Privacy Policy
Last updated: 6 June 2024
XV’S COMMITMENT TO PRIVACY
XV Capital Advisory Pty Ltd (ACN 642 600 002) and its affiliated and related companies in Australia (collectively referred to as XV) are committed to managing personal information in accordance with the Australian Privacy Principles under the Privacy Act 1988 (Cth) and in accordance with other applicable privacy laws.
This document sets out our policies for managing your personal information and is referred to as our Privacy Policy. This Privacy Policy outlines how we collect, store, process, use and disclose personal information (including personal information we collect, and personal information submitted to us, whether offline or online).
In this Privacy Policy, “we” and “us” refers to XV and “you” refers to any individual about whom we collect personal information.
Other terms and conditions may apply to you such as:
- the privacy terms and conditions contained in contractual arrangements we may have with you; and
- the collection notices and privacy statements which may be provided to you at the time your personal information is collected (for example, the collection notice provided when you become a client or the collection notice provided when you commence work with us).
ABOUT XV
XV is a sports innovation and advisory, sports technology venture acceleration and sports technology investment group.
Please contact us for a full list of the companies which comprise XV and which are subject to this Privacy Policy. This Privacy Policy applies to the website www.xvcapitaladvisory.com.
WHAT INFORMATION DOES XV COLLECT ABOUT YOU?
Clients and prospective clients
When you enquire about our services or when you become a client of XV, a record is made which includes your personal information.
The type of personal information that we collect will vary depending on the circumstances of collection and the kind of service that you request from us, but will typically include:
- your name, email, addresses and other contact details;
- information about your employer or an organisation who you represent;
- your tax file number;
- your professional details;
- correspondence sent by you; and
- any additional personal information you provide to us, or authorise us to collect, as part of your interaction with XV.
XV generally collects personal information directly from you. We may collect and update your personal information over the phone, by email, over the internet or social media, or in person. We may also collect personal information about you from other sources, for example:
- our affiliated and related companies;
- our clients; and
- third party suppliers and contractors who assist us to operate our business.
XV also collects and uses personal information for market research purposes and to innovate our delivery of products and services.
Prospective employees/applicants
We collect personal information when recruiting personnel, such as your name, contact details, qualifications and education and work history. Generally, we will collect this information directly from you.
We may also collect personal information from third parties in ways which you would expect (for example, from recruitment agencies or referees you have nominated). Before offering you a position, we may collect additional details such as your tax file number and superannuation information and other information necessary to determine your suitability for certain positions.
Other individuals
XV may collect personal information about other individuals who are not clients of XV. This includes individuals that contact XV including via our website and other individuals who interact with XV on a commercial basis. The kinds of personal information we collect will depend on the capacity in which you are dealing with XV. Generally, it would include your name, contact details, and information regarding our interactions and transactions with you.
You can always decline to give XV any personal information we request, but that may mean we cannot provide you with some or all of the services you have requested. If you have any concerns about personal information we have requested, please let us know.
Visitors to our websites
You may visit our website (www.xvcapitaladvisory.com) without identifying yourself. If you provide any personal information to XV, your personal information will be managed in accordance with this Privacy Policy.
XV's websites use cookies. A 'cookie' is a small file stored on your computer's browser, which assists in managing customised settings of the website and delivering content. We collect certain information such as your device type, browser type, IP address, pages you have accessed on our websites and on third-party websites. You are not identifiable from such information.
You can use the settings in your browser to control how your browser deals with cookies. However, in doing so, you may be unable to access certain pages or content on our website.
XV's websites may contain links to third-party websites. XV is not responsible for the content or privacy practices of websites that are linked to our website.
HOW AND WHY DOES XV COLLECT AND USE YOUR PERSONAL INFORMATION?
XV collects and uses personal information to carry out our business, to assess and manage our clients' needs, and provide services. We may also use personal information to fulfil administrative functions associated with these services.
The purposes for which we usually collect and use personal information depends on the nature of your interaction with us, but may include:
- responding to requests for information and other general inquiries;
- researching, developing and expanding our services;
- recruitment processes (including for internships and work experience); and
- responding to enquires and complaints.
Use for administration and management
XV will also use and disclose personal information for a range of administrative, management and operational purposes. This includes:
- administering billing and payments and debt recovery;
- planning, managing, monitoring and evaluating our services;
- quality improvement activities;
- statistical analysis and reporting;
- training staff, contractors and other workers;
- risk management and management of legal liabilities and claims;
- responding to enquiries and complaints regarding our services;
- obtaining advice from consultants and other professional advisers; and
- responding to subpoenas and other legal orders and obligations.
CAN YOU DEAL WITH XV ANONYMOUSLY?
XV will provide individuals with the opportunity of remaining anonymous or using a pseudonym in their dealings with us where it is lawful and practicable. Generally, it is not practicable for XV to deal with individuals anonymously or pseudonymously on an ongoing basis. If we do not collect personal information about you, you may be unable to utilise our services.
HOW DOES XV HOLD INFORMATION?
XV stores information in paper-based files or other electronic record keeping methods in secure databases (including trusted third-party storage providers based in Australia and overseas). We take reasonable steps to protect your personal information from misuse, interference and loss and from unauthorised access, modification or disclosure.
We take the security of your personal information very seriously and have controls and processes to minimise the risk of a breach occurring in respect of your personal information. XV maintains physical security over paper and electronic data stores, such as through locks and security systems at our premises. We also maintain computer and network security, including the use of security systems such as user identifiers and passwords to control access to our computer systems.
Our website does not necessarily use encryption or other technologies to ensure the secure transmission of information via the internet. Users of our website are encouraged to exercise care in sending personal information via the internet.
We take steps to delete, destroy or de-identify information that we no longer require.
DOES XV USE OR DISCLOSE YOUR PERSONAL INFORMATION FOR DIRECT MARKETING?
XV may use or disclose your personal information for the purpose of direct marketing to keep you informed about that we offer that we think might be of interest to you. We may contact you from time to time, whether by phone, SMS, email or post, to provide you with information regarding our products and services, events, promotions and opportunities, or to ask you for your feedback through surveys on how you found our products and services. If you do not want to receive direct marketing communications, you can opt-out at any time by using the opt-out or unsubscribe instructions in our marketing communications or contacting us using the contact details below.
If you opt-out of receiving marketing material from us, XV may still contact you in relation to its ongoing relationship with you or where required by law.
HOW DOES XV DISCLOSE PERSONAL INFORMATION?
For clients
The purposes for which we may use and disclose your personal information will depend on the services we are providing you. We may share your information with third parties for the reasons for which we collect and use that information (see above) or where we are otherwise allowed or required to do so under law.
Disclosure to contractors, service providers and related entities
XV may disclose information to third parties that we engage in order to provide our services, including contractors and service providers used for data processing, data analysis, customer satisfaction surveys, information technology services and support, website maintenance/development, printing, archiving, mail-outs and market research.
Personal information may also be shared between affiliated and related companies of XV, located in Australia and overseas.
Third parties to whom we have disclosed your personal information may contact you directly to let you know they have collected your personal information and to give you information about their privacy policies.
Other uses and disclosures
We may use and disclose your personal information for administrative purposes, management purposes, operational purposes, or other purposes explained at the time or collection or otherwise as set out in this Privacy Policy.
DOES XV DISCLOSE YOUR PERSONAL INFORMATION OVERSEAS?
XV is a global organisation and works with clients, service providers and commercial interests across the globe. We may disclose personal information outside Australia to other companies within our group of companies, government bodies and law enforcement agencies, successors in title to our business and suppliers we engage to process data on our behalf. We only ever share your personal information outside of Australia where we are permitted to do so under the Privacy Act and applicable privacy laws. Generally, this means we will take reasonable steps to ensure your personal information is treated securely and in accordance with applicable privacy laws.
Where we disclose personal information to overseas recipients, they are likely to be located in New Zealand, the UK, the USA, Singapore and Japan.
HOW CAN YOU ACCESS OR SEEK CORRECTION OF YOUR PERSONAL INFORMATION?
You are entitled to access your personal information held by XV on request. To request access to your personal information, please contact our Privacy Officer using the contact details set out below.
You will not be charged for making a request to access your personal information, but you may be charged for the reasonable time and expense incurred in compiling information in response to your request.
We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date. You can help us to do this by letting us know if you notice errors or discrepancies in information we hold about you and letting us know if your personal details change.
However, if you consider any personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading, you are entitled to request correction of the information. After receiving a request from you, we will take reasonable steps to correct your information.
We may decline your request to access or correct your personal information in certain circumstances in accordance with the Australian Privacy Principles. If we do refuse your request, we will provide you with a reason for our decision and, in the case of a request for correction, we will include a statement with your personal information about the requested correction.
WHAT SHOULD YOU DO IF YOU HAVE A COMPLAINT ABOUT THE HANDLING OF YOUR PERSONAL INFORMATION?
You may contact XV at any time if you have any questions or concerns about this Privacy Policy or about the way in which your personal information has been handled.
You may make a complaint about privacy to the Privacy Officer at the contact details set out below.
The Privacy Officer will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. We will generally respond to your complaint within a week.
If your complaint requires more detailed consideration or investigation, we will acknowledge receipt of your complaint within a week and endeavour to complete our investigation into your complaint promptly. We may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.
In most cases, we will investigate and respond to a complaint within 30 days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know.
If you are not satisfied with our response to your complaint, or you consider that XV may have breached the Australian Privacy Principles or the Privacy Act, a complaint may be made to the Office of the Australian Information Commissioner. The Office of the Australian Information Commissioner can be contacted by telephone on 1300 363 992 or by using the contact details on the website www.oaic.gov.au.
HOW CHANGES ARE MADE TO THIS PRIVACY POLICY?
XV may amend this Privacy Policy from time to time, with or without notice to you. When we make a material change to this Privacy Policy, we will provide notice to you (including by updating our websites, and, where appropriate, notifying you directly). We recommend that you visit our website regularly to keep up to date with any changes.
HOW CAN YOU CONTACT XV?
The contact details for XV are:
Rob Smith
Privacy Officer
XV Capital Advisory Pty Limited
E: rob.smith@xvcapitaladvisory.com
M: +64 21 0872 4522