Privacy Shield Statement for Independent Sales Representatives
LAST UPDATED: April 12, 2019
Avon Products, Inc. ("API," "us" or "we") has created this Privacy Shield Statement for Independent Sales Representatives to explain how we handle your personal information that is collected by our affiliates located in the European Economic Area (“EEA”) and the United Kingdom (the “UK”) and transferred to API in the United States or is provided directly by you to API. Personal information covered by this Statement includes any information relating to an Independent Sales Representative that can be used to identify that individual either on its own or in combination with other readily available data. Such personal information includes, but is not limited to, name, work or personal contact information, date of birth, credit data, bank account information, transactional data, start date, sales plans, gender, country of citizenship, management records, performance data, IP address, or system or application access data.
API subscribes to the EU-US Privacy Shield Framework, as set forth by the United States Department of Commerce, for the collection, use, retention, and disclosure of personal information that is collected by our affiliates located in the EEA and the UK and transferred to API in the United States or is provided directly by you to API. As to such personal information, API certifies that it complies with the seven Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement and Liability (collectively, the "Privacy Shield Principles"). More information about the Privacy Shield Framework, including a list of entities that subscribe to the Privacy Shield, can be found at www.privacyshield.gov.
API is subject to the investigatory and enforcement powers of the Federal Trade Commission and other US authorized statutory bodies with respect to API’s use and disclosure of your personal information in accordance with the Privacy Shield Principles.
This Privacy Shield Statement supplements API’s Privacy Statement at http://www.okhie.com/privacy-statement.html. In the event of any inconsistency between this Privacy Shield Statement and API’s Privacy Statement with respect to the handling of this personal information, this Privacy Shield Statement will control. In the event of any inconsistency between the provisions of this Privacy Shield Statement and the Privacy Shield Principles, the Privacy Shield Principles will control.
Use and Disclosure of Personal Information
API may use and disclose your personal information for the following purposes, consistent with the privacy notices of its EEA and UK affiliates: data storage, monitoring and preventing unauthorized access to or use of data and systems, data analysis, reporting and audits, providing technological and administrative support, improving and developing new features for API’s and its affiliates’ systems, participating in and facilitating corporate and commercial transactions; complying with our or our affiliates’ legal obligations, and for performing insights research to improve your experience as an Independent Sales Representative.
Disclosure of personal information is limited to those persons who must use the information in order to carry out the above purposes. Notwithstanding the foregoing, API may be required to disclose your personal information in response to lawful requests from public authorities, including responding to requests to meet national security or law enforcement requirements.
Where required by applicable law and where applicable, API or its affiliates will provide Independent Sales Representatives an opportunity to opt out prior to disclosing personal information to a third party or using personal information for a purpose that is materially different from the purpose(s) for which that personal information was originally collected or subsequently authorized by the Independent Sales Representative. In certain circumstances, such as when the personal information at issue is considered sensitive, API or its EEA or UK affiliates will provide Independent Sales Representatives an opportunity to opt in (i.e., affirmatively and explicitly consent) prior to the disclosure of personal information to a third party or use of that personal information for a purpose that is materially different from the purpose(s) for which that personal information was originally collected or subsequently authorized by the Independent Sales Representative. Exceptions to consent requirements may apply where the disclosure or use of the personal information is necessary to carry out certain contractual obligations, for other reasons as permitted by the Privacy Shield Principles, or to comply with applicable law.
Accountability for Onward Transfer
We contract with third party companies or individuals, including agents, to perform functions or services on behalf of API and/ or its affiliates (“Service Providers”). These Service Providers may have access to personal information needed to perform their functions, but, if acting as our agent, are restricted from accessing, using, or disclosing the personal information for purposes other than providing their contracted-for services.
API requires Service Providers to enter into a written agreement with API that requires them to either be certified to comply with the Privacy Shield Principles or provide at least the same level of privacy protection as is required by the relevant Privacy Shield Principles.
API is potentially liable for any processing of personal information by Service Providers where such processing is inconsistent with the Privacy Shield Principles. API will not be liable if API was not responsible for the event giving rise to the alleged damage.
We use reasonable and appropriate physical, technical, and administrative safeguards to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.
Data Integrity and Purpose Limitation
We take reasonable steps to ensure that the personal information is reliable for its intended use, accurate, complete, and current to the extent necessary for the purposes for which we use the personal information.
You may ask to access, review, and/or correct the personal information that we maintain about you by sending a request to firstname.lastname@example.org.
Privacy Shield Recourse, Enforcement and Liability
If you have a complaint about API’s use and disclosure of your personal information, please contact us by email at email@example.com. API and its affiliates will investigate and attempt to resolve complaints and disputes regarding the use and disclosure of your personal information in accordance with the Privacy Shield Principles. In the event that your complaints cannot be resolved internally, they will be directed to the Judicial Arbitration and Mediation Services, Inc. (JAMS), an alternative dispute resolution provider based in the US. Resolution by JAMS of your dispute regarding API’s use and disclosure of your personal information in accordance with the Privacy Shield Principles will be free of charge. The JAMS website is found at https://www.jamsadr.com/eu-us-privacy-shield .
In some cases, you may be able to invoke binding arbitration to resolve your dispute regarding API’s use and disclosure of your personal information in accordance with the Privacy Shield Principles.
If you have any questions or concerns regarding this Privacy Shield Statement, please contact us by email at firstname.lastname@example.org or write to one of the following addresses:
Avon Cosmetics Limited, Nunn Mills Road, Northampton, NN1 5PA | United Kingdom, Attn: Privacy Office
Avon Products, Inc., 1 Avon Place, Suffern NY 10901 Attn: Corporate Secretary
Because e-mail communications are not always secure, please do not include sensitive information in your e-mails to us.
Privacy Statement Changes
This Statement may be changed from time to time, consistent with the requirements of the Privacy Shield. You can determine when this Privacy Shield Statement was last revised by referring to the "LAST UPDATED" legend at the top of this page. Any changes to this Statement will become effective upon our posting of the revised Statement on the Site.