[Draft for legal review. Not yet in force.]

Privacy policy

Last updated: [date]

This policy explains how Koluka Pty Ltd (ACN 136 003 140), the owner of the ZAMBEZI® brand ("we", "us"), handles information when you visit zambezibrands.com and its related addresses zambezirum.com, zambezigin.com and zambeziwhiskey.com (the "site").

1. The short version

• You don't create an account, and the site has no forms that collect your name, email or address.
• The site remembers one thing in your browser: the country you picked at the age check, so you aren't asked again.
• We don't sell your information, and the site doesn't use advertising cookies.
• Purchases happen on Tipxy, under Tipxy's own privacy policy.

2. Information we collect

Your age-check answer. When you confirm you're of legal drinking age, the site saves the country you selected and the time you answered in your browser's local storage. It stays on your device. We don't receive it and can't link it to you. It does not record your date of birth.

Technical information. Like most websites, our hosting provider automatically records standard information when a page loads, such as your IP address, browser type, the page requested and the time. This is used to run and secure the site and is kept for [period, e.g. 30 days].

Analytics. [Either: "We do not use analytics." Or: "We use [provider] to count visits and see which pages are popular. It does not use cookies or identify individual visitors." Update to match what is installed.]

Information you send us. If you email us, we receive your email address and whatever you write, and use it only to reply.

3. How we use information

• To show the version of the site that fits your country, and to restrict it to people of legal drinking age.
• To keep the site running, secure and free of abuse.
• To understand, in aggregate, how the site is used, if analytics are in place.
• To answer messages you send us.

4. Buying through Tipxy

We don't sell products on this site. "Buy" buttons take you to Tipxy (tipxy.com), an independent online retailer. Anything you share there, including age verification, payment and delivery details, is collected by Tipxy and its licensed retail partners under their own terms and privacy policy, not this one. Links to Tipxy may include a referral tag so we can see how many visitors came from our site. The tag does not identify you.

5. Sharing

We don't sell, rent or trade personal information. We share technical information only with the service providers that host and run the site, and only so they can do that work, or where the law requires it.

6. Links and social media

The site links to Instagram and other websites we don't control. Their own privacy policies apply once you leave our site.

7. Legal drinking age

The site is intended only for people of legal drinking age where they live: 21 or older in the United States and 18 or older in Australia. We don't knowingly collect information from anyone under that age.

8. Your choices

• To clear your age-check answer, use "Change country" at the foot of any page, or clear this site's data in your browser settings.
• You can ask what information we hold about you, or ask us to correct or delete it, by contacting us (section 11).
• Residents of some US states, including California, have additional rights over their personal information. We'll honour requests made under those laws. Because we don't sell or share personal information for advertising, there is nothing to opt out of.

9. Where information is held

We're based in Australia. The site is hosted by [hosting provider], whose servers may be in the United States or other countries. We handle personal information in line with the Australian Privacy Principles under the Privacy Act 1988 (Cth), to the extent they apply to us.

10. Changes to this policy

We may update this policy from time to time. The date at the top shows when it last changed.

11. Contact us

Koluka Pty Ltd
[postal address]
[email address]

If you're not satisfied with our response to a privacy complaint, you can contact the Office of the Australian Information Commissioner at oaic.gov.au.