Effective Date: May 2021
Amway Registered Customer Privacy Notice
This Privacy Notice describes how Amway International Inc. (“AII”) (7575 Fulton Street East, Ada, Michigan 49355, United States), Amway GmbH (Benzstrasse 11 b-c, 82178 Puchheim, Germany), and your local affiliate (insert postal address) (together, “Amway” or “we” or “us”) use personal data collected or received from customers (“Customers” or “you”). It describes how we collect or receive your personal data, the types of personal data we process, how we use, share and protect these data, how long we retain these data, your rights with respect to the processing of your personal data, and how you can contact us about our privacy practices. We act as joint controllers in relation to your personal data.
How We Collect and Receive Personal Data from You
Where we ask you to provide us with your personal data, we will indicate whether providing the personal data is a statutory or contractual requirement, or a requirement necessary to enter into and/or facilitating a contract, as well as whether you are obliged to provide the personal data and of the possible consequences of a failure to provide the personal data.
Amway collects and receives personal data from Customers in various ways, such as:
Registration. Amway collects your personal data through the registration form that you complete and send to us in paper form or electronically through the Amway websites (the “Website”) in order to become a Customer.
Logged in as Customer. If you are logged in on the Website as a Customer, we collect personal data that you provide to us while using the Website. For example, when you purchase products or services, we collect personal data.
Contacting Us. When you contact us through the various communication channels provided on the “Contact Us” webpage of the Website, we collect personal data and other information that you provide. Examples of such personal data include Amway e-mail addresses, telephone numbers or online forms.
The Types of Personal Data We Process
If you are registering as a Customer directly with Amway, we process the following types of personal data relating to you:
- Contact information (e.g., name, postal or e-mail address, social media handle, fax number and phone number);
- Date of birth;
- Login information incl. username, Amway ID and password; and
- Payment information (e.g., bank account, debit or credit card numbers, Paypal ID);
- Product preferences, purchasing habits, purchasing history, and spending behaviour; and
- Communication preferences.
In addition, when you communicate with us through various communications channels, we collect your contact details, such as your name, email address, address, telephone number, and/or fax number. You may also voluntarily provide other personal data in connection with your inquiries or comments. We encourage you, however, to provide no more personal data relating to you than is necessary in order for us to provide an appropriate response to your inquiries or comments.
We may process other personal data in exceptional circumstances only. If we need to process other types of personal data about you, we will make sure that you are informed about the processing of such personal data and that there is a valid legal basis for doing so (e.g., your consent).
How We Use the Personal Data We Collect
We only process your personal data to the extent it is necessary:
(i) For the performance of your agreement with us or in order to take steps at your request prior to entering into an agreement with us, including to:
- Manage your relationship with us as Customer from initial registration and throughout your time as a Customer;
- Create and manage your online account;
- Address your comments or inquiries;
- Process your orders of products or services;
- Fulfill our obligation to provide support to you;
- Communicate with you;
- Bring you in contact with ABO if you choose to be connected with an ABO (including providing your name, address, telephone number, or e-mail address, purchases, and purchasing history to your ABO);
- Perform accounting, auditing, billing, and collection activities; and
- Enforce contractual terms and conditions.
(ii) To comply with our legal obligations, including to:
- Comply with laws which require us to retain records; and
- Comply with any other laws which may be applicable to us.
(iii) For the purpose of our legitimate interests, including to:
- Operate, evaluate, and improve our products, business, and services, including by:
- Tracking and analyzing your use of products, materials, and/or services;
- De-identifying your personal data in order to carry out analysis on information which does not identify you; and
- Developing new products and services;
- Track, document, and evaluate participation in Amway trainings, meetings, and events;
- Prevent and protect you, us, and others against fraud, unauthorized transactions, claims, and other liabilities;
- Ensure compliance with company policies and industry standards; and
- Process personal data for internal administrative purposes.
When we process your personal data for these purposes, we have carefully balanced our organization’s legitimate interests against your data protection rights. You can obtain further information by contacting us at PrivacyOffice@amway.com.
How We Share Personal Data
Amway does not sell, rent, or trade your personal data. We do share your personal data among us as joint controllers and with:
- Related entities operating direct selling businesses around the world under the company name Amway, to whom it is reasonably necessary or desirable for Amway to disclose personal data;
- Your ABO (if you choose to be connected with an ABO), to allow communication regarding products, services and orders relating to the Amway business;
- Providers of infrastructure- or platform- or software-as-a-service solutions, software development services, information system maintenance services, record management services or marketing services;
- Logistics providers;
- Financial transactions service providers; and
- Government authorities or other third parties, if required or allowed otherwise by law or reasonably necessary to protect the rights, legal interests, property, or safety of you, others, or ourselves.
International Data Transfers
We transfer the personal data we collect about you to entities within the Amway organization, as well as to third-party service providers that process personal data on our behalf. Some of these companies and service providers are located in countries other than the country in which the personal data was originally collected. The laws of those countries may not have the same level of data protection as the country in which you initially provided the personal data. When we transfer your personal data to other countries, we will protect that personal data as described in this Privacy Notice and in accordance with applicable law.
For personal data originating from the EEA that are transferred to countries that have not been recognized by the European Commission as providing an adequate level of data protection, we have put in place contractual safeguards (based on the European Commission’s Standard Contractual Clauses for data transfers outside the EEA) or rely on an equivalent legal mechanism to ensure that your personal data remain protected. For more information on the safeguards we have put in place to protect your personal data when transferred outside the EEA (including how to obtain a copy or consult these safeguards), please contact us at PrivacyOffice@amway.com.
How We Protect Personal Data
We maintain appropriate technical and organizational security safeguards designed to, protect the personal data we process against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure, or use.
How Long We Retain Personal Data
We store personal data as long as necessary to fulfil the purposes for which we collect the data (see above under “How We Use the Personal Data We Collect”), except if required or allowed otherwise by law. Please contact us using our contact details provided below if you have any questions with respect to our data retention practices.
Updates to this Privacy Notice
Amway may update this Privacy Notice from time to time. We will notify you of any significant changes to this Privacy Notice on the relevant Amway websites, in official Amway publications, or through other appropriate communication channels. All changes shall be effective from the date of publication, unless otherwise provided in the notification.
Your Rights
Subject to the relevant legislative provisions, you have the following data protection rights:
The right to access
You have the right to obtain confirmation as to whether or not your personal data are being processed and, where this is the case, access to the personal data. You also have the right to ask us for a copy of your personal data.
The right to rectification
You have the right to ask us to rectify personal data about you that you think are inaccurate. You also have the right to ask us to complete data you think are incomplete. This right always applies.
The right to erasure
This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your data where there’s no compelling reason for us to keep using the data. This is not a general right to erasure; there are exceptions, e.g. if we have a legal obligation to keep your data.
The right to restriction of processing
You have the right to ask us to restrict the processing of your personal data in certain circumstances.
The right to data portability
This right only applies to personal data you have given us. You have the right to ask that we transfer the data you gave us to another organization or give the data to you.
The right to withdraw consent
Where you have provided us with consent to process your personal data, you have the right to withdraw your consent at any time. This will not affect the lawfulness of the processing that has been carried out based on your consent prior to the withdrawal.
The right to object
When we process your personal data for purposes of pursuing our legitimate interests, you have the right to object to such processing at any time. If you object, we will stop the processing unless we have strong and legitimate reasons to continue using your data. Where we process your personal data for direct marketing purposes, you have the right to object at any time to such processing, including for profiling purposes to the extent that it is related to direct marketing.
If you would like to learn more about any of these rights, please contact us at PrivacyOffice@amway.com.
The right to lodge a complaint
If you have concerns about the way we handle or process your personal data, please contact our Privacy Office (contact details below) who will investigate the matter and report back to you. If you are still not satisfied after our response, depending on the law of the country where you live or work, you may have the right to complain to a data-protection regulator.
How to Contact Us
If you have any inquiries about this Privacy Notice, if you would like to update information we have about you, or if you wish to exercise your data protection rights, you may contact your local affiliate via the contact form or our Privacy Office by e-mail (PrivacyOffice@amway.com).
Effective date: [X] March 2021
Amway Website Visitor Privacy/Cookie Notice
This Privacy Notice describes how Amway International Inc. (“AII”) (7575 Fulton Street East, Ada, Michigan 49355, United States), Amway GmbH (Benzstrasse 11 b-c, 82178 Puchheim, Germany), and your local affiliate (insert postal address) (together, “Amway” or “we” or “us”) use personal data collected or received from visitors (“Visitors” or “you”) of this website (“Website”). It describes how we collect or receive your personal data, the types of personal data we process, how we use, share and protect these data, how long we retain these data, your rights with respect to the processing of your personal data, and how you can contact us about our privacy practices. We act as joint controllers in relation to your personal data.
If you are an Amway Business Owner (“ABO”), please read our ABO Privacy Notice accessible when you log in to the Website as an ABO, which includes information about how we process your personal data when you are logged in on the Website as an ABO. If you are a Registered Customer, please read our Registered Customer Privacy Notice accessible when you log in to the Website as a Customer, which includes information about how we process your personal data when you are logged in on the Website as a Customer.
How We Collect and Receive Personal Data from You
Where we ask you to provide us with your personal data, we will indicate whether providing the personal data is a statutory or contractual requirement, or a requirement necessary to enter into and/or facilitating a contract, as well as whether you are obliged to provide the personal data and of the possible consequences of a failure to provide the personal data.
Amway collects and receives personal data from Visitors in various ways, such as:
Contacting Us. When you contact us through the various communication channels provided on the “Contact Us” webpage of the Website, we collect personal data and other information that you provide. Examples of such personal data include Amway e-mail addresses, telephone numbers or online forms.
Cookies. We also use cookies or similar technologies that collect certain Website usage information when you access, view, and use the Website. A cookie is a data file placed on a computer or mobile device when it is used to visit websites. We do not enable third parties to place cookies on your device. As long as you do not log on to our services, your data is anonymous, and we cannot link any provided information to you. The table below provides an overview of the cookies we use and why we use them.
- The following cookie is essential for our Website to function.
| Name | Duration | Purpose |
|---|---|---|
| SS-SERVER-ID | Session | To provide load balancing functionality |
| AWSELB | Session | To load balancing functionality |
| JSESSIONID | Session | To keep the technical session tracked |
| isMarketingCookiesAccepted | 1 year | To store cookies acceptance information |
| isCookieConsentAccepted | 1 year | To store cookies acceptance information |
| isAnalyticsCookiesAccepted | 1 year | To store cookies acceptance information |
| product_sort | 11 years 5 months | To store sorting information |
| grid_product_layout | 11 years 5 months | To store products layout information |
| acceleratorSecureGUID | Session | To enable security mechanisms |
- The following cookies are required to gather statistics and analyze website functionality
| Name | Duration | Purpose |
|---|---|---|
| dtCookie | Session | To track across multiple requests |
| dtLatC | Session | To measure latency for server performance monitoring |
| dtPC | Session | To identify the correct endpoints for beacon transmission; contains the session ID for correlation. |
| dtSa | Session | Intermediate store for page-spanning actions |
| rxVisitor | Session | Visitor ID to correlate sessions |
| rxvt | Session | Session timeout |
- The following cookies are used for analytic purpose, for services which we are using: Tealium, Qualtrics survey, Heap Analytics, Lucky Orange
| Name | Duration | Purpose |
|---|---|---|
| _hp2_id.* | 1 year 1 month | User cookie (stores user_id, identity, other ids) |
| _hp2_props.* | 1 year 1 month | Event properties cookie (stores properties set by addEventProperties API) |
| _hp2_ses_props.* | 30 min | Session properties cookie (stores timestamp and cookie domain/path) |
| utag_main | 1 year | To record a time stamp of when you visit to our site has started, the number of pages you have viewed, the number of visits you have had to our site and a unique ID |
| _lorid | 10 min | ID of the visitor's current recording |
| _lo_uid | 2 years | Unique identifier for the visitor |
| _lo_v | 1 year | Total number of visitor's visits |
| __lotr | 6 months | URL of the visitor's original referrer, if any |
| __lotl | 6 months | URL of the visitor's original landing page, if any |
| QSI_SI_ |
3 months | This cookie is used to track whether we should display the Intercept on repeated user visits |
| QST | 6 months | Persistent cookie used for preventing multiple responses |
- The following cookies are used for sharing the site content on social media.
| Name | Duration | Purpose |
|---|---|---|
| __atuvc | 1 year 1 month | These cookies are associated with the AddThis social sharing widget which is commonly embedded in websites to enable visitors to share content with a range of networking and sharing platforms |
| __atuvs | 30 min | |
| loc | 1 year 1 month | |
| uvc | 1 year 1 month |
- The following cookies are used for fraud prevention and bot management
| Name | Duration | Purpose |
|---|---|---|
| bm_sv | 1 hour 40 min | These cookies are used to analyse traffic to determine if it is automated traffic generated by IT systems or a human user |
| _abck | 1 year | |
| bm_mi | 1 hour 40 min | |
| bm_sz | 3 hours 40 min | |
| ak_bmsc | 1 hour 40 min |
- The following cookie is used for spam and abuse protection
| Name | Duration | Purpose |
|---|---|---|
| _GRECAPTCHA | 6 months | SPAM protection service provided by Google that helps protect websites from spam and abuse. It may analyse traffic, (potentially containing Users’ Personal Data) with the purpose of filtering the parts of traffic recognized as Bots or SPAM and “keeping automated software from engaging in abusive activities on your site”. |
You may disable cookies in your browser’s settings (e.g., under the “Preferences” or “Internet Options” features of your browser). Note, however, that some features of the Website may not function properly if you disable the use of cookies. For detailed information on how to manage or delete cookies, visit http://www.allaboutcookies.org/.
The Types of Personal Data We Process
Through the cookies listed above under the section “How We Collect or Receive Personal Data from You” we collect information regarding your Website usage, IP-address, browser type and operating system.
In addition, when you communicate with us through various communications channels, we collect your contact details, such as your name, email address, address, telephone number, and/or fax number. You may also voluntarily provide other personal data in connection with your inquiries or comments. We encourage you, however, to provide no more personal data relating to you than is necessary in order for us to provide an appropriate response to your inquiries or comments.
We may process other personal data in exceptional circumstances only. If we need to process other types of personal data about you, we will make sure that you are informed about the processing of such personal data and that there is a valid legal basis for doing so (e.g., your consent).
How We Use the Personal Data We Collect
We only process your personal data to the extent it is necessary:
(i) For the performance of an agreement with us or in order to take steps at your request prior to entering into an agreement with us;
(ii) To comply with our legal obligations, including to:
- Comply with laws which require us to retain records; and
- Comply with any other laws which may be applicable to us.
(iii) For the purpose of our legitimate interests, including to:
- Address your comments or inquiries;
- Communicate with you;
- Operate, evaluate, and improve our products, business, and services, including by:
- Tracking and analyzing your use of our services;
- De-identifying your personal data in order to carry out analysis on information which does not identify you; and
- Improving our services;
- Prevent and protect you, us, and others against fraud, unauthorized transactions, claims, and other liabilities;
- Ensure compliance with company policies and industry standards; and
- Process personal data for internal administrative purposes.
How We Share Personal Data
Amway does not sell, rent, or trade your personal data. We do share your personal data among us as joint controllers and with:
- Related entities operating direct selling businesses around the world under the company name Amway, to whom it is reasonably necessary or desirable for Amway to disclose personal data;
- Providers of infrastructure- or platform- or software-as-a-service solutions, software development services, information system maintenance services, record management services or marketing services;
- Government authorities or other third parties, if required or allowed otherwise by law or reasonably necessary to protect the rights, legal interests, property, or safety of you, others, or ourselves.
International Data Transfers
We transfer the personal data we collect about you to entities within the Amway organization, as well as to third-party service providers that process personal data on our behalf. Some of these companies and service providers are located in countries other than the country in which the personal data was originally collected. The laws of those countries may not have the same level of data protection as the country in which you initially provided the personal data. When we transfer your personal data to other countries, we will protect that personal data as described in this Privacy Notice and in accordance with applicable law.
For personal data originating from the EEA that are transferred to countries that have not been recognized by the European Commission as providing an adequate level of data protection, we have put in place contractual safeguards (based on the European Commission’s Standard Contractual Clauses for data transfers outside the EEA) or rely on an equivalent legal mechanism to ensure that your personal data remain protected. For more information on the safeguards we have put in place to protect your personal data when transferred outside the EEA (including how to obtain a copy or consult these safeguards), please contact us at PrivacyOffice@amway.com.
How We Protect Personal Data
We maintain appropriate technical and organizational security safeguards designed to, protect the personal data we process against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure, or use.
How Long We Retain Personal Data
We store personal data as long as necessary to fulfil the purposes for which we collect the data (see above under “How We Use the Personal Data We Collect”), except if required or allowed otherwise by law. Please contact us using our contact details provided below if you have any questions with respect to our data retention practices.
Links to Other Websites
The Website may contain links to websites maintained by third parties, whose information and privacy practices are different than ours. We are not responsible or liable for the information or privacy practices employed by such third parties. We encourage you to read the privacy statements of all third party websites before using such websites or submitting any personal data or any other information on or through such websites.
Updates to this Privacy Notice
Amway may update this Privacy Notice from time to time. We will notify you of any significant changes to this Privacy Notice on the relevant Amway websites, in official Amway publications, or through other appropriate communication channels. All changes shall be effective from the date of publication, unless otherwise provided in the notification.
Your Rights
Subject to the relevant legislative provisions, you have the following data protection rights:
The right to access
You have the right to obtain confirmation as to whether or not your personal data are being processed and, where this is the case, access to the personal data. You also have the right to ask us for a copy of your personal data.
The right to rectification
You have the right to ask us to rectify personal data about you that you think are inaccurate. You also have the right to ask us to complete data you think are incomplete. This right always applies.
The right to erasure
This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your data where there’s no compelling reason for us to keep using the data. This is not a general right to erasure; there are exceptions, e.g. if we have a legal obligation to keep your data.
The right to restriction of processing
You have the right to ask us to restrict the processing of your personal data in certain circumstances.
The right to data portability
This right only applies to personal data you have given us. You have the right to ask that we transfer the data you gave us to another organization or give the data to you.
The right to withdraw consent
Where you have provided us with consent to process your personal data, you have the right to withdraw your consent at any time. This will not affect the lawfulness of the processing that has been carried out based on your consent prior to the withdrawal.
The right to object
When we process your personal data for purposes of pursuing our legitimate interests, you have the right to object to such processing at any time. If you object, we will stop the processing unless we have strong and legitimate reasons to continue using your data.
If you would like to learn more about any of these rights, please contact us at PrivacyOffice@amway.com.
The right to lodge a complaint
If you have concerns about the way we handle or process your personal data, please contact our Privacy Office (contact details below) who will investigate the matter and report back to you. If you are still not satisfied after our response, depending on the law of the country where you live or work, you may have the right to complain to a data-protection regulator.
How to Contact Us
If you have any inquiries about this Privacy Notice, if you would like to update information we have about you, or if you wish to exercise your data protection rights, you may contact your local affiliate via the contact form or our Privacy Office by e-mail (PrivacyOffice@amway.com)
Withdraw your consent
Where we have obtained your consent for the processing of your personal data, you have the right to withdraw your consent at any time. This will not affect the lawfulness of the processing that has happened based on your consent prior to the withdrawal.