Silpada Designs
Safe Harbour Privacy Policy

Silpada Designs (“Silpada”) recognises the importance of building trusting relationships with our customers, employees, and with Silpada Independent Representatives (“Representatives”). We believe that building trust begins with protecting the privacy and confidentiality of your personal information, which is fundamental to the way we do business. Silpada participates in the International Safe Harbour Programme established by the United States and the European Union (see www.export.gov/safeHarbour) for the purpose of regulating transfers of Personal Information from Europe to the United States.

Accordingly, Silpada is committed to protecting the confidentially and privacy of personal information that Silpada collects and uses in the course of its commercial activities. This Privacy Policy describes the following seven principles of the US & EU Safe Harbour Framework that Silpada adheres to: (1) Notice; (2) Choice; (3) Transfer to Third Parties; (4) Access; (5) Security; (6) Data Integrity; and (7) Enforcement.

(1)Notice
Silpada may collect, use or disclose personal information in the manner described below where we have the required consent. Except as otherwise permitted by law, Silpada will ensure that it has the required consent prior to the collection, use or disclosure of your personal information, as described below. Silpada will only collect personal information by lawful and fair means and not in an unreasonably intrusive manner. As a general rule, the personal information that Silpada collects will be limited to that which is necessary for the purposes that are identified for their collection. Silpada will not collect personal information from individuals under the age of 18. Silpada collects personal information from Customers and from Representatives. The purposes for the collection, use and disclosure of the information are described below in Section a. Customers, and Section b. Representatives.

a.Customer Information

Purposes of Collection of Customer Information
Silpada will collect, use and disclose your personal information only for purposes that it was provided and is reasonable in the circumstances of our relationship, as described in further detail below.

In providing various goods and services to its customers, Silpada collects and uses certain personal information obtained from its customers, as follows.

Collection of Customer Personal Information

To purchase Silpada products, customers fill out the information required in the Customer Order Form, of which you as a customer will have seen, filled out, and signed. Customers may also provide similar information by telephone, fax, or email.

To receive additional information about Silpada’s products and services, potential customers fill out the information required in Silpada’s online “Request Information” forms. Potential customers may also provide similar information by telephone, fax, or email.

Use of Customer Personal Information

Silpada will use the personal information disclosed in the Customer Order Form to process and complete the customer’s order, including for shipping and billing purposes, and to verify either the purchase or the delivery.

In addition, a customer’s name, mailing address, email address, telephone number and language preference will be used for the following limited purposes:

1.Customer Satisfaction At Silpada we mean to ensure that the purchasers of our products are completely satisfied with their Silpada products, and all aspects of the purchase process. Accordingly, the personal information identified above may also be used for purposes of monitoring and ensuring customer satisfaction, including trouble shooting problems and resolving disputes.

2.Post-Sale Marketing Purposes The personal information identified above may also be used to keep past and current customers informed of new products and promotions at Silpada, including catalogues and service calls.

3.Detection and Prevention of Fraud We may use personal information regarding customers in order to detect and protect us against error, fraud, or other criminal activity. We may share this information with governmental agencies or other companies assisting us in fraud prevention or investigation. We may do so when: 1) permitted or required by law; 2) trying to protect against or prevent actual or potential fraud or unauthorised activity; or, 3) investigating fraud that has already taken place.

Customer Consent

When a customer fills out and signs a Customer Order Form, Silpada will assume that the customer consents to the collection, use and disclosure of the above personal information, for the purposes which we have set out above, unless notified otherwise.

b.Representative Information

Purposes of Collection of Representative Personal Information
In the course of operating your business as a Representative, Silpada collects and uses certain personal information obtained from you, as follows.

Collection of Representative Personal Information
To become a Representative, a person will typically complete and sign an Independent Retail Sales Representative Application-Agreement (“Representative Application”). The information that Silpada collects in the Representative Application typically includes the person’s name and contact information (i.e., address, telephone, email, fax and credit card information).

Use of Representative Personal Information
If the Representative Application is accepted by Silpada, Silpada will use the personal information disclosed in the Representative Application solely within the context of our commercial relationship with you, and for the following purposes:

1.Processing Application The personal information identified above will be used to receive, consider and process Representative Applications.

2.Processing and Shipping Representative Orders Orders are submitted by Representatives and the respective goods are sometimes shipped directly to Representatives. The personal information identified above will be used to facilitate this process.

3.Sales Motivation As motivation is an integral part of your business opportunity with Silpada, Silpada will, from time to time, publish personal information relating to Representatives (including names, photos, and sales results and achievements) for purposes of recognising and promoting the same.

4.Business Information Purposes As Representatives develop their businesses, the personal information outlined above may be further distributed to their uplines for a variety of purposes, including general information, training, other motivational/recognition purposes, and downline activity.

5.Customer Sales and Business Opportunity Referrals Silpada, if receiving unsolicited requests for product, may use the personal information outlined above for purposes of making a referral to your business of a possible customer.

6.Administrative Purposes From time to time, Silpada may use personal information relating to Representatives for administrative purposes and to trouble shoot problems or resolve disputes.

7.Detection and Prevention of Fraud We may use personal information regarding Representatives in order to detect and protect us against error, fraud, or other criminal activity. We may share this information with governmental agencies or other companies assisting us in fraud prevention or investigation. We may do so when: 1) permitted or required by law; 2) trying to protect against or prevent actual or potential fraud or unauthorised activity; or, 3) investigating fraud that has already taken place.

Where a Representative Application is not accepted by Silpada, Silpada will only keep the information for lawful purposes including documenting why such Representative Application was declined.

Representative Consent
When an individual completes and signs the Representative Application, Silpada will assume that the individual consents to the collection, use and disclosure of their personal information, for the purposes which we have set out above, unless notified otherwise.

Please contact Silpada’s Privacy Officer at compliance@silpada.com with any inquiries or complaints with respect to our policies concerning the handling of personal information or if you wish to request access to or correct your personal information.

(2)Choice

Any individual, customer or Representative may withdraw consent for collection, use and disclosure of personal information at any time, by contacting our Privacy Officer at compliance@silpada.com. Please be reminded that if, as a Representative, you withdraw your consent, Silpada’s ability to maintain a commercial relationship with you may be significantly inhibited.

(3)Transfer to Third Parties

Disclosure of Personal Information
Silpada will not disclose, share, sell or rent your personal information to third parties outside of Silpada and its related affiliates without your consent.

We may, however, also transfer such information in the course of corporate divestitures, mergers, or any dissolution.

You acknowledge that Silpada’s parent corporation is located in the United States and, accordingly, your information may be processed and stored in the United States and that the United States governments, courts or law enforcement agencies may be able to obtain disclosure of you information through lawful means in the United States. We may also disclose this information for the Detection and Prevention of Fraud. Please note that Silpada, its parent corporation and its affiliates will continue to abide by this Privacy Policy, as well as all applicable privacy laws, in respect of the information transferred.

If Silpada transfers personal information to a third party that is acting as our agent, we will ensure that the third party subscribes to Safe Harbour principles or, in the alternative, will enter into a written agreement requiring that the third party provide at least the same level of privacy protection as is required by the relevant principles.

(4)Access

Subject to the exceptions provided by the applicable law, we will provide you with access to any personal information that we have collected, used or disclosed, upon your written request, within 30 days. Please contact Silpada’s Privacy Officer at compliance@silpada.com with any inquiries or complaints with respect to our policies concerning the handling of personal information or if you wish to request access to or correct your personal information.

(5)Security

Silpada is committed to maintaining the security of your personal information. In this regard, Silpada takes all reasonable precautions to ensure that personal information is kept safe from loss, unauthorised access, modification and disclosure. Among the steps taken to protect your information are:

• Data encryption
• Web passwords
• Limiting access to personal information to employees with a need-to-know basis only
• Training internal staff on data protection rules regarding the collection and retention of personal information
• Using SSL (Secure Socket Layers) to submit information over the website
• Restricting access to personal information from our Representative Care Department to the Representative herself/himself
• For a more detailed description of steps that Silpada takes to protect your personal and confidential information, please contact compliance@silpada.com.

(6)Data Integrity

All personal information collected by Silpada will be relevant for the purposes for which it is to be used. Silpada endeavours to ensure that all personal information collected and retained is accurate, current and complete as necessary for the purposes for which we collect, use or disclose the information. As it is important that the information be accurate and up-to-date, please inform us of any changes to your personal information, as soon as possible.

(7)Enforcement

Silpada will provide an annual self-assessment to verify compliance with the Safe Harbour Principles, and confirm that its privacy policies are being followed in practice. Silpada will also provide a self-certification letter to the U.S. Department of Commerce that commits to continued adherence to the Safe Harbour Principles.

OTHER IMPORTANT POINTS

Dispute Resolution

Any questions or concerns regarding the use or disclosure of personal information should be directed to Silpada’s Privacy Officer at compliance@silpada.com. Silpada will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Policy. Should a dispute arise that cannot be resolved through communication, Silpada will use the International Centre for Dispute Resolution/American Arbitration Association (ICDR/AAA). More information about (ICDR/AAA) can be found at http://www.adr.org/sp.asp?id=22090 and http://www.adr.org/sp.asp?id=22014.

Retention of Personal Information

Silpada will retain your personal information, including credit card information, for as long as it is required under tax legislation to keep business records (which may be up to 7 years), and upon the expiry of which all credit card information will be destroyed.

All personal information disclosed in the course of a Representative’s business relationship with Silpada will be retained by Silpada until the later of, (1) termination of the Representative Agreement by either Silpada or the Representative or, (2) for as long as it is required under tax legislation to keep business records (which may be up to 7 years), and upon the expiry of which all personal information will be destroyed.

Amendments to Privacy Policy

Silpada regularly reviews its policies and procedures and may revise its Privacy Policy without notice. In the event of any such amendment, which will be in compliance with the applicable law, the appropriate notice will be posted on Silpada’s website.

Your continued use of our products or websites, or your continuing to act as a Silpada Representative following the posting of changes to this Privacy Policy, will signify your acceptance of those changes.

Contact

If you have any questions with respect to our policies concerning the handling of your personal information or if you wish to request access to or correct your personal information, please contact Silpada’s Privacy Officer at compliance@silpada.com.