The Rugby Factory Pty Ltd
Privacy Policy
Last Updated: 27 February 2026
The Rugby Factory Pty Ltd (“TRF”, “we”, “our”, or “us”) is committed to protecting your privacy.
This Privacy Policy explains how we collect, use, store, share, and protect personal information when you use The Rugby Factory mobile application and associated services.
1. Who We Are
TRF is an Australian company operating a global rugby talent platform.
Data Controller:
The Rugby Factory Pty Ltd
Nixon Street
Sydney, NSW, Australia
[email protected]
2. Information We Collect
2.1 Information You Provide
We may collect:
Name, email address, and date of birth
Password (securely hashed)
Phone number (mandatory for guardians; optional otherwise unless required for verification)
Player profile details
Performance statistics and verification videos
Posts, comments, messages, and other user-generated content
Payments processed via Stripe. We do not store full card numbers.
2.2 Automatically Collected
We may collect:
IP address
Device and browser information
Usage activity and interaction data
Approximate location based on IP
GPS location only where explicit consent is provided
You may revoke location permissions at any time in your device settings.
2.3 Verification Data
To protect platform integrity, we may process:
Date of birth reconfirmation
$0 credit card authorisation
Identity verification results via third-party providers
We receive only confirmation of verification status.
2.4 Fraud Prevention & Integrity
We collect limited device fingerprinting and IP reputation data solely for fraud detection and prevention.
3. Legal Basis (Where Applicable)
Where required by applicable law (including GDPR), we process personal data under:
Contract performance
Legitimate interests (security, fraud prevention, platform integrity)
Consent (marketing, GPS location)
Legal obligation
Parental consent for minors
Where we rely on legitimate interests, we balance those interests against your rights and freedoms.
4. How We Use Information
We use data to:
Operate and manage accounts
Enable rankings, discovery, and comparisons
Process payments
Moderate content and enforce Terms
Detect fraud and protect minors
Improve platform performance
5. How We Share Information
We do not sell, rent, or trade personal information.
We may share information with:
Service providers (hosting, payment, identity verification, analytics)
Sponsors (aggregated or anonymised data only)
Event organisers where you participate
Legal authorities where required
In connection with a merger, acquisition, or sale of assets
All service providers are contractually required to protect data.
6. Marketing
Marketing communications are strictly opt-in.
You may unsubscribe at any time.
Service-related communications (e.g., security alerts) may still be sent.
7. Security
We implement:
TLS encryption in transit
Encryption at rest
Role-based access controls
Monitoring and logging
Encrypted backups
No system is completely secure, but we maintain reasonable safeguards.
8. Children’s Privacy
Users 16+ may register independently
Users 13–15 must use a Guardian-Managed Profile
Children under 13 are not permitted
We do NOT:
Allow direct messaging to minors
Collect gym-based strength statistics under 16
Use children’s data for advertising
Share children’s data for marketing
All communications to Guardian-Managed Profiles are routed through the Guardian.
Guardians may request access, correction, deletion, or withdrawal of consent at any time.
9. Age Verification & Integrity
We may request additional verification to protect users and maintain platform integrity.
10. Reporting & Investigations
We investigate reports under legitimate interest to protect user safety.
Reporter identities remain confidential.
11. Your Rights
Depending on your jurisdiction (including under GDPR, the Australian Privacy Act, and applicable US state laws), you may have rights to:
Access
Correction
Deletion
Restriction
Portability
Object to processing
Withdraw consent
To exercise rights, contact: [email protected]
If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (oaic.gov.au) or your local data protection authority.
12. Data Retention
We retain data only as necessary for operational, legal, and security purposes.
Active accounts: duration of account + 90 days
Payment records: 7 years
Investigation records: 24 months
Logs: 90 days
After the retention period, data is securely deleted or anonymised.
13. International Transfers
Our infrastructure may be located in the EU, Australia, and the United States.
Where personal data is transferred internationally, we rely on:
Standard Contractual Clauses
Adequacy decisions
Contractual safeguards
14. Cookies
We use cookies for:
Essential session management
Security
Analytics and performance
We do not use third-party advertising cookies.
15. Data Breach Notification
We notify affected users and regulators where required by applicable law.
16. Automated Decision-Making
Automated systems may assist in:
Content moderation
Bot detection
Ranking calculations
You may request human review of significant automated decisions.
17. Updates
We may update this policy. Material changes will be communicated via email or in-app notification.
18. Contact
[email protected]
[email protected]
[email protected]
Australian regulator: https://oaic.gov.au