1. Respecting your privacy

1.1. Left Bank Melbourne Buyers Club ("we, our, us") is committed to compliance with privacy laws which apply to its business and which set out standards for the management of personal information.

1.2. This policy outlines our personal information management practices. Specifically:

• the kinds of personal information we collect and hold;
• how we collect and hold it;
• the purposes for which we collect, hold, use and disclose it;
• your right to access and seek correction of it;
• how you may complain about privacy matters; and
• our sharing of your personal information overseas.

1.3. We have a separate privacy policy concerning our employees - this policy does not apply to the personal information of our employees in their capacity as such.

2. What kinds of personal information do we collect and hold?

2.1. The personal information we collect and hold is what is reasonably necessary for our business functions and activities. When we collect and hold personal information, it is of the following kinds:

• your personal details such as your name, addresses, telephone numbers, age and gender;
• your customer reference number;
• what, how and when you buy from us or have expressed an interest in buying from us.

2.2. Depending on the nature of your dealings with us, we may collect and hold other types of personal information. For example, information collected and held via our secure financial systems about the debit or credit card you might use for your purchases from us.

2.3. You generally have the option of not identifying yourself or of using a pseudonym when dealing with us. But not where this is impractical (for example when you shop online with us) or where the law or a court order provides otherwise.

3. How do we collect and hold personal information?

3.1. When we collect personal information about you, we do so by making a record of it. We do this when:

• you register with us, for example to create an account, to become a member of our Wine Club or to send you information;
• you communicate with us online;
• you take part in our promotions, competitions, testimonials, surveys and focus groups; or
• you deal with us in other ways involving a need for personal information to be provided.

3.2. All of the personal information we collect and hold about you is from your direct dealings with us.

IP addresses

3.3. Whenever you use our web site, or any other web site, the computer on which the web pages are stored (the Web server) needs to know the network address of your computer so that it can send the requested web pages to your Internet browser. The unique network address of your computer is called its "IP address", and is sent automatically each time you access any Internet site. From a computer's IP address, it is possible to determine the general geographic location of that computer, but otherwise it is anonymous.

3.4. We do not keep a record of the IP addresses from which users access our site except where you have specifically provided us with information about yourself, in which case we also record your IP address for security purposes. An example of this would be when proceeding to a checkout to finalise an order you may wish to make. After completing the form provided, your IP address will be stored along with a transaction number that allows us to track your order. Our servers also record your IP address for security purposes, so that in the event that we are legally required to disclose that information, we can do so. This is the only situation where your IP address would be shared with anyone.

Cookies

3.5. We use cookies to allow you to login to your account, maintain a shopping cart and to purchase items in your shopping cart. Cookies sent to your computer only last while you're logged in to, or are browsing our website. These cookies expire either when you logout of, or a short time after a period of inactivity on, our website. Cookies also allow us to give you a more personalised shopping experience by displaying information and/or products that may be of interest to you throughout our website, thus providing you with a more friendly, interesting and enjoyable shopping experience.

3.6. Most web browsers are set to accept cookies, but you can always change your computer settings to stop them. If you choose to do that, you may not be able to take full advantage of our online services.

Google Analytics

3.7. When you visit certain sections of our website, Google Analytics, a website analytics service provided by Google, Inc ("Google"), will place cookies on your computer's browser. The information generated by the cookies about your use of the website is transmitted to Google. This information is then used for the purpose of compiling statistical reports to enable us to measure and analyse the number of visits to our websites and pages, the average time spent on the site and the pages viewed. We will not (and will not allow any third party to) use Google Analytics to track or to collect any personal data of visitors to our websites. We will not associate any data gathered via use of cookies with any personal data from any source as part of our use of Google Analytics. For further information about Google Analytics please visit http://www.google.com/analytics and for details of Google Analytics' Privacy Policy, click here.

3.8. You may choose to opt-out of Google Analytics using the Google Analytics Opt-out Browser Add-on which you may access here.

4. Is my personal information secure?

4.1. Personal information we hold is generally stored in computer systems. These may be operated by us or by our service providers. In all cases, we have information security requirements aimed at eliminating risks of unauthorised access to, and loss, misuse or wrongful alteration of, personal information.

4.2. If we no longer require your personal information, we will take reasonable steps to destroy or de-identify it unless we are required to keep it by law.

Are my online transactions secure?

4.3. Whilst we take reasonable measures, no data transmission over the Internet can be guaranteed as fully secure and accordingly, we cannot guarantee or warrant the security of any information you send to us using our online forms or products. You submit information over the Internet at your own risk.

4.4. With respect to on-line payments, we employ a Secure Socket Layer (SSL), which scrambles your data to make it unreadable by third parties. It does this by:

• Server authentication: the web server sends a digital certificate to your computer so that you can be sure of its identity (and know that the transaction is protected - you'll see a lock symbol on the bottom right of the browser window).
• Client authentication: your computer authenticates itself to the server by showing its digital signature.
• Encryption: during the internet connection, data that's transferred from your computer to the server is scrambled, so that only your computer and the server can understand the contents of the transaction. This prevents other internet users from intercepting the information sent.

5. Why do we collect, hold, use and disclose personal information?

5.1. When we collect, hold and use your personal information, we do so primarily to sell and promote our products to you and to improve the range of our offerings. For example:

• to learn of your likely preferences so that we may promote our goods and services to you in a way which may be of most interest to you; and
• to assist in investigating your complaints and enquiries.

5.2. We disclose personal information we collect for purposes which are incidental to the sale and promotion of our products to you. For example, we disclose your personal information to service providers who assist us in our day-to-day business operations, including delivery of products to you and to our contracted supplier (or suppliers) of technology services, exclusively for the purposes of them managing our membership database systems and other website related functions.

5.3. When marketing to you, your personal information is only ever used or disclosed for Robert Oatley Vineyard's own purposes. You may opt out of our direct marketing to you. Our direct marketing materials and our website will tell you how to do this.

6. How can you enquire about, access and correct your personal information?

6.1. We will provide you with access to any of your personal information we hold (except in limited circumstances recognised by law). If you wish to access your personal information or have an enquiry about privacy, please contact our Privacy Officer at privacy@robertoatley.com.au. Alternatively, you can write to us at:

Privacy Officer
Left Bank Melbourne Buyers Club Pty Ltd
Level 3,100 Pacific Highway
ST LEONARDS NSW 2065

6.2. Before we provide you with access to your personal information we may require some proof of identity. If you need to correct your personal information, please contact our Privacy Officer at one of the above contact points.

7. How can you complain about our management of personal information?

7.1. If you wish to complain about a breach of the privacy rules that bind us, you may contact our Privacy Officer at one of the above contact points. We may ask you to put your complaint in writing and to provide details about it.

7.2. We may discuss your complaint with our personnel and our service providers and others as appropriate.

7.3. Our Privacy Officer will investigate the matter and attempt to resolve it in a timely way. Our Privacy Officer will inform you in writing about the outcome of the investigation. If our Privacy Officer does not resolve your complaint to your satisfaction and no other complaint resolution procedures are agreed or required by law, our Privacy Officer will inform you that your complaint may be referred to the Privacy Commissioner for further investigation and will provide you with the Commissioner's contact details.

8. Our sharing of your personal information overseas

8.1. Your personal information may be stored on computers physically located overseas.

9. Updates

9.1. This privacy policy is current at the date below. We may change it periodically.

10. More information

10.1. More information about privacy law and privacy principles is available from the Privacy Commissioner. The Privacy Commissioner may be contacted at www.oaic.gov.au (email - enquiries@oaic.gov.au) (Australia).

Last update of this policy: 1 February 2015