Sonenco Hotels & Privacy

Sonenco Hotels is a business name used by a number of related entities that operate hospitality venues. References in this Privacy Policy to “Sonenco Hotels", "we", "us" and "our" refer to the relevant entity operating under the Sonenco Hotels business name that collects, holds, uses or discloses your personal information.

This Privacy Policy applies to all venues, websites and businesses operating under the Sonenco Hotels business name.

We understand the importance of protecting the privacy of an individual’s personal information. This Privacy Policy outlines the ways in which we collect, hold, use, disclose, and otherwise manage, your personal information.

In collecting, holding, using, disclosing and otherwise managing your personal information, we are required to comply with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles in the Privacy Act.

We regularly review our policies and procedures and therefore we may change this Privacy Policy from time to time to reflect changes in our business and privacy practices. The current version of our Privacy Policy will be available on our website.

The Personal Information We Collect

Under the Privacy Act, personal information is information or an opinion about an identified, or reasonably identifiable, individual. During the provision of our hospitality and related services or as a result of our other interactions or dealings with you, we may collect your personal information.

The kinds of personal information that we collects will vary depending on our interaction or dealing with you. However, generally, the kinds of personal information we collect may include:

• contact and identification information such as your name, photograph, date of birth, address, telephone number and email address (for example where you make a reservation at our venues, join one of our mailing lists or join a rewards or loyalty program);

• information regarding your transactions with us, including reservations, ordering history, food or beverage or other dining preferences across our venues;

• where you organise or conduct an event, information regarding the event, your guests and any relevant requirements;

• payment information, such as credit card, bank account or other payment details;

• information regarding your experience at our venues (for example as part of our guest feedback activities or where you contact us with feedback); and

• where you apply for employment with us (in addition to contact and identification information detailed above), information relevant to us considering your application for employment including information in relation to your CV, employment history, qualifications and references.

Depending on the venue you attend, we may also collect identification information, such as a copy of your driver licence, passport information or other recognised proof of identity card. We generally collect this information because we are required to do so by law and/or for venue, patron and employee security purposes. Specific information regarding the collection and handling of this type of personal information may be available at the relevant venue.

We also collect CCTV footage at our venues, including for venue, patron and employee safety purposes. We may additionally use facial recognition technology in our venues to identify you. In addition to security, we may use personal information captured via facial recognition technology in connection with any gaming self-exclusion programs operated by us. Details of suspected or actual illegal or improper conduct, including CCTV footage relating to that conduct, may be shared with relevant law enforcement or regulatory bodies.

At some our venues or events, we may also take photographs or other images or content (such as video or audio recordings). Where we do so, we will provide as much detail as possible regarding why the photographs, images or other content are being taken and the purposes for which they are being used. By attending our venues or events, you consent to us taking such photographs, images or other content and using those photographs, images or other content, including at the venue and on our  websites and social media sites.

We may also collect and hold other kinds of personal information as permitted or required by law or other kinds of personal information that we notify you of at or about the time of collection.

Generally, we do not collect sensitive information about individuals. Information about your health, racial or ethnic origin, political persuasions, criminal record and religious or philosophical beliefs are all examples of sensitive information. There may be circumstances where we collect sensitive information, for example where we need to collect health information regarding your allergies or in a medical emergency or if you apply for employment with us.  Other sensitive information may be captured via our use of CCTV and facial recognition technology to capture images of individuals. If we do collect sensitive information about you, we will only do so with your consent or where we are otherwise permitted to do so by law.

How We Collect Personal Information

Generally, we collect your personal information directly from you. For example, we may collect your personal information where:

• you make a reservation for, or attend, our venues or events;

• you join one of our mailing lists, fill out a survey, enter a promotion, request services or otherwise provide us with your details;

• you make a reservation for a function at our venues;

• you sign up to or participate in any loyalty program;

• you participate in a gaming self-exclusion program or scheme which we participate in;

• you provide feedback to us regarding your experience at our venues or other interaction with us;

• you post information to any of our social media sites;

• you visit one of our websites;

• we need to make a payment to you, for example gaming jackpots; or

• you apply for or express an interest in employment with us.

We generally collect personal information directly from you, however, there may be occasions when we collect your personal information from someone other than you, for example from:

• other entities within Sonenco Hotels;

• our service providers or contractors (for example, where we appoint a service provider/contractor to assist with conducting an event);

• our technology providers (for example, providers of our reservation, ordering, payments or booking systems);

• an information services provider;

• a gaming self-exclusion program provider;

• a publicly maintained record or other publicly available sources of information including social media and similar websites; or

• a referee or previous employer where you apply for employment with us.

We may also derive new personal information about you, such as insights and opinions about your habits and preferences, by aggregating various categories of personal information which we hold about you.

Cookies and Analytical Information

We may collect statistical and other information when you access our website and online platforms available via our websites, by utilising features and technologies of your internet browser or device, including cookies and pixel tags.

The information collected via cookies and analytic tools does not specifically identify you but may include technical data, such as your IP address, browser type, device, pages visited and the time spent on our website. Cookies and pixel tags may be used to send targeted advertising or promotional messages but will not be used to identify you. You may also elect to turn off the internet browser features which allow us to collect statistical information by selecting certain options on your browser, however, this may affect the functionality of certain parts of our website.

How We Use Your Personal information

We collect and uses personal information so that we can provide our hospitality services, interact with you in relation to our services and venues and administer and manage our business and our venues.

Depending on your interaction with us, we may collect, hold, use and disclose your personal information for the purposes listed below:

• manage reservations for our venues or events;

• provide food, beverage and other hospitality services at our venues;

• manage and undertake events conducted at our venues;

• manage and administer the provision of our services and our relationship with you;

• verify your identity;

• make a payment to you;

• maintain venue, patron and employee safety;

• enable us to supply you with information you request from us;

• conduct promotions, competitions, giveaways and events;

• contact you to obtain your feedback regarding our products or services or to conduct other market research;

• provide you with marketing information regarding Sonenco Hotels, our venues and information about our partners (as further detailed below);

• analyse how our websites, mobile apps and other online services are being used, and to seek to improve our websites, mobile apps and other online services and provide more user friendly and customised websites, mobile apps and online services;

• administer, support and improve and develop our business and the products and services we offer, including by undertaking data analytics and related activities;

• comply with the obligations of our venues under any applicable laws; and

• consider any application you make for employment with us.

We may use your personal information for more than one of the purposes listed above depending upon the context.

In addition to the purposes listed above, we may use your personal information for other purposes which we notify you of when we collect the information and for other purposes permitted or required by law.

You are under no obligation to provide your personal information to us. However, without certain information from you, we may not be able to provide services or information to you or may be limited in how we can interact with you.

Marketing Communications

In addition to the purposes outlined in this Privacy Policy, we may use and disclose your personal information in order to inform you of promotions, competitions, giveaways, events, products or services that may be of interest to you. Where you make a reservation at a particular venue or sign up for a direct mailing list or loyalty program of a particular venue our ours, this may include sending you information about that venue, or our other venues or events, that may be of interest to you.

In doing so, we may disclose your personal information to the entities which own and operate Sonenco Hotels or other entities with which we have a commercial relationship or arrangement for the purpose of the other entity contacting you for such direct marketing purposes.

These communications may be sent using email, telephone, SMS, social media or other similar forms of communication.

If you do not wish to receive such communications, you can opt-out at any time by contacting us via the contact details in this Privacy Policy, or through the opt-out or unsubscribe mechanism contained in a marketing communication to you.

When We Share Your Personal Information

We disclose your personal information for the purpose for which we collect it, or another purpose which is permitted by law. This may include disclosing your personal information to:

• the related entities which own and operate Sonenco Hotels;

• our service providers and contractors and other third parties that provide products or services to us including, our technology service providers, data analytics service providers, reservation system providers, event service providers, marketing and communication agencies, and other business or administration service providers;

• our professional advisors, including accountants, tax, insurance, and legal advisors;

• insurance providers and brokers.

• prospective purchasers or their professional advisers in relation to the change of ownership or structure of our venues business’s or assets through a sale, merger, acquisition or business restructure.

We may also disclose your personal information for other purposes where we notify you of the disclosure at or about the time of collecting the information, with your consent or if the disclosure is required or authorised by law. For example, disclosure that may be required or authorised by law include disclosure to law enforcement bodies, liquor and gaming regulators or under Anti-Money Laundering and Counter-Terrorism Financing laws.

If you post information or other content to public sections of our websites or to our social media sites, you acknowledge that the information or content may be viewed by the public and/or users of the relevant website or social media site.

We may also disclose information in anonymous, aggregated form for a range of purposes, including to our business partners for marketing and other commercial purposes.

Overseas Disclosures

We primarily stores personal information with Australia. However, some of the technology service providers may be located outside Australia. This may occur where cloud based software or online platforms are used for reservations, marketing, website hosting or other business systems. Where personal information is disclosed overseas, we take reasonable steps to ensure that it is handled in accordance with the  Australian Privacy Principles or as otherwise permitted under the Privacy Act.

Third Party Links To Other Websites

Our websites may contain links to websites operated and maintained by third parties over which we have absolutely no control. These third party websites are not subject to this Privacy Policy or our privacy standards and procedures. Any information you provide to third party websites will be governed by the terms of the that websites’ privacy policies, and we encourage you to review that website’s privacy policy carefully before you use or submit information to that site. We have no responsibility or liability whatsoever for the content, actions or policies of third party websites. The inclusion of third party links on our websites in no way constitutes an endorsement of such websites’ content, actions or policies.

Licensed Venues & Legal Obligations

As the operator of licensed venues, we are subject to a range of legal and regulatory obligations. In certain circumstances, we may collect, use or disclose personal information where required or authorised by law. This may include information collected or disclosed in connection with responsible service of alcohol obligations; gaming and wagering legislation; self-exclusion or exclusion orders; anti-money laundering and counter-terrorism financing requirements; investigations into incidents occurring at our venues; security, fraud prevention and loss prevention; or requests from government authorities, regulators or law enforcement agencies.

Where personal information is collected for these purposes, it will only be used or disclosed to the extent permitted or required by applicable legislation.

Keeping Your Personal Information Secure

We take the security and protection of the personal information we hold seriously. We take steps reasonable in the circumstances to ensure that the personal information we hold is protected from misuse, interference and loss and from unauthorised access, modification or disclosure.

Your personal information will be kept on databases held on servers kept in a physically and technologically secured environment, accessed only by authorised personnel or contractors. Where personal information is held in hard copy, it will be held in controlled, access restricted premises which only authorised personnel or contractors will be permitted to access.

We will destroy or de-identify personal information in circumstances where it is no longer required, unless we are otherwise required or authorised by law to retain the information.

Accessing and Correcting Your Personal Information

You entitled to access and correct the personal information we hold about and to have any inaccuracies in the information corrected.  In order to maintain the accuracy of your personal information we do rely on the personal information provided to us.   

If you would like to access or correct the personal information that we hold about you, please contact us using the details below and inform us of that you would like to access or correct your personal information. We will grant access to the extent required or authorised by the Privacy Act or other law, and where applicable take steps reasonable in the circumstances to correct personal information where necessary and appropriate.

There are some circumstances specified by law where we may refuse your request to access and/or correct your personal information. However, if one of these circumstances applies, we will provide you with a written explanation of the reasons for refusal, unless it would be unreasonable to provide that notice. If we refuse your request to access or correct your personal information, we will provide you with written reasons for the refusal.

Once we receive your request for access or correction, we will endeavour to respond to your request within a reasonable period after request is made. We may also charge reasonable costs for responding to your request.

Privacy Complaints

If you have any concerns or a complaint about a breach of your privacy or the way we have handled your personal information, please contact us using the contact details below and inform us of the nature of your complaint.

We will first acknowledge your complaint and then determine whether there are immediate steps which can be taken to resolve the complaint. Your complaint will then be investigated. We may ask you to provide further information about your complaint and the outcome you are seeking. In most cases, we will investigate and respond to a complaint within a reasonable time, usually within 30 days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know.

If, after receiving our response, you still consider that your privacy complaint remains unresolved, you may refer your concern to the Office of the Australian Information Commissioner.

Contacting Us

If you have any question about our Privacy Policy, or about how we process your personal information, or would like to make a privacy complaint, please contact us using the following details:

Privacy Officer

Email:  info@sonenco.com.au
Phone: 02 9502 1500
Post:  20 Sussex Street, Sydney NSW 2000

Last Updated: 1 July 2026