1. Introduction

WOSUP Australia Pty Ltd (ACN 632 688 987) (“WOSUP”, “us” or “we”) is committed to protecting your personal information in accordance with the Australian Privacy Principles (APPs) set out in the Privacy Act 1988 (Cth) (Act). WOSUP provides online services via its website www.wosup.com.au and www.wosuprewards.com.au (Websites) and its mobile applications (apps) including for our platform WOSUP Rewards (Online Services)

This Privacy Policy sets out how we handle personal information to comply with our obligations.

We may amend this Privacy Policy from time to time. Reasonable notice of any material changes to the Privacy Policy will be provided before the changes takes effect.

2. What personal information do we collect?

This Privacy Policy uses the definition of personal information which is provided in the Act. The types of personal information which WOSUP collects will depend on the circumstances of its collection and the nature of your particular dealing with us.

2.1. Information collected in general dealings

Information we may collect about you in general dealings includes:

• your name, email address, mobile number, gender, date of birth and post code, favourite teams, events attended, offers redeemed.
• information collected when you use our Online Services including your IP address or the MAC address associated with your wireless device;
• information when you make an enquiry or a complaint, whether via our Online Services, in person, at an event or by otherwise contacting us.

2.2. Information collected relating to venue operations

In the case of matters relating to operations – for example, processing applications for an event day pass; entering into commercial arrangements with our partners, such as venue operators, ticketing agencies and promoters; implementing and maintaining stadium or venue security measures; we may collect additional personal information, including sensitive information, in order to manage and administer our business systems and comply with our legislative obligations. This information may include (depending on the circumstances):

• your place of birth, and gender;
• your photo and/or staff identification card details (for example if required in connection with staffing and venue security arrangements);
• your job title; and/or
• your address.

2.3. Information collected with WOSUP Rewards and marketing related matters

In the case of retail and marketing-related matters, we might collect additional information such as:

• your preferences concerning types of products or services;
• the products you purchased at venues and/or services used at events including amount spent on products/services;
• how often you visit events;
• the frequency of use of certain types of products or services;
• the methods of attending events for example transport;
• the number of people attending events with you;
• feedback you post on social media about WOSUP;
• your postcode ; and
• your use of our Website, our mobile apps and social media platforms you use.

2.4. Information collected relating to WOSUP systems

We will collect information as agreed by ticketing agencies, sporting codes, clubs and/or promoters in connection with tickets you have booked to attend an event.

We may also collect your personal information from third party retailers and commercial partners within the venue for the purpose of facilitating your efficient use of the WOSUP system in the venue.

If your personal information is not collected by WOSUP as set out above, you will not be able to join and/or access the benefits offered on WOSUP Rewards.

3. How do we collect information?

Personal information will be collected either directly from you when you scan the WOSUP cup and join WOSUP Rewards or have agreed to provide your ticketing information to us through third party ticketing providers.

Other ways in which we collect personal information may include:

• through our Online Services, including when you logon to WOSUP Rewards and accept our terms and conditions;
• through the use of cookies and other tracking systems online (please see “Cookies and other online tracking systems” for more information);
• when you contact us, including by phone, email or social media;
• when you access or use our WOSUP Rewards platform;
• when you subscribe to any WOSUP newsletters, participate in surveys, questionnaires, requests for feedback, competitions or promotions or become a member of any WOSUP loyalty programs;
• when you submit your resume or an application, or participate in interviews or testing, for employment or contracting opportunities at WOSUP.

There may be occasions when we collect personal information about you from a third party, such as:

• a service provider;
• a customer ticketing partner, sporting code, club and / or promoter;
• referees or recruiters (if you are a job applicant); and/or
• a publicly available source.

4. Cookies and other online tracking systems

WOSUP uses cookies and other tracking systems on our Websites and through our Online Services. A cookie is a very small text file which is stored on your computer’s hard drive when you first visit the Websites. This information may be used in a number of ways, such as to identify repeat visitors to our Websites, areas of interest on our Websites and to analyse visiting patterns. WOSUP does not use cookies to obtain personal information.

You can disable your web browser from accepting cookies. If you do so, you can still access the Websites, but not all services, transactions or functions may be available.

Where devices connect, or individuals log on, to the WOSUP Rewards platform, we may collect aggregated information regarding usage and ongoing event attendance. We may also collect some personal information with your consent.

WOSUP partners with third party advertising organisations to display advertising on WOSUP’s digital products. If you respond in the affirmative (yes) to a particular sponsored or third-party advertiser’s question, we will be supplying your contact details and cookie data to that sponsor only, This sponsor may use this information to contact you or display relevant offers on their own or a 3rd party website.

WOSUP’s partners may use cookies and web beacons to collect information, which is not personal information, about your internet activities to provide you with targeted advertising based upon your interests.

5. Location information from mobile devices

Where a device (for example mobile telephones, tablets or laptops) is identifiable by Wi-Fi or Bluetooth networks of venues using WOSUP’s cups, we or our third-party service providers may collect data relating to the device identification code and its location. We use this data to better understand space utilisation and passenger flows for security purposes and in order to improve the customer experience and our services.

6. What if you refuse to supply information?

You are not obliged to provide us with your personal information. However, failure to do so may mean that we are unable to transact with you, as you may be unable to join the WOSUP Rewards program. We may also be unable to process any application for employment with us or engagement as a contractor, and issue you a security pass or permit.

7. Dealing with WOSUP anonymously or using a pseudonym

In many cases, we will need certain personal information to respond to queries, or to transact with you, such as contact details, or other information as set out in this Privacy Policy.

You may access the Websites on an anonymous basis or contact WOSUP with a general query anonymously or using a pseudonym. However, where you are engaging in services from us, you will ordinarily not be able to complete the entry or participate in the offer without providing us with certain personal information.

8. How does WOSUP use your personal information?

Personal Information collected by WOSUP is generally held and used as necessary for purposes directly related to our functions and activities including in any of the following ways:

• to provide you with our Online Services and to help us develop, improve, manage and administer all of the services we provide to you, including WOSUP Rewards, competitions, offers, money can’t buy experiences, gamification, discounts, seat upgrades, and the conduct of surveys, questionnaires and requests for feedback;
• to ensure that our business systems are functional and reliable, which may include fulfilling legal obligations;
• to process applications effectively for the issue of authorities, licenses, passes, permissions and permits;
• to assess whether or not any authorities, licenses, passes, permissions and permits should be cancelled or suspended;
• to conduct marketing activities including market research, customer profiling, customer insights and targeted marketing activities (such as through social media and other online channels) and communicating information about our products and services (with your consent, if required);
• as part of the investigation and analysis of incidents or occurrences (including potential incidents and occurrences) which occur on or at WOSUP or events we are facilitating via our systems;
• to investigate, respond to and defend claims made against, or involving, WOSUP;
• to comply with our legal obligations;
• to contract with individuals (such as verifying your identity or communicating with you); and
• to enforce a contract or agreement which WOSUP has with you.

We may also use your personal information for related purposes such as to notify you of services, special offers, opportunities, products or benefits which are being offered by WOSUP or any of our strategic partners, sporting clubs, codes, promoters, clients or associated organisations. We may do this via various marketing channels such as email, SMS, online, mail or over the phone (with your consent, if required).

If you do not wish to receive such information, then you need to inform us. Contact details are provided at the end of this Privacy Policy.

We will not use your personal information for purposes other than those set out in this Privacy Policy without your consent or unless that use is authorised or permitted under the Act or another law.

9. Opting in or out

At the point we collect information from you, you may be asked to “opt in” to consent to us using or disclosing your personal information other than in accordance with this Privacy Policy or any applicable law. For example, you may be asked to opt-in to receive further information or communications from our advertisers and supporters which do not fall into one of the categories described above.

You will be given the opportunity to “opt out” from receiving communications from us in accordance with this Privacy Policy. For example, you will be given the option to unsubscribe from e-newsletters and other marketing or promotional material sent by us. You may “opt out” from receiving these communications by clicking on an unsubscribe link at the end of the email or via the other unsubscribe methods we communicate in the message.

You can also let us know that you would like to “opt out” by contacting us using the contact details set out in the “Contacting Us” section. In your request, please indicate that you wish to stop receiving marketing communications from us.

9a. Data Deletion Request

Users have the right to request the deletion of their personal data in accordance with applicable data protection laws.

To submit a data deletion request, please contact us via privacy@wosup.com.au, contact form on our website, or postal address and include the subject line “Data Deletion Request.

In your request, please provide sufficient information to identify yourself and the data in question. Upon receiving your request, we will verify your identity and take reasonable steps to delete your personal data from our systems, unless we are required by law to retain certain information. We will confirm the completion of the deletion process or inform you of any applicable retention obligations within 30 days of your request.

10. When does WOSUP disclose personal information to third parties?

WOSUP will only disclose your personal information to persons or bodies external to WOSUP where authorised or permitted by the Act, including in the following circumstances:

• where you consent to the disclosure;
• to our contractors or service providers (for the purpose of the services which they provide) so that we can store information, complete a transaction on your behalf, provide you with a service that you have requested or seek your participation in offers, competitions, discounts, surveys, questionnaires or requests for feedback;
• to commercial partners which partner with WOSUP (such as venues and ticketing agencies) and to organisations (such as sporting bodies) for the purposes of facilitating our WOSUP Rewards systems;
• where required by law, including under an order issued by a court or tribunal; or
• for law enforcement or safety purposes, or operational purposes for which the information was collected.

11. Disclosure of your personal information overseas

WOSUP may disclose personal information to recipients who are located outside Australia, including, for example, to its third-party service providers and to international brands or sponsors with whom we partner, who are either located or operate their business overseas. The recipients of such personal information may be located in the United States of America, Ireland, Canada, Japan, Germany, France, Belgium or the United Kingdom.

12. How does WOSUP protect your personal information?

WOSUP has implemented security measures which are designed to provide reasonable protection against the misuse, interference, or loss of your personal information and to prevent unauthorised access, modification or disclosure of your personal information. These measures include:

• network segregation to separate systems of different functions and sensitivity;
• firewalls protecting the network and access control mechanisms;
• secured locations with limited access for information stored as hard copy;
• confidentiality provisions in all our employment and service contracts; and
• registers which are maintained of all visitors to any part of our premises where personal information may be stored, and such visitors are required to be accompanied by a member of our staff at all times.

The WOSUP Rewards platform and the WOSUP Rewards database are held on Amazon Web Services in Australia.

WOSUP also employs secure methods for the destruction or de-identification of personal information, which is undertaken when permitted by law and where such information is no longer required by us.

13. What rights do you have to access and correct your personal information held by us?

WOSUP takes reasonable steps to ensure that all personal information that it collects or uses is accurate, up to date and complete.

You may request access to, and correction of, any of your personal information held by WOSUP, and such access will be provided, and corrections made except where WOSUP refuses such requests in accordance with the APPs.

All requests for access and/or correction will be processed within a reasonable time. In some situations, you may be able to access and correct your personal information directly through our Online Services. Otherwise, please contact our Privacy Officer by email, phone or mail, if you want to access or correct your personal information.

There is no application fee for making a request to access your personal information. However, we may charge an administrative fee for the provision of information in order to recover costs. If WOSUP does not agree to provide you with access to your personal information or to amend or annotate the information that we hold about you, you may seek a review of our decision.

If WOSUP does not agree to make the requested changes to your personal information, you may make a statement about the requested changes and we will attach it to your record.

14. Third party websites

WOSUP may provide links to third party websites on its Websites or through its WOSUP Rewards platform, or allow third party advertising on its Websites or on its WOSUP Rewards platform.

Once you click on a link to a third party’s website or on a third party advertisement, we are not responsible for how your personal information is collected and used on such sites. This Privacy Policy does not apply to any third party websites.

Please see the privacy policy of the relevant website for information on how your personal information will be dealt with on that site.

15. Complaints

If you have any complaints about a breach of the APPs by WOSUP in relation to your personal information, please contact us by writing to the email or mailing address below.

Complaints will be reviewed by WOSUP’s Privacy Officer and we will respond as soon as we can. A response will usually be provided within 30 days of receipt.

If, after following the procedure outlined above, you believe that your complaint has not been satisfactorily addressed by WOSUP, you can make a complaint to the Office of the Information Commissioner (OAIC) at www.oaic.gov.au.

16. Contacting Us

If you have any questions or concerns about this Privacy Policy or our information handling policies you should contact us at:

Privacy Officer
WOSUP Australia Pty Ltd
PO Box 254
Annandale NSW 2038

E-mail: privacy@wosup.com.au

Last updated: 1 March 2022