Kennedy (‘we’, ‘us’, ‘our’) is committed to protecting the privacy of individuals with whom it deals, and it handles personal information it collects and holds in accordance with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs) in the Privacy Act.
This policy governs the processing (including collection by any means, use, disclosure, transfer, storage and destruction) of personal information about natural persons, who are either consumers of Kennedy products or services, or representatives of our cooperation partners (“personal information”), by all business units and entities within Kennedy. . 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, 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.
Any question regarding our processing of personal information may be directed to our Privacy Officer whose details are at the end of this policy.
Updates to this Policy
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.
Personal information is any information or opinion we collect and hold about an identified individual, or an individual who is reasonably identifiable to us and includes sensitive information about your health, race or ethnic origin, membership of a professional or trade organisation and 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 may include:
- your personal and/or professional contact details (such as name and job title, address, email address, phone number, mobile phone number);
- date of birth or age group;
- your gender;
- your driver’s licence number or passport number;
- your Australian Business Number;
- 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 and your references and any other information you provide about yourself in your resume that you submit to us.
General principles for processing personal information
Generally, Kennedy will be guided by the following principles when processing 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 will only collect personal information for specific and specified purposes;
- We will not collect personal information beyond what is necessary to accomplish those purposes;
- We will not use personal information for purposes other than that for which it was collected, for the purposes explained in this policy or otherwise disclosed, , or with prior consent or where otherwise authorised or required by law;
- We will not transfer personal information to third parties or across borders, except as stated herein, or with prior consent;
- We will seek to verify and/or update personal information periodically, and you may request access to and correction of personal information we hold about you;
- We will apply high technical standards to make our processing of personal information secure;
- Except when stated herein, we will not store personal information in identifiable form longer than is necessary to accomplish the relevant purpose, or as is required by law.
Purpose for which we collect and use your personal information
Kennedy collects personal information to:
- facilitate and improve Kennedy’s offerings and services to you;
- deliver and market our products;
- process payments;
- communicate and respond to queries, feedback, communications or complaints from our customers including in relation to our products and services;
- host and manage our events;
- manage our customer accounts and records;
- verify the identity of individuals who use our services;
- protect and ensure the security of our business, networks and services; and
- sales, marketing and business administration.
We may use or disclose your personal information to send you marketing communications about our products, services and events 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.
Transfer of personal data to third parties and/or other countries
Kennedy does purchase supplementary information from public sources to complement our data bases.
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.
We do share personal information with third party vendors when it is necessary to provide services that we don’t perform ourselves, including emailing Kennedy’s newsletters and other correspondence, etc .
We also use third party data hosting companies to store personal information collected by us in their servers, and to do data validation checks for us. All data transfers to third party vendors or partners, including those listed as examples above will be subject to a written contract between us and the third party vendor or partner in question, and the vendor or partner will not have any authority to use such personal information for any purpose other than as instructed by us. Some of Kennedy’s server providers and third-party vendors or partners, that may be located overseas.
When relevant, personal information may be shared among the business units and entities inside and related to Kennedy.
We will disclose personal data when legally obligated to do so under subpoena or court order, or for law enforcement purposes.
Unless you elect otherwise, to keep your choices, some cookies are stored for up 12 months since the last visit. Some cookies are set by third parties which we have chosen to use as suppliers.
Access, review, correction and update of your personal information
You may always contact us to request access to or correction of your personal information we may have stored about you including to ensure it is current, complete and accurate. Kennedy may refuse access to some or all of your personal information if required or permitted 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 or irrelevant. We will take reasonable steps to correct it unless we disagree with your reasons. If we 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. 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.
Access to a number of Kennedy services are protected by access restrictions based on user name and password. It is important that you always choose a password which is hard to guess for others and protect your password against disclosure.
All external transmissions of personal information facilitated by us are protected by encryption. All data storage, at Kennedy and Kennedy operated computer facilities as well as at business partner facilities, will be subject to written contracts which require them to keep the personal information secure and only use or disclose it for the limited purpose for which it was provided.
Generally, processing of personal information will take place in accordance with applicable legislation and best practices concerning data security.
The secure handling of personal information is controlled by documented policies and procedures, including strict physical and logical access control, security back-up, failover, anti-malware protection, monitoring and vulnerability detection mechanisms.
Once Kennedy no longer requires your personal information for any permitted purpose, it will be securely destroyed and/or permanently de-identified.
Please contact Kennedy immediately 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.
While navigating on the Rolex section of our website, you may interact with an embedded website from www.rolex.com. In such case, Privacy Notice and Cookies Policy of www.rolex.com are sole applicable.
If you believe that Kennedy has not handled your personal information in accordance with this Policy or its privacy obligations, please contact us through our Privacy Officer whose details are 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 at:
GPO Box 5218 Sydney NSW 2001
Telephone: 1300 363 992
Contacts details for our Privacy Officer
Privacy Officer: Sharon Gomez
Email address: email@example.com
Phone number: 8614 1100
Address: Kennedy Luxury Group
Level 10, 171 Collins Street, Melbourne 3000 VIC
Last updated June 2019