1. PRIVACY AT ACCOLADE WINES
1.1 Accolade Wines Australia Limited and Accolade Wines Limited, trading as Accolade Wines (each or together “Accolade Wines”, “we”, “us” or “our”) has a commitment to privacy in accordance with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles contained in the Privacy Act (Privacy Principles) and the Data Protection Act 1998 (Act). For the purpose of the Act, the data controller is Accolade Wines Limited (company number 137407) of Accolade House, The Guildway, Old Portsmouth Road, Artington, Guildford GU3 1LR, England.
1.2 The Privacy Principles define "personal information" as information or an opinion relating to an individual which can be used to identify that individual. Personal information includes personal data as defined by the Act.
1.3 This Policy sets out how Accolade Wines and its related bodies corporate (as defined in the Corporations Act) or ultimate holding companies or subsidiaries (as defined in section 1159 of the UK Companies Act 2006) collects, holds, uses and discloses your personal information. It also sets out how you may access and seek correction of your personal information or complain about a possible breach of privacy.
1.4 Accolade Wines views the privacy of personal information as an important issue.
1.5 We understand that when interacting with us the privacy and confidentiality of your personal information is important to you. That is why we are committed to safeguarding the personal information you provide us.
1.6 By accessing or using Accolade Wines’ services, including its websites, you agree to the use and disclosure of your personal information in the manner described in this Policy.
2.2 Accolade Wines may collect and hold (or already hold) personal information about you as a result of information that you have provided to Accolade Wines, our interactions with you and/or your business dealings with Accolade Wines, including without limitation:
a) contact information such as your name, phone number, postal address and email address;
b) employment details;
c) financial and tax related information such as tax file numbers, credit card or bank account numbers, credit history and land holdings;
d) other information which will assist Accolade Wines in conducting its business and to provide its products and services; and
e) other information provided at Accolade Wines’ request.
2.3 We may collect personal information in a number of ways, including:
a) directly from you, including through our website, by telephone, through written correspondence (such as letters and emails), and in person if you visit our cellar doors or wineries;
b) from credit reporting agencies and from the third parties;
c) from publicly available sources of information, such as address validation software and telephone directories; and
d) monitoring and recording calls that you make to us in certain circumstances (we will notify you beforehand).
2.4 When you access an Accolade Wines website, the type of information Accolade Wines may also collect includes information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers and authorised agents. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.
2.5 Accolade Wines, in common with many website providers, may use standard technology called cookies on its websites. Cookies are small data files that are downloaded onto your computer when you visit a particular website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
2.6 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive. This can allow websites to recognise devices throughout the duration of a user’s visit or browsing session. These cookies are known as session cookies.
2.7 In some cases cookies persist across multiple browsing sessions, enabling the website to remember user preferences from previous visits. These cookies are known as preference cookies. Both session cookies and preference cookies reduce the requirement for the user to continually identify themselves on their journey through a website. For example, cookies may be used on this website to remember that the user has verified their date of birth, or to remember the details and the choices from submitted forms.
2.8 Some third party cookies may be placed on devices used to browse this website. These will typically be social media cookies, used by websites such as Facebook, to aid with the integration between any social media elements that the user may interact with and their social media profiles. Analytic cookies may also be placed to log visit statistics and anonymously track the way users browse this website.
2.9 Some areas of this website may invite users to participate, by adding comments or by rating items. This functionality works by incorporating a content management system. These content management systems may require content management cookies to be placed on the browsing device.
2.11 Accolade Wines collects personal information for a range of purposes, including:
a) to provide products and services requested by you;
b) to manage those services, including to enable customer service, delivery and billing;
c) to conduct a credit assessment of you and use information we are permitted by law to use to establish or report on your creditworthiness;
d) to research, develop and improve Accolade Wines’ products and services;
e) to conduct surveys to determine use and satisfaction with Accolade Wines’ products and services;
f) to generate statistics in relation to Accolade Wines’ websites;
g) to directly promote and market products, news, offers, promotions and other services to you where we have your express or implied consent. If you do not wish to receive our news, offers and promotions, we will not contact you about these once you have advised us as such.
2.12 Except where your consent has been provided, your personal information will only be used or disclosed for the primary purpose for which it is collected. We may expressly communicate this purpose to you or it may be clear from the nature of our dealings with you.
2.13 Accolade Wines may also disclose or transfer your personal information where necessary to companies which are “related bodies corporate” of Accolade Wines (as defined in the Corporations Act) or ultimate holding companies or subsidiaries (as defined in section 1159 of the UK Companies Act 2006) and in some circumstances those companies will be international entities. Generally, we will ensure that an international entity is bound by privacy obligations equivalent to the Privacy Principles, Privacy Act and/or the Act, before we disclose or transfer your personal information to it.
2.14 Accolade Wines may also disclose or transfer your personal information to other companies or individuals who assist us in providing products or services or who perform functions on our behalf (such as marketing or advertising companies, mailing houses, consultants, credit reporting agencies and providers and service providers), where you have consented to be contacted for such purposes. In the case of our contracted service providers, we may disclose personal information to the contracted service provider and the contracted service provider may in turn provide us with personal information collected from you in the course of providing the relevant products or services. Your personal information may be transferred overseas for these purposes.
2.15 In certain circumstances we may be a credit provider to you. In these circumstances, we will handle your credit information in accordance with this Policy.
2.16 In the event that Accolade Wines sells or buys any business or assets, we may disclose your personal data to the prospective seller or buyer of such business or assets. If Accolade Wines or substantially all of its assets are acquired by a third party personal data held by it about its customers may be disclosed as one of the transferred assets.
2.18 You have the right to ask us not to process your personal information for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your personal information for such purposes or if we intend to disclose your personal information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at firstname.lastname@example.org.
2.19 If you choose not to provide personal information when requested, Accolade Wines may not be able to provide you with the full range of Accolade Wines services.
2.20 We do not sell, rent or trade our customers’ personal information to or with third parties.
3. SECURITY AND WHERE WE STORE YOUR PERSONAL INFORMATION
3.1 Accolade Wines is committed to keeping your personal information secure. All reasonable precautions will be taken to protect personal information from loss, misuse or alteration.
3.2 The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. By submitting your personal information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Policy.
3.3 We may hold your personal information in a combination of electronic and hard copy files.
3.4 In most circumstances, the information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
3.5 Unfortunately, the transmission of information via the internet is not completely secure and we do not guarantee or warrant that our websites are completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
4. ACCESSING AND CORRECTING PERSONAL INFORMATION
4.1 The Act and the Privacy Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act or Privacy Act, as applicable. Any access requests inside the EEA may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
4.2 If you wish to access or update your personal information held by Accolade Wines, or to complain about possible breaches of privacy, enquiries should be directed to:
BY EMAIL: email@example.com
Accolade Wines Australia Limited
Reynell Road, Reynella SA 5161, Australia
Facsimile: 08 8392 2122
Accolade Wines Limited
Accolade House, The Guildway, Old Portsmouth Road
Artington, Guildford, Surrey GU3 1LR United Kingdom
4.3 The Privacy Officer will endeavour to deal with all enquiries or complaints as soon as is reasonably practicable. Please provide as much detail as you can as this will help us to find the information requested. We will generally provide you with access to your personal information that we have about you, but sometimes that will not be possible, in which case we will give you a written notice explaining why.
4.4 A complaint regarding a breach or possible breach of privacy must first be submitted in writing to Accolade Wines. If we are unable to satisfactorily resolve your concerns about our handling of your personal information, you can contact a regulatory body including, in the case of information provided to Accolade Wines in Australia, the Office of the Australian Information Commissioner.
4.5 If you no longer wish to receive news, offers, promotions or other direct marketing communications from Accolade Wines, please contact us through one of the methods stated above to advise us of such. Our services and communications with you may also contain specific methods to opt out of direct marketing material sent via the particular service or communication.
5. ACCURACY AND COMPLETENESS OF PERSONAL INFORMATION
5.1 Accolade Wines will assume that any personal information provided by you is up to date and complete at the time it is provided, is free from errors and omissions, is not misleading or deceptive and complies with all relevant laws.
5.2 Accolade Wines relies on the personal information provided to it by individuals. Accolade Wines does not undertake to check or verify the accuracy of the personal information provided.
5.3 Persons who provide personal information to Accolade Wines should provide details of any changes to that personal information as soon as reasonably practicable following the change.
5.4 If you think that any personal information we hold about you is inaccurate, incomplete, out-of-date or irrelevant, you may ask us to correct it. We will take reasonable steps to correct it unless we disagree with your reasons. If we refuse to correct your personal information we will give you a written explanation why.
6. OTHER WEBSITES
6.1 Our site may, from time to time, contain links to and from the websites of our partners networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility for liability for these policies. Please check these policies before you submit any personal data to these websites.
7. VARIATION OF POLICY
7.1 Accolade Wines may vary the terms of this Policy from time to time. The amended Policy will apply between us whether or not we have given you specific notice of any change.