Privacy Policy

Effective: 15 March 2022

Introduction

This Privacy Policy outlines the ways in which Naked Wines Ltd Australia Pty Ltd ("Nakedwines.com", "we", "us", "our") collects, uses and shares your information. It applies to information we may collect about you when you access or use our website, nakedwines.com.au (the "Website"), or mobile application (the "Application"), purchase our products or services (the "Products") or communicate with us in any way, e.g., email, telephone or in person.

Please read this Privacy Policy carefully. Your privacy is important to us and we want you to understand how and why we collect, use and share your information. If you have any questions regarding this Privacy Policy, please feel free to contact us at  privacy@nakedwines.com.au .

BY ACCESSING AND/OR USING OUR WEBSITE, APPLICATION AND/OR PRODUCTS, OR BY COMMUNICATING WITH US IN ANY WAY, YOU REPRESENT THAT YOU HAVE READ AND UNDERSTOOD THIS PRIVACY POLICY.

Information Collection and Use

We may collect information about you in three ways — directly from you, automatically when you access or use our Website or Application and from third parties. This information allows us to serve you in a number of ways, for example, by providing the Website and Application to you, fulfilling an order you've placed and responding to your inquiries.

Here are a few examples of ways we may collect information directly from you:

Order Placement.  When you place an order with us, you provide us with your name, email address, shipping and billing addresses, phone number, certain credit card information (type, expiration date and last four digits), your birthday and your order details. We may use this information to process payment, fulfil your order, send you marketing communications, and ensure that your order complies with all applicable laws,  e.g.,  we don't sell wine to persons under 21 years of age.

Angel Sign-Up.   When you sign up to be an Angel, you provide us with your name, email address, shipping and billing addresses, phone number and certain credit card information (type, expiration date and last four digits). We may use this information to process your Angel contributions, keep you informed regarding our products and promotions and ensure you have access to all of our Angel program benefits.

Voucher Registration.   When you register a Naked Wines voucher, you provide us with your email address. We may use this information to send you marketing materials that we believe will be of interest to you.

Communications with Customer Service Agents.   When you reach out to our customer service team, your written communications with our customer service agents,  e.g.,  email and live chat, are stored and your phone communications with our customer service agents are sometimes recorded. We may use this information to assist us in resolving your inquiries and to help us serve you better in the future.

Comments and Posts on our Website and Application.   When you post on our Website or Application,  e.g.,  provide comments, upload images or videos, join groups or rate wines, your posts are available to us. We may use this information to assist us in resolving your inquiries, generate appropriate wine recommendations for you and improve your customer experience.

Here are a few examples of ways we may collect information automatically when you access or use our Website and Application:

Browsing Activities.  When you access or use our Website or Application, we may collect information about your browsing activities, including the pages you viewed, the links you clicked and page response time and download errors. We may use this information to optimize our Website and Application and improve your customer experience.

Device Information.   When you access or use our Website and Application, we may collect information about your web browser, device and operating system. Like the browsing activity information described above, we may use this information to optimize our Website and Application and improve your customer experience.

Here are a few examples of ways we may collect information from third parties:

Business Partners.   When you shop with certain of our business partners, those partners (depending on their own privacy policies and data sharing practices) may provide us with certain contact information for you, such as your email address.

Social Media Accounts.  When you log into our Website or Application from a social media account, we may use information from that account to auto-populate your Nakedwines.com customer profile. For example, instead of asking you to provide your name, we may auto-fill the "name" field with the name you've used in your social media profile. We may also access your contact list for purposes of facilitating invitations from you to your contacts to join Naked Wines and connecting you on our website with your contacts who are already using Naked Wines ( e.g. , a “Find Friends” feature”).  We do not collect or store your contact list data.We may also collect your contacts for purposes of connecting you with friends, who are also Naked Wines customers, on our Website and Application.

Here are some examples of additional information we may collect directly from you, automatically when you use or access our Website or Application or from third parties:

  • Your account balance;

  • Your transaction, membership, order, refund and voucher redemption histories;

  • Links to your social media pages;

  • Certain of your IP addresses; and

  • Persons you've invited to try our Website, Application or Products.

Here are some examples of additional ways we may use your information:

  • Creating and managing your account, orders and subscriptions;

  • Operating, evaluating and improving our Website, Application and Products;

  • Operating, evaluating and improving our business;

  • Complying with laws, regulations and other legal requirements;

  • Complying with relevant industry standards;

  • Complying with our policies;

  • Protecting you, ourselves and other users against unlawful activity, including identity theft and fraud;

  • Protecting and enforcing your rights, our rights and other users' rights under any agreements we've entered into with you, other users or third parties;

  • Maintaining the security of our Website, Application and Products;

  • Providing you with information and advertisements about products, services and promotions, from us or third parties, that may interest you; and

  • Facilitating other marketing activities, for example, compensating third parties who refer you to our Website and Application.

Information Sharing

We may share information about you in the following ways:

With your consent.  In some cases, we'll get your permission before we share your information. For example, we may ask for permission in writing, in person or on the phone, through online “click-through” agreements, when you accept the terms and conditions of our Application and Website or by other means.

In a business transfer.  We may share your information as part of a corporate business transaction, such as a sale, merger, consolidation, change in control, transfer of assets, acquisition, joint venture, corporate reorganization, financing or liquidation or in the unlikely event of insolvency, bankruptcy or receivership.

With related entities, i.e., our parent companies, companies under the control of our parent companies and our subsidiaries.  We may share your information with other companies in the Naked family, including our parent companies — e.g., Naked Wines PLC and Naked Wines International Ltd. — and companies under the control of our parent companies — e.g., www.nakedwines.com Limited and Nakedwines.com, Inc.

With service providers.  We may share your information with service providers, i.e., third parties who perform services on our behalf, such as payment processing, compliance checks, billing, shipping, auditing, marketing and customer service.

With business partners.  We may share your information with business partners, i.e., third parties with whom we've entered into business relationships or partnerships. We allow some of these business partners to place cookies or pixels on our site, which provide them with information regarding your activities on the Website or Application, including whether or not you've placed an order in response to an advertisement hosted by the business partner, whether you've used a voucher to place that order and whether you've signed up to become an Angel.

For legal reasons.  We may share your information for purposes of complying with a law, regulation, subpoena, audit or other government investigation or request. We may also share your information for purposes of enforcing our legal rights, e.g., to enforce our agreements, collect outstanding debts, protect our property rights or prevent fraud and abuse.

Information Security

The security of your information is important to us and we take commercially reasonable steps to make sure your information is protected. Although no system can guarantee the complete security of your information, we use our best efforts to maintain commercially reasonable technical, organizational and physical safeguards, consistent with applicable law, to protect your information.

Information Retention

We keep your information for as long as we need to in light of the purposes for which it was collected, our business needs and our legal and regulatory obligations. We may store some information indefinitely, including after your relationship with us has ended. If we dispose of your information, we will do so in a way that is secure and appropriate to the nature of the information we are disposing.

Third Party Technology

Third party cookies/"Do Not Track."  As explained above, we allow some of our business partners to place cookies or pixels on our site that track certain of your activities on our Website and Application. Some browsers support a "Do Not Track" feature, which is intended to signal to websites that you do not wish to be tracked. Unless otherwise required by law, our Website and Application do not change the way they operate based upon detection of a "Do Not Track" signal.

Third party links and websites.  Our Website and Application may also contain links to third-party websites. These websites are not governed by our Privacy Policy, which applies as described above. We encourage you to read the privacy policies and notices provided by any third-party websites you visit.

Social media.  You may choose to connect to us through a social media platform, such as Facebook, Twitter, Google or Instagram. Please be advised that these social media platforms may collect information from you. When you click on a social plug-in, such as Facebook's "Like" button or Twitter's "tweet" button, that particular social network's plugin is activated and your browser is directly connected to that provider's servers. We do not have control over the collection, use and sharing practices of social media platforms. We encourage you to review their usage and disclosure policies and practices, including their data security practices, before using the social media platforms.

Payment Processing.  Payment processing will be carried out by PayPal, which will process such data as an independent data controller pursuant to its privacy statement available at  www.paypal.com . You may exercise your data subjects rights towards PayPal in connection with such payment service by following the instructions in PayPal's Privacy Statement.

Minors

Our Website, Application and Products are not intended for children or any persons under the age of 18. We don’t knowingly collect information, including personal information as defined by applicable law, from children or any persons under the age of 18.

Information Access, Correction and Deletion Requests

If you would like to access or correct the information we’ve retained about you under Australian law, or to request that such data be deleted, please contact us at  privacy@nakedwines.com.au  and provide the following information:

  • Your name and contact details; and

  • The personal information you want to access, correct or delete.

If you're requesting access, please also provide the following information:

  • How you’d like access to the personal information (such as receiving a copy by email or post, or if you just want to look at the information); and

  • If you authorise a person or organisation to access the personal information on your behalf.

Changes to our Privacy Policy

We may change this Privacy Policy from time to time. Any and all changes to our Privacy Policy will be reflected on this page, and where appropriate provided in person or by another electronic method. The effective date will be stated at the top of the Privacy Policy. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you. You should regularly check this page for any changes to our Privacy Policy.

YOUR CONTINUED USE, ACCESS, OR INTERACTION WITH THE WEBSITE, APPLICATION OR PRODUCTS, OR YOUR CONTINUED COMMUNICATIONS WITH US AFTER THE UPDATED PRIVACY POLICY HAS BEEN POSTED WILL REPRESENT THAT YOU HAVE READ AND UNDERSTOOD THIS PRIVACY POLICY.

Contact Us

If you believe your information is being mishandled, please contact us at  privacy@nakedwines.com.au  and we will review your complaint with our legal and security teams.

If you have questions about this Privacy Policy, please feel free to email us at  privacy@nakedwines.com.au  or call us on 1300 898 677.