1. Scope

The Claremont Football Club Inc. (CFC) (ABN 64 028 387 313) believes privacy is an important right of individuals and values its protection.

Protecting personal information is fundamental to the CFC’s relationship with our members, supporters, business partners and community and industry stakeholders. 

The CFC takes steps to protect your information from misuse and to use your information only in the ways described in this Privacy Policy and in accordance with its obligations under the Privacy Act 1988 (Cth) (Privacy Act).

This Privacy Policy outlines the type of personal information the CFC collects and the ways in which CFC may collect, use, store and disclose this personal information.

When used in this document, depending on the context, ‘we’, ‘our’ and ‘us’ refers to the CFC and except where indicated otherwise, terms used in this Privacy Policy have the same meaning as the in the Privacy Act.

2. Information Collected

2.1 Personal Information
The CFC only collects personal information where reasonably necessary for our functions or activities as a not-for-profit football club.

The personal information, which the CFC collects and holds includes:

• Your name; age, billing and/or shipping address, email address, gender, occupation, telephone number(s) and sporting interests;
• Information about dealings with the CFC, including membership history and use of CFC-related services;
• Opinions and beliefs provided via surveys and questionnaires.

In addition, you may also provide to us and we may, only as reasonably necessary, collect and hold additional personal information, such as:

• Your credit card information; and
• Details of the items ordered or purchased from us.

This privacy policy applies to personal information collected via:

• Our website at http://www.claremontfc.com.au/ (including our membership and team store)
• Email;
• Telephone;
• In person; 
• Documents given to or collected by us;
• Facebook, Instagram, Twitter or other social media;
• Online survey platforms; or
• By some other means.

If any personal information we receive is unsolicited and it is determined that we could not have solicited that information in compliance with this Privacy Policy, the CFC will destroy or de-identify the information if it is lawful and reasonable to do so.

By providing us with personal information, you consent to that information being collected, used, disclosed and stored in accordance with this Privacy Policy.

If you do not give personal information to us, it may affect our ability to provide you with products and/or services. 

2.2 Sensitive Information

We will only collect, use and disclose sensitive information about you if the information is reasonably necessary for one of the purposes of the CFC described in this Privacy Policy and if you consent to the collection.

Generally, the collection of sensitive information, including information relating to health, race, ethnicity or minors, will be for the purpose of complying with our legal and regulatory obligations for events such as hosting functions, junior football clinics or WAFL matches.

2.3 Anonymity and Pseudonymity

In most circumstances, it is impractical for people to communicate with the CFC anonymously as we need to identify you to assist you effectively. However, in circumstances where it is lawful and practical to do so, such as some survey research, the CFC will provide you with the option of not identifying yourself, or using a pseudonym, when entering into communications with us.

2.4 Analytics

When you visit and browse our website or social media platforms, the website host and some third-party service providers such as Google Analytics and Facebook may collect information for statistical, reporting and maintenance services.

Subject to the terms of this Privacy Policy, the information is used to administer and improve the performance of the web services and will not be used to identify you. The information may include:

• The number of users visiting our website and social media platforms and the number of pages viewed.
• The date, time and duration of a visit;
• Visiting patterns of individuals accessing our website and social media platforms;
• The IP address of your computer or device; and
• The path taken through our website and social media platforms.

In the reproduction of this data as an analytical use report, the CFC will not (and will not allow third parties) to track or collect any personal identifiable information or associate with any personally identifiable information from any source (i.e. you will not be identified). 

2.5 Links

Our website or social media may contain links to other websites operated by third parties, including sponsors or partners of the club or the WAFL competition. We make no representations or warranties in relation to the privacy practices of any third parties’ website and are not responsible for the privacy policies or the content of any third-party website. Third party websites are responsible for informing you about their own privacy practices.

2.6 Third Parties

We will only collect personal information about you from a third party if it would be unreasonable and impracticable to collect the information directly from you. In these circumstances, the CFC may collect personal information about you from third parties, such as the Western Australian Football Commission (WAFC), so long as the collection has a direct connection to the purposes of the CFC described in this Privacy Policy.

2.7 Notification

When collecting personal information about you, we will take steps that are reasonable in the circumstances to notify you of that collection. However, where we engage with you multiple times over a short period of time in relation to the same matter, we may not provide you with a separate notice about privacy each time we engage with you. Nonetheless, we will provide you with an opportunity to opt-out of receiving communications about that matter within each of those communications.

3. Storage of Information & Security

The CFC will take reasonable steps to protect all personal information (both hard copy and electronic form) within its direct control from misuse, interference and loss, unauthorised access, modification or disclosure.  These reasonable steps may include holding information in access-controlled premises, requiring logins and passwords in electronic databases and obligating staff under confidentiality agreements.  

Wherever reasonably practicable, the CFC will store electronic personal information on data servers that are owned and controlled by the CFC and are located within the geographical borders of Australia. However, in accordance with the purposes described in this Privacy Policy, we may use cloud computing and third-party service providers where reasonably necessary for services such as payment processing and authorisation, fraud reduction and credit risk reduction, product customisation, marketing and promotional distribution and office administration. In the use of these cloud computing and third-party service providers,

such as Microsoft Office, Google Drive, Mailchimp, Survey Monkey, Bepoz & MYOB, some personal information may be stored, processed, used or disclosed overseas (in locations such as the US) by the CFC.

Where such parties are located overseas, you may have rights to enforce such parties’ compliance with applicable data protection laws, but you may not have recourse against those parties under the Australian Privacy Act in relation to how those parties treat your personal information. Where we use these services, we will use our reasonable endeavours to limit any use or disclosure of personal information overseas and ensure that any storage, processing, use or disclosure of personal information are in compliance with Australian privacy laws.

4. Use & Disclosure of Personal Information

The CFC collects, stores, uses and discloses your personal information for purposes in connection with the objects in our constitution. These purposes include, but are not limited to:

• Improving membership services and managing relationships;
• Connecting with sponsors and/or partners and enabling the promotion of their products and services;
• Marketing products, services and competitions that may interest you;  
• Facilitating internal business operations of CFC;
• Managing football development & operations; 
• Promoting CFC matches & events;
• Enabling community connection with local and regional zones;
• Managing and promoting bar & function centre services;
• Conducting research and development; and
• Complying with legal and regulatory obligations. 

5. Direct Marketing

Unless you request otherwise, we may use your personal information for direct marketing purposes to send you news, information about our activities and general promotional material, which we believe you may find useful or interesting. You consent to us contacting you with such information by means of direct mail, email, SMS, MMS messages, social media and via telephone.

If you do not want us to use your personal information in this manner, please follow relevant instructions contained in an electronic message or contact us using the details contained in section 10 to unsubscribe. We will take reasonable steps to give effect to your request as soon as practically possible. 

6. Adoption, Use or Disclosure of Government Related Identifiers

We do not collect, adopt, use or disclose Government identity numbers, such as tax-file numbers.

7. Quality of Personal Information

We keep our personal information as accurate, complete and up-to-date as possible. We make an effort to ensure this data is of high quality, but this relies on the accuracy and frequency of data provided to you. You can assist us by notifying us if you circumstances change, such as a change of name or address, by using the contact details provided in section 10 of this Privacy Policy.

The CFC also takes reasonable steps to destroy or permanently de-identify personal information, which is no longer needed for the purposes described in this Privacy Policy.

8. Notifiable Data Breaches Scheme

In the event of any loss, or unauthorised access or disclosure of your personal information that is likely to result in serious harm to you, the CFC will investigate and notify you and the Australian Information Commissioner as soon as practicable, in accordance with the Privacy Act.

9. Updating Privacy Policy

Any changes we may make to our Privacy Policy in the future will be posted on this page.

10. Contacting Us Regarding Access, Correction and Privacy Complaints

You have the right to:

• Request access to and seek correction of personal information held by the CFC subject to certain conditions being satisfied;
• Make a complaint in relation to alleged breach of privacy; or
• Submit a query or concern about this Privacy Policy or the CFC’s information handling processes,

By contacting the CFC through:

• Email at admin@claremontigers.com;
• Via phone at 08 9384 9200;
• In-person at 3 Davies Road, Claremont WA 6010.

Where it is lawful, reasonable and practicable, the CFC will facilitate your right to access, correct, complain or query within a reasonable period of time.

Claremont Football Club Privacy Policy 1.0

Updated 14-2-2020