Corporate Privacy Governance Statement & APP Alignment

1) Policy Context & Scope

This Privacy Policy sets out the authoritative standards and operational protocols by which Taylors Wines Pty Ltd (ABN 43 007 733 897) (“Taylors Wines”, “we”, “us”, or “our”) collects, stores, uses, discloses, and protects personal information. This policy is constructed in rigorous conformity with the Privacy Act 1988 (Cth) and the statutory Australian Privacy Principles (APPs).

This document applies universally to all personal information captured across our physical vineyards, administrative headquarters, digital e-commerce storefronts, mobile platforms, and associated brand distributions (including the Wakefield brand portfolio within relevant international jurisdictions).

2) Direct Relationship to Commercial Agreements

To the extent that this Privacy Policy is incorporated by reference into any binding commercial agreement between you and us—such as our Website Terms and Conditions—the text of this policy forms an active, enforceable component of that specific commercial covenant (the "Taylors Wines Agreement").

3) Information Collection Framework

3.1) Methods of Collection

• (a) We collect Personal Information about you when you explicitly provide it to us during the course of executing your interactions with our business. This includes filling out online information fields (e.g., creating an online profile, registering for wine clubs, entering promotional competitions), completing transactions, or interacting via email tracking systems, digital analysis platforms, social media plug-ins, or targeted mobile software applications operated or hosted by us.
• (b) Through these operational touchpoints, we capture the following distinct categories of Personal Information: name, delivery address, billing address, contact phone number, valid email address, digital interaction data (including IP addresses and browser cookies), comprehensive purchase history, transaction records, and specific wine product preference information.

3.2) Reasonableness & Legislative Grounds

• (a) Taylors Wines collects personal information strictly where it is reasonably necessary to perform our core commercial functions, supply our products, or manage customer relationships. To the extent that any information requested is classified as Sensitive Information under federal privacy law (such as health conditions, racial origins, or political affiliations), we will never collect such data without your explicit, unambiguous prior consent. You are under no statutory obligation to provide personal information to us; however, choosing to withhold requested details may prevent us from completing your transactions, shipping products, or granting access to digital membership tiers.
• (b) Specifically, we collect and process Personal Information for the following authorised operational reasons:
• To formulate, execute, and manage binding contractual relations with you (e.g., executing the Taylors Wines Agreement and fulfilling online store transactions);
• To accurately identify, verify, and validate you as a party to the Taylors Wines Agreement or wine club membership;
• To safely supply, transport, and complete delivery of our premium products to your verified address;
• To conduct direct digital and physical marketing campaigns, administer loyalty rewards, and coordinate operations with our internal marketing personnel;
• To facilitate analytics, diagnose website performance issues, and drive ongoing premiumisation improvements across our service environments;
• To satisfy mandatory legal, regulatory, tax, and liquor licensing obligations; and
• For certain defined Legal Reasons as set out under the definitions section of this policy.

3.3) Collecting Corporate Entity

The legal corporate entity responsible for the collection and structural custody of Personal Information is: Taylors Wines Pty Ltd (ABN 43 007 733 897), registering its primary corporate administrative office at Suite 2, Shed 72, 4F Huntley Street, Alexandria NSW 2015, Australia.

4) Strategic Use of Personal Information & Direct Marketing Standards

• (a) We utilise Personal Information to efficiently execute our commercial distributions, process secure financial payments, manage inventory fulfillment, and transmit critical operational notices (such as order status updates, delivery alerts, and security notifications).
• (b) Marketing Communications Consent Governance (Spam Act Compliance): Where you actively provide your name, mobile contact number, or email address to us via an explicit opt-in mechanism, you grant your express consent to Taylors Wines to utilise that Personal Information to market our services, deliver newsletter communications, and broadcast promotional offers. We strictly do not rent, sell, or trade your personal information to third parties to enable them to market their own independent commercial products to you.

Any digital marketing communication distributed by Taylors Wines or the Wakefield brand will feature a fully functional, highly visible, and instantly actionable unsubscribe or opt-out mechanism. You retain an absolute right to withdraw your marketing consent at any time, entirely free of charge, by executing the unsubscribe command or contacting our Privacy Officer.

Where you permit the capture of cookies or tracking pixels, you consent to our deployment of that localised data to manage targeted digital advertising banners across external networks. You maintain total technical control to disable cookies or wipe cached identifier data via your local web browser security controls.

• (c) We reserve the right to process Personal Information to generate aggregated statistical profiles that do not identify any specific individual ("General Information"). This unidentifiable analytical data is utilised to monitor market performance, evaluate wine consumer segment behaviors, and refine our production strategies. We may deploy or share General Information with external commercial entities for any legal business purpose.

5) Disclosure Protocols & Overseas Data Transmissions

5.1) Corporate Disclosure Controls

Generally speaking, Taylors Wines will disclose your Personal Information only to trusted corporate sub-contractors and service providers who require access to data strictly to execute tasks on our behalf. These parties are strictly categorised as:

• Certified cloud storage providers and data infrastructure hosting facilities;
• PCI-DSS compliant financial institutions and encrypted payment gateway processors;
• Authorised logistics firms, freight forwarders, and delivery couriers; and
• Authorised digital marketing platform operators, data analytical firms, and creative agencies working under strict contractual mandates to distribute Taylors Wines or Wakefield Wines campaigns exclusively.

We mandate that all such external service providers execute legally binding confidentiality agreements that strictly prohibit them from retaining, sharing, or deploying our database for any independent purpose. We will also disclose Personal Information if compelled by verified law enforcement bodies or for explicit Legal Reasons.

5.2) Individual Disclosure Liabilities

Where you utilise interactive digital features on our platforms to post public product commentary, star ratings, or social media links, you acknowledge that such content becomes instantly viewable by the general public. You assume full legal, practical, and privacy responsibility for any personal data you voluntarily choose to disclose in these public forums.

5.3) Regulated Overseas Data Transfers

We may, from time to time, transfer your Personal Information to secure data centers or cloud storage repositories located outside the geographic borders of Australia. We will only execute such international transmissions if one of the following strict legal conditions is fully satisfied:

• Our binding contract with the overseas cloud provider strictly obliges them never to use, disclose, or repurpose the personal data except for the single, limited purpose of storing and managing the data under our direct, effective corporate control;
• We have taken robust, reasonable operational steps to ensure the overseas recipient is bound to maintain privacy protections equivalent to the Australian Privacy Principles (APPs);
• We reasonably believe the recipient is subject to a legally enforceable binding scheme or international privacy law that protects data in a manner substantially similar to the APPs, featuring clear avenues for individual enforcement; or
• The transfer is explicitly authorised or mandated under an Australian court order or statutory law.

6) Customer Access Rights & Data Rectification

• (a) You possess a clear legal right to request complete access to the Personal Information held within our corporate repositories. Requests can be initiated by contacting our Privacy Co-ordinator directly or by logging into your secure online account profile. Upon receipt of a valid identity-verified request, we will deliver the data within a reasonable timeframe.
• (b) In strict accordance with APP 12, Taylors Wines reserves the right to deny or partially restrict access in limited circumstances, specifically: (i) if granting access would pose an unreasonable risk to the privacy or safety of other individuals; (ii) if the request is identifiably frivolous, vexatious, or malicious; (iii) if the data would reveal commercially sensitive evaluative summaries generated internally in connection with corporate decision-making; or (iv) if withholding access is strictly required for legal privilege, ongoing litigation, or law enforcement reasons.
• (c) If we formally deny or restrict your access request, we will supply a comprehensive written notice detailing our legal and operational reasons, along with information regarding your rights to lodge an external complaint.

7) Data Quality & Integrity Standards

• (a) Taylors Wines implements continuous quality measures to ensure that all Personal Information collected, used, or disclosed is factually accurate, complete, current, highly relevant, and not misleading.
• (b) If you determine that the information we hold about you is inaccurate or incomplete, you may submit a formal request for rectification. Upon review and verification, we will execute reasonable steps to correct the data within a reasonable timeframe. If we disagree with your assessment of data accuracy, we will notify you of our decisions and, at your formal request, append a permanent note to your customer profile stating your position.
• (c) Where we successfully execute a data correction that was previously disclosed to an external service provider, we will take reasonable steps to notify that third party to update their records accordingly.

8) Structural Storage, Security & Data Breach Notification

• (a) Your Personal Information is stored securely on encrypted physical servers located at our facilities or on cloud-based systems operated by enterprise-grade, certified hosting infrastructure providers under our direct administrative control.
• (b) We implement a rigorous defense-in-depth security architecture comprising physical access restrictions, secure firewalls, network monitoring, multi-factor authentication protocols, and end-to-end encryption for online financial transactions.
• (c) Notifiable Data Breaches (NDB) Scheme Compliance: In the event that Taylors Wines experiences a security incident resulting in unauthorised access, loss, or disclosure of personal information that is deemed likely to result in serious harm to any affected individual, we will instantly invoke our corporate Data Breach Response Plan. In strict compliance with Part IIIC of the Privacy Act 1988 (Cth), we will swiftly assess the incident, take immediate mitigation actions, and formally notify the Office of the Australian Information Commissioner (OAIC) and all affected individuals as required by law.

9) Regulatory Information Disposal Protocols

• (a) Taylors Wines tracks data retention lifecycles. We will implement robust, secure measures to permanently destroy, shred, or completely de-identify Personal Information once it is no longer required for any authorised commercial purpose or statutory legal retention period under the APPs.
• (b) You acknowledge that the systemic characteristics of enterprise backup technology and data replication arrays mean that microscopic remnants of archived data may persist in deep-tier storage systems; however, such data remains completely encrypted, inaccessible to daily operations, and slated for chronological overwrite.

10) Formal Complaints & Regulatory Escalation

• (a) If you believe that Taylors Wines has inadvertently mismanaged your data or breached any requirement of the Australian Privacy Principles (APPs), you have a right to lodge a formal written complaint. Complaints must be explicitly directed to our designated Privacy Officer at:

Attn: Privacy Co-ordinator Taylors Wines Pty Ltd PO Box 7418, Alexandria, NSW 2015, Australia

• (b) Upon receipt of a privacy complaint, our compliance team will execute the following mandatory protocols: (i) formally acknowledge receipt within 5 business days; (ii) launch a comprehensive internal investigation; (iii) deliver a detailed written response within 30 days outlining the findings; and (iv) provide clear guidance on how to escalate the matter to the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au if you remain dissatisfied with our resolution.

11) Definitions & Statutory Interpretation

• Legal Reasons: Refers to circumstances where processing data is required to lessen/prevent serious threats to life or health, investigate suspected unlawful activity or serious organisational misconduct, comply with an explicit Australian law or court tribunal order, or establish/defend a formal legal claim.
• Personal Information: Any information or opinion about an identified individual, or an individual who is reasonably identifiable, regardless of whether the information is factually true or recorded in a material form.
• Sensitive Information: A specific subset of personal information including data regarding racial/ethnic origin, political opinions, religious beliefs, philosophical doctrines, trade union memberships, criminal records, or comprehensive health metrics.
• use: may include to disclose or transfer.
• we / us / our: means Taylors Wines Pty Ltd.
• you: means the individual who has entered into the relevant Taylors Wines Agreement or, if the person who has entered into the Taylors Wines Agreement is an entity (e.g., a company) and not an individual, then in this policy "you" means any individual connected with the entity and who supplies Personal Information to us in the course of the entity’s performance of the Taylors Wines Agreement; or the individual reading this policy, if that individual is also an individual in relation to whom we must, pursuant to the Privacy Act 1988 (Cth), abide by this policy.