PRIVACY POLICY

Handpicked Experience (Sydney) Pty Ltd ABN 66 608 696 966 and its Related Bodies Corporate (as defined in the Corporations Act 2001 (Cth)) (Handpicked Winesus, we or our) are committed to responsible privacy practices and takes your privacy seriously.

This privacy policy (Policy) describes how we manage personal information, including how we collect personal information, both offline and online (including through the website www.handpickedwines.com.au (Site)), the purposes for which we use this information, and to whom this information is disclosed in accordance with our obligations under the Privacy Act 1988 (Cth), as amended or updated from time to time (Privacy Act).

What is personal information?

In this Policy, "personal information" has the meaning set out in the Privacy Act.  Essentially, personal information is information or an opinion about an individual who is identified or reasonably identifiable from that information, or reasonably identifiable from other information combined with that information.

Some types of personal information are classified as 'sensitive information' and/or 'health information', which are subject to additional protection under the Privacy Act.  This may include your disabilities, medical condition, or your dietary or allergy requirements.

Kinds of personal information we collect and hold

The kinds of personal information we collect and hold about you include:

  1. your full name, phone number(s), e-mail address, postal address, demographic information (such as postcode) and date of birth;
  2. your credit card and debit card details, or other payment instrument used by you;
  3. information you provide us through customer surveys;
  4. your preferences and opinions;
  5. information about your access to and use of our Site;
  6. details about products and services you have purchased from us including any enquiries in relation to our products and services and our responses to your enquiries;
  7. technical information and general analytics, such as web browser type and browsing preferences, Internet service provider, referring/exit pages, date/time stamps, IP address, time zone and geolocation data (if applicable), some of which is collected automatically,  arising from your use of the Site and/or platforms, as well as information about your usage of the Site and/or platforms when browsing (see "How we collect personal information" below);
  8. if you are a contractor or a prospective employee, your employment history and educational qualifications;
  9. if you have contacted us to make a complaint, provide feedback, submit an enquiry, request a call-back or request a product replacement, you name, mailing or street address, email address, and phone number(s); and
  10. any other personal information requested by us or provided by you or a third party to us.

We may also collect other kinds of personal information as permitted or required by law.

Generally, we will not collect sensitive information about you.  However, in certain circumstances such as where you order our products through the Site or choose to visit one of our Cellar Doors in Sydney or Melbourne, we may need to collect limited sensitive information about you.  For instance, this can include where you disclose details of disabilities, medical condition, or other specific dietary or allergy requirements to us.

Purposes for which we collect, hold, use and disclose personal information

The purposes for which we collect, hold, use and disclose personal information include the following:

  1. to enable you to access and use our Site;
  2. to provide our products and services to you, including to enable the delivery of products sold through our Site to you;
  3. to verify your identity and age (for example, to ensure that you are over eighteen (18) years old; or if you request access to the personal information we hold about you);
  4. to address any issues or complaints that we or you may have regarding our relationship, our products or our services;
  5. to prevent, detect and investigate suspicious, fraudulent, criminal or other activity that may cause you, us or others harm, including in relation to our products and services;
  6. to comply with our legal obligations such as notifying you of matters that we may be required by law to do so;
  7. to identify opportunities to improve our products and services and to improve our service to you;
  8. for analytics and market research, including to improve our Site and the products and services offered on our Site;
  9. for direct marketing purposes, including to send you news, information about our activities and general promotional material which we believe may be useful to you (see "Direct marketing communications" below);
  10. to monitor who is accessing our Site or using services offered on the Site for the purposes of improving our products/services and Site functionality;
  11. gain insights about you so that we can serve you better, understand your preferences and interests, personalise your experience and/or enhance products and services you are offered and receive;
  12. to consider your employment application or a contracting position with us; and
  13. contact and communicate with you regarding any of the above, including via electronic messaging such as SMS (with your consent), email, by mail, by phone or in any other lawful and authorised manner.

We may also use or disclose your personal information for other purposes to which you have consented or as otherwise permitted or required by law.

Technical information and general analytics, such as web browser type and browsing preferences are used for the purpose of gauging visitor traffic, trends and delivering personalised content to you while you are using the Site, and to improve the Site and our products and services.

To whom do we disclose personal information?

We may disclose your personal information to third parties in connection with the purposes described above.  We may also disclose your personal information between our Related Bodies Corporate (as defined in the Corporations Act 2001 (Cth) (Related Bodies Corporate), including for the purpose of direct marketing (where you agree to us doing so). See "Direct marketing communications" below.

This may include disclosing your personal information to the following types of third parties:

  1. service providers who assist us with our activities, such as postal companies, couriers, website hosts, IT back-up service providers, and other IT or payment service providers;
  2. our other contractors who assist us in performing our functions and activities, such as including marketing agencies, insurance providers and professional advisers;
  3. any third parties to whom you have directed or permitted us to disclose your personal information (e.g. referees);
  4. in the unlikely event that Handpicked Wines (or any companies in its group) or any of their assets may be acquired or considered for acquisition by a third party, that third party and its advisors;
  5. third parties that require the information for law enforcement or to prevent a serious threat to public safety; and
  6. any other persons as permitted or required by law.

We use third party service providers to provide us with web analytics services, such as:

  1. Microsoft Azure;
  2. Google Analytics;
  3. Facebook Pixel;
  4. Google Console;
  5. Google AdWords; and
  6. TheFork.

You should contact these companies directly if you have any questions about their collection and/or use of information.

Whilst we will always maintain robust privacy practices, we are not responsible for the privacy practices of third parties, so you should review their relevant privacy policy to satisfy yourself as to how they protect and handle your personal information.

Where we disclose your personal information to third parties with whom we have a business relationship we will use reasonable commercial efforts to ensure that such third parties only use your personal information as reasonably required for the purpose we disclosed it to them and in a manner consistent with applicable laws, for example by (where commercially practical) including suitable privacy and confidentiality clauses in our agreement with a third party service provider to whom we disclose your personal information.  To assist us in improving our products and services, we monitor aggregated data that is collected by our Site and may share this with third parties collectively and in an anonymous way.  This data will not reveal personal information.

How we collect personal information

We collect personal information in a number of ways. We collect your personal information directly from you, including when you:

  1. access or use the Site, or when you deal with us online (including through social media);
  2. purchase our products or services;
  3. subscribe to our newsletters;
  4. register for, or participate in, our loyalty programs, including the Handpicked Wines Rewards Program;
  5. fill out our forms or surveys;
  6. enter into or participate in our promotions or events;
  7. call us, write to us or visit us in-store, including when you visit our Cellar Doors and provide information to us; and
  8. apply to work with us or are engaged by us as a contractor.

Where it is reasonable and practicable to do so, we will only collect personal information about you from you directly and not from third parties. 

In limited circumstances, we may collect personal information about you from publicly available sources (such as the Internet) and from third parties (such as from the person who ordered the products, if you are a recipient of any products purchased through the Site by a third party or are accepting delivery for such products; or from referees, if you apply for a position as an employee or contractor with us).  We may also collect personal information through third parties such as our service providers.

Cookies

We use "cookies" and similar tracking technology, such as web beacons on our Site, which enable us to monitor traffic patterns and to serve you more efficiently if you revisit the Site.  A cookie does not identify you personally, but it does identify your computer.  You may disable your web browser from accepting cookies and other tracking technologies used to collect technical information and general analytics when browsing our Site.  If you do so, you can still access our Site, but it may impact your user experience of the Site.

Storage and security

We will take reasonable steps, in accordance with any Office of the Australian Information Commission (OAIC) guidance and including technical and organisational measures, to keep any personal information we hold about you secure and to protect it from unauthorised access, modification or disclosure, and from misuse, interference and loss.

Among other techniques, we usually:

  1. store information behind our "firewall" in a secure digital location; and
  2. restrict the number of employees who can have access to such information.

Personal information no longer required

We will take reasonable steps to destroy, delete or de-identify personal information which we no longer require for the purposes under which it was collected, provided that there is no legal requirement for us to retain the personal information. These retention periods will be periodically reviewed.

Direct marketing communications

We will only send you direct marketing communications (either through mail, SMS or email), including any news and exclusive offers, promotions, or events, where you have consented for us to do so.

You may opt-out of receiving direct marketing communications at any time by contacting us or by using opt-out facilities provided in the respective direct marketing communication. We may also disclose your personal information between our Related Bodies Corporate, including for the purpose of direct marketing (where you agree to us doing so).

You may also opt out of targeted advertising by using the links below: 

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal

How you may access personal information we hold about you and seek correction of it

You may request access to personal information which we hold about you at any time by contacting us using the contact details below.  We will provide access to that information in accordance with the Privacy Act, subject to any exemptions which may apply.  We may require that the person requesting access provides suitable identification and, where permitted by law, we may charge an administration fee for granting access to your personal information, in which case we will let you know in advance.

If you become aware that any personal information we hold about you is incorrect or if you wish to update your information, please contact us using the contact details below.  Where we agree that the information needs to be corrected, we will update it.  If we do not agree, you can request that we make a record of your correction request with the relevant information.

You can also ask us to notify any third parties that we provided incorrect information to about the correction.  We’ll try and help where we can - if we can’t, then we’ll let you know.

Questions or complaints?

If you have any questions, concerns or complaints about our collection, use or disclosure of personal information, or if you believe that we have not complied with the Privacy Act, please contact us using our contact details below.

We will take any privacy complaint seriously and any complaint will be assessed by an appropriate person with the aim of resolving any issue in a timely and efficient manner.  We request that you cooperate with us during this process and provide us with any relevant information that we may need.

If you have raised a complaint with us and you are unsatisfied with the outcome or have further concerns about the way we handle your personal information under the Privacy Act, you may complain to the Information Commissioner at the OAIC, whose contact details are set out below:

Office of the Australian Information Commissioner

Mail address: GPO Box 5218, Sydney NSW 2001

Phone: 1300 363 992

Online: www.oaic.gov.au

Email: enquiries@oaic.gov.au

Our contact details

You can contact us at:

Handpicked Privacy Officer

Mail address: PO Box 20723, World Square NSW 2002

Phone: (02) 9475 7888

Email: cellardoor@handpickedwines.com.au

Changes to this Policy

We may change or update this Policy from time to time to keep up-to-date with legal requirements and the way we operate our business.  An up-to-date version of this Policy is available at any time on this page at https://handpickedwines.com.au/pages/privacypolicy. You are responsible for reviewing this Policy periodically and informing yourself of any changes.  We suggest that you check back regularly.  If we make significant changes to our Privacy Policy, we will seek to inform you by notice on our Site or by email.

 

Last update: 11 June 2024