Privacy Policy | Equipped for Sport

Effective date: 3 September 2026

1. About this Privacy Policy

Equipped For Sport Pty Ltd trading as Equipped For Sport, ABN 28 701 343 688, ACN 701 343 688 (“EFS”, “Equipped For Sport”, “we”, “us” or “our”) respects the privacy of the people whose information is handled through our services.

This Privacy Policy explains how we collect, hold, use, disclose and protect personal information.

EFS operates in Australia and has prepared this Policy having regard to the Privacy Act 1988 (Cth), the Australian Privacy Principles and other applicable Australian privacy laws.

Our contact email for privacy matters is contact@equippedforsport.com.

2. Scope

This Policy applies to personal information handled through:

(a) the EFS Platform;

(b) EFSD and associated applications;

(d) EFS websites;

(e) EFS accounts;

(f) EFS subscriptions;

(g) transactions facilitated by EFS;

(h) communications sent using EFS;

(i) EFS artificial intelligence and automation functionality;

(j) connected applications and integrations;

(k) EFS support and customer service;

(l) EFS hardware and associated services; and

(m) other EFS products and services.

3. EFS and Club responsibilities

EFS may receive personal information directly from an individual or from a Club.

Where a Club collects information about its members, players, parents, volunteers, staff, customers or other people and enters or imports that information into EFS, the Club remains responsible for its own collection and use of that information.

EFS provides the technology used to store and process that information.

EFS also independently handles information for its own purposes, including account administration, EFS billing, security, fraud prevention, compliance, service analytics, support and Platform operations.

Individuals with questions concerning Club-maintained information should ordinarily contact the relevant Club first.

Individuals may also contact EFS and we will deal with a request in accordance with applicable law, including by coordinating with the relevant Club where appropriate.

4. The kinds of information we may collect

Depending on how EFS is used, we may collect or hold information including:

(a) name;

(b) date of birth and age;

(d) postal or residential address;

(e) telephone number;

(f) email address;

(g) parent, guardian and family relationship information;

(h) emergency contacts;

(i) Club, team, squad, group, season and membership information;

(j) player, athlete or participant history;

(k) photographs, video and media;

(l) attendance and participation;

(m) sporting assessments, grading, evaluations, reviews and performance information;

(n) health conditions;

(o) allergies;

(p) injury information;

(q) disability and accessibility information;

(r) dietary information;

(s) information concerning cultural requirements where supplied;

(t) identity verification information;

(u) Working With Children Check and similar compliance information;

(v) driver’s licence, passport or other identification information where legitimately required;

(w) banking or payout information;

(x) purchase, payment, refund and transaction history;

(y) invoices and accounting information;

(z) IP address;

(aa) browser and device information;

(ab) login, authentication and security information;

(ac) approximate or precise device location where a location-enabled feature is used;

(ad) messages and communications;

(ae) survey and form responses;

(af) documents and files;

(ag) committee, governance, policy and handover records;

(ah) user permissions and Club roles;

(ai) support requests;

(aj) audit history and activity logs;

(ak) information supplied through integrations;

(al) AI prompts and information supplied to AI functionality; and

(am) other information reasonably necessary to provide EFS functionality selected by a Club or user.

The exact information collected depends on the EFS features being used.

5. Sensitive information

Some information handled through EFS may constitute sensitive information under Australian privacy law.

This may include health information, disability information, certain cultural information and other protected categories.

Sensitive information will only be collected or processed where reasonably necessary for a permitted function and where the collection is authorised by law, supported by appropriate consent where required, or another lawful exception applies.

Where a Club collects sensitive information and provides it to EFS, the Club is responsible for ensuring that its collection and disclosure to EFS is lawful.

EFS encourages Clubs to collect only information reasonably necessary for legitimate Club functions.

6. Children

EFS is designed for sporting organisations and therefore may handle significant amounts of information concerning children and young people.

A Club may create or import a child participant record even where the child does not have an EFS login.

A person must generally be at least 13 to create their own EFS account.

Users under 18 may be required to have an associated parent or guardian account for particular functionality.

For example, EFS may require parent or guardian involvement for registration, consent, higher-risk information or other functions where adult involvement is appropriate.

Where a Club enters information concerning a child into EFS, the Club is responsible for ensuring that it is entitled to collect, use and disclose that information.

Specific parental consent is not necessarily required for every ordinary Club administrative record. However, consent must be obtained where required by applicable privacy or other law, including where required because of the nature of sensitive information or the particular intended use or disclosure.

Clubs must take particular care before publicly publishing a child’s personal information, photograph, video, contact information or other information through a Club Portal.

EFS may provide technical controls designed to help Clubs manage children’s information, but the Club remains responsible for the way it uses those controls.

7. How we collect information

We may collect information:

(a) directly from you;

(b) when you create an account;

(d) from a Club;

(e) from a Club administrator;

(f) from a registration;

(g) from a purchase or transaction;

(h) from an uploaded spreadsheet, file or document;

(i) from a connected sporting platform;

(j) from Stripe, Square or another payment provider;

(k) from an authorised integration;

(l) when you submit a form or survey;

(m) when you contact support;

(n) when you use an EFS website or application;

(o) through cookies and similar technology;

(p) through authentication and security systems;

(q) through system and audit logs;

(r) through device location permissions where a location-enabled feature is used; and

(s) from another lawful source where reasonably necessary.

8. Why we collect and use information

We may collect, hold, use or disclose information for purposes including:

(a) creating and managing EFS accounts;

(b) operating Club workspaces;

(d) supporting registrations;

(e) managing family relationships and guardians;

(f) organising teams, groups and seasons;

(g) conducting grading, reviews and team formation;

(h) processing or recording payments;

(i) facilitating Club Transactions;

(j) supplying EFS products;

(k) delivering tickets and digital products;

(l) operating merchandise and canteen services;

(m) managing facilities and assets;

(n) operating Club portals;

(o) providing communications;

(p) managing documents and Club Vault information;

(q) supporting volunteer and committee administration;

(r) providing AI and automation functions where enabled;

(s) operating integrations;

(t) providing customer support;

(u) securing the Platform;

(v) detecting fraud and abuse;

(w) maintaining logs and audit history;

(x) investigating complaints and incidents;

(y) meeting legal and regulatory obligations;

(z) administering subscriptions and EFS billing;

(aa) improving EFS products;

(ab) performing analytics;

(ac) developing new features;

(ad) performing capacity planning;

(ae) producing aggregated or de-identified statistics; and

(af) otherwise performing functions reasonably expected in connection with the services requested by a Club or user.

9. Information provided by Clubs

A Club may import information from an existing database, registration platform, spreadsheet, governing body, competition system or other authorised source.

EFS does not independently verify every item of Club-provided information.

The Club is responsible for ensuring that information supplied to EFS is obtained lawfully and is appropriate for the Club’s intended use.

10. Artificial intelligence

EFS provides or may provide artificial intelligence functionality powered principally by OpenAI and potentially other providers in the future.

When AI functionality is enabled, information submitted to or selected for AI processing may be disclosed to the relevant AI service provider for processing.

That information may include personal information where a Club or authorised user includes personal information in a prompt, document or selected dataset.

Clubs are responsible for ensuring that they are authorised to use personal information with AI functionality.

EFS may provide a Club-level setting allowing a Club to prevent AI systems from accessing Club information.

Where a Club disables AI access, functionality that depends on AI may be disabled or significantly reduced.

EFS does not require Clubs to enable AI functionality simply in order to maintain their core Club records.

EFS seeks to design AI functionality so that meaningful human involvement remains in significant decisions affecting individuals.

AI output should not be treated as automatically correct.

11. Automated decisions and decision support

EFS may use computer programs to assist with security, fraud detection, matching, prioritisation, categorisation, recommendations, allocation, workflow automation and other functions.

Some EFS features may use personal information to produce recommendations or assist a person making a decision.

Where an automated system is used in a way that makes, or substantially and directly contributes to making, a decision that could reasonably be expected to significantly affect an individual’s rights or interests, EFS will describe the relevant categories of personal information and decisions in this Policy or another notice where required by law.

EFS’s general design position is that significant sporting or participant decisions using EFS decision-support tools should involve human review.

12. Payments

EFS uses third-party payment processors.

Payments for subscriptions, hardware and other products sold by EFS are generally processed by Stripe.

Payments for products supplied by Clubs may be processed through a Club’s connected Stripe or Square account.

EFS does not ordinarily store complete credit or debit card numbers or CVV/card security codes.

Payment processors may provide EFS with related information including:

(a) payment status;

(b) payment provider transaction identifiers;

(d) limited or masked card information;

(e) billing details;

(f) payment amount;

(g) refund information;

(h) dispute and chargeback information; and

(i) other information reasonably necessary for transaction administration, reconciliation, security and support.

Payment processors handle payment credentials under their own privacy and security arrangements.

13. Club payment information

Where a Club connects Stripe or Square, EFS may receive information necessary to facilitate the integration, reconcile transactions, calculate EFS platform fees, display transaction information and provide related functionality.

Funds for Club Transactions are ordinarily paid to or for the benefit of the relevant Club, subject to processing fees, EFS platform fees, refunds, disputes and the configuration of the payment processor.

14. Location information

EFS does not currently require precise GPS location for ordinary Platform use but may introduce features that use device location.

Location-enabled functionality may include delivery, matchday, facilities, asset management, attendance, field operations or other location-dependent services.

Where precise device location is required, EFS will ordinarily request device or browser permission.

A user may generally decline location permission, although the relevant feature may not work correctly.

Location information will not be collected merely because EFS has reserved the possibility of providing location functionality in the future.

15. Photographs and video

Clubs may store or publish photographs and videos using EFS.

These may include images of children.

The relevant Club is responsible for determining whether it has authority to collect, store, use or publish the image.

EFS processes the image to provide the service selected by the Club.

16. Communications

EFS may use contact information for:

(a) transactional messages;

(b) account and security notifications;

(d) Club operational communications;

(e) support;

(f) EFS marketing where permitted; and

(g) Club marketing where the Club has configured a relevant communication.

Recipients may unsubscribe from marketing messages.

Unsubscribing from marketing does not necessarily prevent messages that are required to complete a transaction, administer an account, provide security notifications or deliver a service requested by the recipient.

Clubs are responsible for their own mailing lists and their compliance with applicable marketing and communications law.

17. Cookies and analytics

EFS websites and applications may use cookies, browser storage and similar technology for:

(a) authentication;

(b) security;

(d) remembering preferences;

(e) Platform functionality;

(f) analytics; and

(g) performance monitoring.

The EFS marketing website currently uses Google Analytics.

Google Analytics may collect information about website usage, devices and interactions in accordance with Google’s applicable privacy arrangements.

The core EFS Platform may use essential and functional technology even where marketing analytics is not used.

18. Disclosure of information

EFS may disclose personal information to:

(a) the Club with which an individual is associated;

(b) authorised Club administrators and personnel;

(d) Square;

(e) Amazon Web Services;

(f) OpenAI where AI functionality is enabled;

(g) Hostinger and infrastructure providers;

(h) email and communications service providers;

(i) analytics providers;

(j) security and authentication providers;

(k) professional advisers;

(l) insurers;

(m) contractors assisting EFS;

(n) providers of integrations authorised by a Club;

(o) regulators, courts, law enforcement or government bodies where legally required or reasonably necessary;

(p) a purchaser or successor in connection with a legitimate corporate transaction, subject to appropriate protections; and

(q) other parties where authorised by the individual or otherwise permitted by law.

EFS does not sell personal information to advertisers.

19. Overseas processing and disclosure

EFS uses Australian and overseas technology providers.

EFS currently uses Amazon Web Services services in the Sydney, Australia region for relevant infrastructure and storage services.

EFS also currently uses hosting infrastructure supplied by Hostinger in Indonesia.

Information processed using OpenAI, Google Analytics, Stripe, Square or other international technology providers may be processed or accessed outside Australia.

Countries in which personal information may be processed or disclosed are therefore likely to include:

Australia, Indonesia and the United States of America, together with other countries in which EFS’s service providers or their subprocessors lawfully operate.

The exact location may vary according to the provider, service configuration and infrastructure used at the relevant time.

Where required by Australian privacy law, EFS will take reasonable steps in relation to overseas disclosures of personal information.

20. Data security

EFS takes reasonable technical, administrative and organisational steps designed to protect personal information from misuse, interference, loss and unauthorised access, modification or disclosure.

Measures may include:

(a) access controls;

(b) account permissions;

(d) encryption;

(e) secure communication protocols;

(f) restricted administrative access;

(g) monitoring and logging;

(h) backups;

(i) security reviews;

(j) infrastructure security controls; and

(k) incident response procedures.

The exact safeguards may evolve as technology and risk change.

No organisation can guarantee that electronic information will never be compromised.

21. Club Vault

EFS may provide a Club Vault intended for restricted or confidential information.

Vault information may include governance documents, financial information, contracts, credentials, API information and other restricted Club records.

EFS may require multi-factor authentication for users authorised to access Club Vault.

Clubs remain responsible for determining who should have Vault access and for removing that access when it is no longer required.

22. Data breaches

EFS maintains processes for responding to suspected privacy and security incidents.

Where a breach is subject to the Notifiable Data Breaches scheme or another mandatory notification requirement, EFS will assess the incident and make notifications required by applicable law.

Depending on the circumstances, this may include notification to affected individuals and the Office of the Australian Information Commissioner.

A Club must promptly notify EFS if it becomes aware of suspected unauthorised access to EFS information through the Club’s accounts or users.

23. Data quality

EFS takes reasonable steps within its control to maintain the accuracy and integrity of information.

Much of the operational information held in EFS is entered or maintained by Clubs.

Individuals who believe Club information is inaccurate should generally contact the Club responsible for the information.

24. Access to personal information

An individual may request access to personal information about them held by EFS.

Requests may be made to contact@equippedforsport.com.

Where information is controlled or maintained principally by a Club, EFS may refer the request to, or consult with, that Club.

EFS will provide access where required by applicable law.

Access may be refused, limited or provided in an alternative form where permitted by law, including where disclosure would unreasonably affect another person’s privacy, reveal legally protected information or another statutory exception applies.

EFS will not refuse access merely because information is inconvenient or unfavourable.

25. Correction

An individual may ask EFS or the relevant Club to correct personal information that is inaccurate, out of date, incomplete, irrelevant or misleading.

Where appropriate, EFS may ask the Club responsible for the relevant operational record to review the correction.

26. Deletion requests

Individuals may request deletion of information.

Deletion is not an absolute right under Australian law and EFS may need to retain information where reasonably necessary or legally required.

For Club operational information, deletion decisions may require involvement of the relevant Club.

EFS may retain records required for financial, legal, fraud, security, audit or dispute purposes.

Information may also remain in secure backups until those backups expire under normal retention cycles.

27. Club closure and retention

When a Club leaves EFS, EFS’s standard approach is to provide a 30-day read-only period unless different arrangements apply.

After that period, ordinary Club access may be removed.

Club information may be retained for up to 12 months following termination or closure to allow recovery, legal compliance, account administration or an authorised restoration where appropriate.

After the applicable retention period, EFS may delete or de-identify operational Club information unless continued retention is legally required or otherwise authorised.

Financial, transaction, audit, fraud and security information may be retained for longer where required or reasonably necessary.

Backups expire through EFS’s ordinary backup cycles.

A Club may request permanent deletion of its account and associated Club information.

EFS will action such a request subject to legal retention requirements, legitimate dispute or security requirements, technical backup cycles and information EFS is independently required or entitled to retain.

28. Aggregated and de-identified information

EFS may use aggregated or de-identified information for analytics, benchmarking, research, product improvement, security, operational planning and similar legitimate purposes.

Information will only be treated as de-identified where individuals are not reasonably identifiable.

EFS may retain genuinely de-identified information after identifiable source records are deleted.

29. Direct marketing

EFS may send marketing communications where permitted by law.

Recipients may unsubscribe using the mechanism provided in the relevant communication or by contacting EFS.

EFS will not require a person to continue receiving optional EFS marketing as a condition of receiving ordinary Platform services.

A Club is separately responsible for marketing communications it sends using EFS.

30. Privacy complaints

A person who believes EFS has mishandled their personal information may contact:

contact@equippedforsport.com

Please provide sufficient information for us to understand and investigate the issue.

EFS will seek to acknowledge and investigate complaints within a reasonable period.

Where appropriate, we may consult the relevant Club.

If a privacy complaint cannot be resolved, an individual may have the right to complain to the Office of the Australian Information Commissioner or another appropriate regulator.

31. Changes to this Privacy Policy

EFS may update this Privacy Policy as EFS services, technology and legal obligations change.

Material changes will be communicated where appropriate.

The current version will be made available through an EFS website or Platform.

32. Contact

Privacy enquiries, access requests, correction requests and privacy complaints may be sent to:

Equipped For Sport Pty Ltd trading as Equipped For Sport
ABN 28 701 343 688
ACN 701 343 688
Email: contact@equippedforsport.com