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ORIFLAME PRIVACY NOTICE – BRAND PARTNERS

Publication Date: 17th 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:
  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.

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:

  1. Strictly Necessary Cookies

     

    Some cookies are essential for the operation of the website. For example, some cookies allow us to identify registered users and ensure they can access the website. If a registered user opts to disable these cookies, the user may not be able to access all of the content of the website.

     

  2. Performance Cookies

     

    Other cookies may be used to analyze how users use the site and to monitor site performance. This allows us to provide a high quality experience by customizing the offering and quickly identifying and fixing any issues that arise. For example, performance cookies may be used to keep track of which pages are most popular and to determine why some pages are receiving error messages.

     

  3. Functionality Cookies

     

    Functionality cookies are used to allow us to remember users’ preferences and tailor the website/app to provide enhanced features.

     

  4. Targeting Cookies

     

    We may use cookies to serve users with adverts which promote Oriflame products that are relevant to them and their interests. Note that we do not allow third parties to advertise their own products and services on our website/ app.

     

  5. Google Analytics

 

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.

 

 

___________________________________

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.