Privacy
policy —

1. SUMMARY

ASEA, LLC 1 (See Appendix A for market specific data processors) is committed to respecting and protecting your privacy. We act in accordance with the requirements of the various privacy and data protection laws applicable in the countries or markets where we operate.

This Privacy Notice explains how we collect, use, and share Personal Data pertaining to our Customers and preferred Customers, Associates, job applicants and office and Website visitors (collectively, “you” and “your”) and explains the rights you have regarding our use of your Personal Data.

This Privacy Notice also applies to you if you publish information on the Internet (e.g. publicly available websites or blogs, Twitter, Instagram, Facebook, etc.) that we may collect data from, either directly or through third parties. Please consider that not all sections may be equally relevant or applicable to you depending on the circumstances.

Please ensure you read this Privacy Notice carefully before using our Website or Apps and/or providing us with your Personal Data.

2. WHO ARE WE AND HOW TO CONTACT US

ASEA, LLC 1 and its affiliates and subsidiaries (“ASEA, LLC”, “we”, “us” and “our”) are an international group of companies offering personal care products, cosmetics, nutritional supplements and other goods or services through (i) the ASEA websites (whether local or global) (each a “Website”), (ii) ASEA Connect app and tools (the “App”) and (iii) a network of customers and associates.

Depending on who you are, your Personal Data is processed by different entities of ASEA, LLC 1 and/or for different purposes. You will find in section 10. D, the list of the ASEA entities acting as data controllers responsible for processing your Personal Data. Please contact the Privacy Team or our Data Protection Officer [dataprotection@aseaglobal.org] if you have questions or concerns, or to exercise your rights as described or you may write to us at:

ASEA, LLC 1
Attn: Legal Department
1488 W. Pleasant View Dr.
Pleasant Grove, Utah 84062

In case of using our website for information purposes only, meaning if you do not register or otherwise provide us with information, we shall only collect the data transmitted by your server to our browser. If you want to view our website, we shall collect the following data that are technically necessary for us for displaying our website to you and for ensuring stability and security:

• sender IP address
• requested resource (URL, file download)
• HTTP method
• HTTP User Agent header

However, this data is stored separately from other information, so we are unable to allocate this data to a particular person. After an anonymous assessment for statistical purposes, this data will be deleted after 7 days.

We hold on to your Personal Data for as long as necessary to achieve the processing purposes listed above under section 5, “Personal Data we collect from you”. We no longer store your Personal Data when our (contractual) relationship with you comes to an end, unless further storage is permitted or required under applicable law.

A. WHEN CONTACTING US VIA EMAIL OR ON OUR CONTACT FORM:

In this case, we will store your communicated data (your email-address, possibly your name and your phone number) to answer your questions. We retain this information for legal compliance and to track that we have received and addressed your questions.

1 United States: Asea, LLC, Canada: Asea Enterprises, ULC, Mexico: Asea-Redox de Mexico, S. de R.L. de CV, Australia: Asea Pty Ltd, New Zealand: Asea New Zealand ULC, Hong Kong: Asea Redox International LTD, Indonesia: PT Asea Redox Indonesia, Malaysia: Asea Redox Malaysia SDN. BHD., Philippines: Asea International Inc., Singapore: Asea Redox International Singapore PTE. LTD, Taiwan: Asea Taiwan, LLC, Thailand: Asea Redox (Thailand) Company LTD, Germany: Asea Services Europe GmbH, Italy: Asea Italy Srl, Luxembourg: Asea Luxembourg S.a.r.l., Netherlands: Asea Netherlands B.V., Switzerland: Asea Redox Schweiz GmbH

3. THE PERSONAL DATA WE COLLECT

When using the term “personal data”, we mean information that relates to you and allows us to identify you, either directly or in combination with other information that we may hold. The following data may be collected:

From Associates:

Categories:
- Identifiers, Limited Protected Class Information (such as gender, marital status, and national status), Commercial Information, Online Activity, Geolocation Data, Sensory Information, and photos and videos when you participate at ASEA events for recognition.
Generally, we collect first name, last name, birth date, email address, mobile or home phone number, fax number (optional) and address data (street address, street address 2 (optional), postal code, city), your Government ID (if legally required), Credit Card details or bank account details. Shipping address, if different from your billing address. Optional: Spouse our company details relevant to your ASEA business.
For Switzerland- in addition to the above: Gender, Social Security number, civil status
For France – in addition to the above: Gender, Social Security number, civil status, SIRET, Place of Birth
For Italy on addition to the above: Social Security Fiscal Code number
Registering to our newsletter: we collect your email address;
Register to our events: we collect your phone number, the billing address and payment details if there is a charge for the event;
Interactions by other means: i.e. if you send an email or call our customer service. In this case we will process the data that are given to us at your own initiative.

From Customers:

Categories:
- Identifiers, Limited Protected Class Information (such as gender, marital status, and national status), Commercial Information, Online Activity, Geolocation Data, Sensory Information, and Employment Information.
Generally, we collect first name, last name, birth date, email address, mobile or home phone number, fax number (optional) and address data (street address, street address 2 (optional), postal code, city), Credit Card details or bank account details. Shipping address, if different from your billing address.
Registering to our newsletter: we collect your email address;
Register to our events: we collect your phone number, the billing address and payment details if there is a charge for the event;
Interactions by other means: i.e. if you send an email or call our customer service. In this case we will process the data that are given to us at your own initiative.

For Employees:

Categories:
- Identifiers, Limited Protected Class Information (such as gender and national status), Commercial Information, Online Activity, Geolocation Data, Sensory Information, and Employment Information.
Generally, we collect first name, last name, birth date, email address, mobile or home phone number, address data (street address, street address 2 (optional), postal code, city), your Government ID, Social Security Number, bank account details, civil status, work history, education history, and background check (not performed for European employees unless legally required.
Interactions by other means: i.e. if you send an email. In this case we will process the data that are given to us at your own initiative.

From Web Users:

Categories:
- Identifiers, Commercial Information (when making purchases), Online Activity, and Geolocation Data.
While browsing our website, we gather geolocation data, IP data, and track your usage of our websites to determine whether our websites provide the best user experience for you.
Interactions by other means: i.e. if you send an email or call our customer service. In this case we will process the data that are given to us at your own initiative.
If you elect to participate in the opportunity, we gather the information in the above section for Associates.

Please note, this website is not designed or intended for the use of minors under the age of 16. We do not knowingly process information from minors under the age of 16 and do not allow such minors to participate in the opportunity.

4. CATEGORIES OF SERVICE PROVIDERS WHO RECEIVE INFORMATION FROM US

We do not sell your information to third parties such as data brokers. However, to provide services essential to our relationship with you, we use a variety of service providers for our business purposes.

For our prospective and current Associates, as well as our Web Users, we cooperate with the following categories of service providers:

Logistics companies for shipment processing
Webhosts
Cloud service providers
Website managers and developers
E-commerce application developers
Communications and management applications
Digital Marketing services
Email communications
Application developers
The ASEA family of corporate entities
Associates in your upline organization but only to the extent that the upline Associate is entitled to earn commissions on your product sales. We will take reasonable steps to ensure that these individuals have implemented reasonable security mechanisms to protect your personal data.

For employees we use the following service providers:

Payroll processors
Expense reporting tools
Travel support tools
Background checks (not performed for employees in Europe unless required by law (for example, Italy))
Cloud service providers
Website managers and developers
Application developers
The ASEA family of corporate entities

A. PLAUSIBLE ANALYTICS

Our website uses Plausible Analytics to help us understand visitor trends and the effectiveness of our marketing efforts. We chose Plausible Analytics because it is a privacy-focused company and platform that eschews personally identifiable information in favor of anonymous aggregate data.

Plausible is built to be compliant with the different privacy regulations, such as GDPR. Plausible doesn’t use cookies and doesn’t collect any personal data whatsoever.

For more information, please see the Plausible Analytics Data Policy.

B. SOCIAL MEDIA

We use the social media links of the YouTube company. In doing so, we use what is called the two-click solution. This means that if you visit our site, initially no personal data will be passed on to the providers of these links. You can recognize the provider of the link by the marking on the box above its initial letter or by the logo. We offer you the possibility to directly communicate with the provider of the link via the button. Only if you click on the marked field and thereby activate it will the link provider receive the information that you accessed the corresponding website of our online offer. By activating the link, your personal data is transmitted to the respective link provider and stored there (for US providers in the USA). Since the link provider collects data particularly via cookies, we recommend that you delete all cookies before clicking on the greyed-out box using your browser's security settings.

We have no influence on the data collected and data processing operations, nor are we aware of the full extent of data collection, the purposes of processing, or the storage periods. We also have no information on the deletion of the data collected by the link provider.
The link provider stores the data collected about you in form of user profiles and uses these for purposes of advertising, market research and/or demand-oriented design of its website. Such evaluation is especially made (also for users who are not logged in) to display customized advertising and to inform other users of the social network about your activities on our website. You have a right to object to the creation of these user profiles. You must contact the respective link provider to exercise this right. Through the links we offer you the possibility to interact with social networks and other users so that we can improve our offer and make it more interesting for you as a user.

The data is passed on regardless of whether you have an account with the link provider and are logged in there. If you are logged in with the link provider, your data collected with us will be directly assigned to your existing account with the link provider. When you operate the activated button and link the page, for example, the link provider will also store this information in your user account and publicly communicate this to your contacts. We recommend that you regularly log out after using a social network, especially before activating the button, as this way you can avoid being assigned to your profile with the link provider.

For more information on the purpose and extent of the data collection and its processing by the link provider, please refer to the Privacy Statements of these providers provided below. Here, you will also find further information on your respective rights and settings options for protecting your privacy.

C. COOKIES

Cookies will be stored on your computer during your usage of our website. Cookies are small text files stored on your computer and that are allocated to the browser used by you and by which the authority placing the cookie will receive certain information. Cookies cannot be used to run programs or to transmit viruses to your computer. They serve to make the Internet offering more user-friendly and effective.

ASEA uses so-called “session-cookies” for being able to assign requests and requirements of the interested party. Based on these session cookies, ASEA will be able to measure the frequency of page impressions and the general navigation. Our session cookies are characterized by the fact that they are automatically deleted after 60 minutes after their placement from the fixed disk, again. The cookie’s name and the session ID generated by the accessed website will be stored in the session cookie. The session cookie does not have any impact on your privacy. It does not read or store any of your data, but only technical data generated by the system on its own. Of course, you can always refuse cookies, provided that your browser allows for it. Please note that certain functions of this website such as the ordering process may not be used or only used to a limited extent if your browser is set to not accept session cookies (of our website).

When you visit our website or use our Apps, we automatically collect, store and use technical information about your equipment and interaction with our Website and Apps (“General Information”). This General Information is sent from your computer or personal device to us using a variety of cookies and other technical means. Some web browsers may transmit “do-not-track” signals to websites with which the browser communicates. Our websites do not currently respond to these “do-not-track” signals.

5. PERSONAL DATA WE COLLECT FROM THIRD PARTIES

Most of the Personal Data that we collect about you will be information that you provide to us directly. In some circumstances we may also receive Personal Data about you from:

Associates, Individuals who provide us with your Personal Data (e.g. your family members), Regulatory bodies, and other companies providing services to us (e.g. social listening companies).

Some of these third-party sources may include publicly available sources of information. We may receive Personal Data from social networks when you engage with our content, reference our Site or Service, or grant us permission to access information from the social networks.

In addition, we could collect, either directly or through third-party service providers, information that is publicly available on the Internet (e.g. from websites, blogs, social media).

6. HOW WE USE YOUR PERSONAL DATA

As an Associate or Customer, we use your personal data for the following legal basis and purpose:

1. To fulfil our contract with you, in cases such as

- Creating and managing your Associate account or Customer account
  This is to fulfil our contract with you and to comply with legal obligations, including accounting and tax requirements.
- Executing our Associate Agreement with you
  This is to fulfil our contract with you and to comply with legal obligations, including accounting and tax requirements.
- Processing your product order
  When you place an order, we use your personal data to fulfil your order. We contact you by email to send you confirmation of your order and payment status. This is to meet our contractual obligations to you.
- Deliver and process product returns
- Processing payments
- Enforcing our policies and rights

2. Based on our legitimate business purposes, in cases such as:

- Communicate with you as part of our business relationship
- Communicate your sales performance data to Associates in your upline as this information is subject to their commission payments
- Statistical and marketing analysis as well as maintenance and development
- Protect the integrity and security of our services
- Improve the user experience of our websites
- Provide you with information and advertising for similar products you have already purchased. You can object to the use of your email address at any time without incurring any costs other than the transmission costs according to the basic rates by using the unsubscribe link contained in each communication or by You can withdraw your consent at any time by clicking the unsubscribe link included in the footer of ASEA news emails or by logging in to your ASEA® Virtual Office > MY ACCOUNT > Edit Information and unchecking the email permissions checkboxes. Note that you may have a right to oppose certain uses of your personal data. You can withdraw your consent at any time by clicking the unsubscribe link included in the footer of ASEA news emails or by logging into your AREA Virtual Office > MY ACCOUNT > Edit Information and unchecking the email permissions checkboxes. For details, please refer to our Privacy Notice. To exercise these rights, you can contact us at dataprotection@aseaglobal.org

3. To meet our legal obligations, in cases such as:

- for tax and accounting purposes;
- responding to requests by authorities or other public institutions as required by law

As a prospective or current Employee, we use your personal data for the following legal basis and purpose:

1. To fulfil our employment contract with you.

2. Based on our legitimate business purposes for security of our organization.

3. To meet our legal obligations.

As a Web User, we use your personal data for the following legal basis and purpose:

1. Based on our legitimate business purposes such as:

- Statistical and marketing analysis as well as maintenance and development
- Protect the integrity and security of our services

7. TRANSFERS OF DATA WITHIN THE ASEA FAMILY OF COMPANIES

We transfer Personal Data to other jurisdictions as necessary for the purposes described in this Privacy Notice, including to jurisdictions that may not provide the same level of data protection as the jurisdiction in which your Personal Data was originally collected. For instance, we may transfer your data to the U.S. because our parent companies are located there.

When we transfer your Personal Data to other countries or jurisdictions, we will protect that data as described in this Privacy Notice and in accordance with applicable law. Where required under applicable law, we will put in place binding contractual obligations with the data recipient to safeguard your data protection rights. Furthermore, we will notify any data transfer and/or data transfer mechanisms to the competent Supervisory Authority where required under applicable law.

With respect to transfers originating from the European Economic Area (“EEA”) to the United States and other non-EEA jurisdictions, we implement standard contractual clauses approved by the European Commission, and other appropriate solutions to address cross-border transfers as required or permitted by Articles 46 and 49 of the General Data Protection Regulation. Please contact the Privacy Team, if you have any questions with respect to the safeguards we have put in place to protect your Personal Data when we transfer this (including how to obtain a copy of or consult these safeguards).

Appendix A lists the ASEA entities that may receive your information depending on your location.

8. HOW WE PROTECT YOUR PERSONAL DATA

We protect your Personal Data and implement reasonable security including physical (e.g. secured filing cabinets), technical and organizational security measures appropriate to protect your Personal Data against unauthorized or unlawful processing and against any accidental loss, destruction, or damage.

We operate data networks protected by industry standard firewall and password protection systems. We also use transport layer security (TLS) to protect the transmission of your Personal Data. Access to this information will be provided only to authorized individuals for legitimate business purpose.

In addition, access to your Personal Data is restricted to staff and service providers on a need-to-know basis.

While we endeavor to always protect our systems, sites, operations and information against unauthorized access, use, modification and disclosure, due to the inherent nature of the Internet as an open global communications vehicle and other risk factors, we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others.

Please contact the Privacy Team (dataprotection@aseaglobal.org) if you have any questions about how we protect your Personal Data.

9. HOW LONG WE KEEP YOUR PERSONAL INFORMATION

We hold on to your personal data for as long as necessary to achieve the processing purposes listed above. This means, for instance, that we no longer store your personal data when our (contractual) relationship with you comes to an end, unless further storage is permitted or required under applicable law.

10. CHANGES TO THIS PRIVACY NOTICE

We may make changes to this Privacy notice from time to time. We will publish any new version of this Privacy Notice on our website. Any changes to this Privacy Notice will be considered effective immediately after the changes are posted on this Website unless otherwise indicated. The Privacy Notice was last revised on May 19, 2022.

11. YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION

You may ask ASEA to access, rectify, erase, and restrict how we process your Personal Data. You may review the Personal Data we have in our Information and Communications systems concerning you and make corrections to that Personal Data.  In certain circumstances, you may even ask that we delete some of the Personal Data we may have collected about you or restrict how we process that information.

We will endeavor to respond to your requests within 30 days. Should we be unable to comply within 30 days, we will contact you and let you know of any delay.

Authorizing your Request:

To authenticate your identity when you make a request, we may require additional information to process your request. We cannot process your privacy requests if we cannot authenticate your identity. In the event we cannot authenticate your identity, we will use the information you have provided us to opt you out of marketing emails from us.

If you want to exercise your rights, you may contact us at dataprotection@aseaglobal.org. Asea will not discriminate you because you have made a request to exercise your privacy rights.

ASEA’s privacy team has received training to help you exercise your privacy rights.

If you would like to lodge a complaint against us, you may contact your local supervisory authority. If you have trouble locating a supervisory authority, please contact our privacy team at dataprotection@aseaglobal.org and we will help you contact a supervisory authority.

Privacy policy —