This privacy policy (the Policy) sets out in accordance with the Privacy Act 1988 (Cth) (the Privacy Act) the way in which The Australian Wine Research Institute Limited (ACN 007 558 296), Wine Australia (ABN 89 636 749 924) and Australian Grape and Wine (ABN 45 903 873 163) (together Sustainable Winegrowing Australia, we, us, or our) may collect, store, use, manage and protect your Personal Information. It contains the broad privacy framework within which we operate, and should be read in conjunction with any supplementary privacy policies and implementation procedures that we introduce or vary from time to time.
By:
a. using this website and/or the Sustainable Winegrowing Australia member website;
b. accessing, requesting, enquiring about, or purchasing Sustainable Winegrowing Australia products and services (either online or in person); or
c. providing Personal Information to Sustainable Winegrowing Australia, its officers, agents or employees,
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.
you do not agree to us handling your Personal Information in the manner set out in this Policy you must immediately cease to access this website or our products and services, and you should not provide us with any of your Personal Information.
1. What is Personal Information?
Personal information is information or an opinion that identifies you, or from which your identity can be reasonably ascertained (irrespective of whether the information or opinion is true or not, and regardless of whatever form it is recorded in).
2. What is Sensitive Information?
Sensitive Information is any Personal Information that is about your:
a. health, treatments or other medical needs
b. race, ethnicity or religion
c. genetics and biometrics
d. political opinions
e. philosophical beliefs
f. professional, trade or political affiliations and memberships
g. criminal record or
h. sexuality.
3. What kinds of Personal Information might we collect and hold?
We may collect (and hold) different Personal Information from you depending upon how you interact with us.
If you access our website, we may collect information about how you have used our website.
If you contact us, we may collect your full name, address, e-mail address, phone number or contact details.
Depending upon how you interact with us, we may also collect information about:
a. what services you are requesting or enquiring about
b. your demographic
c. your interests
d. your bank account details
e. questions and answers that you have exchanged with us
f. your purchases of products and services related to our activities
g. your location
h. the technology you use to access our services and
i. how and when you use our services
j. your technical ability.
We do not usually collect or retain Sensitive Information, unless you consent to the collection and the information is reasonably necessary for our business. By providing us with any Sensitive Information, you hereby consent to us using that information in any of the ways, and for any of the purposes, described in this Policy.
4. How do we collect Personal Information?
We collect Personal Information:
a. directly from you – when we contact you, when you contact us, when you visit our offices, when you visit our website or the Sustainable Winegrowing Australia member website, when you post about us on social media, when you complete a survey, enquire about a service, receive a service, attend an event organised by us or where you provide consent.
b. from third parties who you have authorised to provide us with information; and
c. publicly available information and databases.
5. How do we hold and secure your Personal Information?
We store your Personal Information in hard copy format and digitally, on site. We also engage third party information technology/cloud service providers to assist us with the storage of our data and to administer our internal operations. We take reasonable care to ensure that your Personal Information is kept securely and disposed of when it is no longer necessary to retain it to fulfil the purposes for which the information was collected, or as required by law. To help protect the privacy of data and Personal Information collected and held, we maintain physical, technical and administrative safeguards. Security technology is updated and tested on an ongoing basis, however, no data transmission over the internet can be guaranteed as totally secure. Our employees sign confidentiality agreements on commencement of their employment. Access to the Personal Information is restricted to employees who need it to provide services or to conduct our business. To the extent permitted by law, we accept no responsibility for unauthorised access of Personal Information held by us. However, in the event of any such unauthorised access and/or disclosure, we comply with our obligations under the Privacy Act in dealing with any such unauthorised access and/or disclosure, including any obligations in respect of eligible data breaches within the meaning of the Privacy Act.
6. Why do we collect, hold, use and disclose Personal Information?
We may collect Personal Information for a number of reasons, including but not limited to:
a. offering services to you;
b. providing you, or the organisation you represent, with products or services,
c. providing you with information about our products or services;
d. developing, improving or refining products or services;
e. internal business purposes;
f. providing you with marketing material;
g. contacting you in relation to our business activities;
h. better understanding our clients and customers;
i. tailoring our marketing, services, promotions and operations;
j. any purposes authorised by law;
k. any purpose disclosed to or authorised by you;
l. any purposes that you may reasonably expect; and
m. corporate governance, auditing, record keeping and maintaining registers.
If we collect Personal Information for a specific purpose, we will not use this information for other purposes unless those purposes are allowed by the Australian Privacy Principles (APPs) (under the Privacy Act). If we collect Personal Information for a non-specific purpose, our use of this information may extend beyond the uses in clause 7 of this Policy, but will be restricted to purposes that we reasonably consider to be related to our functions and activities.
7. What do we do with your Personal Information?
If we collect Personal Information from you, we may:
a. use that information to identify you and verify your identity and financial information;
b. use that information for any of the purposes in clause 6 of this Policy;
c. provide a problem-solving service to you;
d. provide an email service to you;
e. send out survey forms to you or conduct phone surveys regarding our services;
f. use that information for accounting purposes;
g. use that information to consult with stakeholders on services;
h. use that information to respond to access to information requests;
i. use that information to communicate with the public, stakeholders, staff members and government agencies;
j. store that information in accordance with this Policy;
k. pass that information amongst our employees, as well as entities, contractors or consultants and government agencies and entities we work with, including our related parties;
l. pass that information to third parties who provide products or services to us (including our accountants, auditors, lawyers, IT contractors, cloud service providers and other service providers);
m. provide that information to third parties as required by law;
n. if the information is provided to us online, provide that information to third parties for the sole purpose of processing the online information provided;
o. provide that information to third parties, but only where this is reasonable to facilitate the conduct of our business and you would reasonably expect us to provide that information; and
p. provide that information to third parties where you have consented to this.
There are also a limited number of circumstances in which the Privacy Act permits the use or disclosure of your Personal Information without your consent. An example of this is where the use or disclosure is necessary to prevent a serious and imminent threat to any person’s life, health or safety or a serious threat to public health or safety.
We will take reasonable care to ensure that Personal Information is kept accurately, and is complete and up-to-date.
8. Do you use my information for Direct Marketing?
We may use your Personal Information to communicate directly with you to promote a product or service (Direct Marketing). We use Direct Marketing to provide you with information about products or services that we believe you may be interested in. If you receive Direct Marketing material from us, and do not wish to continue receiving it, please contact us by any of the methods set out in paragraph 14 below, 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?
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. A cookie helps us to recognise when you re-visit the website, and to optimise your experience. We do not collect any Personal Information from you when you use cookies on our website.
Additionally, our website may contain links to enable visitors to visit another website easily. However, once that link is used, the visitor leaves the Sustainable Winegrowing Australia website. Please note that we do not have any control over any other websites. Therefore, we cannot be responsible for the protection and privacy of any information provided whilst visiting such sites and such sites are not governed by this Policy. Please exercise caution and look at the privacy statement applicable to the website in question before sharing Personal Information.
10. Do we ever send your information overseas?
We may disclose your Personal Information to overseas entities who provide cloud data storage services to us. We may also need to disclose your Personal Information to other overseas entities in different countries from time to time. We will not provide your Personal Information to any overseas entities unless we have informed you and specified the overseas countries to which disclosure will occur (where reasonably practicable).
11. Can you access your Personal Information or request it be corrected?
a. This Policy is available on our website, sustainablewinegrowing.com.au. You may also request a copy of this Policy from our Privacy Officer.
b. You may request access to the Personal Information that we hold about you by contacting us by any of the methods as set out in paragraph 14, below (an Access Request).
c. Upon receiving an Access Request we may request further details from you to verify your identity. We reserve the right not to provide you with access to Personal Information if we cannot verify your identity to our reasonable satisfaction.
d. An administrative fee may be charged to cover our costs in providing you with access to your Personal Information once we receive your Access Request. This fee will be explained to you before it has been incurred (if applicable).
e. We undertake to respond to your Access Request within 30 days by:
i. providing you with access to your Personal Information; or
ii. rejecting your Access Request, and providing you with reasons for this rejection.
f. If the Access Request will take longer than 30 days to resolve, we will provide you with an expected response date.
g. Access Requests may be denied where:
i. we believe your request is frivolous or vexatious;
ii. we are entitled to reject it by law;
iii. we are unable to verify your identity; or
iv. you have not paid the administrative fees referred to in paragraph 11d, above.
h. If you believe that the Personal Information that we hold is inaccurate, incomplete, misleading, not up-to-date, not relevant or otherwise requires correction, you may send us a Correction Request by contacting us by any of the methods as set out in paragraph 14, below. We may request further details from you to verify your identity. We reserve the right not to grant your Correction Request if we cannot verify your identity to our reasonable satisfaction. After receiving your Correction Request and verifying your identity, we will review your Personal Information and promptly correct any information found to be incorrect.
i. The Correction Request service is free of charge and we undertake to respond to your Correction Request within 30 days. If the Correction Request will take longer than 30 days to resolve, we will provide you with an expected response date.
12. What happens if you want to deal with us anonymously or using a pseudonym?
You can deal with us either anonymously or by using a pseudonym if you choose. If, however, you do so we may not be able to provide you with accurate or useful information or our full range of products and services, and we may not be able to handle your inquiry appropriately.
13. Does this Policy ever change?
From time to time we may make changes to this Policy so you should check it each time you visit our website to keep up to date on any changes. The date of the most recent revisions will appear at the bottom of this Privacy Policy. If you do not agree with the applicable version at the time of using our services, please do not continue to use our services. If you do continue to use our communication platforms, you accept the terms of our updated Privacy Policy. If material changes are made to our Privacy Policy we will notify you by placing a notice on our website.
14. What happens if you have a question or complaint about how we have handled your Personal Information?
If you have a question or complaint, you can raise it with us by:
Emailing: enquiries@awri.com.au
Calling us on: (08) 8313 6600
Faxing us on: (08) 8313 6601
Sending a letter to:
The Privacy Officer
The Australian Wine Research Institute Ltd
PO BOX 197
Glen Osmond SA 5064
We take all complaints seriously and will respond to you within a reasonable period of time, unless we consider your complaint to be frivolous or vexatious.
If you aren’t 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
Review date: February 2024
Last updated: February 2021
Review by: AWRI
Approved by: Joint Steering Committee