PRIVACY STATEMENT FOR REPRESENTATIVES
1. Who is responsible for your personal information
This Privacy Statement applies to the personal information of Avon Representatives. References to “Avon”, “us”, “we” or “our” in this Privacy Statement mean Women’s Cosmetics Ltd. AVON, Ganu Street, Birkirkara BKR 1102, Malta, who is a controller of your personal information. This means Avon will decide the purposes for which and the ways in which your personal information is processed.
2. Personal information we collect about you
When using the term “personal information” in this Privacy Statement, we mean information that relates to you and allows us to identify you, either directly or in combination with other information that we may hold. We obtain this information either directly from you. We may collect the following personal information about you:
- Your name and contact details (title, surname, first name, any other name(s), postal address, an alternative delivery address, e-mail address, telephone numbers).
- Your date of birth.
- Information on your purchases from Avon, commission and discount records and your reporting line information, as well as information about your preferences for particular types of products.
- The communications you exchange with us (for example, your emails, letters, calls, or posts and messages on social media. This may include communications with other Avon independent sales representatives which are shared with us).
3. How and why we use the personal information that we collect (and on what legal basis)
For Representatives we use your personal information for the following purposes:
- To fulfil your orders, discounts and incentives and manage your Representative account. When you or your customers place an order with us, we use your personal information to fulfil that order and provide appropriate commissions, rebates, discounts and incentives. This is to meet our contractual obligations to you.
- To communicate with you and manage our relationship with you. We may contact you by email, SMS or telephone for administrative or operational reasons, for example in order to send you confirmation of your order and your payments. This is to meet our legitimate business interests in sharing relevant information with you, and ensuring you are up to date with your orders
- To personalise and improve your Representative experience. We may use your personal information in order to tailor our service to your needs and preferences and to provide you with a personalised Representative experience. For example, you may provide us with specific delivery preferences about where your order should be left. We may also collect information on how you use our website. This is to meet our business interests in showing you products that will be most useful to you, and to answer any questions you have most effectively.
- To inform you about our products and offers that you may like. To help you sell Avon products to your customers, we may contact you by email, SMS or telephone about our products and offers. We may use the information we have about you (including your purchasing history) to build a profile about your preferences and to send you products and offers tailored to you to ensure that we run our business most effectively. If you do not want to receive marketing communications from us, please contact us or use the ‘unsubscribe’ links in marketing emails.
- To improve our services, fulfil our administrative purposes and protect our business interests.The business purposes for which we will use your personal information include accounting, billing, audit, ID verification, fraud screening, safety, security and legal purposes, statistical and marketing analysis, systems testing, maintenance and development. This will include the use of your personal information to comply with our legal obligations, for example, our obligation to maintain tax records. Where there is no specific legal obligation we are required to meet, we process this personal information to meet our legitimate interests in managing our business and keeping our records accurate and up to date.
If you object to the use of your personal information to fulfil any of the purposes set out above, please contact us. Whilst your decision to provide your personal information to Avon is generally voluntary, if you do not provide certain information Avon may not be able to accomplish some of the purposes outlined in this Privacy Statement. For example, we need to know your name and postal address before we can post products to you, and we need to know your payment details so that we can take payments from you when you buy products.
4. How we may share or transfer the data we collect
We may disclose your Personal Information:
- Avon customers;
- other Avon group companies (for a list of the these companies click here); and
- government authorities.
This sharing will be for the purposes set out above or to comply with specific legal obligations to which we are subject.
Avon uses appropriate safeguards to protect personal information which is transferred to countries outside of the European Economic Area which are considered to provide a lower level of protection for personal information. European Commission-approved Standard Contractual Clauses are in place with our email system provider and IT support and IT system maintenance suppliers.
If you choose to link to third party websites via our website, third parties may collect information about your use of our website. Similarly, where you choose to interact with Avon content on social media, third parties may collect information. Information collected by third party social media services is governed by the privacy policies of those third parties. Where you are directed to a third party’s website by Avon, Avon is not responsible for the processing of your personal information by any third party.
5. How long we keep your personal information
Your personal information will be used and stored by Avon for the length of your association with Avon and for a length of time needed after to take into account any ongoing obligations we may have (e.g. to store the information for accounting purposes) or the length of time given to commence or defend any legal claims. If you would like more specific timescales please contact us. We will stop processing your data for direct marketing, including profiling activities, if you object to such processing of your data or if you withdraw your consent to processing, where your consent has previously been obtained.
6. Your responsibilities
- To ensure that we can keep your personal information up to date, please inform us promptly of any changes to your personal information.
- As an independent sales representative, you are legally responsible for the personal information that you hold through the course of your business belonging to customers and any other individuals. You agree to comply with all applicable data protection laws in respect of the personal information collected, received, processed and stored by you. You will not use any personal information for any purpose which is incompatible with this Privacy Statement.
7. Your rights
You have a right to request access to the personal information that we hold about you and to have any inaccurate personal information we hold about you rectified. You may also have the right to restrict the processing of your personal information, to port your personal information to another controller or to have your personal information erased.
If you have an issue or complaint about how we handle your personal information, please contact us. In the event we are unable to resolve the issue then contact your local data privacy supervisory authority.
8. How to contact us
If you have any questions, comments or requests regarding this Privacy Statement please email us at email@example.com or in writing to us at AVON, Ganu Street, Birkirkara BKR 1102, Malta.
9. Changes to this Privacy Statement
We may make changes to this Privacy Statement from time to time. We will publish any new version of this Privacy Statement on our website.