1.1 WhereIAm Group Pty Ltd (ACN 157 847 928) and its wholly-owned subsidiary, Where I Am Corp (collectively, ‘Sports Where I Amʼ,‘we’, ‘us’ or ‘our’) have adopted this Privacy Policy to ensure that we have standards in place to protect the Personal Information that we collect about individuals that is necessary and incidental to:

(a) Providing the system and services that we offer; and

(b) The normal day-to-day operations of our business.

1.2 This Privacy Policy is designed to comply with global privacy standards, including:

(a) The Australian Privacy Principles set by the Australian Government for the handling of Personal Information under the Privacy Act 1988 (Cth) (Privacy Act);

(b) The regulations and principles set by the European Unionʼs General Data Protection Regulation (Regulation 2016/679) (GDPR) for the handling of Personal Data;

(c) The UK General Data Protection Regulation and the Data Protection Act 2018; and

(d) State privacy laws in the United States, including the California Consumer Privacy Act as amended by the California Privacy Rights Act (collectively, 'CCPA').

(collectively, “Applicable Privacy Laws”)

1.3 By publishing this Privacy Policy we aim to make it easy for our customers and the public to understand what Personal Information we collect and store, why we do so, how we receive and/or obtain that information, and the rights an individual has with respect to their Personal Information in our possession.

2.1 Our Privacy Policy deals with how we handle “personal information” and “personal data” as it is defined in the Applicable Privacy Laws (Personal Information). This relates to information that identifies, relates to, describes, or is reasonably capable of being associated with an individual.

2.2 We act as data controllers for the personal information collected through our website (sportswhereiam.com), mobile applications, customer service channels, and ticket distribution platforms (collectively, the "Services").We therefore handle Personal Information in our own right and also for and on behalf of our customers and users.

2.3 Our Privacy Policy does not apply to information we collect about businesses or companies, however it does apply to information about the people in those businesses or companies that we store.

2.4 The Privacy Policy applies to all forms of information, physical and digital, whether collected or stored electronically or in hardcopy.

2.5 If, at any time, an individual provides Personal Information or other information about someone other than himself or herself, the individual warrants that they have that person's consent to provide such information for the purpose specified.

2.6 We consider the protection of privacy of children very important. We do not knowingly collect personal data from children under the age of 16 without obtaining parental consent. If an individual is under 16 years of age, then they should not use or access the service at any time or in any manner. If we learn that Personal Information has been collected on the service from persons under 16 years of age and without verifiable parental consent, then we will take the appropriate steps to delete such information.

3.1 In the course of business it is necessary for us to collect Personal Information. This information allows us to identify who an individual is for the purposes of our business, share Personal Information when asked of us, contact the individual in the ordinary course of business and transact with the individual. Without limitation, the type of information we may collect is:

(a) Identifiers. We may collect personal details such as an individual’s name, location, date of birth, nationality, family details and other information defined as “Personal Information” in the Applicable Privacy Laws that allows us to identify who the individual is;

(b) Contact Information. We may collect information such as an individual’s email address, telephone & fax number, third-party usernames, residential, business and postal address and other information that allows us to contact the individual;

(c) Profile Information. Including when you create an account with us, or when you connect or provide us with your third-party profile details (e.g. Facebook). In these circumstances we may collect information specified on those profiles, as well as any content like messages, posts or photos you post or make available;

(d) Financial and Transactional Information. We may collect financial information related to an individual such as any bank or credit card details used to transact with us; billing address, transaction history, and purchase details and other information that allows us to transact with the individual and/or provide them with our services;

(e) Technical Information. We may collect the IP Addresses of users accessing our systems, the actions of users on our website and other digital information created by an individualʼs use of our online systems, including browser type, operating system, network activity, clickstream data, and interactions with pixels/cookies;

(f) Booking Information: We may collect information specific to bookings that are made or facilitated through us, which may include information regarding your planned itinerary, as well as other types of information such as event preferences, itinerary details, seating preferences, delivery instructions ;

(g) Statistical Information. We may collect, create, and process de-identified, aggregated, or anonymised statistical data derived from your interactions with our Services (such as general event attendance trends, platform usage patterns, purchase histories, and venue popularity). This aggregated data does not directly or indirectly reveal your identity and is used solely to analyse platform performance, improve customer experience, and optimise our ticket distribution services; and

(h) Information an individual sends us. We may collect any personal correspondence that an individual sends us, or that is sent to us by others about the individual’s activities. This includes, without limitation, information or feedback contained in communications between you and our customer support teams, which from time to time might take place over third party platforms (e.g. Facebook).

3.2 We may collect other Personal Information about an individual, which we will maintain in accordance with this Privacy Policy.

3.3 To the extent that any data we collect is fully de-identified, anonymised, or aggregated such that it cannot reasonably be used to identify an individual or device, such data does not constitute Personal Information, and Applicable Privacy Laws do not apply to our use or disclosure of that data.

4.1 Most information will be collected in association with an individualʼs use of Sports Where I Am, an enquiry about Sports Where I Am or generally dealing with us and our Services. However, we may also receive Personal Information from sources such as advertising, an individualʼs own promotions, public records, mailing lists, contractors, staff, recruitment agencies and our business partners. In particular, information is likely to be collected as follows:

(a) Registrations/Subscriptions. When an individual registers or subscribes for a service, account, connection or other process whereby they enter Personal Information details in order to receive or access something, including a transaction;

(b) Purchases/Bookings. When an individual purchases tickets, or makes bookings with our assistance, or when we are engaged to make such purchases or bookings on behalf of individuals;

(c) Sharing with other Users. When an individual provides Personal Information to other users of the website or service;

(d) Supply. When an individual supplies us with goods or services;

(e) Contact. When an individual contacts us in any way, including without limitation through our customer service channels, by completing user surveys, leaving feedback, or participating in promotional contests;

(f) Access. When an individual accesses us physically we may require them to provide us with details for us to permit them such access. When an individual accesses us through the internet we may collect information using cookies (if relevant – an individual can adjust their browserʼs setting to accept or reject cookies) or analytical services; and/or

(g) Pixel Tags. Pixel tags enable us to send email messages in a format customers can read and they tell us whether mail has been opened. Third-party tools (e.g., Meta Pixel, Google Tag Manager) measure conversion rates and serve targeted advertisements based on your browsing habits. Our systems automatically detect and honour Global Privacy Control browser signals as valid opt-out requests under applicable US state laws.

4.2 We may receive information from public records, mailing lists, recruitment agencies, advertising partners, and social media platforms when you link your profile. As there are many circumstances in which we may collect information both electronically and physically, we will endeavour to ensure that an individual is always aware of when their Personal Information is being collected.

4.3 Where we obtain Personal Information without an individualʼs knowledge (such as by accidental acquisition from a client) we will either delete/destroy the information, or inform the individual that we hold such information, in accordance with the Applicable Privacy Laws.

5.1 In general, the primary principle is that we will not use any Personal Information other than for the purpose for which it was collected other than with the individualʼs permission. The purpose of collection is determined by the circumstances in which the information was collected and/or submitted, but generally relates to the operation of our business or the provision of services request by you.

5.2 We will only process Personal Information when we can identify a lawful basis to do so. It is always our responsibility to ensure that we can demonstrate which lawful basis applies to the particular processing purpose.

5.3 The most common lawful bases relied upon are:

(a) Consent: we will only rely upon express, clear and informed consent. Any consent provided may specify and/or restrict the purpose, and can be withdrawn at any time without penalty. We will keep a record of when and how we got consent from an individual;

(b) Legitimate interests: we will only rely upon an identifiable legitimate interest where we can demonstrate that the processing of Personal Information is necessary to achieve it by balancing it against the individualʼs interests, rights and freedoms. We will keep a record of our legitimate interests assessments; and

(c) Contract Performance: Processing necessary to fulfill ticket orders, manage accounts, and deliver requested services.

5.4 We may utilise automated processing, machine learning, and artificial intelligence (AI) technologies such as automated customer support tools, fraud prevention algorithms, and personalised event recommendation engines. We do not sell your Personal Information to AI developers or use your Personal Information to train public, un-anonymised third-party Large Language Models (LLMs). Where required by Applicable Privacy Laws, you have the right to request human intervention or opt out of automated profiling that produces significant legal or commercial effects.

5.5 We will retain Personal Information for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

5.6 If it is necessary for us to disclose an individualʼs Personal Information to third parties in a manner compliant with Applicable Privacy Laws in the course of our business, we will inform you that we intend to do so, or have done so, as soon as practical.

5.7 We will not disclose or sell or surrender Personal Information to unrelated third parties under any circumstances including monetary payment, unless the prior written consent of the individual is obtained. However, we disclose Personal Information to:

(a) Service Providers: Cloud hostings, payment processors (e.g., Stripe, PayPal), and email delivery tools (e.g., Mailchimp, Google Workspace) located in the US and Australia.

(b) Primary Venues & Primary Brokers: Venues, teams, or primary ticketing partners strictly necessary to facilitate your physical entry into an event.

(c) Corporate Restructuring: Potential buyers or corporate successors in the event of a merger, acquisition, or asset sale.

(d) Law Enforcement and Regulatory Bodies: Where required by legal process or to investigate suspected fraud or breach of terms.

5.8 We recognise that under US state privacy laws (including California's CCPA/CPRA, Virginia's VCDPA, and Texas's TDPSA), residents possess specific statutory rights regarding their personal data. While we do not sell data for money, our use of third-party advertising pixels and analytics cookies may constitute a "Sale" or "Sharing" (for cross-context behavioral advertising) under California law.

5.9 In these circumstances, US Resident Rights possess the right to Opt out of the "Sale" or "Sharing" of data for targeted behavioral advertising; click the "Do Not Sell or Share My Personal Information" link in our website footer; enable Global Privacy Control (GPC) on your browser.

5.10 Information is used to enable us to operate our business, especially as it relates to an individual. This may include:

(a) The provision of goods and services between an individual and us;

(b) Verifying an individualʼs identity;

(c) Communicating with an individual about: i Their relationship with us; ii Our goods and Services; iii Our own marketing and promotions to customers and prospects; iv Offers from our partners to our customers; v Competitions, surveys and questionnaires

(d) Investigating any complaints about or made by an individual, or if we have reason to suspect that an individual is in breach of any of our terms and conditions or that an individual is or has been otherwise engaged in any unlawful activity; and/or

(e) As required or permitted by Applicable Privacy Laws.

5.11 There are some circumstances in which we must disclose an individualʼs information:

(a) Where the disclosure is necessary to provide you with services that you have requested, and we have agreed to provide;

(b) Where the disclosure is necessary to improve our service delivery and business practices, though in these circumstances we will endeavour to de-identify any personal information before disclosing it;

(c) Where we reasonably believe that an individual may be engaged in fraudulent, deceptive or unlawful activity that a governmental authority should be made aware of;

(d) As required by Applicable Privacy Laws including in compliance with court orders, statutory tax reporting, or government mandates; and/or

(e) In order to sell our business (in that we may need to transfer Personal Information to a new owner).

5.12 We operate internationally and may transfer, store, or process your Personal Information outside of your country of residence, including to our subsidiary (Where I Am Corp.) in the United States and and other jurisdictions where our servers and third-party service providers are located. When we disclose Personal Information to overseas recipients, we take reasonable steps to ensure that appropriate data protection safeguards are in place in accordance with Applicable Privacy Laws such as executing intra-group data transfer agreements, standard contractual clauses, or obtaining your express consent where necessary to fulfill your ticket transactions and bookings.

6.1 An individual may opt to not have us collect their Personal Information. This may prevent us from offering them some or all of our services and may terminate their access to some or all of the services they access with or through us. They will be aware of this when:

(a) Opt In. Where relevant, the individual will have the right to choose to have information collected and/or receive information from us; or

(b) Opt Out. Where relevant, the individual will have the right to choose to exclude himself or herself from some or all collection of information and/or receiving information from us.

6.2 If an individual believes that they have received information from us that they did not opt in or out to receive, they should contact us on the details below.

7.1 We will take all reasonable precautions to protect an individualʼs Personal Information from unauthorised access. This includes appropriately securing our physical facilities electronic networks and the implementation of role-based access controls restricting internal employee data access.

7.2 We uses Transport Layer Security (TLS) and SSL encryption for data in transit and AES-256 for data at rest to store and transfer Personal Information. Despite this, the security of online transactions and the security of communications sent by electronic means or by post cannot be guaranteed. Each individual that provides information to us via the internet, over the phone or by post does so at their own risk. We cannot accept responsibility for misuse or loss of, or unauthorised access to, Personal Information where the security of information is not within our control.

7.3 Our Services are intended for a general audience and are not directed at children.

7.4 We do not knowingly collect Personal Information from children under 13 years of age without verifiable parental consent. We do not sell or share the Personal Information of consumers under 16 years of age without explicit opt-in authorisation. If we learn that we have inadvertently collected data from a child under 13 without parental consent, we will destroy the data immediately.

7.5 We are not responsible for the privacy or security practices of any third party (including third parties that we are permitted to disclose an individualʼs Personal Information to in accordance with this policy or any applicable laws) unless otherwise required by Applicable Privacy Laws. The collection and use of an individualʼs information by such third parties may be subject to separate privacy and security policies.

7.6 If an individual suspects any misuse or loss of, or unauthorised access to, their Personal Information, they should let us know immediately.

7.7 We are not liable for any loss, damage or claim arising out of another personʼs use of the Personal Information where we were authorised to provide that person with the Personal Information.

7.8 Where there is a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Information, then:

(a) We will immediately establish the likelihood and severity of the resulting risk to wider rights and freedoms of natural persons;

(b) If we determine there is a risk from the security breach, then we will immediately notify the relevant supervisory authority and provide all relevant information on the particular breach, and by no later than 72 hours after having first become aware of the breach;

(c) If we determine there is a high risk from the security breach (a higher threshold than set for notifying supervisory authorities), we will immediately notify the affected individuals and provide all relevant information on the particular breach without undue delay.

7.9 We will document the facts relating to any security breach, its effects and the remedial action taken, and investigate the cause of the breach and how to prevent similar situations in the future.

8.1 Users of Sports Where I Am can update their Personal Information from within their Sports Where I Am account or profile.

8.2 Depending on your country or state of residence, you hold specific statutory rights regarding your Personal Information under Applicable Privacy Laws.

8.3 You have the right to request from us the Personal Information that we have about you, and we have an obligation to provide you with such information as soon as practicable, and by no later than 28 days of receiving the written request. We may be required to transmit the Personal Information directly to another organisation if this is technically feasible.

8.4 If an individual cannot update their own information, we will correct any errors in the Personal Information we hold about an individual within 28 days of receiving written notice from them about those errors, or two months where the request for rectification is complex.

8.5 It is an individualʼs responsibility to provide us with accurate and truthful Personal Information. We cannot be liable for any information that is provided to us that is incorrect.

8.6 Where a request to access Personal Information is manifestly unfounded, excessive and/or repetitive, we may refuse to respond or charge an individual a reasonable fee for our costs incurred in meeting any of their requests to disclose the Personal Information we hold about them. Where we refuse to respond to a request, we will explain why to the individual, informing them of their right to complain to the supervisory authority and to a judicial remedy without undue delay and at the latest within 28 days.

8.7 You have the right to opt out of direct marketing, restrict how we process your data, or opt out of the "sale" or "sharing" of your data for cross-context behavioral advertising.

8.8 We may be required to delete or remove all Personal Information we have on an individual upon request in the following circumstances:

(a) Where the Personal Information is no longer necessary in relation to the purpose for which it was originally collected and/or processed;

(b) When the individual withdraws consent;

(c) When the individual objects to the processing and there is no overriding legitimate interest for continuing the processing;

(d) The processing of the Personal Information was otherwise in breach of Applicable Privacy Laws;

(e) The Personal Information has to be erased in order to comply with a legal obligation; and/or

(f) The Personal Information is in relation to a child.

8.9 We may refuse to delete or remove all Personal Information we have on an individual where the Personal Information was processed for the following reasons:

(a) To exercise the right of freedom of expression and information;

(b) To comply with a legal obligation for the performance of a public interest task or exercise of official authority.

(c) For public health purposes in the public interest;

(d) Archiving purposes in the public interest, scientific research historical research or statistical purposes; or

(e) The exercise or defence of legal claims.

8.10 We will never discriminate against you, such as by charging higher ticket prices, denying services, or offering a lower quality of user experience, for exercising any of your privacy rights.

8.11 If we decline to take action on your privacy request, residents in applicable jurisdictions have the right to appeal our decision by replying directly to our written notice.

8.12 To submit a request to access, correct, delete, or opt out, please contact our Data Protection Officer at privacy@sportswhereiam.com. We will verify your identity using account credentials and fulfill your request free of charge within 28 to 30 days of receipt.

9.1 We have appointed a Data Protection Officer to oversee the management of this Privacy Policy and compliance with the Applicable Privacy Laws.

9.2 If you believe your privacy rights have been infringed, please submit a written complaint to our Data Protection Officer. We will attempt to resolve the matter directly with you within 30 days.

9.3 If you remain dissatisfied, you have the right to lodge a complaint with your local regulatory authority:

(a) Australia: Office of the Australian Information Commissioner (OAIC) — www.oaic.gov.au

(b) United Kingdom: Information Commissioner’s Office (ICO) — www.ico.org.uk

(c) European Union: Your national Data Protection Authority (DPA)

(d) United States: The Federal Trade Commission (FTC) or your State Attorney General.

10.1 From time to time, we may send an individual important notices, such as changes to our terms, conditions and policies. Because this information is important to the individualʼs interaction with us, they may not opt out of receiving these communications.

11.1 All correspondence with regards to privacy should be addressed to:

Global Data Protection Officer WhereIAm Group Pty Ltd PO Box 1200
Windsor VIC 3141 privacy@sportswhereiam.com
You may contact the Data Protection Officer by email in the first instance.

12.1 We reserve the right to modify this Privacy Policy at any time., Updates will be posted on our webpage at sportswhereiam.com/privacy-policy with a revised "Last Updated" date. Continued use of our Services following notice of amendments indicates acceptance of the revised policy.

12.2 We may do things in addition to what is stated in this Privacy Policy to comply with the Applicable Privacy Laws, and nothing in this Privacy Policy shall deem us to have not complied with Applicable Privacy Laws.