Winchester Australia Limited Privacy Policy

Winchester Australia Limited ACN 004 645 318 (referred to as “we” and “us”) is committed to respecting and protecting your privacy. This Privacy Policy (“Policy“) outlines our approach to privacy and how we collect, use and protect your Personal Information.

Personal Information is defined in the Privacy Act 1988 (Cth) and means information or an opinion about an identified individual or an individual who is reasonably identifiable.
We are bound by the Australian Privacy Principles contained in the Privacy Act 1988 (Cth).

Privacy Officer. We have appointed a Privacy Officer who you can contact if you have any concerns in relation to your Personal Information. The contact details of our Privacy Officer are at the end of this Policy.

How we collect Personal Information. Where reasonably practicable, we attempt to collect Personal Information directly from individuals. When we collect Personal Information, we will generally explain to the individual why we are collecting it, who we give it to and how we will use or disclose it or, alternatively, those matters will be obvious from the circumstances. We will collect Personal Information from you by lawful and fair means and not in an unreasonably intrusive way.

We may collect Personal Information from individuals who are not customers of our business but whose Personal Information is given to us by those individuals via our website ( (Website) or in the course of a transaction or recruitment with us.

When you visit our Website, we, and/or third parties, may place cookies on your browser to enhance and manage our Website and improve our business and the services we provide to you. We and/or Google may use this information to optimise and place advertisements, including advertisements of third party vendors, on our own and third party websites. Google’s ability to use and share information collected by Google Analytics is restricted by the Google Analytics Terms of Use and Privacy Policy. By using the Website and agreeing to this Policy, you grant us permission to place and store cookies on your browser. Cookies can be managed by accessing the individual settings in your brower. We will not identify users or their browsing activities, except where required by law.

Categories of Personal Information collected. We collect the following type of Personal information:

Log Personal Information and cookies, such as your IP address, including details concerning your access to our Website, such as date and time, status and data volume transferred, details of the websites that you used to access our Website, your browser type, products you viewed or searched for, information on your browser (type of browser and version number) and other technical device information.

Contact Personal Information, such as your name, date of birth, contact details (email, home and billing address), telephone number, driver’s licence, occupation and references.

Financial Personal Information, such as payment details, bank account information and credit information.

Other Personal Information that you provide to us in the course of a transaction with us or when visiting our Website.

Purpose of collecting Personal Information. We collect your Personal Information for the purposes of conducting our business. This will include the following purposes; to enable you to use the Website, to complete a transaction with us, to provide our services to you, to answer your questions, to consider an employment opportunity with us or to comply with our legal obligations.

You have the option to refrain from providing your Personal Information or you may provide us with incomplete information. However, we may not be able to enter into a transaction with you at all or you may not be able to utilise our Website to the fullest extent possible.

We will not use your Personal Information for automated decision-making. We do not create any personalised profiles using your Personal Information.

Subscriptions. If you subscribe to any service for which we are asking you to provide consent for collecting, using and disclosing Personal Information in a certain way that is not covered in this Policy, you may revoke your consent at any time by notifying our Privacy Officer.

If you have subscribed to a newsletter or a service, we may send you additional information about similar services or products. You may request that we cease sending you this additional information at any time by notifying our Privacy Officer.

Disclosure of Personal Information. We will generally use or disclose your Personal Information only for the primary purpose for which it was collected or for a related secondary purpose where you would reasonably expect us to use or disclose the Personal Information for that secondary purpose. We may otherwise use and disclose your Personal Information if you have given us consent for the use or disclosure or it is required or authorised by law.

Generally, we use and disclose your Personal Information for the purpose of providing you with our goods and services, or otherwise to enable us to carry out our business. This may include:

a. to operate, protect, improve and optimise our services, business and our users’ experience, such as to perform analytics, conduct research and for advertising and marketing;
b. to improve our Website;
c. to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
d. to send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting. You may opt out of receiving these direct marketing communications at any time. Our electronic marketing activities will comply with the requirements of the Spam Act 2003 (Cth).;
e. to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners;
f. to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties; and
g. to consider your employment application.

We will only grant access to your Personal Information for the purposes described above to:
a. our employees and related bodies corporate;
b. third party suppliers and service providers (including providers for the operation of our Websites and/or our business or in connection with providing our products and services to you);
c. professional advisers, dealers and agents;
d. payment systems operators (eg merchants receiving card payments);
e. our existing or potential agents, business partners or partners;
f. specific third parties authorised by you to receive information held by us; and/or
g. other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.

Where your Personal Information is transferred outside Australia for the purposes described above (including to our associated companies in the USA and the EU), we will take reasonable steps to ensure that overseas recipients will deal with that information in a way that is consistent with the Australian Privacy Law.

Retention. You can request that we delete your Personal Information at any time. Otherwise, we will retain your Personal Information in accordance with any retention periods under the law.

Security. We maintain appropriate administrative, technical and physical safeguards to protect your Personal Information against loss, misuse, unauthorised access, disclosure, alteration or destruction.

Third Party Links. Our Website may, from time to time, contain links to and from the websites of our partner networks, third party organisations and affiliates. If you follow a link to any of those websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Personal Information to these websites.

Changes to the Policy. Any changes we make to this Policy in the future will be posted on our Website. Please check frequently to see any updates or changes. If you have signed up to a service that is provided through the Website, you will be notified by email of any changes to the Policy.

Access and complaints procedure. You have certain rights to access the Personal Information we collect and hold about you. We will allow an individual access to the Personal Information we hold about them within a reasonable time after it is requested. You may make a request for access by contacting our Privacy Officer.

We take those steps reasonable in the circumstances to ensure that the Personal Information that we collect, use and disclose is accurate, up to date and complete. Where you request to correct Personal Information, we will take reasonable steps to correct the information, having regard to the purpose for which it is held.

To make a complaint about how we handle your Personal Information, you may contact our Privacy Officer. We will respond to your complaint within a reasonable time after it is received. If you are not satisfied by our response, you may acquire further information regarding privacy from the Office of the Australian Information Commissioner.

Privacy Officer: Simon Murphy
Phone: 03 5245 2434
Last Review Date: July 2018