SheerSense® takes the privacy of our Distributors and visitors to our website 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.
SheerSense® Limited processes personal data in accordance with the data protection laws and other applicable laws and regulations that are in force in the United Kingdom.
Your Consent to Use Personal Data
We use your Personal Data only with your consent. You may withhold or withdraw your consent for SheerSense® Limited to process your Personal Data. Certain Personal Data is required for us 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 SheerSense® Limited 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. You are not required to consent to this use of your Personal Data. By using SheerSense® Limited’s website, you consent to the collection of certain information.
What Information Do We Collect?
The Personal Data we may collect is the following:
date of birth
landline number, mobile number
date of registration
initial distributor account password
sponsor’s name & ID number
VAT registration number (if applicable)
email drop history
Banking details or other information needed to process payments to you
IP and MAC addresses and browser information
Cookies are small text files that are sent to your computer so that our website 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.
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 SheerSense® Limited through our website;
• the submission of an online order for SheerSense® Limited services or products;
• the submission of a Distributor Registration Application;
• when we and you communicate by email, telephone or otherwise.
SheerSense® Limited 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 SheerSense® Limited if you receive such a request.
How Do We Use Your Personal Data?
SheerSense® Limited processes Personal Data for a variety of purposes, including:
• to verify, process and administer your orders for SheerSense® Limited services and products
• to ensure a secure ordering process in connection with your purchase or usage of SheerSense® Limited 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 SheerSense® Limited’s legal and financial interests (including fraud detection and prevention)
• for the provision of services to our 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 services and products from SheerSense® Limited.
Legal Basis for Processing Your Data
There are three Legal Bases that provide legitimacy for our processing of your data.
CONSENT – the Independent Distributor and user of our website gives consent for us to process their personal data, as they provide the information themselves when they fill in the application form, and any information provided to their Back Office account, hosted by SheerSense® Limited.
CONTRACT – During the enquiry concerning registration, the enquirer may request more information which may require the processing of personal data for contact information;
in order to complete the Distributor Registration, personal data processing is necessary;
and to complete legitimate contractual obligations, eg. payment of commission.
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 SheerSense® Limited on secure servers supported by JMV Solutions Ltd.
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.
Specialist technical solutions are provided by JMV Solutions 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 at SheerSense® Limited.
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 located at Krystal Hosting Limited and FourFront Limited in the United kingdom.
All Personal Data is stored according to industry standards.
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.
How Long Do We Keep Your Personal Data?
SheerSense® Limited keeps 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.
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® Limited website, on completion of anytransactions, closing your web browsers when you have concluded your online activities and not providing your Personal Data to anyone.
SheerSense® Limited 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
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 endeavour to settle the matter with us.
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 undie delay and, in any case, within 30 days.
Limitation of Liability