PRIVACY & DATA PROTECTION POLICY(AVG/GDPR)
1. INTRODUCTION
GOLIVEA(“GOLIVEA”, “we”, “us”, or “our”) respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, and share your personal information when you visit our website www.golivea.eu, purchase our products, or join us as an Independent Brand Ambassador.
This document fulfills our obligation to provide a “Clarification Text” regarding data processing under the General Data Protection Regulation (EU) 2016/679 (GDPR) and the Dutch Implementation Act (Uitvoeringswet AVG).
2. DATA CONTROLLER
The legal entity responsible for the processing of your personal data is:
- Company Name: Golivea B.V.
- Registered Address: Stroombaan 10, 1181VX, Amstelveen, The Netherlands
- Chamber of Commerce (KVK): 97870862
- Email: [email protected]
3. PERSONAL DATA WE COLLECT
We collect and process different categories of personal data depending on your relationship with us (Customer or Brand Ambassador):
- Identity Data: First name, last name, date of birth (for age verification).
- Contact Data: Billing address, delivery address, email address, telephone numbers.
- Financial Data: Bank account details (IBAN) for commission payments (Brand Ambassadors only), and payment transaction history.
- Profile Data: Username, password, purchases or orders made by you, your interests, preferences, and feedback.
- Technical Data: Internet Protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform.
4. LEGAL BASIS FOR PROCESSING
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
a. Performance of Contract: To process your orders, deliver products, and manage your Brand Ambassador Agreement (including calculating and paying commissions).
b. Legal Obligation: To comply with legal requirements, such as tax reporting to the Dutch Tax Authority (Belastingdienst) and consumer protection laws.
c. Consent: Where you have given explicit consent to receive marketing communications (as detailed in the “Commercial Electronic Message Consent”). You have the right to withdraw consent at any time.
d. Legitimate Interest: To prevent fraud, ensure network security, and analyze business performance to improve our services.
5. INTERNATIONAL DATA TRANSFERS (CROSS-BORDER)
GOLIVEA is part of a global organization. To provide our services, we may transfer your personal data to our parent company, affiliates, or service providers located outside the European Economic Area (EEA).
5.1. Transfer to Turkey
Your data (specifically sales volume, genealogy structure, and order history) may be processed by our operational headquarters in Turkey.
5.2. Legal Safeguards
Turkey is currently considered a “Third Country” by the European Commission regarding data protection adequacy. To ensure your data remains protected, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission. These clauses impose legally binding obligations on our non-EEA partners to protect your data according to EU standards.
6. DATA SHARING
We may have to share your personal data with the parties set out below for the purposes set out in this policy:
- Logistics Partners: (e.g., PostNL, DHL, UPS) to deliver your orders.
- Payment Service Providers: (e.g., Mollie, Adyen, Stripe) to process payments securely.
- Upline Sponsors: If you are a Brand Ambassador, limited data (Name, Rank, Volume) is visible to your direct Upline Sponsor to facilitate training and support within the network marketing structure.
- Professional Advisers: Lawyers, bankers, auditors, and insurers.
- Regulators: The Tax Authority (Belastingdienst) and other authorities who require reporting of processing activities in certain circumstances.
- Referring Brand Ambassadors: If you are a retail Customer, limited details of your purchase (such as your Name and Order Volume) are shared with the specific Brand Ambassador whose referral link or code you used. This sharing is strictly necessary for the performance of the direct sales model and to calculate the Ambassador’s commissions.
7. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
- Tax Records: Under Dutch tax law, we are required to keep certain administrative records including invoice and transaction data, for a period of 7 years.
- Marketing Data: We keep your data until you unsubscribe or withdraw your consent.
8. YOUR RIGHTS (GDPR/AVG)
Under the GDPR, you have the following rights regarding your personal data:
- Right of Access: Request a copy of the personal data we hold about you.
- Right to Rectification: Request correction of the personal data that we hold about you.
- Right to Erasure (“Right to be Forgotten”): Request the deletion of your personal data where there is no good reason for us continuing to process it (subject to legal tax retention periods).
- Right to Restriction: Request the restriction of processing of your personal data.
- Right to Data Portability: Request the transfer of your personal data to you or to a third party.
- Right to Object: Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
- You also have the right to object where we are processing your personal data for direct marketing purposes.
- Right to Lodge a Complaint: You also have the right to lodge a complaint with the supervisory authority in the Netherlands: Autoriteit Persoonsgegevens.
To exercise any of these rights, please contact us at [email protected]. We will respond within one month, unless the request is complex, in which case this period may be extended by up to two additional months in accordance with applicable law.
9. COOKIES
Our website uses cookies to distinguish you from other users.
- Functional Cookies: We use strictly necessary cookies to ensure our website functions securely (e.g., remembering your shopping cart). These do not require consent.
- Analytical & Marketing Cookies: We only place non-essential tracking or marketing cookies if you grant us explicit, prior consent via our Cookie Banner , in accordance with the Dutch Telecommunications Act. You can withdraw your consent or change your preferences at any time using the “Cookie Settings” link in our footer.
10. COMPLAINTS
You have the right to make a complaint at any time to the Autoriteit Persoonsgegevens (AP), the Dutch supervisory authority for data protection issues (www.autoriteitpersoonsgegevens.nl).
We would, however, appreciate the chance to deal with your concerns before you approach the AP, so please contact us in the first instance.