Privacy Policy

1. General

MiJock Ventures Pty Ltd (ACN 697 843 986) (collectively referred to as “we”, “us” or “our”) is committed to protecting the privacy of personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (as amended from time to time) (“Privacy Laws”).

This Privacy Policy sets out how we collect, use, and disclose your personal information when you:

• visit our website www.mijock.com.au, access and use the MiJock platform made available through the website, together with any associated platforms, portals or applications operated by us (“Platform”);
• create an account or acquire a subscription to the Platform as a horse trainer, horse owner, horse manager or jockey (each a “Member”);
• use the Platform to communicate with other Members, share information or images, or make, offer or accept bookings or engagements; or
• otherwise engage with us and provide personal information to us by any other means, including physically or electronically,

(collectively, the “Services”).

By using and accessing any of the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy.

If you do not agree to this Privacy Policy, please do not use or access any of the Services.

2. What Personal Information We Collect

When used in this Privacy Policy, the terms “personal information” and “sensitive information” have the meaning given to them under the Privacy Laws, and we are referring to information that identifies, relates to, describes or can be associated with you.

We only collect your personal information where that personal information is necessary for one or more of our business functions or to provide the Services.

The types of personal information we collect may vary depending on the type of interaction you have with us.

When you use our Services, the personal information we collect includes:

• Basic contact details, including your full name, date of birth, address, phone number and email address;
• Account information, including your username, password, security questions and preferences to keep your account secure;
• Profile and professional information, including whether you are a trainer, owner, manager or jockey, your licence or registration details issued by any racing authority, your business or stable details, your qualifications and experience, and your availability;
• Jockey information, including your weight, height and other racing-related information relevant to your participation as a jockey. Where we collect body weight or similar information relating to your physical condition, we will do so with your express consent (except where otherwise permitted or required by the Privacy Laws), and may use and disclose that information for the purposes described in this Privacy Policy;
• Subscription information, including your subscription level, selections, status, renewal settings and related details;
• Payment information, which is processed securely via third-party payment processors. We do not receive or store your full payment card details;
• Racing and horse-related information, including information regarding horses you own, train or ride, training progress, race plans, racing managers, nominations, acceptances, bookings and engagements, to the extent that information identifies or is associated with you or another individual;
• Content and communications, including messages, chat records and other communications exchanged with other Members through the Platform, and any information, images or videos you upload, post or share, together with records relating to those communications and interactions;
• Customer support information, including any information you choose to provide when contacting us for assistance, submitting enquiries, leaving reviews or otherwise communicating with our support team;
• Marketing preferences, so we understand how you wish to receive marketing communications and promotional materials from us;
• Marketing interaction data, such as information about your engagement with our marketing emails, SMS messages and other promotional content; and
• Device and usage data, including your IP address which helps us understand how people use our Services and improve our offerings, as well as other related device information and browsing behaviour.

Some features of the Services may require you to directly provide us with certain information about yourself. You may choose not to provide this information, but doing so may prevent you from using or accessing these features.

If you do not provide us with your personal information, this may impact or restrict our ability to interact with you.

In limited circumstances, we may collect sensitive information about you, including information relating to your body weight or other health-related information where relevant to the Services. We will only collect such information with your express consent or otherwise in accordance with the Privacy Laws.

Where you provide us with personal information about another individual (for example, a co-owner, an employee, a stable or riding contact, or another Member), you must ensure that you are authorised to provide that information and that the individual has been made aware of this Privacy Policy.

3. How Your Personal Information May Be Collected

Your personal information may be collected by us in various ways, including, but not limited to, when you:

• visit the Platform, engage with the Platform and/or create an account;
• acquire, manage or renew a subscription;
• create or update your Member profile;
• communicate with other Members through the Platform;
• make, offer, accept, vary or cancel a booking or engagement through the Platform;
• upload, post or share information, images or videos through the Platform;
• apply for a position with us;
• enter our competition or promotion, or a competition or promotion authorised by us and run by a third party;
• subscribe to our newsletter (if applicable);
• participate in a survey or feedback form;
• engage in any customer support interactions (including email, live chat and social media);
• contact any of our employees, contractors or officers;
• interact with the Platform through cookies, analytics and other tracking technologies; and/or
• interact with our marketing partners or advertising platforms, including when you engage with our advertisements or promotions.

We may also collect personal information about you from third parties, including:

• other Members, for example where another Member shares information relating to a booking, engagement or horse with which you are associated, or provides your contact details in connection with a booking or engagement;
• racing authorities and publicly available racing records, for example to verify your identity, licence or registration status; and
• third-party applications and service providers integrated with the Platform, such as payment processors, communication tools, subscription management applications and analytics tools, which may provide us with information relating to your interactions with those applications.

4. How Your Personal Information Will Be Used

We collect your personal information so that we can use it for our functions and activities and provide the Services to you. This includes using your personal information for the following purposes:

• Account Management: to create and manage your account on the Platform, as well as managing your account, subscriptions, preferences and settings;
• Platform Facilitation: to operate the Platform as a platform connecting trainers, owners, jockeys and industry participants, including displaying your profile and content you choose to share to other Members, facilitating communications between Members, and facilitating race nominations, bookings and engagements. This includes displaying jockey profile information, including weight information, to other Members where this forms part of the ordinary operation and functionality of the Platform;
• Verification: to verify your identity and, where applicable, your licence or registration status with the relevant racing authority;
• Subscription and Payment Processing: to process, confirm and administer your subscription and any applicable fees, process refunds, and verify your nominated electronic payment method;
• Customer Service: to provide customer service support, responding to feedback, complaints and enquiries, troubleshooting issues, and send important service-related, administrative and transactional communications;
• Platform Integrity, Compliance and Dispute Resolution: to monitor, review, store and retain communications and content exchanged through the Platform for operational, security, compliance, fraud prevention, dispute resolution, complaint handling and regulatory purposes, including responding to requests or enquiries from racing authorities and investigating actual or suspected breaches of our terms, policies or applicable laws;
• Marketing Communications: to keep you informed about marketing initiatives, including direct marketing campaigns, promotions, events, new products and features, newsletters and updates, using emails, SMS and retargeting ads;
• Testimonials, Case Studies and Promotional Activities: to publish testimonials, reviews, success stories, case studies and other promotional materials that include information you have provided to us;
• Recruitment: to assess, process and manage employment applications and recruitment activities;
• Service and Platform Improvement: to recognise the device you use, analyse how you interact with the Platform and our Services, and improve functionality, performance and user experience. This includes using website analytics, conversion rate optimisation testing and performance optimisation tools;
• Internal business operations: to support our internal operations, including business administration, record keeping, fraud prevention, security, risk management, and compliance with legal and regulatory obligations;
• Promotions: to conduct and administer promotions, competitions or other promotional activities and enable your participation in them;
• Research, insights and analytics: to conduct product and market research, to understand preferences, patterns, interests and behaviours to enhance product development and improvement, and to generate aggregated data, statistics, insights and analytics;
• Artificial Intelligence and Technology Development: to develop, test, validate, operate, improve and support artificial intelligence systems, machine learning models, predictive analytics tools, recommendation engines, and other technologies used in connection with the Platform and our business, including by analysing information, content and usage data collected through the Services;
• Development: for administrative, planning, service development, quality control and research purposes; and/or
• Communications: to provide personalised communications, including information about offers, promotions, new products and features that may be relevant to you.

We may combine personal information and other information collected through the Platform with information obtained from other users, third parties and external sources to develop analytics, reports, insights, benchmarking products, databases and other products and services. Subject to applicable law and your consent where required, we may use, disclose, licence, publish, distribute, sell, commercialise or otherwise exploit personal information and information derived from personal information, including in identifiable, aggregated, anonymised, de-identified or derived form.

We may also use your personal information for other purposes not listed above which will be made clear to you at the time we collect your personal information, or for such purposes as may be required or permitted by law.

5. Cookies and Web Beacons

We use cookies, web beacons, and similar technologies on the Platform and through our Services to identify specific devices in order to collect aggregate information on how visitors are experiencing the Platform. A “cookie” is a small text file stored on a user’s computer or other Internet-connected device which contains information about the user. Cookies collect device information, IP address, approximate location, pages visited, time spent, interactions, subscription and checkout activity, advertising interactions and related conversion data. This information helps us understand usage patterns, improve functionality and performance, personalise your experience, and support our marketing and advertising activities.

We use the following tools and technologies which may place cookies on your device:

• analytics tools such as Google Analytics (GA4);
• advertising and social media pixels, including Meta Pixel, TikTok Pixel and similar advertising technologies;
• platform cookies, including session, checkout and login cookies;
• marketing and customer engagement tools (including Attio and HubSpot);
• user experience and performance tools (including Hotjar), heatmapping and session recording technologies; and
• artificial intelligence, machine learning and automated analytics tools that assist us in analysing Platform usage, user behaviour, service performance and customer interactions, and in improving our Platform, products and services.

Most browsers automatically accept cookies by default, but you can choose to set your browser to remove or reject cookies through your browser controls. Please keep in mind that removing or blocking cookies can impact your user experience and may cause some of the Services, including certain features and general functionality, to work incorrectly or no longer be available. Additionally, blocking cookies may not completely prevent how we share information with third parties such as our service providers.

6. Marketing Communications

Where you have consented, we and our related entities may use your personal information from time to time to contact you (including via SMS, email or telephone) to let you know about news, special offers, products and services that you might be interested in (Marketing Communications).

You may opt out at any time by following the instructions in the Marketing Communications, or otherwise by contacting us directly via the contact details in section 16 below.

If you opt out of Marketing Communications, we may still send you non-promotional communications that are necessary for administrative, transactional or service-related purposes, such as subscription confirmations, receipts, booking notifications, account notices or important service updates.

7. Disclosure of Information to Third Parties

We may disclose personal information we collect from you.

The types of persons and organisations to whom we may disclose your personal information includes:

• other Members: certain information, including your name, profile and professional information, jockey information, availability, and any information, images or content you choose to share through the Platform, will be made available to other Members as part of the ordinary operation of the Platform, in accordance with the nature of the Services, and any applicable settings;
• our employees, related entities, suppliers, consultants, contractors or agents:
  • to carry out the purposes set out in section 4 above or for other purposes directly related to the purpose for which the personal information is collected; and/or
  • to assist us in providing and promoting our products and services to you;
• suppliers and other external service providers involved in operating and supporting our business, such as IT and infrastructure providers, web hosting companies, system administrators, electronic payment processors, communication and messaging providers, marketing technology vendors, analytics providers, development partners and agencies, customer support platforms, data entry providers, debt collection agents, and electronic network administrators;
• racing authorities and industry bodies, where disclosure is required or authorised by law, by the applicable rules of racing, or where reasonably necessary to verify licensing or registration, facilitate race nominations, acceptances, bookings or engagements, investigate complaints or disputes, respond to regulatory enquiries, or provide records relating to bookings, engagements, communications and Platform activity;
• professional advisors, including accountants, solicitors, business advisors, consultants and other specialists;
• law enforcement bodies, courts, tribunals and regulators, where required or authorised by law;
• data customers, commercial partners, analytics providers, research organisations and other third parties to whom we disclose, licence, sell or otherwise commercialise information and data in accordance with this Privacy Policy;
• a purchaser or prospective purchaser (and its advisers) of all or part of our business or assets, subject to appropriate confidentiality obligations; and/or
• nominated third parties you have consented to.

8. Where Your Personal Information Is Stored

Your personal information will be held in physical or electronic form and may be stored by us or by a third party that we have engaged to store your personal information.

Where we store your personal information depends on what interaction you have had with us and how we use your personal information.

9. Security and Retention of Your Information

We take reasonable steps to protect your personal information from misuse or unauthorised disclosure by limiting access where appropriate.

Please be aware that no security measures are perfect or impenetrable, and we cannot guarantee “perfect security”. In addition, any information you send to us may not be secure while in transit. We recommend that you do not use insecure channels to communicate sensitive or confidential information to us.

How long we retain your personal information depends on different factors, such as whether we need the information to maintain your account, to provide the Services, comply with legal obligations, resolve disputes or enforce other applicable contracts and policies.

10. Overseas Disclosure

We may disclose personal information to our third-party suppliers and service providers located outside of Australia for some of the purposes listed above. This may involve disclosure to countries including, without limitation, the United States of America, Ireland, the United Kingdom, Singapore, Malaysia, Germany and India.

Where we disclose personal information overseas, we take reasonable steps to ensure that appropriate safeguards are in place to protect your personal information and that recipients handle it in accordance with applicable privacy requirements. However, privacy laws in other countries may differ from those in Australia and may not provide the same level of protection.

11. Links to Other Websites

When you are on the Platform, you may be directed to other websites that are beyond our control. If you visit one of these linked websites, you should review their privacy and other policies. A link to a third-party website is not an endorsement by us as to the accuracy or trustworthiness of that website or any contents and information collected, and we are not responsible for the policies and practices of those third-party websites.

12. Access to Personal Information and Correction

Under the Privacy Laws, you have rights to access and correct personal information that we hold about you.

You may request access to the personal information and seek correction of same by contacting us via the contact details in section 16 below.

There may be instances where we cannot grant you access to the personal information that we hold about you, for example, if it would result in a breach of confidentiality or would interfere with the privacy of others.

We may charge a reasonable administration fee to cover the costs of meeting your request.

Where we receive a request to access or correct the personal information, we will take reasonable steps to respond to such requests within a reasonable period of time.

13. Employment Applications

Generally, when you apply for a position with us through the Platform, a third-party website, or a recruitment agency, we will collect and store the type of personal information we reasonably require to assess your job application.

Depending on the position that you are applying for, we may collect and store some or all of the following information (without limitation) from you:

• full name;
• gender;
• date of birth and/or age;
• postal address;
• telephone number and email address;
• education details;
• employment history and other information relating to your work experience;
• information that would enable us to identify you and your work entitlements in Australia, such as your driver’s licence or passport details; and
• references (it is your responsibility that you provide us with contact details of people who have provided their express consent to you for their personal information to be included in your employment application).

In considering your application, we may also obtain personal information about you from third parties, for example, from your previous employers or nominated referees. Subject to your consent, we may also collect sensitive information about you such as information about your health (including any disability) or any criminal record you may have.

We may, unless you tell us otherwise, store your personal information for future employment opportunities.

We may disclose your information to:

• your referees or previous employers;
• recruitment agencies or agencies or contractors acting on our behalf;
• our related entities;
• law enforcement agencies to verify whether you have a criminal record;
• educational organisations to the extent necessary to verify your qualifications; and
• other government bodies for the purposes of assessing your working rights in Australia and your driving record.

14. Changes to This Privacy Policy

We may modify or update this Privacy Policy from time to time, including to reflect changes to our practices or for other operational, legal, or regulatory reasons.

We will post the revised Privacy Policy on our website, update the “Last Updated” date and take any other steps required by Privacy Laws.

15. Queries and Complaints

If you have queries and/or complaints about how we handle your personal information, please contact us in accordance with section 16 below.

If you are dissatisfied with our response to your complaint or consider that we have breached the Privacy Laws, you may refer your complaint to the Office of the Australian Information Commissioner (OAIC):

• Address: Office of the Australian Information Commissioner, GPO Box 5218, Sydney NSW 2001;
• Phone: 1300 363 992;
• Email: [email protected]; and
• Website: https://www.oaic.gov.au/.

16. Contact

Should you have any questions about our privacy practices or this Privacy Policy, or if you would like to exercise any of the rights available to you, please contact us via email to [email protected].