Reviewing how you handle Amazon buyer data: responding to misuse allegations

This article is for sellers who have received a notice from Amazon about how they handle buyer information, or who feel uneasy about how they contact buyers or manage order data. We walk through where the rules come from, the actions that tend to trigger notices, how to review your internal processes, and how to build a plan of action and prevent recurrence.

What "Improper Use of Buyer Information" Means: Where the Rules Come From

Amazon refers to the buyer names, addresses, phone numbers, and similar information you see on order pages and reports in Seller Central (セラーセントラル) as "personal data," and requires you to manage it in accordance with your agreement with Amazon, the Amazon Services Privacy Notice (Amazonサービスプライバシー規約), and Japan's Act on the Protection of Personal Information (個人情報保護法). Under the Amazon Services Business Solutions Agreement (Amazonサービスビジネスソリューション契約, referred to below as "the Agreement"), a customer's personal information is always treated as "Confidential Information."

This article is based on the text of Seller Central Help and the Agreement as of September 2026. Policies and on-screen labels can change, so please also check the notice you received and the latest Help content.

The main rules are spread across several places: the Help page "Prohibited Seller Activities and Actions, and Compliance Requirements" (出品者の禁止活動および行為、ならびに遵守事項), the "Communication Guidelines" (コミュニケーションに関するガイドライン), Section 11 of the Agreement, and the API terms that apply to connected tools.

Section 11 of the Agreement requires you to: use Confidential Information only to the extent reasonably necessary to use the Services; not disclose it except as required to comply with the law; protect it with reasonable measures; and retain it only as long as necessary, deleting it promptly once it is no longer needed. These obligations continue for five years after the Agreement ends. Reviewing your practices against these four angles - use, disclosure, protection, and deletion - makes it easier to catch gaps.

If you don't follow "Prohibited Seller Activities and Actions, and Compliance Requirements," Amazon states you may face measures such as listing removal, suspension of your access to tools and reports, loss of selling privileges, or a permanent ban. Under the Agreement, Amazon can also suspend or terminate your use of the Services for a material breach of the terms, among other reasons (Section 3).

Sellers based outside Japan also commit to Amazon that they will take measures at least equivalent to those needed to comply with the Amazon.co.jp Privacy Notice (Amazon.co.jpプライバシー規約), and must cooperate with any Amazon investigation if improper handling is suspected.

What to Check First If You Receive a Notice

Start by opening the notification email and the Account Health (アカウント健全性) page in Seller Central, and write down the following items.

You need to check the notice and the screen to see which policy name is shown for a buyer-information violation. Note down the policy name exactly as it appears, and use the same name in your plan of action. If violations of the same policy reach the limit within 180 days, your account can be suspended immediately (for how to read your score, see how to check your Account Health score).

Even if you're only at the warning stage, start corrective action right away. Section 3 of the Agreement provides that if you don't cure a material breach within 7 days of a notice requiring you to do so, Amazon may suspend your use of the Services. Stop the message template, automated send, or outside data transfer that caused the issue first, record when and what you stopped, and then move on to your review.

Next, cross-check your sending history. Check the Sent Messages in Buyer-Seller Messaging (メッセージ管理) to see what was sent to the order in question and when, and use your internal work records or the sending logs of any tool to confirm who sent it and from which screen or tool. If the message was sent automatically, also check the tool's settings and templates.

If your account has been suspended, use "Reactivate your selling account" (「出品用アカウントの再開」) near the top of the Account Health page and follow the on-screen instructions to submit your appeal. If you believe the suspension was a mistake, you can also submit your explanation by following the instructions on the Account Health page. If Amazon asks for additional information, submit it from "View Account Health Requests" (「アカウント健全性の要請を見る」). For the overall process, see an overview of the path from account suspension to reinstatement.

Actions That Tend to Trigger a Notice: Where Contact, Storage, and Sharing Cross the Line

Contact You Can and Can't Send

Amazon treats Buyer-Seller Messaging (メッセージ管理) as the only approved way to contact buyers. As a rule, you may contact buyers only when necessary to complete an order or to reply to a customer service inquiry; contact for marketing or promotional purposes is not allowed through any channel, including email, mail, or phone. In addition, you can send the proactive messages the guidelines allow (such as requesting a review or sending an invoice), as long as you meet the conditions.

Situation	What you can do
You want to confirm a problem with the shipping address or the details of a customization	You can contact the buyer through Buyer-Seller Messaging
You want to let the buyer know an item is out of stock and suggest a substitute	Don't suggest a substitute; cancel the order instead (if you want to tell the buyer you can't ship it, you can contact them through "Contact Buyer")
You just want to say thank you	You can't send this (it's not among the Permitted Proactive Messages)
You want to notify the buyer individually of shipment or a tracking number	Don't send this (order and shipment confirmations are not among the Permitted Proactive Messages). Once you send a shipping confirmation, Amazon notifies the buyer automatically
You want to proactively send usage tips or instructions	Don't send these as a proactive message (if the buyer asks a question, you can provide this guidance in your reply)
You want to announce a new product or a coupon	This can't be sent through any channel
You want to give the buyer's address to a delivery carrier so it can send a notification	Not allowed (this applies even to the anonymized address)
You want to call or text the buyer's phone number	Not allowed (the phone number is meant to be entered on the shipping label, with exceptions such as a pharmacist providing information for Class 1 over-the-counter drugs)

Requesting a review is limited to designated methods such as the "Request a Review" (「レビューのリクエスト」) page, and you can't use wording that encourages a favorable review or offer any kind of reward. For details, see reviewing product-review warnings and how you request reviews.

Requirements for Messages, and What You Can't Include

A proactive message you initiate as a seller must be sent within 30 days of order completion, include the 17-digit order number, and be written in the language the buyer specified. Permitted messages also can't include external links (other than a secure https link necessary to complete the order and links to Amazon), unnecessary attachments, unsubscribe links, or tracking pixels. Since you're also prohibited from providing or asking for any email address other than the one Amazon assigns, avoid any wording that gives buyers a way to contact you outside Amazon, such as your company's email address or website (phone numbers for warranty, carrier, or manufacturer purposes are allowed as an exception).

Storage and Sharing Problems That Commonly Occur

• Keeping a phone number you looked up for a shipping label in a spreadsheet or on a computer after shipment (Amazon requires you to delete it once shipping is complete)
• Building a customer list from order data and sending mailings by email or postal mail
• Sharing order data with a friend who's helping out or an outside contractor beyond what the work requires (for example, being unclear about the line between name and address, which are needed if you're only asking them to ship the item, and the phone number, which isn't)
• Sourcing a product with no inventory of your own, such as through another online store, and entering the buyer's name, address, and phone number directly into that site's order form so it ships straight to the buyer (this passes buyer information to a third party, which risks violating the disclosure restriction in Section 11 of the Agreement and the rule against sharing phone numbers with third parties; see also reviewing a drop-shipping operation)
• Writing a buyer's personal information into seller feedback (評価/フィードバック)
• Sharing login credentials among several people so it's unclear who has viewed buyer information

If your operation amounts to drop shipping with no inventory, stop shipping directly from your supplier, ask the supplier to delete any buyer information you passed along and record the date and their response, and consider whether you can switch to shipping through your own warehouse instead.

"Legally Fine" Isn't Enough: Two Different Yardsticks - Law and Amazon's Rules

Some of the laws that touch on buyer information take the view that "it's fine with the individual's consent," but Amazon's rules restrict use more narrowly.

Point	The legal view (general explanation)	Amazon's rule
Scope of use	Article 18 of the APPI: without consent, information shouldn't be handled beyond the scope necessary to achieve the purpose of use	Only when reasonably necessary to use the Services
Advertising contact	Act on Regulation of Transmission of Specified Electronic Mail: advertising emails can be sent only to people who, among others, have consented	No consent-based exception is provided; not allowed through any channel, including email, mail, or phone
Providing to others	Article 27 of the APPI: as a rule, the individual's consent is required. A contractor engaged within the scope of the purpose of use doesn't count as a "third party" (though Article 25 requires you to supervise that contractor)	No disclosure except as required to comply with the law. Phone numbers aren't shared with third parties
Storage and deletion	Article 22 of the APPI: make efforts to erase information without delay once it's no longer needed	Retain only as long as necessary and delete promptly
Data breaches and similar incidents	Article 26 of the APPI: in certain cases, report to the Personal Information Protection Commission (個人情報保護委員会) and notify the individuals affected	Notify Amazon promptly and take appropriate security measures

One idea to be especially careful of is that "it's fine to contact a buyer outside Amazon if the buyer consents." Some Help content can be read as making consent a condition, but as noted above, Amazon treats Buyer-Seller Messaging as the only approved way to contact buyers. Avoid citing that wording to justify your actions in a plan of action, and don't set up an outside contact channel on your own judgment. If you're unsure, check with Technical Support (テクニカルサポート).

When a Breach or Loss Has Occurred or Is Suspected

If buyer information has been breached, lost, or damaged, or there's a risk of that happening, you need to notify Amazon promptly and take appropriate security measures. If unauthorized access is suspected, preserve the records you'll need to identify the cause - such as access logs and sending history - before deleting any data. Help doesn't specify a contact point or method for the notification. If you're unsure, use Seller Assistant (セラーアシスタント) in Seller Central to reach Technical Support and confirm (see preparing to consult Technical Support).

Under the law, a breach must be reported to the Personal Information Protection Commission and the affected individuals notified if it falls into any of these categories: it involves specially sensitive personal information; there's a risk of financial harm; there's a risk it resulted from wrongful intent; or it affects more than 1,000 individuals. According to the Commission, a preliminary report is due within 3 to 5 days of discovery, and a final report within 30 days (60 days if wrongful intent is involved). Check with a lawyer or other professional to determine whether your situation applies.

Steps for an Internal Review: Taking Stock of How Information Flows and Who Has Access

Stopping only the specific conduct cited in the notice can leave the same problem sitting elsewhere. Map out where buyer information enters your business, where it ends up, and who can access it.

STEP 1. Identify the Entry Points and Where Information Ends Up

Ask each staff member which routes they use to touch buyer information - the order management screen, reports, printing labels or packing slips, connected tools, and so on - and identify the places where information tends to be left behind.

Where it tends to be left	Information typically involved	What to check
Computer download folder	Order reports, label data	Whether phone numbers for already-shipped orders are still there
Cloud spreadsheets and shared folders	Shipment tracking sheets, inquiry records	Who the folder is shared with and who can view it
Copies of packing slips and shipping labels	Name, address, phone number	Whether you're still keeping copies that show a phone number after shipment, and where they're stored and how they're disposed of
Contractor or warehouse devices	Data handed over for shipping	How the data was transferred and whether it's deleted once the work is done
Personal smartphones and personal email	Photos of slips, forwarded order information	Whether it remains on devices outside your business systems
Connected-tool providers	Order data imported into the tool	How long it's retained and who can access it

STEP 2. Decide the Purpose, the Person Responsible, and When to Delete

For each piece of information you find, decide what it will be used for, who may access it, and when it will be deleted. Some documents must be kept for tax purposes, so check retention periods with a tax accountant as well. The "within 30 days of order delivery" retention period you may see mentioned in a connected tool's documentation is a requirement for solution providers under the Data Protection Policy (データ保護ポリシー) - including sellers who develop or use their own SP-API applications - and doesn't automatically apply to sellers who only use Seller Central.

STEP 3. Review User Permissions

Under "Settings" (「設定」) > "User Permissions" (「ユーザー権限」), you can invite employees and edit or remove their permissions under "Manage Employees" (「従業員の管理」), and edit or disable an outside service provider's permissions under "Manage Your Services" (「サービスの管理」). As a seller, you're responsible for the actions of any user you add, including misuse. Check whether each person has their own individual login credentials, whether any permissions are broader than they need to be, and whether access remains for someone who has left or a business whose contract has ended, and record the date and details of any change. Two-Step Verification is required for access to Seller Central. Only Professional sellers can set up User Permissions. We haven't been able to confirm a clear official statement on how this applies to an Individual seller asking someone for help, so check with Technical Support if you're unsure.

STEP 4. Review Connected Tools and Outside Contractors

As noted in STEP 3, you're also responsible for the actions of any service provider you add to your account. In addition, handing information over to a tool or an outside contractor in the first place touches on the use and disclosure restrictions in Section 11 of the Agreement. Don't assume you're off the hook just because "the tool or the contractor was handling it." The Acceptable Use Policy for Amazon's API (APIの適正利用規約) similarly prohibits using a buyer's personally identifiable information for anything other than shipping or a legal requirement, including for marketing.

If you notice a message you didn't send or a setting you didn't change, also consider whether unauthorized access has occurred, change your password, check whether your permissions or payment information have been altered, and report it to Technical Support.

How to Build Your Plan of Action or Appeal

For appeals, Amazon says to write clearly and concisely based on the facts, leave out information about other cases, identify the root cause, and lay out what you actually did along with the dates you made changes and any supporting documents. Organize your explanation in the following order.

1. Identify the facts: which information, who used it, through which channel, and for what purpose
2. Root cause: why it happened (see the table below)
3. Corrective action already taken: deleting data, revoking permissions, disconnecting a tool, and so on, with dates
4. Prevention going forward: internal rules, sharing them with staff, and periodic reviews

Example root cause	Example corrective action	Example prevention measure
Didn't know the contact rules	Stopped the improper message and its template	A list of permitted contact and a check before sending
Permissions were broader than the work required	Removed unnecessary permissions and created individual accounts	Record permission changes and review them periodically
An automated-send setting in a tool	Disabled the feature; disconnected the tool	Check the purpose and retention period before adopting a tool
Didn't know how an outside contractor was handling the data	Asked the contractor to delete the data provided and confirmed completion	Agreed on how data is transferred and when it's deleted

Follow the instructions in your notice for what to submit, but records of data deletion, records of permission changes, and documented internal rules can all help support your explanation.

A Sample Outline for Your Explanation

Below is a sample outline for a case where a staff member called a buyer using a phone number left in a shipment tracking sheet. It is not a real case, so rewrite it to match what actually happened in your business.

We copied buyer phone numbers from our order reports into a shipment tracking sheet, and continued to keep them there after shipment. Between [date] and [date], our shipping staff used this number to call [number] buyers to confirm delivery dates. We confirmed on [date], by reviewing our sending history and stored files, that the numbers were not used for any other purpose or shared with any third party. The root cause was that we had not shared a rule limiting phone number use to entering it on shipping labels, and had not set a retention period for the tracking sheet.
On [date], we deleted all buyer phone numbers from our internal files and restricted access to the tracking sheet to shipping staff only.
Going forward, we will contact buyers only through Buyer-Seller Messaging, and will delete phone numbers once shipping is complete. We have documented this procedure, explained it to everyone on staff, and will review our stored files and user permissions once a month.

For more on how to structure your plan, see how to build a plan of action.

What Not to Do

• Downplaying the facts: If your explanation contradicts your records, it can undermine the credibility of your entire account.
• Deleting data without a record: Keep track of what you deleted and when - file names, the number of records, the deletion date, and so on.
• Contacting the buyer again on your own: An explanation or apology can be treated as a new violation if it doesn't count as contact necessary to complete the order. That said, if a breach means you're legally required to notify the individual under the APPI, don't decide on your own how to do it - check with Technical Support or a lawyer about the notification method first.
• Altering documents, or continuing to sell on a different account: Both violate Amazon's policies and risk making your situation worse, so don't do either.
• Submitting template text as is: It won't convey what you actually changed in your business. See also what's often missing when you reuse a template.

Operating Rules to Prevent Recurrence

When building your system after correcting the problem, it can help to look at the Personal Information Protection Commission's guidelines (通則編), which organize security measures into organizational, personnel-related, physical, and technical categories.

For a broader review of your operations, see also day-to-day management to prevent another suspension.

Frequently Asked Questions

Q. What if a buyer asks to use a different way to contact them?

A. Directing a buyer outside Amazon's sales process is prohibited. Even if the buyer requests it, keep the conversation within Buyer-Seller Messaging.

Q. How long can I keep order data?

A. Delete phone numbers once shipping is complete. For everything else, the Agreement's principle is to retain data only as long as necessary, including for statutory obligations such as tax requirements. See "STEP 2" above for how to decide this within your own business.

Q. Is it a violation to share buyer information with a contractor handling shipping?

A. Under the APPI, a contractor you engage within the scope of your purpose doesn't count as a third party, but you're still required to supervise that contractor (Article 25). Amazon's Agreement also has its own disclosure restrictions and provisions holding you responsible as the seller. Limit what you share to what the work actually requires, and check with a professional on anything you're unsure about.

Q. Do I still need to review this if I sell only through FBA?

A. For FBA orders, Buyer-Seller Messaging can only be used for questions about the product itself; direct buyers to Amazon Customer Service for shipping, returns, and refunds. The ban on contact for marketing purposes and the need to manage permissions and connected tools still apply to FBA, so a review is necessary.

Summary

The basics are to confirm what was flagged using the notice and your records, review how information flows and who has access, and present your corrective action and prevention plan in line with the facts.

• Contact buyers only through Buyer-Seller Messaging, and limit it to what's necessary to complete an order, replies to inquiries, and the proactive messages the guidelines allow (such as requesting a review or sending an invoice). Marketing contact isn't allowed through any channel
• Use phone numbers only for shipping labels, and delete them once shipping is complete
• Don't apply the legal principle of "fine with consent" directly to Amazon's rules
• Review how users, connected tools, and outside contractors handle information too, since you're responsible for it as the seller
• Write your plan of action in the order of facts, root cause, dated corrective action, and prevention

If you're unsure how to proceed, organize the notice and your internal records, and consider consulting a professional as well.

*This article provides a general explanation. The appropriate response in individual cases depends on the circumstances.

Further reading

When Amazon flags product-review practices: reviewing requests and buyer communications Read article → Building an Amazon Plan of Action: root causes, corrective steps and prevention Read article → Reviewing your Amazon Account Health Rating: warnings and improvement priorities Read article →