Network TwentyOne Estonia (collectively referred to as “we”, “us” or “our”) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you how we look after your personal data and tell you about your privacy rights and how the law protects you.
This privacy notice gives you information about how we collect and process your personal data, including any personal data you provide through this website when you register for access to the website or purchase a product or service from us. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This website is not intended for children and we do not knowingly collect data relating to persons under the age of 18.
We are the “data controller” and responsible for your personal data. We have appointed a data privacy officer (“DPO”) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights set forth below, please email us at DPofficerEU@n21.com or you may contact the DPO by mail using the contact information:
Our full details are
Full name of legal entity: Network TwentyOne Estonia
Title of DPO: Magdalena Viks
Email address: DPofficerEU@n21.com
Postal address: Kuremarja 1-1
Parnamae kulla 74014
You have the right to make a complaint at any time to your local supervisory authority for data protection. We would, however, appreciate the chance to deal with your concerns before you approach your supervisory authority so please contact us, using the above details, in the first instance.
Changes to the Privacy Notice and Your Duty to Inform Us of Changes
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
- THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, username, IBO/ABO number, and Amway upline name and pin level.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes payment card details to purchase products and services, which you can also access for your re-order convenience.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Preference Data your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
- Purchase Data includes only your purchases from us.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. However, in the future, if we do collect any Special Categories of Personal Data from you, we will obtain your consent, as required by law, before processing such special categories of personal data.
If You Fail to Provide Personal Data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
- HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact, Financial, Preference, Marketing and Communication, and Purchase Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- purchase our products or services;
- create an account on our website;
- subscribe to our services;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
- Automated technologies or interactions. As you interact with our website and/or purchase products, we may automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
- HOW WE USE YOUR PERSONAL DATA AND FOR WHAT PURPOSE
We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to do so by law).
The types of lawful basis that we will rely on to process your personal data are listed in the table below. Generally, we do not rely on consent as a legal basis for processing your personal data. However, where we do so, you have the right to withdraw consent to marketing at any time by contacting us, using the contact details above.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||Identity, Contact||Performance of a contract with you Necessary for our legitimate interests to provide business functionality to our website|
|To process and deliver your order including, if applicable:(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
|Identity, Contact, Financial, Transaction, Marketing and Communications||Performance of a contract with youNecessary for our legitimate interests to recover debts due to us|
(b) Asking you to leave a review or take a survey
|Identity, Contact, Preference, Marketing and Communications||Performance of a contract with youNecessary to comply with a legal obligation
Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services
|To enable you to partake in a prize draw, competition or complete a survey||Identity, Contact, Preference, Usage, Marketing and Communications||Performance of a contract with youNecessary for our legitimate interests to study how customers use our products/services, to develop them and grow our business|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||Identity, Contact, Technical||Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, and to prevent fraudNecessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||Identity, Contact, Preference, Usage, Marketing and Communications, Technical||Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||Technical, Usage||Necessary for our legitimate interests to understand how our customers utilize our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||Identity, Contact, Technical, Usage, Preference||Necessary for our legitimate interests to develop our products/services and grow our business|
|To generate purchase activity reports for you and your upline IBO/ABO, if applicable.||Identity, Purchases||Performance of a contract with youNecessary for our legitimate interests to provide business functionality to our website.|
Promotional Offers from Us
We may use your Identity, Contact, Technical, Usage and Preference Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing.
We do not share your personal data with third parties for marketing purposes. If this changes in the future, we will get your express opt-in consent before we do so.
You can ask us to stop sending you marketing messages at any time by contacting us. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or other transactions you previously entered into with us.
Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
- DISCLOSURES OF YOUR PERSONAL DATA
We will only share personal data with others when we are legally permitted to do so. We may have to share your personal data with the parties set out below:
- Service providers who provide IT and system administration services so we can operate the website.
- Third party organisations that otherwise assist us in providing goods, services or information to you.
- Third parties listed in the table above.
- Our Network TwentyOne corporate affiliated entities.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
- Auditors and other professional advisers.
- Law enforcement or other government and regulatory agencies or to other third parties as required by, and in accordance with, applicable law or regulation.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
- INTERNATIONAL TRANSFERS/ EU-US PRIVACY SHIELD
We may share your personal data with our corporate affiliate Network TwentyOne International, Inc. (“N21 USA”) in the United State who develops and maintains the website on our behalf. This will involve transferring your data outside the European Economic Area (EEA). N21 USA participates in the EU-US Privacy Shield Framework regarding the collection, use, and retention of personal information from European Union member countries. N21 USA has certified with the Department of Commerce that it adheres to the Privacy Shield Principles. To learn more about the Privacy Shield Principles, go to https://www.commerce.gov/tags/eu-us-privacy-shield . You can review N21 USA’s EU-US Privacy Shield Policy statement here:
In any event, whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the US, we may transfer data to them if they are part of the EU-US Privacy Shield Framework mentioned above which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
- DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
- DATA RETENTION– How Long Will You Use My Personal Data For?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
- YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
No Fee Usually Required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What We May Need from You
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time Limit to Respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.