PRIVACY
POLICY.

This document sets out the policy of Padelground and its related entities, relating to the privacy of your personal information (Privacy Policy). Padelground is committed to protecting the privacy of the personal information it collects and receives. Padelground is bound by the Australian Privacy Principles (APP) contained in the Privacy Act 1988 (Cth) (Act). This Privacy Policy applies to all your dealings with Padelground whether at one of the branded clubs, head office or via the Padelground website (www.padelground.com.au).

This Privacy Policy seeks to explain:

• ▸the kinds of personal information Padelground collects & holds;
• ▸how Padelground collects and holds your personal information;
• ▸why Padelground collects, holds, uses and discloses your personal information;
• ▸how you may access and seek the correction of your personal information as held by Padelground;
• ▸how you may complain about a breach of the APPs or a registered APP code (if any) that Padelground are bound by, and how Padelground will deal with such a complaint; and
• ▸if Padelground is likely to disclose your personal information to overseas recipients and the countries in which such recipients are likely to be located (if it is practicable to specify those countries in this policy).

By using Padelground website www.padelground.com.au, completing any membership application forms, personal trainer forms, competition entry forms and filling any forms in the franchisee recruitment process, you accept this Privacy Policy and expressly consent to Padelground collection, use and disclosure of your personal information in the manner described in this Privacy Policy.

Padelground only collects personal information (being information that identifies or could reasonably identify an individual) where Padelground considers it to be reasonably necessary for Padelground's services, functions and activities. Padelground collects personal information to deliver our products and services to members including in circumstances when:

• ▸processing and managing membership enrolments;
• ▸facilitating members & casual guests;
• ▸conducting marketing activities, research & special offers;
• ▸accurately identifying who is using Padelground services;
• ▸communicating with members & website visitors to Padelground website and online enquiries;
• ▸profiling our members & their interests;
• ▸operating Padelground's business.

The types of information Padelground collects includes: name, age, gender, date of birth & next of kin; health information (height, weight, medical conditions); health and fitness goals; licence and banking details; contact details (including phone, fax and e-mail); views and opinions; and responses to forms and surveys (if any).

Sensitive information is information about you that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs or affiliations, membership of a professional or trade association, membership of a trade union, details of health, disability, sexual orientation or criminal record. It is Padelground's policy to only collect your sensitive information where it is reasonably necessary for Padelground's functions or activities and either you have consented or Padelground are required or authorised under law to do so.

Padelground will solicit your personal information by lawful and fair means directly from you unless it is unreasonable or impracticable to do so.

Padelground will collect personal information directly:

• ▸by email;
• ▸over the telephone (including calls and SMS);
• ▸via social media and over the intranet (including surveys);
• ▸by written correspondence (such as letters, faxes);
• ▸on hard copy forms (including registration forms, competition entry forms and surveys);
• ▸in person; or
• ▸through the Padelground website (online purchases, web form submission or participation in a live chat);
• ▸electronic systems such as applications and use of the club access card; and
• ▸through Padelground's security surveillance cameras.

Padelground may also collect information from third parties including: your coach; market researchers & direct marketing providers; parents or guardians of underage members; our current members (refer a friend); the Australian Tax Office (ATO) and the Australian Securities and Investment Commission (ASIC); and public sources (directories, membership lists, professional and trade associations, ASIC, bankruptcy or court registry searches).

The main purposes for which Padelground collects, holds, uses and discloses personal information are to provide services and benefits to members and guests, and to grow Padelground's membership and casual user base.

Padelground collects information to service its members and guests. Padelground can use your information to:

• ▸process applications for memberships;
• ▸understand Padelground's members' needs and requirements;
• ▸manage & run the Padelground website & social media platforms;
• ▸provide you with information about Padelground's services;
• ▸deliver or enhance Padelground's products and services;
• ▸help Padelground maximise the benefits provided to members;
• ▸any other purpose directly related to Padelground's business and for which you have provided consent (where it is reasonably required by law).

The Padelground website requires subscriptions or registrations to use certain services, functions or content. You will know what information is being collected via these processes when you complete the relevant forms and provide the required details prior to submitting the application. Padelground will collect data relating to any transactions you carry out through Padelground's website and the fulfilment of your order. Padelground may also use your data to monitor for any unauthorised use of Padelground's website, content or subscriptions to Padelground's services.

If Padelground collects personal information for a purpose (the primary purpose), Padelground will not use or disclose the information for any other purpose (the secondary purpose) unless:

• ▸you would have consented to the use or disclosure of your personal information; or
• ▸you would reasonably expect Padelground to use or disclose your information for the secondary purpose and the secondary purpose is directly related to the primary purpose;
• ▸use or disclosure is required or authorised under Australian law or a court/tribunal;
• ▸a permitted situation exists in relation to Padelground's use or disclosure of the information;
• ▸a permitted health situation exists in relation to use or disclosure of the information; or
• ▸Padelground reasonably believes that the use or disclosure of the information is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body.

If Padelground uses or discloses your information because Padelground reasonably believes that the use or disclosure of your information is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body, Padelground will make a written note of the use or disclosure.

You can refuse to provide personal information. However, a refusal may mean that the service you requested is not provided or membership will be refused or forfeited.

Padelground may use and disclose personal information for related purposes to third parties. Types of organisations to whom Padelground may disclose your personal information includes:

• ▸government bodies such as ATO, ASIC, Australian Prudential Regulatory Authority and the police or courts (as required by law);
• ▸various law enforcement agencies and governments for security, customs and immigration purposes;
• ▸banking service providers;
• ▸rewards partner program providers;
• ▸professional or government organisations; and
• ▸Padelground's contracted service providers including: information technology service providers; planning research and development providers; conference organisers; marketing and communications agencies; mailing houses, freight and courier services; printers & distributors of marketing material; debt collectors and banks; coaches; and external advisers (recruiters, auditors & lawyers).

Padelground does not rent, sell or exchange your personal information with third parties without your prior approval.

Padelground does not adopt, use or disclose government-related identifiers (such as a Medicare number or licence number) as Padelground's own identifier for you unless:

• ▸it's required/authorised by law or court/tribunal order;
• ▸it's reasonably necessary to verify your identity;
• ▸it's reasonably necessary to fulfil Padelground's obligations; or
• ▸Padelground reasonably believes it is reasonably necessary for one or more enforcement-related activities.

To improve Padelground's services, Padelground sometimes collects de-identified information from web users. The information collected does not identify an individual but does help Padelground to analyse and improve its web services. When you visit the Padelground website, a record of your visit is logged and the following data is supplied by your browser:

• ▸your IP address and/or domain name;
• ▸your operating system (type of browser & platform);
• ▸the date, time and length of your visit; and
• ▸the resources you accessed or downloaded.

Padelground uses this information to customise the website for visitors and to collect data for analysis, quality control, administration and improving the website. It is not used for any other purpose. Aggregated data may be shared with third parties. You can stop your browser from accepting new cookies or disable cookies altogether by changing your browser preferences.

Links to third-party websites that Padelground does not operate or control are provided for your convenience. Padelground is not responsible for the privacy or security practices of those websites. Third-party websites should have their own privacy and security policies which Padelground encourages you to read before supplying any personal information to them.

If Padelground holds your information, Padelground may use or disclose that information (other than sensitive information) for direct marketing if: Padelground collected the information from you; and you would reasonably expect Padelground to use or disclose the information for that purpose; and Padelground provided you with a simple way to opt out of receiving direct marketing from Padelground; and you have not made such an opt out request to Padelground.

Padelground can use or disclose your sensitive information for the purpose of direct marketing if you have consented to the use or disclosure of that information for direct marketing.

If Padelground has collected the personal information that Padelground used to send you direct marketing material from a third party, you can ask Padelground to notify you of its source of information. It is Padelground's policy to do so unless it is unreasonable or impracticable.

If Padelground uses or discloses your personal information for the purpose of direct marketing, you may request not to receive direct marketing communications from Padelground.

If Padelground uses or discloses your personal information for the purpose of facilitating direct marketing by other organisations, you may request that Padelground does not use or disclose your information for this purpose.

Padelground will give effect to your request not to receive direct marketing from Padelground or an entity facilitated by Padelground within a reasonable time after the request is made.

Padelground stores information in different ways, including paper and electronic forms. Padelground takes reasonable steps to protect it from misuse, interference, loss, unauthorised access, modification or disclosure including:

• ▸secure password protected databases for storage;
• ▸confidentiality requirements of staff;
• ▸security firewalls for access to Padelground's systems;
• ▸servers kept at a secure location with limited access;
• ▸document storage security requirements;
• ▸granting access only to verified individuals;
• ▸access controls for Padelground's buildings;
• ▸limiting the provision of personal information to third parties and subject to guarantees about use; and
• ▸training staff to deal with the information.

Padelground cannot guarantee that personal information will be protected against unauthorised access or misuse and Padelground does not accept any liability for the improper actions of unauthorised third parties. Padelground will retain your personal information for as long as necessary to fulfil Padelground's obligations to you, to protect its legal interests, to comply with laws or as otherwise stated to you when Padelground collects your personal information. Once Padelground is no longer required to retain your personal information, Padelground will take reasonable steps to destroy your personal information or to ensure that your personal information is de-identified.

Padelground and Padelground group entities may disclose your personal information to other third-party service providers operating outside Australia who work with Padelground or one of Padelground's suppliers, agents, or partners. Padelground may also store your personal information on servers based overseas or in the "cloud" or other types of networked or electronic storage.

Before disclosing your personal information to an overseas third party, Padelground will first take reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles in relation to your personal information; or that the recipient of the information is subject to a law, or binding scheme, that has the effect of protecting your personal information in a way that is substantially similar to the way in which the Australian Privacy Principles protect the information.

If your personal information is collected using a document that references this Privacy Policy, you are taken to consent to the disclosure, transfer, storing or processing of your personal information outside of Australia.

You have the option of not identifying yourself or using a pseudonym when dealing with Padelground provided that it is lawful and practicable.

Padelground will try to accommodate a request for anonymity if possible. However, your right to anonymity does not apply in relation to a matter if Padelground is required/authorised by law or court/tribunal order to deal with identified individuals; or it is impracticable for Padelground to deal with individuals who have not identified themselves.

It is Padelground's policy to enable you to access the Padelground website and make general phone queries without having to identify yourself and to enable you to respond to Padelground surveys anonymously. In some cases, however, if you don't provide Padelground with your personal information when requested, Padelground may not be able to respond to your request or provide you with our service.

You have the right, upon request, to access any of Padelground's records containing your personal information. To request access to your personal information please contact the Privacy Officer, set out at the end of this Policy.

Padelground will respond to your request to access your personal information within a reasonable period of time. On the basis that it is reasonable and practicable to do so, Padelground will give you access to the information requested.

If Padelground refuses your request to access personal information, Padelground will provide a written notice setting out the reasons for the refusal & how you can complain about the refusal.

• ▸poses a serious threat to the life, health or safety;
• ▸would have an unreasonable impact on the privacy of others;
• ▸is frivolous or vexatious;
• ▸relates to legal proceedings;
• ▸reveals Padelground's intentions or prejudice any negotiations;
• ▸would be unlawful;
• ▸is required or authorised by law or court/tribunal order;
• ▸is likely to prejudice enforcement-related activities; or
• ▸relates to a commercially sensitive decision process.

When you make a request to access personal information, Padelground will require you to provide some form of identification (such as a driver's licence or passport) so Padelground can verify that you are the person to whom the information relates.

Padelground will take reasonable steps to ensure Padelground's records of personal information are accurate, up to date and complete.

However, the accuracy of information depends to a large extent on the information you provide. If you do not give Padelground all the personal information Padelground may require, or the personal information provided is inaccurate or incomplete, then the products, services and information Padelground provide may be affected.

If you think there is something wrong with the information Padelground holds about you, please contact the Privacy Officer. Padelground will respond to your request to correct your personal information in a reasonable period of time.

If you have any issues you wish to discuss with Padelground or if you're concerned about how Padelground has collected or managed your personal information please contact the Privacy Officer.

For information about privacy or if your concerns are not resolved, contact the Office of the Australian Information Commissioner at www.oaic.gov.au and on 1300 363 992.

Padelground may, from time to time, review and update this privacy policy to take account of new laws and changes to Padelground's operations. Changes to this Privacy Policy will not affect Padelground's use of previously provided information.

This Privacy Policy is available on the Padelground website at www.padelground.com.au. A printed Privacy Policy can be obtained free of charge by contacting the Privacy Officer.