This Policy applies to all Kennedy Vinciullo services, content and materials (collectively, KV Services).
We may, from time to time, update this Policy; the most recent version will always be available on our website. When we make material changes to this Policy, you will be provided notice of the same, as appropriate in the circumstances, such as by sending you an email. Therefore, please ensure you read any such notice carefully.
- AUSTRALIAN PRIVACY PRINCIPLES
As an Australian business, Kennedy Vinciullo is bound by the Australian Privacy Principles (APPs) set out in the Privacy Act 1988 (Cth) (Act). The purpose of the APPs is to govern standards, rights and obligations surrounding personal information.
The Act defines “personal information” as meaning 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.
In some circumstances, including where it is necessary for the conduct of your matter, we may need to collect sensitive information (as that term is defined in the Act), which includes health information. We must obtain your consent to collect sensitive information (unless an exemption applies).
A copy of the APPs may be obtained from the website of the Office of the Australian Information Commissioner at https://www.oaic.gov.au/privacy/australian-privacy-principles/.
- PERSONAL DATA WE COLLECT FROM YOU
Kennedy Vinciullo collects data from you to provide the best possible service to you, tailored to your particular needs.
We have set out below the categories of personal data that will be collected:
- User Data: this is personal data collected when you register/sign up for KV Services which is provided by you or collected by us to enable you to accept and receive KV Services. This may include your full name, email address, phone number, birth date, business and/or residential address and country.
- Usage Data: this is the personal data collected through your use of the KV Services. This may include your full name, email address, phone number, birth date, business and/or residential address and country.
- Payment & Purchase Data: We may collect certain personal data if you sign up/make a purchase from Kennedy Vinciullo and which enables us to provide you with an overall better service. The exact personal data collected will vary depending on product or service as well as the payment method but will include information such as:
- name, address, postal code, email address and phone number;
- credit or debit card type, expiration date, and certain digits of your card number;
- details of your purchase and payment history; and
- mobile phone number.
The following describes personal data collected from third party sources:
- Authentication partners: if you register for or log into our services using third party credentials, we will import your information from such third party to help create your account with us.
- Payment partners: if you choose to pay for a service via a payment partner, we may receive data from our payment partners to enable us to send you invoices and/or process your payment and provide you with what you’ve purchased.
- Advertisers and other advertising partners: we may obtain certain data about you, such as cookie ID, mobile device ID, or email address, and inferences about your interests and preferences from certain advertisers and advertising partners that allow us to deliver more relevant ads and measure their effectiveness.
- WHAT WE USE YOUR PERSONAL DATA FOR
In addition to providing KV Services to you, Kennedy Vinciullo may process your personal data to:
- improve KV Services;
- maintain our relationship with you;
- for marketing, promotion, and advertising purpose;
- for an employment or potential employment related purpose;
- comply with legal obligations and law enforcement requests;
- for insurance purposes;
- understand, troubleshoot, and address issues with the KV Services;
- fulfil contractual obligations with third parties;
- establish, exercise, or defend legal claims;
- conduct business planning, reporting, and forecasting;
- process your payment; and
- detect fraud, including fraudulent payments and fraudulent use of the service.
- SHARING YOUR PERSONAL DATA
We may share personal data with:
- other service providers: including barristers, experts and law firms in other jurisdictions, and organisations that provide services to us, your professional advisers (e.g. your accountant), auditors for compliance purposes, and/or courts, tribunals and other regulatory authorities, in the conduct of your matter;
- payment processors: we will share your personal data with our payment processors as and when necessary to enable them to process your payments, and for anti-fraud purposes;
- advertising partners: Kennedy Vinciullo and its advertising partners may, from time to time, process certain personal data to help Kennedy Vinciullo understand your preferences so that we may deliver more relevant advertising to you;
- law enforcement and data protection authorities: personal data will be shared when we believe, in good faith, it is necessary for us to do so in order to comply with a legal obligation under applicable law, or respond to valid legal process, such as a search warrant, a court order, or a subpoena. We also share your personal data where we believe, in good faith, that it is necessary for the purpose of our own, or a third party’s legitimate interest relating to national security, law enforcement, litigation, criminal investigation, protecting the safety of any person, or to prevent death or imminent bodily harm, provided that we deem that such interest is not overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data; and
- INTERNATIONAL DATA TRANSFER
Kennedy Vinciullo may subcontract processing to, or share your personal data with, third parties located in countries other than Australia. This is because Kennedy Vinciullo may use providers, such as document management companies, to help securely store your data and keep it safe. Your personal data, therefore, may be subject to privacy laws that are different from those in Australia. The APPs require us to ensure any foreign country is compliant with the APPs, unless you consent otherwise. Any submission of your personal information will constitute consent for such information to be stored, transferred, disclosed or processed outside of Australia.
From time to time, we may display advertisements from third parties and other content that links to third-party websites. Kennedy Vinciullo cannot control or be held responsible for third parties’ privacy practices and content. If you click on a third-party advertisement or link, please understand that you are leaving the KV Service and any personal data you provide will not be covered by this Policy.
- DATA RETENTION & DELETION
Kennedy Vinciullo keeps your personal data only as long as necessary to provide you with the KV Service and for legitimate and essential business purposes, such as maintaining the performance of the KV Service, making data-driven business decisions about new features and offerings, complying with our legal obligations, and resolving disputes. Kennedy Vinciullo keeps some of your personal data for as long as you are a user of the KV Service.
At your request, we will delete or anonymise your personal data so that it no longer identifies you, unless we are legally allowed or required to maintain certain personal data, including situations such as the following:
- if there is an unresolved issue relating to your account;
- where we need to retain the personal data for our legal, tax, audit, and accounting obligations, we will retain the necessary personal data for the period required by applicable law; and/or
- where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users.
- KEEPING YOUR PERSONAL DATA SAFE
Kennedy Vinciullo takes all reasonable steps to protect our clients’ and users’ personal data. We implement appropriate technical and organisational measures to help protect the security of your personal data; however, please note that no system is ever completely secure.
- ACCESS TO PERSONAL DATA
The APPs permit you to obtain access to the personal information we hold about you in certain circumstances, and correct inaccurate personal information subject to certain exceptions. If you would like to obtain such access, please contact us as set out below.
- COMPLAINTS PROCEDURE & HOW TO CONTACT US
If you have a complaint concerning the manner in which we maintain the privacy of your personal information, please contact us as set out below. All complaints will be considered by us, and we may seek further information from you to clarify your concerns. If we agree that your complaint is well founded, we will, in consultation with you, take appropriate steps to rectify the problem. If you remain dissatisfied with the outcome, you may refer the matter to the Office of the Australian Information Commissioner.
Thank you for reading our Policy. If you have any questions about this Policy, please contact Carla Vinciullo who acts our Data Protection Officer by emailing firstname.lastname@example.org, or by writing to us at the following address:
Attention: Carla Vinciullo
PO Box 171
West Perth WA 6872