privacy policies
Medley Privacy Policy
Last updated: January 2024
1. Who we are
In this Privacy Policy, the expressions “Medley”, "we", "us" and "our" are a reference to Medley Jewellery Pty Ltd ACN 168 235 514 and its Related Bodies Corporate (as defined by the provisions of the Corporations Act 2001 (Cth)).
2. About this Policy
This Privacy Policy describes how we manage your personal information and comply with our obligations under applicable privacy laws.
By providing personal information to us, you consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy and any other arrangements that apply between us. We may change our Privacy Policy from time to time by publishing changes to it on our website. We encourage you to check our website periodically to ensure that you are aware of our current Privacy Policy.
This Privacy Policy should be read in conjunction with any privacy collection notice or statement that we provide to you.
3. What personal information do we collect, hold, use and disclose?
Personal information is information which relates to an identified or reasonably identifiable individual. Generally, the types of personal information we collect about you are limited to information that is needed to facilitate your dealings with us, facilitate your purchases in store and online, and information about how you engage with our website or products and services.
The information we collect may include:
• your contact details, including identification information such as your date of birth;
• information about reason for purchase (for example a 16th, 18th or 21st birthday gift, engagement, wedding, other relationship anniversary);
• payment and account information (for example, credit/debit card details, including card type, card number and expiry date and other financial details);
• identity information (for example, government identifiers such as passport details, driver licence details, bank cards, account statements or utility bills);
• audio (voice recordings from your conversations with our customer sales team or from a virtual sales appointment with one of our sales professionals);
• information about your financial and personal circumstances (for example, your employment status and details);
• electronic and visual information (for example, instore video surveillance footage);
• information about the products or services you have purchased or are interested in; and
• information about how you interact with our websites, such as information about your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from websites, advertising data, IP address and standard web log information and cookies and other tracking technologies, such as beacons and information derived from the digital devices you use near our stores, to help ensure our website and services are able to function properly. Some of this data is not personally identifiable to you and will be aggregated and anonymised for analytics purposes (such as device IDs).
Sensitive information
Sensitive information includes information such as sexual orientation, biometric and genetic information, health information, religious beliefs, ethnic and racial origin, and trade union beliefs.
In general, we attempt to limit the sensitive information we may collect from our customers, however, we may collect sensitive information from you in order to provide you with our products and services. We do not collect sensitive information from you without your consent.
If you have business dealings with us, apply for a job with us or are employed by us, we may also collect your professional or employment-related information, which may include sensitive information.
4. Why do we collect, hold, use and disclose personal information?
If you are a customer or potential customer, we collect, use and disclose your information to provide you with our products and services, to provide you with information about our products and services, to otherwise facilitate your dealings with us and for any other purpose with your consent. If you have business dealings with us or you are an employee or prospective employee, we collect and use your information to manage your relationship with us.
In addition to the purposes described below, we will inform you of the purposes for which your personal information is collected when or before it is collected. If we intend to use the personal information we have collected for purposes not previously communicated, we will ask for your consent before doing so, unless applicable laws allow us to do so without your consent.
Below is a list of the key purposes for processing the personal information of our customers, prospective customers, employees, prospective employees, contractors, and business partners:
Providing products and services to you
• To provide you with our products and services that you have ordered (fulfilling orders in store and online, and processing repairs, special orders and returns).
• To process transactions and payments relating to our provision of products and services to you.
• To manage our customer relationship with you.
• To optimise our products and services, our website, and your experience (for example, by aggregating the information we hold about you, including matching that information with information provided to us by third parties, performing analytics, conducting research for advertising and marketing, and creating personalised advertising).
• To help to recognise you when you visit our website and show you content which may be of interest to you.
• To verify your identity (for example, this may be required in accordance with our instore policies for products of a certain value).
Communicating with you
• To communicate with you (including for marketing purposes or when you complete a transaction on our website).
• To conduct surveys, competitions and other promotional activities managed by us or our business partners.
• To identify products and services which may be of interest to you and to notify you of these (this can also include reminders or updates about products you’ve notified us you are interested in).
• To provide relevant after-sale services, respond to your enquiries and resolve complaints.
• To create and display advertising and marketing in a way that is personalised to you (including online advertising and marketing and telephone marketing for selected campaigns).
• To let you know of updates relating to our Related Bodies Corporate that we think may be of interest to you.
Managing our employee relationships
• To undertake background checks when you apply for a role.
• To administer and respond to your application to work with us.
• To manage our employees in accordance with our recruitment and HR practices.
• To provide you with access to, and to record your attendance at, one of our physical sites or locations.
• To communicate with you or process information in the ordinary course of any business you undertake with us as an employee, contractor or service provider (or as an employee of a contractor or service provider).
• To contact you about relevant company matters relating to your employment or business relationship with us, and seek your feedback.
• To provide our ongoing training, development, promotion, and career and succession planning services.
• To properly manage our business affairs.
Operating our business
• To develop our employee training resources.
• To facilitate a sale or transfer of assets or other corporate transaction.
• To manage our business risk and undertake reasonable mitigation controls to reduce fraud and other illegal behaviour.
• To manage and resolve complaints, disputes or other legal action.
• Where required by applicable laws, to report to regulatory authorities (for example, under data security laws or anti-money laundering laws).
• To comply with our legal obligations.
• To run a lawful business.
• To share information with our Related Bodies Corporate.
• To process your personal information when one of our Related Bodies Corporate is responsible for providing a product or service to you or to us.
5. How do we collect personal information?
We collect personal information:
• directly from you (for example when you: purchase products or services from us, book an appointment instore or online with our one our sales professionals, call our customer services team, complete a survey, provide feedback or enter a competition or promotion, interact with us for any reason on our website or via our customer service channels - including from cookies or other tracking technologies placed on our websites, or when you connect with us via social media);
• from our third party partners (for example when you: participate in a promotion that we run with a partner such as another retailer we may collect your information from that partner; apply to purchase a product with one of our credit or buy now pay later service partners - including to notify you whether or not your application for credit was successful, use our virtual sales process - including your conversations with our online sales professionals which may be recorded, processed by a third party and handled by us for internal training purposes, or from your insurer or claims management company - including when we are assisting you to make an insurance purchase and your insurer passes your information to us);
• through other means (for example: from someone you know when they buy a gift for you and provide your information when purchasing that gift, from publicly available sources including court judgments, directorship and bankruptcy searches, and the White Pages directory and via social media platforms including Meta, X (Twitter) and TikTok including from cookies placed on those sites); and
• via audio and camera surveillance (such as CCTV) at our stores and other premises.
In some cases, we will also match personal information we hold about you to other information held by third parties or other publicly available information, in order to enhance and improve our understanding of our customers. We will only use such information for internal analytics to provide better services. If you do not wish for this to occur in respect of your personal information, you may request that we do not collect and handle your personal information in this way by contacting us using the details set out in this Policy.
6. To whom do we disclose your personal information?
We may disclose your personal information for the purposes described in this Privacy Policy to:
• our employees, contractors, consultants and other agents;
• our Related Bodies Corporate and their employees, contractors, consultants and other agents;
• our third party partners such as advertising agencies (including online advertising agencies);
• marketing analytics agencies (including online marketing analytics agencies) and to trusted third parties for the purpose of matching and enhancing personal information we hold about you (except where you have opted out of such data enhancement);
• third party suppliers and service providers (including providers for the operation of our websites and/or our business or in connection with providing our products and services, for example repairers);
• our professional advisers, agents and insurers;
• payment systems operators (including merchants receiving card payments);
• our sponsors or promoters of any competition that we conduct;
• anyone to whom our assets or businesses (or any part of them) are transferred;
• specific third parties authorised by you to receive information held by us, such as insurance companies; and
• other persons such as government agencies, regulatory bodies and law enforcement agencies as required or authorised by law (for example, CCTV footage may be provided to law enforcement agencies and insurers in connection with the management of the security of our premises).
If you purchase products and require cross border shipment, these shipments are subject to opening and inspection by customs authorities. In order to facilitate customs clearance and comply with local laws, we may provide certain order, shipment and product information (such as your name and title) to our international carriers and such information may be communicated by the carriers to customs authorities.
When we disclose your personal information to third party service providers, where applicable we will make those providers aware of the confidential nature of your personal information. If required under the privacy laws, that information is disclosed on a “need to know” basis only.
7. How do we store your personal information?
7.1 Security and storage of personal information
We generally hold personal information in our electronic databases but may also store your personal information in hard copy form and in various third party databases and platforms. We cannot guarantee the security of your personal information, but we take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information.
7.2 Information we keep about you that is needed to manage you as a customer
We will store your personal information for as long as you are a customer. We may retain your personal information for at least ten years after you stop being a customer in order to comply with our legal obligations, our contractual obligations or to respond to any questions or complaints you may have regarding our transactions or interactions with you, or the products and services you have purchased from us.
Note: We may also need to keep your personal information for a longer period but only where this is required or permitted by applicable law or regulations.
7.3 Information that we keep about you which is not related to your relationship with us as a customer
If you are not a customer and/or if we handle personal information about you that is separate to our relationship with you as a customer (for example, information about your interaction with our website or information about your engagement with our marketing), we will retain your personal information for as long as we continue to interact with you (including via our website), with the exception of where you request to opt out from those interactions. We will use reasonable endeavours to retain your personal information for only the period when your account is active (subject to any reasonable request to delete information).
Note: We may also need to keep your personal information for a longer period but only where this is required or permitted by applicable law or regulations.
8. Overseas disclosure
To operate our business, we may disclose personal information outside of the country of purchase, including to our Related Bodies Corporate in Australia, New Zealand and Canada and to our service providers located in the UK, USA, Canada, New Zealand, Hong Kong, India, Sri Lanka, and the Philippines. Since we are headquartered in Australia, we will usually handle your personal information in Australia.
9. Direct marketing
We and/or our carefully selected business partners may send you direct marketing communications and information about our products and services. This may take the form of emails, SMS, telephone calls, mail or other forms of communication. You may opt out of receiving marketing materials from us by using the opt out facilities provided (for example, an unsubscribe link), or by contacting us using the details set out at the end of this Policy.
10. Using our website and cookies
• While 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 and the internet protocol address assigned to your computer.
• We may also use cookies or other similar tracking technologies on our website that help us track your use of our websites and remember your preferences. Cookies are small files that store information on your computer, TV, 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 websites may not work as intended for you if you do so.
• We may also use cookies to enable us to collect data that may include personal information. For example, where a cookie is linked to your customer account, it will be considered personal information under applicable privacy laws. We will handle any personal information collected by cookies in the same way that we handle all other personal information as described in this Privacy Policy.
10.1 Persistent cookies
We use persistent cookies to enable basic web traffic analysis and enable personalised product recommendations. We engage a number of web analytics service providers to conduct this analysis. This analysis, amongst other things, shows us which areas of our website are popular against those that are not visited often. This allows us to prioritise our enhancements to our website and increase the productivity of our website. In some cases, cookies may enable us to aggregate certain information with other personal information that we collect and hold about you. For example, we may use information collected by cookies to assist us to enhance your experience with us. We also use persistent cookies in relation to affiliate marketing with web based traffic through affiliate networks.
10.2 Web analytics tools
Our web analytics service providers use a range of analysis tools on our website. These tools do not use any sensitive personal information you have provided us, nor do they use any personal information. We may tag your activity on our website with a non-identifying reference that we may later use to link your website activity with your existing customer profile.
The services we use may include In-Ads Notice Labels to disclose interest-based advertising to you. Third-party vendors and search engines, for example Google and Meta, may show our adverts on websites and search-results across the Internet. We and our third-party vendors use first-party cookies (such as the Google Analytics and the Meta cookie) and third-party cookies together to inform, optimise, and serve adverts based on your past visits to our website.
10.3 Retargeting
We also use retargeting services to display content specific adverts to visitors that have previously visited our website when those visitors go to other websites.
11. Accessing or correcting your personal information
We make every effort to maintain the accuracy and completeness of your personal information that we store and to ensure that your personal information is up to date. You have a right to access or correct your personal information.
You can access the personal information we hold about you by contacting us using the information at the end of this Privacy Policy. Sometimes, we may not be able to provide you with access to all of your personal information and, where this is the case, we will tell you why. We may also need to verify your identity when you request to access or correct your personal information.
If you think that any personal information we hold about you is inaccurate, please contact us.
Any such request must contain sufficient details for us to be able to address it. We agree to respond to any such request within a reasonable period of time.
12. Privacy rights
In certain circumstances, you may have additional rights with respect to the personal information that we or anyone acting on our behalf holds about you under applicable privacy laws. These additional rights are described in more detail in this section. You may generally seek to exercise these rights by contacting us.
We may not be required to allow you to exercise these rights under law and, where we are not obliged to comply with your request and it is operationally difficult for us to do so, we will let you know as soon as possible.
12.1 Withdrawal of consent
Where we rely on your voluntary consent to use, store, process or disclose your personal information, you may have a right to withdraw your consent. Should you withdraw your consent, we will, where required by law, stop processing activities relevant to your consent. We agree to process any such request within a reasonable period of time.
12.2 Access, correction and portability of your personal information and other rights
Under some privacy laws, you may be entitled to exercise the following rights:
• To object to the use of your personal information for direct marketing.
• To request confirmation of whether we store your personal information, and where we do store your personal information, you can request access to it.
• To have access to any personal information relating to you which we store, except in some exceptional circumstances provided by law. This information shall be provided to you in a structured, commonly used and machine-readable format.
• To edit and correct such information (and/or request that we do so) if you consider that the information is inaccurate, out of date, incomplete, irrelevant or misleading.
• To ask us to stop or to restrict our processing of your personal information if the information we are using about you is not correct, or where we have not provided you with a reason regarding our processing of your information in accordance with applicable laws.
• To ask us to delete personal information that we hold about you in certain circumstances, noting we may not be able to nor required to delete personal information where we have a legal basis to retain and use this personal information (i.e. where a transactional or contractual relationship exists or for compliance purposes). Where this is the case, we will tell you why.
• To request confirmation of the categories of persons who may have access to personal information within our systems and for how long the personal information may be kept.
Where we have disclosed your personal information to a third party and you request to access, correct or delete your personal information, we will inform that third party of any requests you make to us to access, correct or delete your personal information or restrict the use of your personal information.
13. Links to third party websites
Our website may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. Those websites may also collect your personal information when you visit them (including information generated through the use of cookies). The privacy policies that apply to those other websites may differ substantially from our Privacy Policy, so we encourage you to read them carefully before using those websites.
14. Complaints
If you believe that we have breached any privacy law, or you wish to make a complaint about the way we have handled your personal information, you can contact us using the details at the end of this Privacy Policy. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time.
If you think that we have failed to resolve the complaint satisfactorily or would prefer to directly lodge your complaint with the relevant body, you may lodge a complaint with the Office of the Australian Information Commissioner. For further information on how to make a complaint, you can visit Privacy complaints - Home (oaic.gov.au), or phone 1300 363 992. For users from any other location, contact your local information commissioner.
15. Modifications and updates
We reserve the right to modify our Privacy Policy as our business needs require. We will take reasonable steps to notify you of such changes (whether by direct communication or by posting a
notice on our website). If you do not agree to our continued use of your personal information due to the changes in our Privacy Policy, please contact us.
16. How to contact us
For further information about our Privacy Policy, please contact us at:
Medley website and store customers:
Attention: Privacy Officer Email: contactus@medleyjewellery.com.au
Phone 1800522546
Last updated: 2 January 2024