PRIVACY POLICY
In this Privacy Policy, 'us' 'we' or 'our' means Terranu Pty Ltd (ABN 68 639 777 432).
We are committed to respecting your personal information. Our Privacy Policy sets outs out how we collect, use, store and disclose your personal information in accordance with the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (Privacy Act) and where indicated and applicable to you the General Data Protection Regulation (EU) 2016/679 (GDPR).
By providing personal information to us, you acknowledge that you have read and understood this Privacy Policy and you consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy and any other arrangements that apply between us.
What is personal information?
Personal information is 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 the information or opinion is recorded in a material form or not.
What personal information do we collect?
We may collect the following types of personal information:
  • your name, date of birth, mailing or street address, email address, personal and work telephone number, and other contact details;
  • place of employment;
  • your billing and payment information, including your bank, credit card, or other transaction details;
  • your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information;
  • information about your participation in any promotional or special events;
  • details of the products we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and respond to your enquiries;
  • any information that you provide to us when requesting an appointment through our website;
  • any information that you provide to us when giving feedback about our products through our website;
  • any additional information relating to you that you provide to us directly or indirectly through our website; privacy policy; or
  • any other personal information that may be required in order to facilitate your dealings with us.
How do we collect personal information?
We may collect these types of personal information directly from you when you:
  • use our website;
  • enquire about or receive products from us;
  • make an order for or purchase products from us;
  • register an account on a user portal on our website;
  • participate in one of our club memberships (eg Terranu Wine Club);
  • communicate with us through correspondence, social networking sites (eg Facebook, Twitter, Instagram, LinkedIn), chats, email, online chat bots, our website, or when you share information with us from other social applications, or websites;
  • interact with our sites, content, advertising, marketing campaigns, promotions and special events.
We may also receive your personal information indirectly from third parties when you interact with them or their content, advertising and marketing campaigns relevant to our products – for example, resellers and retailers of our products.
If you wish to provide the personal information of a third party to us, you must first inform the third party about our Privacy Policy and that you are providing their personal information to us.
Why do we collect, hold, use and disclose personal information?
We may collect, hold, use and disclose your personal information for the following purposes:
  • to provide products to you;
  • to identify orders placed by you through our website;
  • to provide appropriate information and opinions about our products to you;
  • to operate, protect, improve and optimise our website, and user-experience - such as to perform research and analytics;
  • for advertising and marketing purposes;
  • to send you marketing and promotional messages, and other information that may be of interest to you;
  • to send you communications regarding our event, content, research and special offers from us;
  • to send administrative messages, reminders, technical notes, updates, security alerts, and information about the products;
  • to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners;
  • to provide information credit reporting agencies and courts, tribunals and regulatory authorities if you fail to pay for the products we have provided;
  • to courts, tribunals, regulatory authorities, and law enforcement officers as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights; and
  • to comply with our legal obligations, resolve any disputes that we may have with any of our website users or clients, and enforce our agreements with third parties.
We may also disclose your personal information to a trusted third party who also holds other information about you. This third party may combine that information in order to enable it and us to develop anonymised consumer insights so that we can better understand your preferences and interests, personalise your experience and enhance the products that you receive.
When no longer required by us, unless required by law to retain it, we will take reasonable steps to destroy or de-identify your personal information securely.
Do we use your personal information for direct marketing?
We may send you direct marketing communications and information about us and our products. This may take the form of emails, SMS, mail or other forms of communication. You may opt-out of receiving marketing communications and information from us by contacting us at compliance@terranuwines.co or by using the opt-out facilities provided (eg an unsubscribe link).
To whom do we disclose your personal information?
We may disclose personal information for the purposes described in this Privacy Policy to:
  • third party product suppliers, including suppliers of wine products;
  • third party service providers, including third party payment service providers that we rely on to process your payments to us (e.g. Stripe, PayPal, eWay);
  • our employees, including receptionists, for administrative purposes;
  • our related bodies corporate;
  • professional advisers;
  • our existing or potential agents, business partners or partners;
  • our sponsors or promoters of any competition that we conduct;
  • anyone to whom our assets or businesses (or any part of them) are transferred;
  • specific third parties authorised by you to receive information held by us; and/or
  • other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.
Individuals residing in the EU – GDPR
Your rights under the GDPR
Individuals residing in the EU, have certain rights as to how personal information that is personal data (as defined under the GDPR (Personal Data) is obtained and used. We comply with the principles of data protection set out in the GDPR in relation to those individuals.
In addition to the rights in our Privacy Policy, you have rights with respect to your personal information under the GDPR. Your rights include, but are not limited the following:
  • Access: you have the right to ask us for copies of your Personal Data;
  • Rectification: you have the right to ask us to rectify your personal data you think is inaccurate. You also have the right to ask us to complete your personal data if you think it is incomplete;
  • Erasure: you have the right to ask us to erase your Personal Data;
  • Restriction of processing: you have the right to object to the processing of your Personal Data; and
  • Data Portability: you have the right to ask that we transfer the Personal Data you gave us to another organisation, or to you.
These rights are not absolute, and some only apply in certain circumstances. You are not required to pay any charge for exercising your rights.
If you make a request in relation to any of these rights, we have one month to respond to you. If you wish to make a request, please contact us at compliance@terranuwines.co.
How do we use collect, store and process Personal Data?
We collect, use, store and process Personal Data where we have a lawful basis to do so. The lawful basis for which we collect your Personal Data depends on the data we collect and how we use it. The lawful bases that may apply to our processing activities are:
  • Consent: you have given clear consent for us to process your Personal Data for a specific purpose.
  • Contract: the processing of your Personal Data is necessary for the performance of an agreement with you to provide products.
  • Legal obligation: the processing of your Personal Data is necessary for us to comply with (not including contractual obligations).
  • Vital interests: the processing of your Personal Data is necessary to protect someone’s life.
  • Public task: the processing of your Personal Data is necessary for us to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law.
  • Legitimate interests: you have given clear consent for us to process your Personal Data for a specific purpose.
We will not process any of your Personal Data that is considered “sensitive data” under the GDPR unless we have obtained your explicit consent, or if it is being collected subject to and in accordance with the GDPR.
Disclosure and transfer of personal information outside Australia
We do not disclose or transfer personal information to persons located outside of Australia.
Using our website and cookies
We may collect personal information about you when you use and access our website. While we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer.
We may also use 'cookies' or other similar tracking technologies on our website that help us track your website and/or mobile app usage and remember your preferences. Cookies are small files that store information on your computer, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies, but our website may not work as intended for you if you do so.
We may also use cookies to enable us to collect data that may include personal information. For example, where a cookie is linked to your account, it will be considered personal information under the Privacy Act. We will handle any personal information collected by cookies in the same way that we handle all other personal information as described in this Privacy Policy.
Our website uses Google Analytics, a service that enables the tracking of user analytics including but not limited to browser information, operating system information, pages viewed while browsing the website, session times and referring website addresses, and enables us to help understand traffic and usage of the website. Information about you regarding your usage behaviour is held by Google and is subject to its privacy policy which can be viewed here. Information about privacy issues relating to Google Analytics can be found here: https://support.google.com/analytics/topic/2919631?hl=en&ref_topic=1008008
We may also use the Google Ads service to enable remarketing services, and Google UserID, demographic and interest reports. Information about you regarding your web usage behaviour is held by Google. Information from Google’s UserID service may be connected to other data that we hold about you.
Our website may also use Facebook pixels for conversion tracking and custom audiences, in accordance with Facebook’s terms which can be viewed here: https://www.facebook.com/customaudiences/app/tos/?ref=u2u.
We may also use other third-party providers. You can opt out of a third-party vendor's use of cookies, or the collection and use of information for ad targeting, by visiting the Network Advertising Initiative opt out page or AdChoices.
Security
We take reasonable steps to protect your personal information from misuse, interference and accidental loss, as well as unauthorised access, use, destruction, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information. In particular:
  • access to our information systems is controlled through identity and access management, including password protection and restricted access of certain files to seniors employees;
  • we require website users to not take any action that would constitute a breach of the privacy rights of an individual in our Website Terms and Conditions available at Website T & C and
  • it is our policy to require any contractors that might have access to your personal information to enter into a binding legal contract requiring them to keep that information confidential before being granted access to that information.
However, we cannot guarantee the security of your personal information.
We may retain your personal information to fulfil the purposes outlined in this Privacy Policy for as long as needed, as allowed, or as required by law.
Links
Our website, and documents produced in the course of providing the products, such as reports, may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. The privacy policies and other terms that apply to those other websites may differ substantially from our Privacy Policy, so we encourage individuals to read them before using those websites.
Accessing or correcting your personal information, and accessing and managing consents
You can access the personal information we hold about you by contacting us using the below contact information. Sometimes, we may not be able to provide you with access to all of your personal information and, where this is the case, we will tell you why. We reserve the right to charge a reasonable fee for searching for, and providing access to, your information on a per-request basis. We may also need to verify your identity when you request your personal information.
You can also access and manage any consents you have given us to use your Personal Data for any particular purpose using the below contact information.
If you think that any personal information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the below contact information and we will take reasonable steps to ensure that it is corrected.
Where the laws applicable in your location require it, you may exercise the following data protection rights (without limiting your rights under this Privacy Policy): the right of deletion, the right to amend or rectify your personal data, the right to object to the use of your personal data, the right to restrict processing of your data, the right of access, and the right of portability.
Changes to this Privacy Policy
We may change our Privacy Policy from time to time by publishing changes to it on our website. We encourage you to check our website periodically to ensure that you are aware of our current Privacy Policy.
Making a complaint
If you think we have breached the Privacy Act, or you wish to make a complaint about the way we have handled your personal information, you can contact us about your complaint using the below contact information. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time. If you think that we have failed to resolve the complaint satisfactorily, please let us know and we will provide you with information about the further steps you can take.
If you are a resident in the EU and should you have any concerns, or wish to exercise your rights in relation to our collection and/or processing of your Personal Data, then in addition to the process set out above you have the right to complain to a supervisory authority, within the meaning of the GDPR.
Contact Us
For further information about our Privacy Policy or practices, or to access or correct your personal information, or make a complaint, please contact us using the following contact details:
By mail:
Privacy Officer
Terranu Pty Ltd
2 Park Street, Sydney NSW 2000
Effective date: 11 May 2020