21-29 October 2017 sydney-polo-club
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XI FIP WORLD POLO CHAMPIONSHIP – PRIVACY POLICY 

This Privacy Policy covers the XI FIP World Polo Championship 2017, administered by World Cup Polo Pty Ltd (WCP). The WCP recognises that privacy is important and that an individual has the right to control his or her Personal Information. The WCP is committed to protecting the privacy of individuals and their Personal Information which the WCP collects during the course of administering the XI FIP World Polo Championship.

This Privacy Policy is based on the Australian Privacy Principles in Schedule 1 to the Privacy Act and sets out the way the WCP handles the Personal Information it collects, uses, discloses and stores on:

(a) XI FIP World Polo Championship participants, including Players and Officials (together, Participants);

(b) persons who register for any WCP sanctioned accreditation or licensing program;

(c) persons who purchase or receive information about tickets to Matches;

(d) persons who subscribe and/or register to any XI FIP World Polo Championship program, newsletter or promotional offer; or

(e) persons who request services from the WCP or more information about the XI FIP World Polo Championship Competitions or Matches (you, your).

1. ANONYMITY AND PSEUDONYMITY

Wherever it is lawful and practicable, you will have the option of not identifying yourself, or of using a pseudonym, when entering transactions, or otherwise dealing with, the WCP in relation to a particular matter.

2. COLLECTION

2.1 The WCP only collects Personal Information about you by lawful and fair means and as is reasonably necessary for one or more of the WCP’s functions or activities in administering the XI FIP World Polo Championship, including for the following primary purposes:

(a) organisation, conduct and promotion of Competitions and Matches (including for the purpose of providing information and making ticket offers to you);

(b) direct communication with you by XI FIP World Polo Championship Administrators;

(c) disclosure to XI FIP World Polo Championship Partners, unless you have indicated thatyou do not want to receive any communication from XI FIP World Polo Championship Partners;

(d) compliance with the WCP Rules, including the administration of the XI FIP World Polo Championship (if you are a Participant); and

(e) any use that is obvious at the time the Personal Information is collected.

2.2 Members of the WCP corporate group may also share Personal Information with each other for these primary purposes and otherwise in administering and developing the sport of polo.

2.3 The types of Personal Information the WCP may collect depends on the purposes for which it is collected but may include (without limitation):

(a) your name, gender, occupation, residential address, email address, telephone number and other contact details;

(b) purchasing preferences and financial details.

2.4 Where it is reasonable and practicable to do so, the WCP will only collect your Personal Information from you. If you are a Minor, the WCP may collect Personal Information about you from your parent or legal guardian.

2.5 The WCP will collect Personal Information from you mainly through relevant forms (whether in hard copy or online) approved by the WCP or the XI FIP World Polo Championship Administrators from time to time. However, during the ordinary course of its activities and functions, the WCP may also collect Personal Information that is given to it by a third party (such as a corporate partner of the WCP or XI FIP World Polo Championship Administrators, or information that is on public record), or which is otherwise unsolicited. This information from third parties forms part of your Personal Information.

2.6 Where the WCP receives unsolicited Personal Information about you, it will, within a reasonable period after receiving that information, determine whether or not it could have collected the information if the WCP had solicited the information itself. If the WCP determines that it could not have collected the Personal Information the WCP will, as soon as practicable but only if it is lawful and reasonable to do so, destroy the information or ensure that the information is de-identified.

2.7 If the WCP collects Personal Information about you from someone other than yourself (or your parent or legal guardian), the WCP will take reasonable steps to ensure you are made aware of the matters listed in clause 2.8 below. Generally, if appropriate, the WCP will tell you why it is collecting Personal Information and how it plans to use it, unless it is impracticable to do so or it is self-evident.

2.8 Before or at the time of collection of Personal Information (or if that is not practicable, as soon as practicable after), the WCP will take reasonable steps to ensure that you are aware of:

(a) how to contact the WCP in relation to this Privacy Policy;

(b) the fact that you can gain access to the information held on you and seek correction of such information;

(c) the purposes for which the information is collected;

(d) the organisations (or types of organisations) to which the WCP usually discloses information of that kind;

(e) any law that requires the information to be collected;

(f) the main consequences (if any) for you if all or part of the information is not provided;

(g) whether the WCP is likely to disclose the personal information to overseas recipients; and

(h) if the WCP is likely to disclose your Personal Information to overseas recipients — the countries in which such recipients are likely to be located if it is practicable to specify those countries in the notification or to otherwise make you aware of them.

Sensitive information

2.9 The WCP will not collect Sensitive Information about you unless:

(a) you have consented;

(b) it is specifically permitted to do so under the WCP Rules, including for health, medical and anti-doping testing purposes and investigation of disputes (whatever the nature of the dispute), or if it is reasonably necessary for one or more of the WCP’s functions or activities

in administering the XI FIP World Polo Championship;

(c) the collection is required or authorised by law;

(d) a Permitted General Situation exists; or

(e) otherwise permitted under the provisions of the Australian Privacy Principles relating to the collection of Sensitive Information.

3. USE AND DISCLOSURE

3.1 The WCP will not use or disclose Personal Information about you for a secondary purpose other than the primary purposes (the secondary purpose) identified in clause 2.1 above unless:

(a) you have consented to the use or disclosure;

(b) both of the following apply:

(i) the secondary purpose is related to the primary purpose of collection and, if the Personal Information is Sensitive Information, directly related to the primary purpose of collection; and

(ii) you would reasonably expect the WCP to use or disclose the information for the secondary purpose;

(c) a Permitted General Situation exists.

Direct Marketing

3.2 The WCP may use or disclose your Personal Information to a XI FIP World Polo Championship Administrator for the secondary purpose of direct marketing communication, if:

(a) it collected the information from you;

(b) you would reasonably expect your Personal Information would be used or disclosed for direct marketing;

(c) the WCP has provided a simple means by which you can request not to receive direct marketing; and

(d) you have not made a request of the kind referred to in 3.2(c).

3.3 In other cases where you would not reasonably expect your Personal Information to be used for direct marketing, or the information has been collected from a third party, the WCP may use the information for the secondary purpose of direct marketing communication only if the following are satisfied:

(a) you have consented to the use or disclosure for direct marketing, or it is impracticable to seek your consent before that use;

(b) the WCP will not charge you for giving effect to a request by you not to receive direct marketing communication;

(c) You have not made a request to the WCP not to receive direct marketing communication;

 

(d) In each direct marketing communication, the WCP always prominently displays a simple notice or actionable option that you may express a wish not to receive any further direct marketing communication; and

(e) each written direct marketing communication by the WCP with you sets out the WCP’s contact details including business address, telephone and fax numbers, and email address.

3.4 The WCP may disclose your Personal Information to its service providers such as ticketing agents, mail houses or other similar third-party organisations for the purpose of implementing the primary purposes, including fulfilling ticket requests and communicating XI FIP World Polo Championship related offers. For example, the WCP uses third party credit card payment gateway services on its website. If you pay for tickets or services through the WCP’s website, the WCP will be required to provide certain financial details to the third party service provider to effect the transaction. The WCP requires these third party organisations to keep your contact details and Personal Information confidential and only use them for the designated purpose.

3.5 Subject to compliance with the Privacy Act and this Privacy Policy, the XI FIP World Polo Championship Administrators may also:

(a) disclose your Personal Information to their affiliates to enable them to administer the sport of polo in their area and provide related activities and services; and

(b) unless you inform the WCP otherwise, disclose your information to sponsors and partners to enable them to provide you with information, materials and promotional opportunities.

3.6 The WCP may, in its discretion, disclose your Personal Information where it is otherwise permitted or required to do so under the Australian Privacy Principles or at law.

4. DATA QUALITY AND SECURITY

4.1 The WCP will take reasonable steps to make sure that the Personal Information it collects, uses or discloses is accurate, complete and up-to-date.

4.2 The WCP will also take reasonable steps to protect the Personal Information it holds about you or that is within its direct control from misuse, interference and loss and from unauthorised access, modification or disclosure. However, the internet is an inherently risky environment and any information you send via digital means is sent at your own risk.

4.3 The WCP will take reasonable steps to destroy or permanently de-identify Personal Information if it is no longer needed for any purpose for which the information may be used or disclosed under clause 2, unless the WCP is required by or under an Australian law, or a Court order, to retain the information.

5. OPENNESS, ACCESS AND CORRECTION

5.1 At your request, the WCP will take reasonable steps to let you know, in general terms, what sort of Personal Information it holds, for what purposes, and how it collects, holds, uses and discloses that information.

5.2 The WCP will provide you, within a reasonable period after a request from you, with access to the Personal Information it holds on you, except to the extent that the WCP is not required to do so under Article 12.3 of the Australian Privacy Principles.

5.3 Before supplying any Personal Information to you, the WCP must be reasonably satisfied as to your identity (for example, by asking to see your passport or driver’s licence). The WCP is not under any obligation to provide Personal Information to you where the WCP is not required to do so under the Australian Privacy Principles or otherwise at law. 

5.4 If the WCP refuses to provide you with access to Personal information it holds on you in the manner requested by you or because one of the exceptions in Article 12.3 of the Australian Privacy Principles applies, the WCP will either:

(a) take such steps (if any) as are reasonable in the circumstances to give access to the information in a way that meets the needs of the WCP and you; or

(b) provide you with a written notice that sets out:

(i) the reasons for the refusal except to the extent that, having regard to the grounds for the refusal, it would be unreasonable to do so; and

(ii) the mechanisms available to complain about the refusal; and (iii) any other matter prescribed by the Privacy Act regulations.

5.5 If.

(a) the WCP is satisfied that, having regard to a purpose for which the Personal Information is held, the information is inaccurate, out-of-date, incomplete or irrelevant or misleading; or

(b) you request the WCP to correct your Personal Information, the WCP will take reasonable steps to correct the Personal Information to ensure that, having regard to the purpose for which it is held, it is accurate, up-to-date, complete, relevant and not misleading. The WCP will not charge you for making such a request or for correcting the information.

5.6 If the WCP refuses to correct the Personal Information at your request, the WCP will provide you with a written notice that sets out the same matters listed in 5.4(b).

6. NO LIABILITY

6.1 To the maximum extent permissible by law, the WCP expressly disclaims any liability for a breach of this Policy.

6.2 By providing the WCP with Personal Information, you acknowledge that any damage caused to you or any other individual by the disclosure of that information shall be limited to the amount recoverable under applicable legislation and otherwise not be recoverable from the WCP or any of its related bodies.

7. TRANSBORDER DATA FLOWS

7.1 The WCP will not transfer your Personal Information unless it has first taken steps reasonable in the circumstances to ensure that the information that it transfers will not be held, used or disclosed by the recipient of the information inconsistently with, or otherwise in breach of, the Australian Privacy Principles (for example, by adopting appropriate contractual clauses).

7.2 The WCP may transfer Personal Information about you to someone who is in a foreign country only if:

(a) the WCP 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 the Australian Privacy Principles and there are mechanisms available to you to enforce that protection or scheme;

(b) you consent to the transfer after the WCP has informed you that 7.1 will no longer apply if you provide your consent.

7.3 Clause 7.1 does not apply to the transfer of Personal Information in accordance with the WCP

Rules, including to facilitate the registration of a Player by an international polo association.

8. INQUIRIES PROCEDURE

8.1 All complaints and inquiries concerning your Personal Information, including in respect of alleged breaches of this Privacy Policy or the Australian Privacy Principles, will be directed to the WCP Privacy Officer (or a person who is delegated that function from time to time). This will ensure that all such matters will be dealt with:

(a) consistently across the WCP (rather than having a series of different approaches across the WCP); and

(b) in accordance with applicable law, including the Privacy Act.

8.2 At all times, privacy complaints will be treated seriously, dealt with promptly and confidentially, and will not affect your existing obligations or commercial arrangements with the WCP.

9. INTERPRETATION

9.1 Any capitalised terms or phrases used but not defined in this Policy have the meaning given to them in the Privacy Act.

9.2 Any reference to the WCP in this Privacy Policy is a reference to all those entities individually and collectively unless the context requires otherwise.

9.3 This Privacy Policy is designed to safeguard Personal Information and to comply with the law and so may need to be varied or changed by the WCP from time to time.

9.4 Headings are for ease of reference only and do not affect the meaning of the parts of this Policy.

9.5 The singular includes the plural and vice versa and words importing a gender include other genders.

9.6 Other grammatical forms of defined words or expressions have corresponding meanings.

9.7 A reference to a Rule or sub-Rule or to a Schedule or Guideline is a reference to a Rule or sub Rule of these Rules or to a Schedule or Guideline to these Rules respectively.

9.8 A reference to a document or agreement, including these Rules, includes a reference to that document or agreement as amended, novated, altered or replaced from time to time.

10. DEFINITIONS

In this Policy:

Competition means the XI FIP Polo World Championship carried out under the auspices of the WCP.

Country means the Polo team of any Country registered with the WCP for the purposes of competing in the XI

FIP Polo World Championship.

Country Official means any person involved with the administration, management or organisation of a Club (whether paid or unpaid), including employees, contractors, consultants, volunteers, officers and directors and representatives.

Health Information means:

(a) information or an opinion about:

(i) your health or a disability (at any point in time);

(ii) your expressed wishes about the future provision of health services to you; or

(iii) a health service provided, or to be provided, to you, that is also Personal Information;

(b) other Personal Information collected to provide, or in providing, a health service; or

(c) other Personal Information about you collected in connection with the donation, or intended donation, by you of your body parts, organs or body substances.

Game means a game of polo and includes any match staged, participated in, sanctioned by, or played under the auspices of the WCP (including any match held as part of a Competition).

Game Official means any person in charge of safety or any other person appointed by the WCP, the Federation of International Polo (FIP) or a Competition Administrator to assume responsibility in connection with a Match including:

(a) The umpire for a Game;

(b) The goal judges;

(c) The third man;

(d) The timekeeper for a Game

(e) The scorer for a Game

(f) The ground manager for any ground where a Game is played;

(g) Any person who assists in the preparation for, or the conduct of, a Game (including the organisation, management, control or administration of the Game as an event), and whether any such persons is:

(i) Engaged by the WCP or a Country or otherwise;

(ii) An employee, contractor, agent, volunteer or otherwise; or

(iii) Paid or unpaid.

Official means:

(a) a Country Official, Match Official or Team Official;

(b) an employee, consultant, officer or director of the WCP, or a Competition Administrator; or

(c) a member of a council, committee, panel or body constituted by the WCP, or a Competition Administrator.

Permitted General Situation exists if, in relation to the collection, use or disclosure by the WCP of Personal

Information about you:

(a) it is unreasonable or impracticable to obtain your consent to the collection, use or disclosure;

(b) the WCP reasonably believes that the collection, use or disclosure is necessary to lessen or prevent a serious threat to the life, health or safety of any individual, or to public health or safety;

(c) the WCP has reason to suspect that unlawful activity, or misconduct of a serious nature, that relates to the WCP functions or activities has been, is being or may be engaged in (including such things as investigations into breaches of the WCP Rules);

(d) the WCP reasonably believes that the collection, use or disclosure is necessary in order for the entity to take appropriate action in relation to the matter;

(e) the collection, use or disclosure is reasonably necessary for the establishment, exercise or defence of a legal or equitable claim.

Personal Information means information or an opinion (including forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.

Player means any person who is, from time to time, registered to a Country for the purposes of competing in the XI FIP World Polo Championship.

Privacy Act means the Privacy Act 1988 (Cth).

WCP Privacy Officer means the person appointed by the WCP from time to time to deal with complaints and inquiries under this Policy.

WCP Rules means its constitution, rules, regulations, policies and procedures and any other ancillary document that governs the WCP in administering the XI FIP World Polo Championship, as promulgated and amended from time to time.

XI FIP World Polo Championship Administrators mean the WCP, the Federation of International Polo (FIP), (ARLC), a Competition Administrator with which the Participant has a direct relationship, including for the purposes participation in the XI FIP World Polo Championship.

XI FIP World Polo Championship Partners means any entity that has a commercial agreement or arrangement with the WCP, or the Federation of International Polo (as the case may be) and which you may also have a direct relationship with (including by participation in a Competition).

Sensitive Information means:

(a) information or an opinion about your:

(i) racial or ethnic origin;

(ii) political opinions;

(iii) membership of a political association;

(iv) religious beliefs or affiliations;

(v) philosophical beliefs;

(vi) membership of a professional or trade association;

(vii) membership of a trade union;

 

(viii) sexual preferences or practices; or

(ix) criminal record, that is also Personal Information; or

(b) Health Information.

Team Official means any personnel involved with the management, preparation or participation of a Country’s team (whether paid or unpaid), including the coaches, managers, medical staff (including team or match day doctor), physiotherapists, gear persons and other support staff.