SheerSense® Privacy Policy

SheerSense® Limited Privacy Policy

SheerSense Limited takes the privacy of our Distributors and visitors to our websites seriously. We are committed to safeguarding your privacy.

GDPR (General Data Protection Regulation) requires that we inform you how we deal with your personal data.

References to “SheerSense”, “us”, “we” or “our” in this Privacy Policy mean SheerSense Limited.

Where your personal information is passed to us, we are a controller as GDPR defines.
Where SeneGence products and services are provided through a SheerSense Independent Distributor your personal information will also be processed by the Independent Distributor who will also be a controller of your personal information.

SheerSense Distributors are independent of and not employed by SheerSense Limited.

SheerSense Independent Distributors are required to use your personal information in a way which is compatible with this Privacy Policy.

If a Distributor’s use of your personal information in any respect differs from this Privacy Policy then they are required to provide their own Privacy Policy.

SheerSense Limited is not responsible for the use of personal data by its Independent Distributors.

Objective and Scope of This Privacy Policy

This Privacy Statement applies to the personal information of SheerSense customers/visitors to our websites where personal information is passed to us by you or by your Independent Distributor, and to the personal information of SheerSense Independent Distributors.

We process personal data in accordance with the data protection laws and other applicable laws and regulations that are in force in the United Kingdom.

This Privacy Policy applies to personal data, meaning any information relating to an identifiable person who can be directly or indirectly identified.

This Privacy Policy describes how we collect and process information provided by you, your right to limit our processing of your information and your right to access, correct and delete your information that we hold.

Your Consent to Use Personal Data

We use your Personal Data only with your consent. You may withhold or withdraw your consent for us to process your Personal Data. Certain Personal Data is required to provide services or products to you or to meet our legal obligations, and your withholding or withdrawal of consent to use this Personal Data may prevent us from providing the services and products that you require. Other Personal Data is not required for us to provide services or products to you but is used by us to provide you with better service or for marketing, communications and other purposes. By using our websites, you consent to the collection of certain information.

You should not volunteer further information than that which is requested of you.

What Information Do We Collect?

The Personal Data that we may collect is

firstname, lastname
postal address
email address
date of birth
landline number, mobile number
date of registration
initial account password if it is provided by us
sponsor’s name & ID number
VAT registration number (if applicable)
email drop history
Banking details or other information needed to process payments/refunds to you
IP and MAC addresses and browser information

Use of Cookies

Cookies are small text files that are sent to your computer so that our websites can remember the settings and information that you submit, so that you don’t have to re-enter them when you re-visit a page or visit a new page on the same website.
We also use cookies to measure how you use our website so that we can make sure that they meet your needs.

You can control whether or not your computer accepts cookies, however, refusing to accept cookies may affect your experience using our website.

How Do We Collect Information?

We collect Personal Data and other information from you in a variety of ways, including:

• the submission of Personal Data by you to us through our websites;
• the use of cookies;
• the submission of an online order for our services or products;
• the submission of a Distributor Registration Application;
• when you are contacted by email, telephone or otherwise.

We will not contact you by telephone or email to request information such as passwords and pin codes. We recommend that you do not open or respond to e-mails requesting this type of information and that you contact us if you receive such a request.

How Do We Use Your Personal Data?

We processes Personal Data for a variety of purposes, including:

• to verify, process and administer your orders for our services and products
• to ensure a secure ordering process in connection with your purchase or usage of our services and products
• to maintain our commercial relationship with you, including provision of billing and customer services
• to analyse, understand and respond to your service needs
• to improve the products and services that we offer to you and to develop new products and services
• to meet our legal and regulatory obligations and to protect our legal and financial interests (including fraud detection and prevention)
• for the provision of services to Independent Distributors and compliance with our contractual obligations to Independent Distributors
• to facilitate financial, accounting and administrative functions
• to send commercial and marketing communications to you about our services and products.

Legal Basis for Processing Your Data

There are three Legal Bases that provide legitimacy for our processing of your data.

CONSENT – the user of our website gives consent for us to process their personal data, as they provide the information themselves on forms on our websites.

CONTRACT – During an enquiry we may request more information which may require the processing of personal data for contact information in order to complete the Distributor Registration, or orders of product or services; and to complete legitimate contractual obligations, eg. refunds and obligations with goods returns.

LEGITIMATE INTEREST – This basis allows us to process data without an individual’s consent as long as the processing does not interfere with the individual’s rights, freedom or legitimate interest.

We can process an individual’s data without direct consent when the purpose for processing can be described as a reasonable expectation stemming from the relationship between you and us, pursuant to this interest, such as direct physical or electronic mailing, provided that there is an effective opt-out.

Legitimate Interest allows for the transmission of personal data within the organisation for necessary internal operations.

We may also transfer data to a third party for data analysis, market research, email drop handlers, as part of market research.

Who Has Access To Your Personal Data?

The day-to-day operation is handled by us on secure servers supported by JMV Solutions Limited.

Specialist technical solutions are provided by JMV Solutions Limited and Expandia Limited.

Postal address details are handled by the Royal Mail or Parcel Force or an established courier for larger parcels.

Email, telephone contact and other general contact is dealt with in-house by us.

Registration and commission payments for Independent Distributors is provided on secure servers by FourFront Limited who specialise in this facility.

A Distributor’s Sponsor, their Uplines and their Downlines are restricted to information for basic contact and sales history.

Where and How Do We Store Your Personal Data?

Your Personal Data is stored securely at the office of SheerSense® Limited on computer disc and on secure servers supported by JMV Solutions Limited and FourFront Limited in the United kingdom.

Personal Data is stored by SheerSense® Limited according to industry standards.

Independent Distributors are required to safeguard personal data of customers and of other distributors .

Transfer of Personal Data to Third Parties

We may provide your Personal Data to governmental authorities in response to specific requests from those authorities or as part of statistical and analytical reports.

Some Personal Data is transferred to SeneGence International Inc. in the USA when a Distributor has an Upline there.

We will not transfer, sell or make available your Personal Data to third parties except as permitted by this Privacy Policy and applicable law.

How Long Do We Keep Your Personal Data?

In deciding how long to keep personal information after you cease to be active with SheerSense®, we take into account any ongoing obligations we may have (e.g. to store the information for accounting purposes) or the length of time given to commence or defend any legal claims.

We keep your Personal Data as long as it is required for the purposes for which it was initially collected and to ensure the commercial interests of the Independent Distributors and SheerSense® Limited are safeguarded.

In certain cases we may need to keep your Personal Data for a minimum period to comply with legal requirements.

We do not keep your Personal Data longer than permitted by law.
We will stop processing your data for direct marketing, including profiling activities, if you object to such processing of your data or if you withdraw your consent to processing, where your consent has previously been obtained.

Security

SheerSense® Limited has implemented technological and organisational measures to safeguard your Personal Data from unauthorised or improper access during collection and while it is in our possession.

Sensitive information (such as gender, ethnicity, and financial information) is not requested, collected or stored.

You should take measures to safeguard your Personal Data by maintaining the confidentiality of your password, logging out of SheerSense® websites, on completion of any transactions, closing your web browsers when you have concluded your online activities and not providing your Personal Data to anyone.

We and you may communicate by email or chat and these communications may at times contain Personal Information. While it is illegal to intercept or disclose the contents of email and chat communications, these communications are not secure.

Your Right to Access Your Personal Data

You have the right to access your Personal Data, to correct your Personal Data if the information that we have is in error and in some cases to delete your Personal Data. We must respond to your request within 30 days.

You may obtain a copy, in text or machine readable form, or correct or request deletion of your Personal Data by contacting our Compliance Department at Compliance@SheerSense®.com
or by writing to:

Data Protection Officer
SheerSense® Limited
Devlex House
Silverhills Road
Decoy Industrial Estate
Newton Abbot TQ12 5ND

We may impose reasonable restrictions on requests for access to or to correct your Personal Data and we may charge you a reasonable fee as permitted by law for provision of your Personal Data for manifestly unfounded or excessive requests.

If you request deletion of your data, we may not be able to provide services and products to you.

We are permitted to keep certain of your Personal Data in order to meet our legal, financial, audit and business needs, even if you request its deletion.

If you have a complaint concerning these rights please contact us in the first instance.
If we refuse a request we must tell you why and that you have the right to complain to the UK Information Commissioner’s Office at ico.org.uk/concerns and to a judicial review. And we must tell you this without undue delay and, in any case, within 30 days.

Limitation of Liability

SheerSense® Limited uses reasonable efforts to comply with the terms of this Privacy Policy and applicable law regarding the processing of your Personal Data.

Except as provided by applicable law, SheerSense® Limited shall not be responsible for direct or indirect damages that may result from non-compliance with this Privacy Policy.

Changes to Privacy Policy

SheerSense® Limited may change this Privacy Policy at any time without prior notice. All changes are effective immediately after they are posted on SheerSense® Limited’s websites.

SheerSense® Privacy Policy 24 10 2019 All Rights Reserved

The SheerSense® Opportunity