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About this policy
SA Distilling Co Pty Ltd (“Heaps Good Spirits”) and its related bodies corporate (“Company” or “we”) want you to be familiar with how we collect, use and disclose information from and about you.
Under the Privacy Act, ‘personal information’ is generally any information or opinions that identify you personally.
- the kinds of personal information we collect and hold;
- how we collect and hold your personal information;
- our reasons for collecting, holding, using and disclosing personal information;
- how you may access your personal information held by us and have it corrected;
- how you may complain about the way we deal with your personal information, and how we will deal with your complaint; and
- whether we will disclose your personal information to overseas recipients, and if so the likely location(s) of those recipients.
What is personal information?
When used in this policy, the term “personal information” has the meaning given to it in the Act.
In general terms, it is any information that can be used to personally identify you. This may include (but is not limited to) your name, age, gender, postcode and contact details (including phone numbers and email addresses) and possibly financial information, including your credit card, direct debit or PayPal account information.
If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.
Kinds of information we collect and hold
We collect the personal information needed to provide Company Services and for our business operations. If you choose not to provide certain personal information to us, we may not be able to provide you with the services you require.
We may also collect your information through other legitimate third party sources including list brokers, social media organisations, and other data providers or organisations that share data in circumstances where it is lawful and/or you have given permission for them to do so.
We may collect personal information including:
- Your full name, contact details (such as your email address, phone number, and contact preferences), location, and passwords you create for the Heaps Good Spirits website;
- Information about your preferences, interests, opinions, feedback and experiences with our products or services. This information is collected in order to tailor our communications to you and continuously improve our products and services;
- Financial details, if you have provided them to us, such as your bank account, credit card, Paypal or other online payment system details (where you purchase any products or services from us);
- When you visit the Heaps Good Spirits website, we may also collect personal information about you in the following general categories:
- device information: we may collect information about your mobile device such as the hardware model, operating system, preferred language, unique device identifier and mobile network; and
- Other information: we may also collect and log information such as your IP address, access dates and times, browser type and pages visited when you interact with a website.
- Any other personal information requested or required by a Collection Channel.
Lawful collection of data
Heaps Good Spirits also reserves the right to use, disclose or otherwise process any personal information to satisfy any law, regulation or legal request, or in relation to Heaps Good Spirits’s other legitimate interests such as where that personal information is relevant to legal action relating to Heaps Good Spirits).
When and how we collect personal information
We (or our subcontractors) collect and combine personal information in a number of ways through the following channels (each, a Collection Channel):
- Our websites, including but not limited to www.heapsgoodgin.com.au and www.heapsgoodspirits.com.au;
- Any related Heaps Good Spirits website, social media page, internal website, intranet and any Heaps Good Spirits mobile or tablet applications;
our service providers acting on behalf of us (Eventbrite is an example), or other legitimate third party sources;
- Physical and other ad-hoc channels of collecting personal information in relation to events (such as through paper forms, use of QR code scans at events or tablets); and
- Any other means through which an individual provides personal information to Heaps Good Spirits, including either physically or electronically.
Active Information Collection
Personal information may be collected and combined via our Collection Channels if you:
- Purchase products either as a “guest” or a “member” through a Collection Channel, or create an account with Heaps Good Spirits through a Collection Channel (for example if you buy from our Website);
- Subscribe to any newsletters, updates, alerts or news and media releases, or request product or event information or information about our products or services or other information services as well as third party products or services;
- Complete and submit any forms or surveys provided to Heaps Good Spirits, either physically or electronically;
- Conspicuously publish or provide on request your personal information to Heaps Good Spirits;
- Contact us or our clients directly in person or via any medium including mail, telephone, social media and commercial electronic messages (SMS (Short Message Service), MMS (Multimedia Message Service), IM (Instant Messaging) and email) including via the contact details listed on a Website;
- Participate in any events, offers, promotions, competitions or marketing activities;
- Interact with a Website for a specific purpose; or
- Interact with or browse a Website generally.
Passive Information Collection
You can set your browser to notify you before you receive a cookie, giving you the chance to decide whether to accept it. You can also set your browser to turn off cookies. If you do so, some pages in the site may not work properly.
Cookies are either persistent or session based. Persistent cookies are stored on your computer, contain an expiry date, and may be used to track your browsing behaviour upon return to the issuing site. Session cookies are short-lived, are used only during a browsing session, and expire when you quit your browser.
Our sites use both kinds of cookies to provide a rich and session-based experience. The cookies are used to enable us to track anonymised users’ browsing patterns in order to provide statistical information to improve the usability of the sites.
To learn more about cookies and how to manage them, visit allaboutcookies.org
Our websites use Google Analytics for website analytics. We use website analytics data to help us make the website better by understanding how our website is used.
Google Analytics do not identify individual users or associate your IP address with any other data held by Google.
Google Analytics transmits website traffic data to servers offshore.
You can opt out of Google Analytics cookies by installing an add-on for your web browser.
We do not actively seek to collect sensitive information.
Consequences of not providing personal information
No-one is obliged to provide personal information. However, failure to do so may result in Heaps Good Spirits being unable to provide you with our goods, services, information, upcoming opportunities, promotions, events or product information, and other content, including where requested by you.
How we hold personal information
Heaps Good Spirits takes measures to ensure your personal information is protected from unauthorised access, loss, misuse, disclosure or alteration. We also take measures to destroy or permanently de-identify personal information when it is no longer required. The types of measures we take vary with the type of information, and how it is collected and stored.
We may use third party providers to store personal information electronically. We take reasonable steps to ensure this information is held as securely as information stored on our own equipment.
Unfortunately we cannot remove all risks involved in sending information through any channel over the Internet. You send information over the Internet entirely at your own risk.
Our employees and subcontractors are obliged to respect the confidentiality of any personal information obtained.
Access to your personal information
You have a number of rights under the Australian Privacy Law. These include, but not limited to the ability to:
- Access your personal information from us, in a commonly used electronic format.
- Contact us to correct your personal information;
- Withdraw your consent for us to use your personal information.
- For the purpose of transparency – for example to be informer about how your personal information has been collected and used.
- To make a complaint.
- To ask for your personal information to be deleted.
Deletion of information may result in Heaps Good Spirits and its service providers or partners being unable to facilitate or provide you with information about certain transactions (including the uploading, access to, and receipt of content on a Website), other product content, or services information, upcoming promotions, competition or event information, and/or provide certain content, goods or services. Unless required by applicable law, we are not responsible for removing your personal information from the lists of any third party who has previously been provided your information in accordance with this policy.
Unsubscribing from electronic communication
Heaps Good Spirits may determine that it is not legally required to give an individual access to personal information, in which case Heaps Good Spirits will provide you with a written notice of its refusal to provide access;
How we use and disclose personal information
We may disclose personal information to external service providers that assist us to:
- Provide, manage and administer our products, services and business systems (including mailing houses, printers, postal services, call centres, IT technicians, advertising agencies, and providers of client relationship management (CRM) services);
- Develop and market our products and services (including market research analysts, product development consultants and providers of affiliate management services);
- Comply with Payment Card Industry Standards, and securely manage processing of your credit card payments and storage of your credit card details.
To allow social sharing functionality
If you log in with or connect a social media service account with Company Services, we may share your user name, picture, tweets and likes, as well as your activities and comments with other Company Services users and with your friends associated with
your social media service.
We may disclose personal information to our related bodies corporate, so they can:
- Comply with the laws, regulations and licence conditions applying to them; and
- Send you marketing information directly.
We also collect, hold, use and disclose your personal information for marketing purposes, in particular, to:
- Target our communications, competitions and prizes;
- Let you know about upcoming events, promotions and new products and services or other opportunities via direct mail, email, SMS, or MMS;
send you product and service information on behalf of third parties; and
- Enable our related bodies corporate to send you product and service information directly.
- To deliver relevant advertisements and content
- We may use the information we collect from and about you to deliver relevant ads and content to you.
To share with business partners
Where you have expressly consented to this, Company may share your information with business partners to permit them to send you marketing communications consistent with your choices.
To complete a merger or sale of assets
Privacy Officer Details and Requesting Information
You have a right to ask for access to the personal information we hold about you. Please contact the Privacy Officer at:
Postal Address: Privacy Officer, Heaps Good Spirits, PO BOX 1032 Pasadena, SA, 5042
Your personal information will usually be available within 30 days of your request. If there is a fee for accessing your personal information, we will confirm the amount before providing the information.
In some circumstances we may not be able to grant you access to your personal information (for example, if the release of your personal information would have an unreasonable impact on the privacy of others).
It is not always possible to remove or modify information in our databases, but we will take reasonable steps to correct your personal information so it is accurate, up-to-date, complete, relevant and not misleading.
If we decline to make a correction, you may request us to attach to your personal information a statement that it is inaccurate, out-of-date, incomplete, irrelevant or misleading.
If we disclosed the information to a third party before correcting it, you may request us to notify the third party of the correction we’ve made.
We will not charge you to request a correction, or for making a correction or attaching a statement.
If you have a concern about how we have handled your personal information, please let us know so we can fix the problem.
You can contact us at:
Postal Address: Privacy Officer, Heaps Good Spirits, PO BOX 1032 Pasadena, SA, 5042
To lodge a formal complaint, please send details to the Privacy Officer in writing. We will respond within a reasonable time – usually 30 days.
If your complaint is not resolved by the Privacy Officer and concerns credit-related personal information, you may be able take it to an external dispute resolution scheme. The Privacy Officer will give you details of the relevant scheme.
If your complaint is not resolved by our Privacy Officer or an external dispute resolution scheme, you can refer it to the Office of the Australian Information Commissioner.
The contact details are:
Office of the Australian Information Commissioner GPO Box 2999 Canberra ACT 2601, Australia Phone: 1300 363 992 Fax: 02 9284 9666 www.oaic.gov.au
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