Privacy Policy

 

 

This Privacy Policy ("Policy") is designed to govern the collection, use, disclosure, and safeguarding of personal information by Club Community Pty Ltd, a sports apparel drop shipping enterprise registered in Australia, with manufacturing operations in various jurisdictions across Asia. As part of our commitment to ensuring the privacy and security of our valued customers' information, we have implemented practices that are in strict conformity with all applicable legal and regulatory requirements.

Being an entity that engages in both domestic and international transactions, we adhere to the Privacy Act 1988 (Cth) of Australia, the Australian Privacy Principles (APPs), as well as relevant Asian data protection regulations and other international laws and standards. Our operations are guided by the principles of transparency, accountability, and integrity, recognizing the importance of privacy rights in an increasingly interconnected global marketplace.

By accessing, browsing, or using our services, you acknowledge and agree to the terms and conditions outlined in this Policy. This Policy delineates the manner in which we manage your personal information and outlines your rights and choices with regard to such information. It is essential that you read and understand this Policy before using our services.

We encourage you to contact our designated privacy officer as detailed in Section 14, "Contact Information," if you have any questions or concerns relating to this Policy or your privacy rights under Australian, Asian, or other international laws.

Club Community Pty Ltd reserves the right to modify this Policy to reflect legal, technological, or business developments. Your continued use of our services following any such changes signifies your acceptance of the updated Policy.

This Policy is effective as of August 3, 2023.

 

1. Information Collection

In the course of conducting business, Club Community Pty Ltd, may collect and process various types of personal information from customers and other stakeholders. This information collection is conducted in full compliance with the Privacy Act 1988 (Cth) of Australia, relevant Asian data protection laws, and other applicable international standards.

The categories of information that we may collect include, but are not limited to:

  1. Personal Identifiers: Such as names, email addresses, postal addresses, telephone numbers, and other contact information necessary for processing and shipping orders.
  2. Transactional Information: Including purchase history, payment details, and information related to the fulfillment of orders.
  3. Technical and Usage Information: Such as IP addresses, browser types, device information, and details related to your interaction with our website or mobile applications.
  4. Marketing and Communication Preferences: Including your preferences for receiving marketing from us and our third parties and your communication preferences.

The information is collected through various means, including:

  • Direct Interactions: Such as information provided by you when placing an order, creating an account, or contacting us for support or inquiries.
  • Automated Technologies: Such as cookies, log files, and other tracking technologies, as described in Section 6, "Cookies and Tracking Technologies."
  • Third-Party Sources: Including analytics providers, advertising networks, and other external platforms that may provide information about you.

The collection of this information is essential for the provision of our services, the processing of transactions, customer support, and the continuous improvement of our products and offerings. We ensure that all collection practices are proportionate and not excessive, consistent with the principles of necessity and minimization, as mandated by the relevant legal frameworks.

We affirm our commitment to ensuring that all personal information is collected with clear and unambiguous consent, where required, and in accordance with the lawful bases for processing. Where the provision of certain information is mandatory, failure to provide such information may affect the availability or functionality of our services.

 

2. Use of Information

Club Community Pty Ltd collects and processes personal information with the utmost care and in full compliance with applicable laws in Australia, and other relevant jurisdictions. The use of information is aligned with the purposes for which it was collected and is strictly limited to legitimate business interests. Specifically, the information may be used for the following purposes:

  1. Order Processing and Fulfillment: To process, confirm, fulfill, and deliver orders, including managing payments, fees, and charges, and providing related customer support.
  2. Communication and Customer Service: To respond to inquiries, requests, or complaints, and to provide personalized customer service, including product support and warranty services.
  3. Marketing and Promotions: To provide marketing and promotional materials, subject to applicable consent and opt-out mechanisms, including newsletters, special offers, and targeted advertising.
  4. Website and Service Improvement: To analyze usage patterns, preferences, and feedback, facilitating the continuous improvement and personalization of our website, mobile applications, and overall customer experience.
  5. Legal Compliance: To comply with legal and regulatory requirements, including tax, export control, anti-money laundering, and other mandatory governmental obligations.
  6. Security and Fraud Prevention: To implement and maintain security measures, conduct audits, detect and prevent fraudulent activities, and ensure the integrity of our systems and transactions.
  7. Business Operations and Analysis: To manage our relationship with you, conduct internal analyses, audits, and quality control, and facilitate overall business administration and planning.

We adhere to the principles of data minimization and purpose limitation, ensuring that the information is processed only for the purposes stated or for compatible purposes in accordance with applicable laws.

In instances where personal information is to be used for purposes not expressly consented to or otherwise stipulated in this Policy, we will seek additional consent or provide notification as required by law.

Club Community Pty Ltd is committed to maintaining the highest standards of integrity and professionalism in our handling of personal information. Our practices are reflective of our respect for the privacy rights and interests of our customers, business partners, and other stakeholders.

 

3. Disclosure of Information

Club Community Pty Ltd recognizes the importance of maintaining the confidentiality and security of personal information. We disclose personal information only under specific circumstances, in compliance with applicable Australian, Asian, and international legal requirements, and in accordance with the principles laid out in this Privacy Policy.

The disclosure of personal information may occur in the following situations:

  1. To Our Subsidiaries and Affiliates: For purposes consistent with this Policy, including order processing, customer service, marketing, and business analysis.
  2. To Third-Party Service Providers: Such as payment processors, shipping and logistics partners, marketing agencies, and technology providers, who assist in fulfilling our contractual obligations and business functions. We ensure that these third parties adhere to strict confidentiality obligations and process information only on our behalf and under our instructions.
  3. For Legal and Regulatory Compliance: In response to lawful requests from governmental authorities, law enforcement, regulatory bodies, or as otherwise required to comply with legal obligations, including compliance with court orders or legal proceedings.
  4. In Connection with Business Transfers: Such as mergers, acquisitions, divestitures, or other corporate transactions involving part or all of our business assets, where personal information may be part of the transferred assets.
  5. To Protect Rights and Interests: Where necessary to protect our rights, property, safety, or the rights, property, or safety of our customers, employees, or others, including to detect, prevent, or address fraud, security, or technical issues.
  6. With Your Consent: In other situations where we have obtained your explicit consent or provided you with notice, such as sharing with strategic partners or other third parties for specific purposes.

 

4. International Transfers

Given the international scope of Club Community Pty Ltd's operations, including manufacturing in Asia and selling to Australian customers, personal information may be transferred, processed, and stored in countries outside of the jurisdiction in which it was originally collected. These international transfers are conducted in strict adherence to applicable legal frameworks governing cross-border data flows.

The international transfer of personal information may occur in the following contexts:

  1. To Our Subsidiaries and Affiliates: For centralized business operations, customer service, marketing, and other legitimate business purposes.
  2. To Third-Party Service Providers: Including but not limited to payment processors, logistics partners, and technology providers that facilitate our business operations across different jurisdictions.
  3. In Compliance with Legal Requirements: To comply with legal, regulatory, or governmental requests, or as required by applicable international agreements and treaties.
  4. For Other Lawful Purposes: As disclosed to you at the time of collection or with your explicit consent.

We take robust measures to ensure that international transfers are subject to appropriate safeguards, including:

  1. Compliance with Legal Frameworks: Such as the Australian Privacy Principles (APPs), the General Data Protection Regulation (GDPR) for transfers to the European Economic Area (EEA), and other relevant Asian and international data protection regulations.
  2. Implementation of Standard Contractual Clauses (SCCs): Ensuring that data recipients are contractually obligated to provide a level of protection equivalent to that required under applicable privacy laws.
  3. Engagement with Certified Entities: Where possible, we work with entities that have demonstrated compliance with internationally recognized privacy frameworks and certifications.
  4. Regular Monitoring and Assessment: Continuous assessment of our international transfer practices to ensure alignment with evolving legal requirements and industry standards.

Club Community Pty Ltd is committed to upholding the highest standards of privacy and data protection in all cross-border data transfer activities. We recognize the inherent complexities and responsibilities associated with international data flows and strive to maintain transparency, accountability, and legal compliance in all our practices.

 

5. Cookies and Tracking Technologies

Club Community Pty Ltd employs various cookies and tracking technologies on our website and mobile applications to enhance user experience, provide personalized content, and analyze web traffic and user behavior. This practice is conducted in accordance with applicable Australian, Asian, and international laws, and with transparency and respect for individual privacy.

Types of Cookies and Tracking Technologies

  1. Strictly Necessary Cookies: Required for the basic functionality of our website, including navigation, shopping cart features, and access to secure areas.
  2. Performance Cookies: Used to gather information about how users interact with our website, helping us improve performance and user experience.
  3. Functional Cookies: Allow us to remember user preferences, such as language settings and login details, providing a more personalized experience.
  4. Targeting and Advertising Cookies: Employed to deliver tailored advertising and promotions, both on our website and third-party platforms, based on user interests and browsing history.
  5. Analytics and Third-Party Tools: Utilized in collaboration with third-party analytics providers to understand user behavior, demographics, and engagement with our online services.

Purpose and Use

We use these technologies for various purposes, including:

  1. Enhancing User Experience: Providing personalized content, remembering preferences, and facilitating seamless navigation.
  2. Marketing and Advertising: Delivering targeted advertisements and measuring the effectiveness of our marketing campaigns.
  3. Analyzing and Improving Services: Collecting aggregated data to identify trends, improve website functionality, and enhance our product offerings.
  4. Security Measures: Detecting and preventing fraudulent activities and ensuring the integrity of our online services.

Consent and Control

Your consent will be sought for the use of non-essential cookies and tracking technologies, in accordance with the relevant legal requirements. Users have the ability to manage preferences, opt-out of non-essential cookies, or disable cookies altogether through their browser settings.

We provide clear information and access to user controls within our Cookie Policy, linked on our website, allowing users to make informed choices regarding their privacy preferences.

Third-Party Cookies

We may engage third-party service providers, including advertising and analytics partners, who may set and access cookies on your device through our website. Such third-party cookies are governed by the respective privacy policies of these third parties.

clubcommunity.com.au takes diligent measures to ensure that all cookies and tracking technologies are implemented in accordance with legal obligations, ethical standards, and industry best practices.

 

6. Children's Privacy

Club Community Pty Ltd is committed to safeguarding the privacy of children and recognizes the importance of providing additional protections for children who access or use our online services. Our website, products, and services are not directed towards children under the age of 13 (or the relevant age of consent in different jurisdictions), and we do not knowingly collect personal information from children under this age without parental or guardian consent.

 

7. Security Measures

At Club Community Pty Ltd, we place paramount importance on the security of personal information. We have implemented comprehensive and robust security measures designed to protect your information against unauthorized access, alteration, disclosure, or destruction. Our security practices align with legal requirements and recognized industry standards in Australia, Asia, and across other international jurisdictions.

Technical Safeguards

  1. Encryption: We utilize strong encryption protocols to secure data during transmission and while at rest.
  2. Firewalls and Intrusion Detection Systems: Advanced security technologies are employed to detect and prevent unauthorized access to our networks and systems.
  3. Secure Development Practices: Our systems are designed and developed in adherence to best practices in security engineering.

Organizational Measures

  1. Access Controls: Strict access controls are enforced to ensure that only authorized personnel have access to personal information. Access rights are regularly reviewed and updated.
  2. Training and Awareness: All staff members receive regular training on privacy and security awareness to foster a culture of data protection.
  3. Vendor Risk Management: Third-party service providers are assessed for compliance with our security standards and legal obligations.

Physical Safeguards

  1. Secure Facilities: Our data centers and physical premises are equipped with state-of-the-art security measures, including surveillance and controlled access.
  2. Equipment Security: Adequate measures are taken to secure all devices that may store or process personal information.

Incident Response and Management

In the unlikely event of a security breach or incident, we have an established incident response plan to promptly identify, contain, and remediate the situation. We will notify affected individuals and relevant authorities, as required by law, and take all necessary steps to minimize any potential harm.

Continuous Improvement

Our security measures are subject to ongoing review and enhancement to reflect technological advancements and evolving threats. We remain committed to continuous improvement in our security posture.

 

8. Data Retention

Club Community Pty Ltd is committed to retaining personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable legal, regulatory, or contractual obligations. Our data retention practices are governed by a well-defined policy that respects individual privacy rights and complies with all relevant legal frameworks in Australia, and other international jurisdictions.

Retention Periods

Personal information is retained based on the following criteria:

  1. Legal Obligations: Retention in compliance with statutory requirements, including taxation, financial reporting, and other regulatory mandates.
  2. Contractual Necessities: Retention for the duration of our contractual relationship with customers, suppliers, or other business partners.
  3. Legitimate Business Interests: Retention for periods that enable us to provide services, support, product improvements, and maintain an accurate business record.

Secure Disposal and De-identification

Once the applicable retention period expires, or when personal information is no longer required:

  1. Secure Disposal: We implement secure disposal methods, ensuring that the data is permanently erased and cannot be reconstructed.
  2. De-identification: Alternatively, we may de-identify the data, removing all personally identifiable elements, so that the information can no longer be linked to an individual. Such de-identified data may be retained for statistical or analytical purposes.

Special Considerations

In some circumstances, we may retain personal information for extended periods, such as:

  1. Legal Proceedings or Investigations: If we are involved in litigation or a regulatory investigation, relevant data may be retained until the resolution of the matter.
  2. Consent: Where we have obtained explicit consent for extended retention.

Data Minimization

We adhere to the principle of data minimization, collecting only the information necessary for the intended purpose and retaining it for no longer than required.

Your Rights

You may have the right to request information about how long your personal data will be retained, and in some cases, request deletion of your data in accordance with applicable laws.

 

9. Your Rights and Choices

At Club Community Pty Ltd, we respect and uphold your rights regarding your personal information. This section outlines the choices and rights available to you under applicable Australian, Asian, and international privacy laws.

Access and Correction

  1. Right to Access: You have the right to request access to the personal information we hold about you and to obtain a copy of that information.
  2. Right to Correct: If you believe that any personal information we have about you is incorrect or incomplete, you may request correction or updating of that information.

Erasure and Restriction

  1. Right to Erasure: You may have the right to request the deletion of your personal information in certain circumstances.
  2. Right to Restriction: You can request that we restrict the processing of your personal information under specific conditions.

Data Portability

  1. Right to Data Portability: You may have the right to receive your personal information in a structured, commonly used, and machine-readable format, or have it transmitted directly to another organization, where technically feasible.

Object to Processing

  1. Right to Object: You may have the right to object to the processing of your personal information for specific purposes, such as direct marketing.

Consent and Withdrawal

  1. Right to Consent: Where we rely on your consent to process personal information, you have the right to provide or withhold consent.
  2. Right to Withdraw Consent: You may withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

Automated Decisions

  1. Right to Object to Automated Decisions: You may have the right to object to decisions based solely on automated processing, including profiling, if it produces legal effects concerning you or similarly significantly affects you.

 

10. Third-Party Links and Services

Club Community Pty Ltd’s website and services may contain links to third-party websites, applications, and services that are not operated by us. This section outlines our practices and responsibilities regarding such third-party interactions.

Links to Other Websites

Our website may include links to external websites for your convenience and information. These links do not signify an endorsement by Club Community Pty Ltd. Please be aware that we do not control these third-party websites, and their privacy practices may differ from ours. We encourage you to review the privacy policies of any third-party websites before submitting any personal information to them.

Third-Party Services

We may engage third-party service providers, vendors, or partners to perform functions and provide services on our behalf, such as payment processing, marketing, analytics, or other operational activities. These third parties may have access to your personal information as necessary to perform these functions, but they are obligated to comply with strict confidentiality obligations.

Social Media Features

Our website may include social media features, such as Facebook "Like" buttons or Twitter "Tweet" buttons. These features may collect your IP address and the page you are visiting on our site and may set a cookie to enable the feature to function properly. Your interactions with these features are governed by the privacy policy of the company providing them.

Advertising and Analytics Partners

We may work with advertising and analytics partners to deliver targeted advertisements or to understand usage patterns and trends. These third parties may use cookies or other tracking technologies to collect information about your activities on our website and other websites.

Responsibility and Liability

While we strive to work with reputable third parties, Club Community Pty Ltd is not responsible or liable for the privacy practices, policies, or content of third-party sites or services. We encourage you to exercise caution and review their privacy statements carefully.

11. Changes to Privacy Policy

At Club Community Pty Ltd, we recognize that privacy is an evolving area, and as such, our Privacy Policy may need to change to reflect updates in our practices, services, or relevant legal requirements.

 

12. Compliance with Specific Laws and Regulations

Club Community Pty Ltd is committed to operating in full compliance with all applicable laws and regulations governing data protection and privacy. This section outlines our adherence to specific legal frameworks and our approach to ensuring compliance.

Australian Laws

We comply with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth), as well as other relevant state and territory privacy laws, as applicable.

Asian Laws

We adhere to the relevant privacy and data protection laws in Asian jurisdictions where we conduct business, produce garments, or engage with customers or suppliers. This includes compliance with applicable provisions and principles in each specific country or region.

European Union (if applicable)

If we offer products or services to individuals in the European Union, we comply with the General Data Protection Regulation (GDPR) and other related laws and regulations.

United States (if applicable)

If we engage with customers or partners in the United States, we adhere to applicable federal and state privacy laws, including the California Consumer Privacy Act (CCPA), if relevant.

Other International Obligations

We recognize and comply with other international laws and treaties that may apply to our operations, including adherence to cross-border data transfer frameworks and agreements.

Monitoring and Assessment

We regularly review our policies, practices, and procedures to ensure ongoing compliance with all relevant laws and regulations. This includes conducting privacy impact assessments, engaging legal counsel, and collaborating with regulatory authorities as needed.

Reporting and Transparency

We maintain transparency in our privacy practices and are committed to timely reporting and disclosure as required by law, including notifying regulators and individuals of any data breaches in accordance with legal obligations.

 

13. Contact Information

If you have any questions, comments, concerns, or requests regarding this Privacy Policy or our handling of your personal information, you can reach us through the contact information placed on our website.