GAP DRINKS PRIVACY POLICY

This policy explains how GAP Drinks Pty Ltd ACN 090 139 870 (We, Our or Us) collect, use, disclose, store, secure and destroy personal information.  In this policy We refer to an individual as You unless talking about all individuals generally.

We comply with the Privacy Act 1988 (Cth) as amended (Act) including  the Australian Privacy Principles (APPs)   The APPs govern the way in which We collect, use, disclose, store, secure and destroy  your Personal Information.

A copy of the APPs may be obtained from the website of the Office of the Australian Information Commissioner (OAIC).  Contact details for the OAIC are provided at the end of this policy.

WHAT IS PERSONAL INFORMATION

Personal Information means information or an opinion about an identified individual, or an individual who is reasonably identifiable whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not.  Examples of Personal Information We collect include names, addresses, email addresses, and telephone  numbers.  Personal Information may include ‘sensitive information’ about an individual.

SENSITIVE INFORMATION

Sensitive Information means Personal Information relating to a person’s racial or ethnic origins, religion, education, occupation, trade union or other professional or trade association membership, sexual orientation, sexual practices, criminal record; and information about a person’s health or biometrics, or a person’s biometric templates. 

HOW IS PERSONAL INFORMATION COLLECTED?  

We normally collect  Personal Information about an individual directly from the individual.  This is obtained in many ways including correspondence, phone, e-mail, in person, participation in Our marketing events including competitions, and from third parties which includes Our clients.

We may collect information from others about You, including from publicly available sources and authorised third parties, where it is reasonable and impractical to collect it from You, or where We have Your consent.

We normally collect a person’s Personal Information for the primary purpose of providing Our services to the individual, providing information or services to Our clients or customers with the individual’s consent and marketing.  We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure.  You may unsubscribe from our mailing/marketing lists at any time by contacting Us on the unsubscribe option provided with Our marketing materials.

We do not generally collect Sensitive Information. When We do collect Sensitive Information, the Sensitive Information will be used and disclosed only for the purpose for which it was collected, a directly related secondary purpose with Your consent or as required by law.

 

WHOSE PERSONAL INFORMATION DO WE COLLECT?

We do not normally collect Personal Information about individuals who simply visit Our website or make general enquires by telephone.  Individuals are welcome to remain anonymous or use a pseudonym in these circumstances.

We collect Personal Information and Sensitive Information about Our customers and prospective customers to enable Us to provide Our services to them and maintain Our relationship with them.

THIRD PARTIES

Where reasonable and practicable to do so, We will collect Your Personal Information only from You.  However, in some circumstances We may be provided with personal information by third parties.  In such a case We will take reasonable steps to ensure that You are made aware of the information provided to Us by the third party.

DISCLOSURE OF PERSONAL INFORMATION

Your Personal Information may be disclosed in a number of circumstances including the following:

·            Third parties including Our clients where you consent to the use or disclosure; and

·            Where required or authorised by law.

We will not normally disclose Personal Information to anyone overseas.  If We disclose Personal Information to an overseas recipient, We will ensure the recipient is within a jurisdiction that has comparable privacy protections to Australia.

We may disclose Personal Information to others where required or authorised by law, for example in response to a court order or police investigation.

SECURITY OF PERSONAL INFORMATION

We may store Personal Information We collect about individuals in either soft or hard copy or both.  We take reasonable steps to ensure there is no unauthorised access, misuse, modification, loss  or disclosure of this Personal Information while We store it.

When Personal Information is no longer needed for the purpose for which it was obtained, We will take reasonable steps to destroy or permanently de-identify the  Personal Information held by us.  However, some  Personal Information may still be held by a client in their files.

ACCESS TO YOUR PERSONAL INFORMATION INCLUDING TO CORRECT DETAILS

Individuals can request access to the Personal Information we hold about them by contacting Our privacy officer using the details below.  We may need to verify your identity before providing access to your Personal Information.

We normally permit an individual to access, update and/or correct their Personal Information.  However, if  We do not We will provide an explanation for that decision.

If you wish to access your Personal Information, please contact Our privacy officer on the details listed below.  There is no fee for requesting access to the Personal Information but We may choose to charge a reasonable fee to provide access to that information.  We normally respond to an access request within 30 days.

POLICY UPDATES

This Policy may change from time to time and is available on Our website https://www.gapdrinks.com/privacy-policy

PRIVACY COMPLAINTS AND ENQUIRIES

If you have any queries or a concern regarding your privacy please contact Our privacy officer using the details below.  We will investigate all complaints and endeavour to respond within 30 days.

The Privacy Officer

GAP Drinks Pty Ltd

Suite 1, 64 The Esplanade

TERRIGAL  NSW  2260

office@gapdrinks.com

OFFICE OF THE AUSTRALIAN INFORMATION COMMISSIONER

Individuals may also make complaints about breaches of the Privacy Act (including if they are not satisfied with Our handling of their privacy) to the Office of the Australian Information Commissioner.  Their details are:

Email:    enquiries@oaic.gov.au

Post:      GPO Box 5218, SYDNEY  NSW  2001

Phone:   1300 363 993

Fax:        02 9284 9666

Further information is available from the OAIC at https://www.oaic.gov.au