Security Policy
Tulloch Wines holds your security and privacy in the highest
regard.
- Tulloch Wines provides a secure payment gateway with 128 bit
SSL encryption for all online credit card transactions.
- Tulloch 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 JY Tulloch and
Sons Pty Ltd (Tulloch Wines) will take in relation to the treatment
of Personal Information. It includes information on how Tulloch
Wines collects, uses, discloses and keeps secure, individuals'
personal information. It also covers how Tulloch Wines makes the
personal information it holds available for access to and
correction by the individual.
This policy has been drafted having regard to Tulloch 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 Tulloch Wines will only collect personal information where
the information is necessary for Tulloch 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 Tulloch Wines collects Personal Information primarily to
supply employees of member organisations and individuals who obtain
Tulloch Wines products and services directly from Tulloch Wines
with information and details of it's products and services. Tulloch
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 Tulloch 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
Tulloch Wines holds about them
- That individuals should contact Tulloch 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 Tulloch Wines
1.4 Where it is not practicable for Tulloch Wines to
notify individuals of all of the Collection Information before the
collection of Personal Information, Tulloch Wines will ensure
that individuals are notified of the Collection Information as soon
as possible after the collection. Tulloch 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 Tulloch Wines will not collect Sensitive Information from
individuals except with express consent from the individual and
only where it is necessary for Tulloch Wines to collect such
information for an activity or function.
1.6 Tulloch Wines will not collect Personal Information secretly
or in an underhanded way.
2. Use
2.1 Tulloch 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 Tulloch Wines Uses Personal Information primarily for the
purposes listed in 1.2 above.
2.3 If Tulloch 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 Tulloch Wines and implemented free of
charge.
2.4 Tulloch Wines will not use Sensitive Information for Direct
Marketing.
2.5 Tulloch 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 Tulloch Wines will not use Personal Information without taking
reasonable steps to ensure that the information is accurate,
complete and up to date.
2.7 Tulloch 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 Tulloch Wines may Disclose Personal Information to related
or unrelated third parties only if consent has been obtained from
the individual.
3.2 Tulloch 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 Tulloch 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 Tulloch Wines is required to disclose
Personal Information to law enforcement agencies, government
agencies or external advisors Tulloch Wines will only do so in
accordance with the Privacy Act or any other relevant Australian
legislation.
3.5 Tulloch 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, Tulloch Wines will not Disclose Personal Information
otherwise than in accordance with the exceptions set out at 3.1 to
3.5 above.
3.7 Tulloch 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 Tulloch 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 Tulloch 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 Tulloch Wines requires employees and contractors to perform
their duties in a manner that is consistent with Tulloch Wines '
legal responsibilities in relation to privacy.
5.2 Tulloch 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
Tulloch Wines who have a genuine "need to know" as well as "right
to know".
5.3 Tulloch 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 Tulloch Wines will allow its records containing Personal
Information to be accessed by the individual concerned in
accordance with the Privacy Act.
6.2 Tulloch 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
Tulloch Wines, as per the details on the back of this document.
7. Openness
7.1 Contact with Tulloch 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 Tulloch Wines Privacy Officer 638 DeBeyers Road
Pokolbin NSW 2320.
7.2 Tulloch Wines will endeavour to manage any privacy related
complaint efficiently and in a timely manner.
7.3 Tulloch Wines websites will contain a prominently displayed
privacy statement and will include a copy of this Tulloch Wines
Privacy Policy.
8. Anonymous transactions
8.1 Tulloch 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.
Tulloch Wines may however request visitors to provide Personal
Information voluntarily to Tulloch Wines (for example, as part of a
competition or questionnaire).
8.2 Tulloch 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
Tulloch Wines or a Related Body Corporate or those of an
independent third party organisation.
Disclosure generally means the release of information outside
Tulloch 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.
Tulloch Wines means the JY Tulloch and Sons Pty Ltd
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 Tulloch
Wines.
Contacting TULLOCH WINES
If you require further information regarding Tulloch Wines'
Privacy Policy, contact us.
Telephone: 02 4998 7580
638 De Beyers Road, Pokolbin NSW 2320,
AUSTRALIA
ABN 58 099 104 720