ORIFLAME PRIVACY NOTICE – BRAND PARTNERS

Publication Date: 17^th May 2018

What does this policy cover?

This policy describes the Company's, and your Sponsors', processing of your personal data.

References in this policy to the Company, we or us shall mean Oriflame Holdings BV(registered in Bolduc Building A,Utopialaan 52, 5232 CE 's-Hertogenbosch, The Netherlands)

References in this policy to your Sponsor shall mean the Sponsor identified in the confirmation email we send you during the Brand Partner sign-up process (i.e. the Sponsor who sponsored you to become a Brand Partner), and your Sponsors shall mean your Sponsor along with your Sponsor's up-line Sponsors within the Brand Partner Network who will have access to your personal data in accordance with this policy. The details of your Sponsors can be found here: https://uk.oriflame.com/mypages/profile

For the purposes of applicable data protection law (including, the General Data Protection Regulation 2016/ 679 (the "GDPR"), each of the Company and your Sponsors are independent data controllers of your personal data.

What personal data is collected?

The following categories of personal data will be collected about you in connection with this policy:

1. Personal data collected from you: Depending on how you interact with Oriflame, the Company and/ or your Sponsor collect the following data from you when you complete a form on the website, complete the Brand Partner sign-up process, purchase Oriflame products, apply for deferred payment for your purchases, participate in discussion boards or other social media functions on the website, enter a competition, promotion or survey on the website, or otherwise communicate with the Company (for example, when you contact Customer Services):

    

   PERSONAL DATA

   IS THE PROVISION OF PERSONAL DATA A STATUTORY OR CONTRACTUAL REQUIREMENT, OR A REQUIREMENT NECESSARY TO ENTER INTO A CONTRACT?

   POSSIBLE CONSEQUENCES OF FAILURE TO PROVIDE SUCH DATA

   Name*;

   Contractual requirement

   If you don’t provide this data, you won’t be able to register as a Brand Partner

   Date of birth;

   Over 18 statutory requirement

   Registration only accepted for over 18s

   Postal address*;

   Statutory requirement

   We cannot offer credit /bonus without your current address

   Product delivery address*;

   Contractual requirement

   If you do not provide it we will not be able to deliver your order

   Email address*;

   Required for confirmations

   Without email you will not receive confirmations.  You can access online information for this purpose

   Mobile phone number;

   Delivery Requirement (Mobile)

   Without this the Delivery Company cannot contact you for delivery options

   Your password*;

   Contractual requirement

   Without the password you cannot create your account in our online system as the data must be secured

    The fields above which are marked with a (*) are mandatory fields – if you do not provide such personal data, the Company and / or your Sponsors will not be able to fulfil the applicable purposes which are described below in this policy.

1. Personal data collected about you:

• The Company processes personal data related to your history of purchases, level in the Success Plan, performance and recruitment and it shares some/ all of this data with your Sponsors for the management of their downline networks.
• The Company processes the following personal data about you relating to your completion of the Brand Partner sign-up process:
  • Unique Brand Partner ID;
  • Membership start date; and
  • Membership anniversary date.
  • Information obtained via the cookies that the Company places on the website – see below for more information.

    How is your personal data used, and what is the legal basis for this use?

    The Company and your Sponsors each process the above personal data as independent data controllers. Each independently processes your personal data for the following purposes:

• Further, with regard to each of your visits to the website and any Oriflame app, the Company will automatically collect the following personal data:
  • Technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time-zone setting, browser plug-in types and versions, operating system and platform;
  • Information about your visit to the website, including the full Uniform Resource Locators (URL) clickstream to, through and from the website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number; and
• Legal Compliance: To ensure compliance with applicable laws and the protection of the Company's legitimate business interests and legal rights, including, but not limited to, use in connection with legal claims, compliance, regulatory, tax, investigative purposes (including disclosure of such information in connection with legal process or litigation).
• Consent: Subject to the following, the Company will send you direct marketing in relation to the Company's products and services similar to those which you have already purchased, or other products and services provided by the Company, its affiliates and carefully selected partners. This will only be sent where you have given your consent to the Company during the Brand Partner sign-up process or via your online account on the website ('Mobile Office'), or (where permissible) you have been given an opportunity to opt out. You will be able to opt-out of direct marketing by: (i) following the instructions in the communication itself; (ii) changing your marketing preferences via your online account on the website ('Mobile Office'); or (iii) contacting [the Company Customer Service Desk at info@oriflame.co.uk .
• Consent: Subject to the following, your Sponsors may send you direct marketing in relation to the Company's products and services similar to those which you have already purchased, or other products and services provided by the Company, its affiliates and carefully selected partners. This will only be sent where you have given your consent to your Sponsors during the Brand Partner sign-up process or via your online account on the Website ('Mobile Office), or (where permissible) you have been given an opportunity to opt out. You will be able to opt-out of direct marketing by: (i) following the instructions in the communication itself; (ii) changing your marketing preferences via your online account on the Website ('Mobile Office'); (iii) contacting [the Company Customer Service Desk at info@oriflame.co.uk ; or (iv) directly contacting your Sponsor.

  Who will your personal data be shared with, and where?

  1. The Company will share your personal data with Oriflame Kosmetik Vertriebs GmbH, Konigstrasse 10c, 70173 Stuttgart, Germany for group level analytics.
  2. The Company and your Sponsors may each share your personal data with:
     • government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of its own legitimate interests in compliance with applicable laws;

       “Third party service providers and group companies, who will process it on behalf of the Company or your Sponsors for the purposes above.  Such third parties include, but are not limited to, couriers for delivery of your orders (which are located in EEA), customer service operations (which are located in EEA), and marketing providers (which are located in EEA) etc.;

       More information about the Company and your Sponsors retention process is available here https://uk.oriflame.com/customer-service/terms-conditions-uk/retention-uk-18

     • amongst the Sponsors themselves (remember that this means only your Sponsor along with your Sponsor's up-line Sponsors within the Brand Partner Network); and
     • VIP Customers who were not referred by you but who the Company has allocated to you upon their registration as a VIP Customer in order that the VIP Customer can contact you to hear more about Oriflame products and services.

1. Company Processing
   • Contractual Necessity: As required to establish and fulfil a contract with you, for example, if you make a purchase from it. This will include verifying your identity, taking payments, communicating with you, providing customer services and arranging the delivery or other provision of products, awards or services.
   • Legitimate Interests: As required by it to pursue its own legitimate interests, in particular:
     • to ensure the effective management of the Brand Partner Network (including, enabling you to connect with other Brand Partners within the Network);
     • to communicate with you (including providing you with information to help you improve your business (such as providing you with training materials and sessions);
     • to analyse your Brand Partner recruitment and sales performance (including the compiling of internal reports);
     • to invite you to take part in market research or studies, and attend (business update) conferences;
     • to help it monitor, improve, administer and protect its products, content, services and website, both online and offline;
     • to personalise its website, or its products and services for you, and to enable you to participate in interactive features of its website;
     • to monitor and ensure compliance by you with its policies and rules;
     • to investigate and handle any complaints received from you about its products and services or its website;
     • to monitor any Brand Partner account to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law; and
     • to measure or understand the effectiveness of advertising it serves to you and others, and to deliver relevant advertising to you (including, performance of consumer satisfaction and similar studies).
2. Your Sponsors' Processing
   • Legitimate Interests: As required by them to each pursue their legitimate interests, in particular:
     • to ensure the effective management of the Brand Partner Network (including, enabling you to connect with other Brand Partners within the Network);
     • to respond to any comments or complaints you may send them;
     • to communicate with you (including providing you with information to help you improve your business, and inviting you to Brand Partner meetings);
     • to analyse your Brand Partner recruitment and sales performance (including the compiling of internal reports); and
     • to invite you attend training sessions and Brand Partner Network meetings.

• Legal Compliance: To ensure compliance with applicable laws and the protection of your Sponsors' own legitimate business interests and legal rights, including, but not limited to, use in connection with legal claims, compliance, regulatory, tax, investigative purposes (including disclosure of such information in connection with legal process or litigation).
  

What cookies will be used on the website?

The website uses cookies (small files placed on website users’ hard drive) to distinguish you from other users of the website. This helps us to provide you with a high quality experience when you browse the website and also allows us to improve the website. We use cookies to analyze the flow of information; customize the services, content and advertising; measure promotional effectiveness; and promote trust and safety.

We offer certain services that are available only through the use of cookies. Generally, there are the following categories of cookies:

 

We use Google Analytics to understand how visitors engage with our sites and apps. This means that when you visit our website or use one of our mobile applications your browser automatically sends certain information to Google. This includes, for example, the web address of the page that you're visiting and your IP address. You will find the details of how the Google technology collects and processes data following this link https://www.google.com/policies/privacy/partners/.

If you don’t want the Google Analytics to be used in your browser, you can install the Google Analytics browser add-on. You can find more about the Google Analytics and Google privacy policy https://policies.google.com/privacy

Users are always free to decline cookies if their browser permits, although doing so may interfere with their use of the website. Please find detailed information on how to disable cookies here (http://www.allaboutcookies.org/manage-cookies/).

More detail on how businesses use cookies is available here (http://www.allaboutcookies.org/).

Changes to this policy

Any changes we may make to the policy in the future will be posted on the website and, where appropriate, notified to you by e-mail or otherwise. The amendments will be also available at our premises.

Where can I find more information about the handling of my personal data?

See our fuller Privacy FAQs for further details on retention periods, international transfers, contact details and your rights.

 

 

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ANNEX - FAQs

1. What rights do I have in relation to my personal data?

    

   You are entitled to ask the Company and your Sponsors:

1. for a copy of your personal data (in a commonly used electronic form, if you make such a request electronically);
2. to correct your personal data (if it is inaccurate, incomplete or not up-to-date);
3. to 'port' your personal data (i.e. to transfer in a structured, commonly used and machine-readable format, to you or another data controller);
4. to erase your personal data; or
5. to restrict its processing (i.e. processing will temporarily stop (save to the extent that personal data will continue to be stored)).

   You also have rights to object to some processing that is based on our legitimate interests, and to processing for direct marketing purposes. Further, where the Company and/ or your Sponsors has asked for your consent to process your data, you are entitled to withdraw this consent as more fully described above.

   These rights are limited in some situations – for example, where the Company and/ or your Sponsors can demonstrate that it has a legal requirement to process your personal data. In some instances, this may mean that they are able to retain data even if you withdraw your consent.

   Where the Company and/ or your Sponsors requires your personal data to comply with legal or contractual obligations, then provision of such data is mandatory: if such data is not provided, then the Company and/ or your Sponsors will not be able to manage its contractual relationship with you, or to meet obligations placed on them. Above, we have described which data fields you are obliged to provide, and the consequences of not providing them.

   The Company and your Sponsors hope that they can satisfy any queries you may have about the way they process your personal data. If you have any concerns about how they process your personal data, you can get in touch at:

1. The Company: Company's data protection officer can be contacted at privacy@oriflame.com. You may also contact us at the following address:  Oriflame Holdings BV (registered in Bolduc Building A, Utopialaan 52, 5232 CE 's-Hertogenbosch, The Netherlands); and/ or Oriflame Cosmetics UK Ltd, Kiln Farm MK11 3EW
2. Your Sponsor: Using the contact details provided in the confirmation email we sent you during the Brand Partner sign-up process, or those provided in each communication you receive from your Sponsor.

3. If you have unresolved concerns you also have the right to complain to data protection authorities. The relevant data protection authority will be the supervisory authority in the country of your habitual residence, place of work or of an alleged infringement of the GDPR.

1. How long will you hold my data?

The Company and your Sponsors will each keep your personal data for the length of the contractual relationship you have with the Company and, to the extent permitted, after the end of that relationship for as long as necessary to perform the purposes set out in this policy.

Laws may require the Company and your Sponsors to each hold certain personal data for specific periods. In other cases, the Company and your Sponsors will each retain data for an appropriate period after any relationship with you ends to protect itself from legal claims, or to administer its business. 

More information about the Company and your Sponsors' retention practice is available here uk.oriflame.com/customer-service/consultant-retention-uk/

Where will you send my data?

The Company and your Sponsors intend to transfer (including store) your personal data to countries outside of the European Economic Area (the "EEA") (i.e. all 27 EU Member States plus Iceland, Liechtenstein and Norway) which may not provide the same level of protection as those countries within the EEA. In particular, to India, the United States of America and Switzerland.

Where this is the case, and where the transfer is to a Company affiliate or vendor in a country that is not subject to an adequacy decision by the EU Commission, personal data is adequately protected by EU Commission-approved standard contractual clauses (which have been implemented pursuant to Article 46 (2) of the GDPR). If you have any questions about the standard contractual clauses and / or would like to obtain a copy of them, please contact the Company’s data protection officer at privacy@oriflame.com.