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Privacy Statement

bodykey by NUTRILITE™ Privacy Policy

Effective Date: May 2018

This Privacy Policy describes how Amway GmbH, Benzstrasse 11 b-c, D-82178 Puchheim (hereinafter “Amway”) uses personal data collected or received from users (“Users”) of the bodykey by NUTRILITE™ weight loss programme (the “bodykey”).

It describes how we may collect or receive your personal data, the types of personal data we may collect, how we use, share and protect these data, how long we retain these data your rights, and how you can contact us about our privacy practices.

 

How We May Collect or Receive Personal Data from You

Registration. We collect your personal data through the registration form and the form “Design My Plan” that you complete and send to us in paper form or electronically through the bodykey website or app (the “Website”) in order to join bodykey weight loss programme.

Logged in as User. If you are logged in on the Website or the app as User we may collect your personal data from you, for example, when you update your personal information.

Contacting Us. You may also choose to submit your personal data and other information to us through various communication channels, for example, via e-mail, telephone 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 cookies are not essential for our website to function and are generally used to provide, maintain and improve our services.

 

Cookie name

Purpose

 Adobe Measurement 

This cookie is used in order to collect information about the visitors’ use of our websites. All data collected via this cookie is anonymous and not user specific. Information includes the number of visitors to the site, where visitors have come from and which pages they have viewed.

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. 

 

The Types of Personal Data We May Collect

We may collect the following personal data from you:

·         Contact information (e.g., name, postal or e-mail address, fax number and phone number);

·         Gender, age;

·         Family situation working situation (e.g. full-time, part-time);

·         Body measurements (e.g. height, weight);

·         Weight goal;

·         Username, password;

·         bodykey unique code;

·         Nutrition preferences,

·         Information on physical activity;

·         Messages to other users of the website;

·         Communication preferences; and

·         Your website usage, IP-address, browser type and operating system.

We may collect other personal data in exceptional circumstances only. If we do need to process such personal data about you, we will make sure that there is a valid legal basis for doing so (e.g. your explicit 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; (ii) to comply with our legal obligations; or (iii) for the purpose of our legitimate interests, including operating, evaluating and improving our services; 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 customer’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 the personal data we obtain about you to:

·         Manage your registration;

·         Create and manage your online account and respond to your inquiries;

·         Provide suggestions on nutrition and physical activities;

·         Communicate with you;

·         Allow interaction between you and other users and/or visitors of the website (depending on your profile settings);

·         Perform statistical analyses and scientific research

·         Facilitate your use of the Website through the use of cookies (e.g. to remember log in details);

·         Improve the Website, including by tracking and monitoring your use of the Website through the use of cookies, and to diagnose problems with the software or hardware we use;

·         Enforce contractual terms and conditions.

 

How We May 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 within, or outside the European Economic Area (“EEA”); 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.

 

How We Protect Personal Data

We maintain appropriate technical and organisational security safeguards designed to protect the personal data you provide against accidental, unlawful or unauthorised destruction, loss, alteration, access, disclosure or use.

 

How Long We Retain Personal Data

We store personal data only 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 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 the Privacy Policy

We reserve the right to change this Privacy Policy at any time. If we change this Privacy Policy we will update the effective date and such changes will be effective upon posting.

 

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. If you are not satisfied with the way we handle your request, you may lodge a complaint with a supervisory authority.

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 Website Privacy/Cookie Notice, if you would like to update information we have about you, or to exercise your rights, you may contact your local affiliate via Email: InfoCenter-uk@amway.com or by letter: Amway (UK) Limited, 1st Floor North Suite, Willen House, Tongwell Street, Fox Milne, Milton Keynes, Buckinghamshire, MK15 0SB. You may also contact our Data Protection Officer by email (privacy@amway.com) or letter (Data Protection Officer, Benzstrasse 11 b-c, 82178 Puchheim, Germany).