Privacy Policy & Cookie Policy

1. Introduction

(“Whiteharp”, “we”, “us” or “our”) respects your privacy and handles personal information transparently and securely. This policy explains what we collect when you browse our website, request information, make a booking enquiry, attend our hotel or casino, or communicate with us. It also explains your rights under the EU General Data Protection Regulation (“GDPR”) where applicable and relevant Australian privacy requirements.

This policy covers this website and our direct interactions with guests. Third-party booking, payment, map, video, or social platforms process information under their own policies.

2. Data Controller Information

The controller responsible for this processing is , . Contact our Privacy Contact at info@clearslightmoments.com or +61 2 9418 8905.

3. Types of Data Collected

• Identity and contact data: name, email, telephone, postal address, preferred contact method, and date of birth when age verification is legally required.
• Booking and transaction data: stay dates, room and dining preferences, booking history, payment status, and limited billing information. Authorised payment providers handle full card details.
• Enquiry and preference data: messages, accessibility needs, dietary requirements, event requests, feedback, and marketing choices.
• Technical data: IP address, browser, device, operating system, referring page, viewed pages, timestamps, approximate location, and diagnostic logs.
• Security and compliance data: records needed for fraud prevention, responsible gaming, venue safety, legal claims, and hospitality or gaming compliance.

Please provide sensitive information only when necessary for a requested service. Health or accessibility data is processed on an appropriate legal basis and is accessible only to personnel who need it.

4. Legal Basis for Processing (GDPR)

• Contract: to take requested steps before a booking and deliver accommodation, dining, event, and guest services.
• Legal obligation: to keep financial records, verify age or identity, answer lawful requests, and comply with gaming, tax, safety, and consumer laws.
• Legitimate interests: to operate and secure the site, answer enquiries, prevent fraud, improve services, protect people, and establish or defend claims, after balancing your rights.
• Consent: for optional marketing, non-essential cookies, or sensitive data where required. Consent may be withdrawn at any time without affecting earlier lawful processing.
• Vital interests: in rare emergencies where processing is needed to protect life or physical safety.

5. How Data Is Used

We use data to answer enquiries; administer reservations; communicate service updates; personalise guest arrangements; reconcile payments; provide support; maintain security; prevent fraud; satisfy legal duties; analyse site performance; improve facilities; and send marketing where permitted. We do not sell personal data or make decisions with legal or similarly significant effects solely through automation.

6. Data Storage and Retention

Data is stored in access-controlled systems operated by Whiteharp and vetted providers. We generally keep enquiries for up to 24 months after the last interaction, unsuccessful booking enquiries for 12 months, and guest and transaction records for legally required periods (generally seven years in Australia). Security logs are kept only as long as reasonably needed. Consent records remain while consent is active and for a reasonable evidentiary period afterward.

When a retention period ends, information is securely erased or anonymised unless law, a regulator, a dispute, or a legal claim requires longer retention.

7. Your Rights

Subject to applicable law and limited exceptions, you may request:

• access to your data and information about its processing;
• rectification of inaccurate or incomplete information;
• erasure of data no longer needed or unlawfully processed;
• restriction of processing while an issue is reviewed;
• portability of data processed automatically on consent or contract;
• objection to legitimate-interest processing and direct marketing;
• withdrawal of consent at any time; and
• a complaint to your EU/EEA supervisory authority or Australia’s Office of the Australian Information Commissioner.

Use the contact details below. We may request proportionate proof of identity and normally answer GDPR requests within one month, subject to lawful extensions for complex cases.

8. Cookies Policy

Cookies are small files stored on your device. Optional cookies are used only with consent where required.

• Strictly necessary: security, navigation, forms, and session continuity; normally session-only or up to 24 hours.
• Preference: remember language or display choices for up to six months.
• Analytics: measure aggregated use and performance after consent; retained for no more than 13 months.
• Third-party media: may be set when you play YouTube content or use Google Maps and persist according to each provider’s policy.

You can reject optional cookies through available consent controls or browser settings and clear them at any time. Blocking necessary cookies may prevent parts of the site from functioning.

9. Third-Party Services and Transfers

Necessary recipients may include hosting and support providers, booking and payment processors, advisers, fraud-prevention services, Google Maps, and YouTube. They receive only data required for their role and must protect it. If GDPR-protected data is transferred to a country without an adequacy decision, we use an approved safeguard such as European Commission Standard Contractual Clauses and assess supplementary protections where required.

10. Data Protection Measures

Controls include encrypted connections where available, role-based access, confidentiality duties, secure backups, updates, logging, provider due diligence, data minimisation, and incident-response procedures. No internet system is risk-free. We investigate suspected breaches and notify people and regulators within applicable deadlines where required.

11. Contact Information

Send questions, complaints, or rights requests to the Privacy Contact at , ; info@clearslightmoments.com; +61 2 9418 8905.