PRIVACY


Romona Keveza Collection LLC (hereinafter RKC) understands that privacy is important to you.

Please refer to the following privacy information:

Read RKC Privacy Policy for information about how RKC handles Personal Information consistent with our privacy obligations. The Policy includes information on why we collect information, how we use it, who we disclose it to and how we take steps to update and secure it.

Refer to our Privacy Safeguard Statement for information on privacy safeguards on our web site. This includes information as to how we collect, use and disclose information gathered on our web site, including the use of cookies.

1. COLLECTION

1.1 RKC will only collect Personal Information where the information is necessary for RKC to perform one or more of its functions or activities. In this context, "collect" means gather, acquire or obtain by any means, information in circumstances where the individual is identifiable or identified.

1.2 RKC collects Personal Information primarily to supply customers with information about its products and its related companies. RKC also collects and uses Personal Information for secondary purposes including:

      i.        business planning and product development; and

     ii.        to provide individuals with information about promotions, as well as the products and services of RKC affiliated companies and other organizations.

1.3 RKC will not collect Sensitive Information from individuals except with consent and only where it is necessary for RKC to collect such information for an activity or function.

1.4 RKC will not collect Personal Information secretly or in an underhanded way.

1.5 RKC will take steps to ensure that individuals on purchased lists are or have been notified of the information as outlined at 1.3.

2. USE

2.1 RKC will obtain an individual's consent for Use of non-sensitive Personal Information for Secondary Purposes at the time of collection, unless the Use is a related Secondary Purpose which would be within the relevant individual's Reasonable Expectations.

2.2 RKC uses Personal Information primarily for the purposes listed in 1.2 above.

2.3 If RKC relies on the Direct Marketing exception to Direct Market to individuals it will ensure that:

      i.        the individual is clearly notified of their right to Opt Out from further Direct Marketing;

     ii.        there is only one Use of the information before the Opt Out right is given and this Use applies across all RKC Related Bodies Corporate (if the information is shared between those Related Bodies Corporate);

    iii.        the individual is given an Opt Out in all further instances of Direct Marketing if they have not previously chosen to Opt Out; and

    iv.        if the individual Opts Out of all Direct Marketing the Opt Out will be respected by RKC and all its Related Bodies Corporate.

2.4 RKC will not use Sensitive Information for Direct Marketing.

2.5 RKC may use Personal Information to avoid an imminent threat to a person's life or to public safety. It may also use Personal Information for reasons related to law enforcement or internal investigations into unlawful activities.

2.6 RKC will not use Personal Information without taking reasonable steps to ensure that the information is accurate, complete and up to date.

3. DISCLOSURE

3.1 RKC may Disclose Personal Information to related or unrelated third parties if consent has been obtained from the individual. This will include obtaining the individual's consent for Disclosures made.

3.2 RKC may Disclose Personal Information between Related Bodies Corporate. Where information is Disclosed to such a Related Body Corporate, that Related Body Corporate is bound by the original Primary Purpose for which the information was collected.

3.3 RKC may Disclose Personal Information to unrelated third parties to enable outsourcing of functions (such as billing, customer relations management and order fulfillment), where that is Disclosure or Use for a related Secondary Purpose and has been notified to individuals or where such Disclosure is within the individual's Reasonable Expectations.

3.4 RKC may Disclose Personal Information to law enforcement agencies, government agencies, courts or external advisers where permitted or required by law.

3.5 RKC may Disclose Personal Information to avoid an imminent threat to a person's life or to public safety.

3.6 If a Disclosure is not for a Primary Purpose; is not for a related Secondary Purpose; or upfront consent has not been obtained, RKC will not Disclose Personal Information otherwise than in accordance with the exceptions set out at 3.1 to 3.5 above.

3.7 RKC does not generally sell or share its customer lists on a commercial basis with third parties but if it did, it would only do so if we had the appropriate consent of the individual involved. If the consent provided is conditional, RKC will take steps to ensure (by contract) that the use of its customer list by third parties does not exceed the scope of the consent.

4. INFORMATION QUALITY

4.1 RKC will review, on a regular and ongoing basis, its collection and storage practices to ascertain how improvements to accuracy can be achieved.

4.2 RKC will take steps to destroy or de-identify Personal Information after as short a time as possible and after a maximum of seven years from the date of the last customer interaction, unless the law requires otherwise.

5. INFORMATION SECURITY

5.1 RKC requires employees and contractors to perform their duties in a manner that is consistent with RKC’s legal responsibilities in relation to privacy.

5.2 RKC will take all reasonable steps to ensure that paper and electronic records containing Personal Information are stored in facilities that are only accessible by people within RKC who have a genuine "need to know" as well as "right to know".

5.3 RKC will review, on a regular and ongoing basis, its information security practices to ascertain how ongoing responsibilities can be achieved and maintained.

6. ACCESS AND CORRECTION

6.1 RKC will correct its records containing Personal Information as soon as practically possible, at the request of the individual concerned.

6.2 Individuals wishing to lodge a request to access and/or correct their Personal Information should do so by contacting RKC Client Relations Service, as per the details on the website.

6.3 RKC can charge a fee for processing an access request but will generally not do so unless the request is complex or is resource intensive.

7. OPENNESS

7.1 RKC Client Relations Service representatives will be the first point of contact for inquiries about privacy issues. Individuals wishing to make an inquiry or complaint regarding privacy, should do so by contacting RKC Client Relations Service, as per the details on the RKC website.

7.2 RKC websites will contain a prominently displayed privacy statement and will include a copy of RKC Privacy Policy.

8. ANONYMOUS TRANSACTIONS

8.1 RKC will not make it mandatory for visitors to its web sites to provide Personal Information unless such Personal Information is required to answer an inquiry or provide a service. RKC may however request visitors to provide Personal Information voluntarily to RKC (for example, as part of a competition or questionnaire).

9. TRANSFERRING PERSONAL INFORMATION OVERSEAS

9.1 RKC will take reasonable steps to limit the amount of Personal Information it sends to unrelated organizations overseas.

9.2 If Personal Information must be sent by RKC overseas for sound business reasons, RKC will require the overseas organization receiving the information to provide a binding undertaking that it will handle that information in accordance with the National Privacy Principles, preferably as part of the services contract.

10. GLOSSARY

Collection Information means the information outlined in 1.3 notified to individuals prior to, or as soon as practical after, the collection of their Personal Information.

Direct Marketing means the marketing of goods or services through means of communication including written, verbal or electronic means. The goods or services which are marketed may be those of RKC or a Related Body Corporate or those of an independent third party organization.

Disclosure generally means the release of information outside RKC, including under a contract to carry out an "outsourced function".

Opt Out means an individual's expressed request not to receive further Direct Marketing.

Personal Information means information or an opinion (including information or an opinion forming part of a database), whether true or not and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained from the information or opinion.

Primary Purpose is the dominant or fundamental reason for information being collected in a particular transaction.

Reasonable Expectation means a reasonable individual's expectation that their personal information might be Used or Disclosed for the particular purpose.

Related Body Corporate means that where a body corporate is:
• a holding company of another body corporate;
• a subsidiary of another body corporate; or
• a subsidiary of a holding company of another body corporate,

the first mentioned body corporate and the other body corporate are deemed to be related to each other.

Sensitive Information means:

a.     information or an opinion about an individual's:

                      i.        racial or ethnic origin; or

                     ii.        political opinions; or

                    iii.        membership of a political association; or

                    iv.        religious beliefs or affiliations; or

                     v.        philosophical beliefs; or

                    vi.        membership of a professional or trade association; or

                   vii.        membership of a trade union; or

                  viii.        sexual preferences or practices; or

                    ix.        criminal record;

b.    health Information about an individual.

Use means the handling of Personal Information within RKC.

Privacy Safeguard Statement

1. What Personal Information does RKC collect?

The types of personal information that RKC records will depend on your usage of our site. If you carry out a transaction online or send us an email, RKC will record information that may differ from the information RKC collects if you simply visit our site.

      i.        General requests: You can use the online forms for a number of purposes such as to request further information about other products and services. In order to process your request, we will require you to provide us with certain personal information. This includes such details as your name and contact information and information about any existing account. If you send us an email request, we will ask for similar information. We require this information to process your request and to improve the services we provide to you. When you are simply making a query, RKC may also ask for information such as details about yourself in order that RKC can better tailor its services or products to your needs and to provide you with information about a range of RKC services or products you might be interested in. RKC may also conduct voluntary surveys or request other voluntary information from time to time. These surveys provide RKC with important information that enables improvement in the types and quality of services offered and the manner in which those services are offered. It will always be clear whether the information requested is mandatory or voluntary.

     ii.        Navigation Information: Each time you visit RKC's web site, anonymous navigation information is collected by our servers. This information includes:

             o     the type of browser and operating system you are using;

             o     the address of the referring site (ie the previous site you had visited) and the website you leave our site to visit;

             o     the date and time of your visit;

             o     your server's IP address (a number which is unique to the machine); and

             o     the address of the pages you accessed.

This provides RKC with information about how the web site is used and navigated, including the number of hits, the frequency of visits and the duration of visits to each web page on the site. It does not personally identify individual users unless the user has previously elected to identify themselves by submitting personal information. In addition, RKC's web site, like many others, uses cookies. A cookie is a piece of information that the website sends to your browser and which is stored on your hard disk. A cookie helps to identify your browser to the website when you return to visit the site and identifies the previous requests your browser has made. This allows the site to be tailored to you on your return visits. Cookies cannot identify you personally. If you do not wish to receive cookies it is likely that you can disable their use by altering the security settings on your web browser however this may impede your ability to use parts of the site. Your web browser might also contain a mechanism that warns you that a site you are visiting makes use of cookies.

2. What Happens with Your Personal Information?

The personal information collected from you at this site is or may be used:

to notify you about other or new services or promotions from time to time;
to provide customer support;
in order to provide you with the products, services or information you have requested.

Aspects of these functions may be outsourced to third parties who are only authorized by RKC to use this information for these purposes. RKC may also use its customer database, including information provided by you through this web site, to distribute information about other RKC services and other organizations' services to you. If at any time you no longer wish to receive email or postal communications from RKC or from third parties, you can contact RKC Client Relations at any time and make an 'opt out' request, as per details at the end of this Statement.

Information collected on this site may also be combined and de-identified to provide RKC with anonymous demographic and usage information. RKC can then use this aggregated information to develop new and/or more appropriate services and products to offer to customers and may also be provided to third parties.

In addition, anonymous navigation information may be used for statistical analysis of the site, for marketing purposes and to tailor the content of the site to the needs of RKC customers. Statistical information is not disclosed in connection with your personal information.

3. Will personal information be given to anyone else?

Personal information collected at this site will only be disclosed to third parties in accordance with this Privacy Statement and with the terms and conditions of any relevant service. You should check the terms and conditions of individual products and services for information about disclosures.

Information collected at this site may be disclosed to third parties where functions are being outsourced. RKC may also disclose personal information to law enforcement agencies, government agencies, courts or external advisors where permitted or required by law.

4. Access and Correction

You can lodge a correction request with RKC Client Relations at any time as per the details at the end of this Statement.

5. Are personal account details safe when being transmitted?

RKC strives to protect your personal information during its transmission. Customer account information provided through this site is held in a secure server environment behind RKC firewalls.

RKC's secure server software (SSL) is the industry standard and among the best software available today for secure commerce transactions. It encrypts all of your personal information, including your name and address, so that it cannot be read as the information travels over the Internet. However, while RKC maintains high standards in protecting your security, no transmission over the Internet or storage of information on servers connected to the Internet can be guaranteed to be absolutely secure.

6. Are personal account details stored safely?

RKC takes reasonable steps to ensure the security of personal information held by it from such risks as loss or unauthorized access, destruction, use, modification or disclosure of data. RKC only permits your details to be accessed by authorized personnel.