We are Lifeplus Europe Ltd. Lifeplus Europe is the data controller and a data processor. Our nominated representative for data protection and the purposes of the General Data Protection Regulation (EU/2016/679) is Sam Arnold. Our registered office is Lifeplus House, Little End Road, Eaton Socon, St. Neots, Cambridgeshire, PE19 8JH, England. We may be reached at T +44 1480 224610; F +44 1480 224611; email to email@example.com .
Lifeplus Europe is a network marketing company, whose business is the sale of food supplements and personal care products. We also provide information regarding personal care, nutrition and healthy living. A “Customer” is a person or other entity that has purchased a product from us within the previous thirteen months. A “Business Builder” is a Customer who has elected to join the Lifeplus business opportunity. Lifeplus Business Builders are independent business people who earn commissions by referring our products to others who then become Customers.
The primary function of Lifeplus Europe is the fulfilment of Customer orders. In order to accomplish this, we collect the following personal data from our Customers:
- Name, street address, city, postcode, country
- Shipping address, if different
- Telephone and fax numbers
- Email address – while this is not required to fulfill an order, if given, it will permit us to send the Customer status and tracking information on their order
- Payment information (credit card number, expiry date and CVV, or bank account details for direct debit)
- The Lifeplus Personal Identification Number (PIN) of the person who introduced the Customer to Lifeplus (the “sponsor”) which is required in order to determine who should receive commissions on the order
- For gifting orders, whereby a Customer places an order as a gift for a third party recipient (not necessarily a Lifeplus Customer), the name and shipping address of the individual receiving the gift (“Gift Recipient”)
- We will also maintain and occasionally access, for direct marketing purposes, a historical record of all purchase transactions made with Lifeplus.
As a Customer, we will process your personal data for the following purpose:
- Order fulfillment: your purchase of and payment for products establishes a CONTRACT with Lifeplus Europe, which is the lawful basis for this processing. In order to fulfill an order, we must also give your personal information to the shipping company that will transport and deliver it, and the credit card processor or bank, from whom we will receive your payment for the order. In addition to the products you ordered, Lifeplus may include product and business literature and other promotional items such as but not limited to, catalogues, welcome packs, magazines and offers.
If you are also a Business Builder, we will collect additional information as follows:
- Bank account details (if different) to send you electronically transmitted commission payments
- Email address (if different) to send you monthly commission statements
- National Identification Numbers and fiscal information, where required.
As a Business Builder, we will process your data for the following additional purpose:
- Payment of Commissions: when you became a Business Builder, we entered into a CONTRACT with you, which is the lawful basis for this processing. That Contract obligates us to pay you commissions in accordance with our compensation plan on the purchases of products by Customers who you have referred to Lifeplus Europe, and on the purchases of products by other Customers who they may also have referred.
As a Business Builder, you may choose to share certain other personal data with us, such as your birthday, the name of your spouse/partner, etc. We will collect and electronically file this information. We have a LEGITIMATE INTEREST as the lawful basis in retaining and using this information conversationally, as a means of strengthening our personal relationship with you, which is a fundamental business building practice of Lifeplus. On your birthday we may send you a card or other remembrance.
We may also process your personal data for other purposes, as set out in the paragraphs below:
- Promotion to Customers: as a Customer, if you have chosen to provide your email address, Lifeplus will send you occasional emails advising you of new Lifeplus products or product promotions. We will offer you an opt-out in all electronic communications in accordance with the Privacy and Electronic Communications Regulation (PECR).
- Promotion to Business Builders: Lifeplus Europe will send you occasional emails advertising our annual meeting/convention or recognition and fund-raising events. In addition, upon attaining certain ranks within the organization, you will receive certificates, pins or other recognition items through the mails or by courier. Gold and Diamond Business Builders receive a monthly email, briefing them on new developments within the company, including upcoming events and new product introductions. We have a LEGITIMATE INTEREST in marketing these activities, which is the lawful basis for this processing. Business Builders are the source of new Lifeplus Customers, and they must be kept aware of developments within the company.
- Training and Quality: Lifeplus Europe will process your personal data for training and quality purposes. Personal data will be collected directly from you, or collected from telephone calls (live and / or recorded), emails or other written communications received from you, and may be used by all areas of Lifeplus Europe. Our lawful basis for processing your personal data in this way is LEGITIMATE INTEREST, in order for us to be able to review and improve all areas of the business, and your experience as a customer of Lifeplus Europe. Your personal data may also be shared with limited third parties for quality and training purposes, specifically the provision of customer satisfaction surveys carried out by telephone.
Where the lawful basis for processing your personal data is Legitimate Interest, you have the right to object to receiving this information at any time.
- Reporting to Business Builders. We provide a monthly Commission Statement by email, which lists the names of Customers whose purchases contributed to the Business Builder’s commissions, showing the amount of commissions earned from each Customers’ purchases. The lawful basis for this report is LEGITIMATE INTEREST, since Lifeplus is obligated to provide sufficient information for the recipient to be able to determine that they were properly compensated. Lifeplus Teams is an online, real-time report showing the name and total current business volume for each Customer in the Business Builder’s sales organization, along with their address and telephone number. The lawful basis for this report is LEGITIMATE INTEREST. Since Lifeplus revenues are closely tied to the activities of its Business Builders, this report is provided for them to manage their business.
- Compliance with European Union and Member States’ Obligations. Lifeplus Europe operates in many EU Member States and is subject to various mandatory reporting requirements which require us to share your personal data with governmental, taxation and other lawful authorities, such as for VAT and reports of individual earnings. The lawful basis for this processing is LEGAL OBLIGATION.
- Transfer of Personal Data Outside the EEA. The Lifeplus group is a worldwide organization, with its corporate headquarters in the United States. Our primary data centre is located at 30 Industrial Drive, Batesville, AR 72501 USA, and processing for commission statements and the Lifeplus Teams online management report occurs there. To facilitate this processing, personal data that we collect from you will be transferred and stored in the USA, as well as in the UK. The lawful basis for this processing is LEGITIMATE INTEREST. Since Lifeplus maintains a worldwide compensation plan, Business Builders may receive commissions from multiple countries. This data is consolidated in the USA where commissions processing occurs. Lifeplus USA has executed a contract with Lifeplus Europe that contains the standard data protection clauses referred to in GDPR Article 46.2. The contract may be viewed at http://www.lifeplus.com/media/pdf/mediacenter/LPE-LPIDataTransferAgreement.pdf. Personal data of EU persons is stored and processed in accordance with this contract.
As a Gift Recipient, we will process your personal data for the following purpose:
- Order fulfillment: The purchase and payment of a gifting order by a Customer for the benefit of a Gift Recipient creates a CONTRACT between Lifeplus Europe and the Customer, which is the lawful basis for this processing. In order to fulfill this order, your name and address must be provided to the shipping company that will transport and deliver this order. In addition to the products ordered, Lifeplus may include product and business literature and other promotional items such as but not limited to, catalogues, welcome packs, magazines and offers which are deemed to be appropriate to you as a Gift Recipient.
We do not obtain personal data from data brokers or other external sources (except as provided for in this Privacy Notice) and do not engage in automated decision making or profiling (which is the automatic processing of your data to analyze or predict your personal preferences or future behaviours). We also do not collect data or process the personal data of children. We do not sell or otherwise provide your personal data to others for advertising or any commercial purposes.
We do share your personal data with third parties with whom we do business in order to fulfill your orders and to accomplish other functions required to operate our business. These third parties include shipping companies who transport and deliver orders to you, credit card processors and banks that facilitate your payment for products that you order, governmental entities to whom we must report data, etc. We require third-party companies to have certified by contract or by letter signed by an authorized individual, that they comply with the provisions of the GDPR. You may view a specimen of our Third Party GDPR Declaration at www.lifeplus.com/media/pdf/dpa/dpa_en.pdf, which also includes a more complete listing of types of third parties with whom we share data.
You have certain rights with respect to your personal data that we collect and store. Among these are the right to withdraw consents that you may have given and the right to lodge a complaint with a supervisory authority in the Member State of your habitual residence. You also have other specific rights: the right to be informed, the right to object, the right to restrict processing, the right to erasure, the right to rectification, and the right to data portability. Our Customers’ Rights Policy may be viewed at www.lifeplus.com/web-page/privacy-rights.
We will retain your personal data only for as long as is necessary for us to complete the specific purpose for which it was received. For details, see our Data Retention Policy which may be viewed at www.lifeplus.com/web-page/privacy-retention.
This Privacy Notice is published on all Lifeplus websites at www.lifeplus.com/web-page/privacy-notice and is regularly reviewed.
Should you have any concerns or queries regarding this Privacy Notice or how personal data is processed at Lifeplus, please contact firstname.lastname@example.org.
Lifeplus Europe Limited
Registered in England, Company No. 3231785