Privacy Policy

Joval Family Wines Pty Ltd | A.C.N 098 604 212 A.B.N 74 098 604 212 respects the privacy of individuals by treating all personal information as confidential and by handling it in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APP). The full text of the APP is available at www.privacy.gov.au.

In this policy:

• Personal information refers to any information or data provided to us such as name and address, date of birth, contact phone and fax numbers, email address, credit card details, where relevant to the products or services we are providing to you, your financial information;
• Website means sticks.com.au, or a related website operated by the Company; and
• References to 'you' and 'your' mean you, the user of the website and provider of personal information.

Privacy Principles

The Company has implemented internal policies and procedures to ensure that personal information is dealt with in accordance with strict standards of security and confidentiality. By ordering the Company's products and/or using the website, you are deemed to have consented to the collection of personal information required to complete the sales transaction, including your credit card information.

Use and Collection of personal information

The Company collects, uses and stores personal information for the following purposes:

• Identifying its customers and potential customers, including their authorised representatives;
• Processing orders or enquiries received, including via the website;
• Supplying products, services or other benefits to be offered to customers;
• Informing customers of marketing initiatives that may be of interest to them;
• Market and marketing analysis (subject to consent);
• Data processing for statistical purposes (subject to consent);
• Sending advertising materials, newsletters, competition details and other promotional and commercial communication initiatives to customers by email and/or text message; and
• Developing and implementing initiatives to improve our products and services. Any additional purpose for the collection of personal information (not set out in this policy) will be identified at the time that the Company collects personal information from you, or as soon as practicable afterwards.

Where possible, the Company will collect personal information directly from the individual concerned. However, in some circumstances, the Company may need to collect personal information from authorised third parties (for example, your representative). If we are not provided with all the required personal information, we may be unable to process your order or other enquiry.

• When you login to the Company's website and/or online services;
• When you enter any of the Company's competitions and trade promotions;
• When you complete a registration form;
• When you contact the Company about its products and/or services by telephone or using our "contact us" page on our website or any other part of our website;
• During negotiations and/or business transactions with you;
• When the Company supplies products and/or services to you; and
• When the Company responds to an enquiry from you.

Anonymity

If you are making a general enquiry regarding our products through our website, you will not be required to identify yourself. However, if you order goods or services through our online services or website, you will be required to identify yourself so that we can provide the goods and services to the correct person at the correct address.

Disclosure

Except where indicated above, the Company will not disclose your personal information to a third party, unless:

• The disclosure is made as part of giving effect to a purpose for which the information was collected;
• You have consented to the disclosure;
• The third party is an external service provider that assists the Company operate the Company's business and is a party to a confidentiality arrangement with the Company;
• The third party is a person involved in a dealing or proposed dealing (including a sale) of all or part of the Company's assets and/or business;
• That disclosure is to a related body corporate of the Company;
• The disclosure is to an entity that licenses products to the Company;
• The disclosure is reasonably necessary for the establishment, exercise or defence of a legal or equitable claim; or
• The disclosure is permitted, required or authorised by or under any law including under the Privacy Act 1998.

We are not likely to disclose your information to overseas recipients. If in future we wish to disclose personal information to overseas recipients, we will only do so with your consent or otherwise in compliance with the Australian Privacy Principles.

Using the Website

The Company collects and retains data for the purpose of supplying you with, and for the processing of payment for, goods and/or services.

To ensure the Company is meeting your needs, and to develop online services, the Company may collect information from its website server logs. This technology is not used to access any other stored personal information, preventing users from being identified.

The Company may use cookies to collect information from you. Cookies identify a particular computer to the Company's server. The Company may use the information collected in this way to provide the user of that computer with a personalised experience of the website. Your browser may allow you to disable cookies. If you do this, your experience of the website will not be personalised.

Cookies are automatically deleted when you exit the website or close your web browser.

Marketing

The Company may use personal information to advise you of new services and marketing initiatives that may be of interest to you. This may include special product offerings and general information about our business.

If the marketing is received by you by email or by social media, there will be a link on that email or social media contact by which you can unsubscribe from receiving that marketing material.

The Company does not disclose personal information to a third party for the purpose of allowing them to direct market their products or services to an individual, unless that individual has expressly consented to that disclosure.

Updates to your personal information

If your personal information changes, please contact the Company to update this information. The Company may also contact you from time to time to check that your personal information is still accurate.

Security

The Company is committed to maintaining:

• Safeguards to protect personal information against unauthorised use, disclosure, access, alteration, destruction and accidental loss;
• Industry standards for the security and protection of personal information (anti-virus software is regularly updated in order to protect the Company's systems and data); and
• Internal policies on management of personal information, and staff training to ensure compliance with these policies.

Access to Personal Information

Access

The Company will generally allow an individual access to their personal information on request. You can obtain access to your personal information by written request to the Privacy Officer. The Company will endeavour to deal with your request as soon as reasonably practicable.

Restrictions on Access

The Company may restrict access to personal information in accordance with the APP.

Charges for Access

Subject to the level of the request and the amount of time it takes to collate the information, the Company, at its own discretion, may levy a nominal charge for access to personal information.

Correction to Personal Information

Please advise the Privacy Officer if you think that personal information the Company holds is inaccurate. The Company will take all steps necessary to correct the information.

If the Company is unable to provide you with access to your information or make any amendments, the Privacy Officer will inform you of the Company's reasons for this.

Changes to the Privacy Policy

The Company's handling of any personal information it collects from you (including personal information previously collected) will be governed by the most current version of this policy. Please check this policy regularly.

Complaint Resolution

The Company is committed to constantly improving its procedures so that personal information is treated appropriately. If you feel that the Company has failed to deal with your personal information in accordance with the APP or this policy, please contact the Privacy Officer.

The Privacy Officer will:

• Listen to your concerns and grievances regarding the handling of personal information;
• Discuss with you the ways in which the Company can rectify the situation; and
• Put in place an action plan to resolve your complaint and improve the Company's information handling procedures, if appropriate.
• If this process does not result in an outcome that is satisfactory to you, you may contact the Privacy Commissioner's Office. The Company will work together with the Privacy Commissioner's Office to resolve any issues.

The contact details for the Privacy Commissioner's Office are as follows:

Privacy Commissioner
GPO Box 5218, Sydney NSW 2001
Telephone: 1300 363 992; 1800 620 241 (TTY)
Facsimile: +61 2 9284 9666
Email: enquiries@oaic.gov.au

Contact Information

If you wish to access any personal information that we hold about you, or have a query about this policy, please contact our Privacy Officer:

Privacy Officer
Joval Wines Pty Ltd
PO Box 387 Abbotsford Victoria 3067
Email: privacy@joval.com.au

Security Policy

When using online credit card transactions to purchase goods you must provide valid credit card details.

The Company uses the eWAY Payment Gateway for its online credit card transactions. eWAY processes online credit card transactions for thousands of Australian merchants, providing a safe and secure means of collecting payments via the Internet. All online credit card transactions performed on this website using the eWAY gateway are secured payments, as follows:

• Payments are fully automated with an immediate response.
• Your complete credit card number cannot be viewed by the Company or any outside party.
• All transactions are performed under 128 Bit SSL Certificate.
• All transaction data is encrypted for storage within eWAY's bank-grade data centre, further protecting your credit card data.
• eWAY is an authorised third party processor for all the major Australian banks.
• eWAY at no time touches your funds; all monies are directly transferred from your credit card to the merchant account held by the Company.

For more information about eWAY and online credit card payments, please visit www.eWAY.com.au.