Please click here Privacy Notice (Europe)
This Privacy Notice together with our Terms of Use and any other documents referred to in it sets out how Gemba Group Pty Ltd collects, uses, maintains and discloses Personal Data, including any information provided through our website(s) (the “Website”).
Your privacy is of the utmost importance to us. Please read this Privacy Notice carefully to understand our views and practices regarding your personal data and how we will treat it.
Whenever you provide personal information, we are legally obliged to use it in accordance with the laws concerning the protection of personal information.
Who we are: Gemba Group Pty Ltd is wholly owned by the Tenka Group, a group of agencies focussed on shaping a better future for the sport and entertainment industry.

Gemba Group Pty Ltd (Gemba), a company registered in Australia whose registered address is Level 4/4-14 Foster Street Surry Hills, NSW 2010.  For the purposes of the Privacy Act 1988 (Cth) and any other applicable data protection and privacy laws and regulations, Gemba will be the ‘data controller’ for all personal information we determine the means and purpose of processing.
Our data protection practices are aimed at ensuring we protect your privacy in accordance with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth). This Privacy Notice is designed to inform you how we do that in a clear and concise fashion. If you have any questions about our data handling practices, please contact us at the address below.
By “Personal Data” we refer to information collected or held by Gemba, that identifies and relates to you as an individual.
Please note, this notice only covers information we collect as a ‘data controller’. We sometimes collect information as a ‘data processor’ on behalf of our clients. That information will be processed in accordance with the relevant client’s privacy notice.
Information we may collect
We may collect personal information about you when you request our services, including:
  • Your name;
  • Postal address;
  • Invoicing details/address;
  • Information regarding the services you (or your employ, as our client) request;
  • Supplementary information you provide us about yourself when contacting us;
  • Email address; and
  • Telephone numbers (including mobile).
We also collect information about you from third parties (including our clients) for the purposes of developing our products and services. This includes:
  • Profile Data (which may include username and password, purchases or orders made, interests, preferences (e.g. marketing), feedback and survey responses). Specifically:
    • Survey data (name, gender, age, location, family status, household income, educational qualifications, work status, description of job title, email address)
    • Client feedback forms which include name & email address
  • Audience Usage and Engagement Data (which may include information and analytics about how the data subject uses or engages with any products and/or services). Specifically:
    • Purchase data (name, address, email address)
    • Category consumption data taken from Surveys (i.e. product purchase and category intent)
  • Social Media Data (including social media identifiers or handles, login data, posts, conversations, content or sentiment information associated with a social media user)
We may also collect technical information about you when you visit the Website. This information may include the Internet protocol (IP) address used to connect your computer to the Internet, your browser type and version, time zone setting, operating system and platform, browser plug-in types and version, the full URL clickstream to, through and from the Website, page response times, download errors, length of visits to certain pages, page interaction (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page.
We also anonymise and aggregate personal data (so that it does not personally identify you). This is not personally identifiable, so we are allowed to use this for any purpose (such as testing our systems and carrying out customer research and analysis).
If you fail to provide us with Personal Information
You do not have to give us your personal information but this may affect how we provide our services and you may not be able to use certain functions and may not receive the optimal user experience.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you .In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
How we use your information
We will use your personal information for a number of purposes including:
  • to provide our products and services to our clients;
  • to develop and improve our products and services;
  • internal record keeping;
  • to carry out any obligations owed to you through the use of our Website and in respect of any contracts entered into between you and us;
  • to give you information that you request from us and to improve our services;
  • to notify you about changes to our services;
  • to allow us to operate the Website efficiently;
  • to ensure that the content from our Website is presented in the most effective manner for you and your computer;
  • any relevant troubleshooting, testing or statistical analysis as appropriate; and
  • to keep the Website secure.
Where we have your permission to do so, we may also use the information collected to:
  • provide you with information about our services that we offer via promotional communications; and
  • keep you up to date with features on the Website.
However, you can opt-out of these communications at any time by emailing [email protected].
How long we will retain your Personal Information for
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Legal basis of processing
We always ensure that a Lawful basis exists for all of the Personal Information we process at Gemba.  We rely on the following bases for our processing activities:
  • Contract: To fulfill our contract with you.
  • Legitimate Interests: These include:
    • The development and improvement of our products and services
    • The effective administration of our business, website, and services
    • To keep our website updated and relevant, to develop our organisation and to inform our marketing strategy
    • to ensure our customers are satisfied with our products and services
  • Consent: Where you have provided us with your consent.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at [email protected].
Protecting your information
We take our security obligations very seriously and constantly monitor for breaches and potential weaknesses.
We are committed to ensuring that your information is secure and we have procedures in place to try and prevent any unauthorised access or disclosures and to safeguard and keep secure the information that we collect online.
All the Personal Data collected by us and stored electronically is held on a secure server in the Australia only. Where required, this information is encrypted for additional security. We use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorise access to Personal Data only for those employees who require it to fulfil their job responsibilities.
However, you should be aware that providing information over the internet can never be guaranteed as being completely safe and if you choose to send such information to us via the internet, you do so at your own risk.
Transfer of data outside of Australia
We may transfer your information outside of Australia to our group companies or service providers. We shall not transfer any personal data to any country outside of the Australia unless we ensure that such personal data is subject to an adequate level of protection and appropriate legal safeguards in accordance with Data Protection Legislation. You can contact us if you wish to receive more information about these transfers and safeguards.
Sharing your information with others
Sometimes we may share your information with third parties in the following ways:
  • we may use carefully selected sub-processors to help us collect, store or manage your information. This will always be managed under the terms of a written data processing agreement;
  • analytics and search engine providers that assist us in the improvement and optimisation of the Website;
  •  our group companies;
  • if we are required to do so by law or pursuant to a binding regulatory request;
  • to exercise or enforce our legal rights; and
  • if Gemba is acquired by a third party.
Your Rights
You have rights in relation to any Personal Data that we hold about you. These are rights to:
  • ask us for a copy of the personal data we hold about you;
  • correct or update your personal data;
  • request that we delete your personal data;
  • object to the handling of your personal data where we are relying on a legitimate interest;
  • restrict the processing of your personal data; and
  • request the transfer of your personal data (or some of it) to a third party service provider.
These rights do not always apply and we will let you know or reasoning if we are unable to comply with a request.
If you wish to access your Personal Data you may make a request by contacting Gemba.
The information you request must relate to you or another person that you have authority to act on their behalf. Gemba will require a confirmation of your ID prior to providing any information about the data we hold. If you are unable to provide sufficient information to prove your ID, Gemba reserves the right to refuse your request.
If you have provided us with consent to process your information, you always reserve the right to withdraw this consent via the method detailed in the paragraph below. We are committed to ensuring that your wishes are respected and upon notification that you wish to withdraw your consent, Gemba will immediately cease processing the information in question.
Please send your request to Gemba by emailing [email protected]. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Changes to this Privacy Notice
We may change this Privacy Notice at any time to ensure it always accurately reflects the way we collect, use and safeguard your Personal Information.
Please check this notice from time to time to ensure you are aware of any updates we may have made to our Personal Data handling practices. The date of the changes will be listed in the ‘Last updated’ section below. We will endeavour to notify all of our current clients of any updates to this notice via email and we will post the relevant announcement on our website homepage.
We recommend that you print a copy of this page for your reference.
This Website uses cookies to help us recognise different users of the Website and to provide users of the Website with a good experience when using it. Please see our Cookies Policy for further information.
How can you make a complaint?
Please note that if you are not satisfied with the processing of your personal data as set out in this Privacy Notice, please contact us at [email protected].
You have the right to issue a complaint directly with the Office of the Australian Information Commissioner (OAIC).
Contacting us
Please contact us at [email protected] if you have any questions, comments or requests regarding this Privacy Notice.