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Brown Brothers Milawa Vineyard Pty Ltd, ABN 56 005 349 235 and its associated entities (collectively known as Brown Family Wine Group, or BFWG, we, us, or our) is committed to protecting the privacy of individuals’ personal information. BFWG recognises the trust you place in us through your dealings across our various platforms and brands, and we do everything we can to maintain that trust and we will only use your personal information in a manner consistent with this policy.
What is personal information?
“Personal information” is information or an opinion about an identified person, or information from which a person could reasonably be identified. That is regardless of whether the information or opinion is true, and whether or not it is stored in a material or intangible/electronic form.
We do not collect “sensitive information” without your consent. When we refer to “sensitive information” we mean information about a person’s racial or ethnic origin, political opinions, religious beliefs or affiliations, philosophical beliefs, political, professional, trade association or trade union memberships, sexual orientation or practices, criminal records, or health, genetic or biometric information or templates.
COLLECTION OF PERSONAL INFORMATION
From whom do we collect your personal information?
While we endeavour to only collect personal information directly from you (for example, this may occur when we contact you, enter into contracts or arrangements with you, when you attend events arranged or sponsored by us, visit our websites, cellar doors or wineries, when you purchase our products, when you use our free Wi-Fi networks, when you post about us on social media or when you enter a competition), we may also collect your personal information from the following sources that you may be unaware of:
What types of personal information do we collect?
Depending on how you interact with us, we may collect the following personal information from you:
Contact details – if you contact us or use our free Wi-Fi networks, we may collect details which include your name, street/postal address, email address, social media handles, and telephone number.
Member details – if you submit a membership application form and/or subsequently interact with us, such as through our website, by email or at member events, we may collect your abovementioned contact details, government identifiers (such as your driver’s licence number), demographic (age, gender, vocation, educational history), interests and our history of interactions or dealings with you.
Member surveys – we may collect details about a range of issues relating to your interest in wines, such as wine preferences, qualities sought in a wine, purchase locations and feedback on our activities.
Visitor information, images and videos – if you visit our cellar doors, restaurants, wineries and hosted events (e.g., wine and food festivals or dining functions) we may collect your abovementioned contact details, reservation details when making bookings, as well as travel details provided when you visit as a member of a tour group. From time-to-time we will collect photographs and video footage of visitors.
Restaurant diner information – if you dine at our restaurants, we may collect your abovementioned contact details, reservation details when making bookings, travel details and meal preferences. For larger bookings and functions, we may also collect credit card details.
Customer sales information – when you purchase goods or services from us, whether in person or through our website, we may collect your abovementioned contact details, demographic and items purchased. We may also collect your credit card details or banking details in order to procure payment for goods or services you request, however such financial information will be treated in a different manner to the rest of your personal information, as detailed below.
Competition entrant details – if you enter our competitions, we may collect your abovementioned contact details.
Acquisition of other businesses – if we acquire the assets or shares of another business to whom you have disclosed your personal information, such transactions generally involve the disclosure of personal information from the vendor organisation to BFWG, either as part of the due diligence process or as a result of a transfer of assets. In such instances, BFWG collects the personal information held by the newly acquired business.
If you attend any of our sites, facilities or offices (such as our cellar doors, restaurants, wineries, vineyards or bottling or packaging facilities), we may use closed-circuit television cameras and other photographic equipment to record:
Unsolicited personal information
If we receive unsolicited personal information, we will assess whether we would have been entitled to collect that personal information. If we would not have been entitled to collect that personal information, we will destroy or de-identify it as soon as practicable (provided that it is lawful and reasonable to do so).
We collect personal information when individuals communicate with, or purchase products from, us through our website, such as contact details, items purchased, credit card details and other information you choose to provide. Payment details provided through our website are processed through a secure server.
When you access our website, we may receive information about you via a ‘cookie’. A cookie is a piece of information that our web server may send to your computer when you visit the website. The cookie is stored on your machine, but does not identify you or give us any information about your computer, so is not personally identifiable information under current Australia law, although it may be in other jurisdictions. A cookie helps us to recognise when you re-visit the website, and helps us to optimise your experience, troubleshoot any problems and better serve content. Through the use of sessional cookies, we collect information such as Internet Protocol ‘IP’ addresses, device IDs, MAC addresses, browser information, installed software, hardware type, access date and time, number of visitors, pages viewed, types of transactions conducted, time spent on the website and documents downloaded. We use this information to evaluate the performance and effectiveness of our website. With most internet browsers, you can erase cookies from your computer hard drive, block all cookies, or receive a warning before a cookie is stored. If you wish to do this, refer to your browser instructions or help screen to learn more.
STORAGE AND SECURITY OF PERSONAL INFORMATION
How do we secure your personal information?
Storage of personal information
Transfer of information outside of Australia
Personal information may be stored and managed by systems, services and third-party platforms (including cloud-based service providers) located outside of Australia. To assist BFWG to store and access your personal information on the Cloud, we may store your personal information with, or allow it to be accessed by, overseas third parties who provide:
If you proceed to submit your personal information to us, you are consenting to the transmission, disclosure, storage, and access of your personal information by third parties in overseas jurisdictions. In that respect, Australian Privacy Principle 8 which ordinarily obliges BFWG to take reasonable steps to ensure that overseas recipients of your information do not breach the Australian Privacy Principles (except Principle 1) will not apply.
Please note that if any of those overseas recipients handle your personal information in a manner which is inconsistent, or does not comply, with the Australian Privacy Principles:
DISCLOSURE OF PERSONAL INFORMATION
We may disclose your personal information to third parties in limited circumstances:
USE OF PERSONAL INFORMATION
How do we use your personal information?
We may use your personal information for the reasons we collected it and for other reasonable business purposes, which may include:
We will never sell or disclose your credit card, financial or personal information to third parties.
Do we use your personal information to conduct direct marketing?
We send to our customers, potential customers, members’ and persons who access our free Wi-Fi networks, information about our products and services that we consider may be of interest. We also engage third parties to undertake those activities. These communications are sent in various forms, including mail, SMS and email. Where a person has indicated a preference in regards to a method of communication, we endeavour to use that method whenever it is practicable to do so. You can opt-out of receiving marketing communications at any time by lodging a request with our Privacy Officer (details below) or by using opt-out facilities provided in marketing communications. Once we have received your opt-out request, we will remove you from our direct marketing programs as soon as reasonably practicable. We do not trade in, rent, or sell your personal information to other parties under any circumstances.
ACCESS TO, AND CORRECTION OF, PERSONAL INFORMATION
How can you access and correct your personal information?
You may request access to your personal information held by BFWG by sending a written request to our Privacy Officer (details below). Upon receiving an access request, we may request further details from you in order to verify your identity. We reserve the right to refuse access to personal information if we cannot verify your identity to our reasonable satisfaction. This information will generally be provided in an appropriate form within 30 days, except where law allows us to refuse your request, in which case we will provide reasons why we have refused. We may charge a fee for providing access if it requires a significant amount of time to locate your information or to collate or present it in an appropriate form. This fee will be explained to you before it has been incurred. In limited circumstances, and only where it is permitted under the Privacy Act, we may not be able to provide access to information: for example, where it would have an unreasonable impact upon the privacy of others or where we believe your request is frivolous or vexatious.
We will take reasonable steps to ensure personal information we collect, and use is accurate, up-to-date and complete. Where personal information we hold about you is out-of-date, incomplete, or incorrect, please write or email use as soon as possible and we will promptly correct any information accordingly.
EU and California residents also have the following additional rights:
Dealing with us anonymously or using a pseudonym
You can deal with us anonymously or by using a pseudonym if you choose. However, if you do so we may be unable to provide you with accurate or useful information and (in some circumstances) you may not be able to access a full range of our products and services. For example, we may not be able to process your request, sell you alcoholic beverages, provide a definitive response, assess your eligibility for events, offers or promotions, or we may need to ask you further questions and require more time to respond.
Privacy concerns or complaints
If you have any queries or concerns about your personal information or would like to make a privacy or personal information related complaint, please contact our Privacy Officer for assistance (details below). We will treat your complaint confidentially and we take all complaints seriously. We aim to ensure we contact you and that your complaint is resolved within a reasonable period of time, or the time required by the Privacy Act.
If a privacy concern or complaint is not resolved to your satisfaction, you can contact the Office of the Australian Information Commissioner or the local regulator in your jurisdiction in Europe or California, as applicable.
You can contact us at the following address:
Brown Brothers Milawa Vineyard Pty Ltd
239 Milawa Bobinawarrah Road, Milawa, Victoria, 3678, Australia
Phone: +61 (0)3 5720 5500
Facsimile: +61 (0)3 5720 5511
Last updated: – May 2023.