PRIVACY POLICY

INTRODUCTION

Saleyards Distillery Pty Ltd (Capricorn Distilling Co.) is committed to respecting the privacy of your personal information. This Privacy Policy explains how we deal with your personal information that we collect, use, disclose or process. We will update this Privacy Policy from time to time when we change how we deal with personal information. We will post any changes to the Privacy Policy on our website, and will endeavour to notify you when this occurs. Definition of personal information Throughout this Privacy Policy, we use the term ‘personal information’ to refer to information relating to an identified or identifiable natural person, including 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. For example, your full name, date of birth, address, mobile telephone number, email address and credit card details are examples of information which may constitute personal information. Personal information may also include information we may collect about your individual preferences. Problems, complaints or queries If you have any questions about our Privacy Policy, or any problems or complaints about how we have collected, used, stored, handled, disclosed and/or processed your personal information, please contact our privacy officer via one of the following channels:

Saleyards Distillery:
21 Ern Harley Drive, Burleigh Heads QLD 4220
Email: hello@capricorndistilling.com

Please allow 30 days for this request to be processed. On receipt of your query, problem or complaint a review will be conducted and findings will be communicated to you where required. If you do not receive a satisfactory response to your query, problem or complaint within 30 days, you may refer your query, problem or complaint to the Office of the Australian Information Commissioner via the contact details listed at https://www.oaic.gov.au/contact-us, or, for individuals in the EU, to the data protection supervisory authority in your country.

ON WHAT BASIS DO WE PROCESS YOUR DATA?

Lawful basis of processing Capricorn Distilling Co. will only collect, monitor, use, disclose, or process any personal information about you with your consent (which we endeavour to obtain at the same time as collecting your personal information) or if it is otherwise lawful to do so. The only personal information collected by us is what has been provided to or collected by us in accordance with this Privacy Policy or has been provided to us lawfully by third parties. We will generally deal with your personal information for the primary purposes set out in this Privacy Policy.

Capricorn Distilling Co. also reserves the right to use, disclose or otherwise process any personal information to satisfy any law, regulation or legal request, or in relation to Capricorn Distilling Co.’s other legitimate interests such as where that personal information is relevant to legal action relating to Capricorn Distilling Co.

WHEN AND HOW DO WE COLLECT PERSONAL INFORMATION?

Collection channels We (or our subcontractors) collect and combine personal information in a number of ways through the following channels (each, a Collection Channel): our online properties (here and after, each a “Website”), including: our websites, including but not limited to www.capricorndistilling.com.au; any related Capricorn Distilling Co. website, social media page, internal website, intranet and any Capricorn Distilling Co. mobile or tablet applications; our service providers acting on behalf of us (including but not limited to Eventbrite and Pozible), or other legitimate third party sources; physical and other ad-hoc channels of collecting personal information in relation to events and the Capricorn Distilling Co. distilleries (such as through paper forms or tablets); and any other means through which an individual provides personal information to Capricorn Distilling Co. ,including either physically or electronically. Active Information Collection Personal information may be collected and combined via our Collection Channels if you: you purchase products either as a “guest” or a “member” through a Collection Channel, or create an account with Capricorn Distilling Co. through a Collection Channel; subscribe to any newsletters, updates, alerts or news and media releases, or request launch or event information or information about our products or services or other information services as well as third party products or services; have previously provided us with personal information prior to this Privacy Policy coming into effect, either directly from you personally or via a third party; complete and submit any forms or surveys provided to Capricorn Distilling Co., either physically or electronically; conspicuously publish or provide on request your personal information Capricorn Distilling Co; contact us or our clients directly in person or via any medium including mail, telephone, social media and commercial electronic messages (SMS (Short Message Service), MMS (Multimedia Message Service), IM (Instant Messaging) and email) including via the contact details listed on a Website; participate in any events, offers, promotions, competitions or marketing activities; interact with a Website for a specific purpose; or interact with or browse a Website generally. We also collect your information through other legitimate third party sources including list brokers, social media organisations, and other data providers or organisations that share data in circumstances where it is lawful and/or you have given permission for them to do so. We may collect personal information from you in a passive manner including through the use of cookies and other tracking tools such as internet tags, tracking pixels, web beacons and unique device identifiers.

WHAT KIND OF PERSONAL INFORMATION DOES CAPRICORN DISTILLING CO. COLLECT?

We may collect personal information including: your full name, contact details (such as your email address, phone number, and contact preferences), location, and passwords you create for the Capricorn Distilling Co. website; information about your preferences, interests, opinions, feedback and experiences with our products or services. This information is collected in order to tailor our communications to you and continuously improve our products and services; financial details, if you have provided them to us, such as your bank account, credit card, Paypal or other online payment system details (where you purchase any products or services from us); When you visit the Capricorn Distilling Co. website, we may also collect personal information about you in the following general categories: usage and preference information: we collect information about how you interact with the Capricorn Distilling Co. website, including the pages you visit, your preferences and settings that you choose. We may do this through the use of cookies and other similar technologies that uniquely identify you; device information: we may collect information about your mobile device such as the hardware model, operating system, preferred language, unique device identifier and mobile network; and other information: we may also collect and log information such as your IP address, access dates and times, browser type and pages visited when you interact with a website. any other personal information you provide directly to us. Where you provide us with unsolicited personal information, we will retain this information where it falls within our primary purposes for collection of personal information (as stated in this Privacy Policy). any other personal information requested or required by a Collection Channel. Sensitive Information We do not seek to collect sensitive information (or “special categories” of information under the GDPR). If we do collect sensitive information, we will only do so with your consent and where you provide it to us directly. Where you provide us with any sensitive information (including, but not limited to, information about your sexual orientation, religious beliefs, medical and/or criminal history), we will only use this information for the purposes stated at the time of collection and will only share this information with our trusted third parties in the manner stated in this Privacy Policy. Consequences of not providing personal information 1. If you don’t provide us with personal information, we may be unable to provide you with our goods and services or other content, information, upcoming opportunity, promotion, event or product information.

FOR WHAT PURPOSES DOES CAPRICORN DISTILLING CO COLLECT, HOLD, USE AND DISCLOSE PERSONAL INFORMATION?

1. Personal information that Capricorn Distilling Co. collects will be used for the following primary purposes: Special offers, marketing and advertising a. where you have provided your separate consent, to provide you with early access to new releases, exclusive events, special offers, newsletters, events and promotions either of Capricorn Distilling Co. or its trusted partners, and to otherwise market to you (with direct marketing materials), via any medium including mail, telephone, commercial electronic messages (such as SMS, MMS, instant messaging, email, social media, mobile applications), or any other form of electronic, emerging, digital or conventional communications channel.; b. to provide you with relevant advertising; Managing our relationship c. to carry out any purchases you make and otherwise manage our commercial and trading relationship with you including identifying you in our system and contacting you, invoicing you correctly, sending you our products and to address your expectations of us in respect of how we conduct our business; d. to ensure that your personal information remains up-to-date and complete; e. to provide you with information about your Capricorn Distilling Co. account, customer account, transactions, content, services and products; f. to fulfil obligations in respect of any contract between you and Capricorn Distilling Co.; to render services related to our Capricorn Distilling Co. and customers (such as after sales services and enquiries); to facilitate payments from you; g. to contact you, including sending you any technical, administrative or legal notices relevant to Capricorn Distilling Co. or the Capricorn Distilling Co. Websites; h. to otherwise maintain our relationship with you; Capricorn Distilling Co.’s Website i. To maintain the functionality of the Capricorn Distilling Co. website, including the provision of information to you relating to the content available on the website; to improve the website and system administration; Improving our offerings j. to better understand and meet your needs and interests, to enable us to improve the nature of the goods and services we provide and to more accurately market our goods and services, and research our customers; k. to obtain opinions or comments about products and/or services and to conduct other research and development; l. to record statistical or de-identified data for analysis including marketing analysis; m. to conduct market research including identifying like minded individuals; Miscellaneous n. to share personal information with our group companies and their related bodies corporate and agents, and other trusted third parties in the manner described in this Privacy Policy; o. for any further purposes stated in a particular Collection Channel; p. where explicitly notified to you, to undertake recruitment for Capricorn Distilling Co.; q. to manage your employment with Capricorn Distilling Co. (if applicable); r. any other purpose as may be deemed reasonably necessary by Capricorn Distilling Co. in the circumstances; s. as needed to satisfy any law, regulation or legal request, to protect the rights or property of Capricorn Distilling Co., any member of the Capricorn Distilling Co. group, or any member of the public, to protect the integrity of the Capricorn Distilling Co. website, to fulfill your requests, or to cooperate in any law enforcement investigation or an investigation on a matter of public safety. Capricorn Distilling Co. does not send advertising or marketing information without obtaining prior consent, for example the consent contained within this Privacy Policy. If you receive communications from Capricorn Distilling Co. which you do not wish to receive, you may remove your name from the database either by using the functional unsubscribe facility (if the communication is via commercial electronic message) or by contacting Capricorn Distilling Co. Privacy Officer as described above. Please allow 30 days for this request to be processed. Despite removing your name from the database from receiving future advertising and marketing information, Capricorn Distilling Co. may send you non-commercial “Administrative Emails”. Administrative Emails relate to a Capricorn Distilling Co. user account and may include administrative and transaction confirmations, requests and inquiries or information about a particular Capricorn Distilling Co. user account. If you do not wish to receive such communications from Capricorn Distilling Co., you may remove your name from the database by contacting Capricorn Distilling Co. Privacy Officer. Please allow 30 days for this request to be processed. Automated decision-making Capricorn Distilling Co. does not make decisions that produce significant effects on you which are solely based on automated decision making.

HOW DO WE SHARE YOUR PERSONAL INFORMATION?

Solely for the purposes described above, personal information may be shared with the entities below including their directors, servants and agents and related bodies corporate: our marketing and email sending partners; technical service providers, such as mail carriers, hosting providers, IT companies and communications agencies; other trusted service providers; and Capricorn Distilling Co. group companies (if applicable). These recipients may be engaged by Capricorn Distilling Co. to perform a variety of functions, such as legal and accounting services, data storage, support services, conducting market research, processing credit card payments, assisting with promotions and providing technical services for our websites. These companies may have access to personal information if needed to perform such functions. Your credit card details are only used to facilitate your purchase. They are not used for any other purpose and will never be supplied to a third party other than Capricorn Distilling Co. or our relevant service provider. If you are a business we trade with, we may disclose your information to debt recovery agents or credit reporting bodies if necessary. Some of the recipients of your personal information may be located overseas. Capricorn Distilling Co. employees, data processors and other trusted third parties are obliged to respect the confidentiality of any personal information held by Capricorn Distilling Co.. However, security of communications over the Internet cannot be guaranteed, and therefore absolute assurance that information will be secure at all times cannot be given. Capricorn Distilling Co. will not be held responsible for events arising from unauthorised access to personal information except to the extent required by the relevant privacy laws. The recipients of your personal information are located in countries including Australia, the United Kingdom and the United States.

HOW DO WE HOLD, AND LONG DO WE HOLD YOUR PERSONAL INFORMATION?

Security Capricorn Distilling Co. takes appropriate security measures to keep personal information secure and to prevent unauthorised access, disclosure, modification or destruction of personal information. Capricorn Distilling Co., its employees and its subcontractors are obliged to respect the confidentiality of any personal information held by Capricorn Distilling Co.. Capricorn Distilling Co. also takes reasonable steps to keep personal information accurate, up to date, complete and relevant. Capricorn Distilling Co. takes reasonable steps to ensure only those necessary have access to your personal information. Personal information is stored on secure servers that are protected in controlled facilities. This service may be performed on our behalf and data may be hosted by our selected data storage providers. In some cases these facilities may be overseas, as described above. Capricorn Distilling Co. retains your information only for as long as necessary for the purposes listed in this Privacy Policy.

YOUR PRIVACY RIGHTS

You have a number of rights under the Australian Privacy Law and the GDPR. These include: (access) to request access to your personal information from us, in a commonly used electronic format. On a case by case basis, Capricorn Distilling Co. may determine that it is not legally required to give an individual access to personal information, in which case Capricorn Distilling Co. will provide you with a written notice of its refusal to provide access; (correction) to request that we correct your personal information; (withdrawing consent) to withdraw your consent for us to use your personal information. Please note that you can also opt-out of online marketing communications at any time by using the unsubscribe feature in each electronic commercial message; (transparency) to be informed generally about the collection and use of your personal data, including where we intend to further process your personal data for additional purposes other than as discussed above; and (complaint) to complain about a breach of the Australian Privacy Principles. (deletion) you may also request that we delete your personal information, and all reasonable steps to delete the information will be made, except where it is required for legal reasons. Deletion of information may result in Capricorn Distilling Co. and its service providers or partners being unable to facilitate or provide you with information about certain transactions (including the uploading, access to, and receipt of content on a Website), other product content, or services information, upcoming promotion, competition or event information, and/or provide certain content, goods or services. Unless required by applicable law, we are not responsible for removing your personal information from the lists of any third party who has previously been provided your information in accordance with this policy. MISCELLANEOUS User submissions Capricorn Distilling Co. may provide areas on a Website where you can upload user-generated content, post or provide information about yourself, communicate with other users, provide reviews for content, products and/or services or interact with or vote on particular content. This information may be shared with others and may be publicly posted on our Websites, including without limitation, other social media platforms and other public forums in which you choose to participate. This information may become publicly available and may be read, collected and used by others outside of our Websites. Capricorn Distilling Co. is not responsible for the conduct of others who may read, collect and use this information.