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This Privacy Policy sets out the approach which Gregory Jewellers will take in relation to the treatment of Personal Information.
It includes information on how Gregory Jewellers collects, uses, discloses and keeps secure, individuals' Personal Information. It also details how Gregory Jewellers makes the Personal Information it holds available for access to and correction by the individual.
- COLLECTION
1.1 Gregory Jewellers will only collect Personal Information where the information is necessary for Gregory Jewellers to perform one or more of its functions or activities. In this context, "collect" means gather, acquire or obtain by any means, information in circumstances where the individual is identifiable or identified.
1.2 Gregory Jewellers collects Personal Information primarily to supply customers with the products and services ordered from it and its related companies. Gregory Jewellers also collects and uses Personal Information for secondary purposes including:
i. Billing and account management
ii. Business planning and product development; and
iii. To provide individuals with information about promotions, as well as the products and services of Gregory Jewellers affiliated companies and other organizations.
iv. To enhance the online shopping experience by displaying products and/or services that match the personal preferences of individuals based on their previous website browsing history and/or buying activity.
1.3 Gregory Jewellers will not collect Sensitive Information from individuals except with consent and only where it is necessary for Gregory Jewellers to collect such information for an activity or function.
1.4 Gregory Jewellers will not collect Personal Information secretly or in an underhanded way.
1.5 Gregory Jewellers will take steps to ensure that individuals on purchased lists are or have been notified of the information as outlined at 1.3.
- USE
2.1 Gregory Jewellers will obtain an individual's consent for Use of non-sensitive Personal Information for Secondary Purposes at the time of collection, unless the Use is a related Secondary Purpose which would be within the relevant individual's Reasonable Expectations.
2.2 Gregory Jewellers Uses Personal Information primarily for the purposes listed in 1.2 above.
2.3 If Gregory Jewellers relies on the Direct Marketing exception to Direct Market to individuals it will ensure that:
i. the individual is clearly notified of their right to Opt Out from further Direct Marketing;
ii. there is only one Use of the information before the Opt Out right is given and this Use applies across all Gregory Jewellers Related Bodies Corporate (if the information is shared between those Related Bodies Corporate);
iii. the individual is given an Opt Out in all further instances of Direct Marketing if they have not previously chosen to Opt Out; and
iv. if the individual Opts Out of all Direct Marketing the Opt Out will be respected by Gregory Jewellers and all its Related Bodies Corporate.
2.4 Gregory Jewellers will not use Sensitive Information for Direct Marketing.
2.5 Gregory Jewellers may use Personal Information to avoid an imminent threat to a person's life or to public safety. It may also use Personal Information for reasons related to law enforcement or internal investigations into unlawful activities.
2.6 Gregory Jewellers will not use Personal Information without taking reasonable steps to ensure that the information is accurate, complete and up to date.
- DISCLOSURE
3.1 Gregory Jewellers may Disclose Personal Information to related or unrelated third parties if consent has been obtained from the individual. This will include obtaining the individual's consent for Disclosures made under the credit reporting requirements of the Privacy Act.
3.2 Gregory Jewellers may Disclose Personal Information between Related Bodies Corporate. Where information is Disclosed to such a Related Body Corporate, that Related Body Corporate is bound by the original Primary Purpose for which the information was collected.
3.3 Gregory Jewellers may Disclose Personal Information to unrelated third parties to enable outsourcing of functions (such as billing, customer relations management and order fulfillment), where that is Disclosure or Use for a related Secondary Purpose and has been notified to individuals or where such Disclosure is within the individual's Reasonable Expectations.
3.4 Gregory Jewellers will take reasonable steps to ensure that its contracts with third parties include requirements for third parties to comply with the Use and Disclosure requirements of the Privacy Act.
3.5 Gregory Jewellers may Disclose Personal Information to law enforcement agencies, government agencies, courts or external advisers where permitted or required by law.
3.6 Gregory Jewellers may Disclose Personal Information to avoid an imminent threat to a person's life or to public safety.
3.7 If a Disclosure is not for a Primary Purpose; is not for a related Secondary Purpose; or upfront consent has not been obtained, Gregory Jewellers will not Disclose Personal Information otherwise than in accordance with the exceptions set out at 3.1 to 3.6 above.
3.8 Gregory Jewellers does not generally sell or share its customer lists on a commercial basis with third parties but if it did, it would only do so if we had the appropriate consent of the individual involved. If the consent provided is conditional, Gregory Jewellers will take steps to ensure (by contract) that the use of its customer list by third parties does not exceed the scope of the consent.
- INFORMATION QUALITY
4.1 Gregory Jewellers will review, on a regular and ongoing basis, its collection and storage practices to ascertain how improvements to accuracy can be achieved.
4.2 Gregory Jewellers will take steps to destroy or de-identify Personal Information after as short a time as possible and after a maximum of seven years from the date of the last customer interaction, unless the law requires otherwise.
- INFORMATION SECURITY
5.1 Gregory Jewellers requires employees and contractors to perform their duties in a manner that is consistent with Gregory Jewellers' legal responsibilities in relation to privacy.
5.2 Gregory Jewellers will take all reasonable steps to ensure that paper and electronic records containing Personal Information are stored in facilities that are only accessible by people within Gregory Jewellers who have a genuine "need to know" as well as "right to know".
5.3 Gregory Jewellers will review, on a regular and ongoing basis, its information security practices to ascertain how ongoing responsibilities can be achieved and maintained.
- ACCESS AND CORRECTION
6.1 Gregory Jewellers will allow its records containing Personal Information to be accessed by the individual concerned in accordance with the Privacy Act.
6.2 Gregory Jewellers will correct its records containing Personal Information as soon as practically possible, at the request of the individual concerned in accordance with the Privacy Act.
6.3 Individuals wishing to lodge a request to access and/or correct their Personal Information should do so by contacting Gregory Jewellers Customer Service, as per the details on the website.
6.4 Gregory Jewellers can charge a fee for processing an access request but will generally not do so unless the request is complex or is resource intensive.
- OPENNESS
7.1 Gregory Jewellers Customer Service representatives will be the first point of contact for inquiries about privacy issues. Individuals wishing to make an inquiry or complaint regarding privacy, should do so by contacting Gregory Jewellers Customer Service, as per the details on the Gregory Jewellers website.
7.2 Gregory Jewellers websites will contain a prominently displayed privacy statement and will include a copy of Gregory Jewellers Privacy Policy.
- ANONYMOUS TRANSACTIONS
8.1 Gregory Jewellers will not make it mandatory for visitors to its web sites to provide Personal Information unless such Personal Information is required to answer an inquiry or provide a service. Gregory Jewellers may however request visitors to provide Personal Information voluntarily to Gregory Jewellers (for example, as part of a competition or questionnaire).
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