Privacy Policy

This is the privacy policy for the Harvest Road Group Pty Ltd (ACN 169 138 014) and its related entities (referred to herein as we, us or our).

This privacy policy sets out how we collect, use, disclose and manage your personal information.

Our commitment to privacy

We are committed to protecting the privacy of your personal information. We work to ensure that we comply with the Privacy Act 1988 (Cth) (Privacy Act), including the Australian Privacy Principles under the Privacy Act, and any other applicable privacy laws. If you are resident in the European Economic Area (EEA) or the United Kingdom (UK), applicable privacy laws include the EU General Data Protection Regulation and the UK General Data Protection Regulation respectively.

Collecting personal information

How we collect personal information

Personal Information is information or an opinion that identifies an individual. This can include names, addresses, email addresses, phone and phone numbers.

Sensitive information is a type of personal information that includes information about an individual’s racial or ethnic origin, professional, political or religious affiliations or memberships, sexual orientation or practices, criminal record, health, genetics and/or biometrics.

At all times we try to collect directly from you only the personal information we reasonably need for the particular function or activity we are carrying out. This can include when you visit our website, contact us, make a booking with us, submit a booking enquiry to us, raise a query or complaint with us, sign up to one of our mailing lists, apply for a job with us (as further described below), contract with us or otherwise interact with us.

We may also collect your personal information (including sensitive information) that we reasonably need from third parties, including government agencies, regulators, commercial counterparties and third party service providers (including credit reporting, recruitment or information agencies), and from publicly available records when handling or resolving a complaint, investigation (including investigating a data breach), conducting recruitment processes or otherwise performing any particular function or activity we are carrying out.

The types of personal information we collect

Depending on the nature of our relationship and interactions with you, we may collect a range of personal information. This includes your name, contact details (including your address, email address and phone number), date of birth, gender, nationality, organisation and IP address. If you attend one of our events, we may also take audio or visual recordings which identify you.

On occasion, we may collect information about you of a sensitive nature (such as information about your health). However, we will only do this with your consent or otherwise in accordance with applicable laws.

If you apply for a career with us

We also collect personal information when recruiting people to work with us. This may include the types of information listed above, along with your qualifications, work history and reference details. Before offering you a position, we may collect additional details such as your tax file number, superannuation information and other background check information (such as police clearances and working with children checks, to the extent required or permitted by applicable laws).

Generally, we will collect this information directly from you. We may also collect this information from third parties (such as recruitment agencies, background check agencies or your referees).

Why we collect personal information

The purposes for which we collect your personal information depend on the nature of our relationship and interactions with you. These purposes may include:

providing services to you or facilitating the provision of services to you by others;
responding to your requests for information, complaints and other enquiries;
marketing, including by informing you of activities, events and developments (as further described below);
complying with our contractual, legal or regulatory obligations or exercising our legal rights;
monitoring, analysing or improving our business, services or website;
facilitating our recruitment processes; and
managing our relationship or interactions with you.

Legal bases for processing personal information if resident in the EEA or UK

We process your personal information where it is in our legitimate interests to do so. We believe that our use of your personal information is within a number of our legitimate interests, including the purposes listed above under the heading ‘why we collect personal information’.

We may also process your sensitive personal information where it is in the course of our activities as a not-for-profit body, or where processing your sensitive personal information is necessary for us to exercise our rights or carry out our employment and social security law obligations.

Cookies and analytics

We use cookies and analytics (including Google tools) in relation to your use of our websites. Please refer to our website terms for more information in relation to this, including in relation to the personal information that we may collect by using such cookies and analytics.

Anonymous dealings

You may choose to remain anonymous or use a pseudonym in your communications with us where it is lawful and practicable. However, if you choose to do so, please note that we may not be able to provide you with information or goods and services, or effectively manage our relationship with you.

Storing personal information

We endeavour to take reasonable steps to protect your personal information from misuse, interference and loss and from unauthorised access, modification or disclosure. We also endeavour to take reasonable steps to destroy or de-identify personal information that we no longer require.

We maintain physical security over paper and electronic data stores, including through the use of locks and security systems at our premises. We also maintain computer and network security such as firewalls to protect your personal information and to control access to our computer systems.

We secure communications between your browser and this website with encryption technology wherever possible. We also encourage you to exercise care in sending personal information via the internet.

Using and disclosing personal information

General use and disclosure

We may use and disclose your personal information for our legitimate business purposes, including for the purposes set out above in relation to our collection of personal information. For example, we may disclose your personal information to:

our internal divisions, business units, departments, related entities or affiliates;
third parties who work with us (including those who assist us in providing goods and services to you on our behalf);
our representatives, agents or contractors who assist us in administering our business (including for data storage or processing, printing, mailing, marketing, planning and goods or services development) or provide services to us;
our advisors (including lawyers and accountants), insurers, auditors and financiers;
other parties when required by law, such as law enforcement entities or regulators;
potential investors in, or purchasers of, any part of our business; and
Recruitment firms and recruitment service providers

We do not share your personal information except in accordance with this privacy policy or as permitted by the Privacy Act or other applicable privacy laws.

To additional protect your personal information when disclosing it to third parties, we also include special privacy provisions in our contracts and engagements.

Marketing

We may use the personal information you provide to us to send information to you, including promotional material about us (and our various entities, goods and services) and the goods and services of relevant third parties. We may send you such information by direct mail, telemarketing, email, SMS, MMS or other similar means.

If you do not want to receive marketing from us, you can unsubscribe by emailing us (see email contact below) or by clicking on the “unsubscribe” link in an automated mailout that you have received from us.

Overseas disclosures

We may disclose, transfer, store, process or use your personal information outside of your country of residence (or where you are resident in the European Economic Area (EEA), outside of the EEA). This may happen if our related entities, employees, contractors or third parties we engage with are located overseas, including in the United States of America and the United Kingdom.

For residents in the EEA and United Kingdom (UK), we may transfer your personal information outside of the EEA and UK provided that the means of transfer provides adequate safeguards in relation to your data, including in accordance with any applicable laws.

Accessing and correction of personal information

If you would like to access any of the personal information we hold about you, please email us (see email contact below). We will endeavour to provide access promptly and free of charge. However, we may refuse to provide access, or may charge a fee for compiling the requested information, if it is lawful for us to do so. If we refuse a request for information, or decide to charge such a fee, we will provide you with a reason for our decision as required by applicable privacy laws.

Please let us know if there are any errors or discrepancies in the personal information we hold about you or if your details have changed. We will take reasonable steps to correct, update and/or delete this information in accordance with applicable privacy laws following your request. Please note, if you choose to update and/or delete the personal information we hold about you, we may not be able to provide you with requested information, products or services, or to effectively conduct our relationship with you.

If you are resident in the EEA or the UK

In addition to the above right of access and right of rectification, you may also have other rights in relation to the personal information we hold about you. These include the right to object to, or restrict our processing of, your personal information, the right to request that we erase your personal information, and the right to transfer your personal information between service providers.

However, please note that some of these rights may not always apply to the personal information we hold about you as there are sometimes requirements and exemptions which mean we need to keep the personal information, or other times when the rights may not apply at all.

How long do we keep your personal information?

When your personal information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your personal information (including sensitive information). When determining the appropriate retention period, we consider the risks of the processing, our contractual, legal and regulatory obligations, and our legitimate interests as described in this privacy policy.

Enquiries and complaints

You can contact us at any time if you have any questions or concerns about this privacy policy or the way in which your personal information has been handled, or if you have a privacy complaint, by emailing us at info@harvestroad.com.

We will consider your questions, concerns and complaints to work out what steps can be taken in response. If you make a complaint which requires detailed consideration or investigation, we may ask you to give us more information about your complaint and the outcome you are seeking. We may need to gather relevant facts, locate and review relevant documents and speak with other people involved. In any event, we will endeavour to provide you with a response within 30 days.

If you are not satisfied with an outcome following the above process, you may wish to contact the Office of the Australian Information Commissioner at:

www.oaic.gov.au
1300 363 992

If you are resident in the EEA or UK

You have the right to make a complaint to your local data protection authority, which in the UK is the Information Commissioner’s Office (www.ico.org.uk). The authorities for EU Member States are listed (along with contact details) on the European Commission website here.

Updates to this privacy policy

We may amend this privacy policy from time to time, with or without notice to you. We recommend that you check this page regularly and each time you visit this website.

This privacy policy was last updated in February 2023 (V2023-02).

Terms & Conditions - Subi Spritz - Spritz a la French Ticket Giveaway

1 Definitions

Unless the context requires otherwise, in these terms and conditions:

(a) Prize means the prize referred to in clause 5.1 (as substituted from time to time);

(b) Prize Winner means an entrant that is selected in accordance with clause 4.1;

(d) Promotion Period means the period commencing at 10:00am AWST on 14 March 2025 and ending at 11.59pm AWST on 19 March 2025;

(e) Promotional Post means the social media post on our Instagram account announcing the Promotion;

(f) us, we, and our refers to Harvest Road Oceans ABN (78 165 170 445) of Level 7, 190 St Georges Terrace, Perth, WA 6000; and

(g) you and your refers to the person entering the Promotion and accepting these terms and conditions.

2 Eligibility

To be eligible to enter the Promotion, you must be 18 years of age or older, and be following the Leeuwin Coast Instagram account (@leeuwincoast) during the Promotion Period.

3 Entry to the Promotion

To enter the Promotion, you must comment on the Promotional Post during the Promotion Period. No other method of entry will be accepted.

4 Draws

4.1 Prize Winners

At 9:00am on 20 March 2025 at Level 7, 190 St Georges Terrace, Perth, WA 6000, we will select one (1) eligible entry at random as the Prize Winner.

4.2 Award of Prizes

A Prize will be awarded to a Prize Winner only once they have claimed their Prize in accordance with clause 6 of these terms and conditions.

5 Prize

5.1 Prizes

Each Prize Winner will receive two (2) tickets to the Subi Spritz - Spritz a la French event on 21 March 2025 located at Mistelle, 205 Nicholson Road, Shenton Park, WA 6008. The Prize includes admission to the Subi Spritz- Spritz a la French event only. All other expenses including but not limited to travel, accommodation, and meals, are the sole responsibility of the Prize Winner.

5.2 Prize Value

The maximum total retail value of each Prize is estimated to be $50.00 (2 tickets at $25.00 each).

5.3 Price Conditions

Each Prize is subject to the following conditions:

(a) No sale, transfer or exchange of Prize: each Prize is non-transferable and cannot be exchanged or redeemed for cash, resold (at a premium or otherwise) or advertised or offered for resale through any medium. If for any reason, a Prize Winner cannot take any component of their Prize, then the Prize will be forfeited.

(b) Prize Terms: the components of each Prize are subject to availability. If any component of a Prize is unavailable for any reason due to circumstances beyond our reasonable control, we reserve the right to substitute that component of the Prize with another prize of equal or greater value, subject to any applicable laws or written directions made under applicable legislation.

(c) Additional Terms: it is a condition of accepting a Prize that the Prize Winner (and any guests participating in using the Prize) must comply with any conditions of use applicable to that Prize. We are not responsible or liable for any loss, damage or injury suffered by any Prize Winner or their guest as a result of the conduct of any Prize suppliers, or otherwise as a result of the Prize Winner and their guest accepting and/or using a Prize, except for any loss, damage or injury which is due to our negligence or wilful misconduct or which cannot be excluded by law. We are not responsible for any changes in times or dates, cancellations or rescheduling of events that may prevent a Prize winner from redeeming their Prize or any part of it.

6 Claim of Prize

We will contact each Prize Winner via Instagram within one (1) day of a draw completed in accordance with clause 4.1 to notify them that they are a Prize Winner. Each Prize Winner must provide photo identification (and any other information we reasonably request) via email to our nominated representative to verify that they meet the eligibility criteria set out in clause 2 and that they are the relevant Prize Winner. The Prize Winner will receive the Prize via email within one (1) business day of being notified that they are a Prize Winner.

7 Redraw

We reserve the right to redraw Prizes, in accordance with the terms and conditions of the original draw, if a Prize Winner is unable to satisfy these terms and conditions or forfeits their right to their Prize. A redraw is to occur up to a maximum of ten times (or any other number of times as determined in our sole discretion). If a Prize Winner has not claimed their Prize in accordance with these termsand conditions after ten redraws (or the number of redraws we determine) the Prize will be forfeited.

8 Winner publicity

You irrevocably agree that we may use your entry for any matter incidental to the Promotion (or anyother promotion we run) without compensating you for such use, including by:

(a) reproducing and communicating your entry to the public in whole or in part; and

(b) publicising, broadcasting and communicating your name, character, likeness and Instagram profile to the public.

9 General conditions

(a) Use of automated software: the use of any automated entry software or any other mechanical or electronic means which allows you to automatically enter the Promotion repeatedly is prohibited and will render all entries submitted by you invalid.

(b) Lost ordelayed communications: we will not be responsible for any delayed, lost ormisdirected email or any other communication.

(c) Disclaimer: our responsibility to provide a Prize is limited to the Prizes described in these terms and conditions. We do not accept any further liability or commitment beyond what is stated in these terms and conditions and will not be liablefor any failure of our agents or contactors to supply Prizes as stated. All times are best estimates only and we do not guarantee that events will takeplace exactly at the times stated in these terms and conditions. The Promotion is in no way sponsored, endorsed or administered by, or associated with Instagram.

(d) Release: to the extent permitted by law:

(1) you and any other person partaking in any component of a Prize, release and indemnify us in respect of any claim, loss, damage, injury, expense, cost or charge sustained or in any way incurred in connection with the Prize or Promotion, or your or their participation in the Prize or Promotion; and

(2) Us, our related entities, their officers, employees, contractors and agents will not be liable for any loss, damage personal injury or other liability (including direct, indirect, consequential and economic losses) suffered or sustained in connection with this Promotion, the promotion of this Promotion, or the use of any Prize.

(e) Force Majeure: we will not be responsible for any forces of nature, pandemics, acts of God, war (declared or undeclared), riot, explosion, acts of terrorism, labour or industrial dispute including strike, action or inaction of Government (including in relation to COVID-19), forced or cessation of or interruption totrade and any other acts which are not reasonably within our control and may affect the Promotion or a Prize. If one or more of these acts occur, we reserve the right to cancel the Promotion, defer the Promotion, or change these termsand conditions.

(f) Disputes :in the event of a dispute, our decision is final and binding and no correspondence will be entered into.

(g) Privacy Notice: we may collect your personal information (including, for example, your name, handle and contact details) for the purposes of:

(1) conducting the Promotion, including publicising the results of the Promotion;

(2) running future promotions;

(3) our general marketing and publicity activities; and

(4) any other purposes related or ancillary to the above purposes.

We may disclose the personal information we collect to our related entities, the employees, contractors and agents of our related entities, and our employees, contractors, agents, partners and co-promoters in connection with the above purposes. By entering this Promotion, unless you otherwise advise us, you consent to the retention and use of your personal information in this manner. Additional information about how we collect, use and disclose personal information, and the privacy complaints process, is available in our privacy policy available at https://www.leeuwincoast.com/legal/privacy

(h) Amending these terms and conditions: subject to any applicable laws or written directions made under applicable legislation, we reserve the right to amend these terms and conditions to address any misinterpretation, misinformation or misunderstanding that may arise in the application of these terms and conditions.

(i) Acceptance of Terms and Conditions: your participation in the Promotion constitutes an acceptance of these terms and conditions. If you do not accept all of these terms and conditions, you must not participate in the Promotion.

(j) Disqualification: we may disqualify you from participating in the Promotion for any reason in oursole discretion. You agree that any decision to disqualify you is final.

(k) Cancellation of the Promotion: subject to any applicable laws or written directions, we reservethe right to cancel the Promotion at any time for any reason whatsoever.

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