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Pandora Jewelry Privacy Policy

  1. Our commitment to your privacy
    1. This document is the privacy policy of Pandora Jewelry Pty Ltd (ACN 114 638 970) and its related bodies corporate (PANDORA, we or us).
    2. At PANDORA, we are fully committed to respecting the privacy of our customers, business partners, contractors, suppliers and employees in the performance of our business activities.
    3. This policy describes how we will comply with the obligations contained in the Privacy Act 1988 (Cth) (Privacy Act).
  2. What personal information do we collect and hold?
    1. When used in this privacy policy, the term “personal information” has the meaning given to that term in the Privacy Act. In general terms, “personal information” is any information that can be used to personally identify you. Examples of personal information include names, addresses, email addresses and telephone numbers. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.
    2. We may collect the following types of personal information:
      (1) name;
      (2) mailing, email or street address;
      (3) telephone or facsimile number;
      (4) age or birth date;
      (5) profession, occupation or job title;
      (6) details of the products and services you have purchased from us or which you have enquired about, together with any additional information necessary to deliver those products and services and to respond to your enquiries;
      (7) any additional information relating to you that you provide to us directly through our websites or indirectly through use of our websites or your online presence, through our representatives or otherwise; and
      (8) information you provide to us at our stores (including stores operated by franchisees and authorised retailers), via customer surveys or in telephone conversations with us from time to time.
    3. We may also collect some information that is not personal information because it does not identify you or anyone else. For example, we may collect anonymous answers to surveys or aggregated information about how users use our website.
  3. How do we collect your personal information?
    1. We will collect your personal information directly from you unless it is unreasonable or impracticable to do so. When collecting personal information from you, we may collect that information in various ways, including when you:
      (1) access or use our website;
      (2) speak with one of our representatives, either in a store or by telephone;
      (3) complete an application or purchase order;
      (4) order products from us;
      (5) contact us for information;
      (6) require a refund or exchange;
      (7) participate in surveys or research;
      (8) enter a promotion;
      (9) subscribe to the PANDORA Club or mailing lists;
      (10) register your details on our website;
      (11) apply for a franchise or retail account; or
      (12) submit a job application or accept employment with us.
    2. We may also collect personal information from third parties including:
      (1) from third party companies such as credit reporting bureaus, law enforcement agencies and other government entities;
      (2) PANDORA franchisees; and
      (3) PANDORA authorised distributors and retailers.
    3. If you do not provide us with the personal information described above, some or all of the following may happen:
      (1) we may not be able to provide the requested products or services to you, either to the same standard or at all;
      (2) we may not be able to provide you with information about products and services that you may want, including information about discounts, sales or special promotions; or
      (3) we may be unable to tailor the content of our websites to your preferences and your experience of our websites may not be as enjoyable or useful.
  4. Sensitive information
    Sensitive Information is information or opinion about such things as race, ethnicity, criminal records and health information and other meanings as set out in the Privacy Act. Sensitive information will be used by us only for the purpose for which it was obtained and with your consent or where required or authorised by law.
  5. Using personal information
    1. We collect personal information about you so that we can perform our business activities and functions and to provide quality customer service.
    2. We collect, hold, use and disclose your personal information for the following purposes:
      (1) to complete sales transactions;
      (2) to deal with queries or customer service issues. We may also keep information on your communications with our sales team through our Customer Relationship Management (CRM) System;
      (3) to keep you up-to-date with products, services, events and promotions that we think would be of particular interest through a variety of channels;
      (4) to conduct business processing functions including providing personal information to our related bodies corporate, contractors, service providers or other third parties;
      (5) for the administrative, marketing (including direct marketing), planning, product or service development, quality control and research purposes of PANDORA, its related bodies corporate, contractors or service providers;
      (6) for training, employment or employment application purposes;
      (7) for planning, product development or research purposes;
      (8) to process and respond to any complaint made by you; and
      (9) to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority of any country (or political sub-division of a country).
    3. We may send you direct marketing communications and information about our products and services that we consider may be of interest to you. These communications may be sent in various forms, including mail, SMS, fax and email, in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth). If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so. In addition, at any time you may opt-out of receiving marketing communications from us by contacting us (see the details below) or by using the opt-out facilities provided in the marketing communications. We will then ensure that your name is removed from our mailing list.
  6. Disclosing personal information
    1. We only send or disclose your personal information to third party organisations when:
      (1) we have your consent to share your information;
      (2) we need to share your information in order to provide the product or service you have requested;
      (3) we otherwise have a need to send your information to third party service providers; or
      (4) we are required or authorised by law to disclose the information.
    2. We may disclose your personal information to our employees, related bodies corporate (including our Danish parent PANDORA A/S), contractors or service providers for the purposes of operating our website or our business, fulfilling requests by you, and to otherwise provide products and services to you. Examples of the third party service providers that we disclose your personal information to include, without limitation, web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, debt collectors, and professional advisors such as accountants, solicitors, business advisors and consultants.
    3. We may also disclose your personal information to suppliers and other third parties with whom we have commercial relationships, for business, marketing, and related purposes.
  7. Our website
    1. This privacy policy also applies to the use of our website.
    2. When you access our website, we may send a “cookie” (which is a small summary file containing a unique ID number) to your computer. This enables us to recognise your computer and greet you each time you visit our website without bothering you with a request to register. It also enables us to keep track of products or services you view so that, if you consent, we can send you news about those products or services. We also use cookies to measure traffic patterns, to determine which areas of our website have been visited and to measure transaction patterns in the aggregate. We use this to research our users’ habits so that we can improve our online products and services. Our cookies do not collect personal information. If you do not wish to receive cookies, you can set your browser so that your computer does not accept them.
    3. We may log IP addresses (that is, the electronic addresses of computers connected to the internet) to analyse trends, administer the website, track users movements, and gather broad demographic information.
    4. As our website is linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.
    5. Our website may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing you about their own privacy practices.
  8. Data quality
    1. PANDORA will take reasonable steps to make sure that the personal information it collects, uses or discloses is accurate, complete and up-to-date.
  9. Data security
    1. PANDORA is committed to ensuring the security of personal information and will take reasonable precautions to protect this information from loss, misuse or alteration and from unauthorised access, modification or disclosure. Also, see paragraph 7.4 of this privacy policy.
    2. We may hold your information in either electronic or hard copy form. Personal information is destroyed or de-identified when no longer needed or where we are no longer required by law to retain it (whichever is the later).
  10. Data location and overseas recipients
    1. We may disclose your personal information for the purposes listed above to entities located outside of Australia, including:
      (1) our related bodies corporate;
      (2) our data hosting and other IT service providers; and
      (3) third party suppliers and service providers.
      Such overseas recipients are likely to be located in Denmark.
    2. We take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information.
  11. Access and correction
    1. You may request access to any personal information we hold about you at any time by contacting us (see contact details below). Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you).
    2. There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.
    3. If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment then we will add a note to the personal information stating that you disagree with it.
  12. Complaints
    1. If you believe that your privacy has been breached, please contact us using the contact information below and provide details of the incident so that we can investigate it.
    2. We will treat your complaint confidentially. Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in timely and appropriate manner.
    3. If you are not satisfied with our handling of your complaint or our proposed resolution, you have a right to lodge a further complaint with the Office of the Australian Information Commissioner (for more information, please see www.oaic.gov.au). The Office of the Australian Information Commissioner can provide you with further information about the next steps in its complaints process.
  13. Policy changes
    1. PANDORA may make changes to this Privacy Policy from time to time for any reason, including without limitation in order to comply with any future amendments to the Privacy Act. Any updated versions of this privacy policy will be effective from the date of posting on our website.
    2. This privacy policy was last updated on 12 March 2014.
  14. Contact
    1. If you have any questions about this privacy policy or if you have any concerns or a complaint regarding the treatment of your personal information, you should contact our Compliance Officer using the details set out below.

      Post: Attn: The Compliance Officer
      PANDORA Jewelry
      PO Box 906
      Newport NSW 2106
      Tel: +61 (0)2 9986 0660
      Email: au-info@pandora.net

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