Raffle Privacy Policy

This Privacy Policy explains how GT Comrades Cricket Club Inc., ABN 19 217 257 197, handles personal information collected in connection with the Club’s raffle platform at https://raffles.gtcomrades.com.au. The Club adopts the practices described in this Policy as its operating privacy standard, including where particular provisions of the Privacy Act 1988 (Cth) may not apply to the Club.

The Club does not intentionally collect or store complete payment-card numbers, card security codes (CVV/CVC) or card expiry details in its raffle database.

Payment information is entered into and processed by the Club’s payment service provider. The provider may collect payment-card, billing, fraud-prevention and transaction information under its own privacy terms. The Club generally receives payment status, transaction identifiers and other information needed to reconcile the payment and allocate an entry, rather than complete card credentials.

The Club uses third-party technology providers to operate the raffle. Current providers include Supabase for database/authentication services, Netlify for website/application hosting and deployment, Brevo for transactional email, and an approved payment service provider for payments. Providers may use their own subprocessors.

Personal information may pass from the participant’s browser to the Club’s hosted application, database, payment provider and email provider as reasonably necessary for the relevant transaction or claim.

The Club’s primary raffle database is currently hosted through Supabase in the Tokyo, Japan region (ap-northeast-1). Accordingly, core raffle records may be stored in Japan.

The website/application is hosted using Netlify infrastructure, which may involve processing through infrastructure outside Australia. Transactional email is delivered through Brevo, whose service infrastructure may involve processing in the European Union and other locations used by its subprocessors. Payment providers may process personal information in Australia, the United States and other jurisdictions in which they or their subprocessors operate.

As a result, personal information may be stored, processed, accessed or disclosed outside Australia, including in Japan and potentially the European Union, United States and other jurisdictions used by service providers. Hosting arrangements and subprocessors may change over time. The Club will take reasonable steps appropriate to its legal obligations when selecting and using service providers and will update this Policy if there is a material change in its handling of personal information.

Operational raffle emails may include ticket confirmations, promotional claim confirmations, material raffle updates, draw information, prize communications, refund/payment communications and service notices. Transactional emails may be sent from raffle@gtcomrades.com.au.

Purchasing or claiming an entry does not automatically subscribe a participant to unrelated marketing. The Club will not use raffle contact details for ongoing promotional marketing unless the person separately consents or the communication is otherwise permitted by law. Where required, marketing communications will identify the sender and provide a functional unsubscribe mechanism.

The Club does not sell participant personal information. Information may be disclosed to service providers and professional advisers where reasonably necessary to operate or protect the raffle, process payments, send communications, investigate fraud or disputes, obtain professional advice, comply with law, respond to lawful government/regulatory requests or enforce the raffle rules.

The Club may publish limited winner information, such as first name, abbreviated surname, winning ticket number and prize won, on the raffle website and Club social channels. The Club will not publish a winner’s residential address, complete phone number, full email address, identification documents or payment information unless required by law.

The Club uses reasonable technical and organisational safeguards appropriate to the platform, including HTTPS, protected administrator access, access controls, server-side secrets, database security rules, audit records and reputable technology/payment providers. No internet service can be guaranteed completely secure.

Club officers and volunteers with access to raffle information should access only what they reasonably need, keep credentials confidential, avoid sharing participant exports unnecessarily and securely delete local working copies when no longer required.

If the Club becomes aware of a suspected data breach, it will take reasonable steps to contain the incident, preserve relevant evidence, assess the information and people affected, reduce likely harm, secure affected systems and comply with any notification obligations that apply to the Club.

Raffle and fundraising information will be retained for as long as reasonably necessary for community-gaming compliance, fundraising and accounting records, audit, dispute resolution, fraud prevention, prize administration, security and other legitimate operational purposes.

Where a NSW fundraising record-keeping requirement requires a longer period, the Club will retain the relevant record for that period. Financial/accounting records may need to be retained for at least seven years, while other fundraising records may need to be retained for at least three years depending on the Club’s authority/status and applicable requirements. Information no longer reasonably required will be securely deleted or de-identified where practical.

Participants may contact secretary.gtccc@gmail.com to ask what personal information the Club holds about them or to request correction of inaccurate information. The Club may need to verify identity before providing access or making a change. Some records cannot be deleted or altered where retention is reasonably required for legal, accounting, fraud-prevention, prize-administration or draw-integrity purposes.

The raffle is restricted to persons aged 18 years or over. The Club does not knowingly invite children to enter the raffle. If the Club becomes aware that a person under 18 has submitted an entry, it may take reasonable steps to investigate and deal with the entry and information consistently with the raffle rules and applicable law.

The Club may update this Policy where reasonably necessary. Material changes affecting current raffle participants will be published on the raffle website and, where appropriate, communicated directly.

Privacy questions, access/correction requests or complaints may be sent to secretary.gtccc@gmail.com. The Club aims to acknowledge and investigate privacy concerns within a reasonable period.