[COMPANY NAME] ("We" or "us") are committed to protecting and respecting your privacy.

This Privacy Policy, together with our Website Terms of Use and our Rules and any other documents referred to in it, sets out the basis on which any personal data we collect from you or about you will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat them. By providing your data in the Registration Form ("CAF") either electronically on [URL OF RELEVANT MARKET WEBSITE] or in paper form, you are accepting the practices described in this Privacy Policy.

The data controller is [COMPANY NAME] of [ADDRESS].

We process your personal data pursuant to the information provided below.

1   Information we may collect from you

We may collect and process the following data about you:

1. Information you give us. You may give us information about you on our site or by filling in a written registration form or by corresponding with us by phone, e-mail, fax or otherwise. This includes information you provide when you register to use our site, subscribe to be our consultant, search for a product, place an order on our site, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, when you correspond with our customer service and when you report a problem with our site. The information you give us may include your:
2. name;
3. date of birth;
4. address;
5. e-mail address;
6. phone number and mobile phone number;
7. unique consultant ID;
8. personal identification number;
9. ·national tax code or number;
10. social insurance/security number;
11. bank account details;
12. information about adverse reactions to our products;
13. ·name and surname of your legal guardian if you are below 16 years of age; and
    • and passport number (for the consultants taking part in international conferences).

       

      Please be aware that if you do not provide such information in some cases, we will not be able to provide you with the service you have requested.

14. Information we collect about you. We store the history of your purchases, your level in our consultants’ network structure, your performance, the recruits sponsored by you etc.

    With regard to each of your visits to our site, we may automatically collect the following information:

15. 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;
16. information about your visit to our site, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (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.

    Our site also places cookies on your terminal equipment (please see section 9 for more information about this).

17. Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. We also work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them. We may also receive information about you from other members of the consultants' network (for example, your sponsor).

    Click here to learn more about the information we collect.

    2   Uses made of the information

     

    We use information held about you in the following ways:

18. To carry out our obligations arising from any contracts entered into between you and us, and to provide you with the information, products and services that you request from us including resolving any disputes, collect fees, and troubleshoot problems;
19. To provide you with the rights, benefits, and entitlements, and other conditions as applicable under the contractual relationship between you and us;
20. To comply with other regulations applicable to our cooperation with you, such as, tax laws, social security laws, statistical obligations etc.;
21. To monitor and ensure compliance by you with our policies and rules;
22. To provide you with information about goods or services we feel may interest you. We will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. Please see section 6 below for more information;
23. To notify you about changes to our service;
24. To ensure that content from our site is presented in the most effective manner for you and for your computer;
25. To ensure effective management of the network of our consultants by ourselves but also by other members of our consultants networks (mainly your sponsor);
26. To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
27. To improve our site to ensure that content is presented in the most effective manner for you and for your computer;
28. To allow you to participate in interactive features of our service, when you choose to do so;
29. To keep our site safe and secure;
30. To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you, this includes performance of consumer satisfaction and similar studies; and
31. To respond to requests and legal demands from regulators or other authorities.

    Click here to learn more about how we use the information we collect.

    3   Disclosure of your information

     

32. We do not sell, rent or trade your personal data.
33. We may give access to your personal data, and allow its processing, by companies that are members of our group (ultimate holding company and its subsidiaries) in order to support us in the performance of the activities listed above in point 2 (Uses made of the information).
34. We may give access to your information, and allow its processing, within a strictly defined scope and purposes to selected third parties such as:
35. Our business partners: suppliers and sub-contractors for the performance of any contract we enter into with them. This includes among others: carriers, credit collection agencies, banks, factoring services providers, logistics services (such as picking and packing) providers, customer support services providers etc. 
36. Other members of our consultants network (primarily to your sponsor in our network and your down-line consultants) for the purpose of effective management of our consultants' network. If you do not want us to pass your personal data to the other consultants in the network for the mentioned purpose, please change the settings at your profile after logging to “my pages” or contact customer service by sending an email to [     ] or by calling to our helpdesk line at [       ].
37. VIP Customers who were not referred by you but who Oriflame 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.
38. Advertisers and advertising networks that need the data to select and serve relevant adverts to you and others.  We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, new joint consultants from certain area).
39. Analytics and search engine providers that assist us in the improvement and optimisation of our site.
40. Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
41. Providers of technical solutions allowing us to send to you our messages (including marketing messages or customer satisfaction surveys when you have consented to receive such information) e.g. mass mailing solutions providers, mass texting solutions providers.

    We may also disclose your personal data to third parties:

42. In the event that we sell, buy or in other way transfer any business or assets, in which case we may disclose your personal data to the prospective seller, buyer or acquirer of such business or assets.
43. If our company or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
44. If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our policies and/or terms of use and/or other applicable agreements; or to protect our rights, property, or safety of our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

    Click here to learn more about how we share the information which we collect.

    4   How and where we store your personal data

     

    The data that we collect about you may be transferred to, and stored in, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details, processing of your Success Plan entitlements and the provision of support services.

    We will take all steps necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and applicable laws.

    Click here to learn more about the transfer of your information by us outside the EEA.

    5   Duty of care

     

    Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site (your “Account”), you are responsible for keeping this password confidential. We ask you not to share this password with anyone. If you do share your password with others, you will be responsible for all actions taken in the name of your Account. If you lose control of your password, you may lose substantial control over your personal data and may be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason, you should immediately notify us using the details provided in section 11, and change your password. We will not ask you to provide us with your password except during the login process. Our employees are subject to additional requirements in the area of data protection.

    Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

    6   Marketing communications

     

    From time to time, we would like to send you information, by e-mail and/ or SMS, about our products and services which may be of interest to you (including, for example, newsletters and promotional communications).

    We will do this only if you have consented [insert relevant time e.g. at the point of registration or at any later time by ticking relevant tick box on your Account]. If you change your mind and do not want us to use your data in this way please: select relevant tick box on your Account or contact customer service by sending an email to [     ] or by calling to our helpdesk line at [       ];

    7   Your rights

     

45. Marketing Communications. Further to section 6, you have the right to ask us not to process your personal data for marketing purposes.
46. Access to information, rectification and deletion. You have the right to access information held about you (including your personal data), and to request its rectification or deletion, or to receive a copy of your personal data in a portable format. You can see, review and change most of your personal data by signing on to your Account. Alternatively, upon your request to [Oriflame Customer Service contact detail –e-mail address, website or other appropriate], we will amend your personal data on your behalf. Further, upon your request to [Oriflame Customer Service contact detail –e-mail address, website or other appropriate], we will close your Account as soon as reasonably possible, in accordance with applicable law. We may request additional information from you to verify that you are in fact the holder of the account.

    Click here to learn more about the additional rights you may have in relation to your personal data.

47. Retention. We retain your personal data for as long as necessary to administer the relationship with you. If you terminate your relationship with Oriflame, we will retain personal data to comply with legal obligations, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations, and generate business reports for a reasonable period of time, after which we will take steps to delete, anonymise or securely archive your personal data.

    Click here to learn more about how long we retain your personal data for.

    8   Cookies

     

    Our site uses cookies (small files placed on website users’ hard drive) to distinguish you from other users of our site. This helps us to provide you with a high quality experience when you browse our site and also allows us to improve our site. 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:

48. Strictly Necessary Cookies

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

49. 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. These cookies may also be used to highlight products or site services that will be of interest to the users based on their usage of the site.

50. Functionality Cookies

    Functionality cookies are used to allow us to remember users’ preferences.

51. Targeting Cookies or Advertising Cookies

We may use cookies to serve users with adverts that are relevant to them and their interests. We may also use third party cookies with regards to market research, revenue tracking, improving site functionality and monitoring compliance with these terms and conditions and copyright policy.

Users are always free to decline cookies if their browser permits, although doing so may interfere with their use of the site. 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/).

Any changes we may make to our Privacy Policy in the future will be posted on our site and, where appropriate, notified to you by e-mail or otherwise. The amendments will be also available at our premises. They will be effective as of the publication date.

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to our customer service or to the specially designed e-mail address: privacy@oriflame.com.

If you believe that we have not complied with this Privacy Policy, you may write to the address above or call our customer service at [      ]. Please describe in as much detail as possible the ways in which you believe that this Privacy Policy has not been complied with. We will investigate your complaint promptly.

Publication date: [      ]

In order to meet privacy regulations in the EEA, ORIFLAME provides additional information to its EEA-based CONSULTANTS

1. Who is responsible for your PERSONAL DATA?

[COMPANY] is the data controller in respect of your personal data. We can be contacted using the following details: [insert contact information].

[In addition, you can contact Oriflame's Data Protection Officer at [insert generic email address].]

1. More about THE PERSONAL DATA ORIFLAME Collects, AND WHY

1. To carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us including resolving any disputes, collect fees, and troubleshoot problems;
   1. What information do we collect? [insert]
   2. What is the legal basis for collecting this information?
      • [Oriflame processes your information with your consent;
      • Oriflame processes your information when we need to do this to fulfil a contract with you (for example, the service contract);
      • Oriflame processes your information where we are required to do this by law (for example, where it is necessary to retain it in connection with potential litigation); or
      • Oriflame processes your information when it is in our legitimate interests to do this and when these interests are not overridden by your data protection rights. For example, Oriflame has a legitimate interest in delivering the requested products or services.]
   3. What is the source of this information?
      • [You provide this information to us when you [insert when the consultant will provide this information e.g. when it completes a certain form on the site.]]
   4. What is the source of this information?
      • [You provide this information to us when you [insert when the consultant will provide this information e.g. when it completes a certain form on the site.]]
   5. What is the source of this information?
      • [You provide this information to us when you [insert when the consultant will provide this information e.g. when it completes a certain form on the site.]]
   6. What is the source of this information?
      • [You provide this information to us when you [insert when the consultant will provide this information e.g. when it completes a certain form on the site.]]
   7. What is the source of this information?
      • [You provide this information to us when you [insert when the consultant will provide this information e.g. when it completes a certain form on the site.]]
   8. What is the source of this information?
      • [You provide this information to us when you [insert when the consultant will provide this information e.g. when it browses Oriflame websites.]]
   9. What is the source of this information?
      • [You provide this information to us when you [insert when the consultant will provide this information e.g. when it completes a certain form on the site.]]
   10. What is the source of this information?
       • [You provide this information to us when you [insert when the consultant will provide this information e.g. when it completes a certain form on the site.]]
   11. What is the source of this information?
       • [You provide this information to us when you [insert when the consultant will provide this information e.g. when it completes a certain form on the site.]]
   12. What is the source of this information?
       • [You provide this information to us when you [insert when the consultant will provide this information e.g. when it completes a certain form on the site.]]
   13. What is the source of this information?
       • [You provide this information to us when you [insert when the consultant will provide this information e.g. when it browses Oriflame websites.]]
   14. What is the source of this information?
2. To provide you with the rights, benefits, and entitlements, and other conditions as applicable under the contractual relationship between you and us;
   1. What information do we collect? [insert]
   2. What is the legal basis for collecting this information?
      • Oriflame processes your information when we need to do this to fulfil a contract with you (for example, the service contract).
3. To comply with other regulations applicable to our cooperation with you such as e.g. tax laws, social security laws, statistical obligations etc.
   1. What information do we collect? [insert]
   2. What is the legal basis for collecting this information?
      • Oriflame processes your information where we are required to do this by law (for example, where it is necessary to retain it in connection with potential litigation).
4. To monitor and assure compliance by you with our policies and rules;
   1. What information do we collect? [insert]
   2. What is the legal basis for collecting this information?
      • Oriflame processes your information when it is in our legitimate interests to do this and when these interests are not overridden by your data protection rights. For example, Oriflame has a legitimate interest in ensuring compliance with specified policies and rules.]
5. To provide you with information about goods or services we feel may interest you. We will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you;
   1. What information do we collect? [insert]
   2. What is the legal basis for collecting this information?
      • Oriflame processes your information when it is in our legitimate interests to do this and when these interests are not overridden by your data protection rights. For example, Oriflame has a legitimate interest in sending electronic direct marketing to consultants.]
6. To notify you about changes to our service;
   1. What information do we collect? [insert]
   2. What is the legal basis for collecting this information?
      • Oriflame processes your information when it is in our legitimate interests to do this and when these interests are not overridden by your data protection rights. For example, Oriflame has a legitimate interest in informing consultants about changes to its services.]
7. To ensure that content from our site is presented in the most effective manner for you and for your computer;
   1. What information do we collect? [insert e.g. cookies]
   2. What is the legal basis for collecting this information?
      • Oriflame processes your information when it is in our legitimate interests to do this and when these interests are not overridden by your data protection rights. For example, Oriflame has a legitimate interest in delivering relevant content to consultants on its websites.]
8. To ensure effective management of the network of our consultants by ourselves but also by other members of our consultants networks (mainly your sponsor);
   1. What information do we collect? [insert]
   2. What is the legal basis for collecting this information?
      • Oriflame processes your information when it is in our legitimate interests to do this and when these interests are not overridden by your data protection rights. For example, Oriflame has a legitimate interest in effectively managing its network of consultants.]
9. To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
   1. What information do we collect? [insert]
   2. What is the legal basis for collecting this information?
      • Oriflame processes your information when it is in our legitimate interests to do this and when these interests are not overridden by your data protection rights. For example, Oriflame has a legitimate interest in administering its websites.]
10. To allow you to participate in interactive features of our service, when you choose to do so;
    1. What information do we collect? [insert]
    2. What is the legal basis for collecting this information?
       • Oriflame processes your information when it is in our legitimate interests to do this and when these interests are not overridden by your data protection rights. For example, Oriflame has a legitimate interest in delivering interactive service features to consultants.]
11. To keep our site safe and secure;
    1. What information do we collect? [insert]
    2. What is the legal basis for collecting this information?
       • Oriflame processes your information when it is in our legitimate interests to do this and when these interests are not overridden by your data protection rights. For example, Oriflame has a legitimate interest in ensuring that its websites, and all personal data collected or otherwise processed on such websites, are safe and secure.]
12. To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you, this includes performance of the consumer satisfaction and similar studies;
    1. What information do we collect? [insert e.g. cookies]
    2. What is the legal basis for collecting this information?
       • Oriflame processes your information when it is in our legitimate interests to do this and when these interests are not overridden by your data protection rights. For example, Oriflame has a legitimate interest in measuring and understanding the effectiveness of the advertising it serves to consultants.]
13. To respond to requests and legal demands from regulators or other authorities;
    1. What information do we collect? [insert]
    2. What is the legal basis for collecting this information?
       • Oriflame processes your information where we are required to do this by law (for example, where it is necessary to retain it in connection with potential litigation).

1. What is the source of this information?
   • [You provide this information to us when you [insert when the consultant will provide this information e.g. when it completes a certain form on the site.]]

• [You provide this information to us when you [insert when the consultant will provide this information e.g. when it completes a certain form on the site.]]

1. MORE INFORMATION ABOUT YOUR CHOICES IN RESPECT OF ORIFLAME'S USE OF YOUR PERSONAL DATA

• You have the right to access, rectify, block, complete and delete your personal data, and to restrict its use. You also have the right to request further information about the processing of your personal data; and
• In certain circumstances, you also have the right to object to the processing of your personal data by us.

You can exercise the above rights by contacting us using the details provided above at any time. All requests will be dealt with at the earliest opportunity and any delay will be kept to a minimum.

There are exceptions to these rights; for example, access may be refused if it would reveal personal data about another person or if we are prevented from disclosing such information by law.

You also have the right to make a complaint to the data protection supervisory authority or to seek a remedy through the courts if you believe that your rights have been breached.

When we ask you to supply us with information we will make it clear whether the information we are asking for must be supplied so that we can provide the products and services to you, or whether the supply of any information we ask for is optional.

1. MORE INFORMATION ABOUT ORIFLAME'S TRANSFER OF YOUR PERSONAL DATA OUTSIDE THE eea

The personal data we collect about you which relates to [insert] may be stored on servers located in countries outside the EEA, including countries which have different data protection standards to those which apply in the EEA, for example, the United States.

[We put in place European Commission approved standard contractual clauses to protect this data. A copy of these clauses is available for your review upon request to us using the detail provided above.]

1. MORE INFORMATION ABOUT ORIFLAME'S RETENTION OF YOUR PERSONAL DATA

• [insert applicable retention periods].