Sport Shutter Pty Ltd
Privacy Policy
Effective Date: 03 March, 2026
1 Introduction
1.1 About This Policy
Sport Shutter Pty Ltd ACN 645 232 284 (Sport Shutter) is committed to protecting your privacy and complying with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs).
This Privacy Policy explains:
• what personal information we collect;
• how we collect, use, disclose and store your personal information;
• your rights to access and correct your personal information;
• how to make a complaint about a breach of the APPs; and
• how we will handle any complaint.
1.2 Our Services
Sport Shutter operates an online marketplace platform at sportshutter.com (Website) that connects photographers who upload and sell photographs directly to customers who purchase licenses to use those photographs (Services).
1.3 Consent
By using our Website or Services, or by providing your personal information to us, you consent to the collection, use, disclosure and storage of your personal information in accordance with this Privacy Policy. If you do not agree with this Privacy Policy, you must not use our Website or Services or provide us with your personal information.
1.4 Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of material changes by:
• posting the updated Privacy Policy on our Website;
• sending an email notification to the address associated with your account; or
• displaying a prominent notice on the Website.
Your continued use of our Website or Services after any changes indicates your acceptance of the updated Privacy Policy. We recommend you review this Privacy Policy regularly.
2 What Personal Information We Collect
2.1 Types of Personal Information
Personal information is 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.
We may collect the following types of personal information:
2.1.1 Account and Identity Information
• Full name
• Email address
• Username and password
• Date of birth
• Phone number
• Residential or business address
• Proof of identity documents (if required for verification purposes)
2.1.2 Payment and Financial Information
• Credit card or debit card details
• Bank account details (for photographers receiving payments)
• Billing address
2.1.3 Profile and Content Information
• Profile photographs and biographical information
• Photographs uploaded by photographers
• Comments, reviews and feedback
• Communications with other users
• Marketing preferences
2.1.4 Technical and Usage Information
• IP address
• Browser type and version
• Device information (type, operating system, unique device identifiers)
• Cookie identifiers
• Pages visited and links clicked
• Time and date of visits
• Referring website addresses
• Search queries entered on our Website
• Download and upload activity
2.1.5 Location Information
• Geographic location based on IP address
• Location data from mobile devices (if you enable location services)
2.1.6 Communications
• Correspondence with our customer support team
• Survey responses
• Feedback and complaints
• Any other information you provide to us
2.2 Sensitive Information
We do not generally collect sensitive information unless:
• you voluntarily provide it;
• it is necessary for our functions or activities;
• we are required or authorized by law; and
• you have consented to the collection.
If photographs uploaded to our platform contain sensitive information about identifiable individuals, it is the photographer's responsibility to obtain appropriate consents and comply with privacy laws.
2.3 Information About Third Parties
If you provide us with personal information about another person (for example, when submitting a model release), you must ensure that:
• you are authorised to provide that information to us;
• you have informed that person about this Privacy Policy; and
• you have obtained their consent where required.
2.4 Anonymous and Pseudonymous Interactions
Where practicable, you may interact with us anonymously or using a pseudonym. However, this may not be possible where:
• we are required or authorised by law to collect your real name and contact details;
• it is impractical to provide our Services without knowing your identity; or
• we need to verify your identity for security or fraud prevention purposes.
For example, you cannot create an account or make purchases anonymously or under a pseudonym.
3 How We Collect Personal Information
3.1 Direct Collection
We collect personal information directly from you when you:
• create an account (as a photographer or customer);
• complete registration forms;
• upload photographs or other content;
• purchase photographs or licenses;
• communicate with us via email, phone, or contact forms;
• subscribe to newsletters or marketing communications;
• participate in surveys, competitions or promotions;
• provide feedback or reviews;
• make inquiries or complaints; or
• otherwise interact with our Website or Services.
3.2 Automatic Collection
We automatically collect certain information when you access or use our Website or Services through:
3.2.1 Cookies and Similar Technologies
We use cookies, web beacons, pixels and similar technologies to:
• remember your preferences and settings;
• authenticate your account;
• analyze how you use our Website;
• improve our Services;
• deliver targeted advertising; and
• prevent fraud and enhance security.
You can control cookies through your browser settings, but disabling cookies may affect your ability to use certain features of our Website.
3.2.2 Analytics Tools
We use analytics services (including Google Analytics) to collect information about how users interact with our Website. These services may use cookies and similar technologies to collect and analyse usage data.
3.2.3 Log Files
Our servers automatically record information including your IP address, browser type, referring/exit pages, operating system, date/time stamps and clickstream data.
3.3 Collection from Third Parties
We may collect personal information about you from third parties, including:
3.3.1 Payment Processors
We receive transaction information from third-party payment processors when you make purchases or receive payments through our platform.
3.3.2 Social Media Platforms
If you connect your Sport Shutter account to social media platforms or use social media features on our Website, we may receive information from those platforms in accordance with their privacy policies and your privacy settings.
3.3.3 Service Providers
We may receive information from service providers who assist us with identity verification, fraud prevention, analytics, marketing and other business functions.
3.3.4 Publicly Available Sources
We may collect information from publicly available sources such as public registers, directories and social media profiles.
3.3.5 Other Users
We may receive information about you from other users, such as when:
• another user includes you in a photograph they upload;
• another user provides your contact details; or
• another user makes a complaint or inquiry that involves you.
4 How We Use Your Personal Information
4.1 Primary Purposes
We collect, use and disclose your personal information for the following purposes:
4.1.1 Providing Our Services
• Creating and managing your account
• Processing transactions between photographers and customers
• Facilitating the upload, display, sale and licensing of photographs
• Processing payments and distributing funds to photographers
• Providing customer support
• Communicating with you about your account and transactions
• Enforcing our Terms and Conditions and Content License Agreements
4.1.2 Service Improvement and Development
• Analyzing how users interact with our Services
• Improving our Website, Services and user experience
• Developing new features and functionality
• Conducting research and analysis
• Testing and troubleshooting
4.1.3 Marketing and Communications
• Sending you newsletters, promotional materials and service updates
• Providing you with personalised content and recommendations
• Conducting surveys and seeking feedback
• Informing you about new features, products or services
4.1.4 Security and Fraud Prevention
• Verifying your identity
• Detecting, preventing and investigating fraud, unauthorized access and illegal activities
• Protecting the security and integrity of our Website and Services
• Complying with security requirements
4.1.5 Legal and Regulatory Compliance
• Complying with our legal obligations under Australian and international laws
• Responding to legal processes and government requests
• Enforcing our legal rights and defending against legal claims
• Complying with tax, accounting and reporting requirements
• Resolving disputes
4.1.6 Business Operations
• Managing our business operations
• Conducting audits and quality assurance
• Maintaining business records
• Business planning and reporting
• Facilitating corporate transactions (such as mergers, acquisitions or sales)
4.2 Secondary Purposes
We may also use your personal information for purposes related to the primary purposes set out above, where you would reasonably expect us to use the information for that secondary purpose.
4.3 Direct Marketing
We may use your personal information to send you direct marketing communications about our products and services, including:
• email newsletters
• promotional offers
• service updates
• new feature announcements
• surveys and feedback requests
You can opt out of receiving marketing communications at any time by:
• clicking the "unsubscribe" link in our emails;
• adjusting your account settings; or
• contacting us using the details provided in this Privacy Policy.
We will not use or disclose sensitive information for direct marketing purposes without your express consent.
5 How We Disclose Your Personal Information
5.1 Disclosure to Other Users
5.1.1 Photographers
When you create a photographer account, certain information is made publicly visible to customers and other users, including:
• Your photographer name/username
• Profile information you choose to make public
• Photographs you upload
5.1.2 Customers
When you purchase a photograph, your transaction information may be shared with the photographer in accordance with our Terms and Conditions.
5.2 Disclosure to Service Providers
We may disclose your personal information to third-party service providers who assist us with our business operations, including:
5.2.1 Payment Processors
We use third-party payment processors to handle payment transactions. These processors collect and process payment information in accordance with their own privacy policies and applicable payment card industry standards.
5.2.2 Cloud Hosting Providers
We store data on servers operated by cloud hosting providers located in Australia and overseas.
5.2.3 Technology Service Providers
We engage service providers for:
• Website hosting and maintenance
• Data storage and backup
• Email delivery services
• Analytics and data analysis
• Customer relationship management
• Marketing automation
• Security and fraud prevention
5.2.4 Professional Advisors
We may disclose information to:
• Legal advisors
• Accountants and auditors
• Business advisors and consultants
• Insurance providers
5.3 Disclosure for Business Transactions
If Sport Shutter is involved in a merger, acquisition, sale of assets, corporate reorganization or other business transaction, we may disclose your personal information to:
• potential or actual buyers, investors or successor entities;
• advisors involved in the transaction; and
• parties conducting due diligence.
Any such disclosure will be subject to confidentiality obligations and the recipient will be required to handle your personal information in accordance with this Privacy Policy or an equivalent policy.
5.4 Legal and Regulatory Disclosure
We may disclose your personal information where:
• required or authorized by law;
• necessary to comply with legal process (such as subpoenas, court orders or warrants);
• requested by government authorities or law enforcement agencies;
• necessary to enforce our Terms and Conditions or other agreements;
• necessary to protect our rights, property or safety, or the rights, property or safety of our users or the public;
• necessary to detect, prevent or investigate fraud, security breaches or illegal activities; or
• necessary in connection with actual or contemplated legal proceedings.
5.5 Disclosure with Your Consent
We may disclose your personal information to other parties where you have provided your consent or it is reasonably necessary and you would expect us to do so.
5.6 De-identified and Aggregated Information
We may disclose de-identified or aggregated information that does not identify you personally for research, statistical analysis, marketing or other business purposes.
6 Overseas Disclosure
6.1 Storage and Processing Overseas
Your personal information may be stored on servers located outside Australia, including in:
• United States of America
• European Union countries
• Singapore
• Other countries where our service providers operate
6.2 Service Providers Overseas
We may disclose your personal information to overseas service providers who assist us with:
• cloud hosting and data storage
• payment processing
• customer support
• analytics and data analysis
• marketing services
6.3 Your Acknowledgment
By using our Services, you acknowledge and agree that:
• your personal information may be transferred to, stored and processed in countries outside Australia;
• overseas recipients may not be subject to the Privacy Act or laws that provide the same level of protection as Australian privacy laws; and
• you may not be able to seek redress under the Privacy Act in relation to how overseas recipients handle your personal information.
7 Data Security
7.1 Security Measures
We implement reasonable physical, technical and administrative security measures to protect your personal information from:
• unauthorized access, use or disclosure
• loss, misuse or alteration
• destruction
Our security measures include:
• encryption of data in transit and at rest
• secure servers and databases
• firewalls and intrusion detection systems
• access controls and authentication
• regular security assessments and updates
• employee training on data security and privacy
• confidentiality obligations for staff and service providers
7.2 Account Security
You are responsible for:
• maintaining the confidentiality of your username and password;
• all activities that occur under your account; and
• notifying us immediately of any unauthorized access or security breach.
7.3 Limitations
While we implement reasonable security measures, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security of your personal information.
7.4 Data Breaches
In the event of a data breach that is likely to result in serious harm to you, we will:
• notify you as soon as practicable where required in accordance with the Privacy Act;
• notify the Office of the Australian Information Commissioner (OAIC) where required in accordancy with the Privacy Act; and
• take reasonable steps to remediate the breach.
8 Data Retention
8.1 Retention Period
We retain your personal information for as long as:
• necessary to provide our Services to you;
• your account remains active;
• required to comply with our legal obligations;
• necessary for backup, archival and audit purposes;
• necessary to resolve disputes or enforce our agreements; and
• otherwise as required or permitted by law.
8.2 Active Accounts
For active accounts, we retain personal information until:
• you delete your account; or
• your account is terminated in accordance with our Terms and Conditions.
8.3 Inactive Accounts
If your account has been inactive for more than 12 months, we may delete your account and associated personal information after providing reasonable notice.
8.4 Deletion Upon Request
You may request deletion of your personal information, subject to:
• our legal and regulatory obligations;
• ongoing legitimate business purposes;
• existing Content License Agreements (as defined in our Terms and Conditions); and
• our need to resolve disputes or enforce our agreements.
8.5 Backup Systems
Personal information may persist in backup systems for a limited period after deletion from our active systems.
9 Your Rights and Choices
9.1 Access to Your Personal Information
You have the right to request access to the personal information we hold about you. To request access you must:
• submit a request using the contact details in this Privacy Policy;
• provide sufficient information to verify your identity, including complying with our reasonable requests in this regard; and
• specify the information you wish to access.
We will respond to your access request within a reasonable period (generally within 30 days) and will provide you with access to your personal information unless:
• we are not required by law to provide access;
• providing access would be unlawful;
• providing access would prejudice enforcement activities, legal proceedings or dispute resolution;
• providing access would reveal commercially sensitive information; or
• providing access would be unreasonably burdensome or expensive.
If we refuse your access request (in whole or in part), we will provide you with written reasons for the refusal and the mechanisms available to complain about the refusal. In most circumstances we will not charge any fee for providing access to your personal information. However, we nevertheless reserve the right to charge a reasonable fee to cover the costs of providing access to your personal information, where we deem it appropriate in the circumstances.
9.2 Correction of Personal Information
You have the right to request correction of your personal information if it is inaccurate, out-of-date, incomplete, irrelevant or misleading. To request correction you must:
• submit a request using the contact details in this Privacy Policy;
• specify the information you believe is incorrect; and
• provide evidence supporting the correction (if applicable).
You can also update certain information directly through your account settings.
We will respond to your correction request within a reasonable period and will take reasonable steps to correct the information. If we refuse to correct your personal information, we will:
• provide you with written reasons for the refusal;
• provide mechanisms for you to complain about the refusal; and
• upon your request, take reasonable steps to associate a statement with your personal information that you believe it is inaccurate, out-of-date, incomplete, irrelevant or misleading.
We do not charge a fee for correcting your personal information or associating a statement with it.
9.3 Marketing Preferences
You can opt out of receiving marketing communications by:
• clicking the "unsubscribe" link in our emails;
• updating your marketing preferences in your account settings;
• contacting us using the details in this Privacy Policy.
Please note that even if you opt out of marketing communications, we will still send you:
• transactional emails related to your account and purchases;
• service announcements and updates;
• important notices about changes to our Terms and Conditions or Privacy Policy; and
• responses to your inquiries.
9.4 Deletion of Personal Information
You may request deletion of your personal information by:
• deleting your account through your account settings; or
• contacting us using the details in this Privacy Policy.
When you delete your account:
• we will delete or de-identify your personal information, except where we are required or permitted to retain it;
• photographs you have uploaded will be removed from the Website;
• existing Content License Agreements will remain in effect; and
• transaction records will be retained as required by law.
Please note that:
• deletion may not be immediate and some information may persist in backup systems;
• we may retain certain information as required for legal, accounting or regulatory purposes;
• we may retain aggregated or de-identified information; and
• some information may remain visible in cached or archived pages.
9.5 Portability
Upon request, we will provide you with a copy of your personal information in a structured, commonly used and machine-readable format where:
• technically feasible;
• required by law; and
• we hold the information in electronic form.
9.6 Objection to Processing
You may object to our processing of your personal information in certain circumstances. If you object, we will:
• consider your objection;
• cease processing if we do not have legitimate grounds that override your interests; or
• explain why we must continue processing.
10 Children's Privacy
10.1 Age Restrictions
Our Services are not intended for children under 18 years of age. We do not knowingly collect personal information from children under 18.
10.2 Parental Supervision
Children under 18 may only use our Services under the supervision of a parent or guardian who must:
• create and maintain the account;
• supervise all use of the Services;
• be responsible for all activities under the account; and
• agree to our Terms and Conditions and this Privacy Policy.
10.3 Photographs Containing Children
If you upload photographs containing images of children, you must:
• obtain appropriate consent from parents or guardians;
• comply with all applicable laws regarding children's privacy; and
• ensure you have valid model releases where required.
10.4 Deletion of Children's Information
If we become aware that we have collected personal information from a child under 18 without appropriate parental consent, we will take steps to delete that information as soon as practicable. If you believe we have collected information from a child without appropriate consent, please contact us immediately using the details in this Privacy Policy.
11 Contact Us
If you have any questions, concerns or complaints about this Privacy Policy or our privacy practices, please contact us:
Privacy Officer
Sport Shutter Pty Ltd
Email: support@sportshutter.com
We will acknowledge receipt of your inquiry within 5 business days and will endeavor to respond substantively within 30 days. When contacting us, please provide:
• your full name and contact details;
• sufficient information to verify your identity;
• details of your inquiry, request or complaint; and
• your preferred method of communication.
12 Complaints And Dispute Resolution
12.1 Making a Complaint
If you believe we have breached the Privacy Act or the APPs, you may lodge a complaint with us using the contact information provided in this Privacy Policy.
Your complaint should include:
• your contact details;
• details of the alleged breach;
• the outcome you are seeking; and
• any supporting documentation.
12.2 Our Complaints Process
When we receive a complaint, we will:
• acknowledge receipt of your complaint within 5 business days;
• investigate your complaint thoroughly and objectively; and
• provide you with a written response within 30 days (or longer if more time is reasonably needed).
If you are not satisfied with our response to your complaint, you may contact the Office of the Australian Information Commissioner (OAIC):
Online: https://www.oaic.gov.au/privacy/privacy-complaints
Phone: 1300 363 992
Mail:
Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
Email: enquiries@oaic.gov.au
The OAIC can investigate complaints about alleged breaches of the Privacy Act and the APPs.