Security and Privacy Statement
Avon Cosmetics, Inc., a company incorporated under the laws of the Philippines (referred to herein as "AVON," "we," "us" and "our"), understands the importance of the privacy of individuals (referred to as "users" and "you") who visit and interact with our websites. This Security and Privacy Statement (the "Statement") outlines the information AVON collects through this website (the "AVON WEBSITE"), and how AVON will use and disclose that information. This Statement represents the sole, authorized statement of AVON's practices with respect to the collection of information through the AVON WEBSITE and AVON's use of such information. By using the AVON WEBSITE, you agree to this Statement. If you do not agree to this Statement, please do not use the AVON WEBSITE.
This Statement applies solely to AVON's collection of information through the AVON WEBSITE and AVON's use and disclosure of such information. This Statement does not apply to any of the following:
- AVON's collection of information through any website other than the AVON WEBSITE, or the use or disclosure of any information so collected;
- AVON's collection of information offline, for example, by telephone or direct mail, or the use or disclosure of any information so collected;
- or the collection, use or disclosure of information by any of our subsidiaries or affiliated entities or any third party.
AVON controls and operates the AVON WEBSITE from its office Makati City, Philippines and the AVON WEBSITE is not intended to subject AVON to the laws or jurisdiction of any state, country or territory other than those of the Philippines. AVON makes no representation or warranty that this AVON WEBSITE, in whole or in part, is appropriate or available for use in other locations. Those who choose to access the AVON WEBSITES from other locations do so on their own initiative and at their own risk and are responsible for compliance with local laws, rules and regulations, if and to the extent local laws, rules or regulations are applicable.
CHANGES TO THIS STATEMENT:
Because our business changes continually, we reserve the right to change this Statement without prior notice. You can determine when this Statement was last revised by referring to the "LAST UPDATED" legend at the top of this page. Any changes to this Statement will become effective upon posting of the revised Statement on the AVON WEBSITE. Your continued use of the AVON WEBSITE following the posting of changes to our Statement will signify your acceptance of those changes.
THE INFORMATION WE COLLECT
We collect two basic types of information through the AVON WEBSITE: Personally Identifiable Information, Non-Personally Identifiable Information. "Personally Identifiable Information"
) is information that identifies you as an individual -- for example, your name, address, telephone number, mobile number email address, credit card information, billing address, shipping information and any government issued personal identification number. "Non-Personally Identifiable Information"
) is aggregated information, demographic information IP addresses and any other information that does not reveal your specific identity.
- PERSONALLY IDENTIFIABLE INFORMATION (PII):
You do not have to provide PII to access the AVON WEBSITE. However, in order for you to take advantage of particular opportunities provided through the AVON WEBSITE (for example, to register for an account with Avon, to make a purchase through the website, to make payment to your Avon account through the Avon website, to sign up to receive AVON email newsletters), we may require that you furnish us with PII through the AVON WEBSITE. AVON will collect PII from you through the AVON WEBSITE only when you provide it to us voluntarily. By submitting PII to AVON, you consent to the collection, use, processing and disclosure of PII as set forth in this Statement.
- NON-PERSONALLY IDENTIFIABLE INFORMATION (NON-PII). When you visit and interact with the AVON WEBSITE, we and our third party and affiliated service providers who provide certain services (including without limitation website hosting, data analysis, newsletter services, order fulfillment, and other services of an administrative nature) (such third party and affiliated service providers, our "Service Providers") may collect Non-PII (for example, a list of the AVON WEBSITE pages you visit). Non-PII is generally collected from four different sources: environmental variables, cookies, pixel tags, and information that you voluntarily provide.
- SERVER LOG FILES. Your Internet Protocol (IP) address is an identifying number that is automatically assigned to your computer by your Internet Service Provider (ISP). This number is identified and logged automatically in our and/or our Service Providers' server log files whenever you visit the AVON WEBSITE, along with the time(s) of your visit(s) and the page(s) that you visited. We use your IP address, and the IP addresses of all users, to calculate usage levels on the AVON WEBSITES, to help diagnose problems with the AVON WEBSITES' servers, and to administer the AVON WEBSITES. We also reserve the right to use IP addresses to communicate with users and, if necessary, to block access by users who fail to comply with our Terms and Conditions of Use located at Terms and Conditions or other policies. Collecting IP addresses is standard practice on the Internet and IP addresses are collected automatically by many websites.
- PIXEL TAGS. We and our Service Providers may also use so-called "pixel tags," "web beacons," "clear GIFs" or similar means (collectively, "Pixel Tags") in connection with some AVON WEBSITE pages and HTML-formatted email messages to, among other things, compile aggregate statistics about website usage and response rates. A Pixel Tag is an electronic image, often a single pixel (1x1), that is ordinarily not visible to website visitors and may be associated with cookies on 'visitors' hard drives. Pixel Tags allow us and our Service Providers to count users who have visited certain pages of the AVON WEBSITE, to deliver customized services, and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted email messages, Pixel Tags can tell the sender whether and when the email has been opened.
- OTHER NON-PERSONALLY IDENTIFIABLE INFORMATION THAT YOU VOLUNTARILY PROVIDE. We also collect certain Non-PII -- for example, your geographic location -- when you voluntarily provide such information to us. Additionally, we may aggregate PII in a manner such that the end-product does not personally identify you or any other user of the AVON WEBSITE, for example, by using PII to calculate the percentage of our users who have a particular zip code or telephone area code. Such aggregate information is deemed to be Non-PII for purposes of this Statement.
HOW DO WE USE THE PII WE COLLECT
Please note that AVON will share your information with Avon Products, Inc. which will jointly use such PII you provide through the Site. We may use the PII we collect in the following ways:
- RESPONDING TO YOUR INQUIRIES AND FULFILLING YOUR REQUESTS. We may use your PII to respond to your inquiries to AVON and to fulfill your requests -- for example, to send you newsletters that you request when you sign up to join our mailing lists, to send you updates about AVON news and events, to send you information on or contact you about becoming an independent sales representative (an "AVON Independent Sales Representative") or to provide PII about you to AVON Independent Sales Representatives when you provide it to us for that purpose.
- COMMUNICATING WITH YOU ABOUT PRODUCTS AND SERVICES. Subject to your right to opt out (see “OPTING OUT OF CERTAIN AVON COMMUNICATIONS” below), we may use your PII to send you information about specials, new products and services, and other items that may be of interest to you.
- PERSONALIZING YOUR AVON WEBSITE EXPERIENCE. We may use your PII to personalize your experience on the AVON WEBSITE, for example, by presenting products and offers to you through the AVON WEBSITE that we believe may be of interest to you.
- SENDING ADMINISTRATIVE COMMUNICATIONS. From time to time, at our sole discretion, we may use your PII (a) to confirm your registration with the AVON WEBSITE (b) to confirm a transaction through the AVON WEBSITE, (c) to inform you that we have received your PII, (d) to provide you with information regarding the AVON WEBSITE or (e) to inform you of changes to this Statement, our Terms and Conditions of Use, or our other terms, conditions, or policies ("Administrative Emails/Messages"). Because this information may be critical to your use of the AVON WEBSITE, you may not opt out of receiving Administrative Emails/Messages.
- INTERNAL BUSINESS PURPOSES. We may use PII about you for internal business purposes, such as data analysis, audits, developing new products, enhancing our website, improving our services, identifying usage trends and determining the effectiveness of our promotional campaigns.
HOW IS THE PII WE COLLECT DISCLOSED
We may disclose the PII we collect in the following ways:
- DISCLOSURE TO AFFILIATES. As a global company, Avon may share PII about you with its global affiliated entities for the purposes outlined in this Statement. A list of such global affiliated entities can be found in http://www.avoncompany.com/aboutavon/avonmarkets.html.
- DISCLOSURE TO THIRD PARTIES FOR DIRECT MARKETING PURPOSES. We may disclose PII about you to third parties for their direct marketing purposes when you affirmatively consent to such disclosure. For example:
- Disclosing PII about You to AVON Independent Sales Representatives: If you wish to order products through an AVON Independent Sales Representative or to otherwise have an AVON Independent Sales Representative work with you to facilitate your AVON experience, AVON needs to provide your PII to such AVON Independent Sales Representative. Therefore, if you opt in to having an AVON Independent Sales Representative work with you to facilitate your AVON experience or to having your PII shared with an AVON Independent Sales Representative, we may disclose your PII to such AVON Independent Sales Representative. Such AVON Independent Sales Representatives may use your PII for direct marketing purposes. WE DO NOT CONTROL, AND ARE NOT RESPONSIBLE OR LIABLE FOR, THE USE OF PII ABOUT YOU BY SUCH AVON INDEPENDENT SALES REPRESENTATIVES.
- Facilitating Special Offers from Third Parties: From time to time, we may give you the opportunity to opt in to participate in special third party offers that require us to share certain PII with such third parties. We will disclose this anticipated sharing of PII at the time we make such opportunities available to you. If you opt in to participate in such an offer, we may disclose PII about you to such third parties for their direct marketing purposes. We recommend that you consult such third parties' privacy policies in advance if you wish to participate in these offers.
- DISCLOSING AVON INDEPENDENT SALES REPRESENTATIVE INFORMATION. If you are an AVON Independent Sales Representative, we may disclose certain PII (for example, your name, email address, telephone number and other contact information) and other information to current and potential AVON customers who are seeking the assistance of an AVON Independent Sales Representative, to customers who are or who become attached to you, and to other AVON Independent Sales Representatives (for example, if you are a "downline" AVON Independent Sales representative, we may make your PII and other information about you available to your Leadership Representative).
- FACILITATING SWEEPSTAKES, CONTESTS AND SIMILAR PROMOTIONS. We may, whether alone or in cooperation with third party sponsors, operate sweepstakes, contests and similar promotions ("Promotions") through or in connection with the AVON WEBSITE. We typically ask you for certain PII when you enter or otherwise participate in a Promotion, and, if applicable, when you win a Promotion. We reserve the right to share this PII with affiliated and third party sponsors of such Promotions ("Sponsors"), or otherwise in accordance with the rules applicable to the Promotion. You should carefully review the rules of each Promotion in which you participate through the AVON WEBSITE, as they may contain important additional information about our or Sponsors' use of your PII. To the extent that the terms and conditions of such rules concerning the treatment of your PII conflict with this Statement, the terms and conditions of such rules shall control.
- FACILITATING "EMAIL A FRIEND" FUNCTIONALITY. If you wish to use the AVON WEBSITE's functionality to send a friend a link to an AVON WEBSITE page (e.g., by utilizing the "Send an ECard" functionality), you must provide us with your name and email address, as well as your friend's name and email address, so that we may facilitate your sending of such link. Your name and your email address will be disclosed to your friend in such email.
- BUSINESS TRANSFERS. We reserve the right to transfer any and all PII and Non-PII that we collect from users of the AVON WEBSITES to a third party in the event of any merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of AVON's assets or stock (including without limitation in connection with any bankruptcy or similar proceedings).
- CROSS BORDER TRANSFERS. To help us perform more effectively and efficiently in the future, we may need to transfer PII about you to affiliates and Service Providers located in other countries, including the United States. By using the AVON WEBSITE, you agree to such transfers of PII about you.
- OTHER DISCLOSURES. Finally, notwithstanding any other provision of this Statement or the Terms and Conditions of Use to the contrary, we reserve the right to disclose and use your PII if we believe that we are required to do so: (a) by law; (b) in response to legal process, for example, in response to a court order or a subpoena; (c) in response to a law enforcement agency's request; (d) to enforce the Terms and Conditions of Use or our other terms, conditions, or policies; (e) to protect our operations; (f) to protect the rights, privacy, safety or property of AVON, you or others; and/or (g) to permit us to pursue available remedies or limit the damages that we may sustain. For example, we may, to the fullest extent the law allows, disclose PII about you to law enforcement agencies to assist them in identifying individuals who have been or may be engaged in unlawful activities.
HOW DO WE USE AND DISCLOSE THE NON-PII WE COLLECT:
Because Non-PII does not personally identify you, we reserve the right to use Non-PII, and to disclose Non-PII to third parties, for any purpose.
HOW DO WE USE AND DISCLOSE THE IP ADDRESSES WE COLLECT:
We use IP Addresses for purposes such as calculating usage levels on the AVON WEBSITE, helping diagnose server problems, and administering the AVON WEBSITE. We may use IP Addresses to communicate with users and, if necessary, to block access by users who fail to comply with our Terms and Conditions of Use located at the bottom of home page of the AVON WEBSITE (the "Terms and Conditions of Use") or other policies. We may also use and disclose IP Addresses in accordance with Sections 4 and 5 above. Please note that we treat IP Addresses, server log files and related information as Non-PII, except where we are required to do otherwise under applicable law.
COLLECTION, USE AND DISCLOSURE OF INFORMATION BY THIRD PARTIES
NOTE THAT THIS STATEMENT DOES NOT ADDRESS THE PRIVACY PRACTICES OR POLICIES OF THIRD PARTIES, INCLUDING AVON INDEPENDENT SALES REPRESENTATIVES. Without limiting the foregoing:
- AVON INDEPENDENT SALES REPRESENTATIVES: This Statement does not apply to the collection, use or disclosure of information by AVON Independent Sales Representatives, who are independent third party contractors of AVON and are not otherwise affiliated with AVON. For example, this Statement does not apply to:
- the use or disclosure by AVON Independent Sales Representatives of information AVON provides them to enable them to fulfill your orders;
- the use or disclosure of information collected, stored or processed by AVON Independent Sales Representatives through the AVON WEBSITE; or
- any communication between you and an AVON Independent Sales Representative, either directly (for example, through your personal email) or through or in connection with an AVON WEBSITE (for example, through a "mailto:" email link that launches an external email application, or through a "Contact Me" link that takes you to an Avon Independent Sales Representative’s personalized online store that would take you to an online contact form), or the use or disclosure of any information exchanged through such communication. Although we seek to ensure that AVON Independent Sales Representatives honor customers' and contacts' opt-out requests, treat customer information confidentially and act in accordance with applicable law, we are not responsible or liable for the statements, acts or omissions of AVON Independent Sales Representatives.
- OPERATORS OF THIRD PARTY SITES AND SERVICES. The AVON WEBSITE may contain links to websites operated by third parties, or may embed services operated by third parties ("Third Party Sites/Services"), and those third parties may have privacy practices that are different from ours. If you provide information through any Third Party Site/Service, such information will be collected by, and may be used and disclosed by such third parties, in accordance with the privacy practices and policies of such third parties. AVON WEBSITE users should consult such third parties' privacy policies when using Third Party Sites/Services, as we have no control over the use or disclosure of information by third parties.
We are aware of concerns regarding the privacy and confidentiality of PII. We have put in place certain physical, electronic and managerial procedures to help us safeguard against unauthorized access to PII and to help maintain data security. For example, we use an encryption technology called Secure Sockets Layer (SSL) to help protect the transmission of certain information to and from the AVON WEBSITE. Unfortunately, no data transmission over the Internet or data storage solution will be 100% secure. As a result, although we take steps to protect your PII, we cannot ensure or warrant the security of any information you transmit to or receive from us or that we store on our or our Service Providers' systems.
You are ultimately responsible for maintaining the secrecy of your user name, passwords and/or any account information. You are not permitted by AVON to, and we recommend that you do not, disclose your username and password to any other person.
If you have reason to believe that your interaction with an AVON WEBSITE is no longer secure, you must immediately notify us of the problem by contacting us in accordance with the section entitled "CONTACTING US," below. (Note that contacting us by physical mail will delay the time it takes for us to respond to your communication.)
If you no longer wish to receive marketing-related e-mails from AVON on a going-forward basis, you may opt-out of receiving such marketing-related e-mails in a going-forward basis by contacting us at email@example.com
. We will endeavor to comply with your request as soon as reasonably practicable. You may also (i) opt out of receiving other kinds of marketing-related messages from AVON (e.g., by telephone or post) on a going-forward basis or (ii) request that we no longer use or disclose the information that we collect from you through the AVON WEBSITE, by contacting us at Gercon Plaza, 7901 Makati Avenue, Makati City, Philippines.
Please note that if you opt-out as described above, we will not be able to remove your PII from the databases and other records of Avon Independent Sales Representatives, AVON affiliates and other third parties with which we have already shared your PII pursuant to this Statement. If you wish to cease receiving marketing messages from such Avon Independent Sales Representative, affiliate or third party, please contact such AVONIndependent Sales Representative, affiliate or third party, directly.
CHANGING OR REMOVING YOUR PII:
We provide you with several options for reviewing, correcting, updating or otherwise modifying PII that you have previously provided to AVON through the AVON WEBSITE. You can request to review, correct, update or suppress PII about you by contacting us as set forth below: Gercon Plaza, 7901 Makati Avenue, Makati City, Philippines.
We will endeavor to comply with your requests to change, modify or suppress PII about you as soon as reasonably practicable. However, we may need to retain certain information for recordkeeping purposes, and there may also be residual information that will remain within our databases and other records, which will not be removed or changed. We also reserve the right, from time to time, to re-contact former AVON WEBSITE visitors and users, including AVON Independent Sales Representatives who were formerly AVON eRepresentatives. Finally, we are not responsible for removing information or causing information to be removed from the databases or other records of third parties (including Sponsors, Service Providers and AVON Independent Sales Representatives) with whom we have already shared your PII.
The AVON WEBSITE is not directed to minors, i.e., individuals under 18 years of age and we request that such individuals not provide personally identifiable information, or PII, through the AVON WEBSITE.
AVON does not represent or warrant that the AVON WEBSITE, or any part thereof, is appropriate or available for use in any particular jurisdiction. Those who choose to access the AVON WEBSITE do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations. We may limit the AVON WEBSITE's availability, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion.
If you have any questions regarding this Statement, please contact us either by email at firstname.lastname@example.org
, or by regular mail at Gercon Plaza, 7901 Makati Avenue, Makati City, Philippines.
Please note that email communications are not necessarily secure. Accordingly, you should not include credit card information or other sensitive information in your email correspondence with us.
AVON PHILIPPINES WEBSITE © 2009-2010 Avon Cosmetics, Inc. All rights reserved.