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(Last revised on: 1 August 2014)
Contact us at firstname.lastname@example.org
Arbonne Europe Sàrl and its affiliates (collectively, “Arbonne”) appreciates the importance of protecting your personal information and recognises your trust in Arbonne when you supply personal information to Arbonne.
1. Collection and Use of Information
Arbonne may collect “Personal Information” about you to the extent necessary for one or more of the following reasons:
1.1 the information is required in connection with your use of this website;
1.2 the information is required to provide you with goods and services you requested from Arbonne (including, for example, information required in fulfilling and sending orders for goods and services or information required in connection with billing by Arbonne for those goods and services);
1.3 the information is required to improve goods and services Arbonne offers and in order to market, advertise or otherwise communicate to you the goods and services provided by Arbonne;
1.4 the information is required by Arbonne to assess and access the market for Arbonne's goods and services;
1.5 the information is required to provide security for your use of Arbonne's website; and
1.6 the information is required to comply with taxation, and any other legislative requirements imposed on Arbonne and/or is required in connection with any legal proceeding involving Arbonne whether in relation to you or otherwise.
"Personal Information" means information or an opinion (including information or an opinion forming part of a database), whether true or not, about an individual whose identity is apparent, or can be reasonably ascertained, from the information or opinion. By way of example only, Arbonne may collect your name, address, telephone number, facsimile number, email address, age, date of birth, driver's licence details, credit card information, etc.
2. How Arbonne collects Personal Information from you
Arbonne may collect Personal Information from you in a number of ways including (without limitation): when you contact Arbonne, when you transact business with Arbonne, from Independent Consultants, questionnaires and surveys, over the telephone, person to person, when you purchase Arbonne products or services and from a contract you enter into with Arbonne.
Arbonne may collect de-identified information through your use of Arbonne’s website, including the dates and times you access this website, the domains from which you visited this website, your activity on the website and Internet Protocol addresses. This information is sometimes referred to as “click stream data”, and Arbonne may use this data to analyse trends and statistics in order to improve the service provided through this website.
Arbonne may collect this information through the use of technologies, including “cookies”. A “cookie” is a text file sent by this website to your browser and stored on your computer as an anonymous tag that identifies your computer, but not you, to Arbonne. Please note you can set your browser to disable cookies, but some parts of this website may not function properly or at all if cookies are disabled.
Independent Consultants consent to the collection of personal information in accordance with the terms of the Arbonne Independent Consultant Application and Agreement executed by them when registering with Arbonne. Preferred Clients consent to the collection of personal information in accordance with the Terms and Conditions of the Preferred Client Program executed by them when registering with Arbonne.
3. Effect of non-provision of Personal Information; anonymity
From time to time, you may be able to deal with us anonymously or by pseudonym. However, if the Personal Information Arbonne requests for the provision of goods or services is not provided to Arbonne, or you provide information anonymously, Arbonne may not be able to provide the goods or services to you. As noted above, if you change your browser settings to disable cookies, some parts of Arbonne’s website may not function properly, which may adversely affect Arbonne’s ability to provide your requested goods or services to you.
4. Arbonne's use and disclosure of your Personal Information
By accessing and/or using Arbonne’s website, you are deemed to consent to Arbonne using your Personal Information collected by Arbonne for the following purposes:
4.1 communicating with any necessary party in order to effect an agreement, or in connection with an agreement, entered into by you with Arbonne. Arbonne products are sold through our network of Independent Consultants, including online shopping that is fulfilled directly by Arbonne in connection with an Arbonne Independent Consultant. If you are purchasing goods or services from Arbonne, we will automatically route your personal and purchasing information to an Arbonne Independent Consultant;
4.2 the processing of invoices, bills, and related financial matters necessary for Arbonne's provision of goods and services, including, but without limitation, the disclosure of information to credit agencies and/or service providers;
4.3 notifying you about Arbonne's new or existing products and services;
4.4 market research in relation to Arbonne's products and services;
4.5 the distribution to you (or any organisation, company, or group you represent) educational material and general information relating to Arbonne or its approved partners;
4.6 monitoring use of Arbonne's website.
4.7 the conduct of Arbonne’s internal business functions, for example (but not limited to) Arbonne’s internal accounting or business management purposes;
4.8 for any other purpose which you would reasonably expect the information to be used; and
4.9 as otherwise required by law or in order to comply with Arbonne’s regulatory obligations.
4.10 our third party service and content providers or third party suppliers, for example our website operators and payment processors or third parties that provide us with fulfilment tools and services;
4.11 third party vendors who may require your personal information for the purposes of conference and event registration that you may attend or for your registration in promotional offers and competitions;
4.12 if you are an Arbonne Independent Consultant, to your sponsoring Independent Consultant, your downline or upline, for the purposes of promoting business efficiency.
4.13 if you are an Arbonne Preferred Client or Client, to your Independent Consultant and his or her upline for the purposes of promoting business efficiency, providing you with the products and/or services you requested, and providing you with information about promotional or other special items offered by Arbonne that may be of interest to you.
5. Marketing and Promotional Materials
From time to time, we may send our Independent Consultants and customers marketing materials such as newsletters, company information and updates or promotional offers about our products and services. Our Independent Consultants will automatically receive electronic communications.
If you do not wish to receive any communications about our latest products and services, company information and updates, or promotional activities such as competitions, surveys, conferences or other promotional events, you can opt out by:
5.1 sending an email to email@example.com with your full name and the word “UNSUBSCRIBE” in the subject line; or
5.2 changing your preferences by logging into your Arbonne account and changing your personal settings.
6. Cross-Border Data Flow and Disclosure
To the extent Arbonne collects Personal Information from you in Australia and such Personal Information is disclosed to any affiliated entity that directly, or indirectly, controls, or is controlled by, or is under common control with, Arbonne or an independent third party located in the United States, Arbonne reasonably believes that the entity receiving the Personal Information is subject to a law, binding scheme or contract which effectively upholds principles for the fair handling of information that are substantially similar to the APPs.
Further, Arbonne has taken, wherever possible, reasonable steps to ensure that the Personal Information which it has disclosed will not be held, used or further disclosed by the recipient of the Personal Information inconsistently with the APPs. Arbonne may also make such a disclosure of Personal Information when it is necessary for the performance of a contract between you and Arbonne or for the conclusion or performance of a contract between Arbonne and a third party in your benefit.
By your continued use of this website and by continuing to transact business with Arbonne, you acknowledge that Arbonne may disclose Personal Information in the manner set out in this clause 6.
7. Data security
Arbonne takes reasonable steps to protect the Personal Information Arbonne has under its control against accidental or intentional manipulation, loss, destruction, or against access by unauthorised persons. For example, Personal Information is encrypted during transmission and at rest. Nevertheless, Arbonne is not responsible for harm that you or any person may suffer as a result of breach or requirements under the Privacy Act to maintain the security of your Personal Information in respect of your use of this site or any information you transmit to this site. By using this website, you acknowledge and accept this risk.
8. Third-Party Links and Websites
This website may contain links to websites owned and maintained by independent third parties. Arbonne takes no responsibility for the privacy practices or the content of any websites linked to this website.
9. Amendments and Updates to Policy
Your continued access to and use of this website (including the purchase of goods and/or services) indicates your agreement to the amendments. If you object to such changes, Arbonne will comply with our prior policies as to any data previously collected, but please do not access or use the website.
10. Access, Correction and Further Information
Arbonne takes all reasonable steps to ensure that the Personal Information Arbonne collects is accurate, complete and up to date.
However, Arbonne relies upon the accuracy and completeness of the Personal Information you supply. Accordingly, if you identify any inaccuracy in your Personal Information, you need to make a change or wish to verify such information, please contact Arbonne with a request to access your Personal Information with sufficient information to enable Arbonne to verify your identity.
Arbonne will provide you with access to your Personal Information unless Arbonne is permitted under the Privacy Act or other applicable privacy legislation to refuse to provide you access. If an exception under law applies, we will provide you with the reasons for our refusal unless it is unreasonable to do so. Arbonne reserves the right to charge an administrative fee to cover its reasonable costs for responding to and carrying out your request for access to your Personal Information. Please direct all requests to Arbonne's privacy officer, the details of whom are listed below. We will endeavour to respond to your request for access or correction of your Personal Information within a reasonable period after your request is made.
11. Complaints about privacy
If, after receiving our response, you still consider your privacy complaint remains unresolved, you may then, for example take your complaint to the Office of the Australian Information Commissioner.
Arbonne does not adopt or use any identifiers of any Australian government body or agency assigned to any individual as its own identifier.
13. Contacting Arbonne
Arbonne's privacy officer may be contacted:
(a) by completing the online form at arbonneinternational.com; or
(b) by mail, marked:
Attention of the Compliance Department
Arbonne Europe Sàrl
c/o Arbonne Australia Pty Ltd.
1 Wonderland Drive,
Eastern Creek NSW 2766;
Att: Privacy Officer/Chief Security Officer;
(c) by sending an email to firstname.lastname@example.org.
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