Privacy Policy

Security Policy

Two Rivers Wines holds your security and privacy in the highest regard.

  • Two Rivers Wines provides a secure payment gateway with 128 bit SSL encryption for all online credit card transactions.
  • Two Rivers Wines will only use your information for the express purpose for which you provided it. For more information on security, privacy, data protection & security, and your personal Information, please refer to our Privacy Policy below.

You must be aged 18 years old to purchase alcohol. By placing an order, you confirm that you are at least 18 years old. It is an offence to sell, supply to, or obtain liquor on behalf of a person under the age of 18 years. Liquor Act 1982.

Privacy Policy

This Privacy Policy sets out the approach which Two Rivers Wines will take in relation to the treatment of Personal Information. It includes information on how Two Rivers Wines collects, uses, discloses and keeps secure, individuals’ personal information. It also covers how Two Rivers Wines makes the personal information it holds available for access to and correction by the individual. This policy has been drafted having regard to Two Rivers Wines’ obligations under the Privacy Act. This policy is a public document and has been prepared in light of National Privacy Principle 5, Openness.

1. Collection

1.1 Two Rivers Wines will only collect personal information where the information is necessary for Two Rivers Wines to perform one or more of its functions or activities. In this context, “collect” means gather, acquire or obtain by any means, information in circumstances where the individual is identifiable or identified.

1.2 Two Rivers Wines collects Personal Information primarily to supply employees of member organisations and individuals who obtain Two Rivers Wines products and services directly from Two Rivers Wines with information and details of it’s products and services. Two Rivers Wines also collects and uses Personal Information for secondary purposes including:

  • provision of products and services
  • accounting purposes
  • business planning and product development

1.3 Two Rivers Wines will notify individuals (including, but not limited to, our customers) of the matters listed below at the time of collecting any Personal Information:

  • The main reason that we are collecting Personal Information (this reason will be the Primary Purpose)
  • Other related Uses or Disclosures that we may make of the Personal Information (Secondary Purposes)
  • Our identity and how individuals can contact us, if this is not obvious that individuals can access the Personal Information that Two Rivers Wines holds about them
  • That individuals should contact Two Rivers Wines  (even if they are not a member or an employee of a member) if
  • They wish to access or correct Personal Information collected by us or have any concerns in relation to Personal Information
  • The organisations or types of organisations to whom we usually Disclose the Personal Information
  • Where applicable, any law that requires the Personal Information to be collected the consequences (if any) for the individual if all or part of the Personal Information is not provided to Two Rivers Wines

1.4 Where it is not practicable for Two Rivers Wines  to notify individuals of all of the Collection Information before the collection of Personal Information, Two Rivers Wines  will ensure that individuals are notified of the Collection Information as soon as possible after the collection. Two Rivers Wines will provide “post collection notification” in those circumstances where it is not practicable to notify individuals about the collection of their personal information before it is collected.

1.5 Two Rivers Wines will not collect Sensitive Information from individuals except with express consent from the individual and only where it is necessary for Two Rivers Wines  to collect such information for an activity or function.

1.6 Two Rivers Wines will not collect Personal Information secretly or in an underhanded way.

2. Use

2.1 Two Rivers Wines will obtain an individual’s consent for Use of non-sensitive Personal Information for Secondary Purposes at the time of collection, unless the Use is a related Secondary Purpose which would be within the relevant individual’s Reasonable Expectations.

2.2 Two Rivers Wines Uses Personal Information primarily for the purposes listed in 1.2 above.

2.3 If Two Rivers Wines relies on the Direct Marketing exception to Direct Market to individuals it will ensure that: i) individuals are clearly notified of their right to Opt Out from further Direct Marketing; and ii) if the individual Opts Out of all Direct Marketing the Opt Out will be respected by Two Rivers Wines and implemented free of charge.

2.4 Two Rivers Wines will not use Sensitive Information for Direct Marketing.

2.5 Two Rivers Wines may use Personal Information to avoid an imminent threat to a person’s life or to public safety. It may also use Personal Information for reasons related to law enforcement or internal investigations into unlawful activities.

2.6 Two Rivers Wines will not use Personal Information without taking reasonable steps to ensure that the information is accurate, complete and up to date.

2.7 Two Rivers Wines will not attempt to match de-identified or anonymous data collected through surveys or such online devices as “cookies”, with information identifying an individual, without the consent of the relevant individual.

3. Disclosure

3.1 Two Rivers Wines may Disclose Personal Information to related or unrelated third parties only if consent has been obtained from the individual.

3.2 Two Rivers Wines may Disclose Personal Information to unrelated third parties to enable outsourcing of functions where that Disclosure or Use is for a related Secondary Purpose and has been notified to individuals or where such Disclosure is within the individual’s Reasonable Expectations.

3.3 Two Rivers Wines will take reasonable steps to ensure that its contracts with third parties include requirements for third parties to comply with the Use and Disclosure requirements of the Privacy Act.

3.4 In the rare event that Two Rivers Wines is required to disclose Personal Information to law enforcement agencies, government agencies or external advisors Two Rivers Wines will only do so in accordance with the Privacy Act or any other relevant Australian legislation.

3.5 Two Rivers Wines may Disclose Personal Information to avoid an imminent threat to a person’s life or to public safety.

3.6 If a Disclosure is not for a Primary Purpose; is not for a related Secondary Purpose; or upfront consent has not been obtained, Two Rivers Wines will not Disclose Personal Information otherwise than in accordance with the exceptions set out at 3.1 to 3.5 above.

3.7 Two Rivers Wines does not intend to share its customer lists on a commercial basis with third parties but if it did, it would only do so if we had the appropriate consent of the individual involved.

4. Information quality

4.1 Two Rivers Wines will review, on a regular and ongoing basis, its collection and storage practices to ascertain how improvements to accuracy can be achieved.

4.2 Two Rivers Wines will take steps to destroy or de-identify Personal Information after as short a time as possible and after a maximum of seven years, unless the law requires otherwise.

5. Information security

5.1 Two Rivers Wines requires employees and contractors to perform their duties in a manner that is consistent with Two Rivers Wines ‘ legal responsibilities in relation to privacy.

5.2 Two Rivers Wines will take all reasonable steps to ensure that paper and electronic records containing Personal Information are stored in facilities that are only accessible by people within Two Rivers Wines who have a genuine “need to know” as well as “right to know”.

5.3 Two Rivers Wines will review, on a regular and ongoing basis, its information security practices to ascertain how ongoing responsibilities can be achieved and maintained.

6. Access and correction

6.1 Two Rivers Wines will allow its records containing Personal Information to be accessed by the individual concerned in accordance with the Privacy Act.

6.2 Two Rivers Wines will correct its records containing Personal Information as soon as practically possible, at the request of the individual concerned in accordance with the Privacy Act.

6.3 Individuals wishing to lodge a request to access and/or correct their Personal Information should do so by contacting Two Rivers Wines, as per the details on the back of this document.

7. Openness

7.1 Contact with Two Rivers Wines via phone or web inquiry will be the first point of contact for inquiries about privacy issues.
Any formal privacy related complaints should be directed in writing to the Two Rivers Wines Privacy Officer 2 Yarrawa Road Denman NSW 2328.

7.2 Two Rivers Wines will endeavour to manage any privacy related complaint efficiently and in a timely manner.

7.3 Two Rivers Wines websites will contain a prominently displayed privacy statement and will include a copy of this Two Rivers Wines Privacy Policy.

8. Anonymous transactions

8.1 Two Rivers Wines will not make it mandatory for visitors to its web sites to provide Personal Information unless such Personal Information is required to answer an inquiry or provide a service. Two Rivers Wines may however request visitors to provide Personal Information voluntarily to Two Rivers Wines (for example, as part of a competition or questionnaire).

8.2 Two Rivers Wines will allow its customers to transact with it anonymously wherever that is reasonable and practicable.

9. Glossary

Collection Information means the information outlined in 1.3 notified to individuals prior to, or as soon as practical after, the collection of their Personal Information.

Direct Marketing means the marketing of goods or services through means of communication including written, verbal or electronic means. The goods or services which are marketed may be those of Two Rivers Wines or a Related Body Corporate or those of an independent third party organisation.Disclosure generally means the release of information outside Two Rivers Wines, including under a contract to carry out an “outsourced function”. Opt Out means an individual’s expressed request not to receive further Direct Marketing.

Two Rivers Wines means Inglewood Vineyards Pty Ltd trading as Two Rivers Wines

Personal Information means information or an opinion (including information or an opinion forming part of a database), whether true or not and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained from the information or opinion.

Primary Purpose is the dominant or fundamental reason for information being collected in a particular transaction.

Reasonable Expectation means a reasonable individual’s expectation that their personal information might be Used or Disclosed for the particular purpose.

Sensitive Information means: (a) information or an opinion about an individual’s:    (i) racial or ethnic origin; or (ii) political opinions; or (iii) membership of a political association; or (iv) religious beliefs or affiliations; or (v) philosophical beliefs; or (vi) membership of a professional or trade association; or (vii) membership of a trade union; or (viii) sexual preferences or practices; or (ix) criminal record; that is also personal information or (b) Health Information about an individual. Use means the handling of Personal Information within Two Rivers Wines.

 

Contacting TWO RIVERS WINES 

If you require further information regarding Two Rivers Wines’  Privacy Policy, contact us:

Telephone: 02 65 47 2556, 2 Yarrawa Road, Denman NSW 2328, AUSTRALIA

 

ABN: 86003459256

LIQUOR LICENCE NO.: 24004626