1. Purpose

1.1. This privacy policy (Privacy Policy) applies to personal information collected by M11 Club Pty Ltd ACN 698 422 927 (Company), which outlines how we use, keep secure and disclose personal information.

1.2. The Privacy Policy outlines:
(a) how and when Company collects personal information;
(b) how Company uses and discloses personal information;
(c) how Company keeps personal information secure, accurate and up-to-date;
(d) how an individual can access and correct their personal information; and
(e) how Company will facilitate or resolve a privacy complaint.

1.3. We recommend that you read and understand the Privacy Policy and keep it for future reference. If you require any clarification, you can contact us at the address at the end of this document.

1.4. Company takes your privacy seriously. In dealing with personal information, we comply with the relevant principles in the Privacy Act 1988 (Cth) (Privacy Act).

2. How we collect personal information

2.1. Directly from you

(a) Company tries to collect personal information about you directly from you. If we collect details about you from someone else, we will make you aware that we have done this and the reason for it.
(b) We primarily collect information about you when you use or request our services, or when you communicate with us by email, telephone, in writing or in person.
(c) We also collect information about you if you are providing services to us or if you apply for employment with us.
(d) As far as possible or unless provided otherwise under this privacy policy, we will collect your personal information directly from you.
(e) Depending upon the reason for requiring the information, some of the information we ask you to provide may be identified as mandatory or voluntary. If you do not provide the mandatory data or any other information we require in order for us to provide our services to you, we may be unable to provide or effectively provide our services to you.

2.2. Information collected by our websites

(a) When you visit our website, our web server may request your browser to create a cookie on your computer. A cookie is a small piece of information sent by our server to your browser by other sites.
(b) Our cookies do not contain personal information about users. However, cookies can identify a user’s browser. The cookies transferred by our website are used for such things as capturing information about a user’s web browser, controlling a pop-up window or enabling login access to password protected areas of the website.
(c) Our analytics systems use cookies to gather information regarding visitor activity to our websites. This is not used to identify you as an individual but is collated into aggregate results or classifications.
(d) Third parties may also use their own cookies to collect non-personal information about your activities on our website. This information, which may be combined with information acquired from third parties, may be used to serve you promotional material that we believe you might be interested in based on the content you have viewed.
(e) The cookies placed by third parties are subject to the privacy policies of these third parties. Company has no control over these cookies.
(f) If you do not wish to receive any cookies, you may set your browser to refuse them; go to the browser’s help menu for instructions. Please note that some features of the Company website may not work if cookies are disabled.

2.3 Social media

(a) Company has a number of social media pages, including Instagram and other social media pages, and comments posted on these are open to the public.
(b) If you upload content to these pages, you should be aware that your information is collected by the company operating the social media page. You should refer to the privacy policy of that social media company for information on how the organisation collects, uses and discloses personal information.

2.4. Site User Tracking Experience

(a) We may use tracking software to review and improve your experience of our website. In particular, we may use Facebook Pixel, Active Campaign, Google Analytics, YouTube.
(b) We may use advertising products, such as Remarketing with Facebook, Google Analytics and Google Analytics Demographics and Interest Reporting. Google Analytics collects data about our website traffic via Google Advertising cookies and anonymous identifiers.
(c) Data collected via these Google products is not linked with any personally identifiable information you submit while on our website.

2.5. Collection notices.

(a) At or before collecting personal information, we will take reasonable steps to notify you of: the information collected; why it is collected; whether collection is required or optional; consequences if you do not provide it; the organisations or types of organisations to which we usually disclose it; any likely overseas disclosures; how to access and correct your information; how to complain; and where to find our Privacy Policy.

3. What types of personal information do we collect?

3.1. Personal information

(a) Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable whether the information or opinion is true or not and whether the information is recorded in a material form or not.
(b) We will only collect personal information that is necessary for us to provide our products and services to you. This depends ultimately upon the purpose of collection and we have set out the general purposes of collection at paragraph 6.
(c) The type of information includes (but is not limited to) the following:
(i) your contact information such as full name (first and last), e-mail address, current postal address, delivery address (if different to postal address) and phone numbers;
(ii) your date of birth;
(iii) proof of your identity (including, but not limited to, driver’s licence, passport, birth certificate).

4. Use

4.1. We may use your personal information to:
(a) if required, the verification of your identity, including the verification of your date of birth, if applicable;
(b) provide our services to you, which shall include but is not limited to:
(i) the administration and management of our services, including charging, billing, credit card authorisation and verification, fraud and collecting debts; and
(ii) to offer you updates, or other content or products and services provided by us that may be of interest to you;
(c) publishing winner details;
(d) delivering prizes;
(e) conducting sanctions, fraud, bot and duplicate-account checks;
(f) disclosing information to regulators where required;
(g) sending service, account, renewal, payment and promotion-related messages;
(h) operating cookies, pixels and analytics tools;
(i) managing social-media, influencer and advertising campaign;
(j) conduct evaluations of our services;
(k) subject to your express consent, publish success stories based on the services we have provided and de-identify you if you request;
(l) contact individuals for feedback on our services; and
(m) assist us to perform our corporate and contractual obligations.

4.2. We may also use or disclose your personal information and in doing so we are not required to seek your additional consent:
(a) when it is disclosed or used for a purpose related to the primary purposes of collection detailed above and you would reasonably expect your personal information to be used or disclosed for such a purpose (secondary use);
(b) if we reasonably believe that the use or disclosure is necessary to lessen or prevent a serious or imminent threat to an individual’s life, health or safety or to lessen or prevent a threat to public health or safety;
(c) if we have reason to suspect that unlawful activity has been, or is being, engaged in; or
(d) if it is required or authorised by law or formally requested by a statutory or regulatory authority.

4.3. You consent to the above use of your personal information.

4.4. Direct Marketing
(a) You expressly consent to us using your personal information, including any email address you give to us, to provide you with information and to tell you about our products, services or events or any other direct marketing activity (including third party products, services, and events) which we consider may be of interest to you.
(b) If at any time, you do not wish to receive any further direct marketing communications from us, you may ask us not to send you any further information about products and services and not to disclose your information to other organisations for that purpose. You may do this at any time by using the “unsubscribe” facility included in the email or by contacting us via the details set out at the end of this document.
(c) If we use your personal information for direct marketing, we will ensure we comply with our obligations under the Do Not Call Register Act 2006 and the Spam Act 2003.
(d) We do not use sensitive information to send you direct marketing communications without your consent.

5. How do we store your personal information?

5.1. Our website is hosted in Australia. In addition, web traffic information we collect, such as data collected by Google Analytics may be stored overseas.

5.2. Company holds personal information on databases, electronic and hard copy files.

6. Who do we disclose personal information to?

6.1. Personal information held by Company is disclosed in accordance with the Privacy Act.

6.2. Disclosure to contractors and professional advisors
(a) Company may disclose your information to contractors to whom we outsource certain functions or which provide services to us, such as, our business advisers and auditors.
(b) We take all reasonable measures with our contractors and business advisors ensure they comply with the privacy standards set out in the Privacy Act and any relevant state and territory legislation.

6.3. Where disclosure is required or authorised by law, courts or government departments
(a) Company may also disclose personal information in circumstances where it has statutory obligations or is otherwise required to do so by law, a court or a government department (including the Department of Health).
(b) We do not supply, sell or rent the personal information we collect to unrelated third parties for the purpose of marketing those third parties’ products or services.

7. Overseas disclosure

7.1.Company does not disclose any personal information to overseas entities. However, web traffic information we collect, such as data collected by Google Analytics may be stored overseas.

8. Protection and security

8.1. At Company, privacy is paramount to our business and we take preserving and protecting a person’s identity very seriously and it is a key responsibility and right of all our staff, customers and partners.

8.2. We have taken steps to help ensure your personal information is safe. You will appreciate, however, that we cannot guarantee the security of all transmissions or personal information, especially where the Internet is involved.

8.3. Notwithstanding the above, we will take reasonable steps to:
(a) make sure that the personal information we collect, use or disclose is accurate, complete and up to date;
(b) protect your personal information from misuse, loss, unauthorised access, modification or disclosure both physically and through computer security methods; and
(c) destroy or permanently de-identify personal information if it is no longer needed for its purpose of collection.

8.4. However, the accuracy of personal information depends largely on the information you provide to us, so we recommend that you:
(i) let us know if there are any errors in your personal information; and
(ii) keep us up-to-date with changes to your personal information (such as your name or address).

8.5. We maintain the confidentiality and security of personal information by restricting access to only those staff and service providers with a legitimate need to access it.

8.6. Security measures are in place to prevent the misuse, unauthorised access, modification or disclosure of personal information.

9. Access and correction

9.1. You are entitled to have access to any personal information relating to you which we possess, except in some exceptional circumstances provided by law (e.g. secrecy provisions under the anti-money laundering and counter terrorism financing laws). You are also entitled to edit and correct such information if the information is inaccurate, out of date, incomplete, irrelevant or misleading. If you make an access request, Company will ask you to verify your identity and to specify what information you require. We may ask the reason for your request so we can assist you most effectively. However, you are under no obligation to provide a reason if you do not wish to.

9.2. You can seek access to your personal information held by us and/or seek correction of that personal information by contacting the Company Privacy Officer on the contact details set out in paragraph 11.

9.3. Any person receiving direct marketing from us can request that no further direct marketing be sent by contacting us by telephone, mail or email to unsubscribe from our products, services or communications.

10. Consent

10.1. You agree to the terms of this privacy policy when you continue to use our website or by accepting the terms of our terms and conditions of our services, which refer to this Privacy Policy.

10.2. We reserve the right to modify the Privacy Policy as our business needs require. We will notify you of such changes (whether by direct communication or by posting a notice on our website), after which, your continued use of our products, services or website or your continued dealings with us shall be deemed to be your agreement to the modified terms. If you do not agree to our continued use of your personal information due to the changes in our privacy policy, please contact us via the details set out at the end of this document.

11. Complaints

11.1. If you believe that there has been a breach or potential breach of this Privacy Policy or the privacy legislation, please contact Company on [email protected]

11.2. We take breaches seriously and have procedures to help identify and resolve a breach, potential breach or complaint as quickly as possible.

11.3. You will be notified of the process for dealing with the breach or potential breach. Your complaint will be thoroughly investigated and a response provided within 30 days.