newsletters and emails.

We may also use your Personal Information for other purposes as authorised by you, or in accordance with your requests or instructions.

7) People to whom we disclose Personal Information

We will only disclose your Personal Information to third parties in compliance with this Privacy Policy.

We may share Personal Information about you with:

(a) your representatives, advisers and others you have authorised to interact with us on your behalf;
(b) our staff who need the information to discharge their duties;
(c) EVT Group companies including our cinema, hotel, resort and ski resort operating companies;
(d) the owners (and their employees and representatives) of hotels and resorts that EVT Group companies manage, grant a licence to or provide services to;
(e) our business partners, agents and service providers (including information technology service providers, data hosting and processing companies, loyalty, data and research companies, fraud detection, prevention and security service providers and social media channel operators);
(f) our Marketing Partners, as outlined in part 8 below;
(g) if you are or become a Priority Guest Rewards (PGR) Member, with the Global Hotel Alliance (based in the United Arab Emirates);
(h) payment system operators as outlined in part 9 below, banks and financial institutions;
(i) prospective purchasers of all or part of our business assets or shares in our company or a related entity;
(j) professional advisers who we engage to provide advice on our business; and
(k) government and law enforcement bodies and authorities who ask us to disclose that information, or to other people as required to comply with our legal and regulatory obligations in respect of your Personal Information (including your sensitive information) under any law, regulation or Federal or State government order or direction including in respect of a pandemic, epidemic (including COVID-19) or a state of emergency.

8) Marketing

8.1 How the EVT Group markets its services to you

We may from time to time use your Personal Information in order to send you marketing materials about products or services that you may be interested in (including in some cases products and services that are provided by third parties).  You can opt-out of receiving marketing communications from us by contacting us using the details in the “contact us” section below, or by following the “unsubscribe” or “opt-out” link in the communication you receive from us.

8.2 Our Marketing Partners

The EVT Group will from time to time engage trusted third-party marketing and media partners and programmatic or display vendors (collectively Marketing Partners) to:

(a) send you marketing or promotional content and offers that you may be interested in;
(b) deliver to you personalised advertisements or targeted promotional content via email, online, or via social media platforms.

Promotional content and personalised advertisements may be for goods or services provided by businesses outside the EVT Group.

The Marketing Partners we work with include but are not limited to:

(a) ROKT: ROKT: Some advertisements or offers for goods and services displayed on our websites and through our mobile apps are provided by our specialist Marketing Partner ROKT Pte Ltd, a Singapore company. When you purchase goods and services from us online, we may provide limited information about you to ROKT so that you can choose to opt-in to personalised opportunities offered by ROKT. If you choose to opt-in, your name, email address and other limited information about your transaction with us will be provided by ROKT to the relevant advertiser or their agent to enable fulfilment of the opportunities you have elected to opt-in to.  Any information collected by ROKT is subject to its privacy policy available at http://rokt.com/blog/privacy-policy/
(b) Movio: To enable delivery of personalised advertisements or targeted promotional content, we share your Personal Information with Movio Limited, a New Zealand company that provides marketing services to the EVT Group and to other businesses in the cinema industry.  Movio combines de-identified Personal Information with other data shared by other service providers such as LiveRamp Holdings, Inc., Google, and Facebook, to deliver content that is relevant to you. Any information collected by Movio is subject to its privacy policy available at https://movio.co/privacy-policy/
(c) Facebook: To enable delivery of targeted advertising messages we share hashed email addresses and/or phone numbers of our customers with Facebook and utilise the Facebook pixel on our websites. Facebook uses this hashed information and cookie information to match profiles within their platform to create targeted audiences to deliver content that is relevant to you. Any information collected by Facebook is subject to its privacy policy available at https://www.facebook.com/privacy/explanation

9) Our payment processor

The EVT Group has engaged PayPal trading as Braintree (PayPal) to provide payment processing services (including processing of online credit-card transactions). We provide your Personal Information to PayPal for the purpose of processing payment transactions and for the purposes disclosed in part 6(f) above.

PayPal is an independent data controller, which means that it determines the purposes for and means by which it processes personal information. PayPal’s privacy policy for the Braintree payment processing services is available at https://www.braintreepayments.com/au/legal/braintree-privacy-policy

10) Overseas disclosure

Third parties to whom we may disclose Personal Information may be located outside Australia. The EVT Group, its affiliates, service providers, and related entities use data storage facilities in Australia and in foreign countries including New Zealand, Hong Kong, Singapore, the United Kingdom and the United States of America.

Our Marketing Partners are located and/or use data storage facilities located in Australia and in foreign countries including Hong Kong, India, Japan, The Philippines, New Zealand, Singapore, Sri Lanka, United Kingdom and in Europe and the United States of America.

We take commercially reasonable steps to ensure that any overseas recipient of Personal Information has appropriate safeguards in place to ensure a level of protection of your Personal Information that does not breach Australian or New Zealand privacy law or this Privacy Policy.

11) Personal Information of employees and contractors

11.1 Personal information of employees and contractors

The EVT Group collects, uses, holds and discloses Personal Information of its employees and contractors (including employees of contractors providing services to the EVT Group) in order to manage our employment or contracting relationship with you.

This Personal Information includes your name, contact details, employment or engagement history and other relevant Personal Information. Where relevant, we may also collect additional relevant Personal Information, such as your superannuation details, bank account details, tax file number, citizenship status, work visa or other right to work documents, educational or professional qualifications, emergency contact details, and relevant medical and health-related information (including any disabilities or medical conditions you may have).

We will collect such Personal Information from you where possible, but we may also collect your information from third parties (such as your referees, law enforcement agencies, and other government bodies), in which case we will take reasonable steps to ensure that you are aware of the matters contained in this policy. If you provide us with the personal information of another person (such as the name and contact details of your referees), you must make them aware of the matters contained in this policy.

If you choose not to provide your Personal Information to us, we may not be able to manage or administer our employment or contracting relationship with you, including paying you the full amounts of any salary, wages or other amounts or benefits which you may be entitled to.

We may disclose such Personal Information to companies and businesses within the EVT Group, our contractors, agents and service providers, other parties listed in section 7, and government bodies and regulatory authorities (where required or authorised by law), in order to manage our employment or contracting relationship with you, to allow you to use various information technology systems and platforms to enable you to undertake tasks and activities relevant to your employment or contracting relationship with us, or for purposes listed in section 6, and to our customers and clients in connection with our provision of goods and services to them. Personal Information may be disclosed overseas as outlined in section 10.

11.2 Recorded Images of employees and contractors

From time to time, we may organise for photographs, video or other recordings (Recorded Images) to be taken of our employees and contractors while they are working, attending EVT Group-related work or social events, or undertaking EVT Group-related entertainment activities or experiences.

Recorded Images may be used by us at our discretion for internal and external purposes and to promote a positive image of the EVT Group, including on our internal systems (such as our “Workplace” system), in internal and external corporate, promotional, marketing, HR, training, and induction materials, publicly available websites, brochures, publications or annual reports, or in news media reports.

Recorded Images may be provided to other companies in the EVT Group, and external parties in Australia and overseas – such as marketing providers, printing companies for the purposes of preparing such publications, or to news media organisations for publication in news media reports.

12) Cookies

12.1 What is Cookie Information?

We may collect information and data when you visit our website using cookies, tags, pixels and other similar technologies (Cookie Information). Cookie Information includes pieces of information that a website can transfer to an individual’s computer hard drive for record keeping, such as the IP address of a user’s computer, the URL of a page visited and the time the page was visited by the user. The collection and use of Cookie Information is an industry standard and many websites collect this information.

Cookie Information is useful for facilitating a user’s access to and use of a website. It allows us to track usage patterns and compile data that can help us improve our services.

Cookie Information is useful to advertisers because it helps them understand their advertising audience, and to deliver advertising.

12.2 How do we use Cookie Information?

We may use Cookie Information, or engage third parties who collect similar information and data from publicly available sources, to deliver or modify advertising (including re-marketing) that is customised or more relevant to your interests, characteristics or general location (Targeted Advertising).

In order to carry out Targeted Advertising we may build a user and/or device profile by:

(a) using Cookie Information and de-identified system information that we hold;
(b) using device-matching technologies that utilise mobile device advertising identifiers as well as Cookie Information; and
(c) engaging or working with third parties who provide the EVT Group with information about you collected from publicly available sources or from their own databases.

We may also work with other companies to advertise their products and services online using Cookie Information. When we provide Cookie Information to third parties, we take commercially reasonable steps to ensure that the information is de-identified.

12.3 To whom do we disclose Cookie Information?

Examples of third parties that we may work with and disclose Cookie Information to include external companies and agencies that provide programmatic advertising services, specialist data companies, advertising platform providers, advertising servers, data partners, specialist data providers and social media operators such as Facebook.

12.4 How can you control Cookie Information?

The settings of most web browsers can be modified to prevent the collection of Cookie Information. You can also delete Cookie Information from your device.

Most mobile devices operating common operating systems such as Android or iOS record a unique advertising identifier. This identifier may be part of the Cookie Information we collect, and can be reset in the device settings.

13) Storage and security of your Personal Information

We generally store the Personal Information that we collect in electronic databases, some of which may be held on our behalf by third party data storage providers located in the countries identified in section 10 of this policy.

We may also, at times, keep hard copy records of Personal Information in physical storage facilities.  We use a range of physical and technical security processes and procedures to protect the confidentiality and security of the Personal Information that we hold, and we update these from time to time to address new and emerging security threats.

14) Access to and correction of Personal Information

You have a right to access and correct most of the Personal Information we hold about you.  If you wish to access or correct your Personal Information, please contact us via the details provided in the “contact us” section below.

To protect the integrity and security of the Personal Information we hold, we may ask that you follow a defined access procedure, which may include steps to verify your identity.  In certain cases we may charge you an administration fee for providing you with access to the information you have asked for, but we will inform you of this before proceeding.  There may be cases where we are unable to provide the information you request, such as where it would interfere with the privacy of others or result in a breach of confidentiality.  In these cases we will let you know why we cannot comply with your request.

If you have an account with any of our businesses, receive newsletters or marketing materials or if you are a member of any loyalty program we operate, you can also contact us or update your profile online:

(a) Cinebuzz (Australia): https://www.eventcinemas.com.au/cinebuzz/landing
(b) Cinebuzz (New Zealand): https://www.eventcinemas.co.nz/cinebuzz/landing
(c) Priority Guest Rewards: https://www.priorityguestrewards.com/
(d) Rydges Hotels: https://www.rydges.com/
(e) Atura Hotels: https://www.aturahotels.com/
(f) QT Hotels & Resorts: https://www.qthotels.com/
(g) Independent Collection by EVT: https://www.independentcollection.com.au
(h) Thredbo: https://www.thredbo.com.au
(i) State Theatre: https://www.statetheatre.com.au/
(j) Edge Content & Technology: https://www.edgect.com.au/
(k) Jucy Snooze: https://www.jucysnooze.co.nz/
(l) Lylo: https://lylo.com/

15) Changes to this policy

We may make changes to this policy from time to time, to take into account changes to our standard practices and procedures or where necessary to comply with new laws and regulations.  The latest version of this policy will always be available on our website.

16) Complaints

We try to meet the highest standards in order to protect your privacy.  However, if you are concerned about the way in which we are managing your Personal Information and think we may have breached the Australian Privacy Principles, the Information Privacy Principles (NZ), or any other relevant obligation, please contact us using the contact details set out below.  Complaints must be lodged in writing.  We will deal with the matter within a reasonable time, and will keep you informed of the progress of our investigation.

If we have not responded to you within a reasonable time or if you feel that your complaint has not been resolved satisfactorily, you can contact us to discuss your concerns.

In respect of Personal Information we collect in Australia, you are also entitled to make a complaint to the Office of the Australian Information Commissioner (OAIC). Contact details can be found at the OAIC website: www.oaic.gov.au.

In respect of Personal Information we collect in New Zealand, you are also entitled to make a complaint to the Office of the Privacy Commissioner (OPC). Contact details can be found at the OPC website: www.privacy.org.nz.

17) Contact us

We take the privacy of your Personal Information seriously. If you have any questions, comments, or complaints in relation to this Privacy Policy or our handling of your Personal Information, or if you wish to access or correct your Personal Information, please contact us:

By email: privacy@evt.com; or

By mail: Privacy Officer
EVT Ltd
478 George Street
Sydney NSW 2000