Privacy & Cookie Policy

What does this Privacy Notice apply to?

Avon as part of Natura &Co Group of Companies (“Natura &Co”, “we”, “us”, “our”), are fully committed to the responsible collection, use and care of the personal data of its customers and website users. This Global Privacy Notice for Customers and Website Users (“Privacy Notice”) provides you with information on how Natura &Co collects, uses, and shares personal data through our websites, products, mobile applications, or other sites that display this Privacy Notice. 

If you are in a jurisdiction that recognizes the concept of a Data Controller or similar, the Data Controller is the Natura &Co entity (including Group of Companies) with which you have a customer relationship. If you have a query about how your Personal Data is being used, you can contact the data controller through the Data Protection Officer (DPO) team here.

Key Definitions

Capitalised terms not otherwise defined in this Notice have the following meanings:

Personal Data means any information relating to an identified or identifiable living individual.

Sensitive Personal Data means any information relating to an individual’s racial or ethnic origin, political opinions, religious or other beliefs, trade union membership, criminal records/history or processing of genetic data or biometric data, data concerning health or data concerning a natural person's sex life or sexual orientation. Depending on the country you are based sensitive personal data may also refer to personal information that, once leaked or illegally used, may cause harm to natural persons, including but not limited to information on specially designated status, financial accounts, individual location tracking, as well as the personal information of minors or information on social security, driver’s license, state identification, and passport numbers, precise geolocation, combination of email address, debit card, or credit card with security or access code, password, or other credentials allowing access to financial account.

Processing means the use of personal data including collection, recording, organization, structuring, adaptation or alteration, analysis, retrieval, consultation, providing or blocking access to (including remote access), disclosure, dissemination, aligning, copying, transfer, storage, deletion, hosting, combination, destruction, disposal, or other use or handling of personal data.

Data Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. In our company, the ultimate data controller is Natura & Co., our holding company.

Third Party means any natural person or legal entity, public authority, agency or any other body other than Data Subject, Data Controller, any vendor, supplier or service provider who solely or jointly process personal data on behalf of the Data Controller and acts on the Data Controller’s instructions.

Data Subject means the identified or identifiable living individual to whom the Personal Data relates.

Natura &Co Group of Companies means this.

Personal Data we collect and process

We collect, store, and process your Personal Data in a number of ways including when you:

• Visit our websites, and branded pages and applications through third-party platforms;
• Register an account with us and/or purchase products through our website and/or undertake a live consultation;
• Visit one of our retail stores or counters, including if you register an account with us in store;
• Provide data to our Customer Engagement, our Franchisees, direct marketing campaigns, sweepstakes and competitions;
• Correspond with us across any of our channels (e.g. messaging platforms such as text message, live chat, social media and email)
• Submit a review regarding our products at our websites, and branded pages and applications.

The following categories of Personal Data are followed by information about their source(s), purpose(s), legal bases and disclosure(s).

Categories of Personal Data	Examples of Personal Data and their sources	Purposes and legal bases for Personal Data Processing
Basic Personal Data	Identifiers may include your name, postal and email address, telephone number, gender, date of birth, country/state of residence, title, login information, your consultant/representative ID number, IP address, device identifier or similar other identifiers, beauty profile information. We may get identifiers directly from you when you correspond or communicate with us by phone, e-mail, and online chat, in our store, or otherwise; register or create an account; participate in a contest, sweepstakes or an online survey; sign up for our rewards program or other program or club; sign up for email and/or SMS news and alerts; or use social media to interact with us, or to share something from our websites with others. We may also get identifiers from third parties. like social media platforms, or individuals who purchase goods or services to be delivered to you (such as gifts or gift cards).	We may use these Personal Data to provide and improve the features, products and services you request; for registration, contests and promotions; to communicate with you to provide information; to provide personalized content, information, and to send you brochures, coupons, samples, offers and other information on our products or our Group Of Companies; when we perform our duties in a commercial relationship with you; to provide customer support when you communicate with us; to improve our Sites and Apps, our customer service and support, and the user experience;  to contact you via telephone or text message with offers relevant to your preferences; to allow you to log in with a social media account and share activities on your social media pages, such as Facebook; to verify your identity; to communicate with you about your account and activities on the Sites; to send notice of changes to any of our websites or policies; for processing of Personal Data needed for the assessment and acceptance of customers or vendors; to deliver relevant advertising; and/or for research. To verify your identity and credit score: We may share your data to credit bureaus to verify your identity and assess your credit score where required. When you review a product on our websites, and/or branded pages and applications used for marketing purposes including reprinting in brochures/other market materials and upon obtaining your consent, where required. Depending on the laws applicable in the country you are based, we will process such Personal Data on the basis of our legitimate interest(where applicable and depending on the country you are based), your consent, for the performance of our commercial relationship with you, or as otherwise permitted by law, as applicable.
Sensitive Personal Data	We limit the circumstances where we collect and process these special categories of data.   In some instances, you may have requested services or products that do not directly involve the collection of any special categories of data, but may imply or suggest your religion, health or other special categories of data, such as skin concerns and adverse events from you which may include information on your health and or ethnicity.	We may use these Personal Data to provide products and services you request; for registration, contests and promotions; to provide you with personalized content, information, and to send you brochures, coupons, samples, offers and other information on our products within Natura &Co Group Of Companies; to confirm your identity as a registered member; for analytical and demographic purposes; and when we perform our duties in a contract with you. We process such Sensitive Personal Data on the basis of your consent or as otherwise permitted by the laws applicable depending on the country you are based. This Sensitive Personal Data may be shared for business purposes within the Natura &Co Group of Companies and with service providers. Your Sensitive Personal Data will not be used for any additional purposes that are incompatible with the purposes listed above unless we provide you with notice of those additional purposes.
Commercial Data	We may obtain information on the products and services that you have shown an interest in or purchased, including product preferences, billing address, shipping address, together with purchase details (products, colour, size, quantity, price), methods of payment and/or any communications we have received about your order or purchase; name, card issuer and card type, credit or debit card number, expiration date, CVV code, and/or billing address; fraud checks or flags raised about your transactions, payment card refusals, suspected crimes, complaints and/or claims. We get this directly from you when you purchase goods and services   at any of our retail locations online or in person and in some cases from third parties.	We may use this Personal Data to provide and improve the features, products and services you request; to provide you with personalized content, information, and to send you brochures, coupons, samples, offers and other information on our products or our Group of Companies; to perform all management activities connected with fulfilment of your order, including administrative management of the contract, delivery of goods, payment processing, management of any claims and litigation, and fraud prevention; to validate, confirm, verify, deliver, install, and track your order, including to arrange for shipping, handle returns and refunds, and maintain a record of the purchases you make; to provision products you purchased from us; to provide you offers that may be of interest to you; and/or to deliver relevant advertising. We may also use this data to protect you, other customers and our business against criminal activities and risks, and to make sure we understand and can meet our legal obligations to you and others, and can defend ourselves. Depending on the laws applicable in the country you are based, we will process your Personal Data on the basis of our legitimate interest (where applicable and depending on the country you are based), for the performance of our contract with you, to comply with applicable legal obligations, or as otherwise permitted by law.
Internet or other similar network activity	You can generally visit the website without providing any personal data about yourself. In this case we only collect and store data about your website access which will automatically be transmitted from your browser to us when you access the website. We get this indirectly from you (e.g., from observing your actions on our Sites) or from third parties like data analytics providers. This may include: IP address, MAC address or other unique identifier information (“Device Identifier”) for the computer, mobile device, technology or other device (collectively, “Device”), domain name, browser type and version, browsing history, search history, information about your visit (including products viewed, purchased or search for), details of any website which has referred you to our website, application, or advertisement; location and time zone setting, browser plug-types and versions, operating system and platform, page responses times and errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, keystrokes typed, and mouseovers); the amount of time you spend viewing or using the Website and the pages visited, the number of times you return, or other click-stream or site usage data and mouseovers) and methods used to browse away from the page.	We may use this Data to provide you with personalized content, information, and to send you brochures, coupons, samples, offers and other information on our products or our group of companies; and/or to deliver relevant advertising. We also use this Data to enable the technical delivery of our website's content to your device; to improve our online services and the experience you receive when engaging with us online; as well as for purposes of the technical security of our website.   Depending on the laws applicable in the country you are based, we will process your Personal Data with your consent, and/or for the performance of our contract with you, and/or on the basis of our legitimate interests (where applicable and depending on the country you are based) in ensuring the security of the website, optimizing the website and services we offer to you, improving marketing, analytics, or site functionality, or as otherwise permitted by law. In certain jurisdictions you may be able to select your cookies preferences based on consent.
Preference information and Inferences drawn from other Personal Data	This includes a profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes. It also includes information ascertained about you from social media such as your profile picture, likes, location, and product preferences. We receive these inferences indirectly from you (e.g., from observing your actions on our Sites) or from third parties, such as a data analytics provider.	We use such Data to provide and improve the features, products and services you request; to provide you with personalized content, information, and to send you brochures, coupons, samples, offers and other information on our products or our Group of Companies; to contact you via telephone or text message with offers relevant to your preferences; to improve our websites, products and services, customer service, and customer shopping experience; to create a session replay that shows your visit to our site;  and/or to deliver relevant advertising or provide you with copies of our newsletter and information about our products, store launches, partnerships and in-store events, to contact you regarding service-related matters. We may use your data to gather feedback from you, to enable you to participate in customer research or focus groups, to inform you about products and commercial opportunities you may be interested in, to improve your experience as a Customer by building a profile of your preferences (including purchasing records) to offer you personalized products and offers; to enable your participation in our promotions, contests, prize draws, and special offers; to improve existing and develop new products and services; and to fulfil our administrative and commercial purposes and interests in activities such as those for security purposes, statistic and marketing analyses, systems maintenance, to manage product warranties and refunds. Depending on the laws applicable in the country you are based, we will process your Personal Data on the basis of our legitimate interest (where applicable and depending on the country you are based) and, when required by law, on your consent.
Communication Data	We may collect communication data from various sources, including contact lists, demographic information originally collected from other companies within Natura &Co group, and Personal Data legally obtained from other third parties, which may be combined with other information that we collect for the purposes described in this section, including information on your communications with us (e.g. your emails, letters, calls, posts and messages on our social media). This may include communications with Sales Managers, Regional Managers, and/or Beauty Entrepreneurs if they share such communications with us.	We use such Data to provide and improve the features, products and services you request; to provide you with personalized content, information, and to send you brochures, coupons, samples, offers and other information on our products or our Group of Companies; and/or to deliver relevant advertising. Depending on the laws that apply in your country, we will process your Personal Data on the basis of our legitimate interest(where applicable and depending on the country you are based), for the performance of our contract with you and, when required by law, on your consent.
Other Personal Data we may have collected with your consent	We get this information directly from you. This may include: Information you provide by calling, e-mailing, texting, or chatting online with our team and/or store staff or by responding to surveys or competitions.   ·         Information ascertained about you from social media such as your profile picture, likes, general geo-location details when using one of our mobile applications. ·           ·         Other information we have collected from you with your consent.	We use such Data to provide and improve the features, products and services you request; to provide you with personalized content, information, and to send you brochures, coupons, samples, offers and other information on our products or Natura &Co group of companies; when we perform our duties in a contract with you; and/or for processing of Personal Data needed for the assessment and acceptance of customers and to assist you to find your nearest store. Depending on the laws that apply in your country, we process your Personal Data on the basis of our legitimate interest(where applicable and depending on the country you are based), for the performance of our contract with you and, when required by law, on your consent.

About Third-party sites

You may be able to access our website from a third-party site or vice versa.  Your use of third-party websites is governed by the privacy policy of that site.  Different terms and conditions and privacy policies may apply.  They may send their own cookies or tracking files to your Device, and they may collect your Personal Data for their own purposes.  That information is not subject to this Privacy Notice.

How long we store your Personal Data

We store your Personal Data processed for the purposes stated in this Notice and for the duration of our business relationship with you. Once our business relationship with you has ended and your data is no longer required for these purposes, we will delete your data, unless your data is required also for other purposes set out in this Privacy Notice, and/or is necessary to fulfil applicable legal or regulatory obligations. We also may store your data for dealing with any complaints regarding our products and services. Our retention periods are being determined as per the legal requirements of the country you are based.

How we share and disclose your Personal Data

As a global Company, we may disclose your Personal Data to: 

• Natura &Co Group Of Companies;
• Customers, Sales Leaders and/or Franchisees of Natura &Co, if you have indicated a desire to purchase products this way;
• Third-parties who provide goods or services to help us conduct our business and improve our services;
• External auditors and or legal advisors;
• Other parties to whom we are authorised or required by law to disclose information;
• Law enforcement and other government authorities. To do so, the authority requires an appropriate judicial order or warrant, for which they need to demonstrate that the disclosure of the requested or intercepted information is We reserve the right to challenge these requests.

We may share or transfer your Personal Data in the course of any direct or indirect reorganization process including, but not limited to, mergers, acquisitions, divestitures, bankruptcies, and sales of all or part of our assets. Your Personal Data may be shared following the completion of such transaction and/or during the assessment pending transfer (subject to confidentiality requirements). If transferred, your Personal Data will remain subject to this Privacy Notice or a policy that, at a minimum, protects your privacy to an equal degree as this Privacy Notice unless you otherwise consent.

International Data Transfers: We may transfer your Personal Data to our affiliates and subsidiaries or to other third parties, in accordance with applicable local law, depending on the country you are based. We may also transfer your Personal Data from your country or jurisdiction to other countries or jurisdictions in accordance with legal requirements.

• For international data transfers subject to EEA, UK and Swiss law: we primarily use European Union Commission Standard Contractual Clauses.
• For transfers between other jurisdictions, we may rely on other legal mechanisms for international transfers, as appropriate under the relevant law.
• We have also concluded and executed an Intra-Group Agreement to ensure safe and lawful transfers of personal data take place among entities within the Natura Group of Companies, and also among different countries around the world, where such transfers are necessary in the course of business.

We carry out Transfers Impact Assessments to implement supplementary measures to ensure your personal data is processed under the standards that apply to your territory.

Your Sensitive Personal Data will not be used for any additional purposes that are incompatible with the purposes listed above unless we provide you with notice of those additional purposes.

We do not sell your Personal Data or your Sensitive Personal Data, nor do we share it with third parties for cross-context behavioural advertising.

How we protect your Personal Data

We implement comprehensive technical, physical and organizational measures to ensure a level of security appropriate to the risk to the personal data we process and to ensure compliance with applicable legal requirements. These measures are aimed at safeguarding the ongoing integrity and confidentiality of personal data. We evaluate and improve these measures on an ongoing basis.

How we approach to children’s privacy

Our websites are designed and intended for adults. We understand the importance of taking extra precautions to protect the privacy and safety of children using Natura &Co products and services. 

Where one of our websites may be intended for a younger audience, depending on the country our audiences are based  we get consent from a parent or guardian in accordance with the applicable local law. If you learn that a child has, in violation of this Privacy Notice, registered for email newsletters, or otherwise provided their Personal Data, please report it to us using the contact information provided at the bottom of this Privacy Notice. If we become aware that an underage user has provided Personal Data without parental permission, we will terminate that account and delete all Personal Data provided by that user to the extent feasible and as soon as practicable.

Depending on the country you are based, we may use your personal data to carry out age verification checks and enforce any such age restrictions.

Your rights in relation to the processing of your Personal Data

Depending on the country you are based, you may have some or all of the following rights:

• To obtain information on the personal data processed concerning you and to obtain a copy of such data (right of access);
• To obtain the rectification of any inaccurate personal data and, having regard to the purposes of the processing, the completion of incomplete personal data (right to rectification) (please let us know if and to what extent your data stored by us has changed, so that we can rectify or update the respective data);
• If there are legitimate reasons, to request the deletion of the personal data (right to erasure);
• To request the restriction of the processing of the personal data, if the legal requirements are met (right to restriction of processing);
• To withdraw your consent at any time, if the data processing is based on consent, provided that such withdrawal does not affect the lawfulness of the previous processing of your data (consent withdrawal);
• To receive the personal data provided by you in a structured, commonly used and machine-readable format and to transfer this personal data to another controller or, if technically feasible, to have it transferred by us (right to data portability); and
• Not to be subject to a decision based solely on automated processing which produces legal effects concerning you or significantly affects you in a similar way, if the legal requirements are not met (not to be subject to automated processing).
• To object, where applicable law provides, to the processing of your data (right to object):
  • which is being processed for the purposes of our legitimate interests (where applicable and depending on the country you are based) unless such interests outweigh your individual rights; and/or
  • for direct marketing purposes, without any special reason

 Depending on the country you are based, our digital marketing communications may provide unsubscribe or opt-out mechanisms that allow you to modify your communications preferences. Please note that if you opt-out of marketing communications, we may still contact you with non-promotional communications, such as those about ongoing business relations or administrative messages (e.g. updates on online orders).

In order to exercise your rights, including the withdrawal of your consent, please contact us here. You may also designate an authorized agent to make a request on your behalf. In order to protect your data from unauthorized access or alteration by third parties, all requests regarding your personal information will be subject to verification of the identity of the requesting individual.  We endeavour to respond to a verifiable request within required time frames.

A Data Subject who feels that we are not adhering to this Notice or applicable data protection laws with respect to his or her Personal Data may contact us to register a complaint; submit requests for exercising rights; or address any other issue arising under this Notice. Complaints by any person may also be referred to the DPO team by email here.

Without prejudice to any other remedies, you also have the right to lodge a complaint with a supervisory authority at any time.

Shine the Light Disclosure

California law allows California residents to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please put “Shine the Light” in the” Request Details” portion of your request on the form above or in the subject line, if submitted by e-mail. Note that there are restrictions on the number of times you can exercise some of these rights. You may designate an authorized agent to make a request on your behalf. The agent must provide proof of your authorization. We may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf. We may need to verify your request before completing it. For example, we may ask you to confirm data points we already have about you. We will only use Personal Data provided in a request to verify the requestor’s identity or authority.

Geolocation Data

If you have previously consented to sharing precise geolocation information with our Digital Services, you can choose to stop the collection of this information at any time by changing the preferences on your browser or mobile device settings.

Push Notifications/Alerts

If you have permitted one of our mobile applications to send you push notifications or alerts, you can deactivate these messages at any time in the notification settings on your mobile device.

Changes we make

We may update this Notice periodically and will revise the date at the bottom of this Notice to reflect the date when such update occurred. If we make any material changes in the way we collect, use, and/or share the personal information that you have provided, we will endeavour to provide you with notice before such changes take effect, such as by posting prominent notice on our Company website.

Continued use of the website constitutes acceptance of the new Privacy Notice. We encourage you to periodically review this page for the latest information on our privacy practices. Where required to do so by the applicable law depending on the country you are based, we may seek your prior consent to any material changes we make to this Privacy Notice.

In the event of any difference in interpretation or meaning between the English version and any other translation of this Privacy Notice, the English version shall prevail.

Effective Date: Jan 2024

 

What does this Privacy Notice apply to?

Avon as part of Natura &Co Group of Companies (“Natura &Co”, “we”, “us”, “our”), are fully committed to the responsible collection, use and care of the personal data of its representatives and consultants. This Global Privacy Notice for Representatives and Consultants (“Privacy Notice”) provides you with information on how we collect, use, and share personal data through our websites, products, mobile applications, or other sites that display this Privacy Notice. 

If you are in a jurisdiction that recognizes the concept of a Data Controller or similar, the Data Controller is the Natura &Co entity (including Group of Companies) with which you have a customer relationship. If you have a query about how your Personal Data is being used, you can contact the Data Controller through the Data Protection Officer (DPO) team here.

Key Definitions

Capitalised terms not otherwise defined in this Notice have the following meanings:

Personal Data means any information relating to an identified or identifiable living individual.

Sensitive Personal Data means any information relating to an individual’s racial or ethnic origin, political opinions, religious or other beliefs, trade union membership, criminal records/history or processing of genetic data or biometric data, data concerning health or data concerning a natural person's sex life or sexual orientation. Depending on the country you are based sensitive personal data may also refer to personal information that, once leaked or illegally used, may cause harm to natural persons, including but not limited to information on specially designated status, financial accounts, individual location tracking, as well as the personal information of minors or information on social security, driver’s license, state identification, and passport numbers, precise geolocation, combination of email address, debit card, or credit card with security or access code, password, or other credentials allowing access to financial account.

Processing means the use of personal data including collection, recording, organization, structuring, adaptation or alteration, analysis, retrieval, consultation, providing or blocking access (including remote access) to, disclosure, dissemination, aligning, copying, transfer, storage, deletion, hosting, combination, destruction, disposal, or other use or handling of personal data.

Data Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. In our Company, the ultimate data controller is Natura & Co., our holding company.

Third Party means any natural person or legal entity, public authority, agency or any other body other than Data Subject, Data Controller, any vendor, supplier or service provider who solely or jointly process personal data on behalf of the Data Controller and acts on the Data Controller’s instructions.

Data Subject means the identified or identifiable living individual to whom the Personal Data relates.

Natura &Co Group of Companies means this.

Personal Data we collect and process

We collect, store, and process your Personal Data in a number of ways including:

• When you are appointed as a representative or consultant of any of our brands.
• Depending on your role, your personal information may also be processed by Sales Leaders as independent controllers of your personal information. This means that Sales Leaders may, independently from us running their business operations, process your personal information.
• Sales Leaders will generally use your personal information in a way which is compatible with this Privacy Notice. 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.
• When you visit one of our retail stores or counters, including if you register an account with us in store;
• When you correspond with us across any of our channels (e.g. messaging platforms such as text message, live chat, social media and email).

The following categories of Personal Data are followed by information about their source(s), purpose(s), legal bases and disclosure(s).

Categories of Personal Data	Examples of Personal Data and their sources	Purposes and legal bases for Personal Data Processing
Basic Personal Data	Identifiers may include your name 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 us (e.g. Rep/Consultant ID), and any profile photo you upload to our systems, your date of birth, your banking details	We may 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 identity check before we provide you with an account limit through which to purchase product on payment terms; and a credit check to pursue or defend any legal claim, including to pursue any debt owed by you, in order to meet our legitimate business interests (where applicable and depending on the country you are based), in ensuring we can exercise our legal rights appropriately. We use third parties to carry out these checks. We may contact you by email, SMS or telephone for administrative or operational reasons, for example in order to send you confirmation of your order and your payments. We may contact you by email to send marketing and service emails to introduce our incentives to you or directing product reviews/surveys to you. Depending on the laws applicable in the country you are based, we will process such Personal Data on the basis of our legitimate interest(where applicable and depending on the country you are based), , for the performance of our contract with you, or as otherwise permitted by law.
Sensitive Personal Data	We limit the circumstances where we collect and process these special categories of data.   In some instances, you may have requested services or products that do not directly involve the collection of any special categories of data, but may imply or suggest your religion, health or other special categories of data, such as skin concerns and adverse events from you which may include information on your health and or ethnicity.	We may use this Personal Data to provide the products and services you request; for registration in contests and promotions; to provide you with personalized content, information, and to send you brochures, coupons, samples, offers and other information on our products within Natura &Co group of companies; when we perform our duties in a contract with you. We process this Personal Data on the basis of your consent or as otherwise permitted by the applicable laws of the country you are based. This personal data may be shared for business purposes within the Natura &Co Group of Companies and with service providers.
Commercial Data	Information on your purchases from us, commission and discount records and your reporting line information, as well as information about your preferences for particular types of products.	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 and Consultant experience. To help you sell of our product 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. Depending on the laws applicable in the country you are based, we will process your Personal Data on the basis of our legitimate interest(where applicable and depending on the country you are based), , for the performance of our contract with you, to comply with legal obligations, or as otherwise prescribed by law.
Inferences drawn from other Personal Data	This includes a profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes. It also includes information ascertained about you from social media such as your profile picture, likes, location and friend list and product preferences. We receive these inferences indirectly from you (e.g.from observing your actions on our Sites) or from third parties, such as a data analytics provider.	We use such Personal Data to provide and improve the features, products and services you request; to provide you with personalized content, information, and to send you brochures, coupons, samples, offers and other information on our products or our Group of Companies; and/or to deliver relevant advertising. We may also use it to provide you with copies of our newsletter and information about our products, store launches, partnerships and in-store events, contact you regarding service-related matters. We may use your data to gather feedback from you, to enable you to participate in customer research or focus groups, to inform you about products and commercial opportunities you may be interested in, to improve your experience as a Representative or Consultant by building a profile of your preferences (including purchasing records), to offer you personalized products and offers; to enable your participation in our promotions, contests, prize draws, and special offers; to improve existing and develop new products and services; and to fulfil our administrative and commercial purposes and interests in activities such as those for security purposes, statistic and marketing analyses, systems maintenance and developing, and to manage product warranties and refunds. Depending on the laws applicable in the country you are based, we will process this Personal Data on the basis of our legitimate interest (where applicable and depending on the country you are based), and, when required by law, on your consent.
Communication Data	We may collect communication data from various sources, including contact lists, demographic information originally collected from other companies within Natura &Co group, and Personal Data legally obtained from other third parties, which may be combined with other information that we collect for the purposes described in this section, including information on your communications with us (e.g. your emails, letters, calls, posts and messages on our social media). This may include communications with Sales Managers, Regional Managers, and/or Beauty Entrepreneurs if they share such communications with us.	We use such Data to provide and improve the features, products and services you request; to provide you with personalized content, information, and to send you brochures, coupons, samples, offers and other information on our products or our Group of Companies; and/or to deliver relevant advertising.   Depending on the laws applicable in the country you are based, we will process this Personal Data on the basis of our legitimate interest (where applicable and depending on the country you are based), ,  for the performance of our contract with you and, when required by law, on your consent.
Other Personal Data we may have collected with your consent	We get this information directly from you. This may include: ·         Information ascertained about you from social media such as your profile picture, likes, location and friend list ·         geo-location details when using one of our mobile applications; ·         Other information we have collected from you with your consent.	We use this Personal Data to provide and improve the features, products and services you request; to provide you with personalized content, information, and to send you brochures, coupons, samples, offers and other information on our products or Natura &Co Group of Companies; when we perform our duties in a contract with you; and/or for processing of Personal Data needed for the assessment and acceptance of customers and to assist you to find your nearest store. Depending on the laws applicable in the country you are based, we will process this Personal Data on the basis of our legitimate interest (where applicable and depending on the country you are based), and for the performance of our contract with you and, when required by law, on your consent.

How long we retain your Personal Data

We retain your Personal Data for the purposes stated on this Notice. To the extent retention of your Personal Data is no longer necessary for these purposes, your data will be deleted, unless your data is required for other purposes set out in this Privacy Notice, or further retention is mandatory by applicable laws and/or necessary to fulfil legal or regulatory obligations or to protect our legitimate interests (where applicable depending on the country you are based), including the establishment, exercise, or defence of any existing or potential legal claims. Our retention periods are being determined as per the legal requirements of the country you are based.

How we share and disclose your Personal Data

As a global Company, we may disclose your Personal Data to: 

• Natura &Co Group of Companies;
• Customers, other Representatives, Sales Leaders; and/or Franchisees of Natura &Co;
• Third-parties who provide goods or services to help us conduct our business and improve our services;
• External auditors and or legal advisors;
• Other parties to whom we are authorised or required by law to disclose information;
• Law enforcement and other government authorities. To do so, the authority requires an appropriate judicial order or warrant, for which they need to demonstrate that the disclosure of the requested or intercepted information is We reserve the right to challenge these requests.

We may share or transfer your Personal Data in the course of any direct or indirect reorganization process including, but not limited to, mergers, acquisitions, divestitures, bankruptcies, and sales of all or part of our assets. Your Personal Data may be shared following the completion of such transaction and/or during the assessment pending transfer (subject to confidentiality requirements). If transferred, your Personal Data will remain subject to this Privacy Notice or a policy that, at a minimum, protects your privacy to an equal degree as this Privacy Notice unless you otherwise consent.

International Data Transfers: We may transfer your Personal Data to our affiliates and subsidiaries or to other third parties, in accordance with applicable local law, depending on the country you are based. We may also transfer your Personal Data from your country or jurisdiction to other countries or jurisdictions in accordance with legal requirements.

• For international data transfers subject to EEA, UK and Swiss Law we primarily use European Union Commission Standard Contractual Clauses.
• For transfers between other jurisdictions we may rely on other legal mechanisms for international transfers, as appropriate under the relevant law.
• We have also concluded and executed an Intra-Group Agreement to ensure safe and lawful transfers of personal data take place among entities within the Natura &Co Group of Companies and also among different countries around the world, where such transfers are necessary in the course of business.

We carry out Transfers Impact Assessments to implement supplementary measures to ensure your personal data is processed under the standards that apply to your territory.

Your Sensitive Personal Data will not be used for any additional purposes that are incompatible with the purposes listed above unless we provide you with notice of those additional purposes.

We do not sell your Personal Data or your Sensitive Personal Data, nor do we share it with third parties for cross-context behavioural advertising.

How we protect your Personal Data

We implement comprehensive technical, physical and organizational measures to ensure a level of security appropriate to the risk to the personal data we process and to ensure compliance with applicable legal requirements. These measures are aimed at safeguarding the ongoing integrity and confidentiality of personal data. We evaluate and improve these measures on an ongoing basis.

Your rights in relation to the processing of your Personal Data

Depending on the country you are based, you may have some or all of the following rights:

• To obtain information on the personal data processed concerning you and to obtain a copy of such data (right of access);
• To obtain the rectification of any inaccurate personal data and, having regard to the purposes of the processing, the completion of incomplete personal data (right to rectification) )(please let us know if and to what extent your data stored by us has changed, so that we can rectify or update the respective data);
• If there are legitimate reasons, to request the deletion of the personal data (right to erasure);
• To request the restriction of the processing of the personal data, if the legal requirements are met (right to restriction of processing);
• To withdraw your consent at any time, if the data processing is based on consent, provided that such withdrawal does not affect the lawfulness of the previous processing of your data (consent withdrawal);
• If the legal requirements are met, to receive the personal data provided by you in a structured, commonly used and machine-readable format and to transfer this personal data to another controller or, if technically feasible, to have it transferred by us (right to data portability); and
• Not to be subject to a decision based solely on automated processing which produces legal effects concerning you or significantly affects you in a similar way, if the legal requirements are not met (right not to be subject to automated processing).
• To object, where applicable law provides, to the processing of your data (right to object):
  • which is being processed for the purposes of our legitimate interests (where applicable and depending on the country you are based) unless such interests outweigh your individual rights; and/or
  • for direct marketing purposes, without any special reason

Depending on the country you are based, our digital marketing communications shall provide unsubscribe or opt-out mechanisms that allow you to modify your communications preferences. Please note that if you opt-out of marketing communications, we may still contact you with non-promotional communications, such as those about ongoing business relations or administrative messages.

In order to exercise your rights, including the withdrawal of your consent, please contact us here. You may also designate an authorized agent to make a request on your behalf. In order to protect your data from unauthorized access or alteration by third parties, all requests regarding your personal information will be subject to verification of the identity of the requesting individual.  We endeavour to respond to a verifiable request within required time frames.

A Data Subject who feels that we are not adhering to this Notice or applicable data protection laws with respect to his or her Personal Data may contact us to register a complaint; submit requests for exercising rights; or address any other issue arising under this Notice. Complaints by any person may also be referred to the DPO team by email here.

Without prejudice to any other remedies, you also have the right to lodge a complaint with a supervisory authority at any time.

Shine the Light Disclosure

California law allows California residents to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please put “Shine the Light” in the ”Request Details” portion of your request on the form above or in the subject line, if submitted by e-mail. Note that there are restrictions on the number of times you can exercise some of these rights. You may designate an authorized agent to make a request on your behalf. The agent must provide proof of your authorization. We may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf. We may need to verify your request before completing it. For example, we may ask you to confirm data points we already have about you. We will only use Personal Data provided in a request to verify the requestor’s identity or authority.

Geolocation Data

If you have previously consented to sharing precise geolocation information with our Digital Services, you can choose to stop the collection of this information at any time by changing the preferences on your browser or mobile device settings.

Push Notifications/Alerts

If you have permitted one of our mobile applications to send you push notifications or alerts, you can deactivate these messages at any time in the notification settings on your mobile device.

How we approach to children’s privacy

Our websites are designed and intended for adults. We understand the importance of taking extra precautions to protect the privacy and safety of children using Natura &Co products and services. 

Where one of our websites may be intended for a younger audience, depending on the country our audiences are based we get consent from a parent or guardian in accordance with the applicable local law. If you learn that a child has, in violation of this Privacy Notice, registered for email newsletters, or otherwise provided their Personal Data, please report it to us using the contact information provided at the bottom of this Privacy Notice. If we become aware that an underage user has provided Personal Data without parental permission, we will terminate that account and delete all Personal Data provided by that user to the extent feasible and as soon as practicable.

Depending on the country you are based, we may use your personal data to carry out age verification checks and enforce any such age restrictions.

Changes we make

We may update this Notice periodically and will revise the date at the bottom of this Notice to reflect the date when such update occurred. If we make any material changes in the way we collect, use, and/or share the personal information that you have provided, we will endeavour to provide you with notice before such changes take effect, such as by posting prominent notice on the Company website.

In the event of any difference in interpretation or meaning between the English version and any other translation of this Privacy Notice, the English version shall prevail.

Effective Date: Jan 2024

 

AVON as part of Natura &Co group of companies (“Natura &Co”, “we”, “us”, “our”), is fully committed to the responsible collection, use, and care of the Personal Data of individuals. This Cookies Policy (“Policy”) describes the different categories of cookies or similar technologies (“Cookies”) that may be used in connection with the AVON site you are accessing Site and how you can manage them.

Please note that, to the extent information collected through cookies constitutes Personal Data, we process such Data according to our Privacy Notice. If you have a query about how your Personal Data is being used, you can contact the data controller through the Data Protection Officer (DPO) team here.

We use cookies on our Site, which amongst other things, help us to improve your experience of our Site and to ensure that it performs as you expect it to.

What is a cookie?

Cookies are text files containing small amounts of information, which are downloaded to your computer or mobile device by websites that you visit.

Who sets the cookies?

• First-party cookies: When you visit our Site, it asks your browser to store cookies on your device in order to remember information about you, such as your language preference or login information. Those cookies are set by us.
• Third-party cookies: We also have cookies on our Site that are set by third parties. These are cookies from a domain different than the domain of our Site you are visiting. We use these third-party cookies for our advertising and marketing efforts.

Types of Cookies

We will now explain what cookies we use on our Site and why we use them.

A. Category

• Strictly necessary cookies: These cookies are fundamental in making our Site work. They usually are activated in response to your actions and requests to our Site, such as when you login, set privacy preferences, or fill in forms. You can block them via your browser, but some parts of our Site will not work for you while such cookies are blocked.
• Cookies not strictly necessary: These cookies are not necessary for the proper functioning of our Site. We collect such cookies when you consent to it. We ask for your consent in our cookie banner or in the Site cookie settings, or in App permissions.

B. Subcategory

• Performance cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Site. They assist us in understanding which pages are the most and least favoured, and how visitors move around the Site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our Site and will not be able to monitor its performance.

We also use Google Analytics to help analyse how you use our Site, which generates statistical and other information by means of cookies. If you do not want your website visit data reported by Google Analytics, you can install the Google Analytics opt-out browser add-on at this link.

• Functional cookies: These cookies enable our Site to provide functionality and personalization and they allow the Site to remember choices you make and customised preference settings. They may be set by us or by third party providers whose services we have added to our Site. If you do not allow these cookies, then some or all of these services may not function properly.
• Targeting cookies: These cookies collect information about your browsing habits to make advertising relevant to you and your interests. They may be set through our Site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal data but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.
• Social media cookies: These cookies are inserted by social media services we add to our Site to allow you to share our content with your contacts. They can track your browsing in other Sites and personalise advertising on other Sites based on your interests. If you do not allow these cookies, you may not be able to see or use such sharing tools.

How long will cookies remain on my device?

The length of time that a cookie remains on your device depends on whether it is a “session” or “persistent” cookie.

• Session cookies last until you stop browsing. These are created temporarily. Once you close the browser, all session cookies are deleted.
• Persistent cookies last until they expire or are deleted.

Most of the cookies we use are persistent and will expire between 30 minutes and two years from the date they are downloaded to your device. See the following section on how to manage cookies and for more information on removing them before they expire.

Your Control Over the Cookies:

• We must get your consent to send cookies to your computer or mobile device unless the cookies are strictly necessary to provide services to you or the applicable laws allow otherwise. The cookies do not store any info that could personally identify you. When these cookies collect Personal Data, the lawful basis for such processing is our legitimate business interests, according to the applicable laws.
• You can refuse or accept cookies from our Site and set your cookie preferences when you first arrive at our Site or change them at any time at Cookie Settings
• Alternatively, you can use the cookies settings on your browser. Relevant information on browser settings can be also found on your browser provider's website via your help screen or you may wish to refer to the following site, which is not affiliated with us, for information on commonly used browsers.
• To disable cookies in our Application you should refer to the Settings on your mobile device.
• Unless the cookie is a strictly necessary cookie, you can withdraw your consent to our cookies at any time even if you have previously consented. Please be aware that when you withhold your consent, this does not automatically delete any cookies that are already on your device pursuant to your previous consent. You will need to delete these cookies manually by following the instructions on your web browser and/or device.

Contact us: AVON may amend this Policy from time to time. Please observe the date at the end of this page to see when this Policy was last revised. Changes to this Policy will be effective when we make available the revised version to our Site.

Please direct all questions, comments or, requests regarding this Policy to the DPO team here.

EFFECTIVE DATE: 10/10/2023