Amplify Privacy Notice

This Amplify Privacy Notice (“Notice”) applies to the personal data collection and further processing by Amway GmbH, located at Benzstrasse 11b - c, D-82178 Puchheim, Germany (“Amway GmbH”) and its affiliates and subsidiaries (“Amway,” “we,” “us,” “our”) through the Amway Amplify mobile application (“Amplify App”), including while downloading and/or streaming the Amplify App. The Amplify App is an app developed for Amway Business Owners (“ABOs”) and potential ABOs (collectively “you”) to help them progress their professional development and trace the growth of a prospect into an ABO. This Notice explains how we process personal data collected from you via the Amplify App when you are in the European Economic Area (“EEA”). For purposes of applicable data protection laws in the EEA (“EEA Data Protection Legislation”), Amway GmbH is the data controller and therefore responsible for the collection and processing of your personal data in the context of the Amplify App.

Amway respects individuals’ privacy and values the confidence of its associates, customers, vendors and others with whom we do business. Amway strives to collect, use, disclose and otherwise process personal data in a manner consistent with the laws of the countries in which we do business, and we pride ourselves on upholding the highest ethical standards in our business practices.

We evaluate our privacy notices and procedures to implement improvements and refinements from time to time. If we make material changes to this Notice, we will notify you by means of a prominent notice on the Amplify App, by email, or by other communication means prior to the change becoming effective.

When Does This Notice Apply?

We will process personal data that we collect from you or that you provide to us via the Amplify App in accordance with this Notice.

This Notice does not apply to personal data that we collect from you in connection with your use of an Amway website. Please read our website privacy notice to find out more about such data processing. The Notice also does not apply to personal data that we collect from you in connection with the provision of Amway products and services. Please refer to the separate privacy notice(s) issued to you on that occasion. 

Personal Data We Collect

We collect and process the following information about you in relation to the Amplify App:

Information you give to us: In order to start using the Amplify App, we ask you to give us your Amway party ID, ABO ID and user ID, your password, your email address, phone number, your country of registration (to the extent you have enabled the location settings on your device), image and product preferences and other profile information to launch the Amplify App. Depending on which functionalities of the Amplify App you choose to use, we ask you to give us your prospect and product pictures uploads, and your avatar name. More generally, you can also choose to give us your personal data when you fill out forms on the Amplify App, register for events through the Amplify App or correspond with us, for instance to report a problem in relation to the Amplify App, or when you choose to submit a “User Contribution”.

You may choose whether or not to provide us with your personal data, but the functionality of the Amplify App will only be available if we have certain personal data about you. If you do not provide us with the required personal data, you cannot register for and/or enjoy specific functionalities in the Amplify App.

Information we collect from you when you use the Amplify App: Each time you access the Amplify App we automatically collect information regarding your use of the Amplify App, including your user ID and password, your journey, game level and game/task completion data (displaying your progress in the game), your Leadership Development Points accumulation and development and redemption follow-up, your badge awards, your content views (for instance, your viewing of audio/video files in the Amplify App), your leaderboard position, your rating data for uploaded content (such as pictures), your interaction with third-party sites and links (such as Facebook, Twitter and Instagram), information on the device and browser you use to access the Amplify App, information on error messages that occur during your use of the Amplify App and your selection and purchase of Amway products through the Amplify App.

Location Information: You can choose whether or not to allow the Amplify App to collect and use real-time information about your device's location through the device's privacy settings. If you block the use of location information, some functionalities of the Amplify App may be unavailable or not function properly.

How We Use Your Personal Data

We process your personal data in order to:

1) perform our obligations under the agreement we have with you. The collection and processing of your personal data is necessary for us to provide you with the functionalities of the Amplify App;
2) comply with our legal obligations;
3) pursue 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 partners’ personal data for internal administrative purposes is typically considered a legitimate interest from the company’s perspective. We have carefully balanced our legitimate (business) interests against your data protection rights. If you wish to obtain more information on the balancing exercise we performed, please contact us by using the contact details below.

Where legally required, we will ask for your consent before collecting and further processing your personal data.

We use your personal data for the following purposes:

a) To verify your log-in details and enable you to launch the Amplify App;
b) To enable personalization of the Amplify App;
c) To register and enable your attendance at an Amway event;
d) To help you trace your professional development and learning experience;
e) To share User Contributions you posted on public areas of websites you access through the Amplify App;
f) To offer you all other functionalities of the Amplify App that you requested and to communicate with you to provide you with information about the products, services and features we offer through the Amplify App;
g) To notify you about changes to the Amplify App and this Notice;
h) To allow us to show you relevant content in the Amplify App;
i) To measure or understand the effectiveness of advertising we serve to you, and to deliver relevant advertising to you in the Amplify App;
j) To review, analyze and evaluate your use of (or your decision not to use) our products and services in order to develop and improve the quality of our offering and strengthen our relationship with you and our other existing and potential customers;
k) To ensure the technical security of the Amplify App;
l) To ensure that our data records are accurate and up to date;
m) To administer the Amplify App and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
n) To administer our legitimate internal management analysis, audit, forecasts and business planning and transactions;
o) To establish, defend or exercise our legal rights;
p) To comply with our legal, regulatory and internal governance obligations;
q) For quality, training and security purposes;
r) For market research, analysis and the development of statistics. 

In addition, you can direct us to share your personal data with other parties by authorizing us to link your Amplify App account with a third-party app (for instance, to send status updates to your Facebook, Instagram or Twitter account). Once you direct us to share your personal data with a third party, your data is (also) governed by the third-party’s privacy notices. You can revoke your authorization to share your data with the third party at any time in the Amplify App account settings.

Please note that when you post a User Contribution, you authorize us to publish or otherwise use that contribution on publicly accessible (third-party) websites you visit through the Amplify App. Amway has no control over the further processing of your User Contribution by such third parties.

How We Share Your Personal Data

Amway does not sell, rent or trade your personal data. Amway only shares your personal data with:

• Entities within the Amway group for which it is reasonably necessary or desirable to access and process your personal data;
• Other ABOs, to allow communication regarding Amway products, services and orders;
• Third-party service providers, such as providers of Infrastructure- or Platform- or Software-as-a-Service solutions, software development services, information system maintenance services, record management services or marketing services, social media service providers and reward certificate service providers;
• Third parties that require the data in connection with the sale, merger, bankruptcy, sale of assets or reorganization of our company; and
• Government authorities or other third parties, if required by law, upon official request, or where reasonably necessary to protect the rights, legal interests, property or safety of others or ourselves. 

International Data Transfers

We transfer the personal data we collect about you to entities within the Amway/Alticor group, including Amway’s parent company Alticor Inc., and to third-party service providers and other recipients as mentioned above. Some of these recipients are located in countries other than the country in which the data were originally collected. The laws in those countries may not offer the same level of data protection as the country in which you initially provided the data. When we transfer your personal data outside of the country of original data collection, we will protect that data as described in this Notice and in accordance with applicable law, and we will put in place data transfer mechanisms (e.g., data transfer agreements) where necessary.

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 Standard Contractual Clauses or another appropriate data transfer mechanism to protect your personal data. For more information on the locations of the Amway group entities, please visit https://www.amwayglobal.com/  Please contact us using our contact details provided below, if you have any questions with respect to the safeguards we have put in place to protect your personal data when transferred outside the EEA (including if you wish to obtain a copy of or consult these safeguards).

How We Protect Your 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 Your Personal Data

We store personal data for as long as necessary to fulfil the purposes for which we collect the data (see above under “How We Use Your Personal Data”), usually for the duration of any contractual relationship and for any period thereafter as legally required or permitted by applicable law. This means that, in some cases, we may be required to store your personal data for a period of time following termination of your relationship with us. Please contact us using our contact details provided below, if you have any questions with respect to our data retention practices.

Children

The Amplify App is not intended for, directed at or offered to children within the meaning of EEA Data Protection Legislation, and we do not knowingly collect personal data from children. If we learn we have collected or received personal data from a child in the EEA, we will immediately delete that data. If you believe we might have received personal data from or about a child in the EEA, please contact us using the contact details below.

Your Data Protection Rights

Your rights under EEA Data Protection Legislation 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 have your personal data transmitted to you or to another company. Where we have obtained your consent for processing personal data, you have the right to withdraw your consent at any time. This will not affect the lawfulness of the processing that took place based on your consent prior to the withdrawal. To exercise these rights, you should submit a written request using the contact details below. If you are not satisfied with the way we have handled your request, you can lodge a complaint with the supervisory authority in your country.

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.

How to Contact Us

If you have any comments or inquiries about this Notice, if you would like to update any information we have about you, or if you would like to exercise your rights, you can contact our Data Protection Officer at privacy@amway.com.

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