Regulation on the processing of personal data
1. Amway Privacy Notice for Amway Business Owners and Members
This Privacy Notice describes how Amway LLC, 107140, Moscow, Krasnoselskaya Verkhn., house 3, building 2, floor 2, room I, room. 1.15-23.26.27 (hereinafter “Amway”) uses personal data collected or received from Amway Business Owners (“ABOs”) and Members. 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.
The Notice is mandatory for familiarization by persons who transfer personal data to Amway. The current version of the Regulations is posted on the Amway website in the public web-site, and takes effect from the moment it was posted.
2. How We Collect and Receive Personal Data from You
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 website (the “Website”) in order to become an ABO or Member.
Logged in as ABO or Member. If you are logged in on the Website as an ABO or Member we collect personal data that you provide to us while using the Website, for example, when you order products or services.
Contacting Us. You may also choose to submit your personal data and other information to us through various communication channels provided on the “Contact Us” webpage of the Website, for example, Amway e-mail addresses, telephone numbers or online forms.
Amway processes personal data on the bases of the following documents:
- Constitution of the Russian Federation from 12.12.1993;
- Federal Law “On Accounting” dated December 06, 2011 No. 402-ФЗ;
- Tax Code of the Russian Federation;
3. The Types of Personal Data We Process
We process the following types of personal data relating to you:
- Contact information (e.g., name, postal or e-mail address, fax number and phone number);
- ABO or Member organizational information (e.g., ABO company name, profession and ownership and management details);
- Gender, age, citizenship, date and place of birth;
- Marital Status
- ABO or Member registration number, username and password;
- Passport details (including number, issue date, issue location and expiration date) and National ID number to the extent permitted or required by applicable law;
- Payment information (e.g., such bank account or credit card numbers);
- ABO or Member performance information (e.g., class, status, group and personal qualifications under the Amway Sales and Marketing Plan and financial/bonus history);
- Product preferences, purchasing habits, purchasing history and spending behaviour; and
- Communication preferences.
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 your personal data and that there is a valid legal basis for doing so (e.g. your consent).
4. Categories of subjects whose personal data are processed by Amway
Amway is processing the following personal data:
- Registered Client;
- VIP Client;
- VIP+ Client;
- Designated person;
- Website Visitor;
- Amway contractor;
- as well as representatives of the above categories.
5. 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; (ii) to comply with our legal obligations; or (iii) for the purpose of our legitimate interests, including operating, evaluating and improving our business; preventing and protecting us and others against fraud, unauthorized transactions, claims and other liabilities; and ensuring compliance with company policies and industry standards. For companies like Amway that have global business operations, processing business partner’s personal data for internal administrative purposes is typically also considered a legitimate interest. As required under law, we have carefully balanced our legitimate business interests against your data protection rights.
In particular, we process personal data we obtain about you to:
- To manage your registration as an ABO or Member. Click here https://www.amway.ru/en/start-a-business-new to learn more;
- To manage your registration as a Client, VIP Client, VIP+ Client. Click here https://www.amway.ru/en/start-a-business-new to learn more;
- Create and manage your online account and respond to your inquiries;
- Process your orders of products or services;
- Communicate with you (e.g., about products or services that we offer, or intend to offer);
- Operate, evaluate and improve our services, including by:
- Evaluating your satisfaction with our current communications, materials, products and/or services;
- Tracking and analyzing your use of products, materials and/or services; and
- Developing new products and services.
- Track, document and evaluate participation in Amway meetings and events;
- Assessing your performance under your Amway Business or Member Registration Agreement with us;
- Provide business performance information to you;
- Provide your contact information, business identification information and business performance information to upline ABOs, and contact information to downline ABOs or Members;
- Perform accounting, auditing, billing and collection activities;
- Enforce contractual terms and conditions;
- Protect against and prevent fraud, unauthorized transactions, claims and other liabilities; and
- Comply with applicable legal requirements, industry standards and our policies;
- For statistical and other research purposes;
- For the publication and licensing of photographic and / or audio / video materials bearing your image and / or voice recording, as well as various utterances, and made for marketing or other legal purposes on any produced media for use on any media channels, including (without limitation): Internet, media, as well as brochures and advertisements, honor boards;
- For the organization of events and the organization of long-distance and international logistics for ABO and Clients.
6. How We Share Personal Data
Amway does not sell, rent or trade your personal data. Amway does share your personal data with:
- Entities within the Amway group to whom it is reasonably necessary or desirable for Amway to disclose personal data;
- ABOs, 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; and
- Government authorities or other third parties, if required by law or reasonably necessary to protect the rights, legal interests, property or safety of others or ourselves.
7. International Data Transfers
We transfer the personal data we collect about you to entities within the Amway group, including Amway GmbH (Benzstrasse 11b – c, D-82178 Puchheim), Amway’s mother company Alticor Inc. (7575, Fulton st., Ada, Michigan, 49355, USA). You can find a list of countries in which the Amway Group of Companies is represented by clicking on the link: https://www.amwayglobal.com/. Some data may be stored on the territory of other countries. The level of protection of personal data in these countries may be different compared with the Russian Federation. By transferring your data to such countries, Amway will ensure the security of your data, as specified in these Notice, in accordance with applicable law. Amway includes provisions for ensuring the security of transmitted personal data in contracts with companies to which such data will be transferred.
If you have any questions about the procedure for ensuring the security of your data during transmission abroad, you can use the feedback form on the Amway website or send a request to the Amway legal address.
8. Procedure for processing personal data
By submitting personal data (including filling out the relevant forms on the website), the subject of personal data gives its consent to the processing of personal data, namely the collection, recording, systematization, accumulation, storage, refinement (update, change), retrieval, use , transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction with the use of automation equipment and without it in Amway, as well as the Amway group of companies, including consent to the transboundary transfer in accordance with section 6 of the Regulations.
The ABO and the registered Client in case of the processing of personal data of third parties, including the Designated persons, and their subsequent transfer to Amway, undertake to familiarize such persons with this Notice, as well as to receive from these persons a written consent to the transfer and further processing by Amway and / or a group of companies Amway personal data in the manner and on the terms established by Amway, the agreements entered into by the ABO with Amway. The ABO and the registered Client undertake, upon request of Amway, to provide written confirmation of receipt of consent for the processing of personal data of such persons.
In case this clause or other rules for the processing of personal data will not be fulfilled and / or Amway will have reason to believe that such rules were not fulfilled, measures may be applied to the ABO according to Amway internal regulations, until the contractual relationship between ABO and Amway is terminated.
The processing of personal data by ABOs is necessary for the purposes related to the execution of the Amway Contract, including the maintenance of an international sponsorship line, support for international sponsorship, and the calculation of remuneration, if any.
When storing personal data, Amway uses databases located within the territory of the Russian Federation.
The security of personal data in Amway is ensured by the implementation of agreed measures aimed at preventing (neutralizing) and eliminating threats to the security of personal data, minimizing possible damage, as well as measures to restore data and work personal information systems in case of threats.
9. 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. In Amway the following measures are taken to protect personal data:
- A person responsible for organizing the processing of personal data is appointed;
- The documents defining the policy regarding the processing of personal data are published and published;
- Identifies threats to the security of personal data during their processing;
- The effectiveness of measures taken to ensure the security of personal data is assessed prior to the commissioning of the personal data information system;
- Measures are being taken to eliminate the facts of unauthorized access to personal data;
10. How Long We Retain Personal Data
Amway stores personal data:
- during the term of the contractual relationship or consent,
- 3 (three) years after deleting of the personal account in the absence of contractual and other relations;
- 5 (five) years after the last financial transaction;
- for a longer period, in accordance with the law or the decision of the company. About this decision, the company notifies the subject of personal data.
11. 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.
12. Your Rights
Your rights under applicable law may include access to the personal data we process about you, the right to have such personal data corrected or erased, the right to restrict the processing of your personal data, as well as the right to data portability. 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. To exercise these rights, you should make a written request using our contact details set out below.
You also have the right to object, at any time, to the processing of your personal data which is based on Amway’s legitimate interests. 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 object to processing for direct marketing purposes, we will no longer process your personal data for such purposes.
13. How to Contact Us
If you have any comments or inquiries about this Privacy Notice, if you would like to update information we have about you, or to exercise your rights, you can contact us by sending a letter to the following address: Inforu@amway.com You can also contact the person responsible for processing personal data in Amway, sending an email PrivacyOffice@Amway.com or addressed to the Personal Data Manager. Legal address of the company: 107140, Moscow, Krasnoselskaya Verkhn., house 3, building 2, floor 2, room I, room. 1.15-23.26.27.