PRIVACY POLICY
Fourth Wave Wine Partners Pty Ltd
ABN 32 243 483 797
Date: xx November 2024
1. Overview
This is the privacy policy of Mullet Wines owned and operated by Fourth Wave Wine Partners Pty Limited (“Fourth Wave Wine”, “we”, “us”, “our” and similar grammatical forms as the context may require).
Our privacy policy details the sort of information Fourth Wave Wine may collect about you, how Fourth Wave Wine manages, uses and discloses your personal information, sets out some of your privacy rights in relation to personal information and advises how you can contact us with privacy queries.
By accessing, browsing or using any website owned and/or operated by Fourth Wave Wine (each a ‘Website’) or otherwise registering for an account with us and providing your information to us, you acknowledge that you have read, understood and accept to be bound by the terms of this privacy policy, and you are consenting to our collection, use, disclosure, retention and protection of your personal information as described in this privacy policy. Since this privacy policy is subject to change without prior notice, you should check back on this privacy policy regularly.
We appreciate that your privacy is important to you, Fourth Wave Wine will continue to protect the personal information you provide us and we will manage your personal information in compliance with the Privacy Act 1988 (Cth) (‘Privacy Act’) and the Australian Privacy Principles (‘APPs’). Fourth Wave Wine will only use your personal information in a manner consistent with this policy.
We will take all reasonable steps to ensure that all information we collect, use or disclose is accurate, complete, up-to-date and stored in a secure environment.
2. What information do we collect?
The type of information we collect from you will depend on what services on our Website that you use. The personal information we may collect includes:
· Name;
· Contact details (e.g. email address, telephone number(s), residential and delivery addresses);
· Information to identify you (e.g. date of birth);
· Household details (e.g. number of people living at household and theirages);
· Payment and transaction details/history (including information about payment cards linked to flybuys and associated transactions);
· Records of your communications and interactions with us;
· Details/history of purchases, preferences, interests and behaviour relating to transactions, products, services and activity with our digital services; and
· any other personal information requested by us and/or provided by you or a third party.
Please note we do not collect payment details from you, as payments via our Website are facilitated and processed by a third party service provider on our behalf. Please refer to the section below titled ‘ThirdParty Links’ regarding collection of information by third parties.
General information about visits to our Websites is collected by our computer servers, with small files “cookies” that our Websites transfers to your computer’s hard drive through your Web browser (if you allow the delivery of “cookies”). The “cookies” are used to follow the pattern of movements of users by letting us know which pages on our Websites are visited, in what order and how often and the previous website visited and also to process the items you select if you are making purchases from our online store. The anonymous non-personal information that we collect and analyse is not personal information as described in the Privacy Act.
We may not be able to provide our products or services or make offers to you without your personal information.
3. When do we collect information?
We do not automatically collect personal information from you, such as your name, address, phone number, email address or other personally identifiable information about you.
We collect three categories of information when you use our Website:
· the personal information you voluntarily provide — that is, we collect personal information with your informed consent;
· anonymous non-personal information about how you use our Website; and
· “cookie” based information that makes your use of our Website easier by recording your preferences so that when you return to our Website the “cookie” re-loads that information into your web browser.
For example, we will collect personal information from you when you subscribe to our Website(s), place an order, respond to a promotional offer, competition or survey or fill out a form related to any customer service feature operating on our Websites.
We may monitor and record your communications with us (including email and telephone) for security, dispute resolution, and training purposes.
We will endeavour to collect personal information from you directly, unless if it is impracticable to do so, in which case we may also collect personal information from third parties including from:
· third parties (via agencies on our behalf or our internet service provider);
· Public sources;
· Anyone authorised to act on your behalf; and
· Information service providers (including for data integrity purposes).
4. Why do we collect information?
The personal information collected on our Websites will be used to provide the services you have requested, such as setting up and managing your account with Mullet Wine and/or Fourth Wave Wine or processing any purchases you may make on our Website. Some of the reasons for collecting your personal information include:
· To manage your requests for products and services, including delivery, processing payments, providing refunds and discounts;
· To register and service your account, including keeping your information up-to-date, and verifying your identity;
· To communicate with you about our products, services, and promotions;
· To help us improve our products and services, including conducting product and market research;
· To improve our operational processes to enhance your customer experience;
· To respond to your feedback, queries, or concerns;
· Working with our service providers;
· Investigative, fraud, and loss prevention activities;
· Interacting with Regulators and relevant government entities;
· To meet our responsible service of alcohol commitments;
· Manage our relationships with any of our related companies and brands including the Coles group;
· To comply with legal requirements and obligations, including those which may relate to our licenses, such as reporting to regulators and enforcement bodies; and
· In case we are involved in a takeover or merger, or propose to sell any part of our business, we may need to share your personal information as part of the restructure, takeover or merger.
Using personal information, we endeavour to improve our understanding of your interests, suitability, and behaviour in relation to products, services, and offers, including conducting risk assessments for financial products (including credit and insurance).
We may also handle your personal information to protect our lawful interests and facilitate purchases and potential purchases of our businesses.
5. How do we store your information?
The security of your information is important to us. When we have collected information about you it cannot be seen or modified by anyone other than those authorised to access the information for the purposes stated above. We use different technologies and procedures to help protect personal information from unauthorized access, loss, alternation, disclosure or use. Some of the safeguards we use are physical access controls, information firewalls and access authorisation controls to where your personal information is held in data centres. We also use data encryption when personal information is transferred to and from our service providers. Our commitment to data security means:
· we have procedures to limit access to personal information within our organisation;
· we use security measures and technologies within our organisation to protect your personal information; and
· we use service providers that can establish that they have secure controls relating to software security, access security and network security, including where credit card information is being transferred.
6. What use do we make of your personal information?
We may occasionally send you information and updates about any other product, service or information that we provide to our customers; in addition, we may send you occasional company news and information about other products and services or special promotional offers of our affiliated companies. If at any time you would like to stop receiving future commercial messages from us, we include detailed unsubscribe instructions at the bottom of each email.
We may only release your personal information when we believe release is appropriate to comply with the law, enforce our subscription agreements, website policies and terms & conditions, or protect ours or others’ rights, property, or safety.
We may disclose your personal information to third parties:
· where we have sought your consent or as is otherwise allowed or required by law;
· to our related companies, contractors, suppliers or service providers for the purposes of providing products and services on our behalf and performing our administration and other operations, including accounting and finance checks, IT, marketing, record keeping and statistical purposes, market research, safety purposes, fulfilment services and/or Site traffic analysis;
· to any entity to which we propose to assign any part of our business; or
· or to other organisations with whom we have contractual agreements.
We will only use sensitive information we hold about you for the primary purpose for which it was collected or for a purpose directly related to the primary purpose, and where you would reasonably expect us to use or disclose it for that purpose.
Any information that we no longer use for the purposes contained in this policy is destroyed. The exception to this may be information required for possible data analysis at a future date, or information we are legally required or advised to hold for specific time periods. Wherever practicable subject to the above, the information will be retained in a form that does not allow you to be identified.
7. How can I access the personal information that you collect?
We are happy to provide you with details of personal information held about you except where law allows us to refuse your request. If you wish to access or correct any personal information we hold about you, please contact us. When making an access request, please provide as much detail as you can about the particular information you seek, in order to help us retrieve it. We will take reasonable steps to amend or correct your personal information to keep it accurate and up to date. If you believe that any information we hold about you is incorrect or incomplete, please write or email us as soon as possible at [insert email address]. We will promptly correct any information found to be incorrect.
Under the Privacy Act and other relevant laws, we are required to provide a written response outlining our reasons if we refuse your request. Where we decide not to make a requested correction and you disagree, you may ask us to add a note of your requested correction to the information that explains your correction request.
In limited circumstances, and only where it is permitted under the Privacy Act, we may not be able to provide access to information: for example, where it would have an unreasonable impact upon the privacy of others or where we believe your request is frivolous or vexatious.
8. Privacy Concerns or Complaints
If you have any complaints or concerns about this policy, or if you believe that your personal information has been misused, you can inform us of your complaint by emailing us and we will attempt to resolve the matter. Our details are set out below.
Fourth Wave Wine Partners Pty Ltd
(Address): [insert]
Telephone: [insert]
Email: sales@fourthwavewine.com.au
If you are not satisfied with the outcome of your complaint, you may refer the matter to the Office of theAustralian Information Commissioner (OAIC). Contact details are set out below.
Office of the Australian Information Commissioner
GPO Box 5218 Sydney NSW 2001
Telephone: 1300 363 992.
Email: enquiries@oaic.gov.au
Website: www.oaic.gov.au
OAIC complaints page: http://www.oaic.gov.au/privacy/privacy-complaints
9. “Cookies” and other web use tracking technologies
When you access our Website, small files containing a unique identification (ID) number may be downloaded by your web browser and stored in the cache of your computer. The purpose of sending these files with a unique ID number is so that our Website can recognise your computer when you next visit our Website. The “cookies” that are shared with your computer can’t be used to discover any personal information such as your name, address or email address they merely identify your computer to our Websites when you visit us.
Our systems record a variety of information in relation to interactions with our online services. This can include information about software versions used, device identifiers (like IP address), location data (where available and not disabled by the user), dates, times, file metadata, referring website, data entered, and user activity such as links clicked. We can also log the internet protocol address (IP address) of visitors to our Website so that we can work out the countries in which the computers are located.
We collect information using “cookies” and other tracking technologies for the following reasons:
· to help us monitor the performance of our Website so that we can improve the operation of the Website and the services we offer;
· to provide personalised services to each user of our Website to make their navigation through our Website easier and more rewarding to the user;
· to sell advertising on the Website in order to meet some of the costs of operating the Website and improve the content on the Website; and
· when we have permission from the user, to market the services we provide by sending emails that are personalised to what we understand are the interests of the user.
Even if you have given us permission to send you emails, you can, at any time, decide not to receive further emails and will be able to “unsubscribe” from that service.
If you are unhappy about having a cookie sent to you, you can set your browser to refuse cookies or choose to have your computer warn you each time a cookie is being sent. However, if you turn your cookies off, some of our services may not function properly.
In some cases, third parties may use cookies and other technologies such as web beacons, Flash local stored objects, and JavaScript. These technologies may be used in connection with activities like surveys, online behavioural advertising, website analytics, and email campaign management. The service we may use from time to time include those offered by Google (including AdSense and DoubleClick), Yahoo, Adobe (including Campaign Manager and Analytics), and Microsoft. You can contact us to request further details of the services we use. Many of these services operate without collecting or using any personal information.
Some information we collect is not related to an individual. In many cases the information only relates to a device or is of an aggregated or statistical nature, and we will have no way of knowing the identity of the user. In other cases, we may associate information about your use of our Website over time with your personal information, e.g.where on any occasion you have logged in, followed a link sent to you by email or we have otherwise been able to identity you.
10. Third party links
Our Websites may include links to websites operated by third parties. However, once you have used these links to leave our Website, you should note that we do not have any control over that other website, and assume no responsibility or liability for the content and activities of these linked websites. Remember, this privacy policy is strictly limited to our collection, storage and use of personally identifiable information collected via the Websites or otherwise in the course of our business, and does not apply to any third parties. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such websites and such websites are not governed by this privacy policy. You should exercise caution and look at the privacy statement policy applicable to the website in question. Nonetheless, we seek to protect the integrity of our Websites and welcome any comment about linked websites.
11. Your consent
By accessing, browsing or using our Website, you consent to this privacy policy.
12. Changes to our privacy policy
We are constantly developing and enhancing our use of online technologies and make reasonable efforts to ensure we keep this privacy policy and related documents up to date in this regard. Please check back when you return to use our online services to ensure you are familiar with our current practices.
All changes are effective from the date we post the revised privacy policy. In particular, by continuing to use the Website(s) after the privacy policy has been varied or by otherwise providing your information to us, you agree to be bound by the variation.
This privacy policy was last modified on xx November 2024.
COLLECTION STATEMENT
NB: For Australian use, pursuant to APP 5 which requires that at or before the time or, if that is not practicable, as soon as practicable after, an APP entity collects personal information about an individual, the entity must take such steps (if any) as are reasonable in the circumstances to notify the individual of certain matters. There are many functional ways to achieve this, depending on the medium through which the collection takes place. For instance, online is different to hard copy paper collection.
If you include this collection statement, then you do not need to include an actual express ‘opt in’ check box that users agree to, but you must include this statement in a prominent place at the place of collection so that they are able to see this and in that way you can be confident that they have seen the information and thus been “notified”. If you are unsure, or would like to be very clear on this, you could include a check box also, at the time of collection.
Privacy Collection Statement
“By providing your personal information (PI), you agree to Fourth Wave Wine Partners Pty Limited collecting your PI pursuant to our Privacy Policy [HYPERLINK], which contains full details on how your PI is used/disclosed/stored, how you may contact us, access/correct PI held and our privacy complaints process. If you don’t provide your info you may not be able to access our products/services. Your PI may be transferred overseas, principally to our suppliers and commercial partners primarily located in INSERT COUNTRIES.”
