Introduction and policy scope

This Privacy Policy (Policy) applies to Kennedy Watches & Jewellery Pty Ltd (ABN 82 165 266 491) and its subsidiaries (collectively 'Kennedy', ‘we’, ‘us’, ‘our’) and describes how Kennedy collects, handles and protects the privacy of your personal information.

 

We are committed to protecting your privacy and understand the importance of protecting your personal information.  This policy explains how, and for what purposes, Kennedy collects information about you and from whom, who we disclose your personal information to and how we keep it secure, your rights in relation to your personal including, including how you may access and seek correction of the personal information we hold about you, how to complain about a breach of your privacy and how we will deal with your complaint.

 

We will handle your personal information in accordance with this Policy and legislation including the Privacy Act 1988 (Cth) (Privacy Act), the Australian Privacy Principles (APPs), and the Spam Act 2003 (Cth).

 

This Policy does not apply to the personal information of Kennedy employees.

Contacting us

Any question regarding  this Policy may be directed to us using the contact details at the end of this Policy.

Updates to this Policy

We may update this Policy from time to time if our data processing practices or legal requirements change.  The latest version of this Policy will appear on Kennedy’s website at [https://www.kennedy.com.au/].

Personal information we collect and hold

The types of personal information Kennedy collects about you depends on who you are, the nature of our relationship with you and your dealings with us.  In this Policy:

Personal information means any information or opinion about an identified individual, or an individual who is reasonably identifiable, whether true or not. Personal information does not include information that is de-identified.

Sensitive information means any information or opinion about your health, race or ethnicity, political opinions or associations, religious beliefs or affiliations, philosophical beliefs, membership of a professional association or union, sexual orientation or practices, or criminal record.  We will only collect sensitive information about you with your consent (which may be express or depending on the circumstances, inferred from your conduct) unless otherwise authorised by law.

Personal information that we collect about you depends on the dealings you have with us, (for example, when you visit our websites and use or interact with our services) and may include:

• your personal and/or professional contact details (such as name and job title, address, email address, phone number, mobile phone number);
• your address;
• date of birth or age group;
• your gender;
• your driver’s licence number or passport number;
• your nationality;
• your country of residence;
• your financial details including bank account and credit card or debit card information; and
• your photograph, if you attend one of our events.

If you apply for a job with us, the personal information we collect about you may include your name and contact details, employment and professional history, your education history, your criminal history record,  your references and any other information you provide about yourself in your resume that you submit to us.

How we collect your personal information

Wherever possible, we will collect your personal information directly from you, such as when you contact us, purchase a product from us, attend one of our events or apply for a job with us.  We may also collect personal information about you through third parties with whom we interact in order to provide our services and publicly available sources.

If you apply for a job or contract position with us, we may also collect personal information about you from third parties and publicly available sources, including police agencies to obtain your criminal history record, recruiters, your current or previous employers or your referees.  Purposes for which we collect and use your personal information

Kennedy collects and uses your personal information for the following purposes:

• to facilitate, develop and improve our products and services (including our website);
• to deliver, manage and market our products and services to you, including communications about our products, services and events;
• to process payments;
• to obtain and manage any queries, feedback, communications or complaints from our customers, including in relation to our products and services;
• to offer, promote, host and manage our events;
• to manage our customer accounts and records;
• where necessary, to verify the identity of individuals who use our services;
• for persons applying for a job or contract position, to consider your suitability for employment;
• to protect and ensure the security of our business, networks and services;
• for business administration; and
• to comply with our legal obligations, resolve any disputes and enforce our agreements and rights with third parties.

Direct marketing

We may, with your consent (where required), use your personal information we have collected about you to send you (or direct third party marketing providers to send you) marketing communications about our or our partners’ and suppliers’ products, services and events that we believe may be of interest to you via email, mobile, SMS, and postal mail.  You can opt out of receiving our direct marketing communications at any time by contacting us on the details at the end of this policy.  Any direct marketing message we send will also contain a mechanism in the message to enable you to opt out of receiving direct marketing at that time.

Remaining anonymous or using a pseudonym when dealing with us

You may elect not to identify yourself or you may use a pseudonym in your dealings with us, except where it is impracticable or would be unlawful for us to deal with you on this basis.

It will not always be practicable for Kennedy to interact with you anonymously.  For example, it will not be practicable for us to deal with you on an anonymous basis if you are applying for a position at Kennedy.

To whom we disclose your personal information

In the course of providing our services to you, we may disclose your personal information with the following:

·       organisations we contract to provide services on our behalf, to the extent reasonably necessary to fulfil our obligations to you. This may include payment processors, data storage providers and mailing houses;

·       professional service providers, suppliers and other third parties with whom we have commercial relationships, for business, marketing, online marketing and related purposes;

·       anyone to whom part or all of our assets or businesses are transferred or sold;

·       our professional advisers, including lawyers, accountants and auditors; and

·       government agencies, regulatory bodies and law enforcement agencies, or other similar entities, if required or authorised by law.

Some of Kennedy’s server providers and third-party vendors or partners may be located overseas.

We do not process personal information on behalf of third parties, nor do we sell personal information to, or share personal information with, third parties for their own, independent use, unless you provide express consent for us to do so.

Cookies

When you visit our website, we may use 'cookies' or other similar tracking technologies that help us track your website usage and remember your preferences.  Cookies are small files that store information on your computer, mobile phone or other device.  They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions.  You can disable cookies through your internet browser, but our website may not work as intended for you if you do so.

Whilst we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit, search engine referrals and the internet protocol address assigned to your computer.

While navigating on the Rolex section of our website, we may use additional  cookies to collect information about your visit to the Rolex section of our website. We may share online data collected through these cookies and similar technology with ROLEX SA.

 

Access, review, correction and update of your personal information

You may request access to, or correction of, the personal information we hold about you at any time.  Kennedy may refuse access to some or all of your personal information if required by law, such as where providing access would have an unreasonable impact on the privacy of other individuals or would reveal commercially sensitive information.  If we do, we will explain in writing why and how to complain if you are not satisfied with our decision.

You may also ask us to correct any of your personal information you believe is inaccurate, incomplete, out-of-date, misleading or irrelevant.  Subject to any applicable exceptions or requirements, we will take reasonable steps to correct it.  If we decide to refuse your request, we will explain why in writing  and how to complain if you are not satisfied with our decision.

You may either use the contact details below or contact our Consumer Service.  We will respond to your request within a reasonable time and usually within 30 days.  Please note that prior to accessing and making changes to your account, we must verify your identity properly.  It may take up to 10 business days before any changes we make take effect.

Data storage and security

We store your personal information in hard copy and electronically.  Electronic information is stored by a third party storage provider.

We take all reasonable and appropriate steps (including organisational and technical measures) to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure.

Once Kennedy no longer requires your personal information for any purpose for which it was collected or otherwise is not required by law to keep it, we will take reasonable steps to destroy or de-identify that information.  These steps may vary depending on the nature of the information, the way it was collected and how it was stored.

Please contact Kennedy immediately on the details below if you believe that the personal information we hold about you may have been lost or stolen, or subject to any unauthorised access, modification, interference or disclosure.

Privacy complaints

If you believe that Kennedy has not handled your personal information in accordance with this Policy or its privacy obligations, please contact us using the details set out  below.  If you make a complaint, we will acknowledge receipt of your complaint promptly and may need to verify your identity and ask you to provide us with further information to enable us to investigate your complaint.  We will investigate your complaint and notify you of our decision and offer any resolution that we consider appropriate within a reasonable time. 

 

If you are not satisfied with our resolution of your complaint, you can contact the Office of the Australian Information Commissioner (OAIC) via the OAIC website, www.oaic.gov.au.

Contact us

If you have any questions or comments about this Privacy Policy, wish to request access to or correction of your personal information, wish to make a privacy complaint, or wish to notify us if you believe your personal information has been compromised, please contact us using the following details:

Kennedy Watches & Jewellery Pty Ltd

Email address:  info@kennedy.com.au
Phone number: (03) 8614 1100
Address: Kennedy Luxury Group, Level 5, 489-505 Toorak Road, Toorak VIC 3142