Arbonne Data Protection Policy (including Cookie Policy)

Revision Date: May 2018

Arbonne UK Limited (“Arbonne”, “we”, “us” or “our”) are committed to protecting and respecting your right to privacy. 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 text carefully to understand how we will collect, use, transfer or otherwise process personal data about you.

By accessing and using any part of this website (the "Website") you will be deemed to have consented to the collection and use of your personal data in accordance with the terms of this Data Protection Policy. If you do not consent to the processing of your personal data in accordance with the terms of this Data Protection Policy please leave this Website immediately and do not access or use the Website in the future.

Arbonne Independent Consultants (see below) also consent to the collection of personal data in accordance with the separate EU Data Protection Clauses as part of the Arbonne Independent Consultant Application and Agreement executed by them when registering with us. Preferred Clients consent to the collection of personal data in accordance with the Terms and Conditions of the Preferred Client Program executed by them when registering with us.

You can revoke your individual consent at any time by sending us an email to privacy@arbonne.com or via mail. Please see Section 8 below for more details.

For the purpose of applicable data protection law, the joint data controllers are Arbonne UK Limited of Unit 16 Basset Court, Loake Close, Grange Park, Northampton, NN4 5EZ, and Arbonne International, LLC of 9400 Jeronimo Road, Irvine, California 92618, U.S.A. (“Arbonne International”). Each of the foregoing is registered as a data controller with the UK Information Commissioner’s Office with registration numbers ZA254762 and Z1104619, respectively.

1. Scope of this Data Protection Policy

This Data Protection Policy applies to the information we collect through this Website and all mobile appearances, applications, widgets, and other interactive features that contain a link to this Data Protection Policy ("the Website"), including personal data that Arbonne may receive offline from you.

Arbonne grants its independent consultants certain rights to sell their products (hereinafter referred to as "Arbonne Independent Consultants"). Arbonne Independent Consultants are not employed at Arbonne. As a result, Arbonne has no influence whatsoever and does not accept any responsibility or liability for the collection, use or disclosure of personal data by Arbonne Independent Consultants, including the use of personal data for their own marketing purposes. When you provide personal data to an Arbonne Independent Consultant, Arbonne will gain access to and process such personal data in accordance with this Data Protection Policy. The Arbonne Independent Consultants are each also responsible that they do not process your personal data anymore in case that you withdraw your consent as soon as they are informed about it Arbonne Independent Consultants may provide Arbonne with personal data about their clients. In this case, Arbonne will process these data sets in accordance with this Data Protection Policy to the extent Arbonne has control over such personal data.

If you are a client of an Arbonne Independent Consultant, please contact your Consultant directly to find out about their data protection practices.

2. Personal Data We Collect from You

We may collect and otherwise process the following information (including personal data) about you:

  • Information you give us: You may provide information by filling in forms on the Website. This includes information you provide (for example, your name, address, telephone number, email address, credit card information, etc.) at the time of registering to use the Website, purchasing goods and/or services, registering as an Arbonne Independent Consultant, posting material or requesting further services. We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
  • Information we collect about you: We may automatically collect details of your visits to the Website (including, but not limited to, IP address, traffic data, location data, weblogs and other communication data) and the resources that you access. The information we collect may also include records of correspondence and information you provide to us if you contact us via this Website or other ways of communication, such as postal addresses. We also collect details of transactions you carry out through our Website and of the fulfilment of your orders.
  • 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 are also working 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.
  • Personal Data from Social Media: In certain cases, we will receive your name, email address and/or your (Facebook) ID number from the social media platform, e.g. when you “like” one of our products.

This Website is intended for use by persons ages 18 and older. We do not knowingly collect or use information from unsupervised individuals under the age of 18. Any individual under the age of 18 who uses this Website must have the consent of or be under the supervision of a parent or guardian while using this Website.

3. Cookies

Our Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our Website. For information on the cookies we use and the purposes for which we use them see our separate Cookie Policy.

4. IP Addresses

We may collect information about your computer, including where available your IP address, operating system and browser type, solely for system administration and helpdesk functions and to report aggregated information about our users' browsing actions and patterns.

5. Where We Store your Personal Data

The personal data that we collect from you will be transferred to, and stored in the United Kingdom, as well as destinations outside the European Economic Area (the "EEA") in the USA (to Arbonne International) and other wholly-owned subsidiaries of Arbonne International. The personal data will also be processed by staff operating outside the EEA who work for us or for one of our vendors or suppliers. Such staff may be engaged in, among other things, the fulfilment of orders, the processing of payment details, the delivery of packages and the provision of administrative, customer service or other support services. By submitting your personal data, you agree to this transfer, storing or otherwise processing and to your personal data being disclosed to such third parties irrespective of their location for the purposes set out in this statement. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Data Protection Policy in the areas outside the EEA, such as using the European Commission’s Standard Contractual Clauses (Model Clauses) for personal data transfer to Arbonne International into the United States, and, if necessary, to other wholly-owned subsidiaries of Arbonne International.

We will retain your personal data for a reasonable period of time as long as the purpose exists for which the personal data have been collected or longer if required by applicable law.

We employ reasonable security measures to protect your information from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage. Where we have given you (or where you have chosen) a Personal Identification Number (PIN) which enables you to access certain parts of the Website, you are responsible for keeping this PIN confidential. We ask you not to share a password with anyone. 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 the Website; 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. If you have reason to believe that your contacts with us are no longer secure (for example, if you feel that the security of an account you have with us is impaired), please contact us immediately as described in Section 10 below.

6. Purposes for the Processing of your Personal Data

We may use and analyse the personal data we collect, in accordance with the provisions of the BDSG and other applicable law, so that we can administer, support, manage, improve and develop our business and optimise your experience on our Website.

We use your personal data for the following purposes:

  • For the purposes you have provided the personal data to us, such as responding to your requests;
  • To provide you via email, SMS, telephone or mail with information, products or services that you request from us or which we feel may interest you or are especially tailored to your interest, where you have consented to be contacted for such purposes.
  • To help you find an Arbonne Independent Consultant and to inform you when an Arbonne Independent Consultant provides a new platform for her services.
  • To carry out our obligations arising from any contracts entered into between you and us, including the fulfilment of orders and services, your payment to Arbonne and the payment of commissions. Our products are sold through our network of Arbonne Independent Consultants, including via online shopping that is fulfilled directly by us in connection with an Arbonne Independent Consultant. When you purchase goods or services online from us, your information is automatically routed to our Arbonne Independent Consultants. Each Arbonne Independent Consultant is responsible for her or his own compliance with applicable data protection laws and industry standards.
  • To allow you to participate in interactive features of our service and contests and sweepstakes, when you choose to do so.
  • For internal business purposes, such as data analytics, accounting, developing new products, improving our Internet presence or online/ offline service, determining marketing trends and the effectiveness of our promotions and/or advertisement,
  • To notify you about changes to our service.
  • For fraud prevention, e.g. preventing Independent Consultants whose contracts have been terminated or whose applications have been refused from re-registering.

We undertake that we will not sell, transfer or share any Personal Information about you to any third parties outside of Arbonne and its approved partners, including Arbonne Independent Consultants, who have agreed to comply with the all necessary legal requirements concerning privacy, except under extraordinary circumstances as may be required by law or to protect legal rights. We may also use your data, or permit selected trusted third parties who have agreed to comply with our privacy policy to use your data, to provide you with information about goods and services which may be of interest to you and we or they may contact you about these by email, post or telephone.

7. Transfer of Your Personal Data

We undertake that we will not sell, transfer or share any Personal Data about you to any third parties outside of Arbonne unless and to the extent they have agreed to comply with the all necessary legal requirements concerning your data protection rights, such as personal data transfers:

(a) To Arbonne’s affiliated companies, but not for their direct marketing purposes, to the extent that this is necessary for the above purposes:

(b) To Arbonne’s external service providers providing services, such as web hosting, data analytics, payment and order processing, infrastructure provision, IT services, customer service, e-mail delivery, credit card processing, auditing, training and similar services. (These external parties receive your personal data or access to it exclusively for the purpose of providing such services to us or to you on our behalf.);

(c) To Arbonne Independent Consultants, in so far as they are necessary to contact you, process your orders or provide a service for you;

(d) To an external party in the event of restructuring, merger, sale, joint venture, transfer, transfer or other sale or disposal of our business, assets or shares (including bankruptcy or similar proceedings); and

(e) For data processing according to the following requirements:

  • (i) under applicable law, including applicable law outside the country of your domicile;
  • (ii) to comply with legal procedures;
  • (iii) at the request of public and public authorities, including public and public authorities outside the country of your domicile;
  • (iv) to enforce our general terms and conditions of business;
  • (v) to protect our operations and operations of our affiliates;
  • (vi) to protect our and your rights, privacy, security or our property or our affiliates and other persons, such as fraud protection; and
  • (vii) to enable us to assess available remedies or to limit possible harm.

The Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own security, privacy and cookie policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

8. How to Exercise Your Rights

You have the right to withdraw your consent (entirely or in part) to process your personal data at any time. In particular, you may ask us not to process your personal data for marketing purposes ("opt out"). We will inform you (before collecting your personal data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to opt out by writing us at privacy@arbonne.com or via mail (see Sec. 9). You can also withdraw your consent by writing to this email address. In this case, Arbonne will inform the relevant Independent Consultants and/ or vendors that have access to your personal data that you do not want them to process your personal data. However, while we make reasonable efforts to inform our consultants and vendors about your withdrawal of consent, it may not be technically or legally possible that some or all personal data related to your purchases in the past or on existing customer lists will be deleted or anonymized by Arbonne.

The Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own security, privacy and cookie policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

9. Access to Personal Data

Data protection law gives you the right to access information held about you. You may also ask us to make changes to the information we hold about you to ensure that it is accurate and kept up to date. If you wish to do this, please send your request to privacy@arbonne.com or contact us via email. Arbonne reserves the right to charge a reasonable fee for our costs in providing you with details of the information we hold about you.

10. General

We reserve the right at our discretion to make any changes to this Data Protection Policy. Any amendments to this Data Protection Policy will be immediately effective upon posting on the Website and your continued use of the Website following any such change will constitute your acceptance of such amendments.

If any provision of this Data Protection Policy is held to be illegal, invalid or otherwise unenforceable that shall not affect the legality, validity or enforceability of the remaining provisions, which shall remain in full force and effect.

All questions, comments and requests regarding this Data Protection Policy are welcome and should be addressed to privacy@arbonne.com or to:

Arbonne UK Limited
Attn: Data Protection Officer/Chief Information Security Officer
16 Basset Court
Loake Close
Grange Park,
Northampton NN4 5EZ

PLEASE PRINT A COPY OF THIS AGREEMENT FOR YOUR RECORDS AND PLEASE CHECK THE WEBSITE FREQUENTLY FOR ANY CHANGES TO THIS AGREEMENT.

(Last revised on: May 2018)

The Website uses cookies to distinguish you from other users of the Website, to place items in your shopping cart and to assist your use of the Website. A cookie is a small text file that we store on your browser or the hard drive of your computer if you agree. A cookie will typically contain the name of the domain from which the cookie has come, the "lifetime" of the cookie, and a value, usually a randomly generated unique number.

Cookies help us to improve our Website and to deliver a better and more personalised service. They enable us:

  • to store information about your preferences, and so allow us to customise the Website according to your individual interests;
  • to speed up your searches; and
  • to recognise you when you return to the Website.

You may refuse to accept cookies by activating the setting on your particular browser which allows you to refuse the setting of cookies. However, if you select this setting you may limit the functionality of certain parts of the Website, including online purchasing. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to the Website.

We use the following types of cookies:

  • Strictly necessary cookies. These are required for the operation of our Website, for example, to enable you to log into secure areas of the Website.
  • Analytical cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it.
  • Functionality cookies. These are used to recognise you when you return to our Website, which allows us to personalise our content for you, greet you by name and remember your preferences.
  • Targeting cookies. These record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. We do not provide information that is directly associated with a specific person (such as name and address). However, when you view or interact with an advertisement, the advertiser may make an assumption that you are interested in the subject matter of the advertisement.

Most web browsers allow some control of most cookies through the browser settings. You can opt out of delivery of targeted advertising by Arbonne and by multiple other companies by visiting any of the following websites: www.aboutads.info/choices, www.networkadvertising.org/managing/opt_out.asp and www.evidon.com.

You can find more information about the individual persistent cookies we use and the purposes for which we use them in the table (Third Party Cookies) below. The first column shows the company and /or service that sets the cookie and the name(s) of the cookies, the following column the purposes for which the cookies are used. In the third column, we provide you with a link and further information how you can opt out of these cookies. Please note that you cannot opt out of those cookies that are “strictly necessary” to run our website and provide our services to you:

Optimizely Cookies
optimizelyBuckets
optimizelyEndUserId
optimizelySegments
Analytical/performance cookies
These cookies allow us to analyze how many visitors we have to our website and how visitors use it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily
//www.optimizely.com/opt_out/
AppDynamics Cookies
ADRUM_BT1
ADRUM_BTa
Analytical/performance cookies
These allow us to analyze how many visitors we have to our website and how visitors use it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily
//www.appdynamics.com/cookie-policy/
SalesForce Cookies
inst (Session)
clientSrc (Session)
Sid_client (Session)
Sid (Session)
Oinfo
Oid (Session)
autocomplete
These cookies enable you to navigate the Company’s Web sites and use its features, such as accessing secure areas of the Web sites and using Salesforce Services. //www.salesforce.com/company/privacy/full_privacy.jsp
Note: You will need these cookies to use the Salesforce Services.
Google Cookies
_utma
_utmb
_utmc (Session)
_utmt
_utmz
_ga
_gid
_dc_gtm_UA-54682012-12
Analytical/performance cookies
These allow us to analyze how many visitors we have to our website and how visitors use it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. The information is usually transferred to a Google server and stored there. On behalf of Arbonne Google will use this information to evaluate your use of the website, compiling reports on website activity and providing others with website and internet related services to the website operator. Google Analytics has undertaken that your IP address will not be merged with other data from Google.
//tools.google.com/dlpage/gaoptout
//www.google.com/policies/technologies/cookies/
Note: You can also prevent the data being generated by the cookie about your use of the website to Google (including your IP address) and the processing of these data by Google, by downloading and installing a browser plugin which is available under the following link: https://tools.google.com/dlpage/gaoptout?hl=de). For more information on Terms of Use and Privacy Policy of Google, we refer to https://www.google.com/analytics/terms/de.html or to //www.google.de/intl/de/policies/.
Amazon Web Services Cookies
AWSELB
Required cookies enable you to navigate the Company’s Web sites and use its features, such as accessing secure areas of the Web sites and using Arbonne Services. //aws.amazon.com/privacy/
Note: You may have trouble to see some or all of Amazon’s products of you deny these cookies.
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