1.  IMPORTANT INFORMATION AND WHO WE ARE  

PURPOSE OF THIS PRIVACY POLICY  

This privacy policy aims to give you information on how Oriflame collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product or service or register as a customer or Oriflame consultant.

This website is not intended for children and we do not knowingly collect data relating to children.

This privacy policy supplements other notices and privacy policies and is not intended to override them.

CONTROLLER  

Oriflame Group is made up of different legal entities, details of which can be found here: https://corporate.oriflame.com/   This privacy policy is issued on behalf of the Oriflame Group so when we mention ”Company”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the Oriflame Group responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us. Oriflame Holding AG is the controller and responsible for this website.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy.

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO at privacy@oriflame.com.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES  

We keep our privacy policy under regular review.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS  

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2.  THE DATA WE COLLECT ABOUT YOU  

Each time you visit the website, the Company will automatically collect the following personal data:

• o 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;
• o information about your visit to the website, including the full Uniform Resource Locators (URL) clickstream to, through and from the website (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; and
• o information obtained via the cookies that the Company places on the website – see below for more information.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA  

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

4.  HOW WE USE YOUR PERSONAL DATA  

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

1. Where we need to perform the contract we are about to enter into or have entered into with you.
2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
3. Where we need to comply with a legal obligation.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	(a) Identity(b) Contact	Performance of a contract with you
To process and deliver your order including:(a) Manage payments, fees and charges(b) Collect and recover money owed to us	(a) Identity(b) Contact(c) Financial(d) Transaction(e) Marketing and Communications	(a) Performance of a contract with you(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:(a) Notifying you about changes to our terms or privacy policy(b) Asking you to leave a review or take a survey	(a) Identity(b) Contact(c) Profile(d) Marketing and Communications	(a) Performance of a contract with you(b) Necessary to comply with a legal obligation(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity(b) Contact(c) Profile(d) Usage(e) Marketing and Communications	(a) Performance of a contract with you(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity(b) Contact(c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity(b) Contact(c) Profile(d) Usage(e) Marketing and Communications(f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical(b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity(b) Contact(c) Technical(d) Usage(e) Profile(f) Marketing and Communication	Necessary for our legitimate interests (to develop our products/services and grow our business)

MARKETING  

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can opt out from marketing and advertising through settings in your profile created on the website or by clicking on link provided in the email containing marketing and advertising content.

THIRD-PARTY MARKETING  

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

OPTING OUT  

You can ask us or third parties to stop sending you marketing.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6.  INTERNATIONAL TRANSFERS  

 We share your personal data within the Oriflame Group. This will involve transferring your data outside the European Economic Area (EEA).

1. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
2. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
3. Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7.  DATA SECURITY  

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?  

We store your personal data only as long as required for the intended purpose. If data is processed for multiple purposes, it will be deleted, or only stored in a form that cannot be directly traced back to you, as soon as no longer needed for the final specified purpose.

9.  YOUR LEGAL RIGHTS  

As the party affected by the processing of your data, you may claim certain rights under EU law- the General Data Protection Regulation (GDPR) and other relevant data protection regulations.

You are entitled to ask the Company:

1. i. for a copy of your personal data (in a commonly used electronic form, if you make such a request electronically);
2. ii. to correct your personal data (if it is inaccurate, incomplete or not up-to-date);
3. iii. 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. iv. to erase your personal data; or
5. v. 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 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 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.

The Company hopes 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: the Company’s data protection officer can be contacted at privacy@oriflame.com. You may also contact us at the following address: [insert registered address].

Time limits for compliance with the rights of the data subject.

We make every effort to comply with all requests within 30 days. However, this period may be extended for reasons relating to the specific right or complexity of your request.

Complaint to supervisory authorities.

Oriflame takes your concerns and rights very seriously. However, if you believe that we have not responded in an appropriate manner to your complaints or concerns, you have the right to lodge a complaint with your local data protection authority.