Gold Coast Titans recognizes 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 Rugby League 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, Gold Coast Titans.
2. How we share your information as part of the Rugby League Exchange
Gold Coast Titans is always seeking to better understand our player and fan preferences including by analysing your Personal Information to understand trends and interests. Gold Coast Titans has, in conjunction with the National Rugby League, other clubs, Queensland Rugby League, New South Wales Rugby League, Country League of NSW and selected third parties, established a data storage architecture and data sharing platform for processing Personal Information with this aim (Rugby League Exchange).
3. What types of personal information may we collect?
The types of Personal Information Gold Coast Titans 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, corporate hospitality, subscriptions and attendance history at Gold Coast Titans matches (whether you have used your membership to purchase tickets, or as a casual ticket purchaser – including corporate hospitality);
(c) purchasing preferences and financial details which we collect when you buy tickets, purchase merchandise and/or as part of competitions and promotions;
(d) join a sponsorship program;
(e) for any other club related activities or;
(f) return feedback forms
Gold Coast Titans will generally not collect Sensitive Information from you. However, where Gold Coast Titans 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, Gold Coast Titans will collect Personal Information directly from you (without limitation):
(a) when you order merchandise through our online store located at https://shop.titans.com.au/;
(b) the NRL, QRL, NSWRL and selected third parties (for instance, Ticketek and Ticketmaster);
(c) to register you for events, promotions or competitions
5. Why do we collect, use, hold and disclose your personal information?
Gold Coast Titans collects, uses, discloses or holds Personal Information that is reasonably necessary for Gold Coast Titans to perform one or more functions or activities as a club including (without limitation):
(a) organization, conduct and promotion of matches involving Gold Coast Titans (for instance, providing you information about upcoming ticket offers and deals for the next home matches);
(b) promotion and sale of Gold Coast Titans merchandise;
(c) direct marketing of Gold Coast Titans products or services;
(d) to establish and maintain your membership of the Club, including providing you with newsletters, magazines, renewal notices and other information necessary to inform you of the Club’s activities;
(e) where appropriate, to establish and maintain a sponsorship relationship between you and the Club and to facilitate effective communication channels;
(f) to provide the products, services or information you have requested from the Club;
(g) to answer your inquiries;
(h) to register you for events, promotions or competitions;
(i) in accordance with the membership and partnership charters of the Club;
(j) to assist us to make the Club's facilities, services and products more valuable to our members and stakeholders and;
(k) for direct marketing of products or services and to keep you informed of new developments we believe may be of interest to you.
We use, disclose or hold your Personal Information for the primary purpose for which it was collected, a related secondary purpose, or as otherwise required in accordance with applicable privacy laws (including the Privacy Act and GDPR) (for instance, we may be required to disclose your Personal Information to a law enforcement agency).
6. Who do we disclose your personal information to?
Gold Coast Titans 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, memberships, hospitality or other event ticketing you order;
(c) Law enforcement and emergency services agencies: we may disclose your Personal Information where required or authorized 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) Gold Coast Titans 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.
(e) By providing your personal information you consent to the Club’s confidential disclosure to related parties for this purpose. You may decline any marketing communications by advising the Club of your wishes by the means outlined below;
i. to third parties where we have established partnership relationships and we believe that those organisations will provide valuable products and services to you. Such third parties will be required to keep your information confidential and to use it only to communicate the products and services to you. You may decline any third party communications by advising the Club of your wishes by the means outlined below; and
ii. to different parts of the Club to improve our customer service in general.
7. Transborder data flows
(a) Subject to clauses 7(b) and 7(c), the Gold Coast Titans will not transfer your Personal Information to an overseas recipient unless it has first taken steps reasonable in the circumstances to ensure that the Personal Information that it transfers will not be held, used or disclosed by the recipient of the information inconsistently with, or otherwise in breach of, applicable privacy laws (including the Privacy Act and GDPR). For example, the Gold Coast Titans may adopt appropriate contractual clauses with overseas recipients that ensure their compliance with applicable privacy laws (including the Privacy Act and GDPR).
(b) We may disclose your Personal Information to overseas recipients for things such as processing membership and hosting services, most likely in China, the United States and New Zealand, although countries where such recipients are located may vary.
(c) The Gold Coast Titans may transfer Personal Information about you to someone who is in a foreign country if:
i. the Gold Coast Titans reasonably believes that the recipient is subject to a law or binding scheme that has the effect of protecting the information in a way that is, overall, substantially similar to applicable privacy laws (including the Privacy Act and GDPR) and there are mechanisms available to you to enforce that protection or scheme; and
ii. you expressly consent to the transfer after the Gold Coast Titans has informed you that the applicable privacy laws (including the Privacy Act and GDPR) will no longer apply if you provide your express consent.
8. How is your personal information secured?
We understand you have entrusted us with the protection of your Personal Information. As such, we 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.
9. Access to and correction of personal information
You can access or correct your Personal Information through:
(a) your NRL Account profile; or
(b) contacting our Privacy Officer at the 'Inquiries Procedure' set out below.
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 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.
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).
10. 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 Gold Coast Titans, 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).
11. Inquires procedure
Gold Coast Titans Privacy Officer
Gold Coast Titans, PO Box 8041, GCMC, QLD,9726
(07) 5656 5650
At all times, privacy inquiries and complaints will be treated seriously, dealt with promptly and confidentially.