This Policy sets out how Cellar Door Society PTY LTD (“Cellar Door Society” "we" "our" or "us") protects the privacy of your personal information.
About this Policy
We need to collect, use and disclose personal information in order to perform our business functions and activities. We are dedicated to protecting the privacy and confidentiality of personal information and to maintaining physical, electronic and procedural safeguards to protect personal information in our care.
By providing personal information to us (either directly or allowing another person to do so on your behalf), you agree that this Policy will apply to how we handle your personal information and you consent to us collecting, using and disclosing your personal information as detailed in this Policy. If you do not agree with any part of this Policy, you must not provide your personal information to us. If you do not provide us with your personal information, or if you withdraw a consent that you have given under this Policy, this may affect our capability to provide services to you or negatively impact the services we can provide to you.
We’ll review this policy from time to time to make sure it’s up-to-date. If we make changes, we’ll post the latest version here.
We use the term ‘personal data’ in this policy. By that, we mean any information relating to you as an identifiable individual. This includes information that may of itself identify you such as your name, contact details, trip itinerary, internet protocol (“IP”) address, cookie strings or device IDs, as well as information that may not on its own identify you, but which we store alongside such identifiers, such as how you are using our services or the country you are in when you do so.
Why and how do we use your personal data?
We only use your information where it’s necessary to deliver the services you’ve requested, where it’s necessary to exercise or comply with legal rights or obligations, or for normal business purposes of the kind set out in this policy. This includes reasons to improve or optimise our services and to otherwise protect or further our legitimate interests including fraud prevention and security as well as product enhancement so we can keep making our services even better.
What personal data do we collect?
Everyone who uses our services will have bits and pieces of information about them collected, stored and processed. However, we don’t collect more information than we need. When you use our services, we have to collect, keep and share some personal data and ask that you agree to that in line with this policy. We collect information in three ways:
You give it to us voluntarily
Information you choose to give us might include personal data. It’s always up to you whether or not you choose to give us this kind of information.
We generate or collect it automatically
We generate or collect some information from your computer or device automatically as you use our services. This includes things like your IP address, information about the device and browser you are using to access our services, the website URL you visited us from and the third party sites you visit when you click on links to exit the Cellar Door Society site. We may also know your location from your mobile or your IP address. This helps us to improve your experience and make sure you receive the content that’s most relevant to you.
We receive it from third parties
Sometimes we are given information about you from third parties, depending on how you choose to interact with us. For example, when you come to our website via a promotional partner, or when you log into your Cellar Door Society account.
Our services are not intended for people under 18 years of age, and no one under the age of 18 should provide any information to, on or via our services. We don’t knowingly collect personal data from people under 18, and will delete any that we learn we have collected or received that was not provided by, or with express consent on behalf of, the child’s parent or legal guardian.
How long do we store your personal data?
We only keep your data for as long as we need it, or are required to for legal reasons. We’ll then either delete it or anonymise it so it doesn’t identify you. We treat data differently depending on what it’s used for, but you can ask us to delete your personal data at any time.
When is your information shared with or collected by third parties?
We share your information only where you ask us to, where it’s a necessary part of doing business with you and providing you with the services, or where we need to for legal reasons. Wine suppliers from whom you order will collect your data in line with their own policies. Sometimes companies that advertise via our services may also collect your information. Finally, companies that help us deliver our services will also collect and use your data on our behalf.
Sharing personal data with third parties who process it only under our instruction
We share information relating to our users with selected third parties who provide us with a variety of different services that support the delivery of our services (“Third Party Processors”). These Third Party Processors range from providers of technical infrastructure to customer service and authentication tools. We require any Third Party Processor which handles information on our behalf to do so pursuant to contractual terms which require that the information is kept secure, is processed in accordance with applicable data protection laws, and used only as we have instructed and not for that Third Party Processor’s own purposes (unless you have explicitly consented to them doing so).
Third Party Processors may be located in, or process your information, outside of the Australia. Where our use of a Third Party Processor involves the transfer of personal data from within Australia to a location outside of Australia, we will put in place appropriate measures to ensure that the personal data is adequately protected in that location.
Certain information may also be collected from you by third parties such as advertisers, marketing networks and affiliates using cookies and similar technologies. For example your IP address and events relating to your activity like searches you have carried out or pages you have viewed on Cellar Door Society may be collected and transmitted to these third parties to allow them to serve relevant advertising to you across the web. The information that is collected in this way will never include your name, contact details or other information that would enable you to be identified in the offline world. You can find out more about advertising in Cellar Door Society, including how you can opt out of certain types of advertising.
Disclosing information for legal and other reasons
We may disclose your information where necessary to enforce our Terms of Service or other agreements, or to a prospective or ultimate buyer if Cellar Door Society itself (or part of our business) is sold. We may also disclose your information if necessary to prevent, detect or prosecute illegal or suspected illegal activities, including fraud, or to prevent other damage or where necessary in response to legally binding requests, legal action against us, or to enforce our rights and claims.
How do we keep your personal data secure?
Safeguarding your privacy is embedded in our culture and we use a combination of industry-standard methods to protect it.
Keeping your personal data secure is our highest priority. We limit access to only those Cellar Door Society group employees who have to come into contact with your information to do their jobs and deliver our services.
Unfortunately, no website or app can guarantee complete security but we have created an organisation-wide security programme designed to keep your personal data as safe as possible. It uses a range of technical, organisational and administrative security measures and best-practice techniques, depending on the type of data being processed.
To make sure we maintain a culture of ‘Privacy by Design’, we provide thorough data protection and privacy training to all Cellar Door Society group employees. We develop our services with the goal of using the minimum amount of personal data possible, including through use of data minimisation techniques like anonymisation and pseudonymisation. Also, whenever we develop or update our services in ways that involve the collection or use of new forms of personal data, we conduct a privacy impact assessment to understand, and reduce, the likelihood of any unintended impact on you.
Where do we store your information?
Your data is securely stored in data centers. Your data will only be processed by suppliers who have sophisticated levels of data security in place.
How is your information used for advertising?
You will see various advertisements when you use our services and might also see advertisements about Cellar Door Society when you’re on other platforms. These advertisements might come from us or from third parties and may be personalised to make them more relevant to you. The information used to personalise advertisements you see may include your details of what you’ve searched for on Cellar Door Society or general location information at a city or airport level, but will never include your name, contact details or other information that would enable you to be identified in the offline world.
Advertisements you might see whilst using Cellar Door Society
You’ll often see advertisements while using our services. These will either be delivered by us directly or by third party advertising solution providers we partner with (“Third Party Ad Solutions”).
The majority of these advertisements will be personalised to make them relevant to you and will fall into two different categories. Firstly, advertisements that are personalised for you based on information collected by us or by Third Party Ad Solutions whilst you use our services, such as your general location (by city or country) and your Cellar Door Society searches or ordering history (“Cellar Door Society-related Information”). Cellar Door Society-related Information will never include your name, contact details or other information that would enable you to be identified in the offline world. Secondly, advertisements that are personalised for you based on information that we have no visibility or control over, and which is instead collected from you by Third Party Solutions when you have been using other non-Cellar Door Society websites or platforms (“non-Cellar Door Society Platforms”). Collectively, we refer to these as “interest-based” advertisements.
The information required to deliver these interest-based advertisements will be stored by Third Party Ad Solutions alongside your IP address and/or a cookie ID, so that you can be served the advertisements without the Third Party Ad Solutions needing to store any information that would enable you to be identified in the offline world, like your name or address.
Advertisements you might see whilst on non-Cellar Door Society platforms
You might also see advertisements for our services once you’ve left Cellar Door Society and are using non-Cellar Door Society websites. For example, this would happen where a non-Cellar Door Society Platform that you use makes advertising space available for sale and Cellar Door Society, or a Third Party Ad Solution that we work with, purchases that space. Similar to the advertisements you see whilst using Cellar Door Society, these advertisements may be personalised and served to you because of information that Third Party ad solutions have collected about you, either when you were using our services or when you were using other non-Cellar Door Society Platforms.
Marketing is important to our continued success. We believe we have an exceptional range of products and services that we provide to customers at a high standard. We therefore like to keep in touch with customers and let them know about new opportunities. We may provide you with information about new products, services and promotions either from us, or from third parties which may be of interest to you.
We will not disclose your personal information to third parties for marketing purposes without your consent.
You may opt out at any time if you no longer wish to receive commercial messages from us. You can make this request by contacting us.
We use a combination of cookies and other technologies such as pixels/web beacons and tracking codes (explained below) to collect information for use in line with the purposes set out in this policy.
What is a cookie?
Cookies on our website may be set by us, third parties we’re working with, or independent third parties (such as advertisers).
What are web beacons and pixels?
Web beacons or pixels are small, transparent image files inside a web page or email. We use them to understand how you interact with our services, or if you’ve redirected to a Wine Supplier’s website or app. We might use the pixel to confirm if you went on to book with them, and what you booked. We also use pixels to gather information such as whether you’ve opened an email, so that we can improve our communications to you.
What are tracking codes?
Tracking codes are snippets of code placed in the page to measure things like visits and interactions. We use tracking codes to find out more about how you interact with our services, the advertisements you see and more generally, how you use us.
What are your choices and rights?
If you’ve got a Cellar Door Society account, you can access, edit, download or delete the key personal data associated with your profile at any time by going to your Profile. From here you can also manage your subscription and marketing preferences.
You also have rights in relation to the personal data we have about you, which we explain in more detail below. You can exercise these rights by getting in touch with us via email.
You have the right to ask us for a copy of your personal data; to correct, delete or restrict processing of your personal data; and to obtain the personal data you have provided to us in a structured, machine readable format. In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement). Where we have asked for your consent, you may withdraw consent at any time. If you ask to withdraw your consent to Cellar Door Society processing your data, this will not affect any processing which has already taken place at that time.
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep. If you have unresolved concerns, you have the right to complain to a data protection authority.
To the extent that you’re unable to satisfactorily exercise any of these rights via your Profile, you can do so by contacting us by email.
If you have unresolved concerns, you have the right to complain to the Office of the Australian Information Commissioner Phone 1800 363 992 or Email [email protected]