1. Who is responsible for your personal information

This Privacy Statement applies to the personal information of Avon customers where your personal information is passed to Avon by you or by your Avon Representative. References to “Avon”, “us”, “we” or “our” in this Privacy Statement mean Avon Cosmetics Limited, at Nunn Mills Road, Northampton, NN1 5PA. Where your personal information is passed to Avon, we may be a controller of your personal information. Where you choose to purchase Avon goods via an Avon Representative, your personal information will also be processed by the Representative, as a separate controller of your personal information. Avon Representatives are independent and are not employed by Avon. Avon is not responsible for the use of personal information by Representatives. This means that the Representative will, independently from Avon’s business operations, process your personal information for purposes they decide and in ways that they decide, including for their own marketing purposes. In general, Avon’s independent sales representatives will use your personal information in a way which is compatible with this Privacy Statement. If they use your personal information in a different way, they are required to provide you with further privacy information to comply with their own legal obligations under data protection law.

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 or from Representatives who may provide it to us. We may collect the following personal information about you:

• Your name and contact details (title, surname, first name, any other name(s), postal address, e-mail address, telephone numbers)
• Your date of birth
• Information on your purchases from Avon, and information about your preferences for particular types of products
• Payment card details
• The communications you exchange with us (for example, your emails, letters, calls, or posts and messages on social media)
• Information about how you use our website or our mobile app
• Information on how you use our website using cookies or similar identifiers. Cookies are small pieces of information stored by your browser on your computer’s hard drive. They enable you to navigate on our website and allow us to provide features, such as keeping you logged in to our website. For more information on how we use cookies and how you can remove them, read our Cookie Policy.

3. How and why we use the personal information that we collect

We use your personal information for the following purposes:

• To fulfil your order
When you place your Avon order, we use your personal information to fulfil that order. We may contact you by email and/or SMS to send you confirmation of your order, payment and order status. This is to meet our contractual obligations to you.

• To inform you about our products and offers that you may like
If you have signed up to our Avon Newsletter or purchased from us previously, we may send you email and/or SMS communications about our products and offers. We may also, from time to time, inform you of opportunities to become an Avon Representative. 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. You may also see advertising related to Avon products across the web on the basis of the information we hold about you. This to meet our business interests in marketing our products effectively. If you do not want to receive marketing communications (e.g. emails) from us, please contact us. Where you interact with Avon by posting or messaging on social media, we may use personal information included in social media posts for this purpose.

• 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, 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 records for tax and audit purposes. 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.

• To request your participation in product reviews
We may contact you to ask you to participate in product reviews. This may be for a product you have purchased, a sample provided by Avon or a product we think you may be interested in. We do this to meet our business interests in ensuring we have desirable products and to market our products effectively.

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 may not be able to post products to you without knowing your postal address.

4. How we may share or transfer the data we collect

We may share your personal information with:
• Avon Representatives, Avon Sales Leaders and Avon Zone Managers;
• other Avon group companies (for a list of the these companies see http://www.avoncompany.com/world/index.html );
• suppliers providing services to us in order to help us run our business and improve our services and your customer experience; 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 and other legally acceptable transfer mechanisms are in place with our email system provider and IT support and IT system maintenance suppliers. Contact us using the details set out below to see a copy of the relevant safeguards.

5. How long we keep your personal information

Order processing information will be kept by Avon for 10 years or until tax audit close, whichever is later. Avon may use your personal information while you are active with Avon. In deciding how long to keep personal information after you cease to be active with Avon, we 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 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.

7. How to contact us

If you have any questions, comments or requests regarding this Privacy Statement please email PrivacyUK@avon.com or write to Global Privacy, Avon Cosmetics Limited, Nunn Mills Road, Northampton, NN1 5PA

8. 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.

1. Who is responsible for your personal information

This Privacy Statement applies to the personal information of Avon Representatives and Sales Leaders. References to “Avon”, “us”, “we” or “our” in this Privacy Statement mean Avon Cosmetics Limited, Nunn Mills Road, Northampton, NN1 5PA 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.

Depending on your role, your personal information may also be processed by Sales Leaders as independent controllers of your personal information. This means that Sales Leaders may, independently from Avon’s business operations, process your personal information for purposes they decide and in ways that they decide. For example, your personal information may be processed by Sales Leaders to enable them to support your Avon business. Sales Leaders will generally use your personal information in a way which is compatible with this Privacy Statement. If they use your personal information in a different way, they are required to provide you with further privacy information to comply with their own legal obligations under data protection laws.

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 or from Representatives or Sales Leaders who may provide it to us. 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
• Your banking details
• 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 Sales Leaders which are shared with us)
• Information about how you use our website or our mobile app. We use cookies and other similar technologies (such as Flash LSOs and pixel tags) in our website and mobile app. Cookies are small pieces of information stored by your browser on your computer’s hard drive. They enable you to navigate on our website or app and allow us to provide features, such as keeping you logged in to our website. For more information on how we use cookies and how you can remove them, read our Cookie Policy.
• Identity verification and credit checks (via use of a Credit Reference Agency)

3. How and why we use the personal information that we collect

For Representatives and Sales Leaders, we use your personal information for the following purposes:

• To fulfil your orders, provide appropriate commissions, 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. We may also use your information to carry out an identity check before we provide you with credit for our products and a credit check to pursue or defend any legal claim, including to pursue any debt owed by you, in order to meet our business interests in ensuring we can exercise our legal rights appropriately. We use third parties to carry out these checks (CallCredit and Experian). You can find more information about how the companies that carry out these credit checks for us use your personal information here:http://images.go.experian.com/Web/ExperianInformationSolutionsInc/%7B20f8d2ce-87f3-43b7-8766-7401b6ca1a00%7D_CRAIN_-_Information_Notice_(GDPR).pdf?SP_MID=15266-g&SP_RID=6650171-g.

• 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.

• 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 are a Sales Leader, in addition to the purposes set out above, your personal information may be used by Avon to support the businesses of other Representatives and Sales Leaders, and in particular the reporting of sales performance data.

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 share your personal information with:
• Avon customers
• Avon Sales Leaders;
• other Avon group companies (for a list of the these companies see http://www.avoncompany.com/world/index.html );
• suppliers providing services to us in order to help us run our business and improve our services and your independent sales representative experience (such as credit reference agencies that perform credit and identity checks for us); 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 and other legally acceptable transfer mechanisms are in place with our email system provider and IT support and IT system maintenance suppliers. To protect the personal information of Representatives which is passed to our parent company, Avon Products Inc. is certified to the EU-US Privacy Shield Program. For more information please visit www.avonworldwide.com/privacy-shield.html and www.privacyshield.gov,or contact us using the details set out below to see a copy of the relevant safeguards.

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, Representatives, Sales Leaders 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. Additional information for prospective Representatives

Where you provide your Personal Information to Avon or an Avon Representative or Sales Leader for the purposes of enquiring about becoming an Avon Representative, your personal information may be shared with Avon or an Avon Representative or Sales Leader solely for the purpose of contacting you to discuss becoming an Avon Representative. This may be by via electronic means, including email, telephone, SMS, MMS and social media. If you do not become an Avon Representative your Personal Information will be deleted by Avon within 90 days.

9. How to contact us

If you have any questions, comments or requests regarding this Privacy Statement please email PrivacyUK@avon.com or write to Global Privacy, Avon Cosmetics Limited, Nunn Mills Road, Northampton, NN1 5PA.

10. 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.