- becoming a member;
- using our services including but not limited to receiving newsletters, educational development, information, maximisation of work and networking opportunities, marketing products by our members, representation of member interests in a variety of community activities;
- accessing, requesting information on, enquiring about, using, receiving or providing feedback in relation to our operations or services of Riverland Wine (online, in writing, by telephone or in person);
- attending our venues;
- seeking employment or becoming a business partner or affiliate with us; or
- otherwise providing, or consenting to the collection of, Personal Information by Riverland Wine, its officers, agents or employees, after this Policy has been brought to your attention, you acknowledge and consent to the use, collection, storage or disclosure of your Personal Information by us in accordance with this Policy and the Privacy Act.
1.3 If you do not agree to us handling your Personal Information in the manner set out in this Policy we will not be able to provide our services to you, and you should not provide us with any Personal Information.
1.4 Our Data Breach Policy forms part of this Policy and sets out our approach to any data breach.
2. What is Personal Information?
2.1 We follow the definition of Personal Information given in the Privacy Act:
“Personal Information means 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.”
3. What kinds of Personal Information might we collect and hold?
3.1 The Personal Information we may collect, hold and process about you depends upon how you interact with us. This information may vary depending on our specific needs of Riverland Wine; however, it may include your:
- name, address, email address, telephone number and other identification information;
- requests and information you input into our website to access our services;
- information about how you interact with us, our staff, members or associates online, including via social media;
- demographic information such as age or date of birth, location and activities;
- business relationship and history with us;
- business or associated companies or entities;
- messages, emails, voicemail and other correspondence and frequency of enquiries;
- comments and feedback and responses to surveys;
- interaction with websites, including our website;
- information about how you use our website;
- what computer configurations and software you use;
- your IP address and/or other device identifying data;
- general preferences and interests;
- billing and credit card information;
- other information required to provide a service or information you have requested from us;
- information collected by Cookies, Web Beacons and other technologies; and
- any additional information relating to you that you provide to us directly.
3.2 In some circumstances we may also be required to collect and hold Sensitive Information. According to the Privacy Act, Sensitive Information includes but is not limited to Personal Information, health, racial or ethnic origin, political opinions, membership of a political association, professional or trade association or trade union, religious beliefs or affiliations, philosophical beliefs, sexual orientation or practices, criminal record, biometric information that is to be used for certain purposes. We will generally only collect Sensitive Information if you have a medical incident at our venue, or if we are required to record your criminal record or association with outlawed organisations. In all cases, we will treat your Sensitive Information appropriately and with respect.
4. How do we collect Personal Information?
4.1 We collect Personal Information:
- directly from you for example, when you provide that information to us, we contact you or when you contact us;
- when conducting our activities and/or providing our services;
- when you participate in our activities including marketing or promotional activities;
- from our members and other related organisations, business partners or affiliates that we work with;
- from third parties who you have authorised to provide us with information; and
- from publicly available sources such as the internet and social media.
5. How do we hold and secure your Personal Information?
5.1 We store your Personal Information digitally and in hard copy (unless legally required to retain in hard copy format). All hard copy material is secured on-site at the Loxton Research Centre 1801 Bookpurnong Rd Loxton SA 5333.
5.2 All digital material is secured using password protected computers and databases. Any digital transfer of Personal Information is via secure channels such as HTTPS where possible, and user passwords are encrypted using a one-way hash.
5.3 Any database we manage is only accessible through a local network connection. All confidential documents are securely shredded by a third-party provider after storage is no longer necessary or required for our purposes.
5.4 We primarily use data storage providers located inside Australia. However, some data may potentially be stored overseas, most likely the United States, due to the use of third-party services from businesses that originate in the United States, such as Amazon Web Services. Where appropriate, Riverland Wine has agreements with its storage providers to keep all Personal Information they store secure, using reasonable and appropriate security methods.
5.5 We conduct regular audits of our compliance with this Policy and the Act to ensure that our privacy framework is in line with industry best-practice.
6. Why do we collect, hold, use and disclose Personal Information?
6.1 We collect Personal Information for a number of reasons, including:
- for the furtherance of our Mission and Vision so that the region’s wine industry remains adaptable, dynamic and competitive;
- conduct research in order to identify emerging markets as well as evaluate and respond effectively to market demand and trends;
- facilitate the growth of the region to help drive a profitable, dynamic and sustainable Riverland Wine Industry;
- providing you or a third party with our services or information about our services and activities;
- sending communications you request or contacting you and responding to your enquiries;
- providing third parties with information about you and your activities;
- cooperating with law enforcement bodies and government agencies where required by law or the terms of any relevant licence or industry code of practice;
- communicating with you and providing you with information about your membership with us;
- ensuring consistency of service across our business and other internal business purposes;
- developing or refining our services and activities as well as tailoring our services;
- notifying you about changes to our website, services, or activities we offer or provide via our website;
- internal business purposes;
- providing you with marketing material or contacting you in relation to our business, networking or promotional activities;
- publishing testimonials you provide us; and
- internal corporate purposes, corporate governance, auditing and record keeping.
6.2 Our use of Personal Information may extend beyond the uses described above in clause 6.1 but will be restricted to purposes that we consider to be related to our functions and activities.
7. What do we do with your Personal Information?
7.1 If we collect Personal Information, we may:
- use that information for the purposes stated in this Policy and directly related purposes;
- store that information in accordance with this Policy;
- pass that information amongst entities we work with, our members, associated organisations, business partners or affiliates;
- pass that information to third parties who provide products or services to us (including our accountants, auditors, lawyers, IT contractors, and other service providers); and
- provide that information to third parties as required or allowed by law.
8. Do you use my information for Direct Marketing?
8.1 We may use your Personal Information to communicate directly with you to promote our Mission and Vision.
8.2 We use direct marketing to provide you with information about our services and activities that we believe you may be interested in.
8.3 If you receive direct marketing material from us, and do not wish to continue receiving it, please contact us by any of the methods stated in this Policy, asking to be removed from all future direct marketing programs. Once we have received your opt-out request, we will remove you from our direct marketing programs as soon as reasonably practicable.
9. What about Cookies, pixels and analytics?
9.1 When you access our website or social media channels, or when you use our services and Products, we may receive information about you via automated methods, including (but not limited to) use of a ‘cookie’, a ‘pixel’ or from analytics software.
9.2 These are tools that our web server may direct your traffic to, send to your computer, or embed on a website when you visit our website. These tools help us provide services and products to you, and to recognise when you re-visit the website, serve you customised content and to optimise your experience.
9.3 We generally don’t collect Personal Information through the use of these tools, though we may be able to access your IP address and information about what your computer technology is when using analytical software.
9.4 You may be able to change the settings of your browser so that Cookies are not accepted generally or that you are provided with options to accept or reject them as they are sent to your browser.
10. Do we ever send your information overseas?
10.1 Riverland Wine is a South Australian based organisation. However, our data may be stored in the cloud (such as MS Outlook 365, Dropbox, Google Drive and Salesforce) which may be potentially be stored overseas, most likely in the United States of America. For more details, please refer to paragraph 5.4
10.2 We may upload images and/or footage to our social media accounts from time to time. The social media accounts and website may be hosted on an overseas server. Where applicable, in the event that your information is sent overseas, we will use our best endeavours to ensure that any overseas supplier will keep all Personal Information secure.
11. Can you access your Personal Information or request it be corrected?
11.1 You may request access to the Personal Information that we hold about you by contacting us. Upon receiving an access request, we may request further details from you to verify your identity.
11.2 We reserve the right not to provide you with access to Personal Information if we cannot verify your identity to our reasonable satisfaction. An administrative fee may be charged to cover our costs in providing you with access to your Personal Information. This fee will be explained to you before it has been incurred.
11.3 We will respond to your access request within a reasonable period of time by (a) providing you with access to your Personal Information; (b) rejecting your access request, and providing you reasons for this rejection.
11.4 Access requests may be denied where:(a) we believe your request is frivolous or vexatious; (b) we are entitled to reject a request by law; (c) we are unable to verify your identity, or (d) you have not paid the administrative fee (if any).
11.5 If you believe that the Personal Information that we hold is inaccurate or otherwise requires correction, you may send us a correction request by contacting us. We will review your Personal Information and respond to the request within a reasonable period of time.
12. Sensitive Information
We will only keep your Sensitive Information whilst you consent to us doing so, or if we are required to by law or to protect a legal right. If you want us to delete your Sensitive Information, you may request we do so in writing. This may, however, limit our ability to serve and assist you.
13. What happens if you want to deal with us anonymously or using a pseudonym?
When contacting us, you can do so either anonymously or by using a pseudonym. If you do so, we may not be able to provide you with accurate or useful information, and you may not be able to access a full range of our services. Further, we may not be able to investigate incidents or complaints you have made.
14. Does this Policy ever change?
15. What happens if you have a question or complaint about how we have handled your Personal Information?
15.1 If you have a question or complaint, you can raise it with us by:
Email: email@example.com; or Post: Executive Chairperson
Loxton Research Centre 1801 Bookpurnong Road LOXTON SA 5333
15.2 We take all complaints seriously and will respond to you within a reasonable period of time, usually 30 days, unless we consider your complaint to be frivolous or vexatious or if we are unable to verify your identity.
15.3 If you are not satisfied with the way we have handled your complaint, you can make a complaint to the Office of the Australian Information Commissioner at http://oaic.gov.au.