This privacy policy governs the way PUNTERSTECH Pty Ltd ACN 657 964 022 (we, us) handles personal information. It applies to all personal information we collect in connection with our website (www.punterstech.com) (Website) and our PUNTERSTECH software (PUNTERSTECH). We own and operate PUNTERSTECH software, which develops innovative software solutions for the global wagering marketplace utilizing quantitative modelling, tooling, and advanced intelligent automation systems. The nature of the PUNTERSTECH functionality means that we collect, handle, and disclose a broad range of information, including personal information. ‘Personal information’ is information or an opinion about you (whether true or not) that identifies you or from which your identity is reasonably identifiable. Please take a moment to read this privacy policy as it explains how we collect and handle your personal information, and in what circumstances we will disclose your personal information to third parties.
We also provide PUNTERSTECH to licensed wagering operators, such as bookmakers (our clients). In doing so, we handle personal information about our clients’ customers. How we handle that information, including how we combine, aggregate and de-identify it, is explained under ‘Information we handle on behalf of wagering operators’ below.
We comply with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs), which regulate how we may collect, use, disclose and store personal information. The purpose of this privacy policy is to keep you informed of the ways we gather, manage, store, disclose and protect your personal information and help you to understand your rights (and our obligations) under the Privacy Act.
We may change this privacy policy from time to time. The updated privacy policy will be posted on the Website, with the date of the update shown.
We collect information about you that we reasonably need for our business functions and activities, which primarily involve operating PUNTERSTECH. Operating the PUNTERSTECH Software and Website necessitates the collection and handling of a broad range of information by us, which may include:
We may use your personal information for activities in support of our primary business functions such as processing payments, administration, employment, management, marketing, contracting, IT, legal, and customer support.
We do not collect ‘sensitive information’, which is a subset of personal information that includes health and biometric information.
We will collect and hold your personal information in a fair and lawful manner. Where it is reasonably practical to do so, we will collect your personal information directly from you. For example, we may collect the personal information you directly give us directly through some of the following means:
Where it is not reasonably practical for us to collect your personal information from you directly, we may collect personal information about you from third parties or from publicly available sources. For example, your personal information may be provided to us by one of our clients to enable us to provide services to that client. Payments are processed by third-party payment service providers, and we do not generally access, collect or store full credit card details. In certain cases we may collect personal information from publically available sources and third parties, such as from our suppliers, contractors, clients and business partners. If we collect personal information about you from a third party we will, where appropriate, request that the third party inform you that we are holding such information, how we will use and disclose it, and that you may contact us to gain access to and correct and update the information.
Our clients include licensed wagering operators that use PUNTERSTECH to run their wagering platforms. In providing services to those clients, we receive, store and process information about our clients’ customers and their activity (Client Data). Client Data may include:
The wagering operator is generally responsible for collecting Client Data from its customers and for telling them how it will be handled. If you hold an account with a wagering operator that uses PUNTERSTECH, you should also read that operator’s privacy policy. We handle Client Data in accordance with our agreements with our clients, the Privacy Act and this privacy policy.
We combine and analyse Client Data across our clients, together with information from other sources (such as market, pricing and event data), to create aggregated and de-identified information. We use this information to:
Aggregated and de-identified information does not identify any individual, and we take reasonable technical, contractual and access-control measures to prevent it from being used to re-identify an individual. Information that has been de-identified in this way is not personal information. We own the aggregated and de-identified information we create and may use and share it for any lawful purpose, including with our clients.
Where permitted by our agreements with our clients and by law, we may also use identifiable Client Data across our clients to identify individuals who present fraud, money laundering, automated or bot activity, integrity or responsible gambling risks (for example, the same person holding accounts with several operators, or a self-excluded person opening a new account), and may notify the affected clients of those risks. Otherwise, we will not disclose one client’s identifiable Client Data to another client.
We do not sell Client Data. We retain Client Data for as long as required under our client agreements and to meet the record-keeping obligations that apply to wagering, after which we destroy it, de-identify it or return it to the relevant client.
If we receive personal information about you that we have not requested, and if we determine that we could not have lawfully collected that information under the Privacy Act if we had requested it, we will destroy or de-identify the information (if it is lawful and reasonable to do so). If we collect your personal information in an unsolicited manner, we will take reasonable steps to inform you of such collection and also how we use, disclose and secure your personal information. Such reasonable steps may include referring you to this privacy policy.
It is generally not practical to remain anonymous or to use a pseudonym when dealing with PUNTERSTECH as we usually need to use your personal information to provide services to you. If you choose not to provide us with your personal information, we may not be able to provide you with requested products or services, or provide you with requested information concerning an enquiry, account or complaint.
As a general rule, we only process personal information for purposes that would be considered relevant and reasonable in the circumstances. We collect, hold, use and disclose personal information to:
We may also use your personal information for activities in support of our primary business functions such as processing payments, administration, recruitment, management, IT, legal, and customer support.
PUNTERSTECH uses computer programs, including quantitative models and automated rules, that use personal information (including Client Data) to make, or to substantially and directly assist our clients to make, decisions that may affect our clients’ customers. These include decisions about:
The kinds of personal information used in these decisions include betting history and patterns, account and transaction information, and device and session information. These decisions are made by, or on behalf of, the wagering operator with whom the customer holds an account, and that operator can review and override them. If you have a question about a decision affecting your account, please contact your wagering operator or our Privacy Officer.
We will hold personal information as either secure physical records, electronically on our intranet system, in cloud storage, and in some cases, records on third party servers. Except as described under ‘Overseas disclosures’ below, it is not our usual practice to send data overseas.
We maintain appropriate physical, procedural and technical security for our office and information storage facilities so as to prevent any loss, misuse, unauthorised access, disclosure, or modification of personal information. This also applies to disposal of personal information. We will destroy or de-identify your personal information once it is no longer needed for a valid purpose or required to be kept by law.
Like most businesses, marketing is important to our continued success. We may use your personal information (such as your contact details) to provide you with information about our products and services (including those of third parties and other users of PUNTERSTECH) that we consider may be of interest to you. We may also share, including on behalf of our clients, de-identified or aggregated information, and information collected through cookies and similar technologies (such as advertising pixels), with advertising and social media platforms so that we and our clients can measure the effectiveness of advertising and show relevant advertising to audiences on those platforms. This information does not include your name or contact details.
You may opt out at any time if you no longer wish to receive marketing information from us. You can do this by contacting our Privacy Officer or by using the ‘unsubscribe’ function included in our marketing emails.
We do not use identifiable Client Data for our own direct marketing, and we do not sell Client Data or provide it to other organisations for their own marketing purposes. Information shared with advertising platforms on our clients’ behalf is limited to the de-identified, aggregated and cookie-based information described above.
A cookie is a small text file stored in your computer’s memory or on your hard disk for a pre-defined period of time. We use cookies to identify specific machines in order to collect aggregate information on how visitors are experiencing the Website. This information will help to better adapt the Website to suit personal requirements. We and our clients also use cookies and similar technologies provided by advertising and social media platforms (such as advertising pixels) to measure and target advertising. Those platforms may collect information about your device and browsing activity in accordance with their own privacy policies, and you can manage this through your browser settings and the advertising settings of those platforms. For information on cookie settings of your internet browser, please refer to your browser’s manual.
From time to time we may engage overseas service providers, such as cloud-based software, email and productivity tools, advertising and social media platforms, which may store or process information in other countries, including the United States. Please note that the use of overseas service providers to store personal information will not always involve a disclosure of personal information to that overseas provider. Where we disclose personal information to an overseas recipient, we take reasonable steps, including contractual protections, to ensure that the recipient handles it consistently with the APPs.
Our platform and the Client Data it holds are hosted in Australia.
You may contact our Privacy Officer using the contact details below to request access to, or a correction of, the personal information that we hold about you. We will deal with your request within a reasonable time. On the rare occasion that we refuse access, we will provide you with a written notice setting out the reasons for the refusal and the relevant provisions of the Privacy Act that we rely on to refuse access. We will also provide you with avenues to complain about our refusal to provide you with access to the information.
We are not obliged to correct any of your personal information if we do not agree that it requires correction. If we refuse a correction request, we will provide you with a written notice with our reasons for refusing.
We may recover reasonable costs in relation to a request for access to personal information.
If your request relates to Client Data, we may refer you to the relevant wagering operator, which is generally best placed to respond, and we will assist that operator to respond to your request.
If you have any questions, concerns or complaints about this privacy policy, or how we handle your personal information, please contact our Privacy Officer using the contact details provided below.
Email: info@punterstech.com
We take all complaints seriously and will respond to your complaint within a reasonable period. You may also lodge a complaint with the Office of the Australian Information Commissioner by telephone: 1300 363 992 or email: enquiries@oaic.gov.au.
This privacy policy was last updated on 8 October 2026.