1. Protecting your privacy
The Trustee for Just Add Wines Trust t/as Co Partnership (ABN 16 987 809 526) and its Related Entities (We, Us) are committed to protecting your privacy. This document provides you with information on how we collect, use, store and disclose your personal information.
We will adhere to the provisions of the Australian Privacy Principles (APPs) which are contained within the Privacy Act, in relation to how we collect, use, disclose and protect your Personal Information.
Where applicable, we also adhere to the requirements of the EU General Data Protection Regulation (GDPR).
This policy aims to provide you with information to understand how We collect, use, store and disclose your Personal Information in accordance with the APPs and the GDPR. This policy applies where we are a ‘data controller’ in relation to your Personal Information. That is, where we are in control of the purposes and methods of processing your Personal Information.
Our legal basis for the collection, storage, use and disclosure of your Personal Information arises from your consent to this policy, the protection of our legitimate interests, including the delivery and improvement of our Services.
In this policy:
The meaning of any general language is not restricted by any accompanying example and the words ‘includes’, ‘including’, ‘such as’, ‘for example’ or similar words are not words of limitation.
3. What Personal Information do we collect and why do we need it?
To provide you with our Services or if you apply for a job with us, including by using the links on our Website, we need to collect Personal Information. If we do not collect the Personal Information or if any of the Personal Information you provide is incomplete or inaccurate, we may not be able to provide the Services.
Depending on the nature of the Services we provide to you, the personal information we collect may include:
4. How do we collect the Personal Information?
We aim to collect Personal Information directly from you. We may also collect Personal Information:
If at any time you supply Personal Information to us about any person other than yourself, you represent and we accept that information on the basis that you are authorised to do so and that the relevant person has consented to the disclosure to us.
This privacy statement only covers the collection of Personal Information by our sites only and does not cover the collection of Personal Information from other third parties you access via a hyperlink or otherwise on our sites, whether or not affiliated with us.
5. How do we use your Personal Information?
We use the Personal Information we collect for operational purposes and to:
Any communication with us (regardless of mode) is recorded and stored to assist with the operational purposes set-out above.
If at any time you no longer wish to receive any additional marketing material from us or do not want your information disclosed for direct marketing purposes, contact us using the details in section 11 and we will remove your details from our marketing database.
6. Disclosing personal information
We may be required to disclose your Personal Information by law, by court order or to investigate suspected fraud or other unlawful activity.
We may also disclose your Personal Information to third parties in certain circumstances including:
When we disclose your Personal Information to our third-party service providers, we will attempt to ensure that those service providers have reasonable data security policies and practices in place.
7. Jurisdiction and Cross-Border Transfers
Due to the nature of the Services provided, your Personal Information may be stored and processed in any country where we have operations or where we engage service providers, and we may transfer your Personal Information to countries outside of your country of residence.
These countries may have different privacy and data protection rules to those of Australia and/or your country. However, we will endeavour to ensure that any such transfers comply with applicable laws and that your Personal Information remains protected.
In some circumstances, courts, law enforcement agencies, regulatory agencies or other official authorities in those countries may be entitled to access your Personal Information.
8. Considerations when you send information to us
While we do all we reasonably can to protect your Personal Information from misuse, loss, unauthorised access, modification or disclosure, including investing in security software, no data transfer over the Internet is 100% secure.
The open nature of the Internet is such that information exchanged via the Internet may be accessed and used by people other than those for whom the data is intended. If you send us any information, including (without limitation) Personal Information, it is sent at your own risk.
If you provide Personal Information to us electronically, there are steps you can take to help maintain the information’s privacy. These include:
You are responsible for all actions taken using your username, email or password. If at any time you believe your username or password has been compromised, you should immediately contact us and also change your password.
You should also contact us immediately if you believe:
9. How your information is stored
We endeavour to keep our information systems and files secured from unauthorised access. Those who work with us, including our third-party service providers are aware of the importance we place on protecting your privacy and their role in helping us to do so.
Our procedures to securely store Personal Information include electronic and physical security measures, staff training and use of password protection software.
When the Personal Information that we collect is no longer required, we will remove or de-identify the Personal Information as soon as reasonably possible. We may, however, retain Personal Information for as long as is necessary to comply with any applicable law, for the prevention of fraud, for insurance and governance purposes, in our IT back-up, for the collection of any monies owed and to resolve disputes. There may also be residual Personal Information that will remain within our databases and other records, which will not be removed.
10. How you can update, correct, or delete your Personal Information
You may request access to your Personal Information or correct any inaccurate or out of date information by contacting our Privacy Officer using the details below. For security purposes, before we provide you with personal information, we will ask you to provide evidence of your identity.
You may request the source of any information we collect from a third party. We will provide this at no cost, unless under the Privacy Act or other law there is a reason for this information being withheld.
If there is a reason under the Privacy Act or other law for us not to provide you with information, we will give you a written notice of refusal setting out the reasons for the refusal except to the extent it would be unreasonable to do so and the mechanisms available to you to complain about the refusal.
Level 2, 113 Reservoir Street, Surry Hills NSW 2010
More information about your rights and our obligations in respect to privacy and information on making a privacy complaint are available from the Office of the Australian Information Commissioner by:
GPO Box 5218 Sydney NSW 2001