Privacy policy
Waterfront Golf Ventures Pty Ltd · ACN 701 178 814
Version 1.2 · Last updated 9 October 2026
About this Privacy Policy
This Privacy Policy explains how Waterfront Golf Ventures Pty Ltd (ACN 701 178 814) trading as The Harbour Shot (the Operator) collects, holds, uses and discloses personal information in connection with The Harbour Shot - the Floating Sydney Waterfront Hole-in-One Challenge (the Activity). It covers the Activity, ticket and booking sales, the website, enquiries, prize claims and related communications.
This Policy should be read with the Participant Terms and Conditions of Entry and Play (the Participant Terms) and the Participant Prize Rules (the Prize Rules). Short collection notices at booking, on forms and on-site may explain a particular collection in more detail. Those notices supplement this Policy.
The Operator handles personal information in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles and other applicable privacy and health-records laws to the extent they apply. Where the Privacy Act does not apply to a particular act or practice, this Policy states the Operator’s intended privacy practices.
In this Policy, personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable.
1.Personal information we collect
The kinds of personal information we may collect and hold depend on how you deal with us. They may include:
- (a)identity and contact details, such as your name, email address, telephone number, suburb and, where relevant, date of birth or age;
- (b)booking, Ticket, Allocation and participation details, including purchaser and group-booking information, Play Session, Bay, package, attendance, refund and customer-service records;
- (c)payment and transaction information, including payment status, receipts, refunds and limited payment references supplied by a payment provider;
- (d)radar, camera, cup-sensor, shot, timestamp, Bay, Ticket, sales and event-log data, including an Adjudication Record if a prize result is claimed;
- (e)prize-claim information, including photographic identification shown for verification, evidence of age, a winner declaration, eligibility information, bank account details and parent or legal guardian details where relevant;
- (f)safety, security and incident information, including information about an injury, medical condition, first aid, property damage, conduct, a complaint or an insurance matter;
- (g)communications and consent records, including enquiries, prize determinations, complaints, marketing preferences and publicity opt-outs or consents; and
- (h)website and device information, such as IP address, browser, device, pages viewed, referral information, cookies and analytics data where those technologies are used.
We do not need every category for every person. We seek to collect only information reasonably necessary for the relevant function or activity. We do not ask for a tax file number for participation or prize payment.
Health information and other sensitive information is collected only where reasonably necessary for safety, first aid, incident management or another permitted purpose, and with consent where the law requires it. In an emergency, information may be collected, used or disclosed where permitted by law to protect life, health or safety.
2.How we collect personal information
We usually collect personal information directly from you when you buy or use a Ticket, make a booking, enter the Activity, speak with a Marshal, make a prize claim, complete a form, use the website, contact us, consent to publicity or subscribe to communications.
We may also collect information from a purchaser, group organiser, parent or legal guardian acting for you; from our payment, booking, ticketing, security and technology providers; from a prize supplier or sponsor involved in fulfilling a prize; and from the Land Owner, emergency services, police, an insurer, a witness or another person involved in an incident or complaint.
Radar, cameras, cup sensors and event systems may create or collect information during the Activity. Signs and collection notices will be used where reasonably practicable to tell Participants and visitors about recording and other material collections.
If we receive personal information we did not request, we assess whether we could lawfully have collected it. If not, we delete or de-identify it where lawful and reasonable.
3.Purposes for handling personal information
We collect, hold, use and disclose personal information for purposes connected with operating the Activity, including to:
- (a)sell and administer experience packages, Tickets and Allocations, process payments and refunds, manage queues and Play Sessions, and provide customer service;
- (b)operate the Activity safely, enforce the Participant Terms and Prize Rules, monitor the Containment Zone, investigate incidents and protect people, vessels and property;
- (c)track shots, adjudicate prize claims, verify eligibility and identity, prevent fraud, pay or provide prizes, and keep audit records;
- (d)respond to enquiries, complaints, access or correction requests, legal claims, insurance matters and regulator or authority requests;
- (e)maintain, test and improve our services, systems and event operations using aggregated or de-identified information where practicable;
- (f)send service messages and, where permitted, marketing communications or use separately consented publicity material; and
- (g)comply with law, court or tribunal orders and legal, accounting, tax, insurance, audit and reporting obligations.
If we propose a materially different use or disclosure that is not reasonably expected, we will seek consent or rely on another lawful basis before proceeding.
4.Monitoring recordings and human decisions
The Activity is monitored and may be recorded by Doppler radar ball tracking, cameras and, where fitted, cup sensors. These systems are used for safety, shot tracking, prize adjudication, audit, incident management, record-keeping and investigating possible breaches of the Participant Terms or Prize Rules.
Radar, camera and sensor outputs assist the Marshal. A machine indication, alert, light, sound, sensor trigger, on-screen display or announcement does not decide a prize claim or safety incident. The Marshal makes the determination. Camera recordings used for operations are not intended to record private conversations.
A claimed or awarded result and a prize presentation may be photographed or filmed as an operational record. Using identifiable material for advertising or promotion is dealt with separately under section 6.
5.Payments and prize verification
Payment card details are handled by the payment provider or point-of-sale service. We do not intend to store full payment card numbers or security codes in our own event records. We may retain transaction references, amounts, dates, payment status and refund records.
A Winner must produce current photographic identification and, where relevant, evidence of age, complete a winner declaration and provide bank account details as required by the Prize Rules. Where practicable, staff will sight identification and record the verification outcome without retaining a full copy.
If a copy of identification is reasonably required for a contested claim, insurer, audit or legal purpose, access will be restricted and the copy will be deleted or redacted in accordance with section 11.
A cash prize for a Participant under 18 is paid to a parent or legal guardian who consents to the payment and completes the required verification. We collect the guardian information needed to verify and make that payment.
6.Direct marketing and publicity
Service messages about a booking, Play Session, prize claim, safety issue or change to the service are not marketing. We may send marketing by email or SMS only with consent or where otherwise permitted by law. Marketing messages will identify The Harbour Shot, include contact details and provide a clear way to unsubscribe. We action unsubscribe requests within five working days.
We will not give a Participant or customer list to a sponsor or prize supplier for its own marketing unless the individual separately opts in to receive marketing from that identified organisation. Buying a sponsor’s product or service is not required to participate or claim a prize.
By entering or participating in the Activity, Participants consent to incidental inclusion in general background photographs or footage used for advertising or promotional purposes. A Participant may opt out before play by telling a Marshal and may withdraw consent for future uses. Opting out does not affect participation, adjudication or prize payment.
A featured, close-up or individually identifying promotional use requires separate consent. Consent for such use of a person under 18 must be given by their parent or legal guardian. A person who gave consent may withdraw it for future uses by contacting us. Withdrawal does not make an earlier lawful publication unlawful, but we will stop new uses and take reasonable steps in relation to material we control.
Operational recording, presence at the Activity and acceptance of the Participant Terms do not by themselves amount to consent for direct marketing or a featured, close-up or individually identifying promotional use. Incidental background use is governed by section 6.3.
7.Who we disclose information to
We may disclose personal information where reasonably necessary for the purposes in this Policy to:
- (a)authorised employees, Marshals, contractors and event personnel who need it for their work;
- (b)booking, ticketing, payment, banking, communications, website, hosting, cloud, analytics, radar, camera, sensor, security and records-management providers;
- (c)professional advisers, auditors, accountants, lawyers, investigators and insurers;
- (d)the Land Owner, venue or precinct manager, emergency services, police, regulators, courts, tribunals and government authorities where lawful, reasonably necessary or required;
- (e)a sponsor or prize supplier where necessary to verify, arrange or deliver the applicable prize and the Participant has been informed;
- (f)a parent, legal guardian or authorised representative where appropriate; and
- (g)a prospective buyer or successor to the business under confidentiality arrangements, subject to applicable law.
We do not sell, rent or trade personal information. We require service providers to use personal information only for the services they provide to us or as otherwise permitted by law.
8.Overseas disclosure
At the version date, the Operator is not likely to disclose personal information to an overseas recipient. Some technology providers may use global infrastructure while remaining subject to the Operator’s effective control; whether that is an overseas disclosure depends on the arrangement and applicable law.
Before making an overseas disclosure, we will take reasonable steps required by Australian Privacy Principle 8. We will also update this section or give a collection notice identifying the likely destination country or countries where it is practicable to do so.
9.Website data and cookies
The Harbour Shot website may use cookies and similar technologies that are necessary for booking, security, remembering preferences and understanding website use. Depending on the technology selected, the website may collect IP address, device and browser details, session information, pages viewed and referral data.
You can control many cookies through your browser or device settings. Blocking necessary cookies may affect booking or website functions. If optional analytics or advertising technologies are introduced, the relevant notice and preference controls will be updated before use.
Links to a sponsor, precinct trader or another third-party website are governed by that third party’s privacy practices. We are not responsible for a third party’s handling of information collected directly by it.
10.Data quality and security
We take reasonable steps to keep personal information accurate, up to date, complete and relevant for the purpose for which it is used. Please tell us if your contact, bank or other relevant details change.
We take reasonable steps to protect personal information from misuse, interference, loss and unauthorised access, modification or disclosure. Measures include limiting access by role, staff instructions, secure systems and accounts, authentication controls, supplier due diligence, physical security and secure deletion or de-identification.
No storage or transmission method is completely secure. Email sent over the public internet may not be secure, so do not send unnecessary identity documents or bank details by ordinary email. We will provide a suitable submission method for prize verification where practicable.
11.Retention and deletion
We retain personal information only for as long as it is reasonably needed for the purpose for which it was collected, for a related permitted purpose, or to meet legal, accounting, insurance, audit, dispute and record-keeping requirements.
Our usual retention periods are set out below. A longer or shorter period may apply if required or permitted by law, directed by an authority or insurer, reasonably needed for litigation or a dispute, or justified by the circumstances of a minor or an incident.
| Record | Usual retention period |
|---|---|
| Routine operational data | Radar, camera, sensor and event-log data with no claim, incident, complaint or adjudication matter: up to 90 days after the Play Session, then deleted or de-identified. |
| Prize and adjudication records | Adjudication Records, prize claims, winner declarations, payment evidence, eligibility checks and related consent records: 7 years after the claim is closed or the prize is paid. |
| Identification and bank details | Identification is sighted without copying where practicable. Any required copy, and full bank details held in the claim file, are deleted or redacted within 90 days after verification and payment, unless needed for a dispute, audit, insurer or legal requirement. A minimal payment record may be kept for 7 years. |
| Booking and financial records | Booking, Ticket, payment, refund, invoice, tax and accounting records: 7 years after the transaction or as otherwise required by law. |
| Incidents, complaints and requests | Safety, injury, property damage, insurance, complaint, access and correction records: 7 years after closure, or longer where reasonably necessary for a minor, claim, insurer or legal requirement. |
| Marketing and publicity | Marketing details are kept until consent is withdrawn or the relationship ends, subject to a minimal suppression record. Publicity consent and evidence of permitted use are kept while the material is used and for a reasonable period afterwards. |
When personal information is no longer required, we take reasonable steps to delete it securely or de-identify it. Backup copies may remain for a limited cycle and are protected from ordinary use until overwritten.
12.Anonymity and pseudonyms
Where lawful and practicable, you may make a general enquiry or attend a public spectator area without identifying yourself, or use a pseudonym. We may need your real identity for a named booking, refund, parent or guardian consent, prize claim, payment, incident, complaint, access request or where the law requires it.
A person may be able to buy an in-person experience package without creating a named customer account, depending on the sales channel and payment method. A prize cannot be verified or paid anonymously.
13.Access and correction
You may ask for access to personal information we hold about you or ask us to correct it by contacting the Privacy Officer under section 18. Please describe the information and, if relevant, the booking, Ticket, Play Session or prize claim. We may ask for evidence of identity before acting.
We will respond within a reasonable period, usually within 30 days. There is no fee to make a request. If the law permits a reasonable charge for giving access, we will explain it before incurring the cost.
Access may be refused or limited where an exception applies, including where access would unreasonably affect another person’s privacy, prejudice an investigation, create a serious safety risk or reveal commercially sensitive evaluative information. Where appropriate, we may provide a still image, transcript, extract, redacted copy or supervised viewing instead of an unedited recording.
If we refuse access or correction, we will give written reasons and available complaint options where required by law. If information is corrected, we will take reasonable steps to notify a relevant recipient if you ask and the law requires it.
14.Privacy complaints
You may complain about our handling of personal information by emailing the Privacy Officer under section 18. Please provide your name and contact details, what happened, when it happened, the information affected and the outcome you seek. You may use an authorised representative.
We will acknowledge a privacy complaint within 7 days where practicable, investigate it fairly, ask for further information if needed and aim to give a written response within 30 days. If more time is reasonably required, we will explain why and give an expected response date.
If you are not satisfied with our response, or we do not respond within 30 days, you may be able to complain to the Office of the Australian Information Commissioner at www.oaic.gov.au/privacy/privacy-complaints or on 1300 363 992. The OAIC generally expects you to complain to us first and allow us 30 days to respond.
15.Data breaches
If a suspected data breach occurs, we will take reasonable steps to contain it, protect affected information, assess the likely consequences and reduce the risk of harm. We maintain a response process proportionate to the information we hold.
Where the Notifiable Data Breaches scheme applies and we have reasonable grounds to believe an eligible data breach has occurred, we will notify the Office of the Australian Information Commissioner and affected individuals as required by law. An eligible data breach generally involves unauthorised access, disclosure or loss that is likely to cause serious harm and cannot be adequately remedied.
16.Children and participants under 18
A Participant aged 16 or 17 may take part without parental or guardian consent or supervision. A Participant under 16 may take part only with the consent and supervision required by the Participant Terms. We may collect the Participant’s name, age or date of birth, participation and operational records, and a parent or legal guardian’s identity, contact and consent details where reasonably necessary, including for payment of a cash prize to a Participant under 18.
We handle a child’s information with particular care and take account of the child’s best interests, age and capacity. A parent or legal guardian may make an access, correction or complaint request for the child, subject to identity, authority, the child’s maturity and applicable law.
A featured, close-up or individually identifying promotional use involving a person under 18 requires separate consent from their parent or legal guardian. Incidental background use is governed by section 6.3. A cash prize for a Participant under 18 is handled under the Prize Rules and section 5 of this Policy.
17.Changes to this Policy
We may update this Policy when our practices, providers or legal obligations change. The current version will be published at www.harbourshot.com.au and made available free of charge on request. Material changes will be notified where reasonable and legally required.
A change to this Policy does not authorise a use or disclosure that would otherwise require consent or another lawful basis.
18.Contact
Privacy enquiries, access and correction requests, complaints, marketing opt-outs and withdrawals of publicity consent may be directed to:
Privacy Officer
Waterfront Golf Ventures Pty Ltd trading as The Harbour Shot
Email: contact@harbourshot.com.au
Website: www.harbourshot.com.au