PRIVACY POLICY
Last updated May 2025
Aligned Leisure Pty Ltd (ABN 58 608 613 350) (Aligned Leisure) handles the personal information we collect about you in accordance with this Privacy Policy and our obligations under the Privacy Act 1988 (Cth) (Privacy Act), including the Australian Privacy Principles (APPs). We may also handle personal information in accordance with other applicable privacy laws (such as the Health Records Act 2001 (Vic) (HRA) and the Health Privacy Principles (HPPs)) and other state based privacy laws that govern how service providers like Aligned Leisure handle personal information (such as health information). We also handle personal information in accordance with our contractual obligations.
We understand the importance of being open and transparent with you in the way in which we collect, hold, store, use and share your personal information. We take protecting your privacy very seriously.
We strongly encourage you read this document, so that you understand and are comfortable with how we handle your personal information. If you have any questions about this document, or about Aligned Leisure’s handling of your personal information, please contact us using the relevant contact details set out in section 17.
Aligned Leisure partners with local government authorities, schools and other asset owners (Partners) to manage and operate their key aquatic, sports, leisure and theatre facility assets and deliver broad-based community programs.
Aligned Leisure works with the following Partners:
This Privacy Policy applies to Aligned Leisure, including the recreation and leisure facilities that Aligned Leisure manages for its Partners (see section 2 above).
Our Partners handle your information in accordance with their respective privacy policies and notices and privacy management plans (as applicable).
To better understand how our Partners handle your personal information, you should review the relevant privacy policies, notices and the privacy management plan of the relevant Partner. Our Partners who are Victorian Councils who are required to have a privacy management plan which sets out how they comply with relevant state based privacy laws.
Links to each of the Partner’s privacy policies (current as at the date of this Privacy Policy) are found here:
This document sets out our policies for managing your personal information and is referred to as our Privacy Policy.
In this Privacy Policy, “we“, “us” and “our” refers to Aligned Leisure and “you” and “your” refers to any individual about whom we collect personal information.
This Privacy Policy sets out how we collect, store, process, use and disclose personal information (including personal information we collect, and personal information submitted to us, whether offline or online).
Other terms and conditions may apply to you such as:
- the privacy terms and conditions contained in contractual arrangements we may have with you; and
- the collection notices and privacy statements which may be provided to you at the time your personal information is collected (for example, the collection notice provided to you when you sign up for a membership at a Partner facility that we manage, or the collection notice provided when you commence work with us).
“Personal information” is defined in the Privacy Act, and means information or an opinion about an identified individual, or an individual who is reasonably identifiable:
- whether the information or opinion is true or not; and
- whether the information or opinion is recorded in a material form or not.
In this Privacy Policy, whenever we use the term “personal information”, we are referring to this legal definition.
Personal information does not include aggregated or de-identified data.
In providing our services, we may also collect health information, which is a particular subset of personal information. “Health Information” is a kind of “sensitive information” also defined in the Privacy Act, and means:
- information or an opinion about the health or disability of an individual; or
- information or an opinion about an individual’s expressed wishes about the future provision of health services to that individual;
- personal information collected to provide, or in providing a health service.
In order to provide you with the services that you have requested, or to otherwise interact with us, Aligned Leisure may need to collect your personal information.
In summary, we may collect your personal information when:
- we are awarded a contract to operate a facility (in which case we may receive your personal information from the previous operator or from our new Partner);
- you apply for a membership via a Partners’ site that is managed by us;
- you interact with our employees and contractors at the Partners’ facilities in person or via phone or online (including through our website, a Partners’ website for the services, which we manage, or our social media channels, such as when you contact us to make an enquiry or give us feedback);
- you have a third party provide your personal information on your behalf, such as a carer or legal guardian;
- you apply for a position with us (including for work experience or student placements).
Summary of personal information we collect and how we collect this information
The types of personal information we usually collect about you depends on who you are and your dealings with us. However, the table below sets out a summary of the personal information we generally collect and how we collect this information:
| Who are we collecting personal information from? | What type of information may we collect? | How do we collect this information? |
|---|---|---|
| Adult – members and carers / legal guardians of members | If you are a member or a carer / legal guardian of a member, we may collect the following information:
| We may collect your personal information directly from you, for example:
We may also collect personal information about you from other people and organisations including (but not limited to):
|
| Adult – prospective members and carers / legal guardians of prospective members | If you are a prospective member or a carer / legal guardian of a prospective member, we may collect the following information:
| We may collect your personal information directly from you, for example:
We may also collect personal information about you from other people and organisations including (but not limited to):
|
| Child / student – members and prospective members | If the member or prospective member is a child (under the age of 18), we may collect the following information:
| We may collect your child / student’s personal information directly from you, for example:
We may also collect personal information about you from other people and organisations including (but not limited to):
|
| Child / student – responsible person for members and prospective members (e.g., parent. legal guardian, carer, teacher etc). | If you are the responsible person of a child, we may collect the following information about you:
| We may collect your personal information directly from you, for example:
We may also collect personal information about you from other people and organisations including (but not limited to):
|
| Employment / intern and work experience applicants | If you are applying to work with us, or if we offer you employment, internship or work experience, we may collect the following information:
| We may collect this information if you apply for a position with the Aligned Leisure (including if you are applying for an internship or work experience with us). |
| Other individuals / customers | Depending on who you are (such as a sporting participant, hirer of an area of the facility, visitor or supplier of good and services to us), we may collect:
| We may collect this information if you visit us, complete a facility-related form (such as booking a basketball shooting bay, hiring an area of the facility or attending a sporting event) at a facility or otherwise interact with us in person, online or via phone/ email. |
We may also collect other types of information, which we have summarised below:
| Type of personal information | What this includes | How do we collect this information? |
|---|---|---|
| Online and digital services information (including behavioural information) | We may collect information from you electronically, which includes information such as your IP address, and details about your device. Please see section 12 for further information on the digital information we collect. | We may collect this information when you use our website or any online services, via use of online behavioural technologies, such as cookies. Please see section 12 for further information on the digital information we collect. |
| Photographs or video recordings | We may collect camera surveillance information which includes photographs or video recordings of you. We may also take photographs or video recordings of you during pre-planned activities. | We may collect this information via:
We may use photographs or video recordings of you taken during activities for Aligned Leisure’s promotional purposes. However, where practicable we will seek your consent to taking the photo or video recording. |
| Location information | We may collect location information about you each time you use your membership pass/fob when you enter, exit and move within our facilities. This may include the exact date and time you entered and exited a facility. | We collect this information as part of our attendance data and also for safety and operational purposes. |
| Information required to be collected by law | We may collect information as required by law (such as under State and Territory healthcare legislation). | We may collect this as required. |
| Publicly available online information | We may collect information that is publicly available online, such as on online forums, websites, and social media channels (for example, information that relates to a complaint). | We may collect this directly from the publicly available source (e.g. on the online forum, website, or social media channel). |
In some cases, you may provide us with personal information which relates to another person (for example an emergency contact or a job referee). If you do so, you agree that you have received permission from these individuals for us to collect, use, and share, their personal information in accordance with this Privacy Policy.
You should also let them know about our Privacy Policy (including the information in this Privacy Policy).
We also collect the above information in circumstances where we are awarded a contract to operate a facility. In this case we may receive your personal information from the previous operator or from our new Partner.
Where possible and lawful, you may interact with us anonymously or using a fake name. For example, if you contact us with a general question or query, we will not record your name or other details unless we need it to adequately respond to your query.
However, for many of our functions and the services we provide, we need information about you including your health information as it may not be practicable for us to deal with you anonymously or pseudonymously on an ongoing basis when providing our services.
If you provide incomplete or inaccurate information to us or withhold personal health information from us, we may not be able to provide you with the services you are seeking.
The primary purpose for which we collect your personal information (including health information) will depend on who you are and your interaction with us, for example, if you are a member or other customer, prospective member or customer, job applicant, child or student, contractor, family member, carer, guardian or other authorised representative of a member or other customer or prospective member or customer.
We have summarised the types of purposes for which we may collect your personal information:
| Purpose | Explanation |
|---|---|
| To provide you with our services | We may collect, store and use your personal information to:
|
| To manage your working relationship with us (including when you are a contractor) | We may collect, store and use your personal information to assess your suitability for a position with us, and, if you successfully join us, to manage your working relationship with us. We may collect, store and use your personal information for administration and management purposes. |
| To do business with you | We may collect, store and use your personal information about you if you interact with us on a commercial basis (such as if you are a service provider, contractor or supplier to us), or you otherwise interact with us on a commercial basis. |
| To manage and improve our operations and business and services, including through the use of artificial intelligence | We may collect, store and use your personal information to:
|
| To assist with any business, share sale or corporate restructure | We may collect, store and use your personal information for the purpose of considering, facilitating or implementing a transfer or sale of all or part of our assets or business or if we undergo any other kind of corporate restructure, acquisition or sale or proposal for any such transaction. |
| To comply with contractual obligations we have with a Partner | We may collect, store and use your personal information for the purpose of complying with our contractual obligations with our Partners. For example, we may be required to collect your personal information from our Partner or a previous operator of a facility when we are awarded a contract to operate a facility. |
| To create de-identified or aggregate data sets for data analytics | We may collect, store and use your personal information to create deidentified or aggregate data sets (which is no longer personal information). We do this by de-identifying or aggregating information such as combining your information with information we have about our other individuals. We use this de-identified or aggregate data to assist with our business decisions, such as to:
|
We may share your information with third parties:
- for the reasons for which we collect, store and use that information (see above in section 8);
- for other purposes explained at the time we collect your personal information; or
- where we are otherwise allowed or required to do so under law.
Some of the third parties we may share your information with include the following:
| Recipient | Explanation |
|---|---|
| Fitness-related providers | As a member, prospective member, carer / legal guardian of a member / prospective member or visitors, we may share your personal information with the following non-exhaustive list of parties:
|
| Our service providers and advisors | We may share your personal information with a variety of our service providers to assist us with providing and managing our services. These may include our:
|
| Corporate restructure | We may share your personal information with third parties, whether affiliated or unaffiliated, for the purpose of facilitating or implementing a transfer or sale of all or part of our assets or business or if we undergo any other kind of corporate restructure, acquisition or sale. In this context, your personal information may be transferred to another entity (or if such a sale, transfer, acquisition or corporate restructure is being contemplated by us). |
| Partners, previous operators or new operators | We may be required to share or transfer your personal information with the Partner, a previous operator or a new operator under our contractual arrangements with a Partner. For example, at the end of a contractual arrangement with a Partner we may be required to share or transfer your personal information with the Partner and/or the new operator of a facility. |
| Government and law enforcement agencies | We are sometimes required by certain Commonwealth, State or Territory legislation to report health information to government agencies, regulatory bodies and law enforcement agencies, and to report member’s information to other entities for certain purposes (such as Medicare Australia, NSW Health, the Commonwealth Department of Health and State child protection agencies in relation to children at risk). |
We generally collect your personal information in Australia. However, some of the organisations we may disclose your personal information to are located overseas in United States of America, Italy and Europe. These recipients include our service providers who may handle, process or store your personal information on our behalf.
For example, we may share your personal information with service providers who assist us with storing our data on secure data storage servers, or with improving our services (by analysing data, and conducting member satisfaction enquiries).
We only ever share your personal information outside of Australia where we are permitted to do so under the Privacy Act and applicable privacy laws. Generally, this means we will take reasonable steps to ensure your personal information is treated securely and in accordance with applicable privacy laws.
There are other circumstances where we may disclose your personal information to an overseas recipient. For example, where you have provided your consent or we are otherwise permitted to do so under other relevant laws.
When you provide your personal information to Aligned Leisure, we (or our third party providers acting on our behalf) may use that personal information to send you direct marketing communications to keep you informed about services offered by Aligned Leisure which we think might be of interest to you based on your interactions with us.
We may contact you from time to time, whether by phone, SMS, email or post, to provide you with information regarding our programs, services, events, research forums, promotions and opportunities, or to ask you for your support, either by volunteering, philanthropic donations or otherwise. To help us improve our standards, we may also ask for your feedback through surveys on how you found our services.
We will only send these communications in accordance with applicable privacy and marketing laws (such as the Privacy Act (including Australian Privacy Principle 7) and the Spam Act 2003 (Cth)), and only where you have not opted out from receiving such communications from Aligned Leisure.
If you have indicated a preference for a method of communication, we will endeavour to use that method wherever practical to do so.
We may also use photographs or video recordings of you for Aligned Leisure’s promotional purposes. However, where practicable we will seek your consent to taking the photo or video recording.
How can you opt out?
You are always in control of the direct marketing communications which you receive and can opt-out at any time. Generally, you can opt-out by following the relevant opt-out or unsubscribe instructions in the relevant communication (such as email or SMS message).
You can also contact us using the detail set out in section 17 to tell us you would like to stop receiving direct marketing communications from us.
Important points regarding opting out
Importantly, regardless of whether you opt out from receiving any or all direct marketing communications, we will still communicate with you if we are required by law to provide you with information, or in relation to the services we are providing you with (for example, sending you an invoice in relation to a provided service or sending a SMS reminder about your appointment).
Third party links and sites
When you use our websites or receive communications from us, links to websites which belong to other third parties may be included (and are provided for your convenience). You should make your own enquiries as to the privacy policies of these parties. We are not responsible for information on, or the privacy practices of, any third party websites.
Website use and cookies
You may visit our websites without identifying yourself. If you identify yourself (for example, by making an enquiry), any personal information you provide to us will be managed in accordance with this Privacy Policy.
Our websites also use cookies (and we share personal information we collect within Aligned Leisure). A ‘cookie’ is a small file stored on your computer’s browser, which assists in managing customised settings of the website and delivering content. We collect certain information such as your device type, browser type, “click-through” information, IP address, pages you have accessed on our websites and on third-party websites. Depending on the circumstances, this may or may not be personal information.
At a high level, cookies can be used for a variety of reasons, such as to personalise your browsing experience (for example, by remembering your preferences and recognising you as a repeat visitor to our websites), and to track statistics about the usage of our website. This allows us to better understand our users and improve the layout and functionality of our websites.
If you do not wish to receive any cookies (other than those that are strictly necessary) you can use the settings in your browser to control how your browser deals with cookies. However, in doing so, you may be unable to access certain pages or content on our websites.
We are committed to protecting your personal information and ensuring that we securely store any personal information we collect (and in accordance with applicable privacy laws). We may hold your personal information in hard copy (paper) or electronic form.
We take all reasonable steps to ensure that any personal information we collect, use or disclose is accurate, complete, up-to-date and stored in a secure environment protected from misuse, interference and loss, and from unauthorised access, modification or disclosure.
Security and storage of personal information
| Form | Explanation |
|---|---|
| Paper-based files | We store personal information in paper-based files in secure storage (at our facilities and head office). Personal information may be collected in paper-based documents and converted to electronic form for use or storage (with the original paper-based documents either archived or securely destroyed). We maintain physical security measures to ensure that personal information in paper-based files is protected, such as physical locks and security systems at our premises. |
| Electronic records | We store electronic records in secure databases, using a company server as well as a trusted third party storage providers based in the United States of America, Italy and Europe. We also maintain physical security measures in relation to storage of our electronic records (such as through locks and security systems at our electronic data stores). Using technical methods, we also maintain computer and network security. For example, we use firewalls (security measures for the internet) and other security systems such as passwords, as well as Multi-Factor Authentication to control access to our computer systems. |
| Our websites (including for making payments) | Our websites use technologies to ensure that your personal information is securely transmitted via the internet (including to protect any payments you make). We encourage you to exercise care when sending your personal information via the internet (for example, when communicating with us online, we ask that you do not include your full account or card details). |
How long do we keep your personal information?
We will only keep your personal information we store for as long as is necessary for the purposes set out in this Privacy Policy or as required to comply with any applicable legal obligations.
When we no longer require your personal information (and in accordance with any applicable laws), we will take steps to delete, destroy or de-identify that information.
You are entitled to request access to any of your personal information that we have. To make such a request, please contact us using the relevant contact details set out below in section 17.
We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up to date. You can help us to do this by letting us know if you notice errors or discrepancies in information we hold about you and informing us of any change in your personal details (for example, if your email address changes or if you move and change address).
If you consider any personal information we have about you is inaccurate, out-of-date, incomplete, irrelevant or misleading, you are also entitled to request correction of the information (again, please contact us). After receiving a request from you, we will take reasonable steps to correct your information.
We may decline your request to access or correct your information in certain circumstances in accordance with the applicable privacy laws. If we do refuse your request, we will provide you with a reason for our decision. In addition, in the case we refuse your request for correction, we will include a statement about your request with the personal information we store.
If you have any questions or concerns about this Privacy Policy or how we have handled your personal information, you may contact us at any time using the relevant contact details set out below in section 17.
Please also contact us if you have a complaint about privacy. If you make a complaint about privacy, the following will occur:
| No. | Step |
|---|---|
| 1. | We will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. We will generally acknowledge your complaint within a week. |
| 2. | If your complaint requires more detailed consideration or investigation:
|
| 3. | We will then typically gather relevant facts, locate and review relevant documents and speak with the individuals involved. |
| 4. | In most cases, we will respond to your complaint within 30 business days from when we receive your complaint. If the matter is more complex or our investigation may take longer, we will let you know. |
If you are not satisfied with our response to a complaint, or you consider that we may have breached the Privacy Act (including the Australian Privacy Principles), you are entitled to make a complaint to the Office of the Australian Information Commissioner (the Australian privacy regulator).
You can make a complaint to the Office of the Australian Information Commissioner about our handling of your personal information. Information on making a complaint can be found here.
We may make changes to this Privacy Policy, with or without notice to you. However, where we make a material change to the Privacy Policy, we will provide notice to you (including by updating our websites, and, where appropriate, notifying you directly). We recommend you visit this Privacy Policy regularly to keep you up to date with any changes we make.
You can contact us using the details below:
| ALIGNED LEISURE GROUP | |
|---|---|
| Active Manningham | (03) 9848 0000 139-153 Williamsons Rd, Templestowe Lower VIC 3108 |
| Nillumbik Leisure | (03) 9439 2266 40 Brougham Street, Eltham VIC 3095 |
| Casey Leisure | caseyrace@alignedleisure.com.au (03) 5990 8600 65 Berwick-Cranbourne Rd, Cranbourne East VIC 3977 |
| Mildura Aquatic Facilities | mildura.waves@alignedleisure.com.au (03) 5018 7500 180/190 Deakin Ave, Mildura Vic 3500 |
| Albury Wodonga Aquatic Facilities | (02) 6058 2555 Hedgerow Ct, West Wodonga VIC 3690 |
| Eurobodalla Aquatic Facilities | baypavilions@alignedleisure.com.au (02) 4415 1800 12 Vesper Street, Batemans Bay, NSW 2536 Australia |
| Cardinia Leisure | cardinia@alignedleisure.com.au (03) 5945 2888 4-6 Olympic Way, Pakenham 3810 |
| Bass Coast Leisure | basscoast@alignedlesiure.com.au 41 Wentworth Rd, Wonthaggi VIC 3995 |