ARISTOCRAT TECHNOLOGIES EUROPE LTD (ATEL) WEBSITE PRIVACY POLICY

Effective date: 25 May 2018

INTRODUCTION

Aristocrat Technologies Europe Ltd and its affiliates located in the European Union (Aristocrat or We) are committed to complying with their obligations under the European Union General Data Protection Regulation (“GDPR”), as well as with applicable European Union or national privacy and data protection legislation. This Privacy Policy applies to all Personal Information that Aristocrat collects, uses, discloses, stores and handles through the management of Aristocrat’s website located at https://aristocrat.com/ (the Website). In this policy, “Personal Information” means any information relating to an identified or identifiable person located in the European Union.

COLLECTION OF PERSONAL INFORMATION

Aristocrat only collects Personal Information to the extent necessary to fulfil its functions and activities and will do so only by fair and reasonable means. Generally, we will collect Personal Information directly from the individual to whom the Personal Information relates, but in some circumstances (including as outlined below), it may be necessary for us to collect information from a third party source. To the extent you provide information about friends and family members, you agree to provide such individuals with this Privacy Policy and to obtain their consent to provide the information.

How is Personal Information collected and held by Aristocrat?

Aristocrat is one of the world’s leading providers of gaming solutions. We collect Personal Information so that we can provide our goods and services, and information about those goods and services, to customers, end users and other interested parties. Personal Information collected by Aristocrat may include information you provide or volunteer to provide when using this Website, interacting with our sales and marketing teams and information obtained from other sources, such as public records or bodies. In a few areas on our Website and online customer support tools, we ask you to provide information that will enable us to enhance your Website visit, to assist you with technical support issues or to follow up with you after your visit. It is completely optional for you to participate. For example, we request information from you when you:

  • register on the Website;
  • provide feedback in an online survey;
  • submit your resume;
  • request information from Aristocrat;
  • or submit comments via the “Contact Us” form.

In limited circumstances, we may collect publicly accessible Personal Information about you from a third-party social media platform such as LinkedIn or Google+ in connection with our recruitment and HR processes. We will endeavour to only do this to the extent this is reasonably necessary and relevant to the performance of the job which you are applying for.

We may also collect Personal Information from a third party where particular circumstances require it, for example if we need to obtain a reference from a previous employer prior to offering an individual employment at Aristocrat.

What kinds of Personal Information does Aristocrat collect and hold?

The kinds of Personal Information we collect will depend on the purpose(s) for which we are collecting it. For example, in each of the instances above, we may ask for:

  • your name;
  • e-mail address;
  • phone number;
  • postal address;
  • business name;
  • position and contact telephone number;
  • as well as other similar Personal Information that is needed to register or subscribe you to our services or offers; and
  • other Personal Information provided for the purposes of recruitment (such as ID, driving licence and work permit).

We may also collect and use any other information which you provide to us on a voluntary basis for any of the purposes listed above.

If you do not provide certain requested Personal Information to Aristocrat, Aristocrat may not be able to provide you with access to and use of this Website, nor provide you with access to Aristocrat’s other products and services, nor to fulfil one or more of its functions and activities applicable to you.

Sensitive Information

In certain circumstances, we also collect Personal Information which is classified as Sensitive Information under the GDPR, including police checks.

In respect of customers, suppliers, sub-contractors, associates or other relevant parties. We only collect such Sensitive Information in compliance with EU law.

This Sensitive Information is only accessible by restricted staff within Aristocrat and is only disclosed to an entity (generally the relevant regulatory or government authority or agency) where we have a legal or regulatory requirement or obligation to do so.

USE AND DISCLOSURE OF INFORMATION

The Personal Information you provide will be used to support your relationship with Aristocrat. Among other things, we want to help you quickly find information on the Website and alert you to product upgrades, special offers, updated information and other new products and services from Aristocrat.

Aristocrat is not in the business of selling Personal Information to third parties. We will only record your e-mail address if you send us a message. Your e-mail address will only be used for the purpose for which you have provided it and it will not be added to a mailing list or used for any other purpose without your consent, which you can withdraw at any time.

The purposes for which information is collected, held, used and disclosed Aristocrat may use and disclose your Personal Information for the primary purpose for which it was collected and any related purposes, including where necessary or desirable:

  • to provide this Website and associated material and services to you;
  • to meet our business needs, including to (i) manage Aristocrat’s relationship with you and (ii) obtain professional, financial, technical, administrative or other advice and services in connection with the operation of Aristocrat’s business;
  • to provide direct marketing (as permitted by law), including to provide you with information about (i) this Website and associated material and services, (ii) Aristocrat’s other products and services, and (iii) information about products and services available from Aristocrat’s affiliated entities. Note that we will only use your e-mail address or mobile phone number for advertising purposes if you provide us with your prior consent. You can withdraw your consent at any time by communicating this wish to us through the contact information below;
  • to investigate, prevent or take action regarding any breach or suspected breach by you of this Privacy Policy or the rights of any person;
  • in the context of a corporate transaction (e.g., corporate restructuring, sale or assignment of assets, merger) and to protect our rights or property, to enforce our terms of use and legal notices and for the establishment, exercise and defence of legal claims;
  • to meet our legal or regulatory obligations, any court order or other binding decision;
  • for any purpose to which you subsequently consent from time to time (e.g., use of certain cookies), with the possibility to withdraw your consent at any time; and for purposes unrelated to those described in this Privacy Policy by first notifying you and, where required, offering you a choice as to whether or not we may use your Personal Information in this different manner.

 

Privacy of Job Applicants

To know how we process your Personal Information please access our Applicant Notice http://ally/Docs/Local%20Policies%20%20Procedures/Forms/My%20Country.aspx or request via EMEA Human Resources Department.

SHARING OF PERSONAL INFORMATION

We may share your Personal Information for the purposes mentioned above with:

  • other entities of the Aristocrat group of companies;
  • services providers in connection with the operation of this website and our company, including website hosting, the provision of our services, and promotional material distribution;
  • public authorities, government regulators or other law enforcement officials and the courts, as required or permitted by law or when compelled by a binding order; and
  • other third parties in connection with a corporate restructuring, sale or assignment of assets, merger, or divestiture of Aristocrat and affiliated companies.

 

Sharing of Personal Information with Aristocrat group companies in other countries

As Aristocrat is part of a global organisation, we may from time to time transfer Personal Information to an Aristocrat company located in another country. We will only do this where it is necessary or appropriate to achieve the purposes set out in this Privacy Policy (for example, because that Aristocrat company is responsible for providing systems or services to other group companies like Aristocrat), or it is otherwise made known to you at the time the Personal Information is collected.

Aristocrat group companies operate in all major countries of the world, including Australia, USA, UK, France, Germany and other European countries, New Zealand, India and other Asia-Pacific countries, and in other regions such as the Middle East and South America. The Aristocrat companies that host systems and data (including Personal Information) on behalf of Aristocrat and other group companies are located in US, UK, India, New Zealand, UK, and Macau.

Please note that where Aristocrat transfers Personal Information to an Aristocrat company located outside of the European Union, we will take steps to ensure that the information is only used for purposes permitted under this Privacy Policy and is given the same protection as it has here in the European Union. Where required under the GDPR, Aristocrat will put in place the appropriate contractual safeguards to ensure that your Personal Information remains protected. You have the right to request from us information about, including a copy of, the contractual safeguards Aristocrat put in place to transfer Personal Information to a country that does not guarantee a level of data protection equivalent to that in the EU.

Sharing of Personal Information with third party service providers in other countries

Aristocrat engages a range of third parties to provide services and perform business support functions for us. Some of those third parties need access to Personal Information in order to provide the services or perform the functions Aristocrat requires. Where we share your Personal Information with third-party service providers, they will be contractually bound to use the information only for the purposes of providing the services or performing the functions required by Aristocrat and to store the information securely.

Some of the third parties providing services to Aristocrat may be located outside of the European Union. Where required under the GDPR, Aristocrat will put in place the appropriate contractual safeguards to ensure that your personal information remains protected when transferred to those third parties. You have the right to request from us information about, including a copy of, these contractual safeguards.

Your Personal Information (such as name, address and phone number) or your order and the products you purchase will not be given or sold to any outside organisation for its use in marketing or solicitation without your prior consent. You can withdraw your consent at any time.

RETENTION OF PERSONAL INFORMATION

Aristocrat takes reasonable steps to destroy or permanently de-identify any Personal Information where:

  • Aristocrat no longer needs the Personal Information for any purpose for which the Personal Information was collected or for a related purpose; and
  • Aristocrat is not required by law, gaming or other, a regulator or a court/tribunal order, to retain the Personal Information.

 

ACCURACY OF PERSONAL INFORMATION

Aristocrat will take reasonable steps to ensure that the Personal Information it collects, uses or discloses, is accurate, complete and up to date, and relevant to any proposed use or disclosure.

We seek your assistance by asking you to contact us if your Personal Information changes or you believe the information held on file is incomplete.

YOUR RIGHTS OVER YOUR PERSONAL INFORMATION

Under the GDPR, individuals have a right to request from us access, rectification, erasure, restriction and discontinuance of processing, and portability of your Personal Information and not to be subject to automated individual decision-making. You may, for example, request that Aristocrat confirm whether it holds any Personal Information about you and, where applicable, request that Aristocrat provide you with a copy of your Personal Information. Requests should be addressed to the contact information below.

Our response to your request is in principle provided to you on a free of charge basis. We will only charge you in case your request is manifestly unfounded or excessive.

In certain circumstances, Aristocrat will not need to attend to your request, such as where:

  • access would have an unreasonable impact on the privacy of others;
  • we are required by a gaming or related regulator or other law enforcement agency to withhold the information;
  • the information may affect current legal proceedings;
  • the information may affect the health or safety of another individual;
  • we are not able to identify you; or
  • any other restrictions in applicable privacy or data protection laws apply.

If you are able to establish that your Personal Information is not accurate, complete or up to date, Aristocrat will take reasonable steps to correct such Personal Information so that it is accurate, complete and up to date. If you and Aristocrat are unable to agree about whether your Personal Information is accurate, complete and up to date and you request that Aristocrat associate with your Personal Information a statement claiming that such Personal Information is not accurate, complete or up to date, Aristocrat will take reasonable steps to do so.

Making a complaint to the Regulator

If you believe that we have breached this policy, or any applicable privacy or data protection law, please contact us (contact details are set out below). You should include as much detail as you can about the Personal Information affected, and the circumstances that you believe amount to a breach of this policy or your rights under applicable laws.

We will undertake an internal investigation, and we may contact you if we need to obtain any further information in relation to your complaint. We will generally provide a written response to your complaint within 30 days. Our response will set out the results of our investigation, including whether we agree that Aristocrat has breached this Privacy Policy or the applicable laws.

If you are unhappy with our response to your complaint or if you do not wish to contact us, you have the right to make a complaint to the supervisory authority for privacy in your country.

SECURITY OF PERSONAL INFORMATION

Aristocrat will take reasonable steps to protect and secure your Personal Information to ensure your Personal Information is protected from misuse, loss, theft, and unauthorised modification, access or disclosure. Note, however, that this Website does not provide facilities for the secure transmission of information across the internet. Users should be aware that there are inherent risks transmitting information across the internet.

CUSTOMISED EXPERIENCE

New technologies are emerging on the internet that helps us deliver customized visitor experiences. When you look at our Website, Aristocrat may make a record of your visit and log the following information for statistical purposes:

  • your server address;
  • your top-level domain name (for example .com, .gov, .au, .uk etc);
  • the date, duration and time of your visit to the site;
  • the previous site you have visited; and
  • the type of browser you are using.

If you do not want us to collect this information, please do not access our Website.

COOKIES

A cookie is a small data file that can be used to track internet use. More information about cookies can generally be found in the “help” (or similar) section of your computer’s internet browser. At Aristocrat, we primarily use cookies to help us determine which service and support information is appropriate to your machine. Our use of this technology does not mean that we automatically know any information about you. We might be able to ascertain what type of computer you are using, but beyond that, our use of cookies is designed only to provide you with a better experience when using the Website.

Aristocrat has no desire or intent to infringe on your privacy while using the Website. Cookies can be either “persistent” or “session” based. Persistent cookies are stored on your computer, contain an expiration date, and may be used to track your browsing behaviour upon return to the issuing website. Session cookies are short-lived, are used only during a browsing session, and expire when you quit your browser. You can disable cookies on your web browser, although this may interfere with your use and enjoyment of the Website. For instructions on how to block or delete cookies please consult your browser’s privacy or help documentation.

Below we briefly identify the cookies we use:

Provider Cookie Cookie-Type Purpose Duration of the Cookie Category
google-analytics.com __utm.gif Pixel Google Analytics Tracking Code that logs details about the visitor’s browser and computer. Session Analytic Cookie
aristocrat.com __utma HTTP Collects data on the number of times a user has visited the website as well as dates for the first and most recent visit. Used by Google Analytics. 2 Years Analytic Cookie
aristocrat.com __utmb HTTP Registers a timestamp with the exact time of when the user accessed the website. Used by Google Analytics to calculate the duration of a website visit. 1 day Analytic Cookie
aristocrat.com __utmc HTTP Registers a timestamp with the exact time of when the user leaves the web site. Used by Google Analytics to calculate the duration of a web site visit. Session Analytic Cookie
aristocrat.com __utmt HTTP Used to throttle the speed of requests to the server. 1 day Analytic Cookie
aristocrat.com __utmz HTTP Collects data on where the user came from, what search engine was used, what link was clicked and what search term was used. Used by Google Analytics. 6 Months Analytic Cookie
aristocrat.com _ga HTTP Registers a unique ID that is used to generate statistical data on how the visitor uses the web site. 2 Years Analytic Cookie
aristocrat.com _gid HTTP Registers a unique ID that is used to generate statistical data on how the visitor uses the web site. 1 day Analytic Cookie
vimeo.com vuid HTTP Collects data on the user’s visits to the web site, such as which pages have been read. 2 years Analytic Cookie
doubleclick.net r/collect Pixel This cookie is used to send data to Google Analytics about the visitor’s device and behavior. It tracks the visitor across devices and marketing channels. Session Analytic Cookie
Cookie Settings moove_gdpr_popup HTTP When this Cookie is enabled, these Cookies are used to save your Cookie Setting Preferences. 2 Years Necessary Cookie

 

Access to Personal Information collected

Aristocrat will not make an attempt to identify users or their browsing activities. However, in the unlikely event of an investigation, a law enforcement agency or other government agency may exercise its legal authority to inspect Aristocrat’s or our internet service provider’s logs.

Third-party sites

Please be aware that other websites that may be accessed through our Website may collect your personally identifiable information about you. The information practices of those third-party websites linked to the Aristocrat Website are not covered by this Privacy Policy. You are solely responsible for maintaining the secrecy of your passwords or any account information.

CHANGES TO THIS PRIVACY POLICY

Aristocrat may make changes to this Privacy Policy from time to time, but we will not change the way we use Personal Information you have provided to us previously without informing you or, where legally required, without your consent. If we make any material changes to this Privacy Policy, we will post a revised link on the Website indicating its revision or a comparable notification about the changes. You should check this website periodically to see if any recent changes to this Privacy Policy have been made. You can also tell if this Privacy Policy has changed recently by reviewing the Effective Date posted at the beginning of this Privacy Policy.

CONTACTING ARISTOCRAT

If you have any questions about Aristocrat’s handling of Personal Information, wish to make an request to exercise your rights, or want to make a complaint, you should contact us by one of the following methods:

By email: privacy@aristocrat.com
By post: HR Department, Aristocrat Technologies Europe Ltd.
25 Riverside Way, Uxbridge, Middlesex, UB8 2YF, UK