1. PURPOSE AND SCOPE

The purpose of this Privacy Policy (Privacy Policy) is to provide an understanding of how Rivalry Australia Pty Ltd (we and us) usually utilise your Personal Information (Personal Information) and acknowledge how that information is protected by the Australian legal framework. That framework includes adhering to the Privacy Act 1988 (Cth), and its associated Guidelines known as the Australian Privacy Principles (APP) and the Anti Money Laundering and Counter Terrorism Financing Act 2006 (Cth) (AML/CTF). 

This Privacy Policy is guided by those laws and guidelines to provide people making bets in esports or sports, through our services (our clients or you), a reasonable and transparent understanding of our approach to the use of your Personal Information. We take your privacy seriously, and not only just because the Australian law says we must, but because we believe it to be the right thing to do. 

The scope of this Privacy Policy applies to the collection of your Personal Information and the what, where and why aspects of its collection and use. It also provides assistance with how to interact with the Personal Information you provide to us, how to contact us with relation to your Personal Information, how to make a complaint in relation to your Personal Information and an overview of your rights and choices in relation to your Personal Information.

2. COLLECTION OF YOUR PERSONAL INFORMATION

What information we collect and hold?

We do collect and store your Personal Information in the normal course of running our esports and sports betting business. Sometimes we need to collect this to offer you our products and services and generally manage our business. Sometimes, the law, conditions in our licence, and other gambling rules require us to collect it. The Personal Information we collect includes information such as your: 

  • first name and surname
  • gender
  • date of birth
  • email, residential and/or postal address
  • verification of identity documents (e.g., driver’s licence, birth certificate, passport, etc.);
  • banking or payment details 

However, the APPs also cover the less obvious way we collect your Personal Information such as;

  • cookies and internet data (Click Data) – more will be discussed about Click Data in this policy below
  • data relating to your transactions, when you place bets, including the frequency, volume and value of those bets
  • information about your computer, including (where available) your IP address, device ID, operating system, physical location, browser type and other individually identifiable data, for system administration, statistical and fraud prevention purposes.

What is Click Data and Cookies?

We collect data about you in the use of our website and what your preferences may be. This enables us to recognise you as a repeat customer. In better recognising you and your online preferences, we can provide you a more user friendly and tailored experience with Rivalry online that is less key stroke intensive. 

A key mechanism for Rivalry to track your preferences is by using “cookies”. The OAIC defines cookies as being “…a small data file stored on your device’s browser. Its purpose is to is to help a website keep track of your visits and activity.” (Cookies) Using Cookies we are able to create more relevant promotions for you, and in turn, use Cookies to test our e-mail tools are working and to keep web based administrative statistics. More information on how and why we use Click Data and Cookies, and your option relating to Click Data and Cookies, can be found in this policy below. 

Finally, some Click Data we use may be non-identified data. This means that we cannot necessarily identify the identity of the source of the data and includes: the pages you browse through; websites that directed you to us; keywords you used to find us in search engines; your IP address; Cookies (please see Cookies section above).

You may wish to read further on Cookies and targeted advertising. We encourage you to do so at the OAIC website at the following link OAIC Privacy, advertising and Cookies: https://www.oaic.gov.au/privacy/your-privacy-rights/advertising-and-marketing/targeted-advertising.

How we collect your Personal Information?

Generally, we try to limit the collection of your Personal Information to more obvious interactions with our business or website, where you input your information, such as in an online application form. For example: our “Sign Up” page will, by necessity, ask you for Personal Information such as your e-mail address. 

We collect your Personal Information so that we can open your account and you can place bets using the services of our website and associated products. We also collect your Personal Information to help us manage our business. Further obvious interactions with us, when we collect your Personal Information including:

  • Whenever you interact with our customer support team and share Personal Information, please be aware that this includes conversations conducted through our AI-powered chat system, utilizing large language models (LLM)
  • in the course of being billed or organising a bill
  • when you voluntarily provide it in the use of our Website
  • information that you submit in response to a survey(s) or poll

There are less obvious ways which we collect your Personal Information that you should be aware of, such as;

  • when you personally disclose the information in public areas of the website, like forums
  • credit reporting bodies and customer data validation service providers who help us assess risk to our business under our AML/CTF obligations
  • from types of third parties listed below
  • public sources (e.g., social media and search websites)
  • our industry regulators
  • any other relevant Commonwealth, state or territory government authority or agencies.

Why do we collect and hold your Personal Information?

We collect, store and use (and at times disclose) the Personal Information we have about you to provide you with products and services and to manage our business, which includes the following reasons:

  • to meet our legal requirements under Australian law, our regulators and with relation to any other obligations arising under AML/CT obligations
  • to ensure you are of a legal age to bet on esports in Australia (18+) 
  • to confirm the currency you hold in your account with us and other information like your encrypted password, payment details, banking and card details
  • to verify your identity and assist fraud detection
  • internal monitoring and to provide insights that help us understand the impact of our products, services and experiences have on our customers more broadly
  • to administer our responsible gambling programs (for more information please see our (Responsible Gambling Policy)
  • to protect the safety and security of our people, sites and assets
  • to protect and defend our legal rights and interests
  • to undertake analytics activities that inform our product development initiatives and marketing campaigns
  • to manage, administer and improve the quality of our products and services
  • other administrative and operational tasks like account management, systems development and testing, risk management, investigation of unlawful activity, staff training, maintaining our records, market and customer satisfaction research or collecting debts
  • for other reasons where the law, the conditions of our licence and relevant rules may require us or allow us to use your personal information 

Direct Marketing

We may use your Personal Information to send you information and advertisements about our products and services we think you’d be interested in. Generally, we’ll only use your Personal Information to tell you about the products and services that you’ve expressed an interest in using. Sometimes, we’ll also use Your Personal Information to tell you about our products and services. We tell you about these things by various methods including email and SMS text messages. There is more detail on how we do this, and how you can opt-out, below. 

Targeted Online Advertising

As mentioned above, we use your Personal Information to market our products and services to you – and to show you advertisements. We use digital platforms like social media and Google. We may use marketing agencies and software services to help us deliver that advertising, and to tell you about our products and services that may be of interest to you based on your interactions with us. 

These third-party companies may use Personal Information that they already hold, or information we may provide to them (including through your Cookies and Click Data), to serve you with more relevant advertising about our products and services. They do not use your Personal Information from us for their own purposes. 

Our marketing agencies may contact you directly on our behalf if directed by us in order for us to gain a greater insight into how we can develop products and services that are more relevant to you, for instance, in order to conduct market research. You can hide or block most targeted advertising by following the prompts in that advertising (e.g., opt out link). If you hide or block it, or otherwise opt-out of direct marketing, you won’t get any online advertising based on the personal information we hold and disclose. However, you may still see similar advertisements based on your anonymous browsing history and untargeted advertisements. 

Personalising your visit to our website

If you use our website we may show you personalised offers and content. We can do this using your customer account number and by using Cookies and Click Data. We use this to do things like assign you to the right jurisdiction for your location, altering website navigation based on your most visited pages, or displaying results, etc. from your previous browsing or purchasing.

From time to time we may also use Cookies from third party websites (for example, those that display our advertising) to personalise your online experience with us. Cookies are commonly capable of being blocked by you, but this depends on your personal computer settings and the browser you are using. Usually this can be done via your internet browser settings or deleting Cookies from within your browser’s cache. Keep in mind that if you do reject cookies, it may have a negative impact on your user experience with Rivalry and limit all the interactive features our website uses.

Analytics

We also generate aggregate and personalise insights about our business and brand from the Personal Information we hold. These insights help us to identify trends and patterns that mean we’re creating the right products and services for our customers. This information also drives our marketing campaigns and helps us assess how effective they are.

Opting out of Direct Marketing

You can opt-out of receiving direct marketing or targeted advertising communications at any time. You’ll find the specific instructions through each marketing piece or in your account settings under ‘Contact preferences’. If you cannot find how to opt-out, please contact us via email on [email protected] and we can manually record your marketing preference.

3. HOW WE MAY DISCLOSE OR SHARE YOUR PERSONAL INFORMATION

Third parties

Once we have your Personal Information we may disclose or share that Personal Information, for example:

  • in order to enforce or apply the terms of this Privacy Policy, the Terms & Conditions, or any other agreements;
  • our employees, contractors and service providers in order for them to do their job and provide their services;
  • any regulator, be that State, Territory or Commonwealth jurisdiction and their related authorities and agencies, where they have a valid legal obligation or right to access that information;
  • to any of our related companies or entities, so that they may comply with their obligations at law, licence conditions and betting rules and can market directly to you;
  • to companies or bodies that will verify identity or assist with any obligation of due diligence pursuant to the AML/CTF laws- by using our website you agree to this Privacy Policy and you consent for us to share relevant Personal Information with chosen credit reporting bodies or the equivalent. To perform our Know-Your-Client requirements, in accordance with AML/CTF laws, we use a third party software provider, Sum and Substance Ltd (UK) (SumSub);
  • any business, company or entity that we partner with or third parties used to facilitate a loyalty or affiliate program;
  • for market research or training purposes;
  • in the necessary protection of any person, property or legal right;
  • for marketing and promotional purposes which includes any medium such as postal mail, sms, mms, phone call or otherwise. This may include our authorised and/or related third party partners to provide you product and service information directly. You consent to any such marketing activity unless and until you opt out of it;
  • where we sell or buy any business and we may disclose your personal data to the prospective seller or buyer of such a business or its assets;
  • where you have consented for us to; and
  • Personal information shared during customer interactions with the AI-powered chatbot, may be disclosed or shared solely for the purpose of improving and refining the chatbot's functionality and enhancing the overall customer experience.

Disclosure and Sharing of Your Personal Information overseas

We may choose to share or disclose your Personal Information overseas for the following reasons:

  • for cloud data storage purposes
  • KYC purposes
  • IT support that may be based in another country or jurisdiction
  • Fraud and identification checks
  • Other international firms that we may reasonably choose to use from time to time and for the principal purpose of activities related to our business.

If we do transfer your information Overseas we will take all reasonable steps to ensure that it is treated as securely as it is within Australia (i.e., in accordance with the APPs), or ensure that the transfer of your information is in accordance with the applicable laws. We implement corporate rules, model contracts and privacy shields (where available) to accomplish this.

4. YOUR RIGHTS AND CHOICES

Website options

First and foremost, your use of the Rivalry website is optional. You may choose to navigate away, or not use the site if you are unagreeable with this Privacy Policy.

As mentioned above, you may also limit Cookies by setting your browser to not accept those Cookies. 

Personal Information rights and choices

If you wish to update your Personal Information with us as you believe it to be incorrect you may contact [email protected] . Please note that you may be able to update some of your information via the ‘My Account’ page on our website.

You may also request a copy of your Personal Information record by the following process;

  • we will provide you with a form to complete;
  • we will also require valid proof of your identity to provide with your form; and
  • after we have had a reasonable time to process the form, and your verification of identity, we will respond within a reasonable time (usually thirty (30) days)

We acknowledge that we cannot require you to complete the above mentioned form, however we request you do so to make your request easier to process. Further, we reserve our right to reject an unreasonable request for Personal Information in circumstances where the form of the request would be unreasonably arduous or otherwise unreasonable. 

Personal Information requests may be made via live chat or by e-mail at [email protected].

5. HOW YOU CAN MAKE A COMPLAINT

Compliant Procedure

If you’re worried about how we have handled your Personal Information or your privacy, please let us know so we can take steps to address your concerns.  

If we do not address your concerns when you first raise it, you can make a written complaint and we’ll do our best to resolve it for you. There are two steps available to you with relation to any complaint dispute: 

  • Talk to us: You may put your complaint in writing and seek to resolve your dispute with us directly. We treat all complaints seriously. Your complaint may be made to the below e-mail addresses or contact methods. Upon receipt we will investigate the circumstances of your complaint, assess your complaint (aiming to resolving it quickly and efficiently) and respond to you in a reasonable time (usually 30 days); and/or
  • Contact the Office of the Australian Information Commissioner (OAIC): If we are unable to resolve your dispute with us, or you are not satisfied with how we managed your complaint, you may wish to contact the OAIC (please see the following link to the OAIC’s contact page: https://www.oaic.gov.au/about-us/contact-us) or visit their complaint webpage at https://www.oaic.gov.au/privacy/privacy-complaints/

6. HOW TO CONTACT US

You may contact us with relation to any Personal Information issue, question or otherwise at;

Rivalry Australia Pty Ltd, Level 4, 66 Smith Street, Darwin, NT 0800

[email protected]

Or 

On our 24 hour chat support at www.rivalry.com

Last updated: March 23, 2023