Privacy Statement
Who we are
The Cumulate 10–30–50 platform is operated by Cumulate Advisory Pty Ltd (ABN: 80 686 107 844), of Sherwin Kelly Suite 2, 127 McKinnon Road, McKinnon Vic. Please contact us via email hello@cumulate.au for further information about our privacy statement.
What we collect, and why
People who hold an account
When you request access we collect your email address and mobile number. The email address identifies your account and is where the link to set your password is sent. The mobile number is business contact detail for the conversation about your access — it is never used to sign you in, and there is no SMS path into this platform.
While you use the platform we record sign-in events, the reports you generate, and access denials, each with your account identifier and a timestamp. That record exists so it can be answered later who saw a given athlete’s information, which is a requirement of the security certifications this platform is built for and a protection for the people the reports describe.
Athletes
The platform holds identity information about listed players: name, date of birth, age, gender, height, debut year and career record. This is drawn from publicly published competition rosters — every record in the platform carries its source and the basis on which it was collected, and at present every one reads afl.com.au and publicly published competition roster. It is not collected from athletes directly.
Performance, biological, readiness and off-field figures in the platform are at present synthetic — generated from position-level distributions. They describe nobody. They are not measurements of any named player, and every report says so. Where real measured data is introduced it will be collected under agreement with the club and the athlete, and this statement will be updated before that happens.
We do not hold clinical or psychological information. That category is deliberately outside this platform.
Where information is held
All of it is stored in Google Cloud in the Australia region. Data residency is enforced by organisation policy, which means a service cannot be created in another region even by mistake. Google Cloud is our processor; the information is not sold, and it is not shared with anyone else except as described below.
Signing in
Authentication is handled by Google Identity Platform. We never see or store your password — you set it on a page hosted by Google, and it is never entered on this site. A second factor is mandatory and is an authenticator app: we hold no phone numbers for authentication, and there are no SMS codes and no recovery codes to be intercepted or lost.
While signed in, your browser holds a single session cookie. It cannot be read, is sent only to this site, and expires after eight hours. There are no advertising cookies, no analytics and no tracking of any kind on this platform.
Who can see what
Access is decided by an entitlement recorded against your account, and it is checked on the server on every request — never in your browser, and never saved. A club account reaches its own club and the athletes contracted to it, and no others. Competition-wide access exists for league and administration roles and is granted deliberately, one account at a time. Revoking access takes effect on the next request.
Other services your browser contacts
Two, both Google: Identity Platform, when you sign in or enrol an authenticator; and Google Fonts, which serves the typefaces this site uses. Loading a font discloses your IP address to Google. Nothing else is contacted, and no third party receives your information from us.
How long we keep it
Audit records are stored and kept as per Australian Privacy Standards and are held in immutable storage for that time. Registration records and entitlements persist while an account exists.
Reaching your information
You may ask what we hold about you. Athletes have specific and stronger rights on this platform, set out in our Data Rights statement.
If you are not satisfied with how we handle a privacy matter you may complain to the Office of the Australian Information Commissioner at oaic.gov.au.
Changes
This statement changes when the platform does — particularly when measured athlete data is introduced. We will update the privacy statement to reflect platform changes time to time and the latest statement is available on the site for your perusal.