ACN takes the privacy of our Independent Business Owners (“IBOs”) and customers seriously. We are committed to safeguarding your privacy while providing You with high-quality services and products.
Your Consent to Collect and Use Personal Data
What Information Do We Collect?
The Personal Data and other information that we collect varies depending on your relationship with ACN. Among the Personal Data and other information that We may collect is the following:
• Company details;
• Residential and business address;
• Date of birth;
• National identification number;
• Telephone number;
• IP and MAC addresses and browser information;
• Email address;
• Banking details, credit or debit card information, or other information needed to process payments to or from You;
• Demographic information such as your profession, hobbies, education, gender, ethnicity, and income;
• Location information;
• Recordings of telephone calls;
• Emails and written communications; and
• Other identifying information.
How Do We Collect Information?
We collect Personal Data and other information from You in a variety of ways, including:
* the submission of Personal Data by You to ACN through our websites;
* the submission of a paper or online order for ACN services or products;
* the submission of an Independent Business Owner Application and Agreement;
* through the use of our IBO or customer websites, services and products;
* when We and You communicate by email, telephone, fax, chat line, or otherwise;
* provision of your Personal Data to ACN by ACN’s business partners; and
ACN will not contact You by telephone or email to request information such as credit card numbers, account numbers, passwords and pin codes. We recommend that you do not open or respond to e-mails requesting this type of information and that you contact ACN if You receive such a request.
How Do We Use Your Personal Data?
ACN collects and processes Personal Data for a variety of legitimate purposes, including:
* to verify, process, and administer your orders for ACN services and products;
* to ensure a secure ordering process, to assess your creditworthiness and to conduct credit checks in connection with your purchase or usage of ACN services and products;
* to take payment from You for ACN services and products;
* to maintain our commercial relationship with You, including provision of billing and customer services;
* to analyze, understand, and respond to your service needs, this includes scientific and market research and opinion polls;
* to improve the products and services that We offer to You and to develop new products and services;
* to meet our legal and regulatory obligations and to protect ACN’s legal and financial interests (including fraud detection and prevention) and to conduct IBO compliance investigations;
* to comply with ACN’s reporting obligations to government agencies;
* for the provision of services to our Independent Business Owners and compliance with our contractual obligations to Independent Business Owners;
* to pay commissions and bonuses to IBOs;
* to prepare internal reporting on customer and IBO matters and general business needs;
* to provide to an IBO’s sponsor and upline IBOs;
* to facilitate financial, accounting and administrative functions;
* to enter your details in a publicly available directory enquiry service and directories operated by us or a licensed third party; and
* to identify and inform you about services and products from ACN and ACN business partners that We believe may be of interest to you, including sending commercial and marketing communications.
How Long We Keep Your Personal Data?
ACN keeps your Personal Data as long as it is required for the purposes for which it was initially collected, which may vary depending on the type of Personal Data collected and the purposes for which the data were collected. In the context of the contractual relationship We have with you, We keep your Personal Data as long as needed to provide our services to you and to deal with any questions or complaints you may have about these services. If We use your Personal Data for Our marketing purposes We will keep the data as long as that data is relevant for that purpose and up-to-date. In certain cases We may need to keep your Personal Data for a minimum period to comply with legal requirements. We do not keep your Personal Data longer than permitted by law.
Where We Store Your Personal Data?
Your Personal Data is stored by ACN on secure computer servers located in The Netherlands, and/or Poland. Some Personal Data is transferred to our parent company and affiliates of ACN outside the European Union, including the United States. See Transfer of Personal Data below. All Personal Data is stored according to industry standards. See Security below.
ACN may require IBOs and customers to provide credit or debit card information (“Cardholder Data”) in connection with the purchase of some ACN products and services. Cardholder Data may be used for current payments and stored for future or recurring payments. Payments may be made directly to ACN or through third-party vendors. ACN maintains controls consistent with the Payment Card Industry Data Security Standard and other industry standards to protect Cardholder Data; however, these safeguards may not prevent every unauthorized attempt to access, obtain, or use Cardholder Data.
Transfer of Personal Data
I. Within the ACN Group and Overseas
II. To Other Third Parties
ACN has implemented technological and organizational measures to safeguard your Personal Data from unauthorized or improper access or use during collection and while it is in our possession. Sensitive information (such as gender, ethnicity, financial information and Cardholder Data) is subject to heightened security measures. You should also take measures to safeguard your Personal Data by maintaining the confidentiality of your username and password, logging out of ACN websites, closing your web browsers when You have concluded your online activities, changing your passwords regularly and not providing your Personal Data to persons that are unfamiliar to You.
ACN and You may communicate by email or chat and these communications may at times contain Personal Information. We do not intercept or disclose the contents of email and chat communications in the absence of a warrant or court order or if not required as part of an ongoing investigation; however, these communications may not be secure. We recommend that you do not send sensitive information (such as gender, ethnicity, financial information and Cardholder Data) by email or chat, and we will not ask you to provide such information in this manner.
Your Right to Access Your Personal Data, and other rights
You have the right to access your Personal Data, to correct your Personal Data if the information that We have is erroneous, and in some cases to delete your Personal Data. You may obtain a copy or correct or request deletion of your Personal Data by contacting our Data Protection Officer at email@example.com or by writing to:
Data Protection Officer
ACN Europe B.V.
Thomas R. Malthusstraat 1-3
1066 JR Amsterdam
We may impose reasonable restrictions on requests for access to or to correct your Personal Data and We may charge You a reasonable fee as permitted by law for provision of your Personal Data, in case of unfounded or excessive requests, If you request deletion of your data, We may not be able to provide services and products to You. We are permitted to keep certain of your Personal Data in order to meet our legal, financial, audit, and business needs, even if you request its deletion.
Limitation of Liability
Issue Date: 23 May, 2018