Privacy policy

1. ABOUT US
Vintage Spirit (ABN 51 605 068 380, Us, We, Vintage Spirit and its related
companies) creates and sells premium jewellery.
This policy describes how the Vintage Spirit group handles your personal information.
You can find out more about the Vintage Spirit Group on our website.

2. YOUR PRIVACY IS IMPORTANT TO US
We keep your information safe. We aim to be clear and open about what we do with
it.

We understand that your privacy is important to you, and we value your trust. That’s
why we protect your information and aim to be clear and open about what we do with
it.

This policy describes how we handle your personal information – that is, information
that identifies you or can be reasonably linked to your identity. When we collect this
information, we follow the obligations set out in the Privacy Act 1988 (Cth).
We update our privacy policy when our practices change. You can always find the
most up-to-date version on our website.

3. WHAT INFORMATION DO WE COLLECT?
We collect information about you when you interact with us. We may also collect
information about you from other people and organisations.
We only collect your personal information when we need it to provide our products
and services or to comply with the law. The kinds of information that we collect
depends on how you interact with us. Here are some examples.
Information we collect from you

3.1. We collect the name and contact details (landline, mobile, email) of our
customers and their authorised representatives as well as shareholders,
business contacts, job applicants and contractors and others. We may also
collect:

3.1.1. If you are a customer: Your date of birth, address (supply and mailing
if different), concession details (where applicable), other forms of
identification (such as driver’s licence or passport), payment details, ABN (if applicable) and information about your use of our products and
services.
3.1.2. If you are an authorised representative on another person’s account:
first name, last name, date of birth, telephone number, address and
the relationship with our customer.
3.1.3. If you are a shareholder: Your tax file number, if you provide it.
3.1.4. If you apply for a job with us: Information that you provide about your
right to work, employment history, qualifications and ability.
3.1.5. If you give us personal information about other people, we will assume
that they have agreed that you can do this.

3.2. Information we collect from others
3.2.1. When you get a quote to apply to open an account with us: Your
business credit history information.
3.2.2. When you use our websites mobile apps and platforms: Your IP
address, device identifiers and information about how you use our
websites. We use web analytics services to do this, including Google
Analytics, Google AdSense, DoubleClick, Adobe or Microsoft.
3.2.3. When you participate in market research about us: Information about
you and your responses from the service provider that conducted the
research.
3.2.4. When you engage with our sales partners: Your name, address and
contact details, so we can contact you about products you may be
interested in.
3.2.5. If you are a business contact for our customers or service providers:
Your name, job title and contact details.
3.2.6. If you are a shareholder: To comply with the law and manage your
shares in Vintage Spirit Group, we may collect details about your
investment from our shareholder register service provider.
3.2.7. If you apply for a job with us: Professional background, qualifications
and memberships, and references from your former employers. Where
it is relevant to the role, we may also collect screening check
information (such as background, medical, drugs and alcohol, criminal
records, bankruptcy, directorship and company checks), and abilities
testing, including psychometric testing.

3.3. Sensitive information
The Privacy Act protects your sensitive information, such as information about
your health or ethnicity. Where we need this information for your account (for
example, to ensure continuous service to you or to assist with translation
services), we’ll ask for your permission — except where otherwise allowed by
law.

4. HOW DO WE USE YOUR INFORMATION?
We use your information to deliver our products and services, manage our business
and comply with the law. We also use your information for other reasons, such as to
better understand you and your needs.

4.1. We collect and use your information so we can:

4.1.1. confirm your identity
4.1.2. provide you with the products and services that you have asked for
4.1.3. handle payments and refunds
4.1.4. communicate with you about your account
4.1.5. respond to applications, questions, requests or complaints that you
have made to us
4.1.6. improve customer experience and do market research
4.1.7. if you are a shareholder, manage your shareholding
4.1.8. if you have applied to work with us, assess your application
4.1.9. investigate possible fraud and illegal activity
4.1.10. comply with laws, including assisting government agencies and law
enforcement investigations, and
4.1.11. manage our business.

If we don’t have your personal information, we may not be able to do
these things. For example, we may not be able to deliver the products
or services you have asked for, or respond to your questions.

4.2. Direct marketing
We may also use your personal information to tell you about products or
services that we think you might be interested in. We may send you marketing
messages in various ways, including by mail, email, telephone, SMS, and
advertising through our apps, websites, or third-party websites.
If you tell us how you would prefer to be contacted, we will contact you in that
way where we can.
If you don’t want to receive direct marketing messages, you can opt out:

4.2.1. by following the instructions in any marketing communication you
receive from us (for example, using the ‘unsubscribe’ link in an email
or responding to an SMS as instructed)
Please note that we may still send you important administrative and
safety messages even if you opt out of receiving marketing
communications.
4.2.2. Using data to give you better service
We’re always working to develop and improve our products and
services, and ensure that they better meet your needs.
New technologies let us combine information we have about our
customers and users with data from other sources, such as third-party
websites or the Australian Bureau of Statistics.
4.2.3. We also collect information about people that does not identify them
such as website and advertising analytics, and data from service
providers.

We analyse this data to help us learn more about our customers and
improve our products and services. Where we work with partners or
service providers to do this, we do not pass on personal information
about you.

5. WHO DO WE SHARE YOUR INFORMATION WITH?
We share your information for the purposes set out in section 4, with our service
providers, and to comply with the law. When we do this, we take steps to keep your
information safe.

5.1. We share your personal information with other people and companies where
we need to for the purposes set out in section 4. This includes sharing:

5.1.1. With other companies that help us deliver our products and services,
or to migrate your service if you change service providers
5.1.2. with credit reporting agencies to process new applications
5.1.3. with insurance investigators
5.1.4. with people that you have asked us to give your information to, such
as your authorised representatives or legal advisors
5.1.5. if you have applied to work with us, with your previous employers to
confirm your work history
5.1.6. to comply with laws, and assist government agencies and law
enforcement.

5.2. We also share personal information with people and organisations that help
us with our business, such as professional advisors, IT support, and corporate
and administrative services including debt collectors. We only do this where
it’s needed for those services to be provided to us. When we do this, we take
steps to require our service providers to protect your information.

Vintage Spirit’s website links to a number of third party websites. We are not responsible for the privacy practices of these other sites. We recommend that
individual’s review the Privacy Policy on these websites.

5.3. Sending personal information overseas
Some of our service providers are located or operate outside of Australia.
Where we need to, we send them information so that they can provide us
services. The countries where our service providers may be located are New
Zealand, Canada, the USA and some member states within the European
Union.

6. KEEPING YOUR INFORMATION SAFE
We train our staff in how to keep your information safe and secure. We use secure
systems and environments to hold your information. We only keep your information
for as long as we need it.

We store the information we collect in secure buildings and systems, or using trusted
service providers. Here are some examples of the things we do to protect your
information.

6.1. Staff obligations and training

6.1.1. We train our staff in how to keep your information safe and secure.
6.1.2. Our staff are required to keep your information secure at all times, and
are bound by internal processes and policies that confirm this.
6.1.3. Access to personal information is controlled through access and
identity management systems.
6.2. System security
6.2.1. We take steps in accordance with the Guide to Securing Personal
Information published by the Office of the Information Commissioner,
to secure our systems and the Personal Information we collect.
6.2.2. We also share non-personal information about how people use our
websites with security service providers to ensure that our websites
are protected.
6.3. Services providers and overseas transfers
6.3.1. When we send information overseas or use service providers that
handle or store data, we require them to take steps to keep your
information safe and use it appropriately.

6.4. Building security
We use a mix of ID cards, alarms, cameras, guards and other controls to
protect our offices and buildings.

6.5. Destroying or de-identifying data when no longer required
We aim to keep personal information only for as long as we need for our
business or to comply with the law.
When we no longer need personal information, we take reasonable steps to
destroy or de-identify it.

7. ACCESSING, UPDATING AND CORRECTING YOUR INFORMATION
You can ask to see a copy of the personal information that we hold about you, or ask
us to update or correct it.

You can ask us for a copy of the personal information that we hold about you by
contacting us. Before we give you your information, we will need to confirm your
identity.

7.1. How can you contact us?
See section 9 for details on how you can contact us.

7.2. How long will it take?
We try to make your information available within 30 days after you ask us for
it. If it will take longer, we’ll let you know.

7.3. Can we refuse to give you access?
In some cases, we can refuse access or only give you access to certain
information. For example, we’re not able to let you see information that is
commercially sensitive. If we do this, we’ll write to you explaining our decision.

7.4. Can you correct or update your information?
You can ask us to correct or update any of your personal information that we
have. If we’ve given the information to another party, you can ask us to let
them know it’s incorrect.

If we don’t think the information needs to be corrected, we’ll let you know why.
You can ask us to include a statement that says you believe our record about
you is inaccurate, incomplete, misleading or out of date.

8. MAKING A PRIVACY COMPLAINT
If you’re concerned about how we’ve handled your information, let us know and we’ll
try to fix it. If you’re not satisfied with how we handled your complaint, you can
contact the Australian Privacy Commissioner.

8.1. How can you make a privacy complaint?
If you are concerned about your privacy or how we’ve handled your personal
information, you can make a complaint and we’ll try to fix it. See section 9 for
details on how you can contact us.

8.2. How do we manage privacy complaints?

8.2.1. We will:
8.2.1.1. keep a record of your complaint
8.2.1.2. respond to you about your complaint and let you know how we
will try to resolve it and how long that may take.

8.2.2. What else can you do?
If you’re not satisfied with how we have managed your privacy
complaint, you can contact your local Ombudsman at any time for
advice or to make a complaint. The Ombudsman is independent, and
their services are free.

You can also complain to the Australian Privacy Commissioner who
can be found at the Office of the Australian Information Commissioner
(OAIC).

9. CONTACT US
To ask us a question, access your personal information, request a correction to your
personal information, make a complaint, or get a printed copy of this policy, please
email info@vintagespirit.com.au