Oriflame Cosméticos LDA ("We") arecommitted to protecting and respecting your privacy.

This Privacy Policy (together with our end user licence agreement and any additional terms of use, together with our Terms of Use) applies to your use of;

Oriflame SkinExpert mobile application software, available via the itunes store or Google Play store, once you have downloaded the App onto your mobile device (Device).
Any services available through the App (Services), available on the App Site or another of our websites ( ServiceSites), unless CLUF states that a separate privacy policy applies for a specific Service, in which case only that privacy policy applies.

This privacy policy sets out the basis on which any personal data we collect about you, or that you provide to us, is processed by us. Please read the text below carefully to understand our views and practices regarding your personal data and how We will treat it.

For Data Protection purposes, the data controller is Oriflame Cosméticos LDA with registered office at Edifício Adamastor, Avenida D. João II, Torre B, nº 9-I, 13º piso, B e C, 1990-077 Lisboa.

We process your personal data in accordance with the information provided below.

1Information wemay collect about you

We may collect and process the following data about you:

Information you provide to us. This is information that you give us about yourself by filling in forms on the App Site and Services Sites (together Our Sites), or by communicating with us (for example by email or chat). This includes information you provide when you register to use the App Site, download or register an App, subscribe to any of our Services, search for an App or Service, make a purchase within the App, share data through the App's social networking features, and when you report a problem with an App, our Services or any of our Sites. If you contact us, we will keep a copy of that correspondence. The information you provide may include your details:
- Name
- Mobile phone number
- Email address
- Address
- Date of birth
- Gender
- Date of counselling
- Photo
- Skin concerns (based on the assessment carried out in the App) including ;
  1. Wrinkles
  2. Firmness
  3. Dark spots
  4. Dull skin
  5. Skin type/ethnicity
- Your age
- Your "skin age" (based on App assessment)
  
  Please note that if you do not provide the above information, in some cases we will not be able to provide you with the requested service.
Information collected about you. We store the results and history of your skin counselling.
Information we receive from other sources. We may receive information about you if you use any other websites run by us or other services provided by us. We also work with third parties (including, for example, partners, subcontractors in technical, payment and delivery services, advertising networks, analytical providers, information research providers, etc.).providers, credit reference agencies) and we may obtain information about you from them. We may also receive information about you from other members of the advisor network .

2 Uses of information

We use information about you in the following ways:
- To fulfil our obligations arising from any contracts entered into between you and us in order to provide you with information, products and services that you request from us, including resolving any disputes, collecting fees and resolving problems;
- To grant you the rights, benefits and other conditions in force under the contractual relationship between you and us;
- Tocomply with other regulations applicable to our Company, such as tax legislation, social security legislation, statistical obligations, etc;
- Toprovide you withinformation about products or services that we consider to be of interest to you.We will only contact you by electronic means (email or SMS) with information about products and services similar to those you have previously purchased. Please see section 6 below for more information;
- To notify you of changes to our service;
- Toensure that the content of our website or App is presented in the most effective way for you and your computer;
- To ensure more effective management of our brand partner network on our part, but also on the part of other members of our brand partner network;
- To administer our website or App and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- To improve our website or App to ensure that the content is presented in the most effective way for you, for your computer and mobile device;
- To allow you to participate in interactive features of our service, whenever you choose to do so;
- To keep our site or App secure;
- Tomeasure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you, which includes consumer satisfaction survey and other similar studies; and
- To respond to legal requests and demands from regulators or other authorities.
  
  3 Disclosure of your information
Your data is shared with the Brand Partner who carried out your skin test using your mobile device or computer.
We do not sell, transfer or commercialise your personal data.
Wemay give access to your personal data and allow it to be processed by companies belonging to our group (parent company and its subsidiaries) in order to support us in carrying out the activities listed in point 2 above (Information Uses).
We may give access to your information and allow its processing to third parties, determined by us, for strictly defined purposes, such as:
- Our business partners: suppliers and subcontractors for the performance of any contract we enter into with them. This includes, but is not limited to: carriers, credit collection agencies, factoring service providers, logistics service providers (such as picking and packing), customer support service providers, etc.
- Other members of our Brand Partner network for effective management of our partner network. If you do not wish to pass on your personal data to other partners in the network for the purposes mentioned, please contact us at privacy@oriflame.com.
- Advertisers who need data to select and send relevant adverts to you and others. We may also use aggregated information to help advertisers reach the type of audience they want to reach (e.g. new advisors from a certain region).
- Analytics providers, search engine providers who help us improve and optimise our site .
- Credit reference agencies for the purpose of assessing your credit profile when this is a condition of our entering into a contract with you.
- Providersoftechnical solutions, which allow us to send you our messages (including marketing messages or satisfaction surveys if you have authorised us to receive this type of information) e.g. providers of bulk email solutions, providers of bulk SMS solutions.
  Wemay also disclose your personal information to third parties:
- In the event that we sell, buy or otherwise transfer any business or assets. In this case, we may disclose your personal data to the future seller or buyer of such business or assets.
- If our company or substantially all of its assets are acquired by a third party, in which case the personal data held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligations, or in order to enforce or apply our policies and/or terms of use and/or other agreements in place; or in order to protect our rights, property or the safety of our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
  
  4 How and where we store your personal data
  
  The data we collect about you may be transferred to, and stored at , alocation outside the European Economic Area ("EEA"). Itmay even be processed by employees outside the EEA who work for us or for one of our suppliers. These employees may, among other things, be responsible for fulfilling your order, processing your payment details, processing your Success Plan entitlements and providing Customer Support services.
  
  We will take all necessary steps to ensure that your data is processed securely and in accordance with this Privacy Policy and current legislation.
  
  5 Duty of care
  
  When we give you (or whenever you choose) a password that gives you access to certain parts of our site (hereinafter referred to as "Account"), you are responsible for keeping this password confidential. We ask you not to share your password with anyone. If you share your password with other people, you will be responsible for all actions taken on behalf of your Account. If you lose control of your password, you may lose substantial control over your personal data and may be subject to binding actions taken on your behalf. Therefore, if your password is compromised for any reason, you must notify Oriflame immediately and change your password. We will never ask you for your password, except during the login process. Our employees are subject to additional requirements in the area of information protection.
  
  Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your data transmitted on our site; 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.
  
  6 Marketing Communications
  
  From time to time, we would like to send you information by email and/or SMS regarding our products and services that may be of interest to you (including, for example, newsletters and promotional communications).
  
  We will only do this if you have authorised us to do so. If you change your mind and do not want us to use your data in this way, please contact Customer Service at privacy@oriflame.com;
  
  7 Your rights
Marketing Communications. In addition to section 6, you have the right to contact us in order to process your personal data for marketing purposes.
Access to information, rectification and erasure. You have the right to access information about you (including your personal data), and to request its rectification or erasure, or to receive a copy of your personal data in a portable format. You can view, review and amend most of your personal data by logging into your Account. Alternatively, you can request it at privacy@oriflame.com. We will amend your personal data. In addition, at your request to privacy@oriflame.com, we will close your Account as soon as we are able to, in accordance with current legislation. We may need additional information in order to verify that you are in fact the account holder.
Retention. We keep your personal data for as long as necessary to manage our relationship with you. If you terminate your relationship with Oriflame, we will retain the personal data in order to fulfil legal obligations, prevent fraud, collect any amounts owed, resolve disputes, troubleshoot problems, assist in any investigations and generate business reports during the course of the relationship.We will retain your personal data to fulfil legal obligations, prevent fraud, collect any amounts owed, resolve disputes, solve problems, assist in any investigations and generate business reports for a reasonable period of time, after which we will take the necessary steps to delete, anonymise or securely archive your personal data.

8 Cookies

Our site uses cookies (small files located on the user's hard drive) in order to distinguish you from other users of our site. This helps us to provide you with a good experience when you browse our site, as well as allowing us to improve it. We use cookies to analyse the flow of information; personalise services, content and advertising; measure promotional effectiveness and promote trust and security.

We make some services available only through the use of cookies. In general, cookies perform up to four different functions:
Essential Cookies
Some cookies are essential for the system to function. For example, some cookies allow us to identify registered users and ensure that they have access to the entire system. If a registered user chooses to deactivate these cookies, the User may not be able to access all the content of the system.
Analytical Cookies
Other cookies may be used to analyse how users use the systems and to monitor system performance. This allows us to provide a quality experience by personalising offers and quickly identifying and resolving any issues. For example, analytical cookies may be used to monitor which pages are the most popular and to determine why certain pages are receiving error messages. These cookies may also be used to highlight products or services on the site that are of interest to users, based on their use of the System
Functionality Cookies
Functionality cookies are used to allow us to remember certain user preferences
Behavioural Cookies for Targeted Advertising

We may use cookies to provide Users with advertising relevant to them based on their interests. Oriflame may also use cookies from third parties for market research, revenue tracking, improving site functionality and monitoring compliance with these terms and conditions and copyright policy.

Users always have the freedom to decline cookies if their browser allows it. However, doing so may interfere with the use of the site. Please see detailed information on how to disable cookies here (http://www.allaboutcookies.org/manage-cookies/).

Further details on how companies use cookies can be found at here (http://www.allaboutcookies.org/).

9 Changes to our Privacy Policy

Any changes we may make to our Privacy Policy in the future will be posted on our website and, if necessary, you will be notified via email or otherwise. The changes will also be available on our premises. They will be active from the date of publication.

10 Contact and complaints

Questions, comments and requests regarding this Privacy Policy are welcome and should be directed to our Customer Service Department at the email address created specifically for this purpose: privacy@oriflame.com.

If you feel that we have not complied with this Privacy Policy, you can report the situation to the above address. Please describe in as much detail as possible why you believe this Privacy Policy has not been complied with. We will investigate your complaint promptly.

Publication date: 06-03-2018

TO COMPLY WITH EEE PRIVACY REGULATIONS, ORIFLAME PROVIDES ADDITIONAL INFORMATION TO ITS EEE PARTNERS

WHO IS RESPONSIBLE FOR YOUR DATA?

Oriflame Cosméticos LDA is the data controller with regard to your personal data. We can be contacted at: clientes@oriflame.com

Additionally, you can contact Oriflame's Data Protection Officer at privacy@oriflame.com.

The independent Brand Partner who managed your skin counselling is also the Data Controller.

MORE ABOUT THE PERSONAL DATA ORIFLAME COLLECTS, AND WHY

To fulfil our obligations arising from any contracts entered into between you and us in order to provide you with information, products and services you request from us, including resolving any disputes, collecting fees and resolving problems ;
1. What information do we collect?
  - Name
  - Mobile phone number
  - Email address
  - Address
  - Date of birth
  - Gender
  - Date of counselling
  - Photo
  - Skin concerns (based on the assessment carried out in the App) including ;
    1. Wrinkles
    2. Firmness
    3. Dark spots
    4. Dull skin
    5. Skin type/ethnicity
  - Your age
  - Your "skin age" (based on App assessment)
  - Your skin type category
  - Your age
  - Your "skin age" (based on the app's assessment)
  - The skin type category
  - Your age
  - Your "skin age" (based on the app's assessment)
  - The skin type category
  - Your age
  - Your "skin age" (based on the app's assessment)
  - The skin type category
  - Your age
  - Your "skin age" (based on the App's assessment)
  - Your skin type category
  - Your age
  - Your "skin age" (based on the app's assessment)
  - The skin type category
  - Your age
  - Your "skin age" (based on the app's assessment)
  - The skin type category
  - Your age
  - Your "skin age" (based on the App's assessment)
  - Your skin type category
  - Your age
  - Your "skin age" (based on the app's assessment)
  - The skin type category
  - Your age
  - Your "skin age" (based on the app's assessment)
  - The skin type category
  - Your age
  - Your "skin age" (based on the app's assessment)
  - The skin type category
  - Your age
  - Your "skin age" (based on the app's assessment)
  - The skin type category
  - Your age
  - Your "skin age" (based on the app's assessment)
  - The skin type category
2. What is the legal basis for collecting this information?
  - Oriflame processes information with your consent;
  - Oriflame processes your information where we need to do so to fulfil a contract with you (for example, the service contract);
  - Oriflame processes your information where we need to do so by law (for example, where we need to retain the information for reasons of potential litigation); or
  - Oriflame processes your information where it is in our legitimate interests and where those interests are not overridden by your data protection rights. For example, Oriflame has a legitimate interest in providing products or services you have requested.
3. What is the source of this information?
  - This information is provided to us by you when you carry out skin counselling with a brand partner.
4. What is the legal basis for collecting this information?
  - Oriflame processes your information where we need to do so in order to fulfil a contract with you (for example, the service contract);
5. What is the legal basis for collecting this information?
  - Oriflame processes your information where we need to do so by law (for example, where it is necessary to retain the information for reasons of potential litigation); or
6. What is the source of this information?
  - This information is provided to us by you when you carry out skin counselling with a brand partner.
7. What is the legal basis for collecting this information?
  - Oriflame processes your information where it is in our legitimate interests and where those interests are not overridden by your data protection rights. For example, Oriflame has a legitimate interest in ensuring compliance with specific policies and rules.
8. What is the source of this information?
  - This information is provided to us by you when you carry out skin counselling with a brand partner.
9. What is the legal basis for collecting this information?
  - Oriflame processes your information where it is in our legitimate interests and where those interests are not overridden by your data protection rights. For example, Oriflame has a legitimate interest in sending electronic marketing communications to brand partners.
10. What is the source of this information?
  - This information is provided to us by you when you carry out skin counselling with a brand partner.
11. What is the legal basis for collecting this information?
  - Oriflame processes your information where it is in our legitimate interests and where those interests are not overridden by your data protection rights. For example, Oriflame has a legitimate interest in informing advisors about changes to its services.
12. What is the source of this information?
  - This information is provided to us by you when you carry out skin counselling with a brand partner.
13. What is the legal basis for collecting this information?
  - Oriflame processes your information where it is in our legitimate interests and where those interests are not overridden by your data protection rights. For example, Oriflame has a legitimate interest in providing partners with relevant content on its website.
14. What is the source of this information?
  - This information is provided to us by you when you carry out skin counselling with a brand partner.
15. What is the legal basis for collecting this information?
  - Oriflame processes your information where it is in our legitimate interests and where those interests are not overridden by your data protection rights. For example, Oriflame has a legitimate interest in effectively managing its partner network.
16. What is the source of this information?
  - This information is provided to us by you when you carry out skin counselling with a brand partner.
17. What is the legal basis for collecting this information?
  - Oriflame processes your information where it is in our legitimate interests and where those interests are not overridden by your data protection rights. For example, Oriflame has a legitimate interest in administering its websites.
18. What is the source of this information?
  - This information is provided to us by you when you carry out skin counselling with a brand partner.
19. What is the legal basis for collecting this information?
  - Oriflame processes your information where it is in our legitimate interests and where those interests are not overridden by your data protection rights. For example, Oriflame has a legitimate interest in providing interactive features to advisors.
20. What is the source of this information?
  - This information is provided to us by you when you carry out skin counselling with a brand partner.
21. What is the legal basis for collecting this information?
  - Oriflame processes your information where it is in our legitimate interests and where those interests are not overridden by your data protection rights. For example, Oriflame has a legitimate interest in ensuring that its websites and all personal data collected and processed on those sites are secure.
22. What is the source of this information?
  - This information is provided to us by you when you carry out skin counselling with a brand partner.
23. What is the legal basis for collecting this information?
  - Oriflame processes your information where it is in our legitimate interests and where those interests are not overridden by your data protection rights. For example, Oriflame has a legitimate interest in measuring and understanding the effectiveness of the adverts it sends to partners.
24. What is the source of this information?
  - This information is provided to us by you when you carry out skin counselling with a brand partner.
25. What is the legal basis for collecting this information?
  - Oriflame processes your information where we need to do so by law (for example, where it is necessary to retain the information for reasons of potential litigation).
26. What is the source of this information?
  - This information is provided to us by you when you carry out skin counselling with a brand partner.
To ensure your rights and benefits, and other applicable conditions within the framework of this contractual relationship between both parties;
1. What information do we collect?
  - Name
  - Mobile phone number
  - Email address
  - Address
  - Date of birth
  - Date of counselling
  - Photo
  - Skin concerns (based on the assessment carried out in the App) including ;
    1. Wrinkles
    2. Firmness
    3. Dark spots
    4. Dull skin
In order to comply with other regulations applicable to our collaboration with you, such as tax legislation, social security legislation, statistical obligations, etc.
- What information do we collect? Name
- Mobile phone number
- Email address
- Address
- Date of birth
- Date of counselling
- Photo
- Skin concerns (based on the assessment carried out in the App) including ;
  1. Wrinkles
  2. Firmness
  3. Dark spots
  4. Dull skin
In order to monitor and ensure your compliance with our policies and rules;
1. What information do we collect?
  - Name
  - Mobile phone number
  - Email address
  - Address
  - Date of birth
  - Date of counselling
  - Photo
  - Skin concerns (based on the assessment carried out in the App) including ;
    1. Wrinkles
    2. Firmness
    3. Dark spots
    4. Dull skin
To provide you with information about goods or services that we think may be of interest to you. We will only contact you by electronic means (email or SMS) with information about goods and services similar to those you have previously purchased ;
1. What information do we collect?
  - Name
  - Mobile phone number
  - Email address
  - Address
  - Date of birth
  - Date of counselling
  - Photo
  - Skin concerns (based on the assessment carried out in the App) including ;
    1. Wrinkles
    2. Firmness
    3. Dark spots
    4. Dull skin
To notify you of changes to our services;
1. What information do we collect?
  - Name
  - Mobile phone number
  - Email address
  - Address
  - Date of birth
  - Date of counselling
  - Photo
  - Skin concerns (based on the assessment carried out in the App) including ;
    1. Wrinkles
    2. Firmness
    3. Dark spots
    4. Dull skin
To ensure that the contents of our App are presented in the most efficient way for you and your computer ;
1. What information do we collect?
  - Name
  - Mobile phone number
  - Email address
  - Address
  - Date of birth
  - Date of counselling
  - Photo
  - Skin concerns (based on the assessment carried out in the App) including ;
    1. Wrinkles
    2. Firmness
    3. Dark spots
    4. Dull skin
To ensure effective management of the partner network by Oriflame, as well as by other members of our advisor network (mainly your recruiter);
1. What information do we collect?
  - Name
  - Mobile phone number
  - Email address
  - Address
  - Date of birth
  - Date of counselling
  - Photo
  - Skin concerns (based on the assessment carried out in the App) including ;
    1. Wrinkles
    2. Firmness
    3. Dark spots
    4. Dull skin
To administer our website and for internal operations, including troubleshooting, data analysis, testing, studies, statistical and survey purposes;
1. What information do we collect?
  - Name
  - Mobile phone number
  - Email address
  - Address
  - Date of birth
  - Date of counselling
  - Photo
  - Skin concerns (based on the assessment carried out in the App) including ;
    1. Wrinkles
    2. Firmness
    3. Dark spots
    4. Dull skin
To allow you to use interactive features of our services, whenever you wish;
1. What information do we collect?
  - Name
  - Mobile phone number
  - Email address
  - Address
  - Date of birth
  - Date of counselling
  - Photo
  - Skin concerns (based on the assessment carried out in the App) including ;
    1. Wrinkles
    2. Firmness
    3. Dark spots
    4. Dull skin
To maintain the security of our site;
1. What information do we collect?
  - Name
  - Mobile phone number
  - Email address
  - Address
  - Date of birth
  - Date of counselling
  - Photo
  - Skin concerns (based on the assessment carried out in the App) including ;
    1. Wrinkles
    2. Firmness
    3. Dark spots
    4. Dull skin
To measure and understand the effectiveness of the adverts we direct to you and others, and to direct relevant adverts to you, which includes conducting satisfaction surveys and other similar studies;
1. What information do we collect?
  - Name
  - Mobile phone number
  - Email address
  - Address
  - Date of birth
  - Date of counselling
  - Photo
  - Skin concerns (based on the assessment carried out in the App) including ;
    1. Wrinkles
    2. Firmness
    3. Dark spots
    4. Dull skin
To respond to legal requests from regulators and other authorities;
1. What information do we collect?
  - Name
  - Mobile phone number
  - Email address
  - Address
  - Date of birth
  - Date of counselling
  - Photo
  - Skin concerns (based on the assessment carried out in the App) including ;
    1. Wrinkles
    2. Firmness
    3. Dark spots
    4. Dull skin

What is the source of this information?
- This information is provided to us by you when you carry out skin counselling with a brand partner.

MORE INFORMATION ABOUT YOUR CHOICES REGARDING THE USE OF YOUR PERSONAL DATA BY ORIFLAME

You have the right to access, rectify, block, complete and erase your personal data, and restrict its use. You also have the right to request further information about the processing of your personal data; and
In certain circumstances, you also have the right to object to the processing of your personal data by Oriflame.

You can exercise the above rights by contacting us via the contact details provided above whenever you need to. All requests will be dealt with as quickly as possible.

There are exceptions to these rights; for example, access may be refused if this means disclosing someone else's personal data or if, by law, we cannot disclose this information.

You also have the right to make a complaint to the data protection supervisory authority or seek a resolution through the courts if you believe your rights have been violated.

When we ask you to provide us with information, we will be clear about whether the information we request is necessary to provide you with products and services, or whether providing this information is optional.

MORE INFORMATION ABOUT THE TRANSFER OF YOUR PERSONAL DATA BY ORIFLAME OUTSIDE THE EEA

The personal data we collect about you may be stored on servers located in countries outside the EEA, including countries with different data protection criteria to those applied in the EEA, for example the United States.

We implement contractual clauses approved by the European Commission to protect this data. A copy of these clauses is available to read, just ask us at the contact details provided above.

MORE INFORMATION ABOUT ORIFLAME'S RETENTION OF YOUR PERSONAL DATA

Read terms and conditions

MORE INFORMATION ABOUT THE PERSONS/ENTITIES WITH WHOM ORIFLAME SHARES YOUR PERSONAL DATA

We share your personal data with affiliates and subsidiaries of the Oriflame Oriflame Group of companies, most of which are listed in the notes to our most recent annual report published at http://investors.oriflame.com/investors/reports-and-presentations/annual-reports.
; e
Like many companies, Oriflame contracts with other companies to perform certain business-related functions, such as carriers, credit control agencies, banks, factoring service providers, logistics service providers (such as picking and packing), customer service providers, and other service providers. When we do this, we may share information that they need for certain functions. Oriflame's suppliers who have access to your personal data are obliged to keep the data confidential, maintain appropriate security measures and are not authorised to use the data for any purpose other than to provide the services contracted by Oriflame.

2 Uses of information

3 Disclosure of your information

4 How and where we store your personal data

5 Duty of care

6 Marketing Communications

7 Your rights

8 Cookies

9 Changes to our Privacy Policy

10 Contact and complaints

TO COMPLY WITH EEE PRIVACY REGULATIONS, ORIFLAME PROVIDES ADDITIONAL INFORMATION TO ITS EEE PARTNERS

The personal data we collect about you may be stored on servers located in countries outside the EEA, including countries with different data protection criteria to those applied in the EEA, for example the United States.

We implement contractual clauses approved by the European Commission to protect this data. A copy of these clauses is available to read, just ask us at the contact details provided above.