[COMPANY NAME] (we) are committed to protecting and respecting your privacy.

SCOPE OF POLICY

This policy (together with our end-user licence agreement as set out at [WEB ADDRESS OF EULA] (EULA) and any additional terms of use incorporated by reference into the EULA, together our Terms of Use) applies to your use of:

• [NAME OF APP AND VERSION] mobile application software available via the itunes store or Google Play store (App Site), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).
• Any of the services accessible through the App (Services) that are available on the App Site or other sites of ours (Services Sites), unless the EULA states that a separate privacy policy applies to a particular Service, in which case that privacy policy only applies.

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

  For the purpose of Data Protection, the data controller is [COMPANY NAME] of [ADDRESS].

  INFORMATION WE COLLECT FROM YOU

  We will collect and process the following data about you:

• Information you give us (Submitted information): This is information you give us about you by filling in forms on the App Site and the Services Sites (together Our Sites), or by corresponding with us (for example, by e-mail or chat). It 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 an in-App purchase, share data via an App's social media functions, and when you report a problem with an App, our Services, or any of our Sites. If you contact us, We will keep a record of that correspondence. The information you give us may include;
  • your name
  •  address
  • e-mail address
  • phone number
  • the Device's phone number
  • age
  • username
  • password and other registration information
  • financial and credit card information
  • personal description and photograph
  • [OTHER INFORMATION].
• Information we collect about you and your device. Each time you visit one of our Sites or use one of our Apps we will automatically collect the following information:
• technical information, including the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting, [OTHER INFORMATION] (Device Information);
• information stored on your Device, including contact information, friends lists, login information, photos, videos or other digital content, check ins, [OTHER INFORMATION] (Content Information);
• details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to traffic data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access (Log Information).
• [Location information. We also use [GPS technology] OR [OTHER TECHNOLOGY] to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by [WAY IN WHICH CONSENT CAN BE WITHDRAWN].]
• [Information we receive from other sources (Third Party Information). We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.]
• [Unique application numbers: when you install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.]

  Cookies

  We use cookies to distinguish you from other users of the App, App Site, Appstore or Service Site. This helps us to provide you with a good experience when you use the App or browse any of the sites and also allows us to improve the App and Our sites. For detailed information on the cookies We use and the purposes for which We use them, see our cookie policy [WEB ADDRESS OF COOKIE POLICY].

  Uses made of the information

  We use information held about you in the following ways:

• Submitted Information: [SPECIFY PURPOSES].
• Device information: [SPECIFY PURPOSES].
• Content Information: [SPECIFY PURPOSES]
• Log information: [SPECIFY PURPOSES].
• Location information: [SPECIFY PURPOSES].
• Third Party Information: [SPECIFY PURPOSES]
• Unique application numbers: [SPECIFY PURPOSES].
• [ANY ADDITIONAL CATEGORIES AND THEIR PURPOSES].

  We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.

  [We do not disclose information about identifiable individuals to our advertisers, but We may provide them with anonymous aggregate information about our users (for example, We may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We will use of the personal data We have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.]

  Disclosure of your information

  We will disclose the data we collect from you to the following third parties:

   

  Category of data

  Recipient

  Purpose

   

   

  You agree that we have the right to disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries or affiliates.

  We will disclose your personal information to third parties:

• In the event that We sell or buy any business or assets, in which case We will disclose your personal data to the prospective seller or buyer of such business or assets.
• If [COMPANY NAME] or substantially all of its assets are acquired by a third party, in which case 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 or regulatory obligation or request.
• In order to:
• enforce or apply the EULA, Our Terms of Use (WEB ADDRESSES OF RELEVANT TERMS OF USE), terms and conditions of supply (WEB ADDRESSES OF TERMS AND CONDITIONS OF SUPPLY OF GOODS OR SERVICES) and other agreements or to investigate potential breaches; or
• protect the rights, property or safety of [COMPANY NAME] our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
• [DETAILS OF ANY OTHER THIRD-PARTY DISCLOSURES].

Where We store your personal data

The data that We collect from you will be transferred to, and stored at, a destination outside the European Economic Area (EEA). It will also be processed by staff operating outside the EEA who work for us or for one of our suppliers. These staff may be engaged in the fulfilment of your request, order or reservation, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. [[COMPANY NAME] OR We] will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.]

[All information you provide to us is stored on our secure servers. Any payment transactions [carried out by us or our chosen third-party provider of payment processing services] will be encrypted [using Secured Sockets Layer technology]. Where We have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect your personal data, We cannot guarantee the security of your data transmitted to Our Sites; 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.

We will collect and store personal data on your Device using [application data caches and browser web storage (including HTML 5)] and other technology.

Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

Your rights

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if We intend to use your data for such purposes or if We intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms We use to collect your data. You can also exercise the right at any time by contacting us at privacy@oriflame.com.

Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the App or the Services are advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that We do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.

Access to information

Data Protection law gives you the right to request access to information held about you. Any access request may be subject to a small administrative fee to meet our costs in providing you with details of the information We hold about you.

[WAYS IN WHICH INDIVIDUALS CAN ACCESS THEIR PERSONAL DATA ON CONTROLLER'S WEBSITES AND CORRECT, UPDATE OR DELETE IT]

Changes to privacy policy

Any changes We may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by by e-mail OR when you next start the App or log onto one of the Services Sites. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App or the Services.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to [[ADDRESS] OR [E-MAIL ADDRESS]].