Privacy Policy

TruShare is a racehorse membership platform. Members pay an initial joining fee and an ongoing membership fee to access insights and experiences relating to a premium thoroughbred they choose to follow, and to participate in member Reward Draws. No ownership interest is conferred, and Members do not acquire an ownership interest in any horse.

2.1 Personal Information

Personal information is information or an opinion from which your identity is reasonably apparent. The kind of personal information we collect depends on the nature of your dealings with us, and may include:

• Identity and contact details: name, email address, phone number, postal address, and date of birth (used to confirm you are 18 years or over).
• Membership details: the thoroughbred you choose to follow, your membership status, tier and anniversary date.
• Payment information: information collected when you pay your joining fee or membership fee, including transaction details and bank account details. Payments are processed by our third-party payment provider, and we do not store full card numbers on our own systems.
• Promotion entries: information you provide when you enter any Reward Draw or promotion we run, including the eligibility details we require (such as age and state of residence).
• Correspondence: records of your communications with us, including support enquiries and feedback, whether by website, email, telephone or other means.
• Preferences: your communication preferences and service usage information.
• Survey and research responses: your responses to any surveys or customer research we conduct.
• Employment information: where you apply for a role with us, information about your qualifications and employment history.

2.2 Information We Collect Automatically

• Technical and usage data: details of your visits to our website and app, including IP address, device and browser type, pages visited, referring URLs, traffic data, and how you interact with the Platform.
• Cookies and similar technologies: data collected through cookies, analytics and advertising tools (see clause 8).

2.3 Photographs and Images

We may take, or arrange for another person to take, photographs and images of you while you attend an event. By attending, you acknowledge that these images are owned by TruShare and may be used for promotional, legal or other purposes in accordance with this Policy.

2.4 Sensitive Information

Sensitive information (as defined in the Privacy Act, and including health information, racial or ethnic origin, and biometric information) will only be collected with your consent, or where required or authorised by law. We take appropriate measures to protect the security of any sensitive information we hold.

3.1 Collection From You

We collect your personal information directly from you, including when you:

• interact with us over the phone, in person, online (including via social media), or in writing;
• complete any application, consent form, survey, feedback, complaint, questionnaire or incident report;
• present identification documents to us;
• subscribe to any TruShare publication (including electronic publications);
• purchase, redeem or claim merchandise, products or services from TruShare;
• respond to any inquiries we make for compliance purposes;
• become a Member with us or access our website or app;
• participate in any program, activity, promotion, competition or event run by TruShare;
• negotiate or enter into any arrangement or contract with us;
• apply for or take up employment, a volunteer position, or a contractor or consultant role with us; or
• where we are required to do so by law.

3.2 Providing Information

Depending on the circumstances, some information will be required and some may be optional. If you do not provide the information we request, or choose to remain anonymous or use a pseudonym, this may affect our ability to communicate with you, provide the products or services you request, or allow you to participate in a promotion. Where it is impracticable for us to deal with you as a result, we may be unable to do so.

3.3 Collection From Third Parties

We may collect personal information about you from a third party where it is unreasonable or impracticable to collect it from you directly. Such third parties may include, without limitation, our data analytics providers, payment providers, draw service providers and regulatory bodies.

We use your personal information to:

• provide you with the information or services you request from us;
• create, administer and manage your membership account;
• process your joining fee, membership payments and any Rewards;
• verify your eligibility (including age and location) to become a Member or enter a promotion;
• administer Reward Draws and promotions, including selecting and notifying winners and publishing results as required by law;
• communicate with you about your membership, the thoroughbred you follow, and Platform updates;
• send you marketing and promotional material, which you opt in to receive by creating an account or subscribing with your email (you can unsubscribe at any time);
• administer, manage and provide access to our website and app;
• improve our website, Platform and services, and measure the effectiveness of our advertising;
• meet our legal, regulatory and record-keeping obligations;
• detect, prevent and respond to fraud, misuse or security incidents;
• conduct customer research, surveys and analyses;
• process payments, including determining any liability to Australian GST and other taxes; and
• carry out other internal administrative purposes.

If you do not provide the information we ask for, we may be unable to provide you with membership, process your entry into a promotion, or deliver the services you have requested.

5.1 Conducting Promotions

From time to time we run promotions, including trade promotion lotteries such as our Cohort Rewards Promotion, our Loyalty Rewards Promotion, and our waitlist prize draw. Where you enter one of these promotions:

• we collect and hold the personal information needed to administer the promotion, confirm your eligibility, conduct the draw, and contact and pay any winner; and
• entry is open to Australian residents aged 18 years and over, excluding residents of the Australian Capital Territory. We collect your age and state of residence to confirm your eligibility.

5.2 Publication of Winners

Where required by an applicable trade promotion permit or law, we may publish a winner’s surname, first name initial and postcode, within the period required by that permit or law. We will tell you what will be published in the relevant terms and conditions.

5.3 Use of Winner Details in Marketing

By accepting a Reward, you consent to us using your first name, your suburb, city or region, the value of the Reward, and any photograph, video or statement you provide, in our marketing and promotional materials and across our websites, social media channels and other platforms, in accordance with the Rewards Schedule and without further consent or payment. You may ask us to stop using your image in future marketing at any time by contacting us, and we will act on that request on a reasonable, prospective basis.

5.4 Record Keeping

We retain records relating to entries, draws, winners, verification and prize distribution for the period required by applicable State and Territory gaming laws and our permit conditions, and in any event for at least seven (7) years.

5.5 Relationship With Promotion Terms

The full terms and conditions for each promotion set out how your information is collected, used and disclosed for that promotion, and should be read together with this Privacy Policy.

We take reasonable steps to ensure your personal information is kept secure and is accurate, up to date and stored in a secure environment accessed only by authorised persons. We hold your personal information in electronic form using third-party platforms and service providers, and we take reasonable steps to protect it from misuse, interference, loss, and unauthorised access, modification or disclosure, including through:

• password-protected systems and databases and Secure Socket Layer (SSL) technology for our website;
• regularly assessing the risk of misuse, interference, loss, and unauthorised access, modification or disclosure;
• keeping an audit trail of when personal information is added, changed or deleted, and restricting staff access to those who need it;
• confidentiality requirements for our employees, volunteers and service providers;
• conducting regular audits of our controls; and
• maintaining and regularly updating our data breach response plan to meet our obligations under the Notifiable Data Breaches scheme.

No method of transmission or storage is completely secure, and while we work to protect your information, we cannot guarantee absolute security. When your personal information is no longer needed for any purpose for which it may lawfully be used, and we are not required by law to retain it, we will take reasonable steps to destroy or de-identify it.

We disclose personal information to business partners, authorities, suppliers and successors in title to our business that are engaged to process such information on our behalf, for the following purposes:

• to the extent necessary to provide the service you have requested or to meet the purpose for which the information was submitted;
• to service providers, including payment processors, customer relationship management and email platforms, hosting providers, analytics and advertising providers, draw service providers, and other technology suppliers who help us operate our business;
• to professional advisers, including legal, accounting and audit advisers;
• to regulators, government or law enforcement bodies where required or authorised by law, including in connection with trade promotion permits;
• to actual or prospective purchasers or successors (and their advisers) in connection with a sale, merger or restructure of our business;
• to check your age and eligibility for competitions and promotions; or
• where the disclosure is permitted by law or the APPs, necessary to co-operate with a law enforcement agency, necessary to protect the rights or property of TruShare, necessary to lessen or prevent a serious threat to life, health or safety, or required to establish or defend a legal claim.

We require our service providers to handle your personal information consistently with this Policy and applicable law. We do not sell your personal information.

We collect data about your use of our website and your preferences so we can recognise you as a repeat visitor and provide a more tailored experience. The tools we use include:

• cookies;
• Google Analytics 4 (GA4);
• Google Ads tracking;
• Meta Pixel;
• Meta Conversions API; and
• other cookies and technologies for analytics, measurement and advertising purposes.

Cookies are small data files transferred to your device that help our website and app function, remember your preferences, understand how they are used, and deliver and measure advertising. If you register with us or continue to use our website, you agree to our use of cookies and analytical tools. You can manage or delete cookies through your browser settings, though disabling them may affect your ability to use some features of our website.

8.1 Third-Party Analytics and Advertising

We use third-party analytics and advertising tools (which may include providers such as Google and Meta) that set their own cookies and collect information about your activity on our website and across other sites to help us understand our audience and show relevant advertising. These providers may combine this information with data they hold from other sources, and their handling of your data is governed by their own privacy policies.

Some of our service providers, including our analytics and advertising providers (such as Google and Meta), store or process personal information outside Australia, including in the United States. Using the internet to collect and process data may also involve the transmission of data internationally. Where we disclose your information overseas, we take reasonable steps to ensure it is handled in a way consistent with the APPs.

We will not transfer your personal information overseas unless we reasonably believe that the recipient is subject to privacy protections substantially similar to the APPs (or is otherwise permitted under the APPs), or the transfer is otherwise permitted by law, including where it is necessary for the performance of a contract with you or you have consented to the transfer. Information you post in public or social media environments, or in any chat spaces on the Platform, may become public information and we cannot guarantee the security of that information.

When you create an account or subscribe with your email address, you opt in to receive marketing from us about our products, services, memberships, thoroughbreds, promotions and related offers or activities, via email, SMS, telephone, mail or other means. You may withdraw your consent to marketing at any time through the “settings” in your account, by using the unsubscribe option included in every marketing email, or by contacting us using the details in clause 13. We will action your request promptly. We do not use sensitive information for direct marketing.

Separately, we may contact you about the opening, service, management and administration of your membership. These service communications are necessary to operate your membership, are not marketing, and are not affected by your marketing opt-in or opt-out status.

We take reasonable steps to ensure the personal information we hold is accurate, complete and up to date. You may request access to the personal information we hold about you, and ask us to correct it if it is inaccurate, out of date, incomplete, irrelevant or misleading, by contacting us using the details in clause 13. We will respond within a reasonable period. There is generally no charge for making a request, although we may charge a reasonable fee for giving access in some cases. If we refuse access or correction, we will tell you why in writing.

If you believe we have breached the APPs or mishandled your personal information, please contact us using the details in clause 13, describing your complaint and how you would like it resolved. We will acknowledge your complaint and aim to resolve it within a reasonable period. If you are not satisfied with our response, you can contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au or 1300 363 992.

If you have any queries, requests for access or correction, or complaints relating to the handling of your personal information, please contact:

TruShare Pty Ltd

(ABN 31 694 869 059)

PO Box 1999, Kingscliff NSW 2487

Email: racing@trushare.com.au

We may review, change or update this Privacy Policy from time to time and at our discretion, so that it keeps pace with legislative and other legal or policy changes. We will publish the current version on our website, and the “Last updated” date shows when it was last changed. Changes take effect on publication. Your continued use of our website, goods or services following publication constitutes acceptance of those changes. Significant changes will be notified through our website or by email where appropriate. You should review this Policy regularly.

To the extent that this Privacy Policy exceeds the minimum obligations of TruShare under Commonwealth and State legislation, it documents our voluntarily self-imposed standards. While we are determined to meet those standards as best we can, to the extent permitted by law, TruShare is not liable for any loss, liability, cost, expense or damage arising as a result of TruShare failing to meet any of the voluntarily self-imposed standards in this Privacy Policy.