Privacy
Policy

Kardinia Park Stadium Trust is committed to protecting the privacy of your Personal Information (as defined below). We manage your Personal Information in an open and transparent way, and we will only use your Personal Information when it is necessary or appropriate for us to undertake our services or perform other reasonable business functions and activities.

This Privacy Policy provides you with details of what Personal Information may be held about you by us, how you can access this information and the purposes for which that personal information is collected, held, used and disclosed.

By electing to access our Trust Areas (as defined below), by using our website, products or services and/or by providing your Personal Information or data to us, you will be deemed to consent to the terms and conditions in this Privacy Policy and to us using your Personal Information in a manner consistent with this Privacy Policy, unless you tell us to the contrary by contacting us. If you have any queries, please contact us using the details below.

“We“, “us“, “our” and the “Trust” refers to (and this Privacy Policy applies to) Kardinia Park Stadium Trust (ABN 31 318 314 795). “You” or ““your” refers to an individual whose Personal Information is collected, held, used or disclosed by us from time to time.
If you have any questions regarding this Privacy Policy, please contact us as follows:

The Privacy Officer
Kardinia Park Stadium Trust
Level 1, Brownlow Stand, Kardinia Park Stadium, South Geelong VIC 3220, Australia
Email: enquiries@kardiniapark.vic.gov.au

This Privacy Policy sets out how we comply with our obligations under the Privacy Act 1988 (Australia) and the Information Privacy Principles contained in the Victorian Privacy and Data Protection Act 2014 (Vic) (the “Privacy Laws”).

We are bound by the requirements of these Privacy Laws, which regulate how we may collect, use, disclose and store Personal Information. These Privacy Laws also specify how individuals may access and correct Personal Information held about them.

“Personal Information” means information or an opinion (including information or an opinion 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. For example, these types of information could include your name, contact details, age, image, and health information, unless you tell us to the contrary by contacting us.

Who we collect from
Through provision of our facilities and services, we collect certain information about actual and prospective Patrons (including event patrons and participants, attendees, ticket holders and visitors), Suppliers, Staff, Key Stakeholders, Venue Hirers, Tenants, and other users of our facilities and Trust-owned or used land, including GMHBA Stadium (the “Stadium”).

What we collect
The types of Personal Information we collect will depend on the particular purpose for which they are collected (see the section titled ‘Use and Disclosure of Personal Information’ below). They may include but are not limited to name, age, date of birth, gender, contact details (including mailing/street/e-mail address and phone number), team or region of support, nationality, relationship status, number of children, membership status, interests and profession, as well as applicable transactional information (including credit card details), information relevant to employment or contracting with us or prospective employment or contracting with us, your preferences and/or opinions, where you provide those to us as part of the products and services we provide to you or your access to our premises, details of products and services we have provided to you and/or that you have enquired about, and our response to you, images and video footage of you, including images and video footage collected by security cameras or for promotional purposes and any other Personal Information requested by us, or provided by you or a third party, in connection with the services provided to you or the use of or access to our facilities and any Trust Areas.

We also collect Personal Information that you provide to us, directly or indirectly, through your use of our website, associated applications, social media platforms and/or accounts, including the information described above, the name of any internet service provider and internet protocol (IP) address through which you access those digital platforms, the date and time of access, pages or parts you visit and the internet address of any website from which you link directly to our websites or digital platforms.

Third Parties
Any personal information that you provide via our digital platforms or directly is collected and managed by us. If you provide your personal information to a third party via a link from our website or other digital platforms or an introduction from us, that information is collected and managed by those third parties. You should familiarise yourself with their privacy policies prior to deciding whether you wish to provide them with your information.

If you provide us with information about any third party, you must obtain that person’s permission to give us the information and inform them that you have given the information to us.

How We Collect
We will only collect Personal Information about you by lawful and fair means and not in an unreasonably intrusive manner. Our preference is to collect Personal Information about an individual directly from that individual unless it is unreasonable or impracticable for us to do so.

Personal Information will commonly be collected from:
• your access to our website, usually through log files stored on our web server;
• information entered on our enquiry, order, purchase or registration forms;
• information provided over the Internet via channels outside of our website, including by contacting us through social media platforms;
• information obtained when you purchase products or services from us or our Venue Hirers, including tickets to events at our premises, where you sign up for our mailing list or for memberships, competitions or promotions provided by us from time to time; and
• information where you request information from us, or lodge a complaint with us, or where you are a prospective employee, if you apply for a job with us.
We may collect personal information through a variety of other means as well, including (but not limited to), providing and updating your details online or through a paper form, attending or registering for an event hosted by us or staged on land we may own, operate, lease or manage from time to time, using a third party membership card, subscribing to receive newsletters from us or if you contact us directly via social media, phone or email (or in person).
We may also collect other information through your use of our digital services, including our Wi-Fi network, such as the device ID number (MAC address) of any device used by you when accessing those services. If we hold such information that can be associated to you or the device you are using, then that information may be linked with your Personal Information and will be treated in the same manner as the Personal Information to which it has been linked.

Finally, we may also collect personal information about you from a third party or a publicly available source (including social media), but only if you have consented to such collection, or would reasonably expect us to collect your Personal Information in this way, for instance job applicants and employees provide referee and next of kin details to us, clients might provide us with trade references, etc.

Anonymity
Where practical and appropriate, we will allow you to deal with us anonymously or by using a pseudonym. However, in many circumstances, this might not be possible as many of our services require your Personal Information. If you do not wish to provide the information requested, we may not be able to provide you with a service or the use of our facilities, or the quality of the services or facilities may be impacted.

Children
We consider it is the responsibility of parents or guardians to monitor their children’s use of our websites and other digital services (such as our Wi-Fi network and social media accounts), but it is our policy not to require Personal Information from persons known by us to be under the age of 18 years or offer to send any promotional material to those persons unless parental or guardian permission has been granted.

We may use and disclose your Personal Information for a variety of purposes, including for the primary purpose for which we collected your Personal Information (see below), or for reasonably (or directly if the Personal Information is Sensitive Information) related secondary or ancillary purposes that we believe you should reasonably expect, or where we are otherwise required or authorised by law, including the Privacy Laws.

Use and Disclosure Generally
Typically, we collect, use, and disclose Personal Information for the primary purpose of providing entertainment, facility usage and related services and any other function, power, activity, or purpose consistent with the Kardinia Park Stadium Trust Act 2016 (Vic) and our constitution, including, but not limited to:

• for market research and analysis, business development and to seek your opinion;

• administering our website and social media accounts and to help improve our digital platforms, Wi-Fi network and apps and to enable you to access and use, in an optimal manner, our website and associated services (including our Wi-Fi) and associated social media platforms;

• to contact and communicate with you (including via e-mails, mail and digital and physical newsletters) about our services, facilities, activities and events and general promotional material that we believe may be useful to you;

• for advertising, promotions and marketing, including to send you promotional information about our products and services and relevant information about third parties that we consider may be of interest to you, where permitted by law (including Venue Hirers);

• allowing our Business Partners, Key Stakeholders, Suppliers, Venue Hirers or our other promoters or partners to market and promote their events, products and services to you, where permitted in accordance with this Privacy Policy (see the section titled ‘Third Parties’);

• to process payments and for identity verification purposes;

• to consider receiving goods or services;

• for proper governance, internal record keeping and other administrative purposes and to facilitate operational and administrative requirements, including those relating to Staff and prospective Staff and related employment or contractual matters;

• to answer your queries, including in relation to emails or other correspondence sent to us, for responding, troubleshooting, maintenance purposes and for preventing or addressing email or other abuse;

• to maintain the security of our Stadium, premises, offices, lands and facilities (“Trust Areas”), including minimising and detecting unlawful activity, preventing crowd disturbances and to assist law enforcement and certain Suppliers (such as security contractors) in carrying out their responsibilities, including responsibilities that apply under the Major Sporting Events Act 2009 (Vic), Kardinia Park Stadium Trust Act 2016 (Vic) and other applicable laws;

• to the extent that we consider it reasonably necessary, including to monitor access to, ensure appropriate and lawful use of (including compliance with terms and conditions, policies and procedures applicable to you or your attendance at or involvement in particular events), and profile the types of people using, Trust Areas, Trust websites, the Stadium Wi-Fi network and other Trust digital services, such as in-venue text messaging systems;

• to monitor and enforce (or assist with the enforcement of) terms and conditions, policies and procedures applicable in relation to your use of Trust Areas and your attendance at, or involvement in, any events hosted within Trust Areas, including the Conditions of Entry to the Stadium, our health and safety-related policies and emergency evacuation procedures, to the extent that we consider reasonably necessary or appropriate to disclose or use your Personal Information for those purposes

• to comply with our legal obligations and to manage and resolve any legal, consumer or commercial complaints, disputes and issues we may have; and

• in connection with any transfer or assignment of any of our businesses or assets (or any part of them).

Personal Information that we collect for market research may be aggregated for analysis but we would typically use our reasonable endeavours to ensure that such aggregated data for that purpose does not contain Personal Information.

Disclosure to Third Parties – Why
In the course of conducting our business, we may disclose your Personal Information. We only disclose Personal Information for the purposes for which it was given to us, or for purposes that are directly related to one of our powers, purposes, functions, or activities. We do not give it to anyone else unless one of the following applies:• you have consented to the disclosure; or
• you would reasonably expect, or have been told, that your information is passed to those individuals, businesses, or agencies; or

• it is otherwise required or authorised by law or permitted under this Privacy Policy.
Disclosure to Third Parties – Who
In addition to the purposes set out above, we may disclose Personal Information to the following third parties in accordance with the terms and conditions of this Privacy Policy:

• third-party service providers for the purpose of enabling or assisting us (or them on our behalf) to provide functions, information, access, products and/or services, in each case for purposes consistent with this Privacy Policy (noting that we generally require our contracted partners to comply with applicable laws in providing their services, including all relevant Privacy Laws);

• a Business Partner, Key Stakeholder, Venue Hirer or Supplier, and the personal information is utilised for direct marketing purposes (whether for us, you or the third party) pursuant to this Privacy Policy;

• governing bodies or responsible entities for events held within Trust Areas, such as national or international federations and Key Stakeholders, to the extent that we consider it reasonably necessary or appropriate to disclose information to those parties for purposes consistent with this Privacy Policy;

• our employees, contractors and/or related entities or businesses;

• professional advisers (such as lawyers or auditors) and payment systems processors;

• anyone to whom our business or assets (or any part of them) are, or may be, transferred or assigned;

• upon awful request from any courts, tribunals, regulatory or government authorities or law enforcement officers in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights or those of any hirers or users of Trust Areas;

• to third parties where otherwise required or permitted under the Privacy Laws or other applicable law, including where we believe that the use or disclosure is reasonably necessary to assist a law enforcement body or an agency responsible for government or public security in the performance of their functions or we are required or authorised by law to disclose the information; and

• any persons acting on your behalf including those persons nominated by you, including executors, trustees and legal representatives.

Direct Marketing
We are committed to compliance with all laws and requirements relating to the use of your Personal Information. We will only use or disclose your Personal Information for direct marketing purposes if:
(i) we consider that you would reasonably expect us to use your Personal Information for such purposes;

(ii) you have consented to the use or disclosure for these purposes; or
(iii) we are otherwise permitted to under the Privacy Act or other applicable law (including any Privacy Laws).

From time to time, we may contact you with information about opportunities, products, and services (including events) offered by us, our related entities, our Business Partners and other Suppliers, Venue Hirers, promoters, and governing sports bodies, which we think may be of interest to you. When we contact you, it may be by mail, telephone, email, SMS/text message or social media message.

Where we use or disclose your Personal Information for the purpose of direct marketing, you may remove your name from our distribution list by e-mailing us at enquiries@kardiniapark.vic.gov.au, requesting to be removed from our mailing list, or in the case of marketing emails, by clicking on the ‘unsubscribe’ link at the bottom of the email communication that was sent to you and following the prompts, and we will:

• allow you to request not to receive direct marketing communications (also known as ‘opting out’); and

• comply with your request to ‘opt-out’ of receiving further communications within a reasonable timeframe.

We will not use your Sensitive Information for direct marketing purposes.

Surveillance Activities
As noted above, we operate surveillance cameras within, and in the immediate vicinity of, Trust Areas for various purposes consistent with this Privacy Policy, including venue and queue management, monitoring movement and general operational purposes, as well as for the purposes of minimising, detecting and avoiding unlawful activity, preventing crowd disturbances and assisting law enforcement and our security contractors and Venue Hirer staff and security operators in carrying out their various responsibilities. The surveillance recordings, including Personal Information held on those recordings, may be provided:

• to law enforcement bodies or an agency responsible for government or public security, to the extent that we or our Venue Hirers are required or authorised by applicable law; and

• to third parties, including security contractors, in accordance with this Privacy Policy, to the extent that we are required by applicable law or we consider it reasonably necessary for purposes set out in this Privacy Policy.

We customarily store most of our Personal Information within Trust Areas, or with our service providers, in the State of Victoria.

However, in some circumstances, your Personal Information may be transferred, disclosed or stored, including to or by our related entities, Suppliers, Business Partners, Venue Hirers and other third parties, outside the State of Victoria, or outside Australia, where third parties with whom we may share that information under this Privacy Policy are located outside the State of Victoria or Australia. In addition, while typically Personal Information held by our cloud service providers will be stored on servers within Australia, it is possible that we, or our Suppliers, Business Partners, Venue Hirers and other third parties, will utilise cloud technology in connection with the storage of Personal Information, and it is possible that this may result in trans-border transfer or storage of your Personal Information (e.g. in data storage and cloud computing facilities operated by us, by third parties on our behalf or by third parties).

The countries this information may be disclosed to will vary from time to time, but may include Australia, the United States of America, the European Economic Area, the United Arab Emirates, and Singapore.

Sometimes we use third party platforms and services, including cloud services, to store, backup and process data (including financial data), provide support, account manage, send marketing messages and facilitate our products and services (including customer relationship management and security). These services are hosted and managed by organisations other than us, and some of these services are hosted overseas. We use products and services maintained in Australia, the United States of America, the European Economic Area, the United Arab Emirates, and Singapore.

By providing your Personal Information to us, you consent to our disclosure of your Personal Information to trans-border recipients in accordance with this section of the Privacy Policy. If you have any queries regarding the transfer of your Personal Information, please contact us using the details provided above.

Data Quality and Security
We may hold electronic records of the Personal Information we collect, using cloud technology or by other electronic means, or in paper form.

We will take such steps as are reasonable in the circumstances to protect the Personal Information we hold from misuse or loss and from unauthorised access, modification, or disclosure. We use a range of security measures and processes to protect your Personal Information, including network and computer security (such as login credentials), physical venue security, access control systems and accreditation policies and procedures and IT user policies, procedures, and staff training.

We will also take such steps as are reasonable in the circumstances to destroy or de-identify Personal Information once we no longer need it for any purpose for which the information may be used, disclosed, or retained under the Privacy Laws or this Privacy Policy.

We will not use Government Related Identifiers, such as a driver’s licence number as its own identifier of individuals.

Website Usage

Our website is professionally hosted and operates in a secure environment. You should however be aware that there is always an inherent risk in transmitting your Personal Information via the Internet and that no data transmission over the Internet can be guaranteed as totally secure. Although we strive to protect such information, we do not warrant the security of any information that you provide us over the Internet, and you do so at your own risk.

To make sure you are accessing a secure server, check for the unbroken key or closed lock symbol located generally near a corner of your browser window or the address bar. If it appears, then SSL is active. You can double check this by looking at the URL as well. If SSL is active, then the first characters of that line will read ‘https’ rather than just ‘http’. It is important for you to protect against unauthorised access to your password and to your computer. Ensure you logout when you have finished visiting our website, especially if you have accessed it from a shared computer.

We also log domain and IP address automatically when you visit our website, however, this information does not identify you as an individual, but only the computer that you are using to view the website and your approximate geographic location.

If you visit an area of our website where you are not required to log on, to read, browse or download information, our system may record the date and time of your visit to our site, the pages viewed, and any information downloaded.

Any Personal Information that you submit to us using our website or in an e-mail will only be used in accordance with this Privacy Policy.

Cookies
When you visit our website, we may utilise ‘cookies’. Cookies are pieces of information that a website transfers to your computer for record-keeping purposes. The information collected may be used by us to improve your experience on our website. They enable us to monitor traffic patterns and to serve you more efficiently, including by serving adverts or other promotional material. A cookie does not identify you personally, but it does identify your computer. You can set your browser to notify you when you receive a cookie, and this will provide you with an opportunity to either accept or reject it in each instance.

Our websites use Google Analytics Services, for more information about cookies used, see Google Cookies Policy.

Links to third party sites
This Privacy Policy applies solely to the Trust.
While links to third party websites may be provided on our website, we are not responsible for the content or practices of these third-party websites and nor are we necessarily aware of, nor are we responsible for, differences in privacy statements of external websites linked to or from our website. These links are provided for your convenience and do not represent our endorsement of any linked third-party website.
Our linked websites should not be construed as an endorsement, approval or recommendation by us of the owners or operators of those linked web sites, or of any information, graphics, materials, products or services referred to or contained on those linked web sites. We also recommend that you check the privacy policies of these third parties prior to providing them with your Personal Information. No links may be made to our websites without our prior written consent.

We will take such steps as are reasonable in the circumstances to ensure that the Personal Information that we collect, and hold remains accurate, up to date and complete.

On request, we will provide you with access to your Personal Information held by us unless we are permitted under the Privacy Law or any other law to refuse to provide you with such access. If we are unable to give you access to the information you have requested, we will give you reasons for this decision when we respond to your request.
You will not be charged for accessing your information, although we might have to charge the reasonable cost of providing you with access and processing your request, including photocopying, administration and postage. We will advise you of any fee payable before we process your request.

Please contact us via the details above if you:
• wish to have access to the Personal Information which we hold about you;
• consider that the Personal Information which we hold about you is not accurate, complete or up to date; or
• require further information on our Personal Information handling process.
If you believe that the Personal Information we hold about you is inaccurate, out of date, incomplete or misleading, we will take reasonable steps, consistent with our obligations under the Privacy Law, to correct that information if you so request.

Any complaints will be individually investigated and dealt with in accordance with our obligations under the Privacy Laws.

This Privacy Policy is effective from December 2023.

We will update this Privacy Policy from time to time, in order to maintain our compliance with applicable laws and regulations, address new issues and reflect changes in our internal practices. We will do this by updating this Privacy Policy on our website, currently at https://www.kardiniapark.vic.gov.au/privacy/ .

Please refer to this Privacy Policy regularly. You may obtain a copy of our current Privacy Policy from our website or by contacting us through the details provided above.

If you have a complaint or inquiry about the way in which we have handled any privacy issue, please advise us via the contact details noted above.

We will use reasonable efforts to deal as soon as is reasonably practicable with complaints and inquiries and, in any event, acknowledge your complaint or inquiry within a reasonable time.

If you consider your privacy concerns have not been resolved satisfactorily by us, or you wish to obtain more information on privacy requirements, you can contact the Office of the Australian Information Commissioner on 1300 363 992 or visit their website at www.oaic.gov.au.

The following definitions apply to this Privacy Policy:

• Business Partners means third-party organisations that we have commercial, promotional or advertising arrangements with.

• Government Related Identifiers has the meaning given in the Privacy Laws.

• Key Stakeholders means the Australian Football League (AFL), Geelong Football club and other AFL clubs, Cricket Australia, Cricket Victoria, the International Cricket Council, the National Rugby League (NRL), the Australian Premier Leagues (APL), the City of Greater Geelong, the Government of Victoria (including Visit Victoria) and the Australian Government and other venue hirers conducting major events at the Stadium and other Trust Areas.

• Patrons means any attendees, ticket holders, AFL/Geelong Football Club members, AFL club members, hospitality guests, tenants, users or visitors to any Trust Areas, including any facility or venue owned, operated or managed by the Trust or on Trust Areas from time to time, including the Stadium located within Kardinia Park and all adjacent areas around the Kardinia Park Precinct premises that are controlled by us, the Geelong Sports Museum, the Regional Cricket Hub, Geelong Cricket Club Rooms, Bruce Moore Room, Stadium Management Centre, Venue Management Centre, Geelong Football Club administrative and player training facilities and merchandise outlets, Sports House, Deakin Cats Community Centre, GMHBA Fan Portal, Barwon Health Sunrise Centre, the David Kelly Training Centre, the Kardinia West Oval (including club rooms and stands), the Kardinia Park Netball Complex (including the Geelong Central Netball Association rooms), the Geelong Football Umpires League rooms, the Geelong Cricket Ground and the Senior Citizens rooms and the Blank Space Cafe, as well as staff, tenants, visitors, users and customers of those areas, facilities and buildings.

• Sensitive Information has the meaning given in the Privacy Laws.

• Suppliers means contractors, Business Partners, third party suppliers (such as security contractors, IT providers, venue management contractors and other providers of goods or services to the Trust and/or Trust Areas).

• Staff means the Trust’s full-time staff, part-time staff, casual staff, consultants, work placement personnel, volunteers and recruitment candidates (including any applicant staff member or volunteer).

• Tenants means any tenants of premises within Trust Areas, including but not limited to tenants within Sports House, the Blank SpaceCafé, Barwon Health Sunrise Centre, administrative offices within the Stadium and areas under the control or leased to the Geelong Football Club and/or Deakin Cats.

• Venue Hirers means any entity or organisation or person that hires, licenses or leases any part of any Trust Area. This includes Key Stakeholders and other event promoters, managers and owners.

Kardinia Park Stadium Trust (“the Trust”, “we” or “our”) collects your personal information to communicate with you in relation to information and offers from the Trust and to provide our products and services, including access to our facilities, activities and events.

By providing your personal information you agree it will be disclosed to, and used by, the Trust under the terms of this Collection Statement and/or our Privacy Policy (at www.kardiniapark.vic.gov.au/privacy), which contains, among other information, information about how you may access and seek to correct your personal information or complain about a breach of your privacy, and how we will deal with that complaint.

We may also disclose your personal information to other parties, including our third-party service providers and event partners, who may be located (and so your personal information may be disclosed) overseas, including in the United States of America, the European Economic Area, the United Arab Emirates, Singapore and other countries from time to time. We may use and disclose your personal information for direct marketing and other purposes, unless you opt out (which you can do at any time from our communications in accordance with our Privacy Policy).