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Effective Date: [X] June 2020
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 (Benzstr. 11 b – c 82178 Puchheim, Germany) (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.
- The following cookie is essential for our Website to function.
|JSESSION||This cookie keeps the technical session tracked|
|AWSELB||This cookie is used for load balancing|
|Cart-content||This cookie stores cart details for Visitors|
- The following cookies are not essential for our Website to function and are generally used to provide, maintain, and improve our services.
|Language||This cookie remembers the default language for the user|
|These cookies are used in order to collect information about the Visitors’ use of our websites, including clickstream data and activity on the Website. Information collected includes the number of Visitors to the site, where Visitors have come from, and which pages they have viewed. All data collected via these cookies is anonymous and not user-specific until a user logs in as an ABO or customer.|
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.
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.