PRIVACY POLICY

Version 12 June 2018

Vanguard Luxury Brands Pty Ltd (ACN 128 867 176) (“we”, “our” and “us”) takes the protection of your personal information seriously, and we are committed to complying with the Privacy Principles under the Privacy Act 1988 (Cth) (Privacy Act).

This Privacy Policy sets out the personal information we collect from you, the way in which we collect, use and secure that personal information, the way in which you can access and correct your personal information, and what complaint procedures are available to you if you feel we have breached the Privacy Act.

We may change or update our Privacy Policy from time to time. The latest version of our Privacy Policy is available from our website at http://vanguardluxurybrands.com.au.

WHAT TYPES OF PERSONAL INFORMATION DO WE COLLECT AND HOLD?
We may collect contact details including your name, address, email address, phone numbers and your date of birth / age. We may also collect answers you provide to questions we ask and other information in relation to your dealings with us.

If you apply for employment with us, we may also collect information for the purpose of considering your application including your qualifications and resume as well as reference information from your nominated referees. If you are an individual contractor to us, we may also collect information relevant to your engagement with us including qualifications, work history, resume, reference information from your nominated referees, bank details, feedback from supervisors and training records.

Except as described in this section, we do not generally require you to disclose any sensitive information to us, but if you do provide us with sensitive information, you consent to us collecting that information and using and disclosing that information for the purpose for which you disclosed it to us and as permitted by the Privacy Act and other relevant laws.

HOW DO WE COLLECT AND HOLD YOUR PERSONAL INFORMATION?
We collect your personal information:

directly from you when you provide it to us or our agents or contractors (whether in person, by telephone, email or other written form);
directly from you via our website or when you deal with us online (including through our social media pages);
from publicly available sources; and
from third parties (for example, from referees if you apply for a position as an employee or contractor with us, or from a third-party credit reporting body if we request a credit report about you if you are a customer we directly supply).
We take reasonable steps to ensure that your personal information is held securely. We have implemented appropriate computer security measures (such as firewalls and antivirus) in order to protect your personal information from loss, misuse, alteration or destruction.

WHY DO WE COLLECT, HOLD, USE AND DISCLOSE YOUR PERSONAL INFORMATION?
In general we collect, use and disclose your personal information so that we can do business with you and for purposes connected with our business operations. Some specific purposes include:

to respond to you if you have requested information (including your requests through our website or by email or other correspondence you send to us);
to provide goods or services to you or to receive goods or services from you;
to administer or contact you about rewards, surveys, competitions or other promotional activities or events conducted, sponsored or managed by us or our business partners;
for our own internal business operations, including optimising or bettering our goods and services to you, or analysing and better understanding our customer base;
to verify your identity, address and age or eligibility to participate in a marketing activity;
to consider you for a job with us (whether as an employee or contractor);
to address any issues or complaints that we or you have regarding our relationship; and
to contact you regarding the above, including via electronic messaging such as SMS and email, by mail, by phone or in any other lawful manner.

WHO DO WE DISCLOSE YOUR PERSONAL INFORMATION TO?
We may disclose your personal information to the following third parties in connection with the above-mentioned purposes:

our employees and related bodies corporate;
our contractors and other third parties that provide goods and services to us (including any payment system operators);
our accountants, insurers, lawyers, auditors and other professional advisers and agents;
any third parties to whom you have directed or permitted us to disclose your personal information;
in the event we sell our business, to any third party purchaser and its advisors ;
third parties that require the information for law enforcement; and
otherwise as permitted or required by law.

ARE WE LIKELY TO DISCLOSE YOUR PERSONAL INFORMATION TO OVERSEAS RECIPIENTS?
We distribute premium alcoholic brands, many of whom are owned by overseas companies. Therefore, we may from time to time disclose some of your personal information with our overseas business partners (in USA, Italy, Mexico, Peru, The Netherlands, The United Kingdom, Nicaragua, Czech Republic, France and New Zealand), in connection with consumer competitions and otherwise marketing promotions, and in relation to product complaints and feedback.

Links, cookies and use of our websites and applications

Our website may contain links to other sites. This Privacy Policy applies to our website and not any linked sites which are not operated or controlled by us. We encourage you to read the privacy policies of each website that collects your personal information.

We may use “cookies” and similar technology on our websites and in other technology applications. The use of such technologies is an industry standard, and helps to monitor the effectiveness of advertising and how visitors use our websites/applications. We may use such technologies to generate statistics, measure your activity, improve the usefulness of our websites/applications and to enhance the “customer” experience. If you prefer not to receive cookies you can adjust your Internet browser to refuse cookies or to warn you when cookies are being used. However, our websites may not function properly or optimally if cookies have been turned off.

HOW CAN YOU ACCESS YOUR PERSONAL INFORMATION AND CORRECT IT?
You have a right to request access your personal information and to request corrections from us.

You can request to access your personal information that we have on record about you, or request that we update that personal information, by writing, telephoning or emailing us:

Vanguard Luxury Brands Pty Ltd

Attention: Managing Director

57 Bream St, Coogee NSW 2034, Australia

1300 DRINKS within Australia or + 61 408 411 859 from overseas

admin@vanguardluxurybrands.com

HOW CAN YOU MAKE A COMPLAINT AGAINST US, AND HOW WILL IT BE HANDLED?
You are entitled to complain if you believe that your privacy has been compromised or if we have breached the Privacy Act. If you have a complaint, you should write to us to:

Vanguard Luxury Brands Pty Ltd

Attention: Managing Director

57 Bream St, Coogee NSW 2034, Australia

1300 DRINKS within Australia or + 61 408 411 859 from overseas

admin@vanguardluxurybrands.com

We will attempt to respond to you in writing within a reasonable period of time, informing you of our decision in relation to your complaint.

If you believe that your complaint has not been satisfactorily resolved, then you can access an external dispute resolution service (if applicable) or apply to the Office of the Australian Information Commissioner (OAIC) to have the complaint heard and determined. When we write to you about our decision, we will explain how you may access an external dispute resolution scheme (if applicable) or make a complaint to the OAIC.