Privacy Policy

1. Who does this Privacy Policy apply to?
This Privacy Policy (Policy) applies to Whiteley Ventures Pty Ltd ABN 82 639 667 324 trading as Seadrift Distillery (we or us) and the entities we own or control. Where we are providing services to you, this Policy should be read in conjunction with any agreement under which you engaged us to provide services to you, which in the event of any inconsistency, takes precedence over this Policy. We want you to know that we are committed to protecting your privacy and handling your personal information in an open and transparent way.

2. What does this Privacy Policy cover?
This Policy explains how we collect, handle, store and protect personal information when: (a) we provide services to our customers; (b) people use our websites or otherwise provide information to us; and (c) we perform any other activities that form part of the operation of our business.

3. What laws apply to us?
When handling personal information, we will comply with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (Aust Privacy Act). We will also comply with data protection laws of other jurisdictions, such as the European General Data Protection Regulation. We take our obligations under the Aust Privacy Act including the APPs, the NZ Privacy Act and other applicable data protection laws seriously.

4. What personal information do we collect?
Personal Information is information or an opinion that identifies an individual. Examples of Personal Information we collect include: name, gender, address, email address, phone numbers, social media details and account details. We may collect personal information in the following ways:
(a) directly from our customers to enable us to deliver products, services and events to them.
(b) when performing other activities that form part of the operation of our business, but which do not directly form part of providing services to our customers;
(c) from users interacting with our websites including by use of cookies, web beacons and other web-based technologies; and
(d) from suppliers, contractors and third-party service providers that we engage to help us operate our business.

5. What sensitive information do we collect?
Sensitive information is defined in the Aust Privacy Act to include information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information. We do not collect sensitive information.

6. How we use personal information?
We use the personal information that we collect as permitted by this Privacy Policy for the following reasons:
(a) to provide products and services to our customers;
(b) in undertaking marketing and research with our customers and other people;
(c) to seek feedback on our services;
(d) to manage, improve and tailor user experience on our websites;
(e) to facilitate our internal and external business processes including financial operations and reporting; and
(f) for such secondary purposes that are closely related to the purposes above in circumstances where you would reasonably expect such use or disclosure.

We do not use personal information for any other purposes unless it is necessary to comply with a legal right or duty.

7. When will we disclose your personal information?
We will only disclose your personal information as set out below. Importantly, we will never disclose or sell your personal information to third parties for advertising purposes, or for any other purpose without your authorisation.

We may disclose personal information to: (a) other entities that we own or control; (b) third parties where you consent to the use or disclosure; and (c) third parties that we engage to assist us in providing services to our customers or in the operation of our business (for example our subcontractors, advisors and suppliers). We may also be required to disclose personal information when required by law. We may share non-personal, de-identified and aggregated information with third parties for several purposes, including data analytics, research, submissions, thought leadership and promotional purposes.

8. Transfer of personal information outside Australia
We may store personal information within services provided by offshore cloud service providers. Some of the recipients of your personal information referenced above may be based in countries or regions outside of Australia. Accordingly, any personal information that is collected may be transferred to countries or regions with privacy laws that are different from the privacy laws that apply to this Policy. We will ensure that any such transfer of personal information will only be undertaken in compliance with our legal obligations. Please note that there are various online applications or services that allow you to share content with other users that may be linked to our websites or directed to you by means. Importantly, any personal information that you contribute to these services and applications can be read, collected and used by other users. We have little or no control over these other users and, therefore, we cannot guarantee that any information that you contribute will be handled in accordance with this Policy.

9. Security of personal information
Your personal information is stored in a manner that reasonably protects it from misuse and loss and from unauthorized access, modification or disclosure. We hold personal information in hard copy and electronic formats. We use a range of physical, operational and technological security measures to protect this information.

10. Access to, or correction of, your personal information
You may access your personal information or seek to have that information corrected if you believe that it is incorrect, at any time. If you wish to make any changes to your personal information, you may contact us by emailing the Privacy Officer at carolyn@seadriftdistillery.com . To protect your personal information, we may require identification from you before releasing the requested information.

11. How to lodge a complaint if you think your information has been mishandled
If you have any questions or concerns regarding your privacy, or if you would like to make a complaint, please contact the Privacy Officer at: Privacy Seadrift Distillery 1/12 Sydenham Rd, Brookvale, NSW, 2100. We take all the privacy complaints we receive seriously. We will acknowledge the receipt of a complaint and will work with you to resolve it. If you would like more information about our process for handling complaints, please contact the Privacy Officer above.

12. Breach notification
If there is a breach of privacy involving your personal information, we will comply with any legal obligations in the Aust Privacy Act.

13. Where can I find out more about my privacy rights?
For further information about privacy and the protection of privacy the Office of Australian Information Commissioner’s website at www.oaic.gov.au.

14. Policy Updates:
This Policy may change from time to time and is available on our website. Therefore, we encourage you to periodically review this Policy to be informed about how we are protecting your information. This Policy was last updated July 2021.
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