PRIVACY POLICY

 

1.                  About this policy

Western Suburbs Leagues Club Illawarra Ltd ACN 000 964 152 (Wests Illawarra) are committed to protecting the privacy of your personal information in accordance with Australian privacy laws.

Our Privacy Policy sets out how we and our related entities collect, use, disclose and manage your personal information.

Our Privacy Policy complies with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) as amended from time to time (‘Privacy Act’).

When you engage us to provide you with any goods or services, communicate with us through email, text, by telephone, in writing, participate in any of our promotional activities, or use any of our other services, including our websites or any of our mobile device applications (‘Apps’),  you agree to the use and disclosure of your personal information in the manner described in this policy.

We may from time to time review and update this Privacy Policy so please check our website or any App that you are using periodically to stay informed of any updates.  All personal information collected and held by us will be governed by the most recently updated Privacy Policy. 

2.                  Types of personal information we collect

The kinds of personal information we may collect from you will depend on what type of interaction you have with us.  Personal information we may collect from you includes among other things:

·                     identity particulars - such as your name, address, date of birth, occupation, telephone numbers and e-mail address;

·                     transaction information – we collect transaction details related to your use of our services, including the type of services requested or utilised, order details, date and time services were provided, amounts charged and benefits received and your payment methods.;

·                     personal information you provide to us when you participate in a promotion, competition, promotional activity, survey, market research, subscribe to our mailing list;

·                     your bank, credit or debit account details when you make a purchase;

·                     your records of communication with us;

·                     if you visit our website or use our App, your website and App usage information such as your IP address, dates and times of access, App features, pages viewed, or system activity;

·                     geolocation information - depending on your App settings or device permissions we may collect your precise or approximate location information as determined through data such as GPS, IP address and Wi-Fi, including when the App is running in the foreground (App open and onscreen) or background (App open but not onscreen) of your device.

·                     device information - information about the devices you use to access our services, including the hardware models, device IP address, operating systems and versions, software, file names and versions, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion information, and mobile network information.

 

3.                  The purpose for collecting your personal information

We will generally only collect and use your personal information for the primary purposes of:

·                     our general business operations;

·                     creating and updating your account;

·                     verifying your identity;

·                     processing or facilitating payments for services;  

·                     effectively providing you with our goods and services;

·                     performing internal operations necessary to provide our services, including to troubleshoot software bugs and operational problems, to conduct data analysis, testing and research, and to monitor and analyse usage and activity trends.

·                     perform research and analysis about your use of, interest in, our or others’ products, services, or content;

·                     communicating with you;

·                     responding to your inquiries or complaints;

·                     meeting our legal and regulatory obligations;

·                     conducting, improving and developing a relationship with you;

·                     direct marketing (such as providing you with information about our products and promotional notices and offers); and

·                     improving our websites or Apps.

Your personal information is only collected by lawful and fair means and where practicable, only from you or from a person acting or authorised to act on your behalf.

We will take reasonable steps to ensure that you are aware of:

·                     the likely use of the information;

·                     the right of access to the information;

·                     the identity and contact details of our employee/representative collecting your personal information;

·                     any law requiring collection of the information; and

·                     the main consequences of failure to provide your personal information.

4.                  How we may use and disclose your personal information

We may use your personal information for:

·                     the primary purposes for which it was collected, such as those described above;

·                     administering and responding to your enquiry or feedback about our products and/or services;

·                     conducting, and allowing you to participate in, a promotion, competition, promotional activity, survey, market research or customer behavioural activity;

·                     promoting and marketing our current and future products and services to you, informing you of upcoming events and special promotions and offers and analysing our products and services so as to improve and develop new products and services (but giving you the opportunity to opt out of such direct marketing);

·                     improving the operation of our websites and Apps.

We may disclose personal information we collect from you:

·                     to our related companies, suppliers, service providers, consultants, contractors or agents for the primary proposes for which it was collected or for other purposes directly related to the purpose for which the personal information is collected.  For example, your name and telephone number may be disclosed to our supplier to enable that supplier to respond to your request for information about a particular product;

·                     for direct marketing by us, but giving you the opportunity to opt out of such direct marketing; We will include our contact details in any direct marketing;

·                     to relevant Federal, State, Territory medical,  health and safety  authorities (as required);

·                     where the law requires or authorises us to do so;

·                     to others that you have been informed of at the time any personal information is collected from you;

·                     with your consent (express or implied), to others.

We do not disclose your personal information for any secondary purposes unless your consent has been given or as required by law, and we will not sell or license any personal information that we collect from you.

5.                  How your personal information is stored and secured

We take reasonable steps to protect your personal information from loss, misuse or unauthorised access by restricting access to the information in electronic format and by appropriate physical and communications security.

If a substantial data breach has or may have occurred (for example, your personal information was shared with unauthorised persons) we will notify you as soon as is practicable.

We only keep your personal information for as long as it is required for the purpose for which it was collected or as otherwise required by law. We will take appropriate measures to destroy or permanently de-identity your personal information if we no longer need to retain it.  These measures may vary depending on the type of information concerned, the way it was collected and how it was stored.

6.                  Using our Website or App and Cookies

As with most websites and apps, when you visit our website or use an application on our website, or use our App, we may record anonymous information such as IP address, time, date, referring URL, pages accessed and documents downloaded type of browser and operating system.

We also use “cookies”. A cookie is a small file that stays on your computer or device until, depending on whether it is a sessional or persistent cookie, you turn your computer or device off or it expires. Cookies may collect and store your personal information. You may adjust your internet browser or device settings to disable cookies. If cookies are disabled you may still use our website or App, but the website or App may be limited in the use of some of the features.

Our website may also contain links to or from other websites. We are not responsible for the privacy practices of other websites. This privacy policy applies only to the information we collect on our website. We encourage you to read the privacy policies of other websites you link to from our website.

7.                  Marketing and Opting-Out

We may use your personal information for:

·                     promoting and marketing of our current and future products and services;

·                     informing you of upcoming events and special promotions and offers; and

·                     analysing our products and services so as to improve and develop new products and services.

We may exchange your personal information between our related entities and so they can also assist in the marketing of our products and services to you.

We will only offer you products or services, where we reasonably believe that they could be of interest or benefit to you.

At the point we collect information from you, you may be asked to “opt in” to consent to us using or disclosing your personal information.  You will generally be given the opportunity to “opt out” from receiving marketing communications from us.  You may “opt out” from receiving these communications by clicking on an unsubscribe link at the end of an email or by contacting us with this request.

8.                  Accurate and up-to-date information

We take reasonable steps to ensure your personal information is accurate, up-to-date and not misleading by updating its records whenever true and correct changes to the data come to its attention.

If you believe your information is incorrect, incomplete or not current, you can request that we update this information by contacting our Privacy Officer. To contact our Privacy Officer please see contact details below in paragraph 16.

We will correct information we hold about you if we discover, or you are able to show to a reasonable standard, the information is incorrect. If you seek correction and we disagree that the information is incorrect, we will provide you with its reasons for taking that view.

We disregard information that seems likely to be inaccurate or out-of-date by reason of the time that has elapsed since it was collected or by reason of any other information in our possession.

9.                  Access to your personal information

We acknowledge that you have a general right of access to information concerning you, and to have inaccurate information corrected. You are able to access the personal information we hold about you by contacting our Privacy Officer. If access is refused to your personal information for reasons permitted by the Privacy Act, we will give you a notice explaining our decision to the extent practicable and your options.

To contact our Privacy Officer please see contact details below. If you make an access request, we may ask you to verify your identity and put your request in writing for security reasons.  We may charge a reasonable administration fee to cover the costs of meeting your request. We will reply to your request for access within 30 days of notification by you.

10.              Dealing with unsolicited information

We take all reasonable steps to ensure that all unsolicited information is destroyed or de-identified immediately.

11.              Anonymity when dealing with us

Only where it practicable to do so, we may allow you the option not to identify yourself when dealing with us.

12.              Collecting sensitive information

We do not collect sensitive information, unless it is specifically relevant and necessary for the purpose of our business activities and functions, and your consent is first obtained. All sensitive information that is collected is used in accordance with this privacy policy.

13.              Government identifiers

We do not use government identifiers (e.g. tax file numbers or Medicare numbers) to identify individuals.

14.              Transfer of ownership

As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganisation, dissolution or similar event, your Personal Information may be part of the transferred assets. You acknowledge and agree that any successor to or acquirer of our business (or its assets) will continue to have the right to use your Personal Information in accordance with the terms of this Privacy Policy.

15.              Complaints and disputes

If you have reason to believe that we have not complied with our obligations relating to your personal information under this Privacy Policy or under the Privacy Act, please refer any compliant to queries to our Privacy Officer (details below).

We will ensure your compliant is handled by our Privacy Officer in an appropriate and reasonable manner. Were necessary we may consult with our related entities and partners in order to deal with your complaint. A written notice of our decision regarding your complaint will be provided to you. If you are not satisfied with the outcome, then you may contact the Office of the Australian Privacy Commissioner:

Office of the Australian Information Commissioner

Website: www.oaic.gov.au

Phone: 1300 363 992

16.              Who should you contact for further information?

Please refer any queries or complaints about our Privacy Policy or privacy issues to our:

 

 

Privacy Officer

PO BOX 349
Unanderra NSW 2526
Attention: Privacy Officer

 


Phone:  (02) 4239 5800

Email:   marketing@astergroup.com.au

 

Our Privacy Officer will consider your question or complaint and respond to you in a reasonable timeframe.

Last Updated 1st August 2020