In collecting, holding, using, disclosing and otherwise managing your personal information, NWWD will comply with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles in the Privacy Act.
Kinds of personal information collected
Personal information is information or an opinion about an identified, or reasonably identifiable, individual. During the provision of our goods and services or as a result of our other interactions or dealings with you, NWWD may collect your personal information.
The kinds of personal information that NWWD collects will vary depending on our particular interaction or dealing with you. However, generally speaking, the kinds of personal information NWWD collects may include:
(a) contact and identification information such as your name, address, telephone number, email address and date of birth;
(b) where you purchase whisky or other products or merchandise from us:
(i) information relevant to that transaction, such as the delivery address, any delivery instructions and payment/invoicing related information; and
(ii) information regarding your purchasing history with NWWD or your other dealings with NWWD in relation to our whisky or other products or merchandise;
(c) where you apply for employment with NWWD (in addition to contact and identification information detailed above) information relevant to us considering your application for employment including information in relation to your CV, employment history, qualifications and references.
We also collect internet/technology related information from visitors to our site or users of our other online services, including the referring URL, your IP address, which browser you used to come to the site, the country, state or province, the pages of our site that you viewed during your visit and any search terms entered on our site.
Generally, we do not collect sensitive information about individuals. If we do need to collect sensitive information about you, we will only do so with your consent or where we are required to do so by law. Information about your health, racial or ethnic origin, political persuasions, criminal record and religious or philosophical beliefs are all examples of sensitive information.
If you are not of legal age to purchase alcohol in the jurisdiction in which you reside, then you should not provide your personal information to us.
Collection of personal information by NWWD
Generally, NWWD collects your personal information directly from you. For example, NWWD may collect your personal information:
(a) when you register with us (including where you register as a Starward member), create an online account profile, fill out a survey, enter a promotion (including contests, sweepstakes and rebates), request services or otherwise provide us with your details;
(b) where you use our websites or other online services or otherwise interact or communicate with us (including by email);
(c) if you post information to any of our social media sites;
(d) where you order or purchase whisky or other products or merchandise from us;
(e) where you join our mailing list;
(f) where you attend an event organised or sponsored by us; or
(g) where you apply for or express an interest in employment with us.
There may be occasions when NWWD collects your personal information from someone other than you, for example:
(a) the distributors or retailers of our whisky and our other products;
(b) an information services provider;
(c) from third party marketing databases or marketing lists;
(d) from third parties that organise events for NWWD, collaborate with NWWD in relation to the running of events or conduct events sponsored by NWWD;
(e) a publicly maintained record or other publicly available sources of information including social media and similar websites; or
(f) a referee or previous employer where you apply for employment with NWWD.
Generally, NWWD will only collect your personal information from sources other than you if it is unreasonable or impracticable to collect that personal information from you.
Purposes for which personal information is used
Generally speaking, NWWD collects and uses personal information so that we can develop, improve, promote and sell our whisky and related products and services and conduct our business as a whisky distiller and supplier.
Some examples of the purposes for which NWWD collects, holds, uses and discloses your personal information include to:
(a) enable us to supply you with information you request from us;
(b) supply whisky or other products or merchandise you order from us from time to time;
(c) conduct promotions, competitions, giveaways and events;
(d) contact you to obtain your feedback regarding our products or service or to conduct other market research;
(e) undertake direct marketing (as detailed in paragraph 5 below);
(f) contact you regarding promotions, competitions, giveaways, events or new products or services of NWWD that we consider may be on interest to you;
(g) analyse information we collect so that we can administer, support and improve and develop our business and the products and services we offer;
(h) comply with the obligations of NWWD under any applicable laws; and
(i) consider any application you make for employment with us.
In addition to the purposes listed above, NWWD may use your personal information for other purposes which we notify you of when we collect the information and for other purposes otherwise permitted or required by law.
Where personal information is used or disclosed, NWWD takes steps reasonable in the circumstances to ensure it is relevant to the purpose for which it is to be used or disclosed. You are under no obligation to provide your personal information to NWWD. However, without certain information from you, NWWD may not be able to provide products, services or information to you or may be limited in how we can interact with you.
Disclosure of personal information
(a) related companies of NWWD;
(b) our service providers and contractors and other third parties that provide products or services to us (including our technology service providers, logistics or order fulfilment service providers or other business or administration service providers);
(c) people or entities considering acquiring an interest in NWWD’s business or assets;
(d) third parties who have invested in or acquired an interest in NWWD or manage an investment in NWWD;
(e) NWWD’s professional advisors; and
(f) NWWD’s insurance providers.
NWWD may also disclose your personal information for other purposes if we notify you of the disclosure at or about the time of collecting the information, we have otherwise received your consent or if the disclosure is required or authorised by law.
If you post information or other content to public sections of our websites or to our social media sites, you acknowledge that the information or content may be viewed by the public and/or users of the relevant website or social media site.
Some of the parties that NWWD discloses your personal information to may be located outside Australia, including technology service providers located in the United States of America and Singapore and companies incorporated overseas that own or manage an investment in NWWD (which may include companies incorporated in England and Wales or other jurisdictions).
We take reasonable steps to ensure that any such overseas recipients do not hold, use or disclose your personal information in a way that is inconsistent with the obligations imposed under the Privacy Act and the Australian Privacy Principles in the Privacy Act.
Links to other websites
Security of personal information
NWWD takes steps reasonable in the circumstances to ensure that the personal information it holds is protected from misuse, interference and loss and from unauthorised access, modification or disclosure.
Your personal information will be kept on databases held on servers kept in a physically and technologically secured environment, accessed only by authorised personnel or contractors. Where personal information is held in hard copy, it will be held in controlled, access restricted premises which only authorised personnel or contractors will be permitted to access.
NWWD will destroy or de-identify personal information in circumstances where it is no longer required, unless NWWD is otherwise required or authorised by law to retain the information.
Where you are a Starward member or have another online account with us, you are responsible for maintaining the confidentiality of your user name and password. You shall be responsible for all uses of your membership, whether or not authorized by you. You agree to immediately notify NWWD of any unauthorized use of your user name or password.
Access and correction
NWWD takes steps reasonable in the circumstances to ensure personal information it holds is accurate, up-to-date, complete, relevant and not misleading.
Where you register with us as a Starward member or have another online account with us, you can update your personal information by logging into your account and editing your profile.
In addition, under the Privacy Act, you have a right to seek access to and correction of your personal information that is collected and held by NWWD. If at any time you would like to access or correct the personal information that NWWD holds about you, or you would like more information on NWWD’s approach to privacy, please contact the NWWD Privacy Manager using the details set out in paragraph 12 below. NWWD will grant access to the extent required or authorised by the Privacy Act or other law and take steps reasonable in the circumstances to correct personal information where necessary and appropriate.
To obtain access to your personal information:
(a) you will have to provide proof of identity to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected;
(b) NWWD requests that you be reasonably specific about the information you require; and
(c) NWWD may charge you a reasonable administration fee, which reflects and will not exceed the cost to NWWD for providing access in accordance with your request.
NWWD will endeavour to respond to your request to access or correct your personal information within 30 days from your request. If NWWD refuses your request to access or correct your personal information, NWWD will provide you with written reasons for the refusal and details of complaint mechanisms.
If you are dissatisfied with NWWD’s refusal to grant access to, or correct, your personal information, you may make a complaint to the Office of the Australian Information Commissioner.
For further information or enquiries regarding your personal information, or if you would like to opt-out of receiving any promotional or marketing communications or make a privacy complaint, please contact NWWD’s Privacy Manager using any of the following contact details:
Post: 50 Bertie Street, Port Melbourne, Victoria, 3207
Phone: (+61) 3 9005 4420.
Please direct all privacy complaints to NWWD’s Privacy Manager. At all times, privacy complaints:
(a) will be treated seriously;
(b) will be dealt with promptly;
(c) will be dealt with in a confidential manner; and
(d) will not affect your existing obligations or affect the commercial arrangements between you and NWWD.
NWWD will acknowledge your complaint within 7 days of receipt and endeavour to resolve it within 30 days, unless NWWD informs you otherwise and seeks your agreement in writing.
NWWD’s Privacy Manager will commence an investigation into your complaint. You will be informed of the outcome of your complaint following completion of the investigation. In the event that you are dissatisfied with the outcome of your complaint, or an extension to the time in which NWWD will resolve it, you may refer the complaint to the Office of the Australian Information Commissioner.