South Sydney Rabbitohs – Privacy Policy

Rabbitohs Privacy Policy

1. Introduction

In this Privacy Policy, "we", "us", "our" and "Rabbitohs" means South Sydney District Rugby League Football Club Ltd and its Related Bodies Corporate. Please read this Privacy Policy carefully as it describes how we collect, use and handle your Personal Information.

We respect the importance of your privacy and your right to control your Personal Information and are committed to complying with applicable privacy laws (including the Privacy Act and the GDPR). We will only request Personal Information that is reasonably necessary for us to perform our functions and activities as a club. Please be aware, you are under no obligation to provide us with your Personal Information, but if you choose not to provide your Personal Information, you may not be able to take advantage of one or more of the features or services we offer.

On request and wherever it is lawful and practicable, we will offer you the opportunity of not identifying yourself, or of using a pseudonym, when entering transactions, or otherwise dealing with us.

2. What types of Personal Information may we collect?

The types of Personal Information we may collect depends on the purposes for which such information is collected, and may include:

(a) your name, gender, date or birth, occupation, residential address, email address, telephone number and other contact details;

(b) memberships, subscriptions and attendance history at Rabbitohs matches (whether you have used your membership to purchase tickets, or as a casual ticket purchaser);

(c) purchasing preferences and financial details, for example when you buy tickets, purchase merchandise or as part of competitions and promotions;

(d) information about how you browse, access, use, interact with or register for (together, use) Our Platforms, including information about your device, operating system, software, internet connection, usage patterns and location data; and

(e) any content, information or material that you submit, or that is submitted using your Account, to any of Our Platforms, including your username, profile picture, posts, comments and saved drafts and your communications with other users and with us, regardless of the type of such content, information or material.

We will generally not collect Sensitive Information from you, unless:

(a) you have consented to the collection of such specific Sensitive Information;

(b) we or the NRL are specifically permitted to do so under the NRL Rules, including for health, medical and anti-doping testing purposes and investigation of disputes (whatever the nature of the dispute);

(d) the collection is otherwise permitted under applicable privacy laws (including the Privacy Act and GDPR).

Aggregated data

We may also collect other information when you use or access any of Our Platforms, some of which is Personal Information and some of which is not.

This information will include information about your device, software, operating system, location, IP address and the domain name of your internet service provider. This information is aggregated for reporting purposes. Details that information personal information are removed and you will remain anonymous, unless you have provided express consent for us to recognise you (or your usage).

This information is collected by us to analyse trends and demographics and to assist in improving Our Platforms and other products, services, benefits and experiences that we provide or may in future provide, and may be provided to third parties (including our Partners) for marketing, research and other commercial and non-commercial purposes.

Cookies and similar technologies

We use cookies, web beacons and other technologies on our Platforms to collect information about your usage of our Platforms (for instance, third party websites you visit to better understand your preferences and what types of products, services, benefits and experiences you may be interested in).

3. How do we collect your Personal Information?

We collect your Personal Information in a variety of scenarios, including:

(a) When you give it to us, for example, when you:

order, purchase, or enquire about any of our products or services through any of Our Platforms, including merchandise, membership, and corporate products such as functions and events;
enquire about, or participate in promotional activities, giveaways or competitions that we run (including on behalf of our Partners);
use any of Our Platforms;
register or update an Account (including a profile);
request or receive customer service or technical support;
apply for employment with, or provide services to, us; and
otherwise interact with us, for example at match days, member appreciation days, and other events that we organise or manage;

(b) Through our systems and analytical tools, for example, when you use our Platforms or register an Account (including via cookies and other technologies); and

the NRL, QRL and NSWRL, including their constituent clubs and each of their Related Bodies Corporate, sponsors, broadcasters, advertisers and other commercial and corporate partners;
our Partners and suppliers;
a publicly maintained record or other publicly available sources of information, including social media and similar websites; and
other selected third parties (for example, Ticketek and Ticketmaster).

From time to time, we may have relationships with others, including Partners, that we allow to place advertisements on Our Platforms. As a result, when you visit any of Our Platforms, advertisers and advertising service companies may collect information such as your domain type, IP address and clickstream information.

4. Personal information of minors

If you are under 16:

(a) you must obtain consent from your parent or legal guardian before providing Personal Information to us;

(b) we may also collect Personal Information about you from your parent or legal guardian; and

(c) we may share your Personal Information with your parent or legal guardian, including to ensure your safety on Our Platforms.

If you are under 16, and we determine that Personal Information you have provided to us was provided without consent from your parent or legal guardian, we will delete your Personal Information.

5. Why do we collect, use, hold and disclose your Personal Information?

We are always seeking to better understand our player and fan preferences, trends and interests, including to improve the services, products, benefits and experiences that we and our Partners provide. To do so, we may use, hold or disclose Personal Information that we have collected from you or other third parties.

We generally only collect, use, disclose or hold Personal Information that is reasonably necessary for us to perform one or more of our functions or activities as a club, including:

(a) organising, conducting and promoting matches involving the Rabbitohs (for example, providing you information about upcoming ticket offers and deals for the next home matches);

(b) direct communication with you by Rugby League Administrators;

(c) promoting, selling and direct marketing products, services, benefits and experiences including those provided by our Partners (as described further in this clause 5);

(d) serving content in accordance with your preferences and previous consumption;

(e) managing, improving and monitoring the operation, security and integrity of Our Platforms;

(f) detecting and preventing fraudulent or illegal use of Our Platforms and ensuring compliance with the Terms of Use (including reviewing chat logs and other communications using Our Platforms);

(g) enforcing age restriction controls;

(h) conducting or communicating promotions or competitions involving the Rabbitohs, the NRL or related third-parties, including our Partners;

(i) assisting the NRL to analyse fan behaviour and preferences to improve fan support, fan offerings, provide more targeted content and products and any other purposes described in the NRL’s Privacy Policy, available here: https://www.nrl.com/privacy-policy/; and

(j) complying with our contractual and legal obligations and exercising any lawful rights held by us, or any of the parties that assist us to provide products, services, benefits and experiences (including Our Platforms).

We only use, hold or disclose your Personal Information for the primary purpose for which it was collected, a related secondary purpose, in accordance with any express consent you grant us or as otherwise lawfully required.

Direct Marketing

We may use or disclose your Personal Information to a third party (including a Rugby League Administrator or Partner) for the secondary purpose of direct marketing communications, if:

(a) we collected the information from you;

(b) you would reasonably expect your Personal Information to be used or disclosed for direct marketing;

(d) you have not made a request not to receive direct marketing.

Where you would not reasonably expect your Personal Information to be used for direct marketing, or the information has been collected from a third party (for instance, from the NRL or other clubs), we may use the information for the secondary purpose of direct marketing communication only where:

(a) you have expressly consented to the use or disclosure for direct marketing, or it is impracticable for us to seek your consent before that use;

(b) you have not made a request to us not to receive direct marketing communication;

(c) in each direct marketing communication, we prominently display a simple notice or actionable option through which you may express a wish not to receive any further direct marketing communication; and

(d) each written direct marketing communication by us sets out our contact details including business address, telephone and email address.

6. Who do we disclose your Personal Information to?

We may provide your Personal Information to third parties as part of our functions and activities including:

(a) delivery, courier and postal organisations: we may disclose your Personal Information to delivery, courier and postal organisations to deliver products (including merchandise) that you order;

(b) the NRL, QRL, NSWRL, Country League of New South Wales, any clubs of any such league and selected third parties (for instance, Ticketek and Ticketmaster): we may disclose your Personal Information as part of the Rugby League Exchange. The NRL and selected third parties may send you information about products and services which the NRL believes will be of interest to you. If you do not wish to receive information from the NRL, please opt out from such promotional and marketing information via your NRL account (being the account that you use to access the NRL digital network, including the NRL website and application and fantasy/tipping websites and applications), via links in emails and other communication we send to you from time to time or by contacting the NRL's Privacy Officer in accordance with the NRL Privacy Policy;

(c) our Partners: we may disclose your Personal Information to our Partners, for the purposes of them sending you information about products, services, benefits and experiences which they believe will be of interest to you. Refer to clause 5 for more information;

(d) law enforcement and emergency services agencies: we may disclose your Personal Information where required or authorised to do so by law, including in emergency situations and to assist law enforcement agencies with active investigations. We will always seek to ensure that those to whom we disclose your Personal Information have the legal right to receive it;

(e) organisations involved in marketing and promotions: we engage email marketing providers, market research companies, promotions management and other data analytics companies to perform direct marketing on our behalf. You will always have the right to opt out of receiving promotional materials from us;

(f) organisations involved in competitions and giveaways: we may disclose your Personal Information to our Partners or other third parties in the event of a competition or giveaway that is not directly facilitated by us. You will be informed when registering for the competition if this is the case; and

(g) other users: Our Platforms may include forums, feeds, comments sections, channels, direct messaging and voice or video calling functionality and other tools where users can communicate with one another. When you post or submit information using these tools, the information may be publicly available online and you do so at your own risk. These communications may be viewed or heard by others, and you should avoid revealing any personally identifiable information about you or any other person using these tools.

7. Data quality and security

We will take reasonable steps, with the assistance of others where relevant, to protect your Personal Information from misuse, loss, unauthorised access, modification or disclosure. This includes engaging reputable third-party service providers and ensuring that we use reasonable security systems and procedures.

8. Your rights

You can access, review and manage your Personal Information, including to opt out of receiving promotional and marketing materials from us, through:

(a) your Account (using your login credentials);

(b) communications preferences accessed via links in emails and other communications we send to you from time to time; or

You will be responsible for ensuring your Personal Information remains accurate, complete and up to date. Please ensure that any written request for access or correction addressed to our Privacy Officer provides adequate detail that identifies what Personal Information you want access to or corrected. Where your request will require us to incur costs, we may charge you an access fee to cover those costs (for instance, reasonable staff costs in searching for, locating and retrieving the requested Personal Information). We will inform you of any such charges prior to them being incurred.

In certain circumstances, we may refuse to provide you access to your Personal Information. Where we refuse you access, we will provide you with a written explanation as to the reasons for the rejection (for instance, we may refuse to disclose Personal Information to you where such access would have an unreasonable impact on the privacy of other individuals).

You may also have additional rights under local laws. For example, if the processing of your Personal Information is subject to the GDPR, and your Personal Information is processed based on legitimate interests, you have the right to object to the processing on grounds relating to your specific situation. Under the GDPR, you may also have the right to request to have your Personal Information deleted or restricted and to request for the portability of your Personal Information.

9. Transborder data flows

We may transfer, store, process, use or disclose your Personal Information to overseas recipients for various reasons, such as processing membership and hosting services, most likely in China, the United States and New Zealand, although countries where such recipients are located may vary.

We will not transfer your Personal Information to an overseas recipient unless:

(a) we have first taken steps reasonable in the circumstances to ensure that the Personal Information that we transfer will not be held, used or disclosed by the recipient of the information inconsistently with, or otherwise in breach of, applicable privacy laws (including the Privacy Act and GDPR). For example, we may adopt appropriate contractual clauses with overseas recipients that ensure their compliance with applicable privacy laws (including the Privacy Act and GDPR); or

(b) both of the following apply:

• we reasonably believe that the recipient is subject to a law or binding scheme that has the effect of protecting the information in a way that is, overall, substantially similar to applicable privacy laws (including the Privacy Act and GDPR) and there are mechanisms available to you to enforce that protection or scheme; and

• you expressly consent to the transfer after we have informed you that the applicable privacy laws (including the Privacy Act and GDPR) will no longer apply if you provide your express consent.

You agree to the disclosure and use of such Personal Information in accordance with this Privacy Policy, and consent to its transfer overseas and its collection, storage, processing, use and disclosure by third parties, solely for the purposes described in this Privacy Policy, without us being responsible for such collection, storage, processing, use or disclosure (or for any breach of your privacy).

10. Links to other websites

Our Platforms may contain links to third party websites, applications or accounts, including of our Partners and other companies that we have a relationship with (Third Party Platforms). We are not responsible for the privacy practices of Third Party Platforms. Any concern that you may have regarding the management of your Personal Information in connection with a Third Party Platform should be directed to the operator of that Third Party Platform.

11. Enquiries Procedure

All complaints and enquiries concerning your Personal Information, including in respect of alleged breaches of this Privacy Policy or applicable privacy laws (including the Privacy Act and GDPR), should be directed to our Privacy Officer:

The Privacy Officer

South Sydney District Rugby League Football Club Ltd

417/439 Bunnerong Rd,

Maroubra NSW 2035

+612 8306 9900

[email protected]

Privacy complaints and inquiries will be treated seriously, dealt with promptly and confidentially, and will not affect your existing obligations or commercial arrangements with us.

12. Privacy Policy Updates

This Privacy Policy was last updated in [June 2022]. We may update this Privacy Policy from time to time, in which case we will post the updated version of the Privacy Policy on our website https://www.rabbitohs.com.au/privacy-policy/ but may not personally notify you. As such, please check back periodically to see if our Privacy Policy has been updated.

13. Definitions

In this Privacy Policy:

(a) the words “including”, “includes” or “for example” are not used as, nor are they intended to be, interpreted as words of limitation; and

(b) the following terms have the following meanings:

Account means a person's login credentials and personal account for accessing one or more of Our Platforms.

Competition means any competition, tournament or league registered or carried out by the NRL or States including the pre-season, season proper, finals series and any post season tournament or knockout cup competition and any other football competition or tournament.

Competition Administrator means the entity responsible for the conduct and staging of a Competition and includes (without limitation) the NRL and States (including the divisions and associations that make up the States).

GDPR means the European Union General Data Protection Regulation.

NRL means the Australian Rugby League Commission Limited, National Rugby League Limited and each of its Related Bodies Corporate.

NRL Rules means its constitution, rules, regulations, policies and procedures and any other ancillary document that governs the NRL in administering the game of rugby league, as promulgated and amended from time to time.

NSWRL means the New South Wales Rugby League.

Our Platforms means websites, applications and other systems, accounts and platforms that we own, control or operate, including member portals, apps, and social media and email accounts.

Partner means our sponsors, broadcasters, advertisers and other commercial and corporate partners.

Personal Information means any information or an opinion about an identified natural person, or a natural person who is reasonably identifiable whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not.

Privacy Officer means the person appointed by the South Sydney District Rugby League Football Club Ltd from time to time to deal with complaints and inquiries under this Privacy Policy.

Privacy Act means the Privacy Act 1988 (Cth).

QRL means the Queensland Rugby League.

Related Body Corporate has the meaning given to that term in section 50 of the Corporations Act 2001 (Cth).

Rugby League Administrators mean the NRL, States, a Competition Administrator or a Club (as the case may be).

Rugby League Exchange means the data storage architecture established and administered by the NRL, in conjunction with its constituent clubs, States and selected third parties, for processing your Personal Information.

Sensitive Information means information or an opinion about your racial or ethnic origin, political opinions. membership of political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record that is also Personal Information as well as health information, genetic information, biometric information for the purposes of verification/identification and biometric templates about you.

States means Queensland Rugby League, New South Wales Rugby League, Country Rugby League of New South Wales, NRL Victoria, NRL South Australia, NRL Northern Territory, NRL Western Australia and NRL Tasmania.

Third Party Platforms has the meaning given to that term in clause 10.