privacy policies

In this Privacy Policy, the expressions “Medley Jewellery”, "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)).

At Medley Jewellery, we want your online experience to be enjoyable and we take care to respect your privacy when you visit our website. We endeavour to handle your personal information responsibly and to act fairly and honestly with all our customer transactions.

This Privacy Policy applies to personal information collected by us. We are bound by the Australian Privacy Principles and the Privacy Act 1988 (Cth), which govern the way private sector organisations collect, use, keep secure and disclose personal information.

The purpose of this Privacy Policy is to generally inform people of:

  • how and when we collect personal information;
  • how we use and disclose personal information;
  • how we keep personal information secure, accurate and up to date;
  • how an individual can access and correct their personal information; and
  • how we will facilitate or resolve a privacy complaint.

If you have any concerns or complaints about the manner in which your personal information has been collected, used or disclosed by us, we have put in place an effective mechanism and procedure for you to contact us so that we can attempt to resolve the issue or complaint.

Please see Section 14 for further details.

We can be emailed at support@medleyjewellery.com.au or write to us at 7 Smallwood Place, Murarrie QLD Australia 4172 and our privacy officer will then attempt to resolve the issue. We recommend that you keep this information for future reference.

  1. What is personal information?

The Privacy Act 1988 (Cth) defines “personal information” to mean any information or an opinion about an identified individual, or an individual who is reasonably identifiable:

  • whether the information or opinion is true or not; and
  • whether the information or opinion is recorded in a material form or not.

 

  1. The kinds of personal information collected, used and disclosed by Medley Jewellery

We will only use or disclose your personal information for the primary purposes for which it was collected or as consented to by you.

At or around the time we collect personal information from you, we will endeavour to provide you with a notice which details how we will use and disclose that specific information.

Purpose

Type of Information

Uses

Disclosures

Sales and enquiries

  • Contact information: Such as your name, email address, postal and residential addresses, phone numbers, country of residence (and, if applicable, age).
  • Life-event information: Such as your date of birth and other anniversaries (wedding, birthday, partner’s birthday etc).
  • Product Information: Such as products or services you are interested in or products or services that you have purchased from us or our affiliated partners and organisations.
  • Transactional information: Such as
    • Product details and order summary.
    • Details in relation to your financial institution.
    • Payment card type.
    • Card number.
    • Expiry date.
    • CVV number.
    • Proof of ID (e.g. driver’s licence).
  • Customer services: Information collected in connection with us recording calls to our customer services department for quality assurance purposes.
  • The types of uses we will make of personal information collected for this type of purpose include:
  • Identity verification: if required, the verification of your identity and age.
  • Sales and delivery: the provision of our products and services to you including:
    • Using your personal information in order to contact you regarding products, services or events we think would be of interest to you.
    • Payment processing, including charging, credit card authorisation, verification and debt collection.
    • Checks for financial standing and credit-worthiness (as detailed in our Credit Reporting Policy).
    • Delivery.
  • After-sale services:
    • Refunds, exchanges, warranty claims or repairs.
    • Details of current and past products purchased.
    • To provide customer service functions, including handling customer enquiries and complaints.
    • To provide you with product awareness information.
  • Marketing and consumer analytics: using your personal information to:
    • Aggregate with other information we hold about you, and to then use that data for marketing and consumer analytics.
    • Offer you updates, or other content or products and services or events that may be of interest to you.
    • Improve our services (including contacting you about those improvements and asking you to participate in surveys and reviews about our products and services).
    • Marketing and promotional activities by us (including by direct marketing by mail, telemarketing, email, SMS and MMS messages) such as our customer loyalty programs and newsletters.
  • General administrative and security use:
    • To protect the Medley Jewellery website from security threats, theft, fraud, burglary or other criminal activities.
    • The use of your personal information collected in the administration and management of Medley Jewellery.
    • The maintenance and development of our products and services, business systems and infrastructure.
    • In connection with the sale of any part of Medley Jewellery business or a company owned by a Medley Jewellery entity.
    • To provide customer services to customers and for quality assurance purposes when calls are made to our customer services department
  • The types of disclosures we will make of personal information collected for the type of purposes listed include, without limitation, to:
  • Service providers (including IT service providers).
  • Related bodies corporate of Medley Jewellery
  • Third parties connected with the sales and after sales process including, payment platform providers, financial institutions, credit service providers and credit reporting bodies.
  • Third parties connected with the sales process including, on our behalf and any third-party providers who provide us with ecommerce services, or who assist us in providing our products and services to you.
  • Third parties connected with the marketing process including, messaging service providers, marketing list providers or other third parties who assist us in providing our products and services to you.
  • Third parties in connection with the sale of any part of the Medley Jewellery business or a company owned by a Medley Jewellery entity.
  • As required or authorised by law.

Credit services

  • Contact and identifying information:
    • Your name.
    • Address, previous address, time spent at current address and previous address.
    • Date of birth.
    • Marital status.
    • Email address.
    • Residential status (rent, board, home owner etc).
    • Number of dependants (spouse, children, etc).
    • Details of required primary identification information (such as a current Australian drivers’ licence, passport, birth certificate, etc).
    • Details of required secondary identification information (such as a utility bill, rates, Centrelink statement etc).
    • Alternative Contact (name, address and phone number).
  • Credit information: Personal credit information relating to your financial standing, credit and credit worthiness, including, but not limited to:
    • Employment status and details (including time worked and industry).
    • Financial details (weekly income, share of living expenses, mortgage and loan payments, number of credit/store cards, balance and limits of store/credit cards).
    • Requested credit limit.
  • Credit reporting:
    • The processing of any application and the consideration of your credit information.
    • The processing of any payments, refunds or exchanges.
    • For full details relating to uses of personal information in relation to any credit services which are offered via Medley jewellery, please refer to our Credit Reporting Policy.
  • Marketing: In addition, we may also use this type of personal information for marketing purposes (including direct marketing) and:
    • To aggregate with other information we hold about you, and to then use that data for marketing and consumer analytics.
    • Offer you updates, or other content or products and services that may be of interest to you.
    • Improve our services (including contacting you about those improvements and asking you to participate in surveys about our products and services).
    • Marketing and promotional activities by us (including by direct mail, telemarketing, email, SMS and MMS messages) such as our customer loyalty programs and newsletters.
  • General administrative and security use:
    • To protect Medley Jewellery’s website from security threats, theft, fraud, burglary or other criminal activities.
    • The use of your personal information collected in the administration and management of Medley Jewellery
    • The maintenance and development of our products and services, business systems and infrastructure.
    • In connection with the sale of any part Medley Jewellery business or a company owned by a Medley Jewellery entity.

In summary, we may disclose this type of personal information to:

  • The third party credit provider who is (or may) provide the credit services to you, the details of which are set out in our Credit Reporting Policy.
  • Credit reporting agencies and credit providers, the details of which are set out in our Credit Reporting Policy.
  • Our contractors and agents, including but not limited to third party providers who undertake our bill and/or credit services on our behalf and any third party providers who provide us with ecommerce services, or who assist us in providing our products and services to you.
  • Offshore and Australian service providers (including IT service providers), if any.
  • To third parties in connection with the sale of any part of Medley Jewellery’s business or a company owned by a Medley Jewellery’s entity.
  • Related bodies corporate of Medley Jewellery
  • As required or authorised by law.
  • For full details relating to disclosures of personal information in relation to any credit services which are offered via Medley Jewellery, please refer to our Credit Reporting Policy.

Marketing services which includes social media

  • Contact information: Such as your name, email address, current postal and residential addresses, phone numbers, country of residence (and, if applicable, age).
  • Life-event information: Such as your date of birth, anniversaries (wedding, birthday, partner’s birthdays etc).
  • Product and service interests: Such as:
    • Products or services you are interested in.
    • Products or services that you have purchased.
    • Aggregated information provided by services such as Google Analytics.
  • Social media activity: Including “likes”, comments posted, any of your oppositions or feedback, photos posted or uploaded and other information pertaining to your social media activities which concern, or relate, to Medley Jewellery.
  • Events: including your attendance at any event and participation in any competitions or promotions, photos taken or any reviews or product preferences provided by you.
  • Digital device information: Information which identifies your digital devices, such as the media access control address (or MAC address) of your mobile phone or other digital devices, your device ID, geo-location, computer and connection information.
  • General marketing and consumer analytics: using your personal information to:
    • Aggregate with other information and to then use it for marketing and consumer analytics.
    • Segment our audiences based on behaviour online.
    • Inform you when you have left products in your online cart.
    • Offer you updates, or other content or products and services that may be of interest to you.
    • Improve our services (including contacting you about those improvements and asking you to participate in surveys or reviews about our products and services).
    • Marketing and promotional activities by us (including by direct mail, telemarketing, retargeting, email, SMS/MMS messages and social media advertising) such as our customer loyalty programs and newsletters.
    • In connection with the sale of any part of Medley Jewellery’s business or company.
  • Online accounts or social media: If you create an account with Medley Jewellery, attend an event run or facilitated by Medley (or its agents) or participate in our social media platforms (including but not limited to Facebook, Twitter, Google+, YouTube, TikTok, Pinterest,  Instagram) and you provide us your personal information, we will use it for:
    • Drawing and contacting winners.
    • Adding entrants to marketing database.
    • Responding to social media messages.
    • Customer service related contact.
    • Fulfilling social media platform rules.
    • Passport details required for prizes with travel.
  • Identity verification: if required, the verification of your identity and age.
  • Location-based and device-based marketing: we may use information we collect about your geographical location and digital devices (such as your device MAC address) to send you marketing communications.

We may disclose your personal information to:

  • Our third-party partners, including advertising agencies, digital advertising networks (including but not limited to Google, TikTok and Facebook) and shopping networks.
  • Third parties in connection with the sale of any part of Medley Jewellery’s business or a company owned by a Medley Jewellery’s entity.
  • Service providers (including IT service providers).
  • Third parties in connection with the sale of any part of Medley Jewellery’s business or a company owned by a Medley Jewellery entity.
  • Third parties connected with the marketing process including, messaging service providers, marketing list providers or other third parties who assist us in providing our products and services to you.
  • As required or authorised by law.

Human resources

  • Contact information: Such as name, e-mail address, current postal and residential address, phone numbers, country of residence, next of kin contact details.
  • Employee record information
  • Identifying information: Such as your photo, passport and residency details, date of birth.
  • CV, resume or candidacy related information: Such as the details provided in your resume or CV, your eligibility to work in Australia, your education, previous employment details, professional memberships or trade qualifications.
  • Tax, superannuation and payroll information: Such as your Tax File Number and ATO Declaration, Superannuation details and financial institution details.

  • Background check information: Information obtained from you or third parties to perform background checks. In order to perform background checks we may require the following types of information from you:
  • Birth certificate, passport or citizenship certificate.
  • Address over last 5 years.
  • Driver’s licence details and medicare number.
  • Land rate or water rates or other type of utility bill.
  • Credit or debit card details.
  • If applicable, marriage certificate.
  • We may perform the following types of background checks:
  • Bankruptcy and directorship search and company checks
  • Criminal history.
  • Social media activity.
  • Medical or health information which you voluntarily provide to us (we do not require you to provide this information unless it is related to an incident which has occurred during the course of your employment).
  • Performance related information: Including information and metrics collected by Medley Jewellery systems in the course of the employee or contractor’s engagement with Medley Jewellery.
  • Information collected from referees
  • Security information: Such as CCTV security.
  • Background checks: Utilising the information collected for the purpose of assessing candidate suitability for role, including by obtaining:
    • Verification of your identity and age.
    • Criminal history background checks including publicly available information including but not limited to Facebook, Twitter, Instagram, TikTok YouTube.
    • Confirmation of eligibility to work in Australia.
    • Confirmation of education and qualifications.
    • Confirmation of previous employment.
    • Consideration regarding medical leave.
  • Administration and performance monitoring use: Utilising the information collected for the purpose of:
    • Dealings related to the employer/employee relationship or the contractor/principal relationship (as the case may be).
    • Use of such information whether or not the employment or contractor relationship is prospective, current or past.
    • To facilitate any purchase of any products and associated discounts.
    • Use of such information to monitor systems, performance and time usage and internet usage.
  • General administrative and security use:
    • To protect Medley stores, systems and websites from security threats, fraud, theft, burglary or other criminal activities.
    • The use of your personal information collected in the administration and management of Medley.
    • In connection with the sale of any part of Medley’s business or a company owned by a Medley entity.

We may disclose your personal information to:

  • Superannuation – Super Choice.
  • The Australian Taxation Office.
  • Relevant Worker’s Compensation organisation (e.g. WorkCover, Alliance, etc).
  • Third party referees provided by you in connection with an application made to Medley Jewellery.
  • Service providers (including IT service providers), if any.
  • Recruitment agents used in connection with your application with us.
  • Third parties in connection with the sale of any part of Medley Jewellery’s business or a company owned by a Medley Jewellery’s entity.
  • Third party parties in connection with obtaining any background checks, pre-employment screening (including without limitation psychometric services) or loss prevention consultation and implementation programs.
  • Financial institutions for payroll purposes.
  • As required or authorised by law.

 

  1. How Medley collects and holds personal information

 

3.1 Collection generally

As much as possible or unless provided otherwise in this Privacy Policy or a notification, we will collect your personal information directly from you. Most often, this personal information will be collected from you in connection with a purchase you make from us.

When you engage in certain activities, such as entering a contest or promotion filling out a survey or sending us feedback, we may ask you to provide certain information. It is completely optional for you to engage in these activities.

Depending upon the reason for requiring the information, some of the information we ask you to provide may be identified as mandatory or voluntary. If you do not provide the mandatory information or any other information we require in order for us to provide our products or services to you, we may be unable to provide our products or services to you in an effective manner, or at all.

 

3.2 Other collection types

We may also collect personal information about you from other sources, such as competitions and also from third parties. Some examples of these alternative collection events are:

  • (a) trade promotions, competitions and games (whether in-store or online), including those run by us or run by third parties who participate with us;
  • (b) when we collect personal information about you from someone you know, such as someone who buys a gift for you and your personal information is provided in connection with the purchase of that gift;
  • (c) when we use digital devices and applications to automatically collect information about the digital devices you use near our stores or to otherwise interact with us;
  • (d) when we collect personal information about you from a referee provided by you on an application made with us;
  • (e) when we collect personal information about you from credit reporting bodies, in connection with any credit applications made with us or through us as an agent for a third-party credit provider;
  • (f) when we collect personal information about you from third parties (including other retailers) as part of a co-promotion that we participate in; or
  • (g) when we collect personal information about you from publicly available sources including but not limited to court judgments, directorship and bankruptcy searches, Australia Post, White Pages directory, and social media platforms (including but not limited to Facebook, Twitter, Google, Instagram, Pinterest, TikTok, Youtube etc).

3.3 Notification of collection

If we collect details about you from someone else, we will, whenever reasonably possible, make you aware that we have done this and why, unless special circumstances apply, including as described in this clause 3.3(a) to 3.3(d) below. Generally speaking, we will not tell you when we collect personal information about you in the following circumstances:

  • (a) where information is collected from third party credit reporting bodies;
  • (b) where information is collected from any credit referee, trade referee or personal referee you have listed on any application form (including any employment application) with Medley;
  • (c) where information is collected from publicly available sources including but not limited to court judgments, directorship and bankruptcy searches, social media platforms (including but not limited to Facebook, Twitter, Google, Instagram, Pinterest, TikTok, Youtube etc); or
  • (d) as otherwise required or authorised by law.

3.4 Unsolicited personal information

In the event we collect personal information from you, or a third party, in circumstances where we have not requested or solicited that information (known as unsolicited information), and it is determined by Medley Jewellery (in its absolute discretion) that the personal information is not required, we will destroy the information or ensure that the information is de-identified.

In the event that the unsolicited personal information collected is in relation to potential future employment with Medley Jewellery, such as your CV, resume or candidacy related information, and it is determined by Medley Jewellery (in its absolute discretion) that it may consider you for potential future employment, Medley Jewellery may keep the personal information on its human resource records.

3.5 How we hold your personal information

Once we collect your personal information, we will either hold it securely and store it on infrastructure owned or controlled by us or with a third party service provider who have taken reasonable steps to ensure they comply with the Privacy Act 1988 (Cth). We provide some more general information on our security measures in Section 12 (Data security and quality).

  1. Uses and disclosures of personal information

4.1 Use and disclosure details

We provide a detailed list at Section 2 of some common uses and disclosures we make regarding the personal information we collect.

4.2 Other uses and disclosures

We may also use or disclose your personal information and in doing so we are not required to seek your additional consent:

  • (a) when it is disclosed or used for a purpose related to the primary purposes of collection detailed above and you would reasonably expect your personal information to be used or disclosed for such a purpose;
  • (b) if we reasonably believe that the use or disclosure is necessary to lessen or prevent a serious or imminent threat to an individual’s life, health or safety or to lessen or prevent a threat to public health or safety;
  • (c) if we have reason to suspect that unlawful activity has been, or is being, engaged in; or
  • (d) if it is required or authorised by law.

4.3 Use and disclosure procedures

In the event we propose to use or disclose such personal information other than for reasons set out in the above table at Section 2 or as otherwise outlined in this Privacy Policy, we will first notify you or seek your consent prior to such disclosure or use.

Your personal information is disclosed to these organisations or parties only in relation to the products or services we provide to you or for a purpose permitted by this Privacy Policy.

We take such steps as are reasonable to ensure that these organisations or parties are aware of the provisions of this Privacy Policy in relation to your personal information.

4.4 Communications opt-outs

If you have received communications from us and you no longer wish to receive those sorts of communications, you should contact us via the details set out at the top of this document and we will ensure the relevant communication ceases. Any other use or disclosure we make of your personal information will only be as required or authorised by law or as permitted by this Privacy Policy or otherwise with your consent.

  1. Sensitive information

5.1 Sensitive information generally

Sensitive information is a subset of personal information. It means information or opinion about an individual’s racial or ethnic origin, political opinions, membership of a political organisation, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, health information about an individual, genetic information, biometric information that is to be used for the purpose of automated biometric verification or biometric identification or biometric templates.

5.2 Collection and use of sensitive information

In general, we attempt to limit the collection of sensitive information we may collect from you, but depending on the uses you make of our products this may not always be possible and we may collect sensitive information from you in order to carry out the services provided to you. However, we do not collect sensitive information from you without your consent.

The type of sensitive information we may collect about you is dependent on the services provided to you by Medley Jewellery and will be limited to the purpose(s) for which it is collected. We set out some types of sensitive information we may collect about you in the “Human resources” section of the table at Section 2 above.

We do not use sensitive information to send you Direct Marketing Communications (as set out in Section 6 below) without your express consent.

5.3 Consent

We may collect other types of sensitive information where you have consented and agree to the collection of such information. Generally speaking, we will obtain this type of consent from you at (or around) the point in time in which we collect the information.

  1. Direct Marketing

6.1 Express informed consent

You give your express and informed consent to us using your personal information set out in:

  • (a) the “Sales and enquiries (ecommerce and in-store)” row of the table at Section 2 of this document above;
  • (b) the “Credit services” row of the table at Section 2 of this document above; and
  • (c) the “Marketing services which include Social Media” row of the table at Section 2 of this document above,

to provide you with information and to tell you about our products, services or events or any other direct marketing activity (including third party products, services, and events) which we consider may be of interest to you, whether by post, email, SMS, messaging applications and telephone (Direct Marketing Communications).

6.2 Inferred consent and reasonable expectations of direct marketing

Without limitation to paragraph 6.1, if you have provided inferred or implied consent (e.g. not opting out where an opt-out opportunity has been provided to you) or if it is within your reasonable expectation that we send you Direct Marketing Communications given the transaction or communication you have had with us, then we may also use your personal information for the purpose of sending you Direct Marketing Communications which we consider may be of interest to you.

6.3 Opt-out

If at any time you do not wish to receive any further Direct Marketing Communications from us or others under this Section 6, you may ask us not to send you any further information about products and services and not to disclose your information to other organisations for that purpose. You may do this at any time by using the “unsubscribe” facility included in the Direct Marketing Communication or by contacting us via the details set out at the top of this document.

  1. Online Information

7.1 Online information generally

We endeavour to provide clear, complete and up-to-date information online about our business and the products and services we offer. This includes how to get in touch with us. This information helps you to make informed choices.

7.2 Online contracts and ecommerce

We keep complete and accurate records of online contracts when you accept one of our offers. Our system also helps you to keep an accurate record so there is no confusion about the contract.

If you have a problem with any of our products or services that you receive from us, our website provides further information about how to make a complaint, obtain redress or pursue dispute resolution. We can be emailed at support@medleyjewellery.com.au if there is a problem.

7.3 Collections of personal information via linked websites

This website may offer links to other websites. Those websites may also collect your personal information (including information generated through the use of cookies) when you visit them. We are not responsible for how such third parties collect, use or disclose your personal information, so it is important to familiarise yourself with their privacy policies before providing them with your personal information.

7.4 Uses and disclosures for cross border shipments

If you engage in electronic commerce on this website, please be aware that cross border 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 name and titles) to our international carriers and such information may be communicated by the carriers to customs authorities. Customs authorities require the value of the product item to be stated directly on the package.

7.5 Cookies and IP addresses

If you use our website, we may utilise "cookies" which enable us to monitor traffic patterns, trends and to serve you more efficiently if you revisit a Medley Jewellery website. In most cases, a cookie does not identify you personally but may identify your internet service provider or computer.

We may gather your IP address as part of our business activities and to assist with any operational difficulties or support issues with our services. This information does not identify you personally.

However, in some cases, cookies may enable us to aggregate certain information with other personal information we collect and hold about you. For example, we may use information collected by cookies to assist us to enhance your experience with us. Medley Jewellery extends the same privacy protection to your personal information, whether gathered via cookies or from other sources, as detailed in this Privacy Policy.

You can set your browser to notify you when you receive a cookie and this will provide you with an opportunity to either accept or reject it in each instance. However, if you disable cookies, you may not be able to access certain areas of our websites or take advantage of the improved website experience that cookies offer.

  1. Web analytics, display advertising and retargeting

8.1 Persistent cookies

We use persistent cookies to enable basic web traffic analysis. 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 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.

8.2 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. 

The services we use may include in-ads notice labels to disclose interest-based advertising to you. Third-party vendors and search engines, including but not limited to Google, Instagram, TikTok, Youtube and Facebook, will show Medley ads on websites and search-results across the Internet. Medley Jewellery and third-party vendors use first-party cookies (including but not limited to Google Analytics TikTok Pixel and Facebook cookies) and third-party cookies together to inform, optimise, and serve ads based on an individual's past visits to the Medley website.

8.3 Retargeting

We also use retargeting services to display content specific advertisements to visitors that have previously visited our website when those visitors go to other websites.

  1. Credit Information and our Credit Reporting Policy

9.1 Credit information generally

The Privacy Act 1988 (Cth) contains provisions regarding the use and disclosure of credit information, which applies in relation to the provision of both consumer credit and commercial credit.

9.2 Credit information and Medley Jewellery

When you apply for credit in relation to any products or services you may purchase from Medley Jewellery, or where you agree to be a guarantor, we may need to (or our credit provider may need to) carry out credit reference checks in relation to you. One of the credit checks will include, but is not limited to, obtaining a credit report about you.

9.3 Consent

To the extent necessary, you give your express voluntary consent to Medley Jewellery and its credit provider to obtaining credit reports about you from credit reporting bodies. We, or our credit provider, use credit related information for the purposes set out in the “Credit services” section of the table at Section 2 above and our Credit Reporting Policy which includes but is not limited to using the information for our own internal assessment of your credit worthiness.

9.4 Storage and access

To the extent we are required to keep a copy of your application for credit, we will store any credit information you provide us, or which we obtain about you, with any other personal information we may hold about you.

You may request to access or correct your credit information in accordance with the provisions of Section 13 and the provisions of our Credit Reporting Policy.

9.5 Complaints

Please see Section 14 and the provisions of our Credit Reporting Policy if you wish to make a complaint in relation to our handling of your credit information.

9.6 Credit providers and credit reports

Our credit service providers obtain credit reports from credit reporting bodies. More information about this is set out in our Credit Reporting Policy (including information about how those credit report bodies can be contacted).

9.7 Our Credit Reporting Policy

Please see our Credit Reporting Policy for further information as to the manner in which we collect, use, store and disclosure credit information.

  1. Anonymity and pseudo-anonymity

To the extent practicable and reasonable, we will endeavour to provide you with the option of dealing with Medley Jewellery on an anonymous basis or through the use of a pseudonym. However, there may be circumstances in which it is no longer practicable for Medley Jewellery to correspond with you in this manner and your personal information may be required in order to provide you with our products and services or to resolve any issue you may have.

  1. Cross Border Disclosure

11.1 Cross border disclosures

Any personal information collected and held by Medley may be disclosed to, and held at, a destination outside Australia, including but not limited to the jurisdictions set out in our Cross Border Disclosures Table

Generally speaking, this may be because Medley (being part of a global group of organisations) operates in other jurisdictions. Personal information may also be processed by staff or by other third Jewellery parties operating outside Australia who work for us or for one of our suppliers, agents, partners or related companies.

In addition, we may utilise overseas IT services (including software, platforms and infrastructure), such as data storage facilities or other IT infrastructure (Cross Border IT Services). In such cases, we may own or control such overseas infrastructure, or we may have entered into contractual arrangements with third party service providers to assist Medley Jewellery with providing our products and services to you.

Notwithstanding paragraph 11.1, as we utilise Cross Border IT Services and platforms which can be accessed from various countries via an Internet connection, it is not always practicable to know where your information may be held. If your information is stored in this way, disclosures may occur in countries other than those listed in the Cross Border Disclosures Table

11.2 Provision of informed consent

By submitting your personal information to Medley Jewellery, you expressly agree and consent to the disclosure, transfer, storing or processing of your personal information outside of Australia. In providing this consent, you understand and acknowledge that countries outside Australia do not always have the same privacy protection obligations as Australia in relation to personal information. However, we will take steps to ensure that your information is used by third parties securely and in accordance with the terms of this Privacy Policy.

The Privacy Act 1988 (Cth) requires us to take such steps as are reasonable in the circumstances to ensure that any recipients of your personal information outside of Australia do not breach the privacy principles contained within the Privacy Act 1988 (Cth). By providing your consent, under the Privacy Act 1988 (Cth), we are not required to take such steps as may be reasonable in the circumstances. However, despite this, we acknowledge the importance of protecting personal information and have taken reasonable steps to ensure that your information is used by third parties securely and in accordance with the terms of this Privacy Policy.

11.3 If you do not consent

If you do not agree to the disclosure of your personal information outside Australia by Medley Jewellery, you should (after being informed of the cross border disclosure) tell Medley Jewellery that you do not consent. To do this, either elect not to submit the personal information to Medley Jewellery after being reasonably informed in a collection notification or please contact us via the details set out at the top of this document.

  1. Data security and quality

12.1 Medley Jewellery’s security generally

In this age of internet shopping, we have learned that customers require peace of mind when it comes to the security of using the internet. We have taken steps to help ensure your credit card details and other personal information is safe and protected from unauthorised access, use, disclosure, alteration, or destruction. You will appreciate, however, that we cannot guarantee the security of all transmissions or personal information, especially where the Internet is involved.

Notwithstanding the above, we will take reasonable steps to:

  • (a) make sure that the personal information we collect, use or disclose is accurate, complete and up to date;
  • (b) protect your personal information from misuse, loss, unauthorised access, modification or disclosure both physically and through computer security methods; and
  • (c) destroy or permanently de-identify personal information if it is no longer needed for its purpose of collection.

We can’t tell you all of the technical details behind our security systems and processes as this may compromise the effectiveness of them.

12.2 Accuracy

The accuracy of personal information depends largely on the information you provide to us, so we recommend that you:

  • (a) let us know if there are any errors in your personal information; and
  • (b) keep us up-to-date with changes to your personal information (such as your name or address).

We provide information about how you can access and correct your information in Section 13.

  1. Access to and correction of your personal information

You are entitled to have access to any personal information relating to you which we hold, except in some exceptional circumstances provided by law (including the Privacy Act 1988 (Cth)). You are also entitled to edit and correct such information if the information is inaccurate, out of date, incomplete, irrelevant or misleading.

If you would like access to or correct any records of personal information we have about you, you are able to access and update that information (subject to the above) by contacting us via the details set out at the top of this document.

  1. Resolving Privacy Complaints

14.1 Complaints generally

We have put in place an effective mechanism and procedure to resolve privacy complaints. We will ensure that all complaints are dealt with in a reasonably appropriate timeframe so that any decision (if any decision is required to be made) is made expeditiously and in a manner that does not compromise the integrity or quality of any such decision.

14.2 Contacting Medley Jewellery regarding complaints

If you have any concerns or complaints about the manner in which we have collected, used or disclosed and stored your personal information, please contact us by:

- Telephone: 1800 552 546

- Email: support@medleyjewellery.com.au

- Post: 7 Smallwood Place, Murarrie QLD Australia 4172

Please mark your correspondence to the attention of the Privacy Officer.

14.3 Steps we take to resolve a complaint

In order to resolve a complaint, we:

  • (a) will liaise with you to identify and define the nature and cause of the complaint;
  • (b) may request that you provide the details of the complaint in writing;
  • (c) will keep you informed of the likely time within which we will respond to your complaint; and
  • (d) will inform you of the legislative basis (if any) of our decision in resolving such complaint.

14.4 Register of complaints

We will keep a record of the complaint and any action taken in a Register of Complaints.

  1. Consent, modifications and updates

15.1 Interaction of this Policy with contracts

This Privacy Policy is a compliance document prescribed by law rather than a legal contract between two or more persons. However, certain contracts may incorporate all, or part, of this Privacy Policy into the terms of that contract. In such instances, a Medley Jewellery company may incorporate the terms of this policy such that:

  • (a) certain sections or paragraphs in this policy are incorporated into that contract, but in such a way that they do not give rise to contractual obligations onto the Medley entity, but do create contractual obligations on the other party to the contract; and
  • (b) the consents provided in this policy become contractual terms provided by the other party to the contract.

15.2 Acknowledgement

By using our website, purchasing a product or service from Medley Jewellery (whether in store or online) or entering a competition or interacting with us via social media, where you have been provided with a copy of our Privacy Policy or had a copy of our Privacy Policy reasonably available to you, you are acknowledging and agreeing:

  • (a) to provide the consents given by you in this Privacy Policy; and
  • (b) that you have been informed of all of the matters in this Privacy Policy.

15.3 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 cease providing us with your personal information and contact us via the details set out at the top of this document.

Last Updated: 10/03/2023