Richmond Privacy Policy

1    Who Are We

Your privacy is important to the Australian Football League (ABN 97 489 912 318) (AFL) and each of the 18 AFL Clubs listed in paragraph 12 of this Privacy Policy (AFL Clubs). This Privacy Policy provides information about the personal information that the AFL and AFL Clubs collect and the ways in which the AFL and AFL Clubs may use, hold and disclose this personal information.

The AFL may disclose your personal information to AFL Clubs, and AFL Clubs may disclose your personal information to the AFL.  Each organisation will collect and use your personal information in accordance with this Privacy Policy.

When used in this document, depending on the context, "we," "our" and "us" refers to AFL and/or the AFL Clubs.

2     AFL and AFL Clubs Privacy Policy

Protecting personal information is fundamental to the AFL’s and AFL Clubs’ relationship with our supporters, employees, players and business partners. All personal information received in connection with an AFL or AFL Club product or service, or in the conduct of the AFL’s or AFL Clubs’ business, is therefore treated seriously, having regard to the AFL’s and the AFL Clubs’ legal obligations.

Personal information is information that identifies you or could identify you. The AFL and AFL Clubs are subject to the Privacy Act 1988 (Cth), including the Australian Privacy Principles.

3    Information Collected

Generally, the AFL and the AFL Clubs collect personal information directly from you via your use of the products and services on offer, use of AFL Online (defined in paragraph 9 of this Privacy Policy below) and any registration you make to participate with or receive information from, the AFL or your AFL Club and any business relationship between you and us, including via email.  The personal information which the AFL and AFL Clubs collect and hold includes:

• your name, age, billing and/or shipping address, email address, gender, occupation, telephone number(s) and your AFL Club support;
• information about dealings with the AFL and AFL Clubs, including membership history, and subscriptions for AFL services;
• your AFL game attendance history where you purchase a ticket or use your AFL or AFL Club 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.

We also may collect additional non-personally identifiable information (for example, browser version, IP address), including that will provide information regarding the general use of AFL Online.

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.

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.

4 Opt-Out/Unsubscribe

You can easily unsubscribe at any time you want to our communications by contacting us using the contact details specified in paragraph 11 of this Privacy Policy 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 an AFL or AFL Club 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 AFL or an AFL Club may store your details in as a result of your engagement with a different service or product.

5    Information from Third Parties

During the course of business, the AFL and AFL Clubs may also collect personal information that is given to them by a third party (for example, a corporate partner of the AFL or AFL Clubs or information that is on a publicly maintained record). This information forms part of the personal information described in this Privacy Policy. The AFL and AFL Clubs will not intentionally solicit personal information that is unintentionally disclosed.

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. When you choose to participate, you may be opting to link your activity on AFL Online services with that third party website or service, which may then collect information about your visits to AFL Online and may publish that activity as you request to your "profile" or similar feature with that third party (such as if you choose to share content you find on AFL Online with your "connections" on the third party's website or service).

The information we collect is subject to this Privacy Policy. However, the information collected and stored by the third party remains subject to the third party's privacy practices, including whether the third party continues to share information with us or with other third parties, the types of information shared, and your choices with regard to what is visible to others on that third party's website or service. The third party may allow you to remove the application or feature, in which case we will no longer collect information about you through the application or feature, but we may retain the information previously collected. In addition, we may receive information about you if other users of a third party website or service give us access to their profiles and you are one of their "connections" or information about you is otherwise accessible through your "connections'" web page, profile page, or similar page on a social networking or other third party website or interactive service.

6    Public Forums, Refer a Friend, and Customer Testimonials

The AFL and AFL Clubs may provide bulletin boards, blogs, or chat rooms on AFL Online or mobile applications. Any personal information you choose to submit in such a forum may be read, collected, or used by others who visit these forums, and may be used to send you unsolicited messages. The AFL and AFL Clubs are not responsible for the personal information you choose to submit in these forums.

7    Storage of Personal Information

Wherever reasonably practicable, the AFL and AFL Clubs will store personal information on data servers that are owned and controlled by the AFL and AFL Clubs 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 AFL or AFL Clubs, or by the AFL's or AFL Clubs' third party service providers. In particular, at the date this Privacy Policy was most recently updated, your personal information may be disclosed to recipients in the USA, Gibraltar, China and other countries from time to time.  

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. 

You agree to the disclosure and use of such personal information in accordance with this Privacy Policy, and consent to its disclosure overseas and its use by third parties, including our service providers, in the USA, Gibraltar, China and such other countries in which those parties or their computer systems may be located from time to time, where it may be used solely for the purposes described in this Privacy Policy, without us being responsible for such use (or for any breach).  Where the AFL and AFL Clubs use cloud computing services we will use our reasonable endeavours to ensure that such disclosures are in compliance with Australian privacy laws.

8   Use and Disclosure of Personal Information

The AFL and AFL Clubs collect, hold, use and disclose your personal information for purposes including, without limitation:

• to verify your identity;
• to improve AFL Online;
• 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 AFL and AFL Club’s 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 AFL and the AFL Clubs;
• to promote and market AFL events, products or services;
• to undertake research;
• to enable corporate partners and sponsors of the AFL, including AFL Clubs and the AFL’s digital rights partner Telstra, as well as their related bodies corporate, 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 AFL and AFL Clubs may also disclose personal information where it is otherwise permitted to do so by law.

Where you provide your personal information directly to one AFL Club, although it may be disclosed to the AFL, that personal information will not ordinarily be shared with a different AFL Club.  However, there may be some circumstances where this personal information is shared between AFL Clubs.  For example, if in a transaction you purchase merchandise relating to two AFL Clubs, that transaction may be disclosed to both AFL Clubs.

You consent to the AFL and AFL Clubs using your personal information for sending you information, including promotional material, about the AFL or AFL Clubs, or the AFL or AFL Clubs' 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 non-personal information, such as the number of users who visited AFL Online 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 AFL and AFL Clubs do not otherwise disclose personal information without your permission, unless the disclosure is:

• in accordance with this Privacy Policy or any agreement you enter into with us; or
• required or authorised by law, including without limitation the Australian Privacy Principles under the Privacy Act 1988 (Cth).

9    Accessing AFL Online

“AFL Online” refers to the AFL website with its top-level domain located at http://www.afl.com.au/, all related sub-domains and any other AFL website (including any AFL Club website) which provides an AFL and AFL Club product, AFL and AFL Club service or AFL-related product or service including related mobile applications. You need not disclose your identity to the AFL or AFL Club in order to visit AFL Online, except where personal information is voluntarily supplied, however the AFL or AFL Club internet server may automatically record details about any computer used to access the website (such as the IP address, domain name and browser type), the date and time of access, and details of the information downloaded. This information is used for internal statistical purposes and to improve AFL Online.

Cookies

The AFL or AFL Clubs may use “cookies” on AFL Online. A cookie is a small text file that AFL Online may place on your computer. Usually, cookies are used as a means for our websites to remember your preferences and are thus designed to improve your experience of AFL Online. Cookies may collect and store personal information about you.

You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent.  Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences.

If you disable the use of cookies on your web browser or remove or reject specific cookies from our website or linked sites then you may not be able to gain access to all of the content and facilities on AFL Online.

Website  Analytics

When you visit and browse AFL Online, our website host and some third party service providers may collect information for statistical, reporting and maintenance purposes.

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

• the number of users visiting our website and the number of pages viewed;
• the date, time and duration of a visit;
• visiting patterns of individuals accessing AFL Online;
• the IP address of your computer; and
• the path taken through our website.

The AFL or AFL Clubs use website analytic services to help analyse how you use AFL Online (Website Analytics). Website Analytics generate statistical and other information about website use by means including but not limited to cookies which are stored on users' computers. The information generated is used to create reports about the use of AFL Online. Our third party providers of these services may store this information. The AFL or AFL Clubs will not (and will not allow any third party to) use Website Analytics to track or to collect any personally identifiable information of visitors to AFL Online. The AFL or AFL Clubs will not associate any data gathered from AFL Online with any personally identifying information from any source as part of the AFL's or AFL Clubs' use of Website Analytics.

The AFL and AFL Clubs treat personal information that may be obtained through cookies and any other information supplied to us (for example if you send us an email) in accordance with this Privacy Policy.

Links

AFL Online may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third party website and we 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. 

Children’s Privacy

If you are under 18, you should only use AFL Online with involvement of a parent or guardian. For their protection, we ask that anyone under 18 years of age does not attempt to register with AFL Online or otherwise provide us with any personal information without the consent of a parent or legal guardian.

10    Information Security

The AFL and AFL Clubs will take reasonable steps to protect all personal information within their direct control from misuse, interference, loss, unauthorised access, modification or disclosure. The AFL and AFL Clubs 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.

11      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 AFL and/or AFL Clubs will investigate and notify you and the Australian Information Commissioner as soon as practicable, in accordance with the Privacy Act 1988 (Cth).

12   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 using the contact details set out in this paragraph 12.

An individual may:

• request access to and seek the correction of their personal information held by the AFL and/or AFL Clubs at any time;
• make a complaint in relation to an alleged breach of privacy; or
• submit a query or concern about this Privacy Policy or the AFL or AFL Clubs' information handling processes,

by contacting the AFL by email at privacy.officer@afl.com.au or the relevant AFL Club’s Privacy Officer by email at the corresponding address below:

Alternatively, you may write to the AFL via AFL Privacy Officer, AFL House, 140 Harbour Esplanade, Docklands, Victoria 3008 or telephone on 03 9643 1999.

Access

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 set out in this paragraph 12. The AFL may charge an administration fee where access is provided. The AFL may refuse to provide access if permitted to do so by law.  The AFL aims to provide access to your personal information within 30 days of a valid request.

Complaints

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 AFL.

The AFL’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.

13    AFL Clubs

For the purpose of this policy, “AFL Clubs” means the following:

Adelaide Football Club Limited ACN 008 101 568;

Brisbane Bears – Fitzroy Football Club Limited t/a Brisbane Lions Australian Football Club ACN 054 263 473;

Essendon Football Club ACN 004 286 373;

Carlton Football Club Limited ACN 005 449 909;

Collingwood Football Club Limited ACN 006 211 196;

Fremantle Football Club Limited ACN 066 055 249;

Geelong Football Club Limited ACN 005 150 818;

GCFC Limited ACN 144 555 822;

Western Sydney Football Club Limited ACN 130 190 242;

Hawthorn Football Club Limited ACN 005 068 851;

Melbourne Football Club Limited ACN 005 686 902;

North Melbourne Football Club Limited ACN 006 468 962;

Port Adelaide Football Club Limited ACN 068 839 547;

Richmond Football Club Limited ACN 065 563 011;

St Kilda Saints Football Club Limited ACN 005 174 836;

Sydney Swans Limited ACN 063 349 708;

West Coast Eagles a division of Indian Pacific Ltd ACN 009 178 894; and

Footscray Football Club Limited t/a Western Bulldogs ACN 005 226 595.

14   Updates to Privacy Policy

We may vary this Privacy Policy from time to time, by posting an updated Privacy Policy accessible via the AFL and AFL Club websites.  This Privacy Policy was last updated in May 2018.