- using our website;
- accessing, requesting, enquiring about, or purchasing wine or other products and services from JDW (online, via our mailing list, by phone, or in person);
- entering our competitions or attending our tours;
- visiting our office, cellar door and other premises; or
- providing Personal Information to JDW, its officers, agents or employees, you acknowledge and consent to the use, collection, storage or disclosure of your Personal Information by us in accordance with this Policy and the Privacy Act.
If you do not agree to us handling your Personal Information in the manner set out in this Policy you must immediately cease to access this website or our products and services, and you should not provide us with any of your Personal Information.
1. What is Personal Information?
We follow the definition of Personal Information given in the Privacy Act:
Personal Information means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not.
2. What kinds of Personal Information might we collect and hold?
We may collect (and hold) different Personal Information from you depending upon how you interact with us.
If you access our website, we may collect information about how you have used our site.
If you access our Facebook or other social media pages, we may collect your name, postal/street address, e-mail address, phone number or contact details if you submit them to us.
If you contact us, we may collect your name, postal/street address, e-mail address, phone number or contact details.
We may also collect information about:
- your demographic;
- your interests;
- subscriptions to our mailing lists;
- your purchases of wine and other products and services related to our activities;
- your location;
- the technology you use to access our services; and
- how and when you use our services.
3. How do we collect Personal Information?
We collect Personal Information:
- directly from you (when we contact you, when you contact us, when you place orders and buy wine, when you sign up to a mailing list, when you complete a survey, or enter a competition);
- when you attend a promotional function; and
- from third parties who you have authorised to provide us with information.
4. How do we hold and secure your Personal Information?
We store your Personal Information in hard copy format and/or digitally on site and with a third party storage provider. All hard copy material is secured using an internal file storage system. All digital material located on site is secured using our own internal computer system. Any digital transfer of Personal Information is secured through encryption. Payment details provided through our website are processed through a secure server.
JDW uses data storage providers located in Australia and overseas. Where appropriate, JDW has agreements with its storage providers to keep all Personal Information they store secure, using reasonable and appropriate security methods.
5. Why do we collect, hold, use and disclose Personal Information?
JDW may collect Personal Information for a number of reasons, including:
- providing you with products or services;
- providing you with information about our products or services;
- keeping in touch with you through our mailing list and other communications;
- developing or refining products or services;
- internal business purposes, including processing orders and payments;
- providing you with marketing material;
- contacting you in relation to our business activities, promotions and other special events;
- better understanding our clients and customers;
- to administer our wine clubs;
- to provide and conduct our competitions and events;
- tailoring our marketing, services, promotions and operations;
- for corporate governance, auditing and record keeping; and
- to comply with our legal obligations. For example, we use information regarding a person’s age to ensure that we do not supply alcohol to minors.
Our use of Personal Information may extend beyond these uses, but will be restricted to purposes that we consider to be related to our functions and activities.
6. What do we do with your Personal Information?
If we collect Personal Information from you, we may:
- use that information for any of the purposes in clause 5 of this Policy;
- store that information in accordance with this Policy;
- pass that information amongst our related companies;
- pass that information to third parties who provide products or services to us (including our accountants, auditors, lawyers, IT contractors, designers, distributors and other service providers); or
- provide that information to third parties as required by law.
7. Do you use my information for Direct Marketing?
We may use your Personal Information to communicate directly with you to promote a product or service (Direct Marketing). These communications are sent in various forms, including mail, SMS and email. We use Direct Marketing to provide you with information about products or services that we believe you may be interested in. If you receive Direct Marketing material from us, and do not wish to continue receiving it, please contact us by any of the methods set out in paragraph 13 below, asking to be removed from all future Direct Marketing programs. Once we have received your opt-out request, we will remove you from our Direct Marketing programs as soon as reasonably practicable.
8. What about Cookies?
This Policy does not apply in relation to any other websites linked to, or from, our website. We are not responsible for the privacy practices or the content of those websites. You should contact the operators of those other websites directly for details of their information handling practices.
9. Do we ever send your Personal Information overseas?
Your Personal Information may be stored with, or accessed by, third parties who provide us with various goods and services (such as software, IT infrastructure, website hosting and maintenance services).
If those third parties are situated, and store content, offshore, your Personal Information may be transmitted, disclosed, stored or accessed in overseas jurisdictions.
If you proceed to submit your Personal Information to us, you are consenting to the transmission, storage and access of your Personal Information by third parties in overseas jurisdictions for those purposes. In that respect, Australian Privacy Principle 8 which ordinarily obliges us to take reasonable steps to ensure that overseas recipients of your Personal Information do not breach the Australian Privacy Principles (except Principle 1) will not apply.
Please note that if any of those overseas recipients handle your Personal Information in a manner which is inconsistent, or does not comply, with the Australian Privacy Principles:
- to the maximum extent permitted by law, we will not be accountable under the Privacy Act for any resulting loss or damage that you may suffer;
- to the maximum extent permitted by law, you will not be able to seek redress against us under the Privacy Act;
- the overseas recipient may not be subject to any privacy obligations at all, or to any principles similar to the Australian Privacy Principles;
- you may not be able to seek redress against the overseas recipient in their jurisdiction; and
- in holding your Personal Information, the overseas recipient may be subject to foreign laws which compel their disclosure of your Personal Information to other parties, such as overseas government authorities.
10. Can you access your Personal Information or request it be corrected?
- You may request access to the Personal Information that we hold about you by contacting us by any of the methods set out in paragraph 13 below (an Access Request).
- Upon receiving an Access Request we may request further details from you to verify your identity. We reserve the right not to provide you with access to Personal Information if we cannot verify your identity to our reasonable satisfaction.
- An administrative fee may be charged to cover our costs in providing you with access to your Personal Information. This fee will be explained to you before it has been incurred.
- We will respond to your Access Request within a reasonable period of time by:
- providing you with access to your Personal Information; or
- rejecting your Access Request, and providing you with reasons for this rejection.
- Access Requests may be denied where:
- we believe your request is frivolous or vexatious;
- we are entitled to reject it by law;
- we are unable to verify your identity; or
- you have not paid the administrative fees referred to in paragraph 10c, above.
- If you believe that the Personal Information that we hold is inaccurate or otherwise requires correction, you may send us a correction request by contacting us by any of the methods set out in paragraph 13 below. We will review your Personal Information and respond to the request within a reasonable period of time.
11. What happens if you want to deal with us anonymously or using a pseudonym?
You can deal with us either anonymously or by using a pseudonym if you choose. However, if you do so we may not be able to provide you with accurate or useful information, and you may not be able to access a full range of our products and services.
12. Does this Policy ever change?
From time to time we may make changes to this Policy. Changes come into effect from the time when they are brought to your attention, or when you next log on to our website, whichever is earlier. Please make sure you review the Policy each time you visit our website to keep up to date on any changes.
13. What happens if you have a question or complain about how we have handled your Personal Information?
If you have a question or complaint, you can raise it with us by:
Calling us on 08 85622 266
Sending a letter to P.O. Box 622 Tanunda SA 5352
We take all complaints seriously and will respond to you within a reasonable period of time, unless we consider your complaint to be frivolous or vexatious.
If you aren’t satisfied with the way we have handled your complaint, you can make a complaint to the Office of the Australian Information Commissioner at http://oaic.gov.au.