1. Who is responsible for your personal information
This Privacy Statement applies to the personal information of Avon Representatives and Sales Leaders as Data Subjects. References to “Avon”, “us”, “we” or “our” in this Privacy Statement mean Avon Cosmetics, Inc. 22F Pacific Star, Makati City, 1200 Philippines, 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 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), as well as any unique identifiers allocated to you by Avon (e.g. Rep ID), and any profile photo you upload to our systems.
- • 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)
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 legitimate business interests in ensuring we can exercise our legal rights appropriately.
- • 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.
This is to meet our legitimate 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. This is to meet our legitimate business interests in marketing our products effectively, helping to promote Avon product awareness and to help you build your business with Avon. 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 and credit checks (via use of a Credit Reference Agency), fraud screening, safety, security and legal purposes, statistical and marketing analysis, systems testing, maintenance, development, and to administer the Avon product guarantee and any other rights, statutory or otherwise, to return products. We may also use website navigation data to monitor our websites and improve them. 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.
- • To run competitions
We run certain competitions, and will need to process your name, contact details and certain other information we hold about you as a Representative if you enter, as well as to let you know if you have won. Specific uses of personal data in this context will be detailed in the competition rules. This processing will be on the basis of your consent, if you choose to enter the competition, which can be withdrawn at any time by contacting us.
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 these companies see https://www.avonworldwide.com/countries.html);
- • suppliers (for a list of these suppliers and the purposes for which your data is shared, please click here) 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);
- • to an acquiring party, service providers or other third parties in connection with the consideration, negotiation, or completion of a transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets; and
- • government authorities.
This sharing will be for the purposes set out above (including the engagement of third party service providers, who may act as controllers of your personal information) or to comply with specific legal obligations to which we are subject.
If you choose to click through to third party websites via our website, third parties may collect information about your use of our website, using certain technologies available to them, for example cookies. Similarly, where you choose to interact with Avon content on social media, third parties may collect information about these interactions. Information collected by these third party 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 only responsible for the processing of your personal information by that third party, where the third party is processing your personal data on instructions from Avon.
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, other Representatives, Sales Leaders and any other individuals. This is a unique component of the direct seller relationship. 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 or object to the processing of your personal information, to port your personal information to another controller or to have your personal information erased. You may also object to the use of your personal information to fulfil any of the purposes set out under Section 3 above.
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 Sales Leader/Business Development Manager for the purposes of enquiring about becoming an Avon Representative, your personal information may be shared with Avon or an Avon Sales Leader or Business Development Manager solely for the purpose of contacting you to discuss becoming an Avon Representative. This may be 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 one year.
9. How to contact us
If you have any questions, comments or requests regarding this Privacy Statement please email firstname.lastname@example.org or write to Legal Department, Avon Cosmetics, Inc.,22F Pacific Star Building, Makati cor. Senator Gil Puyat Avenues, Makati City, Philippines 1200.
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.
Last updated: February 02, 2021