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Legal / 012

Privacy
policy.

Effective date: 5 August 2026 | Version: 1.3

Contents

  1. 1. Who we are and our role
  2. 2. Scope of this Policy
  3. 3. Personal information we collect
  4. 4. How we collect information
  5. 5. Why we use information
  6. 6. Health, injury and other sensitive information
  7. 7. Children, parents and guardians
  8. 8. Required and optional information
  9. 9. Who we disclose information to
  10. 10. International processing and transfers
  11. 11. Payment information
  12. 12. Cookies, analytics and advertising technology
  13. 13. Direct marketing by email, SMS and telephone
  14. 14. Photography, video, testimonials and session recordings
  15. 15. Security and access controls
  16. 16. Retention, deletion and de-identification
  17. 17. Access and correction in Australia
  18. 18. Rights outside Australia
  19. 19. Additional overseas requirements
  20. 20. Privacy complaints and regulators
  21. 21. Data breaches
  22. 22. Automated decision-making
  23. 23. Changes to this Policy
  24. 24. Contact us
  25. Appendix A - Website enquiry privacy collection notice
  26. Appendix B - Optional marketing consent wording
  27. Appendix C - Booking and health-information collection notice

1. Who we are and our role

1.1 Thomas Owen Price, a sole trader (ABN 76 992 690 143), trading as HUB Rugby Coaching (HUB, we, us or our), is responsible for the personal information described in this Policy. Business location: New South Wales, Australia. HUB does not operate from a permanent public business premises and operates throughout Australia and internationally through contracted coaching locations and online services.

1.2 For Australian privacy law, we intend to operate as an organisation subject to the Privacy Act 1988 (Cth), the Australian Privacy Principles and, where applicable, the Health Records and Information Privacy Act 2002 (NSW) and Health Privacy Principles. We take this approach because our Services may involve health, injury, disability, fitness and assessment information, even if a small-business exemption might otherwise be considered.

1.3 Our Australian Business Number is 76 992 690 143. Privacy enquiries, rights requests and complaints may be sent to hubrugby1@gmail.com.

2. Scope of this Policy

2.1 This Policy applies when you visit or use our Website, submit an enquiry, contact us by phone, email or social media, book or pay for a Service, participate in coaching, receive online programming, provide health or emergency information, attend an event, appear in media, give a testimonial, make a complaint, or otherwise interact with HUB.

2.2 It applies to Athletes, prospective Athletes, parents and guardians, emergency contacts, Website visitors, enquiry contacts, event participants and other individuals whose information we handle in connection with the Services.

2.3 This Policy does not replace the separate privacy notice of a third-party website, social network, payment provider, booking system, club, school, venue, healthcare provider or other independent organisation. We encourage you to review those notices.

2.4 HUB is currently operated directly by Thomas Owen Price as a sole trader and does not currently employ staff. If coaches, contractors or employees are engaged later, separate workforce notices, access controls and agreements may apply and will sit outside the main scope of this customer-facing Policy.

3. Personal information we collect

We collect only information reasonably necessary for the relevant purpose. Depending on how you interact with us, the categories may include:

Category

Examples

Identity and contact

Name, preferred name, date of birth or age, pronouns where voluntarily provided, address, email, telephone number, country, time zone and communication preferences.

Athlete and rugby profile

Playing level, position, club or school, experience, season demands, goals, training history, availability, equipment and coaching-format preferences.

Parent, guardian and emergency

Parent or guardian identity, relationship, authority, contact details, emergency contacts, authorised collection or release arrangements and safeguarding communications.

Health and sensitive information

Injury and concussion history, medical condition, medication relevant to exercise, disability, accessibility needs, physical limitation, pregnancy, symptoms, medical restrictions, clearance, first-aid or emergency information, and health information arising during coaching.

Assessment and development

Performance observations, test results, measurements, training loads, progress notes, development priorities, program adherence, feedback, session attendance and Athlete-submitted footage.

Booking and payment

Service selected, date, location, package, attendance, invoices, payment status, transaction reference, refunds, chargebacks and limited billing information. Full payment-card data is normally handled by the payment provider.

Communications

Enquiries, emails, SMS, approved messages, call notes, social-media communications, complaints, requests, preferences and records of consent or withdrawal.

Media and testimonials

Photographs, video, audio, online-session recordings, name, voice, likeness, quotes, performance story and the consent choices connected with each use.

Website and device

IP address, device and browser information, pages viewed, referral source, approximate location, cookie identifiers, security logs, form metadata and analytics or advertising data where enabled.

Safety, safeguarding and legal

Incident and near-miss reports, allegations, investigations, conduct records, Working with Children Check-related verification where relevant to a person’s role, insurance and legal correspondence, and disclosures to authorities.

3.1 Please do not include detailed medical, injury, safeguarding or emergency information in the general Website enquiry field or a public social-media message. We will provide a more appropriate collection method when the information is required.

3.2 We do not intentionally collect more information than needed and do not ask an Athlete to provide a diagnosis or intimate detail that is irrelevant to safe coaching.

4. How we collect information

4.1 We may collect information:

directly from you through Website forms, booking and registration forms, medical or emergency forms, consent forms, calls, emails, SMS, approved messaging, social media and in-person discussion;

from an Athlete’s parent, guardian, emergency contact or authorised representative;

from a Coach through observations, assessments, program records, attendance, incident reports and feedback;

from a club, school, academy, venue, healthcare professional or another organisation where you have authorised the disclosure or law otherwise permits it;

from Navitrophic.com and the Navitrophic CRM for Website enquiries and customer administration, Stripe for payments, Amazon Web Services (AWS) for domain registration and DNS, and the business email service where relevant;

automatically when a device accesses the Website, subject to cookie and privacy choices; and

from public sources only where lawful, reasonably expected and relevant, such as verifying a publicly stated playing history or responding to public social-media contact.

4.2 If you provide another person’s information, such as an emergency contact, you should have authority to do so and, where practicable, tell that person about this Policy.

4.3 If we receive unsolicited information that we are not permitted or do not need to keep, we will take reasonable steps to delete or de-identify it, subject to safety, safeguarding and legal requirements.

5. Why we use information

We handle personal information lawfully, fairly, transparently and only where reasonably necessary for a stated purpose. Where another country’s mandatory privacy law applies, we will comply with any additional consent, notice or processing requirement that cannot lawfully be excluded.

Purpose

Typical information

Reason and authority for handling

Respond to an enquiry and recommend a pathway

Identity, contact, rugby profile and goals

Responding to your request; administering enquiries; consent where required.

Form and administer the coaching contract

Identity, guardian, booking, payment and service communications

Providing and administering the coaching contract; recordkeeping, tax and other legal obligations.

Provide, personalise and review coaching

Athlete profile, assessments, attendance, programs and feedback

Providing the requested coaching safely and effectively; consent where sensitive information or a separate activity requires it.

Protect health and safety

Injury, medical restriction, disability, emergency and incident information

Consent where required; emergency and vital safety needs; legal obligations; legal claims; another lawful authority.

Safeguard children and respond to concerns

Guardian, communications, incident, conduct and allegation records

Child-safety and reporting obligations; emergency protection; safeguarding and legal claims; consent only where appropriate and not where reporting is mandatory.

Take payment and maintain financial records

Transaction, invoice, refund and billing data

Processing payment and administering the contract; financial, tax and fraud-prevention obligations.

Operate and secure the Website and systems

Device, log, cookie and security data

Operating and securing the Website; consent for non-essential cookies where required.

Communicate optional marketing

Contact details, channel choices and consent records

Consent or another lawful direct-marketing permission.

Use media, recordings or testimonials

Image, voice, recording, quote and contextual details

Specific consent, except where a private recording is necessary to deliver an expressly requested service and clearly agreed.

Handle complaints, insurance and legal matters

Communications, incidents, records and relevant health or contract data

Legal obligations; insurance administration; establishing, exercising or defending legal claims.

Improve Services

Feedback and de-identified or appropriately minimised data

Service improvement using consent where required and de-identified or minimised information where practical.

5.1 We use information only for the purposes explained in this Policy, including safely providing and improving coaching, maintaining accurate records, protecting people and systems, preventing fraud, resolving disputes and operating the business. We consider necessity, reasonable expectations and the impact on the individual before using information.

5.2 Where consent is the basis, it must be voluntary, informed, specific and recorded. You may withdraw consent for future processing, but withdrawal does not invalidate processing already lawfully carried out and may mean we cannot safely or practically provide a Service that genuinely depends on the information.

5.3 We will not rely on consent to avoid a legal reporting duty or to make an unlawful waiver of privacy or safety rights.

6. Health, injury and other sensitive information

6.1 Health, injury, disability, medical-clearance and emergency information is sensitive and health information. We apply enhanced collection, access, security, use and disclosure controls.

6.2 We collect this information only where reasonably necessary for safe coaching, reasonable adjustments, emergency response, incident management, legal obligations or another clearly explained purpose. A dedicated form or secure channel should be used rather than a general enquiry form.

6.3 Where overseas privacy law applies, we will use any additional consent, lawful authority, safeguarding condition or emergency basis required by that law. We will not rely on consent where a legal reporting or safety obligation requires action without consent.

6.4 Access is limited to people who reasonably need the information, such as the relevant Coach, authorised administrator, safeguarding lead or emergency responder. A Coach should receive only the information required for safe delivery, not an entire medical history by default.

6.5 We do not use health, injury, disability, concussion, safeguarding or emergency information to create advertising audiences, infer promotional vulnerability or target an Athlete with marketing, unless a specific use is demonstrably lawful and supported by valid express consent. Our default is not to use it for advertising.

6.6 Medical clearance remains the responsibility of the qualified practitioner who issues it. We may record that clearance was sighted and any relevant restrictions rather than retaining a full medical document where that is sufficient.

7. Children, parents and guardians

7.1 We may coach Athletes under 18. We therefore design registration, communication, safety and privacy processes around the child’s best interests and age-appropriate participation.

7.2 We generally require a parent or legal guardian to contract for an Athlete under 18, provide guardian and emergency information, authorise necessary health collection and emergency arrangements, and receive primary service communications.

7.3 We also explain important matters to the child in an age-appropriate way and seek the child’s assent where appropriate, particularly for physical contact, media, recordings and optional disclosures. A guardian’s authority does not remove the child’s privacy, safety or complaint rights.

7.4 We do not automatically add a child to a marketing list. Promotional communications should ordinarily be sent to the guardian. A guardian may decline marketing or promotional media without affecting the child’s access to coaching.

7.5 We limit direct messaging with children, avoid disappearing or secret channels, and may copy or route communications through the guardian. Safeguarding communications may be preserved even where a normal chat would otherwise be deleted.

7.6 A parent’s right to access a child’s information may depend on parental responsibility, the child’s maturity and capacity, the child’s safety and applicable law. We may need to verify authority, consult the child, withhold limited information, or seek advice where disclosure could place someone at risk.

8. Required and optional information

8.1 We will identify required fields where practical. Contact, booking, payment, guardian, relevant safety and emergency information may be required to form or safely perform a contract.

8.2 If required information is not provided, we may be unable to respond fully, confirm a booking, process payment, make a reasonable adjustment or provide the Service safely. We will not require information merely because it may be useful for marketing.

8.3 Marketing, public photography, promotional video, paid advertising, testimonials and most session recording are optional and should use separate unticked choices. Declining them does not prevent coaching.

8.4 You may use a pseudonym or limited details for an initial general enquiry where practicable, but identity and guardian verification may be required before coaching, payment, medical collection or child participation.

9. Who we disclose information to

9.1 We may disclose or make information available to the following categories, only for a lawful and relevant purpose:

authorised Coaches, administrators, contractors and safeguarding personnel;

Navitrophic.com, which provides the Website functionality, enquiry forms and Navitrophic CRM, and Amazon Web Services (AWS), which provides domain registration and DNS services;

Stripe, which processes payments, and the business email service used for direct communications; banks, accountants and financial-administration providers where relevant;

a club, school, academy, venue or event organiser where necessary for a confirmed arrangement, safety or attendance and where the disclosure is expected, consented to or otherwise lawful;

doctors, paramedics, hospitals, first aiders and emergency contacts where reasonably necessary for health or safety;

police, child-protection bodies, the NSW Office of the Children’s Guardian, SafeWork NSW, courts, regulators, governing bodies or other authorities where required or permitted by law;

insurers, brokers, lawyers, auditors and professional advisers for advice, incident handling, claims, compliance and dispute resolution;

a genuine purchaser, successor or adviser in a proposed business restructure or sale, subject to confidentiality, due diligence and applicable notice; and

another person you specifically authorise.

9.2 We require service providers to handle information consistently with applicable law and our instructions where they act for us. Some providers independently determine part of their processing and should be reviewed under their own privacy notices.

9.3 We do not sell or rent personal information for money. We do not disclose Athlete lists to unrelated advertisers for their own direct marketing without valid permission or another clear lawful basis.

9.4 We do not disclose a full medical or safeguarding record to a club, venue or Coach where a limited safety instruction or restriction is sufficient.

10. International processing and transfers

10.1 HUB operates from Australia. Information about overseas customers may therefore be accessed or stored in Australia and may also be processed in countries used by our service providers.

10.2 HUB’s current core technology providers are Navitrophic.com for Website functionality, enquiry forms and the Navitrophic CRM; Amazon Web Services (AWS) for domain registration and DNS services; and Stripe for payment processing. HUB communicates directly through its business email account and does not currently use a separate online booking platform, bulk-email or SMS marketing platform, video-conferencing platform, customer analytics platform, advertising-pixel provider or separate customer cloud-storage provider.

10.3 Navitrophic.com, AWS, Stripe and the business email service may use infrastructure or subprocessors located in Australia or overseas, as described in their applicable privacy information. Where Australian Privacy Principle 8 applies, we take reasonable steps before an overseas disclosure and may remain accountable for the recipient’s handling, subject to statutory exceptions.

10.4 Where personal information is transferred outside Australia, we will take reasonable steps to use providers and safeguards appropriate to the information and any mandatory law, which may include contractual protections, access restrictions, encryption, transfer assessments or another recognised mechanism.

10.5 Some countries may require local notices, registrations, representatives, transfer arrangements or other measures. We will assess and implement those requirements where HUB systematically targets or provides Services in that country.

10.6 You may request information about the applicable safeguard by contacting us. We may provide a summary or redacted copy where necessary to protect confidential commercial and security information.

11. Payment information

11.1 Payments are processed by Stripe. Stripe may collect card, bank, device, fraud and identity information under its own terms and privacy notice.

11.2 We aim not to receive or store complete payment-card numbers or security codes. We may receive a token, masked card details, transaction reference, payment status, billing name, invoice address, refund or dispute information.

11.3 We use payment information to process the contract, prevent fraud, reconcile accounts, issue receipts and refunds, handle disputes and meet tax, accounting and legal obligations.

12. Cookies, analytics and advertising technology

12.1 Cookies and similar technologies may store or access information on a device. The Website should use a layered cookie notice and a consent tool where required by the visitor’s law.

Technology category

Purpose

Control

Strictly necessary

Security, form submission, load balancing, consent storage and core Website functions.

Used where necessary; cannot always be disabled through our tool.

Functional

Remembering choices, accessibility settings or optional embedded features.

Consent where required.

Analytics

Understanding visits, performance, errors and content use.

Consent where required; otherwise used only where lawful, proportionate and appropriately minimised.

Advertising

Measuring campaigns, creating or matching audiences and delivering promotional content.

Prior consent where required; disabled on sensitive forms and child/health journeys.

12.2 The Website is provided through Navitrophic.com, and AWS is used for domain registration and DNS. HUB does not currently use a separate customer analytics platform, advertising pixel, behavioural advertising provider or third-party cookie-consent platform. Strictly necessary technical cookies or similar functions may still be used to operate and secure the Website and forms. If optional analytics or advertising technology is introduced, this Policy and any cookie notice will be updated and consent controls will be used where required.

12.3 We do not intentionally send medical conditions, injury details, child registration information, form answers, email addresses or telephone numbers to advertising platforms. Advertising pixels should not fire on medical, emergency, safeguarding or child-registration forms.

12.4 You can use the Website consent controls and browser settings to manage non-essential technologies. Withdrawing consent does not affect processing before withdrawal and may change optional features.

12.5 Third-party video or social embeds may set their own cookies or receive device information when activated. Where required, they should remain blocked until the visitor chooses to load them.

13. Direct marketing by email, SMS and telephone

13.1 We may send coaching offers, discounts, new-program announcements, camp or event information and business updates only where we have a lawful basis for the channel. An enquiry, booking or purchase does not automatically mean that every form of marketing is permitted.

13.2 Our preferred consent design uses separate, optional and unticked choices for:

email marketing;

SMS marketing; and

promotional telephone calls.

13.3 We record who consented, the date and time, the wording and policy version displayed, the source, the channels selected and any withdrawal. Consent is not bundled with coaching, medical, emergency, safeguarding, photography, video or testimonial consent.

13.4 Australian commercial email and SMS messages will identify the sender, include valid contact details and provide a clear functional unsubscribe method. We will action electronic unsubscribe requests within the applicable legal period and maintain the facility for the required period.

13.5 Promotional telephone calls will comply with applicable Do Not Call, calling-time, caller-identification and opt-out rules. A service call requested by you may still occur without marketing consent, but promotional content will be separated where required.

13.6 Marketing to overseas recipients will comply with the mandatory electronic-marketing and telephone-marketing rules that apply in the recipient’s location. We use affirmative consent rather than pre-ticked boxes where consent is required.

13.7 You may withdraw or change a preference at any time using the message instructions or by contacting us. We keep a minimal suppression record so we can respect the opt-out and avoid accidental re-subscription. A new enquiry does not silently override an existing opt-out.

13.8 Necessary service messages, safety notices, booking confirmations, payment receipts and responses you request are not treated as optional marketing merely because they are electronic. We avoid adding promotional content that changes their character where consent is absent.

14. Photography, video, testimonials and session recordings

14.1 We may collect an image, video, voice recording, testimonial or online-session recording only for the purpose explained at the time and under an appropriate lawful basis. Public promotional use generally requires specific consent.

14.2 We provide separate choices for private coaching analysis, internal education, Website use, organic social media, paid advertising, print, testimonial wording, use of a name or club, and recording of an online session.

14.3 For children, guardian consent and age-appropriate Athlete assent are required. We minimise identifying details and do not make promotional media a condition of coaching.

14.4 You may withdraw consent for future use. We will stop new use and take reasonable steps to remove content we control, but public distribution may be difficult to reverse and copies outside our control may remain. We explain this before consent.

14.5 A private coaching recording is retained only for the stated analysis or service period unless a longer period is separately agreed. We do not secretly record online sessions or use recordings to train an artificial-intelligence model without a separate lawful process and clear notice.

14.6 A testimonial is published only after the person or guardian has approved the final wording, identity details and channels. We do not expand an informal health, injury, pressure or mental-wellbeing discussion into a public testimonial without specific approval.

15. Security and access controls

15.1 We take reasonable technical and organisational steps appropriate to the sensitivity and risk of the information. No system is completely secure, but our controls are intended to reduce unauthorised access, loss, misuse, interference, alteration and disclosure.

15.2 Controls may include:

business accounts and multi-factor authentication;

role-based access and restricted health or safeguarding folders;

encryption in transit and, where available, at rest;

secure devices, updates, malware protection and screen locking;

provider due diligence and data-processing terms;

access logs, backups and incident monitoring;

prompt removal of access when a Coach or contractor leaves;

staff and Coach confidentiality, privacy and safeguarding training;

secure deletion or de-identification; and

regular review of access, forms, pixels, integrations and retention.

15.3 Do not send sensitive information through an insecure or public channel when we have provided a secure alternative. Tell us promptly if you believe information or an account has been compromised.

16. Retention, deletion and de-identification

16.1 We retain information only for as long as reasonably necessary for the purpose, safety, safeguarding, legal, tax, insurance, dispute and recordkeeping requirements. The periods below are the proposed operational schedule and must be confirmed against actual systems before publication.

Record

Proposed retention

General enquiries that do not convert

Proposed: 24 months after the last meaningful contact, unless consent supports longer marketing or a dispute/safety reason requires retention.

Contracts, bookings, invoices and payments

Generally 7 years after the end of the relationship or transaction, or the period required by applicable tax, accounting and consumer law.

Adult NSW health records

At least 7 years from the date of the last health service or record entry where the NSW private-health-service retention rule applies.

NSW records collected while under 18

At least until the individual turns 25 where the NSW private-health-service retention rule applies.

Coaching assessments and development records

For the active coaching relationship and a reasonable review/claims period, aligned with any health-record requirement.

Safeguarding, serious incident and legal records

For as long as reasonably required by child-safety, reporting, insurance, legal-claim and limitation obligations; access is strictly restricted.

Marketing consent and suppression

Consent evidence while relied on and for a reasonable compliance period afterward. A minimal suppression record may be kept as long as needed to honour the opt-out.

Media and testimonials

For the consented purpose and publication period, subject to prospective withdrawal and archival/legal needs.

Website and security logs

Proposed: 12 to 24 months, unless needed for an incident, fraud or legal matter.

16.2 At the end of the retention period, we delete, destroy or permanently de-identify information where lawful and practicable. Information may remain temporarily in secure backups until the backup cycle completes and may be retained where deletion would conflict with a legal hold, safeguarding obligation or active claim.

16.3 De-identified information may be retained for statistics, planning and service improvement only where there is no reasonable likelihood of re-identification, taking account of context and available data.

17. Access and correction in Australia

17.1 You may request access to personal information we hold about you and ask us to correct information that is inaccurate, out of date, incomplete, irrelevant or misleading, subject to applicable exceptions.

17.2 Send the request to hubrugby1@gmail.com. We may ask for reasonable identity and authority verification, especially for health, child, safeguarding or guardian records. We will not charge for making a request, but a lawful reasonable charge may apply to providing access in limited circumstances.

17.3 We will respond within the period required by the Privacy Act, HRIP Act or other applicable law. If access or correction is refused in whole or part, we will give the reason and available complaint options unless law permits or requires otherwise.

17.4 A request by a guardian for a child’s information will be assessed under clause 7.6. An emergency contact is not automatically entitled to the Athlete’s records.

18. Rights outside Australia

18.1 Depending on the mandatory privacy law that applies where you live, you may have rights to:

be informed about processing;

access personal data and receive a copy;

rectify inaccurate or incomplete data;

request erasure;

restrict processing;

receive certain data in a portable format;

object to certain processing where mandatory local law gives you that right;

object at any time to direct marketing, including related profiling;

withdraw consent at any time for future processing;

not be subject to certain solely automated decisions with legal or similarly significant effects; and

complain to a privacy or data-protection regulator with jurisdiction over the issue.

18.2 These rights are not absolute. For example, deletion may be limited by legal, health-record, safeguarding, insurance or legal-claims obligations. We will explain any lawful limitation that applies.

18.3 We will respond within any applicable statutory timeframe and may request proportionate identity or authority evidence. We will not ordinarily charge unless applicable law permits a reasonable fee.

18.4 To exercise a right, contact hubrugby1@gmail.com and identify your country and request so we can assess the applicable requirements.

19. Additional overseas requirements

19.1 Privacy rights differ by country and may include access, correction, deletion, objection, portability, withdrawal of consent, appeal or complaint rights. If a mandatory local right applies to you, we will honour it to the extent required.

19.2 Contact us with your country, request and the information needed to verify identity. We will assess the applicable law and respond within the required period. This Policy does not claim that one Australian document, by itself, satisfies every local registration, representative, consent, localisation or youth-privacy rule worldwide.

19.3 We may restrict or stop offering a Service in a country if lawful privacy, safeguarding, licensing or data-transfer requirements cannot reasonably be met.

20. Privacy complaints and regulators

20.1 Contact hubrugby1@gmail.com with the details of your concern. We aim to acknowledge a privacy complaint within 5 business days and investigate it fairly and within the period required by applicable law.

20.2 We may ask for further information, consult a provider or relevant person, preserve records and offer a practical remedy. We will not retaliate against a person for making a good-faith privacy or safeguarding complaint.

20.3 Australian individuals may complain to the Office of the Australian Information Commissioner. A NSW health-information complaint may also be made to the Information and Privacy Commission NSW, subject to its jurisdiction and time limits.

20.4 Overseas individuals may also complain to a privacy or data-protection regulator with jurisdiction in their location. You may contact a regulator without first completing our internal process, although giving us an opportunity to resolve the issue may be useful.

21. Data breaches

21.1 We maintain a response process to contain, investigate, assess and document suspected loss, unauthorised access or unauthorised disclosure of personal information.

21.2 Where the Australian Notifiable Data Breaches scheme applies, we will assess a suspected eligible breach and notify affected individuals and the Office of the Australian Information Commissioner where required. NSW health-privacy, contractual, insurer and other notification requirements may also apply.

21.3 For overseas personal information, we will assess any regulator and individual notification duties under applicable mandatory breach laws and notify within the required time where the legal threshold is met.

21.4 You should contact us immediately if you receive another person’s information, lose a device or message containing HUB information, click a suspicious link connected with HUB, or believe an account or communication has been compromised.

22. Automated decision-making

22.1 We do not currently intend to make decisions about eligibility for coaching, safety, payment, safeguarding or another matter with legal or similarly significant effects solely by automated processing.

22.2 We may use ordinary automation for confirmations, reminders, scheduling, fraud signals, communications routing or analytics. A human can review an important decision. If this changes, we will update this Policy and provide information required by applicable law.

23. Changes to this Policy

23.1 We may update this Policy to reflect changes in law, Services, technology, providers or data practices. The current version and effective date will be posted on the Website.

23.2 If a change materially affects how we use sensitive information, children’s information, consented media, international transfers or direct marketing, we will provide additional notice and obtain new consent where required. We will not treat silence as consent where affirmative consent is required.

24. Contact us

Business Operator: Thomas Owen Price, a sole trader (ABN 76 992 690 143), trading as HUB Rugby Coaching

Business Location: New South Wales, Australia

Email for privacy enquiries, complaints and rights requests: hubrugby1@gmail.com

General email: hubrugby1@gmail.com

Australia telephone: +61 405 330 291

Business operates throughout Australia and internationally through contracted coaching locations and online services. HUB does not operate from a permanent public business premises.

Appendix A - Website enquiry privacy collection notice

WEBSITE COPY

Ready-to-place notice beneath every general enquiry form

HUB Rugby Coaching, operated by Thomas Owen Price (ABN 76 992 690 143), collects your name, contact details, playing level, coaching preference and enquiry to respond, recommend a coaching pathway and administer follow-up. Required fields are marked; without them we may not be able to respond.

Please do not include detailed medical, injury, emergency or safeguarding information in this general form. We will provide a more appropriate form if that information is needed. We may use service providers in Australia and overseas. See our Privacy Policy for access, correction, complaints, retention, international transfers and any mandatory rights that apply where you live.

Optional marketing is controlled by separate unticked choices and is not required to submit the enquiry.

Under-18 routing question to add before submission: “Is the Athlete under 18?” If yes, collect and verify the parent or guardian’s name, relationship, email and telephone number and direct primary communications to that adult.

Appendix B - Optional marketing consent wording

USE ABOVE UNTICKED BOXES

Consent statement

I agree to receive promotional offers, coaching updates, event information and other marketing communications from Thomas Owen Price, a sole trader (ABN 76 992 690 143), trading as HUB Rugby Coaching, through the communication channels I select below. I understand that this consent is optional, is not required to receive coaching, and may be withdrawn at any time.

Display each choice as a separate unticked box:

Email marketing

SMS marketing

Promotional telephone calls

For an under-18 Athlete, the guardian should make the choices and receive the marketing. Record the person, timestamp, source, exact wording, version and selected channels. Do not use a single “accept Privacy Policy and marketing” box.

Appendix C - Booking and health-information collection notice

SENSITIVE INFORMATION

Notice to display before medical, injury or emergency questions

We collect the Athlete’s health, injury, disability, medical-clearance and emergency information to assess safe participation, make reasonable adjustments, deliver coaching, respond to incidents and meet legal or insurance obligations. This information is sensitive and access is restricted to people who reasonably need it.

The information may be disclosed to an authorised Coach, emergency contact, first aider, healthcare or emergency service, insurer, venue, safeguarding body or authority where necessary and lawful. Overseas customer information may be processed in Australia and by approved providers under the safeguards described in our Privacy Policy.

Relevant safety information is required. If it is not provided, we may be unable to provide or continue the Service safely. For an under-18 Athlete, the guardian provides authority and the Athlete is involved in an age-appropriate way.

Consent to health-information handling is separate from marketing, promotional media, testimonials and optional recording. In an emergency or where law requires reporting, we may act without consent where the law permits or requires it.

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