SPIRITS PLATFORM PRIVACY POLICY
INTRODUCTION
This website and its contents (the “Site”) are owned by Spirits Platform Pty Ltd. ACN 604 520 783 (“SPIRITS PLATFORM”). This Privacy Policy describes the way in which SPIRITS PLATFORM (“us”, we”) use and disclose information obtained by us from your use of the Site and how we intend to meet our obligations under the Australian Privacy Principles (‘APPs’) set out in the Privacy Act 1988 (Cth) (‘Privacy Act’). By visiting the Site you are agreeing with and consenting to the practices described in this Privacy Policy. If you do not agree with this Privacy Policy you should immediately cease using the Site. As this Policy may be updated from time to time as the Site and its content develops and matures, we encourage you to check this Policy regularly.
INFORMATION COLLECTED BY US
We may collect personal information, such as your name and email address, and sometimes other contact details such as your residential address and telephone numbers. We collect this information generally to fulfil the purpose for the collection. We will tell you why we are collecting information, when we collect it, and how we plan to use it, or these things will be obvious when we collect the information. We collect personal information directly from you, in a number of ways, including: when you order products; when you register on this Site; when you subscribe to our mailing list; when you enter a competition; and when you make contact with us by sending us an email. Except as expressly provided for in this Privacy Policy, if you provide information about yourself by registering on a page on this Site, by filling out one of our surveys, or otherwise by voluntarily telling us about yourself or your activities, we will collect that personal information for SPIRITS PLATFORM’s own internal use. Except as expressly provided for in this Privacy Policy or where may be otherwise necessary, only designated and authorised SPIRITS PLATFORM sales and marketing employees will use the information you give us, in connection with their duties. This will be for the purposes of identifying consumer preferences, improving our products and services, and the content of this Site. When you give us your first and last name, birthdate, email, day and evening telephone numbers, or postal address, we or our brand partners may contact you by email, regular mail, or telephone from time to time with information about new products and services, special offers, upcoming events and competitions. If you do not provide any of the information required, we may not be able to provide you with the services that you request. If you do not wish to be contacted by all or any of these methods, you may let us know by sending an email message to us at orders@spiritsplatform.com.au. Please be sure to give us your exact name and address so we can be sure that we remove your name from our lists. We do not knowingly solicit or collect personal information from or about children, and we do not knowingly market our products or services to children.
INFORMATION STORED & OBTAINED FROM “COOKIES”
The Site makes use of a feature of Internet web browsers called “cookies”; small pieces of information stored by your browser on your computer’s hard drive. The use of cookies allows your browser to remember some specific information relating to you and your use of the Site and helps us to make your use of the Site easier by storing information about your preferences. Whenever you visit our Site, we will check with your browser for the presence of our cookies, which contain information such as whether you have visited the Site before and your preferences for our Site.
OUR USE AND DISCLOSURE OF YOUR INFORMATION
We are committed to ensuring that our use and disclosure of your information complies with this Privacy Policy and any other applicable laws relating to privacy, data collection and the use of information that are currently enacted or may be enacted in the future. As a guiding principle, we use information that is collected: to operate the Site; to provide you with a product or a service you have requested from the Site; to help us and our brand partners gain a better understanding of your likes and dislikes, so as improve the Site (and other sites run by us), our and our brand partners’ marketing strategies and/or the products and services generally offered by us or our brand partners. We or our brand partners may contact you by any means, including without limitation to, mail, telephone, and email or via SMS. We may also use the information collected to notify you about changes to the Site, and to inform you of services and special offers that we think you’ll find valuable. From time to time we may also use the information to send you information about us and possibly about third parties (we shall send such information directly to you – your information will not be provided to third parties other than our brand partners). In all instances, if you do not want to receive such offers, you will be able to “opt out” from receiving them. To facilitate our efficient use of your information, and to provide you with the services or products requested by you, it may sometimes be necessary for us to disclose your information to third parties. However, this disclosure shall only occur in the following circumstances:
TO OUR BRAND PARTNERS
We promote, distribute and sell products and services of brand partners. Brand partners are the parent companies of the brands we distribute, market and sell for on their behalf in Australia. We may share your information with those brand partners for the purpose of those brand partners marketing, promoting, advertising and selling their products and services to you. In using such information our brand partners agree to use such information in a manner consistent with the terms of this Privacy Policy.
TO OUR EMPLOYEES, CONTRACTORS & AGENTS
We may engage or employ other companies and individuals to perform functions on our behalf. Examples may include, but are not limited to processing credit card payments, fulfilling orders and delivering products, analysing data, providing marketing assistance, providing legal or accounting advice and/or providing information technology and related services. Such parties will have access to only that personal information required by them to perform their functions, and may not use such information for any other purposes.
AGGREGATED STATISTICAL INFORMATION
We may provide aggregated statistical information about access patterns, navigational techniques, product sales, etc. to reputable third parties. However, except in the case of information we provide to our brand partners in all instances such information will simply comprise aggregated data collected about you and other users, and will not include any direct personal information that identifies you as our customer.
WHERE REQUIRED BY LAW
In certain circumstances, we may be required by law to disclose your personal information, for example, where disclosure is ordered by a Court, or subpoenaed in relation to third-party litigation. We also reserve the right to choose to disclose your information to law enforcement agencies in circumstances described in the Australian Privacy Principles and other applicable laws and regulations, including for the purpose of investigating alleged contraventions of the law.
WITH YOUR CONSENT
Other than as outlined above, we will endeavour to provide you with notice (which may occur via your nominated email) when we wish to provide personal information about you to third parties and provide you with the opportunity to choose not to share that information.
A FURTHER WORD ON “COOKIES”
As noted earlier in this Policy, this Site makes use of a feature of Internet browsers called “cookies”. Cookies help us to “remember” your preferences in relation to the Site. By showing how and when you use our Site, cookies help us see which areas are popular and which are not, and to tailor the Site accordingly. The use of cookies is an industry standard and you’ll find most major websites use them. If you prefer not to receive cookies you can adjust you Internet browser to refuse cookies or to warn you when cookies are being used. A number of third-party products are also available to remove cookies from your computer. However, the vast majority of our Site will not function if cookies have been turned off, and set your browser to “warn” you when cookies are used will reduce your enjoyment of the Site. For this reason we strongly recommend that you leave cookies fully functional. Of course, we never use cookies to retrieve information from your computer that was not originally sent by us, do not allow or share third party access to cookies placed by our Site, and except as outlined above, do not share any information obtained from them with any third parties.
HOW SECURE IS MY INFORMATION?
We take all reasonable steps to keep our server secure and free from misuse, interference, loss or unauthorised access and use, by enforcing physical security at the premises in which the server is located, and by using industry-standard technological measures to prevent unauthorised remote access to the server. Sensitive information, such as credit card and related financial information that is transmitted to and from our servers is secured using encryption methods. Unfortunately, no server on the Internet nor any data transmission over the Internet can be guaranteed to be 100% secure. Despite our best efforts to keep our server and transmissions to and from our server secure, we are unable to absolutely guarantee security and there will always be a risk of unauthorised access to your information. Although we will take all reasonable steps to keep secure any information that we hold about you, we will not be held responsible for events arising from unauthorised access, modification or disclosure to such information.
ACCESSING AND CHANGING YOUR INFORMATION
The information that you provide to us is kept in a secure environment to which access is granted only to authorised persons. If you wish to access or correct any personal information we hold about you or have any feedback or concerns about privacy, please contact us by sending us an email to enquiries@spiritsplatform.com.au. Where you seek a response from us, we will let you know who will be handling your matter and when you can expect a full response. In the case of access and correction requests, please provide as much detail as you can about the particular information you seek, in order to help us retrieve it. Under the Privacy Act and other relevant laws, we are required to provide our reasons if we refuse your request for access or correction. Where we decide not to make a requested correction and you disagree, you may ask us to make a note of your requested correction with the information. Please note that under the Privacy Act we may refuse your request to access your information if:
- we reasonably believe that giving you access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety; or
- giving access would have an unreasonable impact on the privacy of other individuals; or
- the request for access is frivolous or vexatious; or
- the information relates to existing or anticipated legal proceedings between us, and would not be accessible by the process of discovery in those proceedings; or
- giving access would prejudice any negotiations between us; or
- giving access would be unlawful; or
- denying access is required or authorised by or under an Australian law or a court/tribunal order; or
- we have reason to suspect you of unlawful activity, or misconduct of a serious nature.
LINKS TO OTHER SITES
The Site contains links to other sites. With the exception of other sites owned by us, we do not control the information collection of sites reached through links from this Site. If you have any questions about the information collection policies of those sites then you should contact the companies controlling those sites directly.
OVERSEAS DISCLOSURE
We will may disclose personal information to brand partners outside of Australia including brand partners in France, Italy, Scotland, Germany, USA, Mexico, Singapore and Spain. Although we will take all reasonable steps to ensure these overseas brand partners will adhere to this Privacy Policy, we cannot guarantee that any overseas brand partner will not breach the Australian Privacy Principles. By supplying your personal information to us, you consent to the overseas transfer on these terms as permitted by the Australian Privacy Principles and agree that we are not liable in this regard, to the fullest extent permitted by law.
HOW CAN YOU COMPLAIN ABOUT OUR MANAGEMENT OF PERSONAL INFORMATION?
If you wish to complain about a breach of the privacy rules that bind us, you may contact us by email to enquiries@spiritsplatform.com.au We may ask you to provide further details about your complaint. We may discuss your complaint with our personnel and our service providers and others as appropriate. We will investigate the matter and attempt to resolve it in a timely way. We will inform you in writing about the outcome of the investigation. If we do not resolve your complaint to your satisfaction and no other complaint resolution procedures are agreed or required by law, we will inform you that your complaint may be referred to the Office of the Australian Information Commissioner for further investigation and will provide you with the Commissioner’s contact details.
OUR CONTACT DETAILS
If we become aware of any ongoing concerns or problems with the Site, we will take the issue seriously and work to address your concerns. If you have any queries about this Privacy Policy, or have a problem or complaint, then you should contact us by sending an email to enquiries@spiritsplatform.com.au