Your privacy is important to Dubbins Pty Ltd (ABN 48 616 303 498).
This policy details the personal information that Dubbins collect and the ways in which Dubbins may use, hold and disclose that personal information.
- Personal information is information that identifies you or could identify you
- “We”, “our” and “us”, when used in this policy, depending on the context, refers to Dubbins Pty Ltd
- “Drafter” refers to the Drafter website with its top-level domain located at http://www.drafter.net.au, and all related sub-domains
- “Drafter’s social media derivatives” include the official Drafter Facebook page (page name: ‘Drafter Fantasy Sports’, username: ‘@getaroundher’), the official Drafter Instagram account (page name: ‘Drafter’, username: ‘@getaroundher’) and the official Drafter Twitter account (page name: ‘Drafter‘, username: ‘@getaroundher’)
All personal information received by Dubbins is treated seriously, having regard to our legal obligations. Dubbins is subject to the Privacy Act 1988 (Cth), including the Australian Privacy Principles.
- Information Collected
In Association with use of the Drafter Platform
Dubbins collect personal information directly from you via your use of the Drafter website, and any registration you make to participate with or receive information from Drafter. This includes, but is not limited to:
Required information to play fantasy
First name; Surname; Date of Birth; AFLW Club which you Support; Email Address
Optional information that may be collected to play fantasy
Associated Facebook profile (required if signing up via Facebook)
Optional information that may be required in relation to the Drafter product
Opinions and beliefs provided via surveys and questionnaires
We also may collect additional non-personally identifiable information (for example, browser version, IP address) that will provide information regarding the general use of Drafter and its social media derivatives.
In Association with General Business
Any information you provide to Dubbins in order to conduct business, including but not limited to information provided in person, in writing, via phone, or via email.
- Opt-Out / Unsubscribe
You can easily unsubscribe from Drafter mail-out communications (email) at any time by contacting us using the contact details specified in section 17 of this policy, or by following the unsubscribe instructions contained in any mail-out e-mail received. It may take some time to put an opt-out or an unsubscribe in effect so you may still receive communications from us after your request is received.
- Information from Third Parties
- Public Forums
We may provide public forums as part of the Drafter website or it’s social media derivatives. Any personal information you choose to submit in such a forum may be read, collected, or used by others who visit these forums, and may be used to send you unsolicited messages. Dubbins are not responsible for the personal information you choose to submit in these forums.
- Storage of Personal Information
We will store personal information on data servers that are owned and controlled by Dubbins, ans managed by Digital Ocean. Primarily, the Digital Ocean servers and are located within Australia. But some supplementary servers are located internationally, specifically for example in Singapore, and some of your personal information may be transferred, stored, processed, used or disclosed overseas by Dubbins. You may have rights to enforce such parties’ compliance with applicable data protection laws, but you may not have recourse against those parties under the Australian Privacy Act (Cth) 1988 in relation to how those parties treat your personal information. Our test environment servers are located in the Philippines, but Dubbins will not transfer, store, process, use or disclose your personal information in the course of developing or testing our products and services.
- Use and Disclosure of Personal Information
Dubbins collect, hold, use and disclose your personal information for purposes including, without limitation:
- to verify your identity and age;
- to provide, and to assist us with providing products and services to you, and to improve the products and services;
- to provide you with information about events, products and/or services that may interest you;
- to facilitate the internal business operations of Dubbins;
- to promote and market Dubbin’s products or services;
- to enable corporate partners and sponsors of Drafter to market and promote their products and services to you; and
- to our third party service providers in connection with any of the above.
- Sharing Information with Third Parties
We engage third parties to perform services in connection with the operation of our business. Examples of these services include payment processing and authorisation, website evaluation, data analysis and, where applicable, data cleansing.We may need to share personal information with these third parties so that they can perform these services, however, we limit the personal information that we give to them and authorise them to use this information only for the purpose of performing those services.We may share aggregated demographic information about our user base with our agents, including agencies or third party vendors so that they can provide marketing analysis and consult on advertising strategies. This information does not identify individual users. We also may share non-personal information, such as the number of users who visited Drafter during a specific time period or who sponsored an AFLW athlete through the website, with our marketing partners, advertisers and others from time to time. This information generally is shared in an aggregated form. Dubbins does not otherwise disclose personal information without your permission, unless the disclosure is:
- in accordance with this policy or any agreement you enter into with us; or
- required or authorised by law, including without limitation the Australian Privacy Principles under the Privacy Act 1988 (Cth).
- Accessing Drafter
You need not disclose your identity to us in order to visit Drafter, except where personal information is voluntarily supplied, however the Drafter internet server may automatically record details about any computer used to access the website (such as the IP address, domain name and browser type), the date and time of access, and details of the information downloaded. This information is used for internal statistical purposes and to improve Drafter.
- Website Analytics
When you visit and browse Drafter, our website host and some third party service providers may collect information for statistical, reporting and maintenance purposes. Subject to the terms of this policy, this information is used to administer and improve the performance of Drafter and will not be used to identify you. The information may include:
- the number of users visiting our website and the number of pages viewed;
- the date, time and duration of a visit;
- visiting patterns of individuals accessing Drafter;
- the IP address of your computer; and
- the path taken through our website.
We use website analytic services to help analyse how you use Drafter (Website Analytics). Website Analytics generate statistical and other information about website use by means including but not limited to cookies which are stored on users’ computers. The information generated is used to create reports about the use of Drafter. Our third party providers of these services may store this information. Dubbins will not (and will not allow any third party to) use Website Analytics to track or to collect any personally identifiable information of visitors to Drafter. Dubbins will not associate any data gathered from Drafter with any personally identifying information from any source as part of our use of Website Analytics. Dubbins treat personal information that may be obtained through cookies and any other information supplied to us (for example if you send us an email) in accordance with this policy.
Drafter may contain links to other websites operated by third parties, specifically to websites operated by our sponsors, partners, and third parties who pay to advertise on our website. We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing you about their own privacy practices.
- Children’s Privacy
If you are under 18, you should only use the Drafter fantasy competitions “Season Game” and “Short Game” with involvement of a parent or guardian. For their protection, we ask that anyone under 18 years of age does not attempt to register for the Drafter fantasy competitions, or otherwise provide us with any personal information without the consent of a parent or legal guardian.
- Information Security
Dubbins will take reasonable steps to protect all personal information within their direct control from misuse, interference, loss, unauthorised access, modification or disclosure. Dubbins will take reasonable steps to hold information securely in electronic or physical form in access controlled premises or in electronic databases requiring logins and passwords.
- Contacting Us Regarding Access, Correction and Privacy Complaints
An individual may:
- request access to and seek the correction of their personal information held by Dubbins at any time;
- make a complaint in relation to an alleged breach of privacy; or
- submit a query or concern about this policy or the information handling processes by contacting us by email at firstname.lastname@example.org.
You will be required to provide proof of identity in order to obtain access to your personal information. We may refuse to provide access if permitted to do so by law. Drafter aims to provide access to your personal information within 30 days of a valid request.
At all times, privacy complaints:
- will be treated seriously;
- will be dealt with promptly;
- will be dealt with in a confidential manner; and
- will not affect your existing rights, obligations or affect the commercial arrangements between you and Dubbins.
Dubbins will commence an investigation into your complaint. You will be informed of the outcome of your complaint within a reasonable period of time following completion of the investigation.
We will vary this policy from time to time, by posting an updated policy accessible via the Drafter website. This policy was last updated on 7 January 2017.