Privacy and Cookies Policy
Accolade Wines and all of its global companies and brands (herein referred to as “Accolade Wines”, “we”, “us” or “our”) have a commitment to privacy in accordance with the privacy laws applicable in the countries in which we operate, and are committed to protecting and maintaining your privacy.
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 your personal information.
1.0 Purpose of this Policy
By providing personal information to us, you accept and consent to our collection, storage, use and disclosure of your personal information in accordance with this Policy.
Section 12 of this Policy provides details on how to contact us in relation to privacy requests, inquiries or complaints.
2.0 Definitions and Interpretation
3.0 How is personal information collected?
The types of personal information Accolade Wines collects will vary depending on the nature of your dealings with Accolade Wines. Generally, the types of personal information we collect and hold may include your name, contact information, employment details, financial and tax related information and any other information provided at Accolade Wines’ request.
We may collect personal information in a number of ways, including:
- directly from you, including through our websites, by telephone, through written correspondence and in person if you visit our cellar doors or wineries;
- from credit reporting agencies;
- from publicly available sources of information; and
- monitoring and recording of calls that you make to us in certain circumstances (we will notify you beforehand).
4.0 How we use personal information
Except where your consent has been provided, Accolade Wines will only use personal information for the primary purpose for which we collected it (or a purpose related to it), where required or permitted by law, or where you have consented to such use or disclosure.
The main purposes for which we may use or disclose personal information include:
- to provide products and services requested by you and to manage those services, including to enable customer service, delivery and billing;
- evaluating and monitoring credit worthiness;
- meeting legal and regulatory requirements; and
- to directly promote and market products, news, promotions and other services to you where we have your express or implied consent. If you do not wish to receive news, offers and promotions, we will not contact you about these once you have advised us as such.
We may expressly communicate to you the primary purpose for which your personal information is collected, or it may be clear from the nature of our dealings with you.
If you receive electronic communications from us, we will provide you with an opportunity to unsubscribe from receiving further information from us.
5.0 Our disclosure of personal information
The primary instances where Accolade Wines may disclose personal information to third parties include:
- to external advisors and service providers including advertising and credit reporting agencies, so they can provide the services we have contracted to them;
- to law enforcement bodies, in order to comply with the law or to protect the rights, property or safety of the public or Accolade Wines; and
- 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.
6.0 How is my personal information stored and kept secure?
Accolade Wines takes reasonable physical and electronic steps to keep the personal information we hold secure from unauthorised access, modification, loss and interference. Accolade Wines has internal policies, procedures and systems in place to ensure compliance with this Policy.
Personal information may be stored electronically and/or in hard copy, and appropriate information security measures are in place to protect this information.
Unfortunately, no data transmission over the internet can be guaranteed to be fully secure and you need to be aware of this when communicating with or providing personal information to Accolade Wines over the internet.
Additionally, we ensure that we only disclose your personal information to third parties where it is necessary or compulsory to do so, and we impose strict security requirements on all such third parties regarding how they hold and deal with personal information.
7.0 International use
Accolade Wines operates as a global business, and has global data storage arrangements. Accordingly, the information that we collect from you may be transferred to, and stored at, a destination outside of the country in which the information was collected. It may also be processed by employees operating outside of the country in which the information was collected or for one of our suppliers or agencies.
Accolade Wines may disclose or transfer your personal information where necessary to companies which are “related bodies corporate” or “ultimate holding companies” or “subsidiaries”. Generally, we will ensure that an international entity is bound by privacy obligations equivalent to the APP’s, Privacy Act and/or the Act, before we disclose or transfer your personal information to it.
8.0 Accuracy of my personal information
We take all reasonable precautions to ensure that the personal information we collect, use and disclose is accurate, complete and up-to-date. However, Accolade Wines will assume that any of the personal information provided by you is up to date and complete at the time it is provided. Accolade Wines does not undertake to check or verify the accuracy of personal information provided.
9.0 How do I access and correct my personal information
If you wish to access or update your personal information held by Accolade Wines, you need to contact our Privacy Officer or Data Protection Officer.
Please see our contact details in section 12 of this Policy.
When you contact us with such a request, we will take steps to update your personal information, provide you with access to your personal information and/or otherwise address your query within a reasonable period after we receive your request. Sometimes it will not be possible for us to grant you access to your personal information that we have about you. In such cases, we will give you a written notice explaining why.
You have the right to ask us not to process your personal information for marketing purposes. We will usually inform you (before collecting your information) 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 or by contacting us at email@example.com.
10.0 How do I make a complaint?
A complaint regarding a breach or possible breach of privacy must first be submitted in writing to Accolade Wines Privacy Officer or Data Protection Officers. Please see our contact details in section 12 of this Policy.
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.
11.0 Policy variations
12.0 How to contact us
If you wish to access or correct your personal information held by Accolade Wines, or to complain about a possible breach of privacy, enquiries should be directed to the Data Protection Officer (for UK residents only) or the Privacy Officer (for all other regions) as follows:
BY EMAIL: firstname.lastname@example.org
Accolade Wines Australia Limited
Reynell Road, Reynella SA 5161, Australia
Facsimile: 08 8392 2122
OR (for UK residents only):
Accolade Wines Limited
Thomas Hardy House, 2 Heath Road, Weybridge, Surrey, KT13 8TB
If you no longer wish to receive promotions or other direct marketing communications from Accolade Wines, please contact us through one of the methods stated above to advise us of such and provide sufficient information to enable us to locate your information. In some cases, our communications with you may contain specific methods to opt out of direct marketing material sent via the particular communication.
13.0 International operations
Accolade Wines Australia Limited (including its related bodies corporate as defined in the Corporations Act 2001) is bound by and complies with the Australian Privacy Principles (“APP’s”) as required by the Privacy Act 1988 (Cth) (“Privacy Act”).
Accolade Wines Limited (including its ultimate holding companies and subsidiaries as defined in the UK Companies Act 2006) complies with the requirements of the Data Protection Act 1998 (“DP Act”). For the purpose of the DP Act, the data controller is Accolade Wines Limited (company number 137407) of Thomas Hardy House, 2 Heath Road, Weybridge, Surrey, KT13 8TB, England. If you are located in the European Economic Area (“EEA”), we take all reasonable steps to comply with the applicable legal requirements and to provide adequate protection for the transfer of personal information outside of the EEA.
Accolade Wines North America, Inc. complies with the requirements of the Online Privacy Protection Act of 2003. Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services are entitled to request and obtain from us once a calendar year information about the customer information Accolade Wines has shared, if any, with other businesses for their own direct marketing uses and the identities of those third parties, subject to certain exceptions. To make such a request, please contact us through one of the methods stated above.
Annexure A – Cookies and Accolade Wines sites
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.
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.
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.
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.
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.