1. Respecting your Privacy

 

General

Independent Liquor Group Supplier Co-operative Ltd (including Independent Liquor Group Supplier Co-operative ABN 63 629 864 769 and its related body corporates My Bottler, SuperCellars, Fleet Street Fine Wine, Spirits & Beer Merchants, their successors in title and assigns and their employees, servants and agents (“we”, “us”, “our” and other similar expressions) are committed to protecting your personal privacy.

As part of our business, we provide a number of services. This Privacy Policy tells you how we collect, store, use and disclose personal information.

 

Personal Information

“Personal Information” is information or an opinion – including information or an opinion forming part of a database, whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion. For the purpose of this Privacy Policy, Personal information may also include anything about credit worthiness, standing history and capacity.
We encourage you to read this policy carefully so that you understand how we deal with that information.
This Privacy Policy will not apply to other websites, services or digital assets which are linked to Independent Liquor Group Supplier Co-operative Ltd and over which it has no control. We recommend reviewing any relevant third-party privacy policy before using any linked website.

 

Changes to this Privacy Policy

As our business evolves, our business processes and policies will be reviewed and may be amended. We may change this policy at any time. We will notify you of any change by posting an updated version of the policy on our website. Please be aware that it is your responsibility to check our website and make sure you keep up-to-date with any changes to this Privacy Policy.

 

Privacy Principles

We follow and comply with the Australian Privacy Principles (“APPs”) in the Privacy Act 1988 (Cth) (“Act”). We have adopted internal policies and procedures to ensure that personal information that we collect, store, use and disclose is dealt with in accordance with the APPs.

You can see the full text of the APPs online at: https://www.oaic.gov.au/privacy/australian-privacy-principles/read-the-australian-privacy-principles.

 

2. Collection of Personal Information

You are welcome to browse our website without ever providing us with your personal information. However, in order to provide you with our products and services, we may collect and use personal information about you. If we are not provided with all the personal information we request, we may not be able to supply our products and services to you, and you or your organisation may not be able to participate in future offers of products or services which we supply.
The personal information we collect, and hold is what is reasonably necessary for our business functions and activities. When we collect and hold personal information, it may be of the following kinds:

 

General Personal information

The type of information we collect depends on how you use our services as well as the type of relationship we have with you and may include your name, date of birth, credit card details, contact details such as mobile number, residential and email address, your service usage information, financial and other business transaction details.

 

Sensitive Personal Information

We do not generally collect information that is sensitive personal information, as defined in the Act. However, where we are required to and able to do so, we will ask for your consent before collecting your sensitive information and let you know the purpose at the same time.

 

Third Party Personal Information

You might also need to provide us information about other persons (e.g. a referee). If so, you represent that, if at any time you supply us with their personal information, you are authorised to do so and you agree to inform that person who we are, that we will use and disclose their personal information as set out in this Privacy Policy.

 

3. How we collect Personal Information

 

Collection

Except where specifically mentioned in this Privacy Policy, we collect personal information from you directly. For example, we may collect personal information when you subscribe to our Newsletter, open an account, deal with us over the telephone, send us a letter, visit our website, when you contact us in writing or when you contact us in person.

We may need to source information about you from a third parties. Wherever possible this will be done with your authorisation or where this is not possible, we will inform you when such information is collected.

 

4. Purpose of Collection

Typically, when we collect, hold and use your personal information, we do so primarily to sell and promote goods and services to you and to improve on the range of our offerings. For example:

• to learn of your likely preference’s so that we may promote goods and services to you in a way which may be of most interest to you. This includes the products and services of our suppliers and other trusted partners who offer products and services that may be of interest to you.
• to assist in investigation your complaints and enquiries.
• subscribing to our newsletter, we will use this information for:
  ***our register of members and shareholders
  ***the provision and offer of membership services.
• a financial product or service, we will use this information to create, administer and maintain a financial service relationship.

In addition, you agree we may hold and use the personal information you provide for the purposes (as relevant) of:

• considering any other application, you may make to us;
• complying with legislative and regulatory requirements;
• performing administrative functions, including accounting, risk management, record keeping, archiving, systems development, credit scoring and staff training;
• managing our rights and obligations in relation to external payment systems;
• conducting market or customer satisfaction research;
• developing, establishing and administering alliances and other arrangements with other organisations in relation to the promotion, administration and use of our respective products and services;
• carry out billing and debt recovery activities;
• developing and identifying products and services that may interest you; or
• providing you with information about other products and services.

If we request personal information and you choose not to or you cannot provide us with that information, we may be unable to accept or continue your subscription or to provide you with the relevant services you have requested or need.

 

5. Disclosure to third parties

Information that we collect is stored in Australia. Wherever our business is outsourced to third parties, personal information provided to these parties remains our property and is only used for the specific purpose for which it is supplied, or a purpose related to that specific purpose as permitted under the Act. Examples of third parties to whom we may disclose personal information you provide include:

• credit reporting agencies;
• financial institutions;
• our agents, suppliers, contractors and external advisers whom we engage from time to time to carry out, or advise on, our functions and activities;
• regulatory bodies, government agencies, law enforcement bodies and courts;
• any person who introduces you to us;
• other organisations with whom we have alliances or arrangements for the purpose of promoting our respective products and services, and any agents used by us and our business partners in administering such an arrangement or alliance;
• anyone supplying goods or services to you in connection with a facility you have applied for;
• external payment systems operators;
• an organisation proposing to fund the acquisition of or acquire, any interest in any obligation you may owe us (whether under a loan, guarantee or security), that organisation’s agents, persons involved in assessing the risks and funding of the acquisition and, after acquisition, the purchaser and any manager;
• any person to the extent necessary, in our view, in order to carry out any instruction you give to us; or
• our related bodies corporate for the marketing of their products and services.

 

6. Overseas Disclosure

In some cases, we may disclose your information to organisations based outside of Australia in order to provide our services to you. We do this:

• where we have made a business decision to store our data with a trusted service provider who is in the business of providing data analytics, storage and processing services. Examples are those who store and process our email and mobile application data. These services commonly involve diverse geographic locations that change from time to time for reasons which include data protection and processing efficiency. Where these services are used by us, it is not practical for us to notify you which country your personal information may be located in;
• when our business which collected your personal information is in a different country to your location;
• when our supply to you necessarily involves overseas disclosures; and
• when you are involved with public liability issues concerning a product, we may disclose your personal information to any overseas supplier of such a product in the course of managing those issues

Wherever possible, we deal with such third parties who are bound by the provisions of the Act and APPs. If this is not possible, we will make every reasonable effort to verify that they would otherwise comply with the APP’s or we reasonably believe they are subject to laws or contractual obligations which effectively uphold the principles for the handling of personal information that are substantially similar to the APP’s.

 

7. Direct Marketing

From time to time, we will use the personal information we collect from you to inform you of products and services that we consider may be of interest to you. If you do not wish to receive direct marketing information you can tell us at any time by contacting our Privacy Officer or using the unsubscribe/opt-out function in the relevant electronic communication or on our website. We will endeavour to action your request within 20 calendar days.

 

8. Incorrect or Updated Information

We rely on the accuracy of the information you provide to us. If you believe or know that information, we hold about you is incorrect, out of date or incomplete, please contact us and we will make all reasonable efforts to correct the information.

 

9. Security and Storage of your Personal Information

We take all commercially reasonable precautions to protect your personal information and keep it secure. Personal information about your accounts and membership is only accessible by you and by those who are authorised to access it.
To prevent unauthorised access or disclosure we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
You acknowledge that the transmission and exchange of information is carried out at your own risk. We cannot guarantee the security of any information that you transmit to us or receive from us. Although we take reasonable measures to safeguard against unauthorised disclosures of information, we cannot assure you that personal information that we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy. We are not responsible or liable for the security of data sent via the internet.
Access to personal information is limited to our employees who specifically need it to carry out their business responsibilities. Our employees are obliged and trained to respect the confidentiality of any personal information held by us. We use encryption technology to safeguard your credit card data used in electronic transactions.
If you register with us or maintain an account, to help us protect your privacy, you should maintain the secrecy of any usernames and passwords you use to access and use our website should these be required.

 

10. Accessing your Personal Information

You may request access to the personal information we hold about you by contacting our Privacy Officer.

We will provide you with such access wherever possible and within a reasonable time.

We may apply a reasonable fee for such access, to cover our costs of meeting your request for access.

We ask that any request is stated as clearly as possible and adequately identifies the personal information you are seeking. We are not obliged to provide you access to personal information where:

• providing access would pose a serious and imminent threat to the life or health of any individual.
• providing access would have unreasonable impact on the privacy of other individuals.
• the request for access is frivolous or vexatious.
• the information sought relates to existing or anticipated legal proceedings between you and us and that information would not be accessible by the process of discovery in those proceedings.
• providing access would be unlawful.
• denying access is required or authorised by or under law.
• providing access would be likely to prejudice an investigation of possible unlawful activity.

If we deny your request for access, we will, where permitted by law, provide you with reasons for that denial.

 

11. Resolving Privacy Issues

If you believe we have failed to observe the privacy of your personal information, you can register your concern or complaint with our Privacy Officer so we have an opportunity to resolve the issue to your satisfaction. 

Our Privacy Officer will:

• listen to your concerns and grievances;
• discuss with you the ways in which we can remedy the situation; and 
• put in place an action plan to resolve your complaint and improve our information handling procedures if appropriate. 

We will consider any complaints and will aim to respond in writing within 30 days. Further Information about privacy concerns or complaints in Australia can be found on the Office of the Australian Privacy Commissioner’s (OAIC) website at www.oaic.gov.au.

 

12. How to Make a Compliant or an Enquiry

If you have any queries, requests for access or correction or complaints relating to the handling of your personal information, please contact our Privacy Officer by phone on +612 9675 8400 or email via privacyofficer@ilg.com.au.