1 Who Are We
When used in this document, depending on the context, “we,” “our” and “us” refers to BHH and/or the HFC.
Protecting personal information is fundamental to BHH’s and HFC’s relationship with our supporters, employees, players and business partners. All personal information received in connection with a BHH or HFC product or service, or in the conduct of the BHH’s or HFC’s business, is therefore treated seriously, having regard to the BHH’s and the HFC’s legal obligations.
Personal information is information that identifies you or could identify you. The BHH and HFC are subject to the Privacy Act 1988 (Cth), including the Australian Privacy Principles.
3 Information Collected
Generally, BHH collect personal information directly from you via your use of the products and services on offer, and any registration you make to participate with or receive information from, the BHH and any business relationship between you and us, including via email. The personal information which the BHH collect and hold includes:
- your name, age, billing and/or shipping address, email address, gender, occupation, telephone number(s);
- information about dealings with the BHH, including membership history, and subscriptions for BHH services;
- your BHH game attendance history where you purchase a ticket or use your BHH membership to obtain entry into a venue; and
- opinions and beliefs provided via surveys and questionnaires.
In addition, you may also provide to us and we may collect and hold additional personal information, such as:
- your credit card information; and
- details of the items ordered or purchased from us.
If you do not give personal information to us, it may affect our ability to provide you with products and/or services.
Where we engage with you multiple times over a short period in relation to the same matter, we may not provide you with a separate notice about privacy each time we engage with you however we will provide you with an opportunity to opt–out of receiving communications about that matter within each of those communications.
You can easily unsubscribe at any time you want to our communications by contacting us using the contact details of email@example.com or by following the instructions contained in an e‐mail.
It may take some time to put an opt‐out or an unsubscribe in effect so you may still receive communications from us for several weeks after your request is received.
For the avoidance of doubt, by opting–out or unsubscribing yourself from a mailing list of a BHH product or service this will ensure your removal from that particular mailing list but will not guarantee your removal from other mailing lists that the BHH may store your details in as a result of your engagement with a different service or product.
5 Information from Third Parties
We may also receive information about you from third parties in relation to other websites. For example, you may choose to participate in a third party application or feature as part of our services (such as logging in through Facebook Connect or Google+ or otherwise linking to the services from another website or interactive service) or on a third party website or service (such as a Facebook application or a similar application or feature) through which you allow us to collect (or the third party to share) information about you, including personal information.
6 Storage of Personal Information
Wherever reasonably practicable, the BHH and HFC will store personal information on data servers that are owned and controlled by the BHH and HFC and are located within the geographical borders of Australia. However, some of your personal information may be transferred, stored, processed, used or disclosed overseas by the BHH or HFC, or by the BHH’s or HFC‘s third party service providers.
This may happen if our service providers are located overseas, or if transactions, information, services or products have an overseas connection. 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 (Cth) 1988 in relation to how those parties treat your personal information.
7 Use and Disclosure of Personal Information
The BHH and HFC collect, hold, use and disclose your personal information for purposes including, without limitation:
- to verify your identity;
- to facilitate community competitions and programs;
- to provide, and to assist us with providing products and services to you, to manage and account for the products and services, and to improve the products and services;
- to manage BHH and HFC relationship(s) with you;
- to provide you with information about events, products and/or services that may interest you;
- to facilitate the internal business operations of the BHH;
- to promote and market BHH events, products or services;
- to undertake research;
- to enable corporate partners and sponsors of the BHH, to market and promote their products and services to you; and
- to provide to our third party service providers in connection with any of the above. The BHH and HFC may also disclose personal information where it is otherwise permitted to do so by law.
You consent to the BHH and HFC using your personal information for sending you information, including promotional material, about the VFL, BHH or HFC, or the BHH or HFC products and services, as well as the products and services of selected third parties, now and in the future. You also consent to us contacting you with such information by means of direct mail, email, SMS, MMS messages, social media and via telephone.
Sharing Information With Third Parties
We engage third parties to perform services in connection with the operation of our business. Examples of these services include payment processing and authorisation, fraud protection and credit risk reduction, product customisation, order fulfilment and shipping, marketing and promotional material distribution, website evaluation, data analysis and, where applicable, data cleansing.
We may need to share personal information with these third parties so that they can perform these services, however, we limit the personal information that we give to them and authorise them to use this information only for the purpose of performing those services. We may share aggregated demographic information about our user base with our agents, including agencies or third party vendors so that they can provide marketing analysis and consult on advertising strategies. This information does not identify individual users. We also may share nonpersonal information, such as the number of users who visited BHH online sites during a specific time period or who purchased a specific product through the website, with our marketing partners, advertisers and others from time to time. This information generally is shared in an aggregated form. The BHH and HFC do not otherwise disclose personal information without your permission, unless the disclosure is:
- required or authorised by law, including without limitation the Australian Privacy Principles under the Privacy Act 1988 (Cth).
8 Information Security
The BHH and HFC will take reasonable steps to protect all personal information within their direct control from misuse, interference, loss, unauthorised access, modification or disclosure. The BHH and HFC will take reasonable steps to hold information securely in electronic or physical form in access controlled premises or in electronic databases requiring logins and passwords.
9 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 BH and/or HFC will investigate and notify you and the Australian Information Commissioner as soon as practicable, in accordance with the Privacy Act 1988 (Cth).
10 Contacting Us Regarding Access, Correction and Privacy Complaints
The privacy laws of some jurisdictions give individuals the right to access, amend or delete their personal information or, in some circumstances, to restrict or object to the processing of their personal information.
Information we hold about you should be up‐to‐date and accurate. Please advise of any changes to your information.
An individual may:
- request access to and seek the correction of their personal information held by the BHH and/or HFC at any time;
by contacting the HFC by email at firstname.lastname@example.org.
You will be required to provide proof of identity in order to obtain access to your personal information. If you would like to request a copy of your data or would like to take steps to exercise your rights, please contact us as at email@example.com. The BHH or HFC may charge an administration fee where access is provided. The BHH or HFC may refuse to provide access if permitted to do so by law. The BHH and HFC aims to provide access to your personal information within 30 days of a valid request.
At all times, privacy complaints:
- will be treated seriously;
- will be dealt with promptly;
- will be dealt with in a confidential manner; and
- will not affect your existing obligations or affect the commercial arrangements between you and the BHH.
The HFC’s Privacy Officer will commence an investigation into your complaint. You will be informed of the outcome of your complaint within a reasonable period of time following completion of the investigation.