CURRENT AS OF 15 JULY 2016

Introduction

At J. L. Footwear Pty Ltd ACN 065 208 077 ("Nine West", "we", "us") your privacy is important to us. We are committed to protecting your privacy when managing your personal information. We have policies and procedures to ensure that all personal information is handled carefully and securely in accordance with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) ("Privacy Act").

The purpose of this Privacy Policy is to tell you:

• what kind of personal information we may gather about you;
• how we may use that information and the choices you have regarding our use of such information;
• whether we disclose your personal information to anyone;
• how you may inquire, access and/or seek correction of your personal information and our access and correction handling procedure; and
• how you may alert us about an alleged breach of the APPs and our complaint handling procedure.

Collection of information

The types of information that Nine West collects from you will depend on the circumstances of collection and on the service that we are providing to you.

Personal information

The type of personal information collected will be directly related to the specified purpose it has been collected for. How much of your personal information that you choose to disclose to us is completely up to you. The only way we know something about you personally is if you provide it to us. However, failure to provide certain information may result in Nine West’s being unable to provide you with the relevant product or service. We will make you aware of the purpose for which we collect the personal information and, where possible, the consequences of not providing it at the time of collection.

For example:

• If you request products or services from us, we may collect information such as your name and contact details (ie billing and/or postal address, phone number(s) or email address), and/or credit card details.
• If you sign up to use a particular service such as our newsletter(s) and e-newsletters, mail outs (about product updates and developments, special events or promotions), loyalty or rewards program(s) or enter into a competition operated by us, we may collect information such as your date of birth and your interests and any other information required to provide that service to you (in addition to your name and contact details)
• If you participate in any surveys we, or a third party service provider acting on our behalf, may conduct from time to time on our website, personal information relating to your survey responses
• If you make an inquiry, provide feedback or make a complaint to us, we may collect your name and contact details
• If you are applying for employment with us, we may collect any information that is relevant to such employment including:
• your name and contact details (ie residential address, phone number(s) and/or email address); and
• any other information relevant to the recruitment process (including any information contained in the application form and your resume)

You acknowledge that the personal information we collect from you is your own information or information which you have been authorised to provide us.

Sensitive information

Nine West does not generally collect sensitive information as defined under the Privacy Act, such as racial or ethnicity information, political opinions or associations, criminal records or health information. However, subject to obtaining your prior consent, Nine West may collect sensitive information from you in the course of considering an application for employment.

Unsolicited information

Where unsolicited information is received by Nine West (such as through our Facebook page) we will determine, within a reasonable period of time, whether or not we would be permitted to collect the information under the APPs. If it would not be permitted for Nine West to collect the information, we will destroy the information or ensure it is de-identified as soon as practicable. Otherwise, Nine West may retain the information in accordance with the terms of this policy.

Anonymous information

We may also collect information about visitors to our website(s). For example, we may collect:

• statistical information about the number of visitors to the websites and the date, time and duration of visits;
• the name of the domain/URL from which you access our websites;
• the internet protocol address

However, we do not collect information about the identity of the visitors unless they voluntarily provide that information.

Method of collection

This personal information will only be collected through lawful and fair means and not in an unreasonably intrusive way.

Nine West collects your personal information when you deal with us directly, including via our website(s) or our Facebook page, via forms or correspondence (ie by mail or email), over the phone or in person.

Nine West may also collect personal information through our related bodies corporate and our third party service providers (such as data relating to survey responses) so that we may provide a better or more relevant product to you.

Use of information

Use of personal information

Nine West will use the personal information you have chosen to provide us for the purpose for which you provided it or a related secondary purpose which you would reasonably expect. Nine West will not use it for any other purpose without your consent, unless permitted or required by law.

Generally, we will use your personal information for the following purposes:

• providing the products and/or services you have requested from Nine West including for example:
  • to process sales transactions (whether in store or online);
  • to deliver the products or services to you;
  • to register you for a service requested by you, such as our newsletter(s) --- and e-newsletters, mail outs, rewards program(s) or competitions and administering such services;
  • to manage warranty claims;
  • to respond to any inquiries, feedback or complaints made by you; and
  • direct marketing of products and services which we believe may interest you, including product updates and developments, special events or promotions;
  • assisting us to improve our products and services and making them more relevant to you;
  • assisting us to improve our website(s) or Facebook page;
  • processing and assessing employment applications for current and future positions; and
  • otherwise managing our internal business operations and processes.

Direct marketing

Nine West will only use your personal information for the purpose of direct marketing activities where we have obtained your consent to do so, or in circumstances where we have collected the information directly from you and you would reasonably expect that your personal information would be used or disclosed for this purpose. We may also share your personal information with our related entities, so that they can provide you directly with marketing material about their products and services.

Nine West will provide you with the opportunity to “opt out” of receiving marketing materials at the time of collection and/or at any time afterwards by either unsubscribing from the email service or contacting our Privacy Officer via the contact details provided below.

Use of anonymous information

Nine West gathers anonymous information to:

• monitor the use of our website(s);
• help us make improvements to the website(s); and
• offer relevant information and services to as many users as possible

Disclosure

There will be occasions when it will be necessary for Nine West to disclose your personal information to third parties.

Nine West may disclose your personal information to:

• Contractors and third party service providers on a confidential basis that we use in the ordinary course of our business to assist with the delivery of the product or service. This includes organisations such as marketing agencies, data processing companies, printing and mailing Nine West, delivery companies, data storage companies (which may use cloud computing storage systems which have the potential to make your personal information accessible by overseas entities) or finance agencies or debt collection agencies;
• Other members of Nine West’s corporate group for marketing purposes (subject to obtaining your prior consent if those entities are not related bodies corporate of Nine West);
• Government authorities or other third parties as required by law;
• or any other purpose that you have consented to.

Transfer of information outside Australia

If you place an online order with Nine West such personal information as is necessary to process your order will be transferred to our third party service providers who will use that personal information for the purpose of fulfilling and tracking your order. Some of those service providers use servers based overseas including in the USA and Hong Kong and it is likely that your personal information will be stored on those servers in order to ensure it is not lost before your order is completed. We may also transfer your personal information to service providers who will hold your information on a cloud computing system which may hold your data on servers located outside of Australia. However, where your personal information is disclosed to an overseas recipient or a cloud computing system, we will take adequate measures to ensure that your personal information is handled in accordance with the APPs, the Privacy Act and our instructions in accordance with this Privacy Policy. By providing Nine West with your personal information, you consent to your personal information being stored or sent overseas for the purposes set out in this Policy.

Otherwise than stated above, we do not disclose personal information that you may give us to any organisation or person outside of Nine West unless you have authorised us to do so.

No sale of personal information

Under no circumstances will Nine West sell or receive payment for licensing or disclosing your personal information.

Security

The security of your information is important to us. Nine West operates secure data networks that are designed to protect your privacy and security. When we have collected information about you it cannot be seen or modified by anyone else. Nine West has implemented generally acceptable standards of technology and operational security to ensure personal information (in both physical and electronic form) is protected against loss, misuse, interference and unauthorised access.

Only authorised Nine West personnel and contractors are provided access to personal information and have agreed to ensure the confidentiality of this information. Reasonable steps are taken to destroy or permanently de-identify any personal information that is no longer required.

We review and update our security measures in light of current technologies. You should however be aware that the internet is not a secure environment and information sent via the internet (including email) cannot be guaranteed to be totally secure.

Data quality, access & correction access

If you are a subscriber to one of our online services or products or loyalty programs, you may access your personal information by accessing your subscriber/account details via the relevant facility on our websites.

Otherwise, you may at any time, request access to personal information that Nine West holds about you by making a request to our Privacy Officer at the address or email address below.

We will endeavour to process any requests for access to personal information within a reasonable period of time. Where possible, we will provide you with access to that information either by providing you with copies of the information requested, allowing you to inspect the information requested, or providing you with a summary of the information held. If we need to deny your request for access we will let you know why and inform you how you may lodge a complaint regarding this decision. Generally this will only be in cases where providing access would be unlawful or is subject to a potential legal claim or proceeding.

Nine West may charge a nominal fee for supplying personal information.

Collection

We will try to ensure that all information we collect, use or disclose about you is accurate, complete, up-to-date and relevant to the service being provided.

If you are a subscriber to one of our online services or products, you may change your personal information by accessing your subscriber/account details via the relevant facility on our website(s).

Otherwise, if you discover or suspect that there is an error or information is missing, please forward your request for correction to our Privacy Officer in writing at the address or email address below. Our Privacy Officer will consider your request and as soon as practicable manage the correction of your personal information and will update you in writing. If your correction request is refused, our Privacy Officer will provide you within a reasonable period of time the reasons for such refusal and inform you of the complaint process (see below).

Complaints about privacy and our data handling procedure

If you have any complaints relating to the management of your personal information or if you believe there has been a breach of the APPs by Nine West, please forward your complaint in writing to our Privacy Officer at the address or email address below.

Our Privacy Officer will consider the complaint and advise you of his/her decision in writing within a reasonable time from receipt of the complaint.

If our Privacy Officer decides that there has been a breach of the APPs, he or she will endeavour to ensure that the breach is rectified within 30 days from the date of the decision and will update you in writing. If the breach has not been rectified within 30 days, then our Privacy Officer will inform Nine West’s Managing Director in order to resolve the matter.

If you are still not satisfied after lodging a complaint with us and giving us a reasonable time to respond, then we suggest that you contact the Office of the Australian Information Commissioner by:

Phone: 1300 363 992 (local call cost, but calls from mobile and pay phones may incur higher charges). If calling from overseas (including Norfolk Island): +61 2 9284 9749 TTY: 1800 620 241 (this number is dedicated to the hearing impaired only, no voice calls.) TIS: Translating and Interpreting Service: 131 450 (If you don’t speak English or English is your second language and you need assistance and ask for the Office of the Australian Information Commissioner)

Post: GPO Box 2999 Canberra ACT 2601 Fax: +61 2 9284 9666 Email: enquiries@oaic.gov.au

Contact privacy officer

Please contact our Privacy Officer on the contact details below if you would like to:

• inquire about or request access and/or update your personal information; or
• report an alleged breach of your privacy rights or make a complaint: talk to our Privacy Officer about our Privacy Policy

Please contact:

Post: Privacy Officer, Nine West, 312 Toorak Road, Street South Yarra VIC 3141 Telephone: (03) 9832 6400 E-mail: privacyofficer@ninewest.com.au

Miscellaneous

"Personal information" has the same meaning as in the Privacy Act.

"Website(s)" refers to all websites and web pages which are owned, operated or under the control of Nine West including but not limited to www.ninewest.com.au and www.facebook.com/ninewestaustralia/.

Nine West reserves the right to amend this Privacy Policy at any time. The effective date will be displayed at the beginning of the Policy to alert you to any changes.

Further information on privacy

For more information about your privacy rights in Australia, visit the Office of the Australian Commissioner’s website, www.oaic.gov.au