Data and cookies

This platform sets one kind of cookie: the session cookie that keeps you signed in. It holds your authentication token, nothing else, and without it the platform cannot know who you are from one page to the next.

There is no analytics, no advertising and no third-party tracking anywhere in this application, so there is nothing optional to turn off. That is also why you are not asked to consent to cookies: a cookie that is strictly necessary to deliver a service you asked for does not require consent, and asking for consent you cannot refuse without losing access would not be a real choice.

Signing out clears the cookie. So does clearing site data in your browser.

Three kinds, and they are not the same:

• People with a login. Name, work email address, role, which distributors you are attached to, when you last signed in, and the date you acknowledged this notice. This includes sales representatives who have been given a login.
• Sales representatives. Name, the distributor they work for, and their reported monthly haircare and colour sales and account counts. Representatives are named in their distributor’s return and appear in a performance ranking. Most do not have an account here; ELEVEN sales can give some a login (see “Sales representatives with a login”).
• Retailers. Business names, their reported sales and the number of doors. This is company information rather than personal data, except where a contact name has been entered.

Everything else the platform holds is commercial: monthly sales figures by distributor, country and product category.

ELEVEN Australia needs to know how its products sell through in each market to manage its distribution agreements, plan supply and measure performance. The figures used to arrive by spreadsheet; this platform replaces that.

The lawful basis is the contract between ELEVEN and each distributor, and ELEVEN’s legitimate interest in managing its distribution network. It is not consent, which is worth stating plainly, because it means acknowledging this notice does not give permission that could later be withdrawn to make the records go away. Your rights over that data are set out below and are unaffected.

ELEVEN Australia staff with an account can see all markets. A distributor can see every country’s sales totals and the sales representatives of every distributor, with their names and sales figures, so each market can compare itself with the others. Each representative’s total units sold are visible to every distributor; from these and the sales figures a distributor’s unit prices can be estimated. The split of units between haircare and colour, a distributor’s retailers and the detail behind its own reports are visible only to that distributor and to ELEVEN Australia. In a country with more than one distributor, the others there can work out a distributor’s share from the country total and its representatives’ figures.

These limits are enforced by the database itself, through row-level security, rather than by the screens alone. Other distributors’ figures reach a distributor only as country and representative totals, never as the underlying reports. A query that forgot to filter would still return nothing it should not. There is no administrative key in the application that can bypass it. Attempts to open another distributor’s pages, and addresses that look like attacks, are recorded for security.

The database is hosted by Supabase in the European Union (Ireland). The application itself is served by Vercel. No data is sold, and none is shared with anyone outside ELEVEN Australia and the distributor it belongs to.

Sales records are kept for as long as ELEVEN trades with the distributor, and afterwards for as long as accounting and contractual record-keeping require. Accounts are removed when someone stops working with the platform.

Your name and your monthly sales figures may be held here because your distributor reports them to ELEVEN Australia as part of its agreement. You did not give that information to ELEVEN directly and you may not have an account on this platform. This page is public so that people without an account can read it: it is how you get told. If you have been given a login, see “Sales representatives with a login” below.

Your name and sales figures are also visible to other distributors that use the platform, and to sales representatives with a login, in the ranking of sales representatives.

You can ask what is held about you, ask for it to be corrected, or object to it being held. Contact your distributor, or ELEVEN directly at the address below.

ELEVEN sales can give a distributor’s sales representative a login. If you have one, ELEVEN stores your email address, entered by ELEVEN sales; a distributor cannot set it. You sign in with a one-time code sent to that address, and your sign-ins are recorded like those of any other login.

A representative login shows the Disruptors leaderboard, the ranking of sales representatives, and nothing else. It is the same view distributors have, so you can see other representatives’ names and sales figures across every country. Your own name and figures were already visible to distributors before you had a login. You can download the leaderboard as Excel or PDF.

To have your login removed, or to ask about your data, write to info@elevenaustralia.com.

You can ask for a copy of your personal data, ask for it to be corrected or deleted, ask that its use be restricted, or object to it. Where deletion would conflict with ELEVEN’s record-keeping obligations, you will be told so and why rather than simply refused.

You can also complain to your national data protection authority.

ELEVEN Australia, EMEA: info@elevenaustralia.com