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World Sport Action Privacy Policy

Last Amended : 29 October 2023

• Introduction

1. 1. 1. This Privacy Policy covers the World Sport Action and its associates, related entities and subsidiaries (together, “we,” “us,” “our,” and the “WSA“). For the avoidance of doubt, a reference in this Privacy Policy to WSA (including the WSA doing or not doing an act) is a reference to, and is intended to also cover, Netball Live Scores and its other entities. Please read this Privacy Policy carefully as it describes how we collect, use, disclose and otherwise handle your Personal Information. The WSA is always seeking to better understand how Players, Participants, Administrators, Clubs, States and, most importantly, fans interact, communicate, and otherwise share Personal Information in order to continue to develop its technology services. For all visitors to our website, and all other individuals that we communicate with in the course of providing our Services or throughout the running of our businesses (each referred to as “you” and “your”), we are the Data Processor of your Personal information.
      2. WSA recognises the importance of your privacy and your rights to your Personal Information and is committed to complying with Applicable Privacy Laws
      3. We regularly review this privacy policy and may make changes as our services or privacy practices change, or as required by Applicable Privacy Laws or regulations.  Future versions of our privacy policy will be available on our website.  We encourage you to review this privacy policy periodically to be informed of how we use your personal information.

• Anonymity and pseudonymity

We offer you the opportunity, wherever it is lawful and practicable, of not identifying yourself, or of using a pseudonym, when entering transactions or otherwise dealing with, the WSA in relation to a particular matter by contacting the WSA Privacy Officer (see clause 11).

• What kinds of personal information do we collect?

1. 1. 1. The types of Personal Information the WSA may collect depends on the purposes for which it is collected but may include (without limitation):
         1. your name, gender, date of birth, occupation, profile picture (image), residential address, email address, telephone number and other contact details and other information that appears on your identification documents;
         2. Your financial information including credit and debit card details, bank account details and/or billing information;
         3. information collected automatically by our website and any other computer systems, to which we give you access, such as your usage data, internet protocol (IP) address, browser type and version, time zone setting and generic location, browser plug-in types and versions, operating system and platform on the devices you use to access our systems;
         4. your favourite Club and other information dealings with the WSA, Clubs, States or selected ticketing companies such as memberships, subscriptions and attendance history at Matches; and
         5. all other information that is required for the purposes of allowing us to provide our services to you; and
         6. all other information that is provided by you voluntarily.
      2. The WSA will not collect Sensitive Information about you unless:
         1. you have consented to the collection of such specific Sensitive Information;
         2. the collection is required or authorised by Applicable Privacy Law; or
         3. the collection is otherwise permitted under Applicable Privacy Laws.

• How do we collect your personal information?

1. 1. 1. The WSA will collect Personal Information about you and your interactions with us, for example:
         1. when you inquire about, purchase, or request information about our services, call us or otherwise visit our website and we provide you with services;
         2. when you subscribe to (or do not opt out of our online services, or our mailing list;
         3. when you attend one of our events;
         4. whenever you interact with us, including over the phone, through our online enquiry from, email, social media channels, or post or leave a review of the services we have provided to you. 
      2. In addition to collecting Personal Information directly from you, the WSA may also collect Personal Information about you from:
         1. the Clubs, States and selected third parties; 
         2. a third party (such as a corporate partner of WSA or Clubs, or by way of referral); or
         3. information that is on public record or which is otherwise unsolicited).
      3. If you are a Minor, the WSA may collect Personal Information about you from your parent or legal guardian.

• Why do we collect, use, hold and disclose your personal information?

1. 1. In certain regions such as the UK and EEA where the GDPR and DPA apply, a lawful basis for collecting and using your Personal Information must be established. Under Australian privacy laws, we are obliged to identify the reasons why we collect your Personal Information. There are six legal justifications that organisations can use. The most relevant of these to us are where we use your Personal Information to:
      1. Fulfil a contract that we have with you as an individual (Contract);
      2. Comply with our legal obligations (Legal Obligation);
      3. Pursue our legitimate interests (our justifiable business aims) but only if those interests are not outweighed by your other rights and freedoms (Legitimate Interests); or
      4. Do something for which you have given your consent (Consent)

The table below sets out the specific purposes for which we use your personal information and the lawful basis we rely on when we do so:

Lawful Basis	Purpose for using your personal information
Contract	Where you are a Player, Participant, Administrators Club, State, fan, supplier or anyone else that contracts with us as an individual, to: administrate or perform our contract with you; or To enable you to access and use our services via our website, associated applications and associated social media platforms; or process your payment information in connection with any contract we have with you; or send you updates about the services you have bought; or to comply with any applicable sporting Rules (including those set by the WSA), that include the administration and development of that sport (if you are a Participant); or any direct communications with you from sporting Administrators consider your employment application or application to provide services to us.
Legal Obligation	If processing of your personal information is necessary: to record your preferences (e.g. marketing) to ensure that we comply with data protection laws; or where we retain information to enable us to bring or defend legal claims; or  where we are required to assist government and law enforcement agencies or regulators.
Legitimate Interests	Where using your information is necessary to pursue our legitimate business interests to: keep internal records; or administrate or perform our contract with your business or employer; or contact and communicate with you, for example, to respond to your queries or complaints, or if we need to tell you something important; or perform accounting, billing and other administrative and operational functions; or perform routine analysis on the performance of our business, and on our marketing and sales activities, including to operate and improve our services for our website, associated applications and associated social media platforms. We may anonymise personal information before we do this; or to organise, conduct and promote Competitions and Matches (including for the purpose of providing information and making ticket offers to you); run competitions and/or offer additional benefits to you; or for advertising and marketing, including to send you promotional information about our products and services and information about third parties that we consider may be of interest to you, serving content that is in accordance with your preferences and previous consumption, serving advertising that is suited to your age, but will not do so if you tell us not to. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below at clause 11; or enable you to use our website; or improve and optimise our websites; or monitor and make improvements to our website to enhance security and prevent fraud; or to protect our business and defend ourselves against legal claims. Where we use your information for our legitimate interests, we have assessed whether such use is necessary and that such use will not infringe on your other rights and freedoms.
Consent	Where you have provided your consent to providing us with information or allowing us to use or share your information.

1. When we collect your Personal Information, your Personal Information will only be used or disclosed for the primary purposes for which it was collected as set out in the table above, a secondary purpose, and in accordance with any express consent you grant the WSA or as otherwise lawfully required (e.g. where your Personal Information is requested by a law enforcement agency).

Direct Marketing

1. WSA may use or disclose your Personal Information to Sporting Administrators for the secondary purpose of direct marketing communication, if:
   1. the WSA has collected the information from you;
   2. you would reasonably expect your Personal Information would be used or disclosed for direct marketing;
   3. the WSA has provided a simple means by which you can request not to receive direct marketing; and
   4. you have not made a request not to receive direct marketing.
2. 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 (for instance, from the Clubs), the WSA may use the information for the secondary purpose of direct marketing communication only where:
   1. you have expressly consented to the use or disclosure for direct marketing, or it is impracticable for the WSA to seek your consent before that use;
   2. you have not made a request to the WSA not to receive direct marketing communication;
   3. each written direct marketing communication by the WSA with you sets out the WSA’s contact details including email address.

• Who do we disclose your personal information to?

1. 1. 1. Subject to compliance with Applicable Privacy Laws, and this Privacy Policy, the WSA may also share your Personal Information with:
         1. Personnel, employees (or other types of workers) of the WSA who have contracts containing confidentiality and data protection obligations; or
         2. Club Partners and other third-party service providers that help us provide our services, such as ticketing agents, payment system operators, mail houses or other similar-third party organisations. We ensure that these organisations only have access to the information required to provide the support we use them for (e.g. fulfilling ticket requests, third party credit card payment gateway services, etc), and have a contract with them that contains confidentiality and data protection obligations. This may include parties located, or that store data, outside of Australia; or
         3. other affiliates (including without limitation the States, a Competition Administrator and a Club) to enable them to administer the sporting game in their area and provide related activities and services; or
         4. Any actual or potential buyers of our business; 
         5. regulatory and law enforcement authorities, courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights; or
         6. our professional advisers such as our accountants or legal advisors where we require specialist advice to help conduct our business; or
         7. States, Sporting Partners and selected other sponsors or promotion partners (unless you inform the WSA otherwise), to enable such recipients to provide you with information, materials and promotional opportunities. This sharing of Personal Information will assist the WSA, Clubs, States, Sporting Partners and selected other partners to more effectively administer promotional and information sharing activities.

• Data quality and security

1. 1. 1. WSA will take reasonable steps to:
         1. make sure that the Personal Information it collects, uses or discloses is accurate, complete and up-to-date; and
         2. 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.
      2. WSA will take reasonable steps to destroy or permanently de-identify Personal Information if it is no longer needed for the purpose for which the information may be used or disclosed (at your request or otherwise) or if you withdraw your consent where consent is required, unless WSA is required by or under law, or a Court order, to retain such information. Where WSA is required to destroy or permanently de-identify your Personal Information, it will take reasonable steps to inform other parties using, holding or disclosing the same Personal Information (including any links to, copies of or replication of that Personal Information).

• Openness, access and correction

1. 1. 1. The WSA will provide you with a variety of ways to access, review and manage your Personal Information. For example, you can access, review and manage your Personal Information at any time in the profile section of the App. You will be responsible for ensuring your Personal Information remains accurate, complete and up to date.
      2. Upon your request, the WSA will take reasonable steps to let you know, in general terms, what types of Personal Information it holds, for what purposes, and how it collects, holds, uses and discloses that information. Where the WSA has collected your Personal Information from you directly or with your consent, you have a right to receive (upon request) that Personal Information from the WSA in a structured, commonly used, machine readable format and/or a right to instruct the NRL to transmit that Personal Information to a third party (if technically feasible).
      3. Before supplying any Personal Information to you or updating your Personal Information at your request, the WSA must be reasonably satisfied as to your identity (for example, by asking to see your passport or driver’s licence). The WSA is not under any obligation to provide Personal Information to you where the WSA is not required to do so under Applicable Privacy Laws.
      4. If the WSA refuses to provide you with access to Personal information it holds on you in the manner requested by you, the WSA will either:
         1. 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 WSA and you; or
         2. provide you with a written notice that sets out:
            1. 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
            2. the mechanisms available to complain about the refusal.
      5. If:
         1. the WSA 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
         2. you request WSA to correct your Personal Information, the WSA 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 WSA will not charge you for making such a request or for correcting the information.
      6. If WSA refuses to correct the Personal Information at your request, WSA will provide you with a written notice that sets out the same matters listed in clause 8.4(b).

• Opt Out

We respect your privacy and offer you the option to opt out of certain data collection, marketing, and competition communications. If you prefer not to receive promotional materials or wish to limit the information collected, you can do so by:

1. Adjusting your communication preferences in your profile settings.
2. Unsubscribing from our promotional emails by using the ‘Unsubscribe’ link included in the emails.
3. Contacting our customer support team to express your preferences and make necessary adjustments.

Please note that while you can opt out of promotional communications, some data collection is necessary for providing the core functionality of our services. However, we are committed to honoring your preferences and ensuring your data is handled in accordance with our privacy policy.

By opting out, you may still receive certain non-promotional communications related to your account or transactions.

For further inquiries or assistance regarding your privacy choices, please contact us at info@worldsportaction.com

• Notifiable data breaches scheme

In the event of any data breach or data loss, or unauthorised access or disclosure of your Personal Information that is likely to result in serious harm to you, WSA will investigate and notify you and where applicable the relevant supervisory authority (e.g. the Australian Information Commissioner) within the prescribed time window under the Applicable Privacy Law following the time of our first becoming aware of the data breach or data loss, or unauthorised access or disclosure, in accordance with Applicable Privacy Laws.

• Transfer of Personal Data overseas

• As we are a [global company], we may disclose your personal information to our other entities located in Australia, the UK or the United States or elsewhere at locations from where we provide our services to you.

• We may also disclose your personal information across borders to others outside our group of companies where:

1. 1. 1. 1. it is necessary for the provision of our services to you;
         2. we are required or authorised by law to do so; 
         3. you may have expressly consented to the disclosure; or 
         4. we are otherwise permitted to disclose the information under any relevant privacy regulations.

• If your Personal Information has been collected in Australia, before transferring it outside of Australia, we will take reasonable steps to endure that the overseas recipient does not breach the Australian privacy principles in relation to your Personal Information.  

• Your legal Rights and Inquiries procedure

1. 1. Where you are resident in the United Kingdom or European Economic Area, you have specific legal rights in relation to your Personal Information. Where you are resident in Australia or the United States, or other locations where we provide our services, you have rights under Applicable Privacy Law and regulations. 
   2. We can decide not to take any action in relation to a request where we have been unable to confirm your identity (this is one of our security processes to make sure we keep information safe) or if we feel the request is unfounded or excessive. We may charge a fee where we decide to proceed with a request that we believe is unfounded or excessive. If this happens, we will always inform you in writing.
   3. If you are resident in the United Kingdom or European Economic Areas and wish to make any of the right requests listed below, you can do so by contacting the WSA info@worldsportaction.com.
      1. Access: You must be told if your personal information is being used and you can ask for a copy of your personal information as well as information about how we are using it to make sure we are abiding by the law.
      2. Correction: You can ask us to correct your personal information if it is inaccurate or incomplete. We might need to verify the new information before we make any changes.
      3. Deletion: You can ask us to delete or remove your personal data if there is no good reason for us to continuing holding it or if you have asked us to stop using it (see below). If we think there is a good reason to keep the information you have asked us to delete (e.g. to comply with regulatory requirements), we will let you know and explain our decision.
      4. Restriction: You can ask us to restrict how we use your personal data and temporarily limit the way we use it.
      5. Objection: You can object to us using your personal data if you want us to stop using it. If we think there is a good reason for us to keep using the information, we will let you know and explain our decision.
      6. Portability: You can ask us to send you or another organisation an electronic copy of your personal data.
      7. Complaints: If you are unhappy with the way we collect and use your personal data, you can complain to the Information Commissioner’s Office (www.ico.org.uk), but we hope that we can respond to your concerns before it reaches that stage. Please contact us at the details set out below. If you still wish to complain to the ICO you can contact them by calling 0303 123 1113. Or go online to www.ico.org.uk/concerns.
   4. All complaints and inquiries concerning your Personal Information, including in respect of alleged breaches of this Privacy Policy or applicable privacy laws (including the Privacy Act and GDPR), should be directed to the WSA Privacy Officer:

The Privacy Officer
World Sport Action
Suite 10, Level 3

1 Mona Vale Road
Mona Vale NSW, Australia 2103

Info@worldsportaction.com 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 WSA.

• How Long we retain/keep your information for

• We retain information are based on the requirements of applicable data protection laws and the purpose for which the information is collected and used. We take into account legal and regulatory provisions which require information to be retained for a minimum period.  We also consider the limitation periods for taking legal action and good practice in the legal industry.

• We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for.

• We may keep identity data, contact data and certain other data (specifically, any exchanges between us by email or any other means) for up to seven years after the end of our contractual relationship with you.

• If you browse our website, we keep personal information collected through our analytics tools for only as long as necessary to fulfil the purposes we collected it for.

• If you have asked for information from us or you have subscribed to our mailing list, we keep your details until you ask us to stop contacting you.

• Privacy Policy updates

This Privacy Policy was updated in [February 2023]. We may update this Privacy Policy from time to time, in which case we will post the updated version of the Privacy Policy on our website (www.worldsportaction.com). As such, please check back periodically to see if our Privacy Policy has been updated.

• Definitions

In this Policy the following terms have the following meanings:

“Applicable Privacy Laws” means the laws which apply to us in the provision of our services, which include the Australian Privacy Principles in the Privacy Act 1988 (Cth) (Privacy Act) and the NDB, the California Consumer Privacy Act (CCPA); the UK’s Data Protection Act 2018 (DPA) and the European Union General Data Protection Regulation (EU) 2016/279 (the GDPR), each to the extent applicable.

“Club” means any Club or Team registered to use our Live Scoring Application from time to time.

“Competition” means any competition, tournament or league registered supported by our Live Scores Application.

“Competition Administrator” means the entity responsible for the conduct and staging of a Competition.

“Data Controller” means a natural or legal person, public authority, agency or any other body which alone or jointly with others determine the purposes and means of processing Personal Information.

“Data Processor” means a natural or legal person, public authority, agency or any other body which processes Personal Information on behalf of the Data Controller. It does not include an employee of the Data Controller

“Match” means a game of sport and includes any match staged, participated in, sanctioned by, or played.

“Match Official” means any person in charge of safety or any other person or a Competition Administrator to assume responsibility in connection with a Match.

“Minor” means any person younger than 16 years of age.

“Official” means:

1. a Club Official, Match Official or Team Official;
2. an employee, consultant, officer or director of the sporting body, the States or a Competition Administrator; or
3. a member of a council, committee, panel or body constituted by the sporting body, States or a Competition Administrator.

“Personal Information” means any information or an opinion about an identified natural person, or a natural person who is reasonably identifiable whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not. Personal Information is also personal data as defined in the Privacy Act. 

“Opt Out” means declining to receive promotional materials, choosing not to have personal information shared with third parties, or deciding not to participate in certain data collection practices.

“Participant” means participants in the game of Sport including the Players and Officials.

“Player” means any person who is, from time to time, registered to a Club or is selected as a member of a Representative Team, whether that person is male or female, junior or senior or an amateur or professional.

“Privacy Policy” means this document as updated from time to time and made available on the WSA’S website (www.worldsportaction.com).

“Representative Match” means a team participating in a Representative Match.

“Representative Team” means any team selected to participate in a Representative Match.

“Sporting Administrators” means any sport, States, a Competition Administrator or a Club (as the case may be) with which the Participant has a direct relationship with WSA’s Live Scoring Application, including for the purposes of registration with the League and participation in a Competition.

“Sensitive Information” means information or an opinion about a natural person’s racial or ethnic origin, political opinions. membership of political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record that is also Personal Information as well as health information, genetic information, biometric information for the purposes of verification/identification and biometric templates about a natural person.

“Special Category Data” (as defined in the UK DPA) means the following data:

1. personal data revealing racial or ethnic origin;
2. personal data revealing political opinions;
3. personal data revealing religious or philosophical beliefs;
4. personal data revealing trade union membership;
5. genetic data;
6. biometric data (where used for identification purposes);
7. data concerning health;
8. data concerning a person’s sex life; and
9. data concerning a person’s sexual orientation.

“State” means any entities that are state organisations, bodies, sporting leagues and associations.

“Team Official” means any personnel involved with the management, preparation or participation of a Club’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.

“WSA Partners” means any entity that has a commercial agreement or arrangement with WSA, States, Competition Administrator or Club (as the case may be) and which you may also have a direct relationship with (including by participation in a Competition).

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