Privacy Policy

1.1 Athletic Ventures Pty Ltd (ACN 642 501 339) ("Athletic Ventures", "we", "our", or "us") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and protect your personal information in relation to our AV Clubhouse service ("Clubhouse"), an information/education product hosted on Notion where subscribers get access to information helpful for financial decisions and investing.

1.2 This Privacy Policy is designed to comply with the Australian Privacy Principles (“APPs”) contained in the Privacy Act 1988 (Cth) and should be read in conjunction with our Terms and Conditions. By using Clubhouse, you consent to the collection, use, and disclosure of your personal information as described in this Privacy Policy.

Types of Personal Information

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2.1 We may collect and hold the following types of personal information:

• (a) Identity Information: Full name, date of birth, gender;
• (b) Contact Information: Email address, physical address, phone number;
• (c) Account Information: Username, password (encrypted);
• (d) Financial Information: Payment details (processed through Stripe);
• (e) Professional Information: Occupation, job title, company name;
• (f) Investment Information: Investment preferences, risk tolerance, investment history;
• (g) Technical Information: login history or activity on Clubhouse,
• (h) IP address, browser type, device information, operating system;
• (i) Usage Data: Log data, access times, pages viewed, features used;
• (j) Communication Data: Records of your interactions with us; and
• (k) Marketing and Communications Data: Your preferences in receiving marketing from us and our third parties and your communication preferences.

Sensitive Information

2.2 We do not generally collect sensitive information as defined in the Privacy Act 1988 (Cth). However, if we do need to collect sensitive information, we will only do so with your explicit consent or where required or authorised by law.

3.1 We collect personal information through various channels, including:

• (a) Direct interactions: When you register for Clubhouse, fill out forms, or correspond with us by post, phone, email, or otherwise;
• (b) Automated technologies: As you interact with Clubhouse, we may automatically collect technical data about your equipment, browsing actions, and patterns;
• (c) Third parties or publicly available sources: We may receive personal information about you from various third parties and public sources, such as:
  • (i) Analytics providers;
  • (ii) Advertising networks;
  • (iii) Search information providers;
  • (iv) identity and background check providers
  • (v) Publicly available sources such as company registries or social media platforms

4.1 We collect and use your personal information for purposes that are directly related to our functions or activities, or as otherwise permitted by law. We will only use or disclose your personal information for the primary purposes for which it was collected, or for secondary purposes if:

• (a) You have consented to the use or disclosure; or
• (b) You would reasonably expect us to use or disclose the information for that secondary purpose, and that purpose is related to the primary purpose of collection; or
• (c) The use or disclosure is required or authorised by or under an Australian law or a court/tribunal order; or
• (d) A permitted general situation exists in relation to the use or disclosure of the information; or
• (e) We reasonably believe that the use or disclosure is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body.

4.2 We collect and use your personal information for the following purposes:

• (a) To provide and maintain Clubhouse;
• (b) To process your subscription and payments;
• (c) To personalise your experience and deliver content relevant to your interests;
• (d) To provide customer support and respond to your inquiries;
• (e) To send you prompts to use AV Club service;
• (f) To inform you about AV College options;
• (g) To offer investment opportunities to eligible users;
• (h) To offer select users further paid opportunities;
• (i) To communicate with you about your account, our services, and important notices;
• (j) To conduct surveys and collect feedback on our services;
• (k) To improve and personalise our services;
• (l) To develop new products, services, features, and functionality;
• (m) To comply with legal obligations;
• (n) To detect and prevent fraud, abuse, security incidents, and other harmful activity;
• (o) To verify your identity and eligibility for certain services;
• (p) To conduct audits and resolve disputes; or
• (q) To enforce our Terms and Conditions and other policies.

5.1 We may disclose your personal information to:

• (a) To enforce our Terms and Conditions and other policies or terms of platforms, including those relating to:
  • (i) Airtable (database management);
  • (ii) EdApp (learning management system);
  • (iii) Notion (content hosting and management); and
  • (iv) Stripe (payment processing);
• (b) Regulators and law enforcement agencies, as required by law;
• (c) Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets; or
• (d) Other third parties with your consent or as permitted by law.

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5.2 We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

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6.1 We may disclose your personal information to recipients located outside Australia, including to our service providers. We take reasonable steps to ensure that these overseas recipients do not breach the Australian Privacy Principles in relation to your personal information.

6.2 Countries other than Australia to which we may disclose your personal information include:

• (a) United States (for Airtable, EdApp, Notion, and Stripe services);
• (b) to the extent relevant, the United Kingdom (if and where we may be using systems or processors domiciled in the United Kingdom); and
• (c) to the extent relevant, the European Union (if and where we may be using systems or processors domiciled in the European Union).

6.3 Your personal information may be transferred to and processed in countries other than Australia, including the United States, where our service providers may be located. These countries may have different data protection laws than Australia.

6.4 When we transfer your personal information outside of Australia, we ensure that:

• (a) Other third parties with your consent or as permitted by law;
• (b) We have taken reasonable steps to ensure that the recipient does not breach the APPs in relation to the information, which may include:
  • (i) Stripe (payment processing)
  • (ii) personal information in accordance with the APPs; or
  • (iii) Ensuring the recipient is subject to a law or binding scheme that provides similar protection to the APPs

6.5 By using Clubhouse, you consent to the transfer of your personal information to these countries. We will take appropriate measures to ensure that your personal information remains protected in accordance with this Privacy Policy and applicable data protection laws.

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7.1 We retain your personal information for as long as necessary to provide you with Clubhouse and to comply with our legal obligations. As our service is likely to be ongoing, we will retain your information until you opt-out or request deletion of your data.

7.2 Specific retention periods for different aspects of your personal information are as follows:

• (a) Account information: Retained for the duration of your account plus 7 years after account closure;
• (b) Financial information: Retained for 7 years as required by Australian tax law;
• (c) Usage data: Retained for 2 years for analytics purposes; and
• (d) Marketing preferences: Retained until you opt-out or request deletion.

7.3 We retain your personal information for as long as necessary to provide you with Clubhouse and to comply with our legal obligations. As our service is likely to be ongoing, we will retain your information until you opt-out or request deletion of your data.

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8.1 Under Australian privacy law, you have the following rights regarding your personal information:

• (a) Access: You have the right to request access to the personal information we hold about you;
• (b) Correction: You have the right to request that we correct inaccurate or incomplete information about you;
• (c) Deletion: You can request that we delete your personal information in certain circumstances;
• (d) Objection: You can object to our processing of your personal information in certain circumstances;
• (e) Withdrawal of consent: You can withdraw your consent at any time where we rely on consent to process your personal information; and
• (f) Opt-out of marketing: You have the right to opt-out of receiving direct marketing communications from us.

To exercise these rights, please contact us using the details provided at the end of this Privacy Policy.

8.2 We will respond to your request within a reasonable timeframe (usually within 30 days).

8.3 Please note that there may be circumstances where we are not required to provide you with access to your personal information or to comply with your request, in which case we will provide you with a written explanation.

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9.1 Under the General Data Protection Regulation (EU 2016/679) (GDPR), an individual residing in the European Union has enhanced privacy rights, including the right to:

• (a) Correction: require us to correct any personal information held about you that is inaccurate or incomplete;
• (b) Deletion: require the deletion of personal information concerning you in certain situations;
• (c) Portability: data portability for personal information you provide to us;
• (d) Consent: object or withdraw your consent at any time to the processing of your personal information;
• (e) Automation: object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you; or
• (f) Processing: otherwise restrict our processing of your personal information in certain circumstances.

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9.2 Subject to some exceptions provided by the relevant privacy lawes, you may request access to your personal information in our customer account database, or seek correction of it, by contacting us at team@athletic.vc. Should we decline you access to your personal information, we will provide a written explanation setting out our reasons for doing so.

9.3 We may charge a reasonable fee that is not excessive to cover the charges of retrieving your personal information from our customer account database. We will not charge you for making the request.

9.4 If you believe that we hold personal information about you that is not accurate, complete, or up to date, then you may request that your personal information be amended.  We will respond to your request to correct your personal information within a reasonable timeframe, and you will not be charged a fee for correcting your personal information. 

9.5If we no longer need your personal information for any of the purposes set out in this Privacy Policy, or as otherwise required by the relevant privacy laws, we will take such steps as are reasonable in the circumstances to destroy your personal information or to de-identify it.

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10.1 We take reasonable steps to protect your personal information from unauthorised access, modification, or disclosure. These measures include:

• (a) Using industry-standard encryption (such as SSL/TLS) for data in transit and at rest;
• (b) Implementing access controls and authentication measures, including multi-factor authentication for administrative access;
• (c) Regularly reviewing and updating our security practices;
• (d) Conducting regular security assessments and penetration testing;
• (e) Providing security training to our employees;
• (f) Maintaining physical security measures for our offices and data centers;
• (g) Implementing data loss prevention techniques;
• (h) Using firewalls and intrusion detection systems; and
• (i) Regularly backing up data and testing restoration procedures.

However, no method of transmission over the Internet or electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

10.2 In the event of a data breach that is likely to result in serious harm to individuals, we will comply with the Notifiable Data Breaches scheme under the Privacy Act 1988 (Cth), including notifying affected individuals and the Office of the Australian Information Commissioner (OAIC).

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11.1 We use cookies and similar tracking technologies to collect information about your browsing activities on Clubhouse. This information helps us improve our services and provide a better user experience.

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12.1 Essential cookies: These are necessary for the website to function and cannot be switched off in our systems.

12.2 Performance cookies: These allow us to count visits and traffic sources so we can measure and improve the performance of our site.

12.3 Functionality cookies: These enable the website to provide enhanced functionality and personalisation.

12.4 Targeting cookies: These may be set through our site by our advertising partners to build a profile of your interests and show you relevant adverts on other sites.

12.5 Managing Cookie Preferences: You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.Unless you have adjusted your browser setting so that it will refuse Cookies, our system will issue Cookies when you direct your browser to our Website.  If you disable or refuse cookies, please note that some parts of Clubhouse may become inaccessible or not function properly.

12.6 Do Not Track Signals: We do not currently respond to "Do Not Track" signals from web browsers.

13.1 Clubhouse may contain links to third-party websites. We are not responsible for the privacy practices or content of these websites. We encourage you to read the privacy policies of these websites before providing any personal information.

13.2 When you leave our website, we recommend that you read the privacy notice of every website you visit.

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14.1 Clubhouse is not intended for use by children under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take steps to delete that information as soon as possible.

14.2 If you believe that we might have any information from or about a child under 18, please contact us using the details provided at the end of this Privacy Policy.

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15.1 We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any material changes by posting the updated Privacy Policy on Clubhouse and updating the "Last Updated" date at the top of this Privacy Policy.

15.2 For significant changes to this Privacy Policy, we will make reasonable efforts to provide notification through our services or by other means, such as email, to inform you of the changes and give you the opportunity to review them before they go into effect.

15.3 We encourage you to review this Privacy Policy periodically to stay informed about our information practices and your privacy choices.

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16.1 If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact our Privacy Officer at:

16.2 Athletic Ventures Pty Ltd Attn: Privacy Officer 1/ 571 South Dowling Street Surry Hills, NSW 2010 Australia Email: team@athletic.vc.

16.3 We will respond to your inquiry within a reasonable timeframe, typically within 30 days.

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17.1 If you believe that we have breached this Privacy Policy or the Australian Privacy Principles, you can make a complaint by contacting our Privacy Officer using the details above. We will investigate your complaint and respond to you in writing within a reasonable time (usually within 30 days).

17.2 If you are not satisfied with our response, or if you believe that we have not adequately dealt with your complaint, you can contact the Office of the Australian Information Commissioner (OAIC) at:

17.3 Office of the Australian Information Commissioner GPO Box 5218 Sydney NSW 2001 Phone: 1300 363 992 Email: enquiries@oaic.gov.au Website: www.oaic.gov.au

18.1 Where practicable, we will give you the option of not identifying yourself or using a pseudonym when dealing with us. However, this will not be possible where we are required or authorised by law to deal with individuals who have identified themselves or for the purposes of providing our services.

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19.1 We may use your personal information to send you marketing communications about our products and services that we believe may be of interest to you. We will always give you the opportunity to opt-out of receiving such communications.

19.2 You can opt-out of receiving marketing communications from us at any time by:

• (a) Following the unsubscribe instructions provided in any marketing communication
• (b) Contacting us using the details provided in the "Contact Us" section of this policy; or
• (c) Adjusting your communication preferences in your account settings.

20.1 We do not use government identifiers (such as tax file numbers or Medicare numbers) as a means of identifying individuals in our records.

20.2 By using Clubhouse, you acknowledge that you have read and understood this Privacy Policy and agree to the collection, use, and disclosure of your personal information as described herein.

This Privacy Policy was last updated on 30 September 2024.