Cowboys Rugby League Football Limited
Personal information means any information about an identified individual or an individual who is reasonably identifiable, whether the information is true or not and whether the information is recorded in a material form or not.
The Cowboys recognise the importance of your privacy and your rights in relation to your personal information and is committed to complying with applicable privacy laws (including the Privacy Act and GDPR).
Dealing with us anonymously or using a pseudonym
Wherever possible, we will let you remain anonymous or use a pseudonym when dealing with us.
However, in most cases, we will need to know some information about you in order to provide products, services or support to you. For example, if you contact us with a query, we may need your contact information to respond to you.
How we share your information as part of the rugby league exchange
The Cowboys are always seeking to better understand our player and fan preferences including by analysing your Personal Information to understand trends and interests. The Cowboys have, in conjunction with the NRL, other Clubs, Queensland Rugby League (QRL), New South Wales Rugby League (NSWRL), Country League of New South Wales and selected third parties, established a data storage architecture and data sharing platform for processing Personal Information with this aim (Rugby League Exchange).
What kinds of personal information we collect
The types of personal information the Cowboys collect depends our dealings with you, but may include (without limitation):
(a) your name, gender, date of birth, occupation, and contact details such as email, address and phone number;
(b) memberships, subscriptions and attendance history at the Cowboys matches (whether you have used your membership to purchase tickets, or as a casual ticket purchaser);
(c) purchasing preferences and payment information which we collect when you buy tickets, purchase merchandise and/or as part of competitions and promotions; and
(d) your preferences regarding products and services (such as your favourite Cowboys players).
We also collect personal information provided to us:
(a) on business cards submitted to us through business card draws; and
(b) on survey forms and competition forms for surveys and competitions we run.
The Cowboys generally do not collect sensitive information such as health information. If we do, we will only do so if:
(a) you have expressly consented to the collection of such sensitive information;
(b) the Cowboys are specifically permitted to do so under the NRL Rules, including for health, medical and anti-doping testing purposes and investigation of disputes (whatever the nature of the dispute);
(c) the collection is required or authorised by law; or
(d) the collection is otherwise permitted under applicable privacy laws (including the Privacy Act and GDPR).
How personal information is collected
The Cowboys generally collect personal information directly from you, such as when you submit it to us.
The Cowboys may also collect personal information from:
(a) the NRL, Queensland Rugby League, New South Wales Rugby League and selected third parties (for instance, Ticketek and Ticketmaster);
(b) a third party (such as a sponsor or corporate partner of the Cowboys); and
(c) information that is on public record.
The purposes for which personal information is collected, used and disclosed
The Cowboys generally only collect, use and disclose personal information to perform the function of administering the North Queensland Cowboys NRL team (the primary purpose), including:
(a) organising, conducting and promoting the Cowboys including conducting and promoting Cowboys games (for instance, providing you information about upcoming ticket offers and deals for the next home matches);
(b) managing Cowboys membership and supporters (including advertising);
(c) promotion and sale of North Queensland Cowboys merchandise;
(d) complying with the NRL Rules; and
(e) conducting our other functions including entertainment, community engagement and support, merchandise, sponsorship, hospitality, training and education.
Your personal information will only be used and disclosed for the primary purpose for which it was collected, a related secondary purpose, in accordance with any express consent you grant the Cowboys or as otherwise lawfully required (e.g. where your Personal Information is requested by a law enforcement agency).
The Cowboys may use your personal information to send you marketing communications if:
(a) you have expressly consented to receive direct marketing communications; or
(b) you would reasonably expect your personal information would be used or disclosed for direct marketing,
(c) the Cowboys have provided a simple means by which you can request not to receive direct marketing; and
(d) you have not made a request not to receive direct marketing.
In each direct marketing communication, the Cowboys provide an unsubscribe option. If you do not wish to receive direct marketing, please unsubscribe through the link.
Disclosing personal information
The Cowboys may provide your personal information to to third parties as part of our functions and activities including (without limitation):
(a) delivery, courier and postal organizations: we may disclose your Personal Information to delivery, courier and postal organizations in order to deliver merchandise you order;
(c) law enforcement and emergency services agencies: we may disclose your Personal Information where required or authorised to do so by law, including in emergency situations and to assist law enforcement agencies with active investigations. We will always ensure that those to whom we disclose your Personal Information have the legal right to receive it; and
(d) marketing and promotions: we engage email marketing providers, market research companies, promotions management and other data analytics companies to perform direct marketing on our behalf. You will always have the right to opt out of receiving promotional materials from us.
The Cowboys may also disclose your information to other service providers such as IT cloud service providers, ticketing agents, mail houses and other similar third party organisations. For example, the Cowboys use third party credit card payment gateway services on our website. If you pay for tickets or services through the Cowboys' website, the Cowboys will be required to provide certain financial details to the third-party service provider to effect the transaction. The Cowboys require these third party organisations to keep your contact details and personal information confidential and only use them to provide services to the Cowboys.
Data quality and security
We understand you have entrusted us with the protection of your Personal Information. As such, we will take reasonable steps, with the assistance of the NRL, to protect your Personal Information from misuse, loss, unauthorized access, modification or disclosure. This includes engaging reputable third party service providers and ensuring that we engage (where possible and practical to do so) in best practice security systems and procedures.
We may store your personal information in hard copy at the Cowboys office or in electronic records in our IT systems. We implement a range of physical and electronic security measures to protect the personal information that we hold, including ensuring that hard copies are stored securely and controlling access to IT systems through use of passwords.
Access and correction
You can access, review and manage your Personal Information through:
(a) your NRL Account (using your login credentials);
(b) communications preferences via links in emails and other communications we send to you from time to time; or
(c) contacting our Privacy Officer (see "inquires and complaints" below).
You will be responsible for ensuring your Personal Information remains accurate, complete and up to date. Please ensure that any written request for access or correction addressed to our Privacy Officer provides adequate detail that identifies what Personal Information you want access to or corrected. Where your request will require the Cowboys to incur costs, we may charge you an access fee to cover those costs (for instance, reasonable staff costs in searching for, locating and retrieving the requested Personal Information). We will inform you of any such charges prior to them being incurred.
In certain circumstances, we may refuse to provide you access to your Personal Information. Where we refuse you access, we will provide you with a written explanation as to the reasons for the rejection (for instance, we may refuse to disclose Personal Information to you where such access would have an unreasonable impact on the privacy of other individuals).
Transborder data flows
- Subject to clauses 2 and 3 below, the Cowboys will not transfer your Personal Information to an overseas recipient unless it has first taken steps reasonable in the circumstances to ensure that the Personal Information that it transfers will not be held, used or disclosed by the recipient of the information inconsistently with, or otherwise in breach of, applicable privacy laws (including the Privacy Act and GDPR). For example, the Cowboys may adopt appropriate contractual clauses with overseas recipients that ensure their compliance with applicable privacy laws (including the Privacy Act and GDPR).
- We may disclose your Personal Information to overseas recipients for things such as processing membership and hosting services, most likely in China, Singapore, the United States and New Zealand, although countries where such recipients are located may vary.
- We may transfer Personal Information about you to someone who is in a foreign country if:
(a) we reasonably believe that the recipient is subject to a law or binding scheme that has the effect of protecting the information in a way that is, overall, substantially similar to applicable privacy laws (including the Privacy Act and GDPR) and there are mechanisms available to you to enforce that protection or scheme; and
(b) you expressly consent to the transfer after we have informed you that the applicable privacy laws (including the Privacy Act and GDPR) will no longer apply if you provide your express consent.
Notifiable data breaches scheme
In the event of any loss, or unauthorised access or disclosure of your Personal Information that is likely to result in serious harm to you, the Cowboys, with the assistance of the NRL, will investigate and notify you and where applicable the relevant supervisory authority (e.g. the Australian Information Commissioner) within 72 hours of becoming aware of the loss, or unauthorised access or disclosure, in accordance with applicable privacy laws (including the Privacy Act and GDPR).
Inquiries and complaints
The Privacy Officer
North Queensland Cowboys
Subject: Attention: Privacy Officer
PO Box 577, Thuringowa Central Qld 4817
+617 4773 0700
At all times, privacy inquiries and complaints will be treated seriously, dealt with promptly and confidentially, and will not affect your existing obligations or commercial arrangements with the Cowboys.