Privacy Policy

SOUTHPORT AUSTRALIAN RULES FOOTBALL CLUB PRIVACY POLICY – JULY 2025

Our Privacy Policy. Our Privacy Policy now includes additional information about the types of personal information we collect (including sensitive information), how we collect it, how we use it, how we hold it and to whom it is disclosed.

1. SUMMARY

Southport Australian Rules Football Club Ltd (ACN 010 452 936) trading as “Southport Sharks” understands that individual privacy is very important, and that each individual ought to have a right of control over their personal information. Southport Sharks are committed to acting with integrity at all times when dealing with personal information entrusted to our organisation, and to the protection of individuals’ privacy in accordance with the Privacy Act 1988 (Cth) (“Privacy Act”) and the Australian Privacy Principles (“APPs“).

Southport Sharks takes all reasonable steps to ensure that any personal information provided is protected from misuse, loss, unauthorised access, modification or disclosure, and is maintained by Southport Sharks in an accurate, complete and up to date manner, and in a secure environment.

This Privacy Policy applies to any interaction that you have with Southport Sharks, including but not limited to, interactions with Sharks Club, Gaming Room, Health & Fitness Centre, restaurants, accommodation (including at Mantra at Sharks) and any events hosted at Southport Sharks.

2. PERSONAL INFORMATION WE COLLECT AND HOLD

Personal Information under the Privacy Act includes information or an opinion about an individual who is identifiable or reasonably identifiable, whether the information is true or not and whether the information or opinion is recorded in material form or not.

The personal information we may collect and hold about you depends on the nature of the products and/or services we provide to you or that we receive from you. We only collect information that is reasonably necessary for our business functions and activities, or which we are required to collect by law.

Personal information we may collect from you includes, but is not limited to:

• your name and contact details such as postal address, email address, and telephone number;
• your date of birth;
• occupation;
• member ID or membership type;
• images of you, including images and biometric templates collected through facial recognition technology, and video and/or audio recordings collected through CCTV;
• personal information contained in identification documents that you provide to us or which we are legally authorised to collect including but not limited to your driver’s licence, passport, and proof of age card;
• gaming play history;
• financial details such as your transaction history and in some cases credit card and bank account details; and
• health information such as medical conditions that you have or your emergency contacts.

• • 2.1 SENSITIVE INFORMATION

Sensitive information is a subset of personal information and includes, but is not limited to, information about a person’s race, sexual orientation, disability, ethnic origin, political opinions, health, religious or philosophical beliefs, biometric information, biometric templates, membership of a professional or trade association or union, health information and criminal record.

We attempt to limit the collection of sensitive information to the maximum extent possible.

There are circumstances however, based on the nature of the products and/or services we provide to you or that we receive from you, where we may collect sensitive information about you. We only collect this information where it is reasonably necessary for our functions or activities and where we have obtained your consent, or otherwise where we are required to do so by law. Your consent may not be required where the collection is authorised or required by law or is necessary to prevent a serious threat to life, health or safety.

• 2.2 WHAT HAPPENS IF YOU DO NOT PROVIDE YOUR PERSONAL INFORMATION TO US

Where lawful and practical, you will have the option not to provide your personal information to us. However, if you do not provide us with your personal information, we may not be able to provide you with our goods and/or services. For example, if you do not provide us with a copy of your valid identification, we may not be able to grant you access to our clubhouse or other licenced venues.

3. HOW, WHEN AND WHY WE COLLECT, HOLD AND USE PERSONAL INFORMATION

We collect, hold and use personal information to support a range of functions, including processing membership applications, providing products and services, and meeting legislative and regulatory requirements.

A summary of when and how Southport Sharks collects and uses your personal information, and the purpose for which your personal information is collected and held is provided below.

• 3.1 WEBSITE ANALYTICS & COOKIES

When you visit our website, certain information is automatically collected, including your IP address, browser type, operating system, referring page, pages visited, time spent, access times, and search behaviour. This data helps us analyse usage patterns, improve site performance, and enhance your experience. It’s reviewed in aggregate and isn’t used to personally identify you.

We also use cookies—small text files stored on your device—to remember preferences, customise content, and improve functionality. Cookies may contain a unique identifier, but do not personally identify you.

You can disable cookies in your browser settings, though this may affect site functionality. We do not combine this data with personal information unless you’ve provided it directly.

• 3.2 EXCLUDED PERSONS

We may collect and use your personal information, including your facial biometric information, when you enter our premises to determine whether you are subject to an exclusion order or are otherwise prohibited from entering. We may also collect your name, image, and/or facial biometric information from law enforcement bodies for this purpose. If a person is found to be excluded, we may take necessary steps to refuse or remove access in accordance with legal requirements and our internal procedures.

When we receive personal information (including sensitive information) from a third party about persons who are excluded (for example, when we receive a remote exclusion), we may use that information to issue that person with an exclusion order and to deny that person access to our premises.

We may also use information received from a third party about an excluded person to create a biometric template of the excluded individual, which will be input into our facial recognition watchlist database. This will mean that the excluded individual may be flagged by our facial recognition system as an excluded person if they attempt to visit our premises, in which case, we may take reasonable steps to remove or deny access to that person.

• 3.3 MARKETING, FILMING AND PHOTOGRAPHY

Southport Sharks events may be filmed and photographed. By entering the venue (or by attending an event) you voluntarily agree to your image being used or published by Southport Sharks and associated brands for promotional purpose and you release Southport Sharks from any liability regarding any such publication or use of your image.

Please inform a staff member or the photographer if you do not wish to be photographed.

• 3.4 FACIAL RECOGNITION TECHNOLOGY (FRT)

Southport Sharks uses facial recognition technology (“FRT”) throughout the premises including at the entry to the Sharks Club and gaming area, Mantra at Sharks, and Health & Fitness Centre.

When you visit our premises, we may collect and use your photograph and biometric information through our FRT system.

We use FRT for the purposes of:

• assisting our personnel to identify and deny individuals who are suspended, banned or excluded from our premises in accordance with our legal obligations;
• to provide a safer gambling environment; and
• to assist our personnel in managing security and safety at our premises.

When you visit out premises, you are consenting to the collection and use of your image, biometric information, and other personal (and sensitive information) via our FRT system. If you do not consent to the collection of your biometric information, you may not be permitted to enter our gaming area or premises. We will take all precautions to prevent the misuse, interference, loss, unauthorised access, modification, and disclosure where FRT sensitive information is collected.

If you are excluded from our premises, including via remote exclusion, we may use your image and/or biometric information to create a biometric template to be held in our FRT watchlist database. This will mean that excluded individuals may be flagged by our FRT system if they attempt to visit our premises during the term of their exclusion. We will only retain biometric information and templates in our database for the minimum time necessary. Once an individual’s exclusion ends, that individual’s biometric information will be securely removed from our FRT watchlist database.

• 3.5 ID SCANNERS

We may require you to scan your ID before you enter our Clubhouse or other licenced venues at Southport Sharks for the purposes of maintaining security at the premises, supporting responsible gaming and complying with our legal obligations. When scanning your ID, we collect your personal information including your name, your date of birth, and the photograph appearing on your photo ID.

Your personal information will be stored in a way that protects it from unauthorised access, modification and disclosure.

4. DISCLOSING PERSONAL INFORMATION

Your personal information may be disclosed to third party providers to assist us in our business functions and activities. We may use third parties to:

• store your personal information;
• manage or administer the products and services we offer;
• process payment information and/or direct debits in relation to your membership;
• conduct transaction monitoring;
• conduct customer due diligence and customer screening for compliance with anti-money laundering and counter-terrorism financing laws; and
• send marketing campaigns to you in relation to our services and/or products.

We may disclose personal information to law enforcement authorities, regulatory bodies, or other government agencies where required or authorised by law, including to comply with legislative or regulatory obligations.

Where we disclose your personal information to an external party, we take all reasonable steps to ensure that they handle your personal information in accordance with the APPs.

• 4.1 GAMING SERVICE PARTICIPATION

We are required under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) to collect your personal information when processing large gaming payouts of $5,000 or more. This includes your full name, residential address, and date of birth. We may also require further identification details, bank account details, employment details, and other relevant information necessary to verify your identity and comply with legal and regulatory obligations.

This information is used solely for compliance, record-keeping, and reporting purposes, and may be disclosed to regulatory authorities as required by law. We take all reasonable steps to ensure that your personal information is handled securely and in accordance with applicable privacy legislation.

• 4.2 TRANSFER OF INFORMATION OVERSEAS

Southport Sharks is not likely to disclose personal information to overseas recipients. However, some of our service providers may be located overseas or may store information (including your personal information) that we provide them overseas. Where your personal information is disclosed to an overseas recipient, we will use reasonable efforts to ensure that it is only held and processed in accordance with the Privacy Act.

5. ACCESS, CORRECTION AND DELETION OF PERSONAL INFORMATION

You have a right to access and/or correct your personal information held by us. You may, at any time, lodge a request for to access or correct your personal information, and we will respond to that request within a reasonable period after it is made. We will not levy a charge for the correction of such information.

Should we for any reason refuse your request for correction of personal information, you will be advised in writing of the grounds for refusal and notified of available complaint mechanisms.

6. COMPLAINTS RESOLUTION

We are committed to providing a fair and responsive system for handling and resolving complaints. You have the right to complain, and to have your complaint handled efficiently. We believe that in receiving complaints, we are provided with a valuable opportunity to improve the services we deliver and to maintain confidence in us and our services.

If at any time you wish to lodge a privacy complaint in respect of the handling, use or disclosure of personal information by us, or make a request for access to or correction of your personal information, you can do so by submitting that your complaint endorsed “Privacy”, via email info@southportsharks.com.au in writing, and addressing it to:

Southport Sharks

P.O. Box 1610

Southport QLD 4215.

We endeavour to respond to, and/or action, all complaints within 28 days of lodgement.

If you are not satisfied with how we have dealt with your complaint, you may refer the complaint to the Office of the Australian Information Commissioner whose details are below:

The Information Commissioner

GPO Box 5288

Sydney NSW 2001

1300 363 992

www.oaic.gov.au.