1. About this Policy

1.1. WithWine Ltd (WithWine) is
committed to maintaining the privacy of its suppliers, customers,
clients and other individuals who interact with WithWine and has
developed this Privacy Policy in line with the Australian Privacy
Principles as established under the Privacy Act 1988 (Cth) (Privacy

1.2. WithWine is bound by the
Australian Privacy Principles that establish the benchmark for how
personal information should be handled. WithWine has adopted those
principles as part of its standard business procedures. All personal
information obtained by WithWine is dealt with in a uniform manner and
every effort is made to maintain its security.

1.3. The purpose of this Privacy Policy
is to describe how WithWine collects, uses and discloses information
and how you may access and correct this information.

2. Personal Information

2.1. WithWine holds personal information about its members, suppliers, customers, clients and other individuals who
interact with WithWine (referred to in this Privacy Policy as “you”).
This information includes, but is not limited to, name, address, phone
number, fax number, email address and platform activity. It may also
include other personal information and financial information.

2.2. WithWine
does not wish to collect any Sensitive Information (as that term is
defined in the Privacy Act) about you, including information or opinions
about your political affiliations, sexual preferences, religious
beliefs and racial or ethnic origin.

3. Collection of Personal Information

3.1. WithWine collects and holds personal information about you for the purposes of:

(a) facilitating the provision of services by WithWine;

(b) conducting anonymous voluntary surveys in order to gain feedback
on matters related to WithWine and improve the services provided by

(c) WithWine’s administrative functions; 

(d) supporting and managing password-protected, member-only access to
the WithWine website and other WithWine owned online platforms; 

(e) supporting and managing an online member and public directory on the WithWine website; and

(f) analytics and research by WithWine, its partners and/or other users of its platform. 

(g) direct marketing by WithWine, its partners and/or other users of its platform.

Should we use your information for any project in partnership with a
3rd party your information will be aggregated and anonymised. We will
not sell your information to 3rd parties.

3.2. WithWine collects personal information in a number of ways, including:

(a) directly from the contact person and/or a designated nominee
through various online and hard copy registration and application forms
issued to facilitate the provision of services by WithWine; 

(b) via the WithWine website;

(c) via fax and other electronic means, including credit card payment remittance slips;

(d) through online surveys where the member has not chosen to remain anonymous.

4. Use and Disclosure of Personal Information

4.1. WithWine has
a policy of not disclosing personal information contained on its
database to anybody outside the WithWine platform for purposes beyond
the completion of transactions. This means that the use of the database
containing personal information is restricted solely to WithWine and its
users. However, where required to do so by law, WithWine will disclose
personal information about you.

5. Cross-Border Disclosure

5.1. WithWine may provide your information to overseas recipients in the following circumstances:

(a) In the event that WithWine owns entities outside of Australia, your personal information may be disclosed to those entities

(b) In the event that either a partial or full share of WithWine is
purchased by overseas entities, your personal information may be
disclosed to those entities

(c) In the event that you have placed an order for products from
outside of Australia, your personal information may be disclosed to
overseas recipients

5.2. By opting into these services you consent to the disclosure of your personal information to such overseas recipients.

6. Storage and Security of Personal Information

6.1. WithWine stores personal information in a combination of secure computer-based storage facilities and paper-based files and records.

6.2. WithWine
generally uses accepted technology and security so that it is satisfied
that personal information is transmitted safely to it through the
internet or other electronic means.

6.3. WithWine
will use its reasonable endeavours to protect your personal information
from misuse, unauthorised access, disclosure, modification or loss.
WithWine’s officers, employees, agents and third party contractors are
expected to observe the confidentiality of your personal information.

6.4. Despite its reasonable endeavours,
WithWine is unable to ensure or warrant the security of any personal
information transmitted to WithWine and all personal information
disclosed by you to WithWine is at your own risk.

6.5. Where WithWine no longer requires
personal information it has collected and stored and is not required by
or under Australian law, or an order of a court or tribunal, to retain
the information, WithWine will take such steps as are reasonable in the
circumstances to destroy the information or to ensure that the
information is no longer personal information.

7. Access to Personal Information

7.1. Upon request, WithWine will inform
you of the type of personal information held about you. You have the
right to access your personal information stored on a computer, on a
database, in personnel files or in any other format WithWine to ensure
that it is accurate unless WithWine has a legal duty of confidentiality
or non-disclosure.

7.2. If you would like to exercise your
right to access your personal information please contact our Privacy
Officer. It is our policy that all requests for access be made in
writing. Our Privacy Officer will arrange for an access form to be sent
to you and can assist with any enquiries you may have about the process.
WithWine must respond to a request by you to access your personal
information within a reasonable period after the request is made.

7.3. WithWine, in its discretion, may
refuse to grant you access to your personal information to the extent
that such denial is permitted by the Australian Privacy Principles. If
WithWine refuses your request to access your personal information under
the Australian Privacy Principles, WithWine must, in writing:

(a) where reasonable, give reasons for the refusal; and

(b) notify you of the mechanisms to complain about the refusal; and

(c) inform you of any other matter prescribed by the regulations.

8. Personal Information to be kept up-to-date

8.1. WithWine will take all reasonable
precautions to ensure that the personal information it collects, uses
and discloses is accurate, complete and up-to-date. However, the
accuracy of that information depends to a large extent on the
information provided by you. In order to prevent inaccuracies in your
personal information you should:

(a) let WithWine know if there are any errors in your personal information; and

(b) keep WithWine up to date with any changes to your personal information such as name, address and telephone number.

9. Correction of Personal Information

9.1. You may contact the Privacy
Officer appointed by WithWine to correct any of your personal
information that is inaccurate, out-of-date, incomplete or to request
that your personal information be deleted. You can contact the Privacy
Officer at privacy@withwine.com. If WithWine is satisfied that your
personal information is inaccurate, out-of-date, incomplete or
irrelevant, or if you request WithWine to correct your personal
information then WithWine must take reasonable steps to correct your
personal information to ensure that, having regard to the purpose for
which it is held, it is accurate, up-to-date, complete and relevant.

9.2. WithWine must respond to a request by you to correct your personal information within a reasonable period after the request is made.

9.3. WithWine will not charge you a fee for the making of the request, or for correcting your personal information.

9.4. If WithWine has previously
disclosed your personal information to another entity, WithWine will
take reasonable steps to notify the other entity of the
correction(unless it is impracticable or unlawful to do so) if you make
such a request.

 9.5. If WithWine refuses your request to correct information, WithWine must, in writing:

(a) give reasons for the refusal except to the extent it would be unreasonable to do so; and

(b) notify you of the mechanisms available to complain about the refusal; and

(c) inform you of any other matters prescribed by the privacy regulations.

10. Direct Marketing

10.1. WithWine may use your personal
information for direct marketing purposes, including for the purposes
set out in clause 3.1(a), to communicate opportunities related to
WithWine and its services via email and postal mail.

10.2. If you do not wish to receive any marketing material from us you can opt-out by contacting us at hello@withwine.com.

10.3. WithWine does not pass on any personal information to parties outside of the WithWine platform (i.e. non-users) for direct marketing.

10.4. Generally, your personal
information is only shared with other users of the WithWine platform if
you have chosen to Follow that user or one of more brand profiles owned
by a user. Other users will be able to see your personal information
though, without you Following them or their brand, if you place an order
with them, subscribe to their mailing list, join their wine club or
similar interaction.

11. Cookies

11.1. A Cookie is a feature stored on
your computer’s hard drive by your web browser. On each visit to the
Website, the WithWine web browser will recognise the Cookie and give
WithWine information about your visit. WithWine uses Cookies for the
purpose of allowing you to have your password saved for easy repeated
access to the website. WithWine may also use Cookies to learn about your
preferences and the way that you use the Website so that it can improve
the Website. Most browsers accept Cookies automatically, but you should
also be able to alter the settings of the browser to refuse Cookies.
You should note that de-activating Cookies may mean that you will no
longer be able to enjoy the full operational capabilities of the

12. How to make a complaint

12.1. If you are concerned that
WithWine may have handled your personal information inappropriately or
you have a complaint regarding an interference with your privacy, please
contact our Privacy Officer at privacy@withwine.com.

12.2. Upon receipt of your complaint,
WithWine will handle the complaint in accordance with its Complaints
Handling Process and Policy. This requires WithWine to:

(a) confirm receipt of your complaint;

(b) advise you what steps will be taken to investigate your complaint;

(c) provide an approximate timeframe within which your complaint will be resolved;

(d) make a decision in relation to your complaint; and

(e) inform you of the outcome of your complaint and the reasons for the decision.

12.3. In response to any complaint, WithWine will:

a) treat all complaints sensitively, seriously and sympathetically;

b) attempt to resolve the matter promptly;

c) keep accurate records of your complaint, WithWine’s investigation of your complaint and the outcome reached.

13. Contact Details

13.1. If you have any queries about
this Privacy Policy, wish to gain access to or correct personal
information WithWine may hold about you or have any complaints regarding
an interference with your privacy or the way we manage your personal
information you may contact the Privacy Officer appointed by WithWine by
email at privacy@withwine.com.

14. Consent

14.1. You acknowledge and agree that by
providing your personal information to WithWine that WithWine, its
related bodies corporate and partners and each of their officers,
employees, agents and contractors are permitted to collect, store, use
and disclose your personal information in the manner set out in this
Privacy Policy and in accordance with the Australian Privacy Principles.