Privacy Policy

 

Sogo Sports Pty Ltd (ACN 605 668 228) and its related bodies corporate (we, us or our) are committed to protecting the privacy of your personal information. We collect, use, store, manage and disclose all personal information in accordance with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth).

About this Privacy Policy

This Privacy Policy explains how we collect, use, manage and disclose personal information and how you can contact us if you have queries about our management of your personal information. The Privacy Policy applies to use of the website www.sogo.golf and any other website created or operated by us from time to time (the Sogo Website) and to any application (including the Sogo Golf App), software, services or tools (the Sogo Application). By registering an account with us, accepting a licence to use our software or application, using our services or tools or submitting personal information to us, you accept the terms of this Privacy Policy, and consent to our use, collection, disclosure and retention of Personal Information as described in this Privacy Policy.

Personal Information is information that identifies you or information by which your identity can reasonably be ascertained. You are welcome to print or download this Privacy Policy at any time at www.sogo.golf/privacy-policy.

If you do not agree to any provisions in this Privacy Policy, you should not disclose any personal information to us.

What kind of Personal Information do we collect and hold?

In order to provide you with our goods and services, we are likely to collect a wide range of Personal Information about you. The type of Personal Information we collect generally includes your name and contact details such as your address, email address, telephone or mobile numbers, as well as information about your dealings with us or other users of our services.

We do not generally collect “sensitive information” as defined by the Privacy Act 1988 (Cth) (such as information about ethnic origin, religious or political views, health information, tax file numbers etc) from you.

How do we collect information?

Non-Personal Information

When you only browse our website, we do not collect your Personal Information. Our internet service provider makes a record of your visit and records information such as your server address; your internet protocol address; the pages you accessed and documents downloaded; the previous site you visited; and the type of browser being used. This information assists us to analyse web traffic and improve your site navigation experience.

We do not identify you or your browsing activities except, in the event of an investigation, where a law enforcement agency may exercise a warrant or other such power to inspect the internet service provider's server logs.

We may also obtain anonymous information from our website using a technology called “cookies”. Cookies are small text files which are transferred to the hard drive of your computer to provide additional functionality to our website and to help us analyse usage of our website. Cookies can identify your web browser but not you. If you wish, you can disable your web browser from accepting cookies. If you disable cookies, you will still be able to access our website but may not be able to access all of our services.

Personal Information

As a part of offering our goods and services to you through the Sogo Website or any Sogo Application, including our online ordering facility, it is likely that we will collect Personal Information about you such as:

  •  your name and title;
  •  your address;
  •  your date of birth;
  •  your Golflink number;
  •  your handicap information;
  •  your phone number and email address;
  •  reference details of you or your organisation related to the services we provide to you;
  •  your credit card information;
  •  location based information relating to your position at or within a golf course; and
  •  any further information, instructions or comments given by you.

We do not store credit card information obtained through the Sogo Website, any Sogo Application or other means; rather this information is provided to our bank, financial institution or relevant merchant facility provider to process the relevant transaction.

We may collect Personal Information that you choose to give us via telephone, mail, the Sogo Website, any Sogo Application, printed or online forms or e-mail, for example:

  •  when you purchase, access or subscribe to our goods or services;
  •  when you subscribe to our mailing lists;
  •  when you complete an entry form for a sanctioned golf course or tournament/competition;
  •  when you knowingly give us information by telephone or via our website, including e- mail;
  •  if you register an account and provide registration details; or 
  • if you complete an online survey or submit an online enquiry.

In certain circumstances, you may also be asked to provide us with specific information about yourself in order to use or access the goods or services, such as score cards, handicaps, tournament results and demographic information including age, gender, and level of golfing experience.

You have the option of not disclosing Personal Information to us or to use a pseudonym when dealing with us in relation to a particular matter, unless it is, in our view, impractical for us to deal with you that way or we are otherwise required by law or authorised by a court or tribunal to deal with you on an identified basis. If you choose to withhold any Personal Information, we may not be able to provide you with part or all of our goods or services.

There may also be occasions when we collect Personal Information (to the extent they are available) from publicly available sources, including social media platforms such as Facebook or Twitter. Sometimes, we may provide content and services on a range of platforms (including social media networks) with interactive features to which you may contribute, if you post your Personal Information in publicly accessible places or social media platforms, your Personal Information will become publicly available (subject to, where applicable, any privacy settings you have in place in social media platforms). We will not be responsible for the protection of Personal Information you choose to publish this way.

Children

We are committed to protecting the privacy needs of children and we encourage parents and guardians to take an active role in their children’s online activities and interests. If we discover that we have inadvertently collected any Personal Information from a child under the age of 15 we will delete that Personal Information as soon as possible. A parent or legal guardian can notify us of an inadvertent collection of Personal Information from a child under the age of 15 and request that we remove such information by sending an email to or by contacting us at the contact information below. Any such request must contain the child’s name and email address so we can locate such child’s Personal Information.

Rate and review

If you provide a review or rating for a product available on our website, you agree that we may publish part or all of your review or rating together with your first name and suburb.

How we use your information

We may use the Personal Information you provide to us for the purposes for which it was initially collected or purposes related to such initial purpose (if such purpose would be within your reasonable expectations). For example, to:

  •  provide you with our goods and services or access to our goods and services, including the delivery of any prizes you won in any Sogo competition;
  •  verify information or conduct audits in connection with our goods and services;
  •    if you have subscribed to our mailing list, sending you information about areas of specific interest;
  •  respond to your questions or requests;
  •  keep a record of our dealings with you and enable us to contact you when necessary;
  •  develop a data profile to enable us to tailor our services to you;
  •  to collate statistical information that does not personally identify you; and
  •  to communicate with you on behalf of official bodies, associations and golf clubs.

We may also use your Personal Information for purposes authorised by laws or regulations, such as to prevent or investigate alleged crime or fraud.

Direct Marketing

By supplying us your Personal Information, you give us permission to use your Personal Information to contact you to inform you about products and services we think would be of particular interest to you. This permission is not limited in time unless you choose to opt out by contacting us using the contact information provided below, or by utilising an ‘unsubscribe’ facility on a communication we send to you in which case we will take steps to ensure you do not receive any such direct marketing information in future.

How your information may be disclosed

We do not sell, rent, lease or provide your Personal Information to other entities unless outlined in this Privacy Policy. We may disclose your personal information where you have consented or when disclosure is necessary to achieve the purpose for which it was submitted (as outlined above).

In providing our goods or services, we may disclose your Personal Information to organisations that carry out functions on our behalf, or assist us to deliver our goods or services, such as our business associates, contractors, agents or service providers. These third parties may change from time to time. Some examples include:

  •  courier and postal service providers for delivering goods or prizes to you;
  •  technology service providers, such as internet service providers, data storage providers, and digital mail providers who send communications on our behalf;
  •  our professional advisers, accountants, lawyers and auditors; and
  •  sponsors or organisations that partner with us.

We will release the following Personal Information to other members or users of any Sogo Application or Sogo Website, official bodies, associations and golf clubs to the extent necessary for us to provide you with our goods and services:

  •  location based information relating to your geographic location at a given time;
  •  the date and time of your geographic location;
  •  your score cards;
  •  your handicap information;  tournament results; and
  • demographic information including age, gender, and level of golfing experience  

You agree that third parties which receive Personal Information from us may use and disclose the personal information subject to their respective privacy policies. We endeavour to take reasonable steps to enter into agreements with third parties that collect, store, disclose and retain personal information in accordance with the Australian privacy principles , except as otherwise required by law.

From time to time, we may provide third parties with information in the form of statistical representations about our users collectively and for the purpose of statistical analysis. Where we provide such information to third parties for this limited statistical purpose, we will not provide Personal Information in such a way that your identity may be obtained.

In addition, we may release your Personal Information under the following circumstances:

  •  when required to do so by a court or under applicable laws or regulation (for example, a subpoena) or where requested by a government agency;
  •  where we consider a company or an individual may be engaged in fraudulent activity or other deceptive practices that a governmental agency should be made aware of; or
  •  to appropriate persons, where your communication suggests possible harm to others. 

Transborder Disclosure

Personal Information may be stored, disclosed, processed in or transferred outside of Australia from time to time, including but not limited to the USA. The countries in which the Personal Information is received may not have data protection laws equivalent to those in force in Australia.

You acknowledge and agree to such international data and information transfers with respect to Personal Information. Clause 8.1 of the Australian Privacy Principles contained in Schedule 1 of the Privacy Act 1988 (Cth) provides that if we disclose Personal Information about an individual to an overseas recipient, then we must take such steps as are reasonable in the circumstances to ensure the overseas recipient does not breach the Australian Privacy Principles in relation to such information. An exception to this is if we obtain your consent. We intend to rely on this exception in the following way. Unless you notify us in writing to the contrary, you will be taken to have consented to the disclosure by us of Personal Information to overseas recipients on the basis that:

  •  clause 8.1 of the Australian Privacy Principles will not apply to such disclosure;
  •  the individual whose personal information is disclosed will not be able to seek redress under the Privacy Act 1988 (Cth);
  •  the overseas recipient may not be subject to any privacy obligations or to any principles similar to the Australian Privacy Principles;
  •  the individual may not be able to seek redress in the overseas jurisdiction; and
  •  the overseas recipient is subject to a foreign law that could compel the disclosure of personal information to a third party, such as an overseas authority.

We may provide links to third party websites within the Sogo Website or Sogo Application, for example, the websites of our sponsors, of Golf Australia Limited and Golf Link Partners PtyLimited. These linked sites are not under our control, and we do not accept responsibility for the conduct of companies the websites of which are linked to the Sogo Website or any Sogo Application. Before disclosing your Personal Information to any third parties on such websites we advise you to examine the terms and conditions of using that website and its privacy statement.

Security

We consider confidentiality of Personal Information collected from you to be of utmost importance. We store the Personal Information via a third party data provider. To prevent unauthorised access, disclosure or misuse, we have implemented procedures and installed equipment to safeguard the security and confidentiality of your information. We continually review these arrangements to ensure we are doing all that are reasonably and technically feasible at the time to protect your Personal Information. However, since no system is 100% secure or error-free, we cannot guarantee that your Personal Information is totally protected, for example, from hackers or misuse.

If you enter or upload Personal Information on our website, you should exercise due care to safeguard any passwords and usernames to access your Personal Information at our website created by you.

We will take reasonable steps to destroy or permanently de-identify any Personal Information from our systems which is no longer required by us.

How to access and amend information you provide

We strive to keep your Personal Information accurate, up-to-date and complete. Our policy enables you to find out what information we hold about you and correct that information if it is wrong.

If you become aware that any Personal Information we hold about you is incorrect or out-of- date, please let us know immediately. We will be happy to accept updated Personal Information in writing from the owner of that information at any time. However, in order to protect your privacy and security, we will take reasonable steps to verify your identity before granting you access or enabling you to make corrections of your Personal Information. Except where the Privacy Act provides otherwise, we reserve the right to recover any reasonable costs involved in providing extensive access to Personal Information, for example the cost of supplying information held in archives.

Our objective is to respond to any request to access personal information within a reasonable timeframe and no later than 30 days. We will endeavour to inform you if this timeframe is not achievable.

In some circumstances, we may not be in a position to grant access to your Personal Information, such circumstances include: 

  •    providing access is likely to pose a serious threat to the safety of an individual or the public;
  •  providing access is likely to unreasonably impact on the privacy of others;
  •  the request for access is frivolous or vexatious;
  •  providing access would reveal information which relates to existing or anticipated legal proceedings or otherwise impact on any negotiations;
  •  providing access is unlawful (including being unlawful as directed by a court or tribunal order) or is likely to impact on actions being taken in relation to alleged unlawful activities relating to our functions and activities; or
  •  granting access would impact on a commercially sensitive decision making process.

Changes to our Privacy Policy

Please note that this Privacy Policy may be updated or revised from time to time without notice and changes will apply immediately. Changes to this Privacy Policy will be published by posting an updated Privacy Policy on our website. Therefore, you should review our Privacy Policy regularly to ensure you are familiar with any changes.

Your continued use of our website or our services after any changes to this Privacy Policy are posted will be taken as your acceptance of those changes.

This Privacy Policy was last updated on 17th November 2015.

Contact us

If you have any questions about our Privacy Policy, or have a problem or complaint, please let us know. We will respond to a complaint as soon as possible, but within 10 working days, to let you know who is responsible for managing your complaint. We will also try to resolve the complaint within 30 days. When this is not possible, we will endeavour to contact you within that time to let you know how long it will take to resolve the complaint.

Our contact details are:

Privacy Officer

Sogo Sports Pty Ltd

280-290 Mann Street, Gosford, NSW, 2250

E-mail: privacy@sogo.golf

If you believe we have not adequately dealt with your complaint, you may complain to the Privacy Commissioner, whose contact details are found on their website http://www.oaic.gov.au/

 

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