Privacy Policy
This Policy was last updated on 13th November 2025 and takes effect from that date.
General
This is the privacy policy of Booki.com.au (ABN 87 132 843 817) (trading as EarlyCrow), and its related bodies (referred to as “EarlyCrow”, “we”, “us”, “our”).
Personal information collected by EarlyCrow may also be shared with our affiliated brands, PonyBet and Betit. Both brands operate under a single Northern Territory wagering licence held by Booki.com.au Pty Ltd, authorised by the Northern Territory Racing and Wagering Commission.
Any sharing of information between brands is conducted solely for purposes related to responsible gambling, risk and compliance management, account security, and meeting regulatory obligations.
EarlyCrow acknowledges the importance of protecting the
privacy and rights of individuals in respect of their Personal Information. Set out
below is our policy relating to the ways we collect and manage your Personal
Information.
“Personal Information” (‘PI’) is information we hold which is
identifiable as being about you, which we collect as a result of your use of
our websites, mobile phone or tablet applications, pages or sites under the
brands that are owned and operated by us (together, the website),
your membership with EarlyCrow or whenever we otherwise deal with
you.
We are committed to ensuring that the PI we collect about you is
protected and is used, stored and disclosed in accordance with Privacy Act 1988
(Cth) (Privacy Act). Please visit
for more information.
This Privacy Policy will not apply
to websites which are linked to this website and over which EarlyCrow has no
control.
Collection of personal information
The kinds of personal information that EarlyCrow generally needs to
collect about members and applicants for membership is:
- name;
-
residential address;
- date of birth;
- gender;
- email address;
- phone
number(s);
- personally submitted preferences;
- bank account and credit card
information;
- financial information;
- identity verification
information;
- recordings of all telephone calls;
- betting activities and
behavioural data;
- website activity; and
- credit information if you have
applied for a credit facility
You must only provide accurate information that
you are authorised to disclose in order to allow us to use your personal
information in accordance with this Privacy Policy.
We will ordinarily
collect your personal information directly from you, primarily through your
use of the website or over the telephone. We may also collect personal
information from others, for example our related companies, with whom we
partner to offer you a wide range of services and rewards, or through our
agents or affiliates whom we engage to undertake marketing activities.
We are
required by law to collect some personal information about people who use our
services. We are required to collect certain information (including identity
verification information) under the Anti-Money Laundering and Counter Terrorism
Financing Act 2006 (Cth) as an example.
We may also collect personal
information from job applicants, our employees and individuals associated with
our business partners and service providers. Usually, this information is
limited to name and contact details and the other information we need for the
purpose of processing a job application and managing our business
relationships.
Collection purposes
EarlyCrow will collect your PI for the following purposes:
- to
process your application for EarlyCrow membership;
- to open an account for
you;
- to provide member services to you;
- to identify you as a member for
security purposes and to comply with our legal obligations;
- to maintain
and manage your betting account;
- to upgrade and enhance your experience when
using our website;
- to tailor or develop information, services or products which
we think may suit you;
- for marketing related purposes, including conducting
research, conducting promotions, sending you offers and telling you (including
via email, SMS or telephone) about products or services we think may be of
interest to you;
- to respond to enquiries and complaints from you;
- to
provide you with customer support;
- to monitor and detect possible fraud or
breaches of our terms and conditions of service;
- to ensure that our products
and services are used in a legal and responsible manner;
- to ensure that you and
your account with us complies with all relevant laws and your contractual
obligations to us;
- to conduct appropriate checks to detect fraud;
- to
process payments;
- to improve our products and services or to conduct
research;
- for security purposes, including to perform functions that we believe
are necessary to protect the security and proper functioning of our betting
platforms;
- to comply with our legal obligations, resolve disputes, and enforce
agreements;
- to establish, exercise or defend any legal claims; and
- to
assist in the enforcement of laws.
Use and disclosure of personal information
EarlyCrow may use and disclose your PI in the following
circumstances:
- to our associated entities and agents;
- in co-operation between brands operated by Booki.com.au
Pty Ltd where required for responsible gambling protocols, fraud prevention, account
monitoring, or compliance with wagering laws and licence obligations;
- to our
affiliates who undertake promotional and marketing activities on our
behalf (including contacting you with special offers that may be of
interest);
- to consultants, contractors, subcontractors, suppliers, service
providers and professional advisors and organisations that provide services to
assist us in operating our business (including IT, consultancy and advisory
services) to us;
- to government agencies, regulators and law enforcement bodies
such as but not limited to the Northern Territory Racing Commission, AUSTRAC,
state and federal police, principal racing authorities and sports controlling
bodies;
- to any third parties or classes of third parties that EarlyCrow
notifies you at the time of collecting your personal information that your
personal information may be disclosed to;
- for taking appropriate action if we
have reason to suspect that unlawful activity or misconduct of a serious nature
in relation to our services has been, is being or may be engaged in;
- to
protect and maintain the integrity of sports / racing codes, by assisting
controlling bodies in their inquiries or notifying such bodies of any betting
activity EarlyCrow considers to be unusual or suspicious;
- where you have
consented to the disclosure either expressly or by the circumstances and your
conduct;
- where we consider disclosure is reasonably necessary to eliminate or
minimise a risk to public health or safety;
- where we consider disclosure
is reasonably necessary to investigate or deal with unlawful activity or
serious misconduct;
- where we consider disclosure is reasonably necessary to
locate missing persons; to establish or defend a legal claim; or
- where the
disclosure is required or authorised by law.
EarlyCrow may use personal
information to create aggregate data about EarlyCrow members through
demographic profiling and statistical analysis of its database, in order to allow
for more efficient operation of the EarlyCrow business. We may provide the
information derived from such profiling or analysis in de-identified form to
potential and existing stakeholders.
EarlyCrow will take all reasonable steps
to ensure that any personal information which is disclosed to a third party is
protected by that party in accordance with the Privacy Act and is used only
for the purpose or purposes for which we supplied that information to them.
Usually, we do this by imposing contractual requirements on or seeking
assurances from third parties as to their compliance with the Privacy
Act.
We may disclose your personal information to organisations outside of
Australia, including to our related bodies corporate, to contractors, and
providers of payment services. The disclosure may be to organisations located
in the United States, Sri Lanka and the Philippines.
EarlyCrow may store data
(including personal information) on secure back-up servers outside
of Australia. This data may be accessed offshore, but only ever in compliance
with all Australian laws, including the Privacy Act, and in accordance with
this Privacy Policy.
Managed Trading Services
Customers acknowledge that the EarlyCrow platform operates
using technology and managed services provided by
BetMakers.
BetMakers delivers trading support and customer liability
management services (collectively referred to as “Managed Trading
Services”) on behalf of Booki.com.au Pty
Ltd. To facilitate this, Booki.com.au Pty
Ltd may disclose Customer Data (including personal information) to
BetMakers to the extent reasonably necessary for BetMakers to host and maintain the
EarlyCrow platform and/or provide Managed Trading Services.
Booki.com.au Pty Ltd has entered into binding contractual agreements with BetMakers requiring strict confidentiality and compliance with Australian privacy law. BetMakers is ISO 27001 certified, the internationally recognised standard for information security management.
For clarity, BetMakers is not authorised to disclose Customer Data to any third party, including other wagering operators who also use BetMakers’ Managed Trading Services. However, customers acknowledge that BetMakers’ trading staff may apply their general industry knowledge and experience when providing services to Booki.com.au Pty Ltd. This may include insights, based on professional expertise or publicly available information, into general betting behaviours within the wagering industry.
Customer data may also be securely reviewed across EarlyCrow and PonyBet as part of internal risk management controls and responsible gambling protocols, in accordance with Australian privacy legislation.
Document Verification Service
For the purposes of verifying your identification using the Document Verification Service, you confirm that you are authorised to provide the details that you provide to us during the account sign-up and identity verification process. This information is sought and used for the purpose of undertaking an information match request in relation to relevant Official Record Holder information and that a corresponding information match result will be provided via the use of third party systems. You acknowledge and consent to the use and access of your information in this way.
Direct marketing and opting out
From time to time, we may use and disclose your personal information
to inform you about EarlyCrow (and its associated entities) products or
services or about promotional activities, which EarlyCrow believes, may be of
interest or of benefit to you (provided that you have granted your express
consent to receive such information). We may do this via email, SMS, telephone, mail
or other means.
If you no longer wish to receive marketing or
promotional material from EarlyCrow at all or in any particular form, you may
contact us at any time by email at
with your request with which we will comply as soon as is
practical.
Where we send you commercial electronic messages for direct
marketing purposes, each message will contain a functional means for you to
opt-out of receiving such messages.
From time to time, we may contact you in
relation to the opening, management and administration of your EarlyCrow
account. These communications can be via any of the modes of contact recorded
when you apply to open an account, register as a member or which we otherwise
collect for the purposes of opening an account. Such communication is not
affected by your opt-in or opt-out status for direct marketing communications.
Security of Personal information and our website
You acknowledge that no data transmission over the Internet is totally
secure. We will take all reasonable precautions to ensure the security of your
Personal Information and protect this information from loss, alteration or
misuse. EarlyCrow employees, agents and contractors are required to maintain
the confidentiality of Members' PI.
Information communicated within a social
media environment (for example, Facebook, Twitter, Chat Rooms) becomes public
information. Ultimately, you are solely responsible for maintaining the secrecy
of your username, password and any account information. Please be
careful whenever using the Internet and our website.
Persons under the
age of 18 (‘Children’) cannot become EarlyCrow members and are excluded from
access to our services. We will not accept their information for the purposes of
opening a wagering account. It is, however, ultimately the responsibility of
parents or guardians to monitor their children’s Internet activities including
where appropriate by using Internet screening software.
You are
responsible for the security of and access to your own computer, mobile device or
any other means used to access the website. You must log out of your account
when you have completed your time on the website, and should not disclose your
username, password or any account information to any other person.
Cookies and how we use them
Cookies are pieces of data stored by your web browser on your hard
drive which contain information relating to your use of the website. When you
access the website, cookies may record details relating to your use of the
website, including what pages you view from the website. This information is
used for site optimisation and to improve the online experience for our
customers. These tracking technologies do not personally identify users but do
identify a user’s browser. If you would prefer not to receive cookies, your
browser can be adjusted to refuse them.
We may use third parties to
serve ads on our website. The advertisers may employ cookies and action tags
(also known as single pixel gifs or web beacons) to measure
advertising effectiveness. Any information that these third parties collect via
cookies and action tags is completely anonymous.
Contact, access, correction and further information
EarlyCrow takes reasonable steps to ensure that Personal Information
we collect is accurate, complete and up to date.
You have the right to
access the personal information we hold about you. If you would like to do so,
please send an email to our Customer Support team. We will provide you with a copy
of your personal information within a reasonable period after the request is
made, usually within 30 days. In some cases, we may not be able to provide you
with access to some or all of your personal information and, where this is the
case, we will provide reasons to you. We may also request verification of your
identity before providing access to the requested
personal information.
We give you the opportunity to correct and update
Personal Information at any time through ‘Edit Account Details’, along with
accessing your betting transactions in the ‘All Bets’ area of the site .
Requests for correction to any personal information can also be made by sending an
email to our Customer Support team.
We may refuse any request for access
to or correction of personal information if the refusal is in accordance with
the Australian Privacy Principles.
Any complaints regarding access to or
correction of personal information should be made to us in writing. We
endeavour to respond to any such complaints within a reasonable period,
usually 30 days. If you have any queries, requests for access or correction or
complaints relating to the handling of your personal information, please see
our Dispute Resolution Policy.
Further information about privacy concerns or
complaints in Australia can be found on the Office of the Australian
Information Commissioner’s (‘OAIC’) website at
If you are not satisfied with our response to your complaint, you may make a complaint to the OAIC.
Updates to this Privacy Policy and consent
In using the website, you agree to be bound by the terms of this Privacy Policy. EarlyCrow may review, change or update this Privacy Policy periodically and reserves the right to change the Privacy Policy at any time at its discretion by posting such changes on the website. We will publish our current Privacy Policy on the website and changes will take effect immediately at the time of publication. Where there is a significant change to the Privacy Policy, we will notify you of the change by posting the change on our site and within a reasonable time before the change comes into effect. If you do not accept the change as notified to you, you should close your Account before the change takes effect. It is the Member’s responsibility to ensure that they are aware of the current rules. Your continued use of the website following publication will constitute your acceptance of those changes. You should review this Privacy Policy regularly and remain familiar with its terms.