Dolphins recognises the importance of your privacy and your right to control your Personal Information and is committed to complying with applicable privacy laws (including the Privacy Act and 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 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, The Dolphins.
2. How we share your information as part of the Rugby League Exchange
The Dolphins is always seeking to better understand our player and fan preferences including by analysing your Personal Information to understand trends and interests. Dolphins has, in conjunction with the NRL, other Clubs, Queensland Rugby League (QRL), New South Wales Rugby League (NSWRL), Country League of New South Wales and selected third parties, established a data storage architecture for processing Personal Information with this aim (Rugby League Exchange).
The NRL will be responsible for the maintenance and administration of the Rugby League Exchange.
3. What types of personal information may we collect?
The types of Personal Information The Dolphins may collect depends on the purposes for which such information is collected but may include (without limitation):
(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 The Dolphins matches (whether you have used your membership to purchase tickets, or as a casual ticket purchaser);
(c) purchasing preferences and financial details which we collect when you buy tickets, purchase merchandise and/or as part of competitions and promotions; and
The Dolphins will generally not collect Sensitive Information from you. However, where The Dolphins seeks to collect Sensitive Information from you, it will do so in accordance with applicable privacy laws (including the Privacy Act and GDPR), for instance by obtaining your express consent for such a collection.
4. How do we collect your personal information?
Where it is reasonable and practicable to do so, The Dolphins will collect Personal Information directly from you as follows (without limitation):
(a) when you order merchandise through our online store located at https://shop.classicsports.com.au
(b) when you purchase and manage membership through our online store located at https://dolphinsnrl.com.au/.
In addition to collecting Personal Information directly from you, we may also collect Personal Information from:
(a) the NRL, Queensland Rugby League, New South Wales Rugby League and selected third parties (for instance, Ticketek and Ticketmaster).
5. Why do we collect, use, hold and disclose your personal information?
The Dolphins generally only collects, uses, discloses or holds Personal Information that is reasonably necessary for The Dolphins to perform one or more functions or activities as a club including (without limitation):
(a) organisation, conduct and promotion of matches involving The Dolphins (for instance, providing you information about upcoming ticket offers and deals for the next home matches);
(b) promotion and sale of The Dolphins merchandise;
(c) direct marketing of The Dolphins products or services; and
(d) direct marketing of The Dolphins corporate partners products and services.
We only use, disclose or hold 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 (e.g. where your Personal Information is requested by a law enforcement agency).
6. Who do we disclose your personal information to?
The Dolphins may provide your Personal Information to third parties as part of our functions and activities including (without limitation):
(a) Delivery, courier and postal organizations: we may disclose your Personal Information to delivery, courier and postal organizations in order to deliver merchandise you order;
(c) 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 ensure that those to whom we disclose your Personal Information have the legal right to receive it;
(d) 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.
7. Data quality and security
We understand you have entrusted us with the protection of your Personal Information. As such, we will take reasonable steps, with the assistance of the NRL, to protect your Personal Information from misuse, loss, unauthorized access, modification or disclosure. This includes engaging reputable third party service providers and ensuring that we engage (where possible and practical to do so) in best practice security systems and procedures.
8. Access to and correction of personal information
You can access, review and manage your Personal Information through:
(a) your NRL Account (using your login credentials);
(b) communications preferences via links in emails and other communications we send to you from time to time; or
(c) by contacting The Dolphins Privacy Officer via [email protected]
Note: Please ensure that any written request for access or correction addressed to our Privacy Officer provides adequate detail that enables us to identify you as well as the specific Personal Information you want to access or have corrected. Where your request will incur costs, we may charge you a 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 your request being actioned.
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 The Dolphins 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).
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 Dolphins, with the assistance of the NRL, will investigate and notify you and where applicable the relevant supervisory authority (e.g. the Australian Information Commissioner) within 72 hours of becoming aware of the loss, or unauthorised access or disclosure, in accordance with applicable privacy laws (including the Privacy Act and GDPR).
10. Inquiries procedure
Email: [email protected]
At all times, privacy inquiries and complaints will be treated seriously, and dealt with promptly and confidentially.
12. Use of your image
The Dolphins may use your personal image captured by an employee and or contractor, broadcaster or another source (subject to copyright) if that image was captured during a club function or club related activity by photograph, video or otherwise.
Your image may be used in The Dolphins promotion and marketing material released through, but not limited to, the following official The Dolphins platforms:
- Social media channels;
- Official correspondence;
- Members materials;
- Advertising campaigns.
Where possible, The Dolphins will request the permission of any individuals clearly identified in a photograph or video and seek express consent for the use of their personal image.
However, if The Dolphins are unable to, or it is not possible to, request the permission of an individual for use of their image, it will proceed to use the image for any reasonable purpose consistent with our club functions and activities.
If your personal image has been used without express consent, you can request that the image be removed by contacting The Dolphins and lodging a formal request.