LAST UPDATED: September 22, 2016
Avon Products, Inc. ("API" "us" or "we") has created this Privacy Shield Statement to explain how we handle your personal information, if you are an Independent Sales Representatives of an affiliated entity of API (each, an “affiliate”) located in the UK, Germany, Italy or Spain (the "Covered EU Countries").
API has subscribed to the EU-US Privacy Shield Framework for the personal information described above. Accordingly, Avon 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://avoncompany.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.
Personal Information Received from the Covered EU Countries
API affiliates located in the Covered EU Countries transfer Independent Sales Representatives’ personal information to API and this information is maintained by API in the United States. That information includes but is not limited to name, work and personal contact information, gender, country of citizenship, date of birth; credit data, marital status, start date, bank account information, transactional data, sales activity and plans, performance data, management records, and system and application access data, and IP address and account information.
Use and Disclosure of Personal Information
API will use and disclose your personal information for purposes consistent with the privacy notices of its affiliates in the Covered EU Countries. Among other disclosures, API may be required to disclose your personal information in response to lawful requests from public and government authorities, including responding to requests to meet national security or law enforcement requirements.
Accountability for Onward Transfer
We contract with other companies and individuals to perform functions or services on behalf of API and its affiliates. They may have access to personal information needed to perform their functions, but are restricted from using the personal information for purposes other than providing services for us or our affiliates. API requires that its agents and service providers that have access to personal information of Independent Sales Representatives that is received from the Covered EU Countries either subscribe to the Privacy Shield Principles or are subject to the EU Privacy Directive or another adequacy finding or enter into a written agreement with us that requires them to provide at least the same level of privacy protection as is required by the relevant Privacy Shield Principles.
API is potentially liable if its agents process your personal information in a manner that is inconsistent with the Privacy Shield Principles.
We use reasonable and appropriate physical, electronic, and administrative safeguards to protect your personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction.
Data Integrity; Purpose Limitation
We take reasonable steps to ensure that the personal information we process is reliable for its intended use, accurate, complete, and current to the extent necessary for the purposes for which we use the personal information. If we intend to use your information for a purpose that is incompatible with the purposes specified in the applicable privacy notices of API affiliates in the Covered EU Countries, or if we intend to disclose it to a type of third party not previously identified, we will notify you and offer you the opportunity to "opt out" of such uses and/or disclosures.
You may ask to review and correct the personal information that we maintain about you by sending a request to email@example.com.
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 firstname.lastname@example.org. 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 Policy, please contact us by email at email@example.com, or write to either of the following addresses:
Avon Products, Inc., 601 Midland Avenue, Rye New York 10580 Attn: Legal Dept. - Privacy Office
Avon Cosmetics Limited, Nunn Mills Road, Northampton, NN1 5PA | United Kingdom,
Attn: Global Privacy Officer
Because e-mail communications are not always secure, please do not include sensitive information in your e-mails to us.
This policy 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.