Privacy Policy

Clubs 4 Fun Pty Ltd (“Clubs4Fun”) is committed to complying with the Australian Privacy Principles in the Privacy Act 1988 (Cth) and protecting any personal information that you share with us.

The Australian Privacy Principles (APPs), outline how Australian and Norfolk Island Government agencies, all private sector and not-for-profit organisations with an annual turnover of more than $3 million, all private health service providers and some small businesses (collectively called ‘APP entities’) must handle, use and manage personal information.

The principles cover:

• the open and transparent management of personal information including having a privacy policy
• an individual having the option of transacting anonymously or using a pseudonym where practicable
• the collection of solicited personal information and receipt of unsolicited personal information including giving notice about collection
• how personal information can be used and disclosed (including overseas)
• maintaining the quality of personal information
• keeping personal information secure
• right for individuals to access and correct their personal information

This privacy policy provides details on how Clubs4Fun collects, holds and uses Personal Information collected through www.Clubs4Fun.com.au  (the Site), from Clubs or directly from you.

We understand the importance of maintaining your trust and confidence and shall use all reasonable measures to ensure that the personal information you provide remains private and is used only as set out in this policy.

Information Collection and Storage

Clubs4Fun receives information from Clubs about their members for the purpose of Clubs4Fun providing the C4F Product. The C4F Product is a Downloadable Social Media, Entertainment and Gaming Platform created for Clubs and their members. Players who register to play on their local Clubs online social gaming site are known as C4F Players. C4F Players can play their favourite games through their smart phone, tablet or PC, make in app purchases, and whilst playing may earn credits to play additional games or to play for longer periods of time.

A C4F Player will have access to online tournaments and skill games with league tables appearing to demonstrate their skills and abilities to other players on the club social network.

To the extent that you have provided your Club with consent to do so, your Club will disclose the following information about you to Clubs4Fun:

1. Club Membership Number;
2. Month and Year of Birth;
3. Gender; and
4. Postcode.

Clubs4Fun has no right to access a Club’s membership database or gaming machine data.

The personal information that you provide is held on our secure servers and may be shared by your Club in accordance with this privacy policy.

You can close your C4F Product account by emailing admin@Clubs4Fun.com.au

If you access the Site the information we collect includes your IP address, type of operating system, type of browser you operate and the area generally where you are located when accessing the website.

When you access the Site, our server makes a record of your visit and logs the following information:

1. the unique identifier for your mobile device;
2. your browser’s internet address;
3. the date and time of your visit to the site;
4. search text and parameters;
5. the pages/files/listings accessed, and documents you requested and/or downloaded;
6. cookie information;
7. the previous site you visited;
8. the type of browser you are using;
9. the username entered if accessing a restricted site;
10. session game play;
11. rewards/voucher allocated and redeemed; and
12. club events viewed.

Purpose of Data Collection

The information we collect may be used:

1. for the purpose that you provided it to us;
2. to comply with our obligations and meet statutory requirements;
3. to verify your identity and age;
4. to provide customer service and review issues with your account or your use of our services;
5. to analyse website usage;
6. to update you on changes to our services or your Club’s services (including information available through this website), this privacy policy and other administrative communications;
7. to advertise and market events, activities, opportunities, offers and the goods and services provided by your Club including by direct mail, telephone, SMS and MMS;
8. to improve our or your Club’s products and services;
9. to customise the content available through our services;
10. to enable you to share your experiences using our services with others;
11. facilitate your participation in and publish your positions in online tournaments and respective league tables;
12. to ensure appropriate legal use of licensed software; and
13. for any other purposes that would reasonably be expected by you.

Sensitive Information is only collected with the express consent of the individual or as required by law or permitted by the Privacy Act.  No sensitive information is collected by Clubs4Fun.

Use and Disclosure

Clubs4Fun will only use and/or disclose your Personal Information for the purposes it was provided or for other purposes permitted by the Privacy Act or that are set out in this Privacy Policy for which you consent.

From time to time, you may be able to visit the Clubs4Fun website or deal with us anonymously or by pseudonym. However, please be aware that, if you do not provide us with certain required personal information, we may not be able to provide you with the services that you seek.

Clubs4Fun will not use your personal information for any other purpose, nor will we disclose it, unless we have your consent to do so or in other circumstances permitted by law.

Third Parties

To deliver its services, Clubs4Fun from time to time engages and is assisted by third parties. You accept that in using Clubs4Fun’s services your information may be transmitted to third parties, that those third parties may:

1. be physically located outside of Australia, and/or
2. pass your information through websites that are hosted overseas.

No third-party content that is accessed by you as a result of passing through our Site is neither endorsed nor recommended by Clubs4Fun.

As far as reasonably practicable, Clubs4Fun will ensure that its relationships with third parties include appropriate protection of your privacy.

These third parties may include (but are not limited to):

1. our related companies, companies in which Clubs4Fun has an ownership interest or our agents, to:
   1. verify your age and identity;
   2. to provide products and/or services to you; or
   3. to market to you, their products and/or services which you may be interested in;
2. employees, third party service and content providers, platform providers, game providers, dealers and agents, contractors and advisors and suppliers who assist Clubs4Fun in managing our business, providing the C4F Product and related content and functionality or operating our website;
3. law enforcement bodies to assist in their functions, courts of law or as otherwise required or authorised by law;
4. regulatory or government bodies for the purposes of resolving customer complaints or conducting investigations.

Clubs4Fun may disclose your personal information to third parties for the following purposes:

1. to provide the service you wish to use;
2. for research purposes relating to the performance, quality, maintenance and improvement of Clubs4Fun’s services and products;
3. for direct marketing of Clubs4Fun services;
4. to customise and promote Clubs4Fun services which may be of interest to you;
5. to provide technical support to you to use Clubs4Fun’s services;
6. if permitted or required by law; or
7. otherwise with your consent.

Where Clubs4Fun discloses your information to third parties that provide services under contract to Clubs4Fun, such contracts require the third party keep your Personal Information confidential and secure.

Protection

Clubs4Fun takes reasonable and prudent precautions to protect all data that it uses, or discloses to third parties from misuse, interference and loss, and from unauthorised access, modification and disclosure to ensure that your Personal Information is protected. These measures include platform encryption, firewalls, and secure servers.

Notwithstanding the above, no data transmission over the internet or any wireless network can be guaranteed to be secure. As a result, while we use reasonable endeavours to protect your Personal Information, we do not warrant or guarantee the security of any information you transmit, and you acknowledge that you provide your information at your own risk.

Acceptance

By visiting the Site, accessing our services or otherwise providing your personal information, you provide consent to the collection and use of your personal information and device data in accordance with this policy.  If you do not agree with the terms of this Privacy Policy, please do not access the services, the Site or otherwise provide consent for a Club to furnish us with your personal information.

Storage

Personal Information is stored and archived for a period of seven (7) years. This includes information about non-members and internet site transmission logs.

Access and Correction

The Privacy Act allows individuals to access and alter records containing their Personal Information. If you wish to access your Personal Information held by Clubs4Fun please provide a written request to the Privacy Officer using the details below. Clubs4Fun will provide you with access to your information except where the Privacy Act prohibits it or if there are exceptions under law where we may refuse your request for access.

Clubs4Fun relies on the information provided by members to their Clubs to be accurate and current. Clubs4Fun takes reasonable steps in the circumstances to ensure that the Personal Information it collects, uses or discloses is accurate, complete and up-to-date.

If you believe your Personal Information is incorrect, please advise us in writing by sending your letter or email to the Privacy Officer using the details below and informing us of the correct information. We will take reasonable steps to correct Club records appropriately and within a reasonable time frame, except where the Privacy Act prohibits it or if there is an exception under law where we may refuse your correction request.

Complaints

If you wish to make a complaint about Clubs4Fun’s use of your Personal Information, please put your complaint in writing, providing as much detail as possible, and forward it by letter or email to the Privacy Officer using the details below. The Privacy Officer, or another representative of Clubs4Fun, will investigate the complaint and will provide you with a written response within a reasonable time following the completion of the investigation.

Cross Border Disclosure

Occasionally, we may disclose personal information to overseas recipients.

The privacy laws in other countries might not be the same as in Australia.  However, where we do disclose your personal information to overseas third parties, we will take such steps as are reasonable to ensure that your personal information is handled in accordance with this Privacy Policy.  Where we, or our related companies, companies in which Clubs4Fun has an ownership interest, our affiliate partners or agents, do make a cross-border disclosure, the overseas recipients are most likely to be located in Singapore.

You acknowledge and agree that:

1. Clubs4Fun will not be accountable under the Privacy Act for any breach of your privacy by an overseas recipient; and
2. You will not be able to seek redress from Clubs4Fun under the Privacy Act for any breach of your privacy by an overseas recipient.

Changes to Our Privacy Policy

Clubs4Fun reserves the right to make changes to this Privacy Policy from time to time. We will publish any changes on the Site at www.Clubs4Fun.com.au. By continuing to use our products, services and website or by continuing to provide us with your Personal Information or consenting for a Club to furnish us with your information after these changes have been published, you confirm your acceptance of these changes.

Definitions used in this Policy

For the purposes of this Policy, the following definitions apply:

1. 1. 1. 1. APPs means the Australian Privacy Principles in the Privacy Act;
         2. Claim means any claim, allegation, suit, action, demand, cause of action or proceeding, irrespective of when it arises, whether or not it is actual or contingent, or whether it is made under agreement or in tort (including in negligence), in equity, under statute or otherwise;
         3. C4F Product means the Gaming Platform and ancillary Support Services
         4. Clubs means any club that has engaged Clubs4Fun to provide the C4F Product
         5. Loss means actual or contingent damage, debt, loss, penalty, fine, expense, liability or costs (including legal costs on a solicitor/client basis and investigative costs);
         6. OAIC means the Office of the Australian Information Commissioner;
         7. Personal Information is information or an opinion about an identified individual(s) or an individual who is reasonably identifiable;
         8. Privacy Act means the Privacy Act 1988 (Cth);
         9. Sensitive Information has the meaning given to that term in the Privacy Act and includes information about an individual’s:
      2. health (including predictive genetic information)
         1. Game Content, and
         2. Platform, and
         3. Apps and Websites, and
         4. Customer Relationship Services;
      3. racial or ethnic origin
      4. political opinions
      5. membership of a political association, professional or trade association or trade union
      6. religious beliefs or affiliations
      7. philosophical beliefs
      8. sexual orientation or practices
      9. criminal record
      10. biometric information that is to be used for certain purposes
      11. biometric templates.
          1. 1. Social Gaming Platform means the provision by C4F of:
             2. Supplied Data means any data about an individual that a Club provides to Clubs4Fun Pty Ltd (including, without limitation, any information provided pursuant to paragraph (b)); and
             3. Support Services means the support and maintenance services provided by Clubs4Fun; and
             4. Suspected Data Breach arises where Clubs4Fun reasonably suspects or believes that any misuse, interference or loss, or unauthorised access, modification or disclosure of Personal Information in breach of the Privacy Act has occurred.

Contact us – Privacy Officer

Further information on Privacy can be obtained by contacting the Club’s Privacy Officer using the contact details below:

Privacy Officer

Iain Cooper

T: +61 417 226626

E: iain.cooper@c4fadmin.com.au