This Privacy Policy (“Policy”) sets out how Food and Wine Victoria Ltd (ACN 106 066 406) (referred to in this Policy as “F+WV”, “we”, “us”, “our”) protects the privacy of your personal and/or sensitive information.
Please note this Policy and all personal and/or sensitive information collected and otherwise dealt with by F+WV is subject to the Privacy Act 1988 (Cth) (“Privacy Act”) and the Australian Privacy Principles (“APP”) contained in Schedule 1 of the Privacy Act, as amended from time to time.
This Policy also is subject to the General Data Protection Regulation 2016/679 (“GDPR”) if you are based in the European Union or the United Kingdom during your interactions with us (“EU individual”).
1. Scope
This Policy explains how F+WV collects, uses, holds and discloses personal and sensitive information provided about individuals to F+WV through the use of https://www.melbournefoodandwine.com.au/, https://staging.globaltable.com.au/, and any other websites operated by F+WV (collectively “the websites”), mobile applications, social media pages or other applications related to F+WV and any services and/or goods offered or provided by F+WV (“services”).
If you are an EU individual, please refer to section 21, which deals with matters specific to EU individuals.
2. Acknowledgement
By continuing to use the websites and/or services or when you make an application to use our services or purchase goods from F+WV, you acknowledge that you have read this Policy and acknowledge and consent to F+WV collecting, holding, using and disclosing personal information supplied by you through your use of the websites and/or services. You also consent to F+WV retaining and/or using personal information provided by you subject to the terms of this Policy, the websites and any other applicable contracts that apply to any goods or services we provide to you.
3. Information of Third Parties
If you provide us with personal or sensitive information of third parties, you will be responsible for informing the individual and obtaining the individual’s consent for their personal or sensitive information to be provided to F+WV for the purposes indicated in the corresponding sections of this Policy or as otherwise indicated at the time of collection.
4. Purpose
The purpose of this Policy is to:
• clearly communicate the personal and/or sensitive information handling practices of F+WV;
• enhance the transparency of F+WV’s information collection processes, and
• give individuals a better and more complete understanding of the sort of personal and/or sensitive information that F+WV holds, and the way F+WV handles that information.
5. Personal Information
In this Policy, “personal information” has the same meaning as defined by section 6 of the Privacy Act:
information or an opinion about an identified individual, or an individual who is reasonably identifiable:
a) whether the information or opinion is true or not; and
b) Whether the information or opinion is recorded in a material form or not.
Personal information may include your name, address (including previous addresses), contact telephone number(s), email addresses and/or other information that is necessary for the delivery of our goods or services to you.
6. Sensitive Information
In this Policy, “sensitive information” has the same meaning as defined by section 6 of the Privacy Act. Sensitive information may include information or an opinion about your membership of a professional or trade association or your health information.
7. Collection
In the course of regular business activity, F+WV will from time to time collect and deal with your personal and/or sensitive information.
If you do not want any of your data collected, you can stop using our websites or services at any time (subject to applicable contracts).
F+WV collects personal and/or sensitive information from individuals in numerous ways, including when an individual:
• visits our websites, social media channels or mobile applications;
• emails F+WV for any reason, including inquiries, comments and complaints;
• telephones F+WV;
• completes an expression of interest form;
• provides F+WV with personal information, including for example by providing a business card;
• purchases tickets for an event run by F+WV from F+WV, a related party and/or a third party;
• registers to be a presenter, speaker, exhibitor or participant at an event run y F+WV;
• makes a purchase from F+WV and/or a third party;
• allows any information on social media to be shared with us.
We may also collect personal information about you from other people or organisations. This may include our service partners and contractors (such as a ticketing office), schools or third parties who conduct market research or run competitions and other promotions on our behalf.
Personal information may also be collected where F+WV is required to do so by law (for child protection, work health and safety, medical treatment or other legislation in Victoria or Australia).
F+WV does not generally take steps to:
• verify personal information about any individual disclosed to it; or
• seek additional personal information about any individual on the basis of information disclosed to it,
except in circumstances where it is reasonably necessary for F+WV to do so, including (but not limited to) confirming the identity of an individual seeking access to personal and/or sensitive information.
When collecting information from you – whether it be via our websites, email, hardcopy, face-to-face or any other services – we will take reasonable steps to inform you of why we are collecting the information, the purposes for which we intend to use that information and to whom it may be disclosed.
We will only collect your sensitive information with your consent and where information is reasonably necessary for one or more of our services.
We note that in certain circumstances, if you do not consent to the use of your personal and/or sensitive information as outlined in this policy or at the time of collection, you may not have access to our services and we might not be able to provide you with our services.
8. Cookies
To ensure we are meeting the needs and requirements of our websites users, and to continue to develop our online services, we collect aggregated information through the use of cookies. We use cookies to collect data about your visit and to allow you to navigate from page to page without having to reload each time. You can refuse cookies by using the appropriate setting on your browser, however, if you do so you may not be able to access portions of our websites. The information we store in cookies shall not be linked to any personally identifiable information you submit while on our websites, however, we may also use this data to tailor advertisements to you.
9. Anonymity
A person may choose to deal with F+WV anonymously. However, in circumstances where a person requests details about personal information held by F+WV, they may be required to provide sufficient details to confirm their identity, to ensure that no unauthorised person is provided with access to personal information.
F+WV does not disclose personal information to any person whose identity cannot be verified.
10. Use
F+WV may use your personal information for the following purposes:
• to verify your identity;
• to process transactions;
• to process and make arrangements for an event or our services;
• to send periodic emails or notifications for processing orders;
• to send you information and updates pertaining to our order;
• to send you related good or service information;
• to send you promotional, marketing or other information about our services and/or events through email, postal mail or some other means unless you otherwise instruct us to cease or refrain from sending you such information;
• to send you communications in connection with our goods and/or services and other events;
• providing and contacting you in relation to our subscription services, where you have subscribed to our services;
• to contact you about our events through email, postal mail or some other means;
• to conduct research about our goods and/or services;
• to monitor and improve our goods and/or services;
• to allow F+WV to personalise our services;
• to process any inquiries you have about the F+WV, our services or events;
• to respond to your feedback or complaints;
• to endeavour to protect against, identify and prevent fraud and other unlawful activity, claims and other liabilities;
• communicating with you before and after an event; or
• determining and handling your requirements, including special assistance requirements for events;
• providing and contacting you in relation to our subscription services, where you have subscribed to our services;
• contacting you in relation to our market research activities, competitions and events; or
• providing, operating and conducting our market research activities, competitions and events
Any personal information collected by F+WV will be used for the purposes for which it was given to F+WV, for secondary purposes which are related to those purposes, for purposes which you have otherwise consented to, or any other purposes in accordance with the Privacy Act.
We will only use and disclose your sensitive information for the primary purpose for which it was collected or a purpose that is directly related to this primary purpose and is reasonably expected, and you consent to the use and disclosure on this basis or as otherwise required to do so by law. If for example, we have collected information about any medical conditions you are suffering, then you consent to us disclosing this information to our service providers (for example restaurants) if they reasonably have a need to know such information in order to safely supply services for your benefit.
11. Disclosure
We may disclose your personal and/or sensitive information we hold to:
• our directors, officers, employees and other associated companies within our corporate group;
• other related and non-related organisations including your company or organisation if you use our services under a corporate account;
• service providers or contractors who help us provide services (for example, for ticketing services, marketing or remarketing purposes through our websites or other social media channels);
• credit card providers;
• credit reporting and fraud checking agencies;
• debt collection agencies, in the event of your default in payment of monies owed to us;
• government, regulatory and law enforcement agencies where the disclosure is required or authorised by law;
• our professional advisors, including our accountants, auditors and lawyers;
• our related entities;
• third party suppliers of goods or services which you have selected;
• third-party sponsors or co-sponsors of promotions on our websites. Only information collected during a promotion will be disclosed to these parties;
• third parties when we contract out some of our functions and activities; or
• to a law enforcement agency if we are requested to do so by that agency in relation to suspected unlawful activity.
F+WV does not otherwise provide personal and/or sensitive information to any other organisations, government agencies or third parties except in accordance with the Privacy Act.
Where appropriate we may handle personal and/or sensitive information relying on applicable exemptions under the Privacy Act, including but not limited to, the related bodies corporate exemption and the employee exemption.
12. Cross-border data flows
We may disclose your personal and/or sensitive information to recipients located overseas, including but not limited to Italy.
Generally, we will only disclose your personal and/or sensitive information to these overseas recipients in connection with our services, as consented to or permitted by law or where we may use an overseas server to host some or all of our business data, including personal and/or sensitive information.
13. Direct Marketing
F+WV may collect and use personal information for the purposes of F+WV and/or third parties providing direct marketing services to users of the F+WV websites, in accordance with the law.
If you do not wish for your information to be used for direct marketing purposes you may contact F+WV at any time and instruct F+WV to cease or refrain from using your information for direct marketing purposes. Contact details for F+WV are provided below at section 25.
Alternatively, when making purchases or registering with F+WV you may elect to ‘opt out’ of receiving direct marketing from F+WV or other third parties.
14. Subscription to F+WV
If you authorise your email subscription to F+WV, we may provide you with information regarding our goods and services through different means, such as by post, email, or any other equivalent means of communication.
Your subscription to F+WV may entail using personal information to make personalised advertising related to our goods and services available to you via post, email or other equivalent electronic means of communication.
We highlight that in order to improve the services we provide to you, personal information provided by you and related to purchases, preferences and tastes may be used for the purposes of analysis, generating user profiles, marketing studies, quality surveys and improving our customer interaction.
If you are a registered user, you can change your preferences related to the sending of these communications through any relevant directions we provide.
You can also unsubscribe by following the information we provide to you.
15. Storage and Security
We take reasonable steps to protect the personal and sensitive information we hold from misuse, interference, loss and unauthorised access, modification or disclosure. F+WV stores your personal and sensitive information physically and/or electronically and has processes in place to endeavour to ensure the security of your personal and sensitive information, such as encryption of data when it is transferred to our service providers and limitations on access to personal and sensitive information within our organisation.
16. Access to personal information
In situations where F+WV holds personal information about you, you are entitled to be given access to any of your personal information by making a written request to F+WV (subject to certain exceptions).
If you would like access to your personal information please make a written request to our Privacy Officer. Details of how to contact us are set out in section 25.
We will normally provide access without charge.
17. Correction of personal information
In the event F+WV holds personal and/or sensitive information about you and:
1. F+WV is satisfied that the information is inaccurate, out of date, incomplete, irrelevant or misleading; or
2. you believe that any of the information that we hold about you is not current or incomplete,
please make a request to our Privacy Officer for correction (refer to section 25 below).
F+WV will take reasonable steps to correct the information to ensure that the information we hold is accurate, up to date, relevant and not misleading.
18. How long do we keep your personal information?
We will keep your personal and/or sensitive information for so long as is necessary for the purpose for which the personal and/or sensitive information was collected.
19. External Websites
Please note the websites may contain links to other external websites. These links are provided as a convenience to you. F+WV is not affiliated with these sites and accordingly has no control over – and is not responsible for – their content, activities, privacy practice or other policies.
The use of cookies by our partners, affiliates, service providers, and other third parties is not covered by this policy. We do not have access or control over these cookies. Our partners, affiliates, and service providers may use session ID cookies to collect data about your visit to their websites and to tailor and deliver advertising messages to you.
20. Children
Where you are under 18 years of age, consent to F+WV collecting, holding, using and disclosing your personal information will usually be required from your parent or legal guardian.
For your protection, F+WV asks that where you are under 18 years of age, you do not attempt to use the website, services or otherwise provide F+WV with any personal information without the consent of your parent or legal guardian.
F+WV recognises however that in certain circumstances, it may be appropriate for F+WV to obtain these instructions directly from you, where you are under 18 years of age, in relation to giving or withholding consent with respect to the collection, holding, use and disclosure of your personal information.
21. GDPR Compliance
If you are a resident of the European Union (or following Brexit, you are a resident of the UK and the UK has laws equivalent to the GDPR in effect) you have certain rights and protections under the GDPR (or the UK equivalent) regarding the processing of your personal data. This section sets out the additional information that we are required to provide to you under the GDPR. Please note that references to the GDPR also includes references to any UK equivalent.
Where the GDPR applies, the meaning of “personal information” has the same meaning as “personal data” and the meaning of “sensitive information” will apply as information concerning the processing of special categories of personal information (“sensitive data”) under the GDPR.
For the purposes of the GDPR we will either be the “data processor” or “data controller” for any personal information you provide to us in connection with our relationship. The precise role we will be assuming is dependent on the context of our relationship with you and the purpose of the processing being undertaken.
Under the GDPR, use of personal information must be based on a legal basis and we are required to provide you with information about this use. We rely on lawful means of processing your personal data, including the following:
• where it is necessary to fulfil a contract with you. This includes where we collect your personal data to enable us to send you our goods or provide you with our services;
• where you have given us valid consent to use your personal data. We will rely on that consent and only use the personal data for the specific purpose for which you have given consent;
• where it is to further our legitimate interests which could include usage statistics, analytics and internal analysis so we can improve our services to you.
We note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. If you need details about the specific legal ground F+WV is relying on to process your personal data, please contact F+WV.
You acknowledge that we may transfer your personal information (including sensitive information) outside of the EU where the transfer is necessary for (a) the performance of a contract between you and us (for example where you purchase a ticket to attend an event) or (b) putting in place or the performance of a contract concluded in your interest (for example where we engage a service provider, such as a restaurant, to provide services in your interest).
If we process any sensitive data about you (for example information about your health for the purposes of informing us of dietary requirements), then we will obtain separate and explicit consent from you for our processing of this sensitive data.
22. Your right as an EU or UK Resident
Under certain circumstances or if you are a resident of the EU or UK, you have various rights under the GDPR in relation to your personal information, including the:
• Right to be informed;
• Right of access;
• Right to rectification;
• Right to object/ withdraw consent;
• Right to restriction of processing;
• Right to erasure or to be forgotten;
• Right to data portability; and
• Right not to be subject to automated processing.
To exercise any of these rights please contact F+WV via the contact details set out in section 25.
23. Withdrawing your consent as an EU or UK resident
Where our lawful basis for processing of your personal data is based on your explicit consent you can withdraw your consent to our collection or processing of your personal data. You can do so by contacting us or by opting out of email communications by following the instructions in those emails or by clicking unsubscribe. If you withdraw your consent to the use of your personal data, you may not have access to our services and we might not be able to provide you with our services. In some circumstances, where we have a legal basis to do so, we may continue to process your information after you have withdrawn consent. For example, if it is necessary to comply with an independent legal obligation or if it is necessary to do so to protect our legitimate interest in keeping our services secure.
24. General
Please note that we reserve our right to amend, remove or vary this Policy at any time without notice. You should check this page regularly to take notice of any changes we may have made to this Policy.
25. Contact
Your privacy is very important to us. For that reason, if you have any questions or concerns about how F+WV handles and safeguards your personal and/or sensitive information or if you wish to access, amend personal and/or sensitive information we hold about you or require a copy of this Policy, please make a request in writing.
Mail:
Food + Wine Victoria Ltd, Level 27/ 727 Collins Street, Docklands Victoria Australia 3008
Please attention the Privacy Officer
Email: info@foodandwinevic.com.au
Phone: 03 9823 6100
In the event that you decide to contact us for any of the reasons above, we request that you please provide us with sufficient details regarding your reason for getting in touch with us.
We note that if necessary, we will ask you to provide us with a copy of your ID card, passport or another valid identity document.
26. Complaints
If you wish to complain about our handling of your personal and/or sensitive information, or if we do not agree to provide access to personal and/or sensitive information or to amend or annotate the information we hold about you, you can:
• escalate your enquiry to F+WV to a formal complaint in writing or by email to the Privacy Officer using the details set out in section 25 above; or
• Pursue the matter further with the Office of the Australia Information Commissioner (OAIC).
We will investigate and consider any complaint received by us and a response will be provided to the complainant as soon as practicable.
If you are not satisfied with the way in which we handle your enquiry, have a complaint about any practice, procedure or action taken in regard to your personal and/or sensitive information, you can contact the OAIC. Current contact details for the OAIC are available on the OAIC’s website at http://www.oaic.gov.au/about-us/contact-us-page.
If you are located in the European Union, and the GDPR applies to you, you have the right to complain to the local data protection authority within the EU in relation to the GDPR. Current contact details for your local authority are available on the European Commission website at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
Last Updated: 9th July 2019