Oriflame Holdings B.V.[A1]  ("We" or "us") are committed to protecting and respecting your privacy.

This Privacy Notice (together with our end-user licence agreement as set out at Terms and Conditions (T&C) and any additional terms of use incorporated by reference into the EULA, together our Terms of Use) applies to your use of;

• SkinExpert mobile application mobile application software available via the itunes store or Google Play store (App Store), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).
• Any of the services accessible through the App (Services) that are available on the App Site or other sites of ours (Services Sites), unless the EULA states that a separate privacy policy applies to a particular Service, in which case that privacy policy only applies.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how We will treat it.

For the purpose of Data Protection, the data controller is Oriflame Holdings B.V of Bolduc Building A Utopialaan 52 5232 CE 's-Hertogenbosch, The Netherlands.

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. This is information you give us about you by filling in forms on the App Site and the Services Sites (together Our Sites), or by corresponding with us (for example, by e-mail or chat). It includes information you provide when you register to use the App Site, download or register an App, subscribe to any of our Services, search for an App or Service, make an in-App purchase, share data via an App's social media functions, and when you report a problem with an App, our Services, or any of our Sites. If you contact us, We will keep a record of that correspondence. The information you give us may include;:
   • Your name
   • Mobile number
   • E-mail address
   • Home Address
   • Birthday
   • Your Gender
   • Date of consultation
   • Your picture
   • Your Skin concerns (based on the assessment logic in app) including;
     1. Wrinkles
     2. Firmness
     3. Dark spots
     4. Dullness
     5. Your skin type/ethnicity
   • Your Age
   • Your calculated skin age (based on the app’s assessment)

      

     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.

2. Information we collect about you. We store the results and history of your skin consultation(s).
3. 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.

   2   Uses made of the information

    

   We use information held about you in the following ways:

   • 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;
   • To provide you with the rights, benefits, and entitlements, and other conditions as applicable under any contractual relationship between you and us;
   • To comply with other regulations applicable to our cooperation with you, such as, tax laws, social security laws, statistical obligations etc.;
   • 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;
   • To notify you about changes to our service;
   • To ensure that content from our site or app is presented in the most effective manner for you and for your computer;
   • To ensure effective management of the network of our consultants by ourselves but also by other members of our consultants networks;
   • To administer our site or app and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
   • To improve our site or app to ensure that content is presented in the most effective manner for you and for your computer or mobile device;
   • To allow you to participate in interactive features of our service, when you choose to do so;
   • To keep our site or app safe and secure;
   • 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
   • To respond to requests and legal demands from regulators or other authorities.

     3   Disclosure of your information

      

4. Your data is shared with the independent beauty consultant who performed your skin analysis with their mobile device or computer.
5. We do not sell, rent or trade your personal data.
6. 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).
7. We may give access to your information, and allow its processing, within a strictly defined scope and purposes to selected third parties such as:
   • 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.
   • Other members of our consultants network (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 contact us at privacy@oriflam.com.
   • 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).
   • Analytics and search engine providers that assist us in the improvement and optimisation of our site.
   • Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
   • 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:

   • 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.
   • 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.
   • 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.

     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 an order, the processing of your payment details, 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.

     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 or app (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. If you change your mind and do not want us to use your data in this way please contact customer service by sending an email to kundservice@oriflame.com;

     7   Your rights

      

8. Marketing Communications. Further to section 6, you have the right to ask us not to process your personal data for marketing purposes.
9. 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 privacy@oriflame.com, we will amend your personal data on your behalf. Further, upon your request to privacy@oriflame.com, 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.
10. 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.

    8   Cookies

     

    Our websites use 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:

11. 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.

12. 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.

13. Functionality Cookies

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

14. 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.

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. 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:  2018-03-15

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

Who is responsible for your PERSONAL DATA?

• ORIFLAME HOLDINGS B.V. is the data controller in respect of your personal data. We can be contacted using the following details: kundservice@oriflame.com
• In addition, you can contact Oriflames Data Protection Officer at privacy@oriflame.com.

• The independent beauty consultant who administered your skin consultation is also a Data Controller.

10.2 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?
      • Your name
      • Mobile number
      • E-mail address
      • Home Address
      • Birthday
      • Date of consultation
      • Your picture
      • Your Skin concerns (based on the assessment logic in app) including;
        1. Wrinkles
        2. Firmness
        3. Dark spots
        4. Dullness
      • Your Age
      • Your calculated skin age (based on the app’s assessment)
      • Your category of skin type
      • Your Age
      • Your calculated skin age (based on the app’s assessment)
      • Your category of skin type
         
   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 take a skin consultation with an independent beauty consultant.
        
        
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?
      • Your name
      • Mobile number
      • E-mail address
      • Home Address
      • Birthday
      • Date of consultation
      • Your picture
      • Your Skin concerns (based on the assessment logic in app) including;
        1. Wrinkles
        2. Firmness
        3. Dark spots
        4. Dullness
           
           
           1. 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);
                
                
           2. What is the source of this information?
              • You provide this information to us when you take a skin consultation with an independent beauty consultant.
           
           
3. To comply with other regulations applicable to our cooperation with you such as e.g. tax laws, social security laws, statistical obligations etc.
   • What information do we collect? Your name
   • Mobile number
   • E-mail address
   • Home Address
   • Birthday
   • Date of consultation
   • Your picture
   • Your Skin concerns (based on the assessment logic in app) including;
     1. Wrinkles
     2. Firmness
     3. Dark spots
     4. Dullness
        
        
        1. 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)
             
             
        2. What is the source of this information?
           • You provide this information to us when you take a skin consultation with an independent beauty consultant.
             
             
4. To monitor and assure compliance by you with our policies and rules;
   1. What information do we collect?
      • Your name
      • Mobile number
      • E-mail address
      • Home Address
      • Birthday
      • Date of consultation
      • Your picture
      • Your Skin concerns (based on the assessment logic in app) including;
        1. Wrinkles
        2. Firmness
        3. Dark spots
        4. Dullness
           
           
           1. 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.
           2. What is the source of this information?
              • You provide this information to us when you take a skin consultation with an independent beauty consultant.
                
                
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?
      • Your name
      • Mobile number
      • E-mail address
      • Home Address
      • Birthday
      • Date of consultation
      • Your picture
      • Your Skin concerns (based on the assessment logic in app) including;
        1. Wrinkles
        2. Firmness
        3. Dark spots
        4. Dullness
           
           
           1. 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.
           2. What is the source of this information?
              • You provide this information to us when you take a skin consultation with an independent beauty consultant.
                
                
6. To notify you about changes to our service;
   1. What information do we collect?
      • Your name
      • Mobile number
      • E-mail address
      • Home Address
      • Birthday
      • Date of consultation
      • Your picture
      • Your Skin concerns (based on the assessment logic in app) including;
        1. Wrinkles
        2. Firmness
        3. Dark spots
        4. Dullness
           
           • Your Age
           • Your calculated skin age (based on the app’s assessment)
           • Your category of skin type
             
             
             1. 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.
             2. What is the source of this information?
                • You provide this information to us when you take a skin consultation with an independent beauty consultant.
           
           
7. To ensure that content from our app is presented in the most effective manner for you and for your computer;
   1. What information do we collect?
      • Your name
      • Mobile number
      • E-mail address
      • Home Address
      • Birthday
      • Date of consultation
      • Your picture
      • Your Skin concerns (based on the assessment logic in app) including;
        1. Wrinkles
        2. Firmness
        3. Dark spots
        4. Dullness
           
           
           1. 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.
           2. What is the source of this information?
              • You provide this information to us when you take a skin consultation with an independent beauty consultant.
                
                
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?
      • Your name
      • Mobile number
      • E-mail address
      • Home Address
      • Birthday
      • Date of consultation
      • Your picture
      • Your Skin concerns (based on the assessment logic in app) including;
        1. Wrinkles
        2. Firmness
        3. Dark spots
        4. Dullness
           
           
           1. 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.
           2. What is the source of this information?
              • You provide this information to us when you take a skin consultation with an independent beauty consultant.
                
                
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?
      • Your name
      • Mobile number
      • E-mail address
      • Home Address
      • Birthday
      • Date of consultation
      • Your picture
      • Your Skin concerns (based on the assessment logic in app) including;
        1. Wrinkles
        2. Firmness
        3. Dark spots
        4. Dullness
           
           
           1. 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.
           2. What is the source of this information?
              • You provide this information to us when you take a skin consultation with an independent beauty consultant.
                
                
10. To allow you to participate in interactive features of our service, when you choose to do so;
    1. What information do we collect?
       • Your name
       • Mobile number
       • E-mail address
       • Home Address
       • Birthday
       • Date of consultation
       • Your picture
       • Your Skin concerns (based on the assessment logic in app) including;
         1. Wrinkles
         2. Firmness
         3. Dark spots
         4. Dullness
            
            
            1. 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.
            2. What is the source of this information?
               • You provide this information to us when you take a skin consultation with an independent beauty consultant.
                 
                 
11. To keep our site safe and secure;
    1. What information do we collect?
       • Your name
       • Mobile number
       • E-mail address
       • Home Address
       • Birthday
       • Date of consultation
       • Your picture
       • Your Skin concerns (based on the assessment logic in app) including;
         1. Wrinkles
         2. Firmness
         3. Dark spots
         4. Dullness
            
            
            1. 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.
            2. What is the source of this information?
               • You provide this information to us when you take a skin consultation with an independent beauty consultant.
                 
                 
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?
       • Your name
       • Mobile number
       • E-mail address
       • Home Address
       • Birthday
       • Date of consultation
       • Your picture
       • Your Skin concerns (based on the assessment logic in app) including;
         1. Wrinkles
         2. Firmness
         3. Dark spots
         4. Dullness
            
            
            1. 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.
            2. What is the source of this information?
               • You provide this information to us when you take a skin consultation with an independent beauty consultant.
                 
                 
13. To respond to requests and legal demands from regulators or other authorities;
    1. What information do we collect?
       • Your name
       • Mobile number
       • E-mail address
       • Home Address
       • Birthday
       • Date of consultation
       • Your picture
       • Your Skin concerns (based on the assessment logic in app) including;
         1. Wrinkles
         2. Firmness
         3. Dark spots
         4. Dullness
            
            
            1. 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).
            2. What is the source of this information?
               • You provide this information to us when you take a skin consultation with an independent beauty consultant
                 
                 
                 

10.3 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.

10.4 MORE INFORMATION ABOUT ORIFLAME'S TRANSFER OF YOUR PERSONAL DATA OUTSIDE THE EEA

The personal data we collect about you 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

10.5 MORE INFORMATION ABOUT ORIFLAME'S RETENTION OF YOUR PERSONAL DATA

- We will retain your information only as long as is necessary for the purposes listed above.

- if you purchase products from your consultant we will retain your information while you are a customer. If you do not purchase products within 3 months of the last skin consultation then we will mark your data as dormant. Once dormant you will still be able to contact your consultant. If you do not contact your consultant within 9 months of becoming dormant then we will erase your personal data provided to us as part of the skin care consultation via the SkinExpert app.