Australian Distilling Co. Pty Ltd (‘we’, ‘us’ or ‘our’) is committed to ensuring the privacy of personal information of individuals with whom we deal. This policy details how we manage the personal information we hold about you.

We are bound by the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (Act). The APPs regulate the collection, handling, use and disclosure of personal information, and allow you to seek access to and update your personal information, or complain about a breach of the APPs.

The Act defines ‘personal information’ as information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not and whether recorded in a material form or not.

We reserve the right to change this policy from time-to-time as required. We encourage you to check our website for any updates to our policy from time-to-time.

1. Collection of personal information

   1. The personal information we collect from you will depend on the dealings we have with you, but we will limit the information we collect to what is reasonably necessary for us to provide you with products and promotions we offer.
   2. The kinds of information we typically collect include name, address, phone number, email address and other information relevant to providing you with our products and to assist with our customer relationship management and market research functions.
   3. We will, whenever possible, collect information from you personally through the use of any of our standard application forms, the subscribe on-line function, or get in touch or cart forms, and will take reasonable steps to provide you with reasons for the collection of your personal information.
   4. When collecting personal information, we will take reasonable steps to make you aware of the purposes for which the information is collected, the organisations to which we may disclose your information, the consequences if you fail to provide the requested information, and whether we are likely to disclose your information to overseas recipients.
   5. We may collect personal information about you indirectly from third parties. Should we collect your information indirectly, we will contact you as soon as reasonably practicable and notify you as to how we collected the information and for what purposes it will be used. We will also determine if we are entitled to receive the information and will treat such information in the manner set out in this Privacy Policy. We will destroy or de-identify all personal information received from third parties which we are not entitled to hold.

2. Use of personal information

   1. We will use your personal information for the purpose for which we collected it, and for related purposes we consider will be within your reasonable expectations. If we use your personal information for any other purpose we will first obtain your consent before we use your personal information, unless we are required or permitted by law to do so without obtaining your permission.
   2. We will only collect personal information about you where we consider it is necessary or desirable for one or more of our business activities or functions. The kinds of activities the personal information is used for include:
      1. providing the products requested, responding to your enquiries, sending you information that you request, or otherwise achieving the purpose for which the information was submitted to us;
      2. contacting you to ask about your experiences with, or impressions of, our products or products;
      3. contacting you from time to time to advise you of new products or promotional offers, offered by us or our dealers that we consider may interest you;
      4. conducting market and client research or monitoring product demand (although where possible we will use “de-identified” information that does not refer to particular individuals when conducting these activities);
      5. improving the nature of the goods and services we provide;
      6. streamlining and personalising your experience within our website, or tailoring our information and products provided;
      7. creating aggregate data about our website visitors and other statistics to allow for more efficient operation of our website;
      8. engaging in other activities where required or permitted by law; and
      9. undertaking any purpose related to any of the above.
   3. We may use personal information to contact you for direct marketing and promotional purposes. You may at any stage opt-out from receiving these communications by contacting our Privacy Officer or using the opt-out function provided for in the communications. If you do not opt-out in either of these ways you will be taken to have consented to receiving such communications from us.
   4. There are no consequences for opting out of receiving our marketing and promotional communications and you may elect to rejoin our marketing list at a later stage.

3. Disclosure of personal information

   1. We do not routinely disclose your personal information to any other person or organisation unless you agree to it. Your personal information will only be used for the purpose for which we collected it, or related purposes we consider within your reasonable expectations.
   2. We may disclose your personal information to:
      1. our authorised agents, contractors or subcontractors that provide administrative or promotional services (for example, mail processing businesses, printers, or market research companies or other service providers). We typically enter into contractual agreements with these organisations to ensure that information we disclose is used only for the limited purposes for which we have provided it; and
      2. our related bodies corporate, and the related bodies corporate of Antipodean Brand Holdings Pty Ltd.
   3. If we propose to disclose your personal information for any other purpose, we will first obtain your consent, unless we are required or permitted by law to do so without seeking your permission.
   4. If we need to disclose personal information to overseas recipients (for instance storing data via a cloud service or where delivery address information for online orders is managed via a third party located overseas), we will comply with the APPs in disclosing your personal information overseas including taking such steps as are reasonably necessary in the circumstances to ensure that the overseas recipient does not breach the APPs.

4. Anonymity and pseudonymity

   You may choose to deal with us on an anonymous basis or use a pseudonym. However, in some instances if you do not provide us with the personal information we require, we may not be able to provide you our products.

5. Security

   We will take necessary precautions to ensure your personal information (in both physical and electronic form) is stored in a safe and secure environment and protected from misuse, loss or unauthorised access. Any personal information held by us will be destroyed or permanently de-identified when it is no longer needed for any purpose for which we might legitimately use or disclose it and it is no longer required to be held by us as a matter of law.

6. Access to and correction of Personal Information

   1. We will take all reasonable measures to ensure that the personal information we hold about you is accurate, complete and up-to-date.
   2. You can contact us to request access to personal information we may hold about you, seek correction to personal information, or to make a complaint about a breach of the APPs or any other matter concerning the handling of your personal information by us. Such requests or complaints should be made in writing and addressed to our Privacy Officer, using the details set out below. The Privacy Officer will establish the identity of the individual before dealing with any request or complaint and may therefore ask questions which relate to the personal information held. We may refuse a request for access to personal information in circumstances prescribed by the Privacy Act.
   3. We encourage you to update us so that the information we hold about you is accurate, current and complete. Should we receive a request to correct information that we hold about you, we will take reasonable steps to correct your information, or where we cannot agree to a correction, we will attempt to flag or mark the stored information with a note to the effect that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading (as the case may be).

7. Website

   1. We collect no personal information about you when you visit the website unless you choose to provide this information to us. We take care to ensure that the personal information collected from and managed via our website is collected and managed in the same manner as other personal information.
   2. From time to time we may collect certain tracking information from the way in which people use our website (for example by using ‘cookies’). This information is collected for the purpose of improving the usefulness and usability of the site. None of this information identifies users personally.
   3. Links from this website to other sites outside of our control are for the convenience of the user. We do not accept responsibility for the privacy practices or content of those websites and you will need to contact or review those websites directly to ascertain the privacy policies of those organisations.
   4. We may collect personal information from you (such as your name, address, telephone number and email address, and any other personal information you volunteer) if you send us an email or if you submit information to us using a message form, or brochure request form or feedback form. We will use this personal information to contact you and provide you with a response to your message, to send you information that you request, and for other related purposes we consider are within your reasonable expectations. We will not use or disclose any such information for any other purpose without your consent.
   5. We may allow third parties to use cookies or other tracking technologies to collect non-personal information about your use of our website, including your IP address, pages viewed and conversion information. This information may be used, among other purposes, to deliver advertising targeted to your interests and to better understand the usage and visitation of our website and other websites tracked by these third parties. This Privacy Policy does not apply to, and we are not responsible for, third party “cookies” or other tracking technologies. We encourage you to check the privacy policies of advertisers and/or services to learn more about their privacy practices

8. Storage and Transmission of Personal Information Online

   1. If you provide any personal information to us via our online services (including email) or if we provide such information to you by such means, the privacy, security and integrity of this information cannot be guaranteed during its transmission unless we have indicated beforehand that a particular transaction or transmission of information will be protected (for example, by encryption).
   2. If we receive your personal information, we will take reasonable steps to store it such that unauthorised access, modification, disclosure, misuse and loss are prevented.

9. Social networking sites We use or may in the future use social networking services such as Twitter, Facebook and YouTube to communicate with the public about our products. When you communicate with us using these services we may collect your personal information, but we only use it to help us communicate with you and the public. The social networking service may choose to handle your personal information for its own purposes and should have their own privacy policy in place, which we encourage you read before making use of the social network service.

10. Changes to our Privacy Policy

    We reserve the right to amend this Privacy Policy at any time by uploading the updated Privacy Policy to our website. You may also obtain a copy of the current version of our Privacy Policy by contacting us. We encourage you to read our Privacy Policy each time you deal with us so that you are aware of any changes made to it.

11. Contacting us

    1. Should you require further information about our Privacy Policy, wish to make a request or complaint, or would like to opt out of receiving certain communications or information, you may contact: The Privacy Officer Australian Distilling Co. PO Box 63 Stepney South Australia 5069 Phone: (08) 8366 0000 Email: [email protected]
    2. If your concerns are not resolved to your satisfaction or you would like further information in regards to the Privacy Act, the matter can be referred to the Office of the Australian Information Commissioner by telephone number 1300 363 992.