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 Justine (Pty) Ltd, a company registered in South Africa with registration number 1964/002772/07 and business address at McConnel Place, 148A Kelvin Drive, Woodlands Ext. 4, Johannesburg. Where your personal information is passed to Avon, we will be a responsible party in any scenario where we determine the means and purposes of processing of such information. Where you choose to purchase Avon goods via an Avon Representative, your personal information will also be processed by the Representative, as a responsible party of your personal information. Avon Representatives are independent and 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 personal information as defined in the Protection of Personal Information Act No. 4 of 2013 ("POPIA"). 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 and/ or physical address, e-mail address, telephone numbers)
• Your date of birth
• Information on your purchases from Justine, your opinions, 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), or with your Consultants on systems that Justine provides.
• 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; they also allow us to assess the website so we can improve it and provide us with information for marketing purposes. For more information on how we use cookies and how you can remove them, read our Cookie Policy.
• Identifiers such as your computer’s IP address or your mobile’s MAC address

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.

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 as part of our marketing communications; which you will only receive if you have opted to receive them. Such marketing communications are sent on the basis of your consent, which you can withdraw at any time by contacting us as set out below. 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 is to meet our legitimate 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 (including to investigate complaints or claims, and to administer the Avon product guarantee and any other rights to return products), 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 process this information on the basis of our legitimate interest to improve our product offering. If you choose to participate, the processing of the information relating to your participation and review is carried out on the basis of your consent, which you can withdraw at any time by contacting us.

•To administer competitions you enter and incentive schemes you have signed up for
We run certain competitions, and will need to process your name and contact details if you enter, as well as to let you know if you have won. We do this on the basis of your consent, which you can withdraw at any time by contacting us as set out below. Specific uses of personal data in this context will be detailed in the competition rules.

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 Area Sales Managers;
•other Avon group companies;
•suppliers providing services to us in order to help us run our business and improve our services and your customer experience;
•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.
Where your personal information is transferred outside of South Africa, Avon uses POPIA compliant mechanisms and ensures that appropriate safeguards are in place to protect personal information which is transferred to countries outside of South Africa which are considered to provide a lower level of protection for personal information. Further, POPIA compliant 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
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 (i.e. to achieve the purpose for which it was collected), 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 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/ deleted in terms of POPIA.
If you have an issue or complaint about how we handle your personal information, please contact our Information Officer.
In the event we are unable to resolve the issue or you are not satisfied with our Information Officer’s suggested remedies, please contact the South African Information Regulator by visiting the South African Information Regulator's website at the following link: http://justice.gov.za/inforeg/

7.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 Justine (Pty) Ltd, a company registered in South Africa with registration number 1964/002772/07 and business address at McConnel Place, 148A Kelvin Drive, Woodlands Ext. 4, Johannesburg who is a responsible party (as that term is defined in the Protection of Personal Information Act No. 4 of 2013 ("POPIA") in respect of your personal information. This means Avon will decide the purposes for which and the ways in which your personal information is processed.
Your personal information may also be processed by Sales Leaders, on our behalf, as operators. This means that Sales Leaders may also, 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 (without limiting the definition of the term in terms of POPIA), 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, ID or passport number, 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)
• Information about how you use our websites or our mobile apps. We use cookies and other similar technologies (such as Flash LSOs and pixel tags) on our websites and mobile apps. Cookies are small pieces of information stored by your browser on your computer's hard drive. They enable you to navigate on our websites or apps and allow us to provide features, such as keeping you logged in to our websites. For more information on how we use cookies and how you can remove them, read our Cookie Policy published on our website.

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 enquiry with a credit bureau before we provide you with credit for our products, or 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. We may use third parties to carry out these checks.

•To communicate with you and manage our relationship with you
We may contact you by email, SMS, any other electronic communication 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 conduct surveys and market research
In order to improve our service to you, we conduct surveys and market research studies using research methods that require us to process your name, contact details and certain other information we hold about you as a Representative. Specific uses of personal data in this context will be detailed in the surveys and research studies.

•To run competitions, loyalty and reward programs
We run certain competitions, loyalty and reward programs, and will need to process your name, contact details and certain other information we hold about you if you enter or are eligible to be entered, 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 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 or representatives;
•other Avon group companies;
•suppliers providing services to us in order to help us run our business and improve our services, and your independent sales representative experience;
•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 operators of your personal information) or to comply with specific legal obligations to which we are subject.

Where your personal information is transferred outside of South Africa, Avon uses POPIA compliant mechanisms and ensures that appropriate safeguards are in place to protect personal information which is transferred to countries outside of South Africa which are considered to provide a lower level of protection for personal information. Further, POPIA compliant 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.

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 (i.e. to achieve the purpose for which it was collected), 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/ deleted in terms of POPIA.
If you have an issue or complaint about how we handle your personal information, please contact our Information Officer.
In the event we are unable to resolve the issue or you are not satisfied with our Information Officer’s suggested remedies, please contact the South African Information Regulator by visiting the South African Information Regulator's website at the following link: http://justice.gov.za/inforeg/

8. Additional information for prospective Representatives
Where you provide your personal information to Avon or an Avon Sales Leader / Area Sales Manager for the purposes of enquiring about becoming an Avon Representative, your personal information may be shared with Avon or an Avon Sales Leader / Area Sales Manager 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.

9.How to contact us
If you have any questions, comments or requests regarding this Privacy Statement please contact your Area Sales Manager or queries@avon.co.za

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.