INTRODUCTION

Willunga Hundred Pty Ltd of 180 Greenhill Road, Parkside, South Australia, 5063 (registered in Australia with company number 052 865 120)(“Willunga100”, “we”, “us” or “our”) have a commitment to privacy in accordance with The Privacy Act 1988 (Privacy Act), and are committed to protecting and maintaining your privacy.

We understand that when interacting with us the privacy and confidentiality of your personal information is important to you. That is why we are committed to safeguarding your personal information.

1.0  Purpose of this Policy

 

This Privacy Policy describes the types of personal information we may collect, and how we use, hold and disclose this personal information.

 

This Privacy Policy also sets out how you can contact us to access or correct your personal information or make a complaint.

 

By providing personal information to us, you accept and consent to our collection, storage, use and disclosure of your personal information in accordance with this Policy.

 

Section 12 of this Policy provides details on how to contact us in relation to privacy requests, inquiries or complaints.

2.0 Definitions and Interpretation

 

For the purposes of this Privacy Policy, "personal information" is defined as information or an opinion relating to an individual which can be used to identify that individual.

 

This Privacy Policy includes examples but is not intended to be restricted in its application to such examples. Accordingly, where the word ‘include’ or 'including' is used, it will mean 'include/including without limitation'.

 

3.0 How is personal information collected?

The types of personal information Willunga 100 collects will vary depending on the nature of your dealings with Willunga 100. Generally, the types of personal information we collect and hold may include your name, contact information, employment details, financial and tax related information and any other information provided at Willunga 100’s request.

 

We may collect personal information in a number of ways, including:

 

  • directly from you, including through our websites, by telephone, through written correspondence and in person if you visit us;
  • from credit reporting agencies;
  • from publicly available sources of information; and
  • monitoring and recording of calls that you make to us in certain circumstances (we will notify you beforehand).

 

4.0 How we use personal information

 

Except where your consent has been provided, Willunga 100 will only use personal information for the primary purpose for which we collected it (or a purpose related to it), where required or permitted by law, or where you have consented to such use or disclosure.

 

The main purposes for which we may use or disclose personal information include:

 

  • to provide products and services requested by you and to manage those services, including to enable customer service, delivery and billing;
  • evaluating and monitoring credit worthiness;
  • meeting legal and regulatory requirements; and
  • to directly promote and market products, news, promotions and other services to you where we have your express or implied consent. If you do not wish to receive news, offers and promotions, we will not contact you about these once you have advised us as such.

 

We may expressly communicate to you the primary purpose for which your personal information is collected, or it may be clear from the nature of our dealings with you.

If you receive electronic communications from us, we will provide you with an opportunity to unsubscribe from receiving further information from us.

 

5.0 Our disclosure of personal information

Except as set out in this Privacy Policy, Willunga 100 will not disclose personal information outside of Willunga 100. Willunga 100 will only disclose personal information to third parties where it is necessary or compulsory to do so.

 

The primary instances where Willunga 100 may disclose personal information to third parties include:

 

  • to external advisors and service providers including advertising and credit reporting agencies, so they can provide the services we have contracted to them;
  • to law enforcement bodies, in order to comply with the law or to protect the rights, property or safety of the public or Willunga 100; and
  • if Willunga 100 or substantially all of its assets are acquired by a third party, personal data held by it about its customers may be disclosed as one of the transferred assets.

 

In certain circumstances we may be a credit provider to you. In these circumstances, we will handle your credit information in accordance with this Privacy Policy.



6.0 How is my personal information stored and kept secure?

Willunga 100 takes reasonable physical and electronic steps to keep the personal information we hold secure from unauthorised access, modification, loss and interference. Willunga 100 has internal policies, procedures and systems in place to ensure compliance with this Policy.

Personal information may be stored electronically and/or in hard copy, and appropriate information security measures are in place to protect this information.

Unfortunately, no data transmission over the internet can be guaranteed to be fully secure and you need to be aware of this when communicating with or providing personal information to Willunga 100 over the internet.

 

Additionally, we ensure that we only disclose your personal information to third parties where it is necessary or compulsory to do so, and we impose strict security requirements on all such third parties regarding how they hold and deal with personal information.

 

7.0 International use

Willunga 100 operates as a global business, and has international distributors who may use global data storage. Accordingly, the information that we collect from you may be transferred to, and stored at, a destination outside of the country in which the information was collected. It may also be processed by employees operating outside of the country in which the information was collected or for one of our suppliers or agencies.

Willunga 100 may disclose or transfer your personal information where necessary to companies which are “related bodies corporate” or “ultimate holding companies” or “subsidiaries”. Generally, we will ensure that an international entity is bound by privacy obligations equivalent to the APP’s or Privacy Act, before we disclose or transfer your personal information to it.

By submitting your personal information, you agree to this transfer, storing or processing. We will take reasonable steps to ensure that your personal information is treated securely and in accordance with this Privacy Policy.

8.0 Accuracy of my personal information

 

We take all reasonable precautions to ensure that the personal information we collect, use and disclose is accurate, complete and up-to-date. However, Willunga 100 will assume that any of the personal information provided by you is up to date and complete at the time it is provided. Willunga 100 does not undertake to check or verify the accuracy of personal information provided.

 

9.0 How do I access and correct my personal information

If you wish to access or update your personal information held by Willunga 100, you need to contact our Privacy Officer. Please see our contact details in section 12 of this Policy.

 

When you contact us with such a request, we will take steps to update your personal information, provide you with access to your personal information and/or otherwise address your query within a reasonable period after we receive your request. Sometimes it will not be possible for us to grant you access to your personal information that we have about you. In such cases, we will give you a written notice explaining why.

 

You have the right to ask us not to process your personal information for marketing purposes. We will usually inform you (before collecting your information) if we intend to use your personal information for such purposes or if we intend to disclose your personal information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data or by contacting us at karen@willunga100.com.

10.0 How do I make a complaint?

A complaint regarding a breach or possible breach of privacy must first be submitted in writing to Willunga 100 Privacy Officer. Please see our contact details in section 12 of this Policy.

If we are unable to satisfactorily resolve your concerns about our handling of your personal information, you can contact a regulatory body including the Office of the Australian Information Commissioner.

 

11.0 Policy variations

 

From time to time, our information handling processes will be reviewed and updated, and we will update this Privacy Policy accordingly. Willunga 100 will notify you of any updates to this Privacy Policy by posting an updated version on our websites and such updates will become effective immediately upon posting.

 

12.0 How to contact us

If you wish to access or correct your personal information held by Willunga 100, or to complain about a possible breach of privacy, enquiries should be directed to the Privacy Officer as follows:

BY EMAIL: karen@willunga100.com BY POST: Privacy Officer

Willinga Hundred Pty Ltd 180 Greenhill Road

Parkside, South Australia 5063

If you no longer wish to receive promotions or other direct marketing communications from Willunga 100, please contact us through one of the methods stated above to advise us of such and provide sufficient information to enable us to locate your information. In some cases, our communications with you may contain specific methods to opt out of direct marketing material sent via the particular communication.