Privacy Policy
This Privacy Policy is designed to tell you what will happen to the information you provide through this website or through any other form of communication with us, Urbnsurf Group Pty Limited, our wholly-owned subsidiaries, or our employees, authorised representatives, agents or contractors. Please be sure to read this entire Privacy Policy before using this website or submitting personal information to us or our employees, authorised representatives, agents or contractors.
Personal Information
This Privacy Policy concerns any personal information or sensitive information about you which is provided to us.
Personal information is 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.
Sensitive information is any personal information about your racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, health, genetics, biometrics or biometric templates. Other than details of any medical conditions that you have (which may be relevant to your use of our venues, products and services) or information about your professional or trade associations or trade union membership (which may be relevant to networking functions or business related promotions), we generally do not wish to be informed of a person’s sensitive information. We, in any event, will collect, use or disclose sensitive information about you only as allowed by law, for example where we have received your consent to do so or the collection is required by law.
Your consent
By using this website or otherwise providing us directly, or through others, with your personal information, you agree with the terms of this Privacy Policy and consent to the collection, use, and disclosure of that information in accordance with this Privacy Policy, the Privacy Act 1988 (Cth) as amended (including the Australian Privacy Principles) (the Act) and other applicable privacy laws.
If you are under the age of 18 years, your parent or guardian (as appropriate) agrees to the terms of this Privacy Policy and consents, on your behalf, to the collection, use, and disclosure of your personal information in accordance with this Privacy Policy, the Act and other applicable privacy laws.
Passive information collection
As you navigate through this website, as well as our other websites and social media sites (such as our webpages on Facebook), and attend our venues, certain information can be passively collected (that is, gathered without you actively providing the information) through various technologies, such as cookies, internet tags or web beacons, navigational data collection, and Wi-Fi, Bluetooth and other wireless networks.
These websites, social media sites and Wi-Fi, Bluetooth and other wireless networks may use and combine such passively collected anonymous information to provide better services to users or visitors, customise the digital or physical experience based on your preferences, compile and analyse statistics and trends and otherwise administer and improve for your use. Such information is not combined with personally identifiable information collected elsewhere unless you have consented.
How we collect your personal information
We collect personal information that is necessary for our business activities and in order to provide and develop our services. We may do this in a number of ways, including:
- directly from you, when you provide it to us or our employees, authorised representatives, agents or contractors, including through:
- your use of our website (including making bookings or purchases), social media sites and applications;
- your use of our venues, including accessing any of our Wi-Fi, Bluetooth and other wireless networks;
- completing and submitting forms via our website and waiver platform;
- any request received from you for access to or to receive our electronic direct mail communications, newsletters and other publications;
- if you send us an email or otherwise contact us; or
- talking to our staff, including about any health issues that you may suffer from that is relevant to your use of our venues, products and services;
- from parents or guardians in the case of a person under the age of 18 or where a family member nominates you;
- from our third party services providers, including providers of the URBNSURF Greenroom service;
- from publicly available resources; or
- by analysing our own records of your use of our venues, products, services and website.
We also may collect your personal information when legally required to do so by law.
What personal information do we collect and why?
The type of personal information we collect may include your name, date of birth, address, postcode, telephone number, email address, social media account information, use of our venues, products and services, details of your surfing ability and surfing habits, whether you have recommended our venues, products and services to anyone else (via our referral system), details of your health and fitness (including preferences for activities such as events and training), any medical conditions that you have that may be relevant to your use of our venues, products and services, and your preferences and purchases regarding our venues, products and services. We may also conduct, or allow third parties to conduct, photography, filming and streaming of your recordings at our venues (and third party venues located in our surf parks) or online, including for the purpose of providing and promoting the URBNSURF Greenroom services. In particular, our third party service provider, Flowstate Zone Pty Ltd (Flowstate), will collect and use of your images and video recordings, which includes sensitive information such as your biometric information or metadata associated with your recordings, for the primary purpose of creating and making available for purchase video content relating to your surf session. Flowstate will handle your personal information in accordance with their Privacy Policy available here Flowstate Privacy Policy. For clarity, we will not be collecting any of your sensitive information from Flowstate but we may collect the images and recordings made by Flowstate and other information associated with the Flowstate service. If you do not wish to be filmed or photographed, please let us know when you make your booking or when you enter the venue.
If we are not provided with the personal information that we request, we may not be able to meet your request or provide our products or services to you.
Your personal information may be used for a number of purposes connected with our business operations, which include to:
- verify your identity;
- facilitate the provision of our products and services to you;
- address or respond to any requests from you;
- inform you of existing and proposed products and services which we provide (including where you have consented to receive marketing communications from us);
- better understand your surfing, skateboarding, training, fitness, events, leisure, entertainment, food, beverage, retail, hire and health needs;
- develop and improve the quality and scope of our venues and the products and services we provide, and seek your feedback;
- help ensure your safety while at our venues, and while using our products and services; and
- optimise and facilitate our marketing, communications and promotional activities.
Where you have consented to receive marketing communications from us, your personal information may be used so that we, our wholly-owned subsidiaries, employees, authorised representatives, agents and contractors can provide you with information about our venues, products and services, such as by way of direct mail, telemarketing, email, SMS or MMS, or to request your feedback for promotional purposes. You always have the right to opt-out of receiving such information. You may exercise that right by contacting us as set out below.
We may also use your personal information for purposes related to those described above, where those purposes would reasonably be expected by you.
We will not use your information for purposes other than those described above unless we have your consent or as permitted by law (including for law enforcement or public health and safety reasons).
Sharing your personal information
We may disclose your personal information in certain circumstances, such as where we are required or authorised by law or where you have consented to us doing so.
We also may disclose your personal information to:
- third parties in accordance with a request made by you;
- our related companies, employees, authorised representatives, agents, contractors and business partners;
- third parties engaged in providing us with professional, business, marketing, communications, technology and corporate services, including the URBNSURF Greenroom services, when reasonably required; and
- healthcare professionals where this is required to help ensure your health and safety; and
- law enforcement in the event of a serious threat to public safety.
When making such a disclosure we will take reasonable steps to ensure that the recipient is bound by privacy obligations.
Unless you consent, we otherwise will not disclose your personal information to third parties.
Does my personal information leave Australia?
We will only send your personal information outside Australia:
- if we are authorised to do so by law;
- for any of the purposes set out in this Privacy Policy (but only to parties that are subject to obligations in relation to personal information no less onerous than those in this Privacy Policy); or
- if you have consented to us doing so.
In the course of our ordinary business operations we commonly disclose personal information to third parties located in the following countries:
- New Zealand; and
- United States.
Access and correction
You may request access to any of the personal information we hold about you by contacting us as specified below. We reserve the right to charge a reasonable fee for the costs of retrieval and supply of any requested information.
We will take all reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up to date. To ensure your personal information is accurate, please notify us of any errors or changes to your personal information by using the contact details provided below, and we will take appropriate steps to update or correct such information in our possession.
Storage and security
We will take all reasonable precautions to safeguard your information from loss, misuse, unauthorised access, modification, disclosure or destruction. We may store your files in hard copy and/or digital copy. We implement a range of physical and electronic security measures to protect the personal information that we hold, including that hard copies are kept in locked cupboards and for digital copies, on servers that have technical measures in place to protect the personal information under our control. You should keep in mind that no internet transmission is ever completely secure or error-free. In particular, e-mails sent to or from this website may not be secure.
Links to other websites
This website may contain links or references to other websites to which this Privacy Policy may not apply. You should check their own privacy policies before providing your personal information.
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, we will:
- investigate; and
- notify you and the Office of the Australian Information Commissioner as soon as practicable, in accordance with the Act.
Complaints
If you have any questions or concerns about our collection, use or disclosure of personal information, or if you believe we have not complied with this Privacy Policy or the Act, please contact us as set out below. Our Privacy Officer will investigate the complaint and determine whether a breach has occurred and what action, if any, to take.
URBNSURF Group Pty Limited will take any privacy complaint seriously and will aim to resolve any such complaint in a timely and efficient manner, and our target response time is 30 days.
URBNSURF Group Pty Limited expects our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can also make a formal complaint with the Officer of the Australian Information Commissioner (which is the regulator responsible for privacy in Australia):
Office of the Australian Information Commissioner (OAIC)
1300 363 992
Director of Compliance
Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
www.oaic.gov.au/privacy/privacy-complaints
How to contact us
If you wish to exercise your right to opt-out of receiving our marketing materials, or you have any questions or concerns about this Privacy Policy or our information practices (including whether and what type of health information we hold about you), please contact us at:
Privacy Officer
Changes to this Privacy Policy
Our Privacy Policy may change from time to time as updated on this website. Before providing us with personal information, please check this Policy on our website for any changes.
This Privacy Policy was last updated in July 2023.