Table of Contents
1. Introduction; Scope
The Avon Company Canada Limited and its affiliates (“Avon”, "us," or "we") have created this Privacy Statement to inform you about how we collect, use and disclose Personal Information.
This Privacy Statement applies to Personal Information collected through this website and any mobile sites, applications, widgets, and other interactive features that link to this Privacy Statement (collectively, the "Site"). Except as specifically provided below, this Privacy Statement does not apply to Personal Information collected by Avon by or through any other means, such as information collected offline.
Avon grants independent contractors selling rights to its products (hereinafter referred to as “Independent Sales Representatives”). Independent Sales Representatives are not employed by Avon. Therefore, Avon does not control, and is not responsible or liable for the collection, use or disclosure of Personal Information by Independent Sales Representatives, including for their marketing purposes. If you provide information to an Independent Sales Representative through the Site, Avon will have access to it and shall treat it in accordance with this Privacy Statement. Independent Sales Representatives may provide Avon with information regarding their customers, in which case Avon will treat such information, once in its possession, in accordance with this Privacy Statement. If you are the customer of an Independent Sales Representative, you should check with your Representative directly to learn about her data privacy practices.
If you apply to become or are an Independent Sales Representative, in addition to the generally applicable provisions of this Privacy Statement, please review the Independent Sales Representative section at the bottom of this Privacy Statement to see important information about additional privacy practices that apply to you.
By using the Site, you agree to our Terms of Use and to our collection, use and disclosure practices, and other activities as described in this Privacy Statement. If you do not agree and consent, please discontinue use of the Site. If you reside outside of Canada, the collection, use, and/or disclosure of your Personal Information may be governed by another Avon privacy statement that applies to that jurisdiction.
2. Collection of Personal Information You Provide
We collect Personal Information from you when you choose to participate in our offers and programs or otherwise provide Personal Information directly to us, including when you register with us, purchase products, participate in our interactive features or otherwise communicate or interact with us on the Site.
"Personal information" is information that, alone or in combination with other information, can personally identify you, such as your name, postal address (including billing and shipping addresses), telephone number, email address, credit card number, and user name. We may also collect demographic information, such as your location, education, profession, age, gender, as well as other information, such as your hobbies and special interests. You may choose to voluntarily submit certain other information to us through the Site, including Personal Information, but you are solely responsible for the decision to share your Personal Information in instances where we have not requested it. Personal Information once “de-identified” is not subject to this Privacy Statement and we may treat it as non-Personal Information and use and disclose it for any purpose and without obligation to you except as prohibited by applicable law.
Information Collected Automatically
We may automatically collect certain information about you when you access or use the Site (“Usage Information”), which may be stored in log files. Usage Information includes, without limitation:
Browser information, including browser type and version;
Device identifiers;
Device type (e.g., Windows or Macintosh);
Screen resolution;
Referring/exit pages;
Date/time stamps;
Operating system version; and
Data regarding network connected hardware.
Usage information also includes IP address. Your "IP Address" is a number that is automatically assigned to the device that you are using by your Internet Service Provider (ISP). An IP Address may be identified and logged automatically in our server log files whenever a user visits the Site, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many websites. We may use IP Addresses for purposes such as calculating Site usage levels, helping diagnose server problems, detecting fraud, and administering the Site. We may also use and disclose IP Addresses for any other purpose as permitted by this Privacy Statement. To the extent that we combine Usage Information with your Personal Information, we will treat the combined information as Personal Information under this Privacy Statement.
Cookies, pixel tags and other tracking technologies now and hereafter developed (“Tracking Technologies”) may be used to collect Usage Information. Some Tracking Technologies are discussed below:
Cookies We and our third-party service providers may use "cookies" on the Site. Cookies, which are small text files stored on your device, allow a web server to transfer data to a device for recordkeeping and other purposes. We use cookies and other technologies to, among other things, better serve you with more tailored information and facilitate your ongoing access to and use of the Site. We may also allow certain third-party service providers to use cookies on the Site. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to delete or block cookies. Browsers offer different functionalities and options so you may need to set them separately. To learn more about cookies, please visit the following site, which is not affiliated with Avon: http://www.allaboutcookies.org/.
Local Storage Objects. We and our third-party service providers may use Flash Local Storage Objects ("Flash LSOs") in certain situations including to recognize you and remember what is in your shopping cart. Flash LSOs are different from browser cookies because of the amount and type of data stored. In addition, you generally cannot control, delete or disable the acceptance of Flash LSOs from your browser. For more information on Flash LSOs, and to learn how to control them, click on the support Page for the Flash Player and choose Global Storage Settings Panel and follow the instructions. To see the Flash LSOs on your device now, go to the Website Storage Settings Panel and follow the instructions to review and, if you choose, to delete any specific Flash LSO.
Pixel tags. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. However, in contrast to cookies, which are stored on your device's hard drive, clear GIFs are embedded invisibly on website pages. We may use clear GIFs (also known as web beacons, web bugs or pixel tags) in connection with the Site to, among other things, track the activities of our Site visitors and compile statistics about Site usage and response rates. We and our third-party service providers also may use clear GIFs in HTML-formatted email messages to help us track email response rates, measure the success of our marketing campaigns, and identify when our emails are viewed or forwarded.
Widgets and similar technologies. If you choose to utilize a widget or similar technology on the Site, such technology may collect information about you. Any Personal Information or other information you make available through such technology may become available publicly, for example, through social media and other websites and platforms on which the applicable technology is also available. In addition, some technology may have the capability to be distributed "virally" in other locations (for example, a friend or a customer of yours may post the widget that contains your information to his or her blog). Avon is not responsible or liable for the collection, use or disclosure of Personal Information and/or other information that is made publicly available.
Location-identifying technologies. GPS (global positioning systems) software, geo-filtering, and other location-aware technologies locate (sometimes precisely) you for purposes such as verifying your location and delivering or restricting relevant content based on your location. We may use geo-location codes that are based on the address you provide us. You may be able to exercise specific privacy choices, such as enabling or disabling certain location-based services, by adjusting the permissions in your mobile device.
Device fingerprinting. Device fingerprinting is the process of analyzing and combining sets of information elements from your device’s browser, such as JavaScript objects and installed fonts, in order to create a “fingerprint” of your device and uniquely identify your device and applications.
In-app tracking methods. There are a variety of tracking technologies that may be included in mobile apps, and these are not browser-based like cookies and cannot be controlled by browser settings. Some use device identifier, or other identifiers such as “Ad IDs” to associate app user activity to a particular app and to track user activity across apps. With respect to our mobile apps, you can stop all collection of information via an app by uninstalling the app.
Some information about your use of the Site and certain Third Party Services (defined below) may be collected using Tracking Technologies across time and services and used by us and third parties for purposes such as to associate different devices you use, and deliver relevant ads and/or other content to you on the Site and certain Third Party Services.
For further information on Tracking Technologies and your choices regarding them, please see the sections entitled “Third Party Services” and “Your Choices” below.
Information from Other Sources
We may obtain information about you from other sources, including third-party service providers, Independent Sales Representatives, and Third Party Services, and combine such information with information we have collected about you. To the extent we combine such third party sourced information with Personal Information we have collected about you on the Site, we will treat the combined information as Personal Information under this Privacy Statement. We are not responsible for the accuracy of any information provided by third parties or third party policies or practices.
3. Use of Personal Information
We may use your Personal Information for any purposes consistent with our statements in this Privacy Statement or as permitted by applicable law including:
for the purposes for which you specifically provided it including, without limitation, to enable us to respond to your inquiries and process and fulfill your requests;
to send you information about your relationship or transactions with us;
to tell you about products, services, programs, and offers that we believe may be of interest to you via email, SMS, telephone or postal mail (for information about how to manage these communications and marketing efforts, please see “Your Choices” below);
to personalize your experience with us including by presenting products or offers tailored to you;
to allow you to use, communicate and interact with others on our Site;
to help you find an Independent Sales Representative including suggesting a new Avon Representative if your current Independent Sales Representative has discontinued selling Avon products, and to facilitate the business activities of an Independent Sales Representative;
for our 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;
to prevent and address fraud, breach of policies or terms, and threats or harm;
to identify and repair bugs on our Site or mobile applications;
to allow you to participate in sweepstakes, contests and similar promotions and to administer these activities (Some of these activities have additional rules, which could contain additional information about how we use and disclose your Personal Information, so we suggest that you read these rules carefully);
to manage our Site, complete and fulfill your order, or otherwise provide you with products or services, for example, to process your payments, have your order delivered to you, communicate with you regarding your purchase and provide you with related customer service; and
4. Disclosure of Personal Information
We may disclose your Personal Information, for any purposes consistent with our statements in this Privacy Statement or as permitted by applicable law including:
for purposes disclosed at the time you provide the information;
with your consent or at your direction;
to companies that are affiliated with us, that are part of the Avon family of companies, but not for their direct marketing purposes;
to third-party service providers who provide services to Avon, such as website hosting, data analysis, payment processing, order fulfillment, infrastructure provision, information technology services, customer service, email delivery services, credit card processing, auditing, training, and other similar services. (These third parties will be supplied with, or have access to, your Personal Information for the purpose of providing these services to us or on our behalf; they are prohibited from using your Personal Information for any purpose other than to provide this assistance, although we may permit them to use aggregate information which does not identify you or de-identified data for other purposes);
to Independent Sales Representatives, to the extent necessary for them to contact you, fulfill your orders or provide a service to you;
to a third party in the event of any proposed or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings); and
as we believe necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or third parties; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
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 Personal Information with such third parties. We will disclose this anticipated sharing of Personal Information at the time we make such opportunities available to you. If you opt in to participate in such an offer, we may disclose your Personal Information 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.
Without limiting the foregoing, we may aggregate Personal Information so that the aggregated information does not personally identify you or anyone else, such as by using Personal Information to calculate the percentage of our customers who live in a particular area. We may share such aggregated information with third parties or affiliates for any purpose.
5. Public Information
Certain features on our Site may give you an opportunity to interact with us and others. These may include blogs, message boards, messaging functionality, chat functionality, and creating community profiles. When you use these features you should be aware that any information you submit, including your name, location and email address, may be publicly available to others. We are not responsible for any information you choose to make public and we strongly discourage you from disclosing any sensitive Personal Information (such as health or credit card information) through these features. If you use these features, your Personal Information may remain on the Site even after you cease use of the Site.
6. Third Party Services
Our Site contains content from and hyperlinks to websites, locations, platforms, and services operated and owned by third parties (“Third Party Services”). In addition, our Site contains features that allow you to interact with, connect to, or access our Site through certain Third Party Services and third party devices (“Third Party Features”). For example, you use a Third Party Feature when you sign-in using your Facebook credentials or “like” or “share” content over social media through our Site. Remember that third parties may use Tracking Technologies to independently collect information about you and may solicit Personal Information from you. Also, if you use a Third Party Feature, both we and the applicable third party may have access to and use information associated with your use of the Third Party Feature. If you publicly reference our Site on a Third Party Service (e.g., by using a hashtag associated with us in a tweet or post), we may use your reference on or in connection with our Site.
Avon may work with third-party service providers who use Tracking Technologies to conduct website analytics to help us track and understand how visitors use our Site. In addition, we may also work with third-party advertising companies who use Tracking Technologies on our Site and Third Party Services to track your activities across time and services, and tailor ads to you based on your activities, which may include sending you an ad on a Third Party Service or third party device after you have left the Site (“Interest-based Advertising”). In the course of serving advertisements to you, these companies may place or recognize a unique cookie on your browser.
The information collected and stored by third parties, whether through our Site, a Third Party Service, a Third Party Feature, or a third party device, remains subject to their own policies and practices, including what information they share with us, your choices on their services and devices, and whether they store information in Canada or elsewhere. We are not responsible for the privacy practices of any third parties who are in control of how your Personal Information is collected, used, or disclosed, including the privacy practices of third party Internet advertising companies. The inclusion of a link on the Site does not imply endorsement of the linked site by us. To the extent we combine information we receive from third parties with Personal Information we collect directly from you on the Site, we will treat the combined information as Personal Information under this Privacy Statement.
Avon's Independent Sales Representatives are solely responsible for their own websites and for any information collected on those websites. If an Independent Sales Representative uses an Avon Site to collect information from you, Avon may have access to that information and shall treat it in accordance with this Privacy Statement.
We may collect and disclose or may have collected and disclosed your Personal Information to certain categories of third parties, as described below.
Category |
Disclose to Third Parties |
---|---|
Contact information and personal identifiers |
We may disclose or may have disclosed this information to:
|
Device Identifiers |
We may disclose or may have disclosed this information to:
|
Demographic information |
We may disclose or may have disclosed this information to:
|
Online or network activity information |
We may disclose or may have disclosed this information to:
|
We may disclose or may have disclosed this information to:
|
7. Your Choices
To opt out of receiving certain marketing and/or promotional communications (emails, push notifications, text messages, and calls) from Avon at any time, you may (1) for emails, follow the "unsubscribe" instructions contained in any such emails you have received, or if you have registered with an Avon Site, use that Site's "modify account information" or similar functionality to opt out from receiving such emails; (2) for push notifications or in-app messages, adjust the permissions in your mobile device; (3) for text messages, text “STOP” in response to any text message you receive from us or contact us at montreal.cpo@avoncanada.com and specify you want to opt-out of text messages; and (4) for calls, request opt-out during any call you receive from us or contact us at montreal.cpo@avoncanada.com and specify you want to opt-out of calls. Please note that your opt-out is limited to the email address, device, or phone number used and will not affect subsequent subscriptions or, for emails, non- promotional communications, such as those about your account, transactions, servicing, or our ongoing business relations.
Access
If you registered with a Site, you may view, change, modify or remove certain Personal Information contained in your personal profile by using the tools found in the profile or account section of the applicable Site.
We will endeavor to comply with your request 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 Site visitors and users, including Independent Sales Representatives. Residents of certain Provinces may have additional rights as set forth in “Additional Province-Specific Privacy Rights” below.
Tracking Technologies Generally
As discussed in the section entitled “Information Collected Automatically,” you may be able to exercise choice with regard to certain Tracking Technologies. Please be aware that if you disable or remove Tracking Technologies some parts of the Site may not work and that when you revisit the Site your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms. For more information on “Do Not Track,” http://www.allaboutdnt.com/.
Analytics and Advertising Tracking Technologies
You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on.
You may exercise choices regarding receipt of Interest-based Advertising by submitting opt outs. Some of the advertisers that perform advertising-related services for us and our partners may participate in the Digital Advertising Alliance ("DAA") Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, visit http://www.aboutads.info/choices, and http://www.aboutads.info/appchoices for information on the DAA’s opt out program for mobile apps. Some of these companies may also be members of the Network Advertising Initiative (“NAI”). If you would like more information about the NAI and to know your choices for their members, please visit http://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain Interest-based Advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). Avon is not responsible for effectiveness of, or compliance with, any third-parties’ opt out options or programs or the accuracy of their statements regarding their programs.
Your Rights
Depending on the province or territory in which you reside, you may have the right to:
Request access to the Personal Information we have collected, used, disclosed about you,
Request that we delete Personal Information we have collected from you (subject to certain exceptions),
Request that we correct the Personal Information we maintain about you, if that information is inaccurate,
Request that we limit our use and disclosure of Personal Information used for inferring characteristics about you,
Request that we provide you with your Personal Information in a portable format;
Request to withdraw your consent to how we collect, use, or disclose your Personal Information.
You can exercise your rights by submitting a request via email to the following email address: montreal.cpo@avoncanada.com.
When you make a request, you can expect the following:
We will verify your identity. You will need to provide us with certain pieces of information, including but not limited to your name, email address and the state in which you reside, in order for us to verify that you are who you say you are.
We will confirm our receipt of your request within 10 business days. If you have not received a response within a few days after that, please let us know by contacting us at the email address designated.
We will respond to your request within 30 days. If necessary, we may need an additional period of time, in which case, we shall describe the reason for such extension.
In certain cases, your request may be denied; for example, if we cannot verify your identity or if providing you the requested information could create an unreasonable risk to someone’s security (for example, if we do not want very sensitive information disclosed inappropriately). If we deny your request, we will explain why we denied it, and to the extent practicable, we will try to provide you as much of the information as we can, with the exception of any specifically withheld information. You may appeal our decision with respect to a request you have submitted by contacting us at the following email address: montreal.cpo@avoncanada.com.
Before processing your request, we will take reasonable steps to verify your identity, which will include verifying that the email address from which you submit the request matches the email address we maintain on file for you. To ensure you are the owner of the email address, you must respond to a confirmation email that we will send to such email address. In some cases, we may ask that you provide additional information to verify your identity. You may also designate an authorized agent to make a request on your behalf. The authorized agent would be required to submit the request via email to the following email address: montreal.cpo@avoncanada.com, and will be required to provide proof that they have been authorized to act on your behalf. If the authorized agent does not provide such proof, you will be required to confirm your identity and the authenticity of the request directly.
We do not “sell” or “share” your personal information collected through this Site. To opt-out of the sale or sharing of your personal information for cross-contextual behavioral advertising purposes in connection with our Brand websites, you must contact montreal.cpo@avoncanada.com, and indicate the nature of your request.
The Site is not directed to children under the age of fourteen (14), and children should not access the Site. If you are a parent or guardian and believe Avon has collected information from your child, please contact us at montreal.cpo@avoncanada.com.
We use reasonable organizational, technical and administrative measures to protect Personal Information under our control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the Contacting Us section below.
We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Statement unless a longer retention period is required or allowed by law, including to allow us to comply with our legal obligations, resolve disputes, and enforce our agreements.
Your Personal Information may be stored and processed in any country where we have operations, including the United States, South Korea and Canada. By interacting with us and providing us with any Personal Information, you consent to the transfer to and processing, storage, and use of information in countries outside of your country of residence, which may provide for different data protection rules than in your country.
12. Updates to This Privacy Statement
From time to time, we may change this Privacy Statement. Please take a look at the "LAST UPDATED" legend at the top of this page to see when this Privacy Statement was last revised. Any changes to this Privacy Statement will become effective when we post the revised Privacy Statement on the Site. If any of these changes regarding your information are material and retroactively applied, we may provide you additional notice to your email address. Your interaction with us following such changes means that you accept the revised Privacy Statement.
If you have any questions about this Privacy Statement, please contact our [Privacy Officer] by email at montreal.cpo@avoncanada.com , or by regular mail at The Avon Company Canada Limited, 5000 Trans-Canada Highway, Pointe-Claire, Quebec H9R 1B6 Attn: Office of the General Counsel. Because email communications are not always secure, please do not include sensitive information in your emails to us.
14. Independent Sales Representatives
The following provisions are applicable only to Avon's Independent Sales Representatives:
This Privacy Statement applies to the Personal Information of Independent Sales Representatives collected by Avon, whether collected online or offline. This information would be collected in addition to any Personal Information we may collect from you as an Avon customer, as described above.
If you seek to become an Avon Representative we may collect and use your Personal Information to determine your eligibility.
In order to be appointed an Avon Representative, you may be required to enter into a separate agreement with Avon ("Representative Agreement"). If you have entered into a Representative Agreement, we may collect, use and disclose your Personal Information in accordance with this Privacy Statement and the terms of your "Representative Agreement." We also may collect, use and disclose your Personal Information as necessary to fulfill our obligations under the Representative Agreement. In the event of a conflict between this Privacy Statement and the Representative Agreement, the terms of the Representative Agreement shall apply. Once you are an Avon Representative (including a sales leader), we may disclose your Personal Information:
• as necessary to comply with legal requirements such as tax and record keeping obligations; and
• to sales consultants or their equivalent, who may be independent contractors to Avon;
• as part of our sales leadership program, to Independent Sales Representatives who are sales leaders;
• to current and potential customers who are seeking the assistance of an Avon Representative;
• as necessary to comply with legal requirements such as tax and record keeping obligations; and
We may also combine any other information that we and our third-party service providers collect about your use of our Site (as described above) with your unique Representative account number. We may use the combined information for purposes such as to analyze Independent Sales Representatives' use of our Sites, in order to evaluate and make improvements to our business model, and for other internal analytics purposes.
This Statement © 2024 The Avon Company Canada Limited. All rights reserved.