Privacy Policy

Our Privacy Policy

 1) Respecting your privacy


            1) WL is committed to compliance with privacy laws which apply to its businesses and which set out standards for the management of personal information.
            2) This policy outlines Our personal information management practices. Specifically:

                  a. the kinds of personal information We collect and hold;
                  b. how We collect and hold it;
                  c. the purposes for which We collect, hold, use and disclose it;
                  d. Your right to access and seek correction of it;
                  e. how You may complain about privacy matters; and
                  f. our sharing of Your personal information overseas.

            3) There are some matters to which this policy does not apply. These are referred to, (see clause 9 below).

   2) What kinds of personal information do we collect and hold?

            1) The personal information We collect and hold is what is reasonably necessary for Our business functions and activities.
            2) When We collect and hold personal information, it is of the following kinds: 

                   a. Your personal details such as Your name, addresses, telephone numbers, age and gender;
                   b. Your customer reference;
                   c. whether You have taken up some of Our other offerings, such as membership of Our clubs and loyalty programs and Our mobile applications;
                   d. any rewards and redemption details applicable to Your membership of Our loyalty/affiliate programs;
                   e. whether You have a connection with others whose personal information We may collect or hold, for example family members who may be linked to Your loyalty/affiliate program membership;
                   f. what, how and when You buy from Us or have expressed an interest in buying from Us; and
                   g. Your stated or likely preferences, for example whether You may be interested in particular products or promotions.

            3) Depending on the nature of Your dealings with Us, We may collect and hold other types of personal information. For example, information collected and held via Our secure financial systems about the debit or credit card You might use for Your purchases from Us.
            4) You generally have the option of not identifying Yourself or of using a pseudonym when dealing with Us. But not where this is impractical (for example when You shop online with Us) or where the law or a court order provides otherwise.


  3)  How do we collect and hold personal information?

            1) When We collect personal information about You, We do so by making a record of it. We do this when:
                   a. You register with Us, for example to create an account, to become a Member of one of Our clubs or affiliation programs or to send You information;
                   b. You communicate with Us online;
                   c. You take part in Our promotions, competitions, testimonials, surveys and focus groups; and
                   d. You deal with Us in other ways involving a need for personal information to be provided such as when You contact customer service or bring a claim against Us.

            2) We may also collect personal information about You by accessing data from other sources and then analysing that data together with the information We already hold about You in order to learn more about Your likely preferences and interests.
            3) When You visit the Website, social media pages or click on Our advertisements on the online media of other companies, Our server may also log details about any computer used to access the Website (such as the IP address, operating system and browser type), the date                      and time of access and details of any information downloaded. We may collect information about You using technology which is not apparent to You, for example "cookies". For information about Our use of this technology, see Our Cookie Statement below.

  4) Most of the personal information We collect and hold about You is from Your direct dealings with Us. We may sometimes collect Your personal information other than from You directly. For example from other suppliers who, in common with Us, have a relationship with You.
  5) Holding of personal information:
        a. personal information We hold is generally stored in computer systems. These may be operated by Us or by Our service providers. In all cases, We have rigorous information security requirements aimed at eliminating risks of unauthorised access to, and loss,                                      misuse or wrongful alteration of, personal information; or
        b. We may store and disclose personal information allowed or required by applicable law or when We deem it is advisable. This means that We may make disclosures that are necessary or advisable to conform to legal and regulatory requirements or processes and to                        protect Our rights, safety and property, users of the Website and the public.

  4) Why do we collect, hold, use and disclose personal information?

  1. When We collect, hold and use Your personal information, We do so primarily to sell and promote Our Goods and Services to You and to improve on the range of Our offerings.
  2. We disclose personal information We collect for purposes which are incidental to the sale and promotion of Our Goods and Services to You. For example, We may disclose Your personal information to service providers who assist Us in our day-to-day business operations, such as the delivery of the Goods to You.
  3. We may collect, hold, use and disclose Your personal information for other purposes which are within reasonable expectations or where permitted by law.
  4. When marketing to You, Your personal information is only ever used or disclosed for Our own purposes. You may opt out of Our direct marketing to You. Our direct marketing materials will tell You how to do this.
  5. We may de-identify Your personal information. We may do this for use and disclosure of the anonymous data to determine preferences and shopping patterns.

 

  5) How can you enquire about, access and correct your personal information?

  1. We comply with the Australian Privacy Principles under the Privacy Act 1988 (Cth). Under the Privacy Act 1988 (Cth) You have a right to request access to Your personal information held by Us and request that it be altered or removed from Our records. You may do this by sending Us an email at privacy@wlwholesalers.com.au or by writing to Wine Lovers Wholesalers, 515 Nepean Highway, Brighton, Victoria 3186.
  2. Before We provide You with access to Your personal information We may require some proof of identity. We may charge a reasonable fee for giving access to Your personal information if Your request requires substantial effort on Our part.
  3. If You need to correct Your personal information, please contact Our Privacy Officer at one of the above contact points and Clause 16.5.1.


  6)   How can you complain about our management of personal information?

  1. If You wish to complain about a breach of the privacy rules that bind Us, You may contact Our Privacy Officer at one of the above contact points at Clause 16.5.1. We may ask You to put Your complaint in writing and to provide details about it.
  2. We may discuss Your complaint with Our personnel and Our service providers and others as appropriate.
  3. Our Privacy Officer will investigate the matter and attempt to resolve it in a timely way. Our Privacy Officer will inform You in writing about the outcome of the investigation. If Our Privacy Officer does not resolve Your complaint to Your satisfaction and no other complaint resolution procedures are agreed or required by law, Our Privacy Officer will inform You that Your complaint may be referred to the Privacy Commissioner for further investigation and will provide You with the Commissioner's contact details.

  7) Our sharing of your personal information overseas

  1. It is Our policy to require all of Our overseas sharing of personal information to be done in a way that requires observance of strict privacy and security standards, both during transit and at the overseas destination.
  2. We may allow Your personal information to be shared with those who are in countries other than Your own location. We do this:
  1. where We have made a business decision to store Our data with a trusted service provider who is in the business of providing data storage and processing services. These services commonly involve diverse geographic locations that change from time to time for reasons that include data protection and processing efficiency. Where these services are used by Us, it is not practical for Us to notify You of which country Your personal information may be located in; and
  2. where You are involved with public liability issues concerning a product We may disclose Your personal information to any overseas supplier of such a product in the course of managing those issues.

 8) Updates

This privacy policy is current at the date below. We may change it periodically.

 9) Other privacy terms and limits of this policy

This is a policy. There may be additional privacy notices and terms relevant to You depending on the nature of Your dealings with WL Wholesalers. There are additional privacy terms in Our loyalty program, club membership contracts, affiliation programs and for use of the Website.

 10) More information

More information about privacy law and privacy principles is available from the Privacy Commissioner. The Privacy Commissioner may be contacted at www.oaic.gov.au (email - enquiries@oaic.gov.au) (Australia).