1. Amway’s position on personal information
Amway Japan G.K., 7-1 Udagawa cho, Shibuya-ku, Tokyo 150-0042, together with Amway International Inc., 7575 Fulton Street East, Ada, Michigan 49355, United States (collectively, “Amway” “we,” “our” or “us”) respect all laws and regulations covering the handling of personal information as well as governmental guidelines and other norms, and we have established and put into practice a Personal Information Protection Policy* and security control actions in order to ensure our compliance.
*Please see the Personal Information Protection Policy posted on our websites.

2. What information is collected & retained
Through the use of our services, inquiries and posts related to our products and campaigns on social media (both on our official account and accounts of the individuals) by the individuals who register as our ABOs, we collect and retain the information described below. This information includes not only information that we explicitly collect from individuals, but also information necessarily collected in the course of conducting Amway business (e.g. credits/debits against Amway and business situation) as well as information that is collected indirectly (e.g. use of websites, official social media accounts, and applications operated and/or provided by Amway as well as public information from government publications, such as official gazettes, and third-party discussions).
(1) Information entered or stated when registering (including business nature change), such as name, date of birth, address, telephone number, fax number, email address, account number, status of residence (for foreign nationals only), etc., and ABO number, and, information that was confirmed regarding clear indication of purpose of referral from upline ABO.
(2) Information about bonuses (e.g. monetary amount, PV/BV, payment timing, type, bonus details, etc.)
(3) Information about product orders/returns and pre-order of products (e.g. products placed in the shopping cart, products ordered/returned, products pre-ordered, payment amount, payment method/the number of installments, delivery destination, order details, etc.)
(4) Information (such as address, telephone number, reasons for change or resignation, etc.) from the change procedure for a change of address, change procedure for adding/removing a partner, or resignation procedure (including business nature change)
(5) The situation of taking the Program for Registration of ABOship and the program for renewal of ABOship and information about the business situation (e.g. business results, qualification achievements, group situation, order situation, problems, etc.)
(6) Information collected by Amway when contacting Amway (for various applications, consultation, inquiries, etc.)
(7) Information about whether or not an application for various types of credit has been withdrawn and the status/results of the screening process, which are provided by consumer credit companies, and information about unauthorized credit applications/unauthorized credit use and the status of ABOs’ outstanding payment obligations to the relevant consumer credit companies, which are provided voluntarily by the relevant consumer credit companies.
(8) Information voluntarily provided by the payment service providers when Amway Atobarai is used which is about unauthorized applications and uses and the status of ABOs' outstanding payment obligations to the relevant payment service providers.
(9) Information about liabilities/obligations against Amway (e.g. amounts of credits/debits, reasons for credits/debits, etc.)
(10) Information collected by us when the individuals register at a website operated by Amway or when they post to official social media accounts (e.g. email address, account name, etc.)
(11) Information automatically collected by us when the individuals use website operated by Amway, etc. (e.g. access logs described below, browsing activity history of websites including cookies, and adding/removing products in the shopping cart, etc.)
* We use cookies and similar technologies to collect usage information of certain websites, when users are accessing, browsing and using our website. Cookies are data files that are placed on the computer or mobile device of users when the computer or mobile device of users is used to visit a website. We do not allow third parties to place cookies on our website user’s device. Unless our website user log on to our services, such user’s cookie data is anonymous.
(12) Information collected by us as the individuals use a digital service provided by us or the parties specified in Section 6. (2)
(13) Video, photos, audio recordings taken during the recognition for qualification achievement, during events, or provided by the individual
(14) Information necessary to run/arrange overseas incentive seminars (e.g. information needed for travel, such as name and passport number, etc. shown on passport/travel documents)
(15) Information recorded at organizations operated by our ABOs
(16) Information included in posts related to our products and campaigns on social media by individuals (e.g. account name, description including personal information, photos, movie, responses to and from third parties, etc.)
Please note that we may record telephone conversations to ensure accuracy.

3. How we use personal information
We may use the information listed in Section 2 above for the following purposes, either inside or outside of Japan:
(1) To provide products and services (e.g. to deliver products/publications, provide after-sales service, calculate/pay bonuses, etc.), to provide various payment methods, to collect payments, and to communicate to individuals to implement those acts, associated with our transactions.
(2) To process the procedures necessary to carry out Amway business (e.g. procedures related to international business, collection of annual membership fees, changing registered information, screening for registration and management of registration status, etc.) and to provide support for Amway business.
(3) To provide information necessary to carry out Amway business (e.g. information about the business situation, information about product orders/returns, information about a group’s business situation, and information about pre-orders for products).
(4) To provide information on products handled by Amway and campaigns deemed beneficial by Amway based on history of purchase and pre-orders, and products in the shopping cart.
(5) To communicate or provide information for the purpose of confirming the status of doing Amway business, resolving a problem, compliance with, and enforcement of, Amway’s Code of Ethics and Rules of Conduct or encouraging business activity, irrespective of registration status for ABO.
(6) For announcing the holding of the qualification achievement recognition and other events, and reporting after such events.
(7) To record or manage requests for advice related to the individual, from the individual or a third party.
(8) To arrange for sending of gifts to the individuals in relation to the achievement of qualifications or campaigns, etc.
(9) To share with the parties specified in Section 6. (2).
(10) To conduct market research, record and analyze data on browsing activity history and purchase history, etc. that we collect (including browsing activities on the websites operated by Amway and the official social media accounts of Amway, and usage status such as adding and removing products from shopping carts), or surveys for the purpose of improvement, advertising measures, and sales promotion of our products and services, and the support to carry out Amway business.
(11) To arrange or run overseas incentive seminars or invitational seminars and events in Japan.
(12) To manage and improve the websites operated by Amway and the official social media accounts of Amway (including deletion of inappropriate posts and identifying posters thereof) and to maintain stable operation of the system.

4. Measures to protect personal information
We take appropriate measures from organizational, human, physical, and technical aspects to prevent incidents including the leakage, loss or damage of personal information/data that we handle and securely manage personal information/data. The outline of our security control actions is as stated in the Appendix 1. For further details of our security control actions, please make an inquiry to “Contact” shown at the end of this document.

5. Providing personal information to third parties
We provide personal information/data that we have collected and retained, whether inside or outside of Japan, either by mail or by using our own information systems or other means, as described below. In the cases where we provide personal information to foreign entities, please check the information provided by the Personal Information Protection Commission at its website (https://www.ppc.go.jp/personalinfo/legal/kaiseihogohou/#gaikoku ) for the systems in regard to the protection of personal information of the countries where those entities are located. For countries that are not listed on the webpage above, please contact us.
(1) Providing the following information to upline ABO as communications for the group follow-up necessary to carry out Amway business, for bonus calculation and for the support of proper product usage.
Name, ABO number, address, telephone number, fax number, email address, date of birth, registration date, membership expiry date, order history, pre-order history, business volume (e.g. PV/BV, bonuses, qualifications), renewal status, confirmation status regarding clear indication of purpose of referral, status of promotions/services provided by Amway, other business situation information (including usage status/trend of social media and analysis data thereof), "Inquiry invoice No." on the invoice related to product delivery, product usage.
* However, during a points compensation* period, the personal information associated with the relevant person or their downline ABOs will be provided to the relevant person’s original upline ABO. Additionally, during that time period the personal information associated with the relevant person or their downline ABOs may be provided to the relevant person’s current upline ABO.
* For information about the “Point Compensation System”, please refer to the “Amway Code of Ethics and Rules of Conduct”.
* In an international business, if there is an International Sponsor (IS) at an Amway’s affiliate in a foreign country, information may also be provided to that affiliate or the IS’s upline ABO.
For more information about “Amway’s affiliate in a foreign country” please refer to our website (https://www.amway.co.jp/about/company/global_markets/index.html).
(2) Providing the names of the upline ABO sponsoring directly and the immediate upline Platinum (PT) in the leg, their ABO numbers, addresses, telephone numbers, and email addresses to downline ABOs as communications for the group follow-up necessary to carry out Amway business and for the support of proper product usage.
(3) Disclosing the names, videos/photos, and information of qualification achievements by posting or exhibiting in various mass media, on websites operated by Amway, and within Amway.
(4) Providing name, date of birth, address, telephone number, email address, special care-required personal information when traveling, and other information that must be provided at the time of application that are necessary for arrangements, to domestic and foreign lodgings, transportation operators, travel agencies and other agents, etc. when arranging or running overseas incentive seminars, or invitational seminars and events in Japan.
(5) Providing consumer credit companies with our registered information (name, ABO number, address, telephone number), products ordered, order amounts, and the number of installment payments/applicable interest rates selected by the relevant applicant for the purpose of processing the application for credit use, and providing information about the user and use of the relevant credit for the purpose of fulfilling contractual obligations to the relevant consumer credit company in the event of suspicion of fraudulent application or use of credit.
(6) Providing Akuru Inc with the name, email address, terminal information (IP address, etc.) and a part of the credit card face information designated as a means of payment, used when purchasing products on the website operated by Amway, in order to use it by matching with the personal information of users held by Akuru Inc to the extent necessary to prevent fraud in credit card payments.
(7) Providing payment service providers of Amway Atobarai with our registered information (name, address, telephone number, email address) and order numbers/order amounts for the purpose of processing using post-pay for product amounts.
(8) Providing our business partners with information necessary to apply for products and services offered by such business partners, such as name, ABO number, address, telephone number, and email address, etc.
(9) Providing administrative agencies with the confirmation status regarding clear indication of purpose of referral by upline ABO, as needed.
(10) We may provide personal information without the individual’s consent under the following circumstances:
(a) When required by law or regulation
(b) When it is necessary to protect a person's life, physical person or property, but it is difficult to obtain the consent of the individual
(c) When it is especially necessary in order to improve public health or to promote child welfare, but it is difficult to obtain the consent of the person
(d) When it is necessary to cooperate with a national government agency or local governmental body, or a designee thereof, in discharging their legal duties, and when obtaining the individual's advance consent could impede the performance of such duties

6. Sharing personal information
We may share personal information that we collect and retain to the extent necessary for the intended purposes as described below.
(1) Types of personal information that may be shared: Types specified in Section 2.
(2) Parties with which information may be shared: Alticor Inc. (USA), Access Business Group International LLC (USA), Amway (China) Co., Ltd. (China), Amway Korea Ltd. (Korea), Amway Business Services Asia Pacific Sdn. Bhd. (Malaysia), Amway Global Services India Private Limited (India), Amway (Singapore) Pte. Ltd. (Singapore), Amway of Australia (Australia), Amway Japan Foundation
(3) Users’ intended uses:
(a) To provide products and services
(b) To calculate bonuses in accordance with the Amway Sales & Marketing Plan
(c) To register & administer international businesses
(d) To resolve problems as necessary to carry out Amway business
(e) To respond to customer service inquiries related to Amway products and services
(f) To conduct market research, data analysis, or surveys
(g) To access video, still images, and audio for business reporting and other purposes
(h) To manage data in the information systems of Amway and the parties specified in Section 6. (2)
(i) To contact and deliver letters, etc. to the supporters for the Remember HOPE Tohoku project and the Tomorrow HOPE health and empowerment support project for children
(j) For other intended purposes as specified in Section 3.
(4) Name of party responsible for controlling shared personal information: Amway Japan G.K. and Amway International Inc. (USA)

7. Outsourcing personal information processing
We outsource the processing of personal information that we collect to outside vendors, either inside or outside of Japan, to carry out the intended purposes specified in Section 3 above and utilize the individual information appropriately and seamlessly, and these vendors are obligated to maintain confidentiality pursuant to contracts executed with us. When outsourcing such work, we select vendors that meet the security measure standards established by us and our parent company, and along with executing outsourcing contracts that cover the protection of personal information, the level of protection is managed and supervised in an appropriate manner.

8. Disclosure requests
With respect to personal information held by us that is subject to disclosure, when an individual wants to receive a notice of intended purposes or a disclosure (including disclosure of the record of provision to a third party); or when he/she desires a correction/addition or deletion to the information; or when he/she wants to request that we stop using or delete such information, or stop providing such information to third parties, as a general rule we will accommodate such requests to the extent that it is reasonably possible if they are submitted using the prescribed form that has been completed by the individual himself/herself. Additionally, with respect to ABO number and information necessary to calculate bonuses of the upline and downline ABOs like PV/BV, when an individual requests that we stop using or delete such information, or stop providing such information to third parties, please note we will not accommodate such requests.
For more information, please use the contact listed below or refer to our company website (http://www.amway.co.jp/privacy/information/index.html).

9. Withholding consent
Personal information is provided at the individual’s discretion. If an individual declines to provide it, in some cases they may not be able to register (or renew) an ABO qualification.

10. Revisions
We may revise this document at our discretion or to comply with applicable laws and regulations. Please be sure to check the version of this document that is posted at amwaylive.com from time to time. Revisions may be made pursuant to the Act on the Protection of Personal Information, the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure and governmental guidelines.

Revised on December 1, 2023

Irina Menshikova
Amway Japan G.K.

Milind Pant
Amway International Inc.

For inquiries about how Amway handles personal information, please contact us by the means listed below.

7-1 Udagawa cho, Shibuya-ku, Tokyo
Amway Japan G.K.
Advice hotline: 0120-123-777

Appendix 1
Outline of Security Control Actions

(Formulation of Fundamental Principles)
- To ensure the appropriate handling of personal data, we have formulated fundamental principles such as the compliance with the relevant laws/regulations and guidelines, etc. and the contact for inquiries and claims management and posted them on our websites.

(Maintenance of Rules for the Handling of Personal Data)
- We have formulated internal rules such as regulations on personal information protection and stipulated the manner of handling and the responsible person/person in charge as well as their responsibilities, etc. according to each phase as to the collection, use, preservation, provision, deletion and disposal, etc. of personal information.

(Organizational Security Control Measures)
- We have deployed a person with ultimate responsibility in managing information who controls our overall management system of personal information and a responsible person for each department that handles personal data.
- We have clarified the employees, etc. who handle personal data and the scope of personal data to be handled and maintained the reporting and communication system in case of recognizing the fact or symptom of breach of laws and internal rules.

(Human Security Control Measures)
- We have educated and made efforts in raising awareness amongst employees (including the management team and temporary workers) about protecting personal information, and we have made the utmost effort to control personal information.

(Physical Security Control Measures)
- We have managed the entry and exit of employees, etc. and restricted the takeout of electronic devices, etc. as well as implemented measures to prevent browsing personal data without authority.
- We have implemented measures to prevent theft or loss of devices, electronic media and documents, etc. that deal with personal data.

(Technical Security Control Measures)
- We have implemented access control and restricted the person in charge and the scope of personal information database, etc. to be handled.
- We have adopted a mechanism to protect information system that deals with personal data from unauthorized access or malware.

(Understanding of External Circumstances)
- We have taken security control actions based on our full understanding in systems in regard to the protection of personal information in countries (please refer to the following link to find the list of countries and the summary of their systems in regard to the protection of personal information:https://www.amwaylive.com/psl/privacyporicy/country_system.html) where we store personal data (including the place where the server for cloud storage service is located) and foreign business entities to which we subcontract tasks that include handling of our personal data located at (including their subcontractors.)