1. Who is collecting your personal information?
The Site is operated by the Liquor Marketing Group (ACN 001 440 320) (LMG) for the benefit of independent liquor stores operating under LMG's "Bottlemart", "Harry Brown" or "SipnSave" brands (Stores).
(a) LMG is the operator of the Site and provides the online platform that allows you to place orders with Stores who are users of the platform;
(c) when you place an order with a Store through the Site, LMG's online platform will provide your order (together with your details) to the relevant Store so that your order can be fulfilled; and
(d) Stores may also have access to records of past orders and other customer details through the online platform.
2. How your personal information is collected
We will collect and hold your personal information in a fair and lawful manner, and not in an intrusive way. Where it is reasonably practical to do so, we will collect your personal information directly from you. We may collect the personal information you directly give us through some of the following means:
(a) when you use the Site (including by making an inquiry or order in relation to goods or services);
(b) in administering and performing any contracts with service providers;
(c) when you contact us via telephone or facsimile;
(d) from correspondence (whether in writing or electronically);
(e) through any other mobile applications provided by our organisation;
(f) while conducting customer satisfaction and market research surveys;
(g) when administering any of our services; and
(h) as otherwise required to manage our business.
In certain cases we may collect personal information from publicly available sources and third parties, such as suppliers, contractors, our clients and business partners.
3. Types of personal information we collect
The type of personal information we may collect can include (but is not limited to), your name, date of birth (to manage age restrictions), postal address, email address, phone numbers and billing information (such as credit card details and the transaction details of your order).
The Site may also automatically collect certain usage data and log information about your use of the Site (e.g. IP address data). Please refer to section 7 for further details.
Where you do not wish to provide us with your personal information, we may not be able to provide you with requested goods or services.
4. Our purposes for handling your personal information, and how we may disclose your personal information
As a general rule, we only process personal information for purposes that are reasonably necessary for our business functions or activities (including the operation of the Site). In general, we collect, hold, use and disclose the personal information that we collect through the Site to:
(a) offer and provide you with our goods and services (including by processing orders that you submit through the Site);
(b) manage and administer those goods and services, including account keeping procedures;
(c) engage our delivery service partners to deliver your order;
(d) engage our payment processing service providers to process the payments you make through the Site;
(e) optimise the Site for you and other users;
(f) communicate with you, including (but not limited to), emailing you tax invoices, dispatch and tracking information, returns and exchange authorisations;
(g) manage the security and integrity of the Site (including by conducting identity verification and fraud detection activities);
(h) comply with our legal and regulatory obligations; and
(i) otherwise to manage our business.
We will not use or disclose your personal information for any other purpose unless you have consented to that use or disclosure, or the disclosure is otherwise permitted under the Privacy Act.
We may disclose personal information between our organisations or to third parties such as our delivery service partners, payment processing service providers, suppliers, organisations that provide us with technical and support services, or our professional advisors, where permitted by the Privacy Act. If we disclose information to a third party, we generally require that the third party protect your information to the same extent that we do.
5. Protection of personal information
We will hold personal information as either secure physical records, electronically on our intranet system, in cloud storage, and in some cases, in records that are stored on third party servers, which may be located overseas.
We maintain appropriate physical, procedural and technical security for our offices and information storage facilities so as to prevent any loss, misuse, unauthorised access, disclosure, or modification of personal information. This also applies to disposal of personal information.
We further protect personal information by restricting access to personal information to only those who need access to the personal information do their job. Appropriate physical, electronic and managerial measures are taken to safeguard the security and integrity of your personal information.
We will destroy or de-identify personal information once it is no longer needed for a valid purpose or required to be kept by law.
6. Direct marketing
Like most businesses, marketing is important to our continued success. We therefore like to stay in touch with customers and let them know about new opportunities. We may provide you with information about new products, services and promotions either from us, or from third parties which may be of interest to you.
We will not disclose your personal information to third parties for marketing purposes without your consent.
You may opt out at any time if you no longer wish to receive commercial messages from LMG, or from any particular Store. You can make this request by clicking the 'unsubscribe' link in any email we send you and following the process to unsubscribe to future messages and promotions. We may also offer the ability to change your marketing and promotions preferences in your online account profile page.
7. Cookies and Data Analytics
We may use third party vendors to show our ads on sites on the Internet and serve these ads based on a user’s prior visits to the Site. We may also use analytics data supplied by these vendors to inform and optimise our ad campaigns based on your prior visits to the Site.
We may also use data that we collect through the Site (including transaction records, usage data and personal information) to generate aggregated and de-identified statistical data sets. These aggregated and de-identified data sets may be used for statistical analysis and research in connection with our businesses, including for marketing and product development purposes.
8. Accessing and correcting your personal information
You may contact LMG or any Store to request access to the personal information that it holds about you and/or to make corrections to that information, at any time. On the rare occasions when access is refused, LMG or the Store (as applicable) will provide you with a written notice stating our reasons for refusing access. LMG or the Store (as applicable) may seek to recover from you reasonable costs incurred for providing you with access to any of the personal information that you request.
A request to correct your personal information may be refused if LMG or the Store (as applicable) does not agree that the information requires correction. If this occurs, LMG or the Store (as applicable) will provide you with a written notice stating our reasons for refusing.
LMG or the Store (as applicable) will respond to all requests for access to or correction of personal information within a reasonable time.
9. Overseas transfers of personal information
We may disclose your personal information to our related entities, service providers and agents, some of whom may use facilities that are located overseas, including in countries such as the United States of America. Please note that the use of overseas facilities to store personal information may not always involve a disclosure of personal information under the Privacy Act.
By providing your personal information to us in connection with the Site, you consent to us disclosing your personal information to any such overseas recipients for purposes necessary or useful in the course of operating our business and the Site, and agree that Australian Privacy Principle 8.1 will not apply to such disclosures. For the avoidance of doubt, in the event that an overseas recipient breaches the Australian Privacy Principles, that entity will not be bound by, and you will not be able to seek redress under, the Privacy Act.
Resolving personal information concerns
All complaints will be taken seriously, and you can expect a response to your complaint within a reasonable period. If you submit your complaint to LMG directly, please allow time for LMG to assess whether your complaint should be forwarded to the relevant Store for response.
If you are dissatisfied with the handling of your complaint, you may contact the Office of the Australian Information Commissioner:
Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
Telephone: 1300 363 992
11. Contact details
If you wish to contact LMG in relation to personal information that LMG has collected about you through the Site, please use the contact details set out below:
Liquor Marketing Group - Privacy Officer
The Binary Centre
Building 1, Level 5
3 Richardson Place
North Ryde NSW
Telephone: (02) 9475 2333
Email: firstname.lastname@example.org; email@example.com; firstname.lastname@example.org
If your query relates to how your personal information has been used by a Store, please contact the relevant Store directly (see section 11.2 below). If you submit such a query to LMG, LMG may forward your query to the relevant Store for response.
If you wish to:
(b) submit a privacy question, concern or complaint to a Store
please contact that Store directly using Customer Support on 1800 647 931 or, depending on the Store you use, email email@example.com; firstname.lastname@example.org; online @sipnsave.com.au.
The last update to this document was May 31st 2018.