1 October 2018
- The Pathway to Professional Football Academy registered as the P2P Football Academy Pty Ltd (ACN 628 766 898) is a football academy based in the Australian Capital Territory. The P2P Football Academy Pty Ltd (referred to in this policy as we, us and the P2P FA) is committed to managing your information in a secure and responsible manner and in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles introduced by the Privacy Amendment (Enhancing Privacy Protection) Act 2012 (Cth). This Policy sets out the way in which the P2P FA uses and discloses personal information and explains your rights and how to contact us.
- YOUR PERSONAL INFORMATION
2.1 In the course of its operations, the P2P FA may collect, use and disclose the personal information of partners, coaches, administrators, participants and other individuals for the purpose of providing football development services in the Australian Capital Territory and as further described in the remainder of this Policy. In each case, the precise nature of the collection, use and disclosure of personal information by the P2P FA depends on the services you request and receive from, and your interaction with, the P2P FA.
2.2 The types of personal information held by the P2P FA may include your name, address, phone numbers, email address, date of birth, gender, occupation, educational institution, educational qualifications, coaching qualifications, employment history, driver’s licence, birth certificate, visa information and social media details. Depending on the services you receive from the P2P FA, the P2P FA may also collect and hold details about your participation history, membership history and credit card information, and details of the items ordered or purchased from the P2P FA.
2.3 In certain circumstances, the P2P FA may collect information about your health or other sensitive information about you (for example, information about your racial or ethnic origin or information about your physical health). The P2P FA may use health information about you to ensure that football programs in which you participate are run safely and in accordance with any special health needs you may have and for insurance purposes. The P2P FA may also use health information as required by the FFA Statutes, including medical and anti-doping testing and investigations.
2.4 In addition, the P2P FA may use health information and other sensitive information which has been de-identified to carry out research, to prepare submissions to government or a government body or to plan events and activities. De-identified information is information which has been aggregated or otherwise de-identified so that it cannot be used to identify you or any other individual.
2.5 When you provide the P2P FA with personal information, this Policy will apply to the manner in which the information is collected, used, disclosed and stored by the P2P FA. If you choose not to provide certain personal information, the P2P FA may not be able to communicate with you. It may also affect the P2P FA’s ability to provide you with the products and services you require. For example, you may not be able to participate in some of the activities on the P2P FA network of websites if you do not provide certain personal information.
- COLLECTING YOUR PERSONAL INFORMATION
3.1 Personal information about you may be collected by the P2P FA from you or from a third party. The P2P FA uses forms, online portals and other electronic or paper correspondence to collect this information.
3.2 For example, the P2P FA may collect personal information from you:
(a) via the P2P FA Sites;
(b) when you provide it to the P2P FA by filling in forms approved by the P2P FA from time to time;
(c) when you contact the P2P FA;
(d) when you engage with the P2P FA via social media;
(e) when you subscribe to receive any P2P FA related newsletters or other information;
(f) when you enter a competition conducted by, or on behalf of, the P2P FA; or
(g) when you lodge a claim or complaint with the P2P FA.
3.3 The P2P FA may also collect personal information about you from third parties, including:
(a) P2P FA corporate partners, licensees, sponsors, suppliers and broadcasters (P2P FA Partners);
(b) your representatives or agents;
(c) the S2S Customer Relationship Management System; and
(d) organisations identified under section 5 (Disclosing Your Personal Information) below.
- USING YOUR PERSONAL INFORMATION
4.1 The P2P FA may use the personal information collected about you as follows:
(a) to verify your identity;
(b) to ensure compliance with the P2P FA’s rules, regulations, policies, procedures and other governing documents;
(c) to organise, conduct and promote football training, matches, tournaments, programs and other events (including for the purpose of distributing newsletters, providing information and making ticket offers);
(d) to process the registration of individuals to participate in football training, tournaments, matches, programs and other events, as a player, coach or otherwise;
(e) to develop programs, activities, events, products, services and merchandise relating to football and the P2P FA;
(f) to provide you with information about our products and services, including information about tickets, merchandise and special offers, or which we reasonably believe may be of interest to you, some of which may be provided by, or in conjunction with P2P FA Partners (both commercial and not-for-profit);
(g) to investigate and take action in connection with any disciplinary, dispute or grievance processes mandated under P2P FA’s rules, regulations, policies, procedures or other governing documents;
(h) to satisfy our obligations and to comply with applicable statutes, regulations and policies as a supporter in football development of the national governing body, FFA, and, ultimately, the regional governing body, the Asian Football Confederation (AFC) and the international governing body, Federation Internationale de Football Association (FIFA);
(i) to satisfy our obligations under the Associations Incorporation Act 1991 and otherwise at law;
(j) to carry out market research and surveys;
(k) to maintain participation and service/benefit records, data and statistics, including for archive and historical purposes;
(l) to contact you if you win a prize in a competition you have entered and to send the prize to you; and
(m) any use that is reasonably apparent at the time the information is collected.
4.2 The P2P FA may also use the personal information collected about you:
(a) to administer, manage and improve the P2P FA Sites (including S2S) and to provide you with access to those P2P FA Sites;
(b) to ensure that content from the P2P FA Sites is presented in the most effective manner for you and for your computer;
(c) to allow you to participate in interactive features of an P2P FA Site, when you choose to do so;
(d) for direct marketing communications from the P2P FA in relation to products, services, tickets, merchandise and special offers made available by the P2P FA or P2P FA Partners. You will be able to opt-out of direct marketing at any time, if you so choose, by utilising the unsubscribe feature on electronic marketing communications, or in the case of other direct marketing materials by contacting the P2P FA Privacy Officer, in accordance with section 10 below;
(e) where permitted by the P2P FA, to enable P2P FA Partners, who have a relationship with the P2P FA, to market and promote their products and services to you. You will be able to opt-out of direct marketing at any time if you so choose, by utilising the unsubscribe feature on electronic marketing communications, or in the case of other direct marketing materials by contacting the P2P FA Privacy Officer in accordance with section 10 below; and
(f) any use that is reasonably apparent at the time the information is collected.
- DISCLOSING YOUR PERSONAL INFORMATION
5.1 The P2P FA may also share your personal information with third parties in relation to the operation of the P2P FA’s business including:
(a) The P2P FA’s related bodies corporate;
(b) Any body established by the P2P FA or FFA to deal with disciplinary, dispute or grievance proceedings;
(c) third party service providers, such as ticketing agents, venue operators, event organisers, IT providers and social media websites;
(d) health providers or professionals;
(e) P2P FA insurers;
(f) P2P FA professional advisors, including our accountants, auditors and lawyers;
(g) as required or authorised by law or where we have a public duty to do so, including for purposes of safety and security; and
(h) where you have consented to your personal information being disclosed to others;
- P2P FA SITES, COOKIES AND OTHER TECHNOLOGIES
6.1 If you visit an P2P FA Site, P2P FA may record information such as your Internet Protocol (IP) address, browser type, Internet Service Provider (ISP), referring/exit pages, operating system, the P2P FA Site pages accessed and any information downloaded. This information is used for statistical, reporting and website administration and maintenance purposes, including identifying usage trends, to track users’ movements around the P2P FA Sites and to gather demographic information about P2P FA users collectively.
6.2 Like many other websites, the P2P FA Sites may use ‘cookies’ from time to time. A cookie is a piece of information that allows us to identify and interact more effectively with your device. The cookie helps the P2P FA to maintain the continuity of your browsing session and remember your details and preferences when you return. You can configure your web browser software to reject cookies however some parts of the P2P FA Sites may not have full functionality in that case.
The services we may use from time to time include Google Analytics, Nielsen, AdTech, Omniture and Facebook. You can find more details in the privacy policies for those services, including information on how to opt-out of certain conduct.
6.4 When we send you emails or other electronic messages, the P2P FA may record where you open the message and click on particular links. This helps us to better understand what information is of interest to you.
- PROTECTING YOUR PERSONAL INFORMATION
7.1 The P2P FA takes the security of personal information seriously. The P2P FA has appointed its Director of Administration to oversee the P2P FA’s management of personal information in accordance with this Policy and the Privacy Act 1988 (Cth).
7.2 The P2P FA takes reasonable steps to protect the security and privacy of your personal information. The P2P FA has directed its staff that personal information must be dealt with in accordance with this Policy and kept secure from unauthorised access or disclosure.
7.3 If you are considering sending us any other personal information through an P2P FA Site or other electronic means, please be aware that the information may be insecure in transit, particularly where no encryption is used (e.g. email, standard HTTP). Any transmission is therefore at your own risk. Once the P2P FA has received your personal information, the P2P FA will take reasonable steps to protect all personal information within its direct control from unauthorised access.
7.4 Where the P2P FA has given you (or where you have chosen) a password which enables you to access certain parts of an P2P FA Site, you are responsible for keeping this password confidential. The P2P FA suggests that you do not share the password with anyone and to change it regularly.
- DISCLOSING YOUR PERSONAL INFORMATION ABROAD
8.1 The P2P FA will store personal information on data servers that are controlled by the P2P FA and are located within the geographical borders of Australia where reasonably possible. However, in some circumstances the personal information that the P2P FA collects may be disclosed to certain recipients, and stored at certain destinations, located outside Australia from time to time.
For example, your personal information may be transferred outside of Australia if any of the P2P FA’s servers from time to time are located outside Australia, or if one of the P2P FA’s service providers or suppliers is located in a country outside Australia. As at the date of this Policy, the P2P FA utilises service providers and suppliers in the USA. The P2P FA may also disclose your personal information outside of Australia in accordance with section 5 (Disclosing Your Personal Information), including to facilitate the registration of a player by a foreign governing body.
8.2 In all cases, by providing your personal information to us or using our services, you consent to the disclosure of your personal information outside Australia as set out in this Policy, and acknowledge that the P2P FA is not required to ensure that overseas recipients handle your personal information in compliance with Australian privacy law. However, where practicable in the circumstances, the P2P FA will take reasonable steps to ensure that overseas recipients only use and disclose such personal information in a manner which is consistent with this Policy. You may have rights to enforce such parties’ compliance with applicable data protection laws, but it is possible that you will not have recourse against those parties under the Privacy Act 1988 (Cth) in relation to how those parties treat your personal information.
- ACCESS TO AND CORRECTION OF YOUR PERSONAL INFORMATION
9.1 The P2P FA takes all reasonable precautions to ensure the personal information that the P2P FA collects, uses and discloses is accurate, complete and up-to-date. However, the accuracy of that information depends on the information you provide. The P2P FA recommends that you let us know if there are any errors in your personal information and keep us up-to-date with changes to your personal information such as your contact details.
9.2 You have the right to access the personal information we hold about you, and can request the correction of your personal data if it is inaccurate, incomplete or out of date. If you would like to do so, please contact the P2P FA Director of Administration to submit an enquiry to access or update the personal information the P2P FA holds about you.
- OPTING OUT OF DIRECT MARKETING COMMUNICATIONS
You can opt out of receiving further messages or communications from the P2P FA at any time by following the unsubscribe instructions in the message sent to you. If you wish to unsubscribe from communications that the P2P FA sends to you, you can also contact the P2P FA Director of Administration at football@P2Pfa.com.au.
- CHANGES TO THIS POLICY
We may modify, alter or otherwise update this Policy at any time by publishing the new version of the Policy on the P2P FA Sites. We will indicate any changes by updating the date of this Policy. If you have any questions about this Policy, please contact the P2P FA Director of Administration at football@P2Pfa.com.au.
- CONTACTING THE P2P FA PRIVACY OFFICER AND MAKING COMPLAINTS
12.1 You may contact the P2P FA Director of Administration by contacting him or her via email at football@P2Pfa.com.au.
12.2 You may complain about our collection, use or disclosure of your personal information by contacting the P2P FA Director of Administration using the contact details above with your full name and contact details, together with a detailed description of the complaint.
We will respond to your complaint within a reasonable period of time and inform you of the next steps we will take in dealing with your complaint. If we are unable to resolve your complaint, we will inform you of the steps available to you in those circumstances.