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dōTERRA India Privacy Notice

Effective Date: 1 July 2021

doTERRA India Private Limited (“doTERRA” or “Company”) respects your concerns about privacy. This Privacy Notice describes why we collect your personal data, types of personal information we obtain, including through doTERRA’s websites and mobile applications listed here (collectively, the “Sites”), how we may use the information, with whom we may share it and the choices available regarding our use of the information. The Notice also describes the measures we take to safeguard the personal information we obtain and how individuals can contact us about our privacy practices.

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Definitions

a) "Automated means" means any equipment capable of operating automatically in response to instructions given for the purpose of processing data.
b) "Child" means a person who has not completed eighteen years of age;
c) "Data fiduciary" means any person, including the State, a company, any juristic entity or any individual who alone or in conjunction with others determines the purpose and means of processing of personal data;
d) "Data principal" means the natural person to whom the personal data relates;
e) "Data processor" means any person, including the State, a company, any juristic entity or any individual, who processes personal data on behalf of a data fiduciary;
f) "Personal Data" means data about or relating to a natural person who is directly or indirectly identifiable, having regard to any characteristic, trait, attribute or any other feature of the identity of such natural person, whether online or offline, or any combination of such features with any other information, and shall include any inference drawn from such data for the purpose of profiling;
g) "Processing" in relation to personal data, means an operation or set of operations performed on personal data, and may include operations such as collection, recording, organisation, structuring, storage, adaptation, alteration, retrieval, use, alignment or combination, indexing, disclosure by transmission, dissemination or otherwise making available, restriction, erasure or destruction.

Person In Charge

This Privacy policy is issued by the Company. When we collect and use your personal data, we, the Company, are a Data Fiduciary, as that term is used in the Personal Data Protection Law (“PDP”) and we are responsible for protecting your rights with respect to your Personal Data.

Information We Obtain

We obtain certain personal information in connection with the products and services we provide. The types of personal information we obtain include:

  • contact information, such as name, phone and fax number, and email and postal address;
  • information used to create your account to access the Sites, such as birth date, spouse’s name, photo, preferred language, Enroller ID, Sponsor ID, online password, and, if you are a Wellness Advocate, a personal identification number (or equivalent) or Tax ID number;
  • payment information, such as name, billing address and payment card details, including card number, expiration date and security code, which is collected and stored by our third-party payment processor on our behalf;
  • information you submit in connection with a business opportunity at doTERRA, such as contact details, information in your résumé (including work history, education, language skills, certifications/licenses and work eligibility status) and details about your current employment;
  • Company may record the conversations between you and Company’s global voice solutions team when you contact our helpline phone number. Also, Company’s tele nurture representatives may contact you to address any inquires made by you or to further communicate with you about Company service offerings. All such conversations will also be recorded for quality and training purposes and to facilitate resolution of any queries or complaints.
  • from time to time, Company publishes thought leadership, marketing collateral and webinars on third-party website platforms. By accessing Company content, Company may collect your name, email address, contact number, designation/job role, company you represent, and any other Company content/ links accessed; and
  • other personal information contained in content you submit to us, such as through the “Feedback” feature, public forums or customer support tools on the Sites.

 

Information We Obtain by Automated Means

When you interact with the Sites, we obtain certain information by automated means, such as cookies, web server logs, web beacons and other technologies. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s web browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server.

We may use these automated technologies to collect information about your equipment, browsing actions and usage patterns. The information we obtain in this manner may include your device IP address, other identifiers associated with your devices, web browser characteristics, device characteristics, language preferences, referring/exit pages, clickstream data, and dates and times of Site visits. These technologies help us (1) remember your information so you will not have to re-enter it; (2) track and understand how you use and interact with our products, services and Sites; (3) tailor our products, services and Sites around your preferences; (4) measure the usability of our products, services and Sites and the effectiveness of our communications; and (5) otherwise manage and enhance our products, services and Sites.

Your web browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of our Sites. For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your mobile device. To the extent required by applicable law, we will obtain your consent before using cookies or similar tools.

How We Use the Information We Obtain

We may use the information we obtain about you to:

  • provide our products and services to you;
  • send promotional materials, newsletters and other communications about our products and services;
  • establish and manage your account with doTERRA;
  • process and fulfill orders in connection with our products and services and keep you informed about the status of your order;
  • identify and authenticate you so you may order our products and access and use the Sites;
  • communicate about, and administer participation in, special events, programs, promotions, offers surveys, focus groups and market research;
  • provide Wellness Advocate and customer support and respond to inquiries;
  • increase and maintain the safety and security of our products and services and prevent misuse;
  • perform data analytics (including market research, trend analysis, financial analysis, and anonymization and aggregation of personal information);
  • operate, evaluate, develop, manage and improve our business and the Sites (including operating, administering, analyzing and improving our products, services and Sites; developing new products and services; managing and evaluating the effectiveness of our communications; performing accounting, auditing, billing reconciliation and collection activities and other internal functions);
  • protect against, identify and prevent fraud and other criminal activity, claims and other liabilities; and
  • comply with and enforce applicable legal requirements, relevant industry standards and policies, including this India Privacy Notice and other doTERRA terms of use and related documents.

We also may use the information we collect about you in other ways for which we provide specific notice at the time of collection and obtain your consent if required by applicable law.

Third-Party Analytics Services

We use third-party web analytics services on the Sites, including Google Analytics and Facebook Pixel. These service providers use automated technologies to collect data (such as IP addresses) to evaluate use of the Sites. To learn more about Google Analytics and how to opt out, please visit https://www.google.com/intl/en/analytics/learn/privacy.html. To learn more about Facebook Pixel and how to opt out, please visit https://www.facebook.com/help/164968693837950?helpref=faq_content.

Online Tracking and Interest-Based Advertising

We may collect information about your online activities to provide you with advertising about products and services tailored to your interests. Where required by applicable law, we will obtain your consent for the processing of your personal information for direct marketing purposes.

You may see our ads on other websites or mobile apps because we participate in advertising networks. Ad networks allow us to target our messaging to users considering demographic data, users’ inferred interests and browsing context. These networks track users’ online activities over time by collecting information through automated means, including through the use of cookies, web server logs, web beacons and other similar technologies. The networks use this information to show ads that may be tailored to individuals’ interests, to track users’ browsers or devices across multiple websites or apps, and to build a profile of users’ online browsing activities. The information our ad networks may collect includes data about users’ visits to websites and apps that participate in the relevant ad networks, such as the pages or ads viewed, and the actions taken on the websites or apps. This data collection takes place both on the Sites and on third-party websites and apps that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts. The Sites are not designed to respond to “do not track” signals received from browsers. To learn how to opt out of ad network interest-based advertising in India, please visit www.aboutads.info/choices, http://www.networkadvertising.org/choices/ and http://preferences-mgr.truste.com/.

Information Sharing

We do not sell or otherwise share personal information about you except as described in this India Privacy Notice. We may share your personal information with (1) our affiliates and subsidiaries and (2) our service providers who perform services on our behalf, such as order fulfillment, customer support, payment processing and data analytics. We do not authorize our service providers to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements.

If you are a doTERRA account holder, we also share your personal information with the account’s sales organization (including upline and downline distributors) for the purpose of administering sales, distribution of doTERRA products, and providing reports of activities to other doTERRA account holders.

We also may disclose information about you (1) if we are required to do so by law or legal process (such as a court order or subpoena); (2) in response to requests by government agencies, such as law enforcement authorities; (3) to establish, exercise or defend our legal rights; (4) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; (5) in connection with an investigation of suspected or actual illegal activity; or (6) otherwise with your consent.

We reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation).

Other Online Services and Third-Party Features

The Sites may provide links to other online services for your convenience and information, and may include third-party features such as apps, tools, payment services, widgets and plug-ins (e.g., Facebook, Twitter, Instagram, YouTube and Pinterest buttons). These online services and third-party features may operate independently from us. The privacy practices of the relevant third parties, including details on the information they may collect about you, is subject to the privacy statements of these parties, which we strongly suggest you review. To the extent any linked online services or third-party features are not owned or controlled by us, doTERRA is not responsible for these third parties’ information practices.

Retention Period of your Personal Data

We only keep your personal data for as long as we need it for the purpose for which we hold your personal data to meet your needs and three years thereafter as required under the law of limitation. To determine the data retention period of your data, we use the following criteria:
a) Where you purchase products and services, we keep your personal data for the duration of our contractual relationship;
b) Where you contact us for an enquiry, we keep your personal data for the duration needed for the processing of your enquiry;
c) Where you create an account, we keep your personal data until you require us to delete it.
d) Where you have consented to direct marketing, we keep your personal data until you unsubscribe
e) Where cookies are placed on your computer, we keep them for as long as necessary to achieve their purposes (e.g. for the duration of a session for shopping cart cookies or session ID cookies) and for a period defined in accordance with local regulations and guidance.

We may retain some personal data to comply with our legal or regulatory obligations, as well as to allow us to manage our rights (for example to assert our claims in courts) or for statistical or historical purposes. When we no longer need to use your personal data, it is removed from our systems and records or anonymized so that you can no longer be identified from it.

Rights of Data Principal

a) Obtain confirmation from the data fiduciary whether the data is processing or has been processed.
b) Correction of your personal data if inaccurate or incomplete;
c) Erasure of your personal data in certain circumstances;
d) Suspension of using your personal data in certain circumstances;
e) Stopping processing your personal data in certain circumstances; and
f) Obtaining your personal data in a structured, commonly used, and computer-readable format.

If you wish to exercise your right, please contact us.

How We Protect Personal Information

We maintain administrative, technical and physical safeguards designed to protect personal information against unauthorized access, disclosure or use.

Children’s Personal Information

The Sites are designed for a general audience service and are not directed to children. doTERRA does not knowingly collect or solicit personally identifiable information from children under the age of 18. If we learn that we have collected personal information from a child under age 18, we will promptly delete that information. If you believe that a child under age 18 may have provided us with personal information, please contact us at privacy@doterra.com.

Updates To This India Privacy Notice

This India Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will indicate at the top of the notice when it was most recently updated.

Grievance Redressal

If you have any questions or concerns as to how your data is being processed, you can contact our Data Protection Officer by writing to Mr. Manoj Shirodkar, (022) 4015 3862 mshirodkar@doterra.com or submit a data subject request on our portal.

 

Appendix A

This India Privacy Notice applies to doTERRA’s processing of personal information, including through the following websites and mobile apps:

www.doterra.com
doterradiamondclub.com
www.doterrapresidentialclub.com
sourcetoyou.com
www.aromatouch.com
labs.doterra.com
themarketplace.doterra.com
www.spa.doterra.com

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