Last Updated: 12/14/2020
We also may interact with you on third-party websites where we post content or invite your feedback, including websites such as Instagram, Facebook, Twitter, Pinterest, and YouTube ("Third-Party Sites"). Please read the privacy policies of those Third-Party Sites and social platforms because the information they collect, including the posts you publish, will be governed by their Privacy Policies respectively, except to the extent you provide or disclose your Personal Information to us via a private messaging function. In addition, if you access third party websites or applications (including by providing such third parties your Rodan + Fields credentials), and share your Personal Information with such third parties, please read the privacy policies of those third parties to learn more about their collection, use, and sharing of your Personal Information.
PLEASE NOTE THAT THIS POLICY DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES, INCLUDING, WITHOUT LIMITATION, OUR INDEPENDENT CONSULTANTS.
INFORMATION COLLECTED ABOUT YOU
We collect the following types of Personal Information in order to provide you with the use of the Site and to help us personalize and improve your experience.
- Information We Collect Automatically: When you use the Site, we collect information sent to us by your computer or mobile device. The information sent to us includes, but is not limited to, the following:
- Location, device, and connection information: We collect location data (including IP addresses), device and connection information (such as referral URL). Your Internet Protocol (IP) address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). This number is identified and logged automatically in our server log files whenever you visit the Site, along with the time(s) of your visit(s) and the page(s) that you visited. We use your IP address, and the IP addresses of all users, for purposes such as calculating Site usage levels, helping diagnose problems with the Site's servers, analyzing trends, including suspicious activity detection and prevention, administering the Site, tracking traffic patterns, and gathering geographic information for aggregate use. Collecting IP addresses is standard practice on the Internet and is done automatically by many websites. If you access the Site or application via a mobile device such as a smartphone, the collected information may also include your device identifiers, location, and other similar mobile device data.
- Environmental Variables: We and our service providers may also collect certain environmental variables, such as your MAC address, computer type (Windows or Macintosh), screen resolution, OS version, internet browser, and internet browser version. These environmental variables are collected by most browsers, and will be used to optimize your experience on the Site.
- Information You Provide To Us: We may collect and store any information you provide us when you use the Site. For example, when you decide to complete a user registration form, complete an online survey, or make a purchase, you may be asked to provide certain information such as your contact information (name, email address, mailing address, and telephone number). If you decide to place an order, we will also need to know your delivery and billing address, credit card number, and expiration date. Enrolling Independent Consultants are also asked to provide their date of birth, Social Security number, and other Personal Information, which is required in order to begin a consultantship.
We may also collect information from or about you from other sources, including through your contact with us, our Sales Support Department, or your results when you respond to a survey. Additionally, for quality and training purposes or for our own protection, we may monitor or record our telephone conversations with you or anyone acting on your behalf. By communicating with Rodan + Fields, you acknowledge that your communication may be overheard, monitored, or recorded without further notice or warning, to the extent permitted by applicable law.
When you make a purchase on our Site, We collect from you the information required to make a purchase — such as your full name, email address, credit card number, shipping, and billing addresses. If you change your mind about storing this information, you can email the Sales Support Department at firstname.lastname@example.org to amend or delete this information. If you would prefer that we not collect any such Personal Information from you, please do not provide us with any such information. Please note that, notwithstanding anything to the contrary herein, your credit card or debit card information (“Credit Card Holder’s Information” or “CCHI”) will be used for payment on the spot, and it may be kept in your account in a tokenized format for future payments or regular payments. Rodan + Fields does not handle any CCHI on its own, and such CCHI is handled by external operators that manage the CCHI in accordance with the PCI data security standards and other industrial standards.
Please note that if you choose to share Personal Information about yourself in an open format, such as through a Third-Party Site like Facebook or Twitter, some of that information could be deemed public and may lose certain protections under applicable privacy laws.
HOW WE USE PERSONAL INFORMATION
Our primary purpose in collecting Personal Information is to provide you with a secure, smooth, efficient, and customized experience. We may use your Personal Information to:
- Process transactions and send notices about your transactions. When you make a purchase through the Site, we may collect your credit card number or other payment account number, billing address, and other information related to such purchase (collectively, "Payment Information") from you, and use such Payment Information in order to fulfill your purchase.
- Permit emails to friends. We may provide the functionality to permit you to send messages regarding Site-related content to a friend through the Site. If you wish to use this feature, you may provide us with your friend's email address so that we can facilitate the sending of your message to your friend. Please note that you are responsible for ensuring you have obtained permission from your friend before sharing your friend’s information with us.
- Provide sales support.
- Send administrative communications regarding the Site, service-related announcements, etc., which are necessary to serve you, respond to your concerns, and provide the high level of customer service that Rodan + Fields offers. Because this information is needed to enable your use of the Site, you may not opt-out of receiving such communications unless you close your account with us.
- Verify your identity, including during account creation and password reset processes.
- Manage risk, or to detect, prevent, and/or remediate suspicious account activity or other potentially prohibited or illegal activities.
- Manage and protect our information technology infrastructure.
- Contact you at any telephone number, by placing a voice call or through text (SMS) or email messaging, as authorized by applicable law, our Terms and Conditions, and the Consultant Agreement.
- Provide targeted marketing and advertising, provide service update notices, and deliver promotional offers based on your communication preferences.
- Detect, prevent, or remediate violations of our Terms and Conditions or Policies and Procedures, as stated in the Consultant Agreement.
HOW WE SHARE PERSONAL INFORMATION WITH OTHER THIRD PARTIES
We may share the Personal Information we collect from you, including your name, contact details, and transactions and activities, in connection with:
- Emails to Friends: Please note that any Personal Information you provide in connection with sending messages regarding Site-related content to a friend through the Site, such as your name and your email address, will be disclosed to your friend.
- Assignment: We reserve the right to transfer any and all information that we collect from Site users to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of Rodan + Fields' business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings).
- Other Non-affiliated Parties, including service providers, such as:
- Suspicious Activity Prevention and Risk Management: to help prevent suspicious activity or assess and manage risk. For example, at the time of order, we may collect and share your email, phone number, billing and shipping addresses, and device information (including IP address and geographic location) with our service provider.
- Shipping: in connection with shipping products you may have ordered through the Site.
- Other Service Providers: to enable service providers under contract with us to support our business operations, such as bill collection, marketing, customer service, and technology services.
Please note that our employees and service providers may be located in foreign jurisdictions, and your Personal Information may be subject to the laws of those foreign jurisdictions and accessible to law enforcement and other authorities.
OUR USE AND YOUR CHOICES REGARDING COOKIES AND OTHER TRACKING TECHNOLOGIES
This section helps you understand what Tracking Technologies are, how we use them, and the options that you have.
What are Cookies and Pixels?: Cookies are a type of technology that installs a small amount of information on a user's computer or other device when they visit a website. Cookies permit a website to, for example, recognize future visits using the same computer or device. Tracking pixels are tiny, transparent graphics with a unique identifier, similar in function to cookies, and are used to provide analytical information concerning the user experience as well as to support customization of our marketing and advertising activities. In contrast to cookies, which are stored on a user's computer hard drive, tracking pixels are embedded invisibly on web pages.
How do we use Tracking Technologies?: The Site may use Tracking Technologies to gather information, customize your visit, and enable us to enhance our services (including through personalized advertisement.) For example, we use Tracking Technologies to recognize you as a previous user of the Site so you do not have to enter your Personal Information every time, and to offer you personalized content. We may use the information gathered through Tracking Technologies to create aggregate tracking information reports regarding user demographics, traffic patterns, and purchases. In some cases, we may link tracking information with Personal Information. We may also use these technologies to help us better manage content, such as by improving the user interface. Finally, we also use these technologies (directly or through service providers) to build a better picture of the type of offers and products that you might be interested in, for location-based advertising (including through push notifications as described below), cross-device matching, and interest-based advertising.
- Location-Based Advertising: To the extent our Site has a corresponding App, we may use our App to obtain the user’s precise location (if the user of the App permits the App to request and collect this information from the applicable mobile device.) We may also determine a zip code from the precise location data received from an App user’s mobile device. Users of the Site also may elect to provide us with their zip code directly. We may use general location data, preferences, or other information received from the Site, including through your mobile device such as through the App, to send you tailored marketing messages based on your location, including making product recommendations. Additionally, we may use information to engage in interactive, real-time discussions with users, which we or the users may initiate. If you would like to opt-out of location-based advertising, please see the choices section below.
- Interest-Based Advertising: We may use the information we collect (alone or in combination with information provided by third parties and service providers) through Tracking Technologies (which may be combined with other Personal Information such as your email address) to deliver targeted advertising to you when you visit our Site or elsewhere. For example, if you are searching our Site for information on a particular product, we may use that information to cause an advertisement to appear on other websites you view promoting a product that matches your search. We also partner with third parties that collect information across various channels, including offline and online, for purposes of delivering more relevant advertising to you or your business. Our partners may place or recognize a tracking technology placed on your computer, device, or directly in our emails/communications, and we may share Personal Information with them for interest-based advertising purposes. Our partners use this information to recognize you across different channels and platforms, including but not limited to, computers, mobile devices, and Smart TVs, over time for advertising, analytics, attribution, and reporting purposes.
Your options: You may choose to decline Tracking Technologies by adjusting your browser preferences, but doing so may affect your use of the Site and your ability to access certain features or engage in certain transactions through the Site. If you delete your cookies, change browsers, or change devices, cookies that the Site may have used in the past (or an opt-out cookie) may no longer work.
- Interest-Based Advertising Opt-Out: As described in this Privacy Notice and to the extent permitted by law, we may collect (or allow third parties such as ad networks, web analytics companies, and social networking platforms to collect) information about your online activities over time and across our Sites and other third-party online properties or services. These third parties may use information about your visits to our Site and other sites, and general geographic information in order to provide advertisements about goods and services of interest to you. For more information about third-party advertisers and how to prevent them from using your information, please visit http://www.networkadvertising.org/choices/. This is a site offered by the Network Advertising Initiative ("NAI") that includes information on how consumers can opt-out of receiving interest-based advertising from some or all of NAI's members. You can also visit http://www.aboutads.info/choices, which is a site offered by the Digital Advertising Alliance ("DAA") that includes information on how consumers can opt-out of receiving internet-based advertising from some or all of DAA's participating companies. Opting out of interest-based advertising does not mean that you will no longer see any advertisements; rather, you will still see advertisements that are general and not tailored to your specific interests and activities.
- Device-Based Opt-Out: In general, opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted out on your computer browser, that opt-out will not necessarily be effective on your mobile device. In the event we are performing cross-device matching (as described above), once you have opted out on one device (“Opted-Out Device”), we will not use any new data from the Opted-Out Device to identify you on another device for interest-based advertising purposes and we will not use data from another device for interest-based advertising purposes on the Opted-Out Device.
TRANSFER OF INFORMATION OUTSIDE YOUR HOME COUNTRY
LAW ENFORCEMENT; EMERGENCIES; COMPLIANCE
CHILDREN UNDER 13
Our Site is not directed to and we do not knowingly collect information from children under thirteen (13). Under our Terms and Conditions, children are not permitted to use our Site or services.
HOW WE SECURE YOUR INFORMATION
We realize that our customers trust us to protect their Personal Information. We take that task seriously. We maintain physical, electronic, and procedural safeguards to protect your Personal Information. We implement various security measures and tools, such as firewalls, to help protect against the loss, misuse, and alteration of the information under our control. For example:
- We use industry-standard Secure Sockets Layer ("SSL") authentication to guarantee the confidentiality of online transactions made on our Site. SSL authentication and encryption of the information that you send to us over the Internet help protect your online transaction information from third-party interception.
- We never display your full credit card number once it is entered. We will only reveal the last four digits of your credit card for verification purposes.
- Data transmission over the Internet or data storage system cannot be guaranteed to be 100% secure. There is always a risk that third parties may unlawfully intercept transmissions. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account that you might have with us has been compromised), please notify us of the problem by emailing us at email@example.com.
MEASURES YOU CAN TAKE
It is important for you to play a role in keeping your information safe and secure. When signing up for an online account, please be sure to choose an account password that is hard for others to guess and never reveal it to anyone else. If you use a shared or public computer, never choose to have your login ID or password remembered and make sure to log out of your account every time you leave the computer.
UPDATING AND ACCESSING YOUR INFORMATION
You have the ability to change and/or correct the Personal Information that you provide us by emailing us at firstname.lastname@example.org. Under applicable law, you may have the right to ask in writing whether we hold any Personal Information about you, to see that information, and request additional details as to how we collect, use or disclose your Personal Information. We may not be able to provide you with all the information that you request, depending on the circumstances, and there may be a charge for any copy of Personal Information requested. You may request that we deactivate your account by emailing us at email@example.com.
Please note that we may need to retain certain information for record-keeping purposes, and there may also be residual information that will remain within our databases and other records, which applicable law may allow us to retain. We may contact former users of the Site who have not explicitly withdrawn consent to such communications in accordance with applicable laws.
You may withdraw your permission to collect, use, and disclose your Personal Information at any time, subject to legal and contractual restrictions and reasonable notice. However, without your permission, we may not be able to provide you with the products or services you have requested.
OPT-OUT FOR MARKETING & PROMOTIONAL CORRESPONDENCE
You may opt-out of receiving future emails from Rodan + Fields. Please note that this opt-out only applies to Rodan + Fields promotional emails. You may opt-out of receiving Promotional Emails by using the opt-out mechanism in the footer of the email itself or by emailing us at firstname.lastname@example.org.
We will endeavor to comply with your request as soon as reasonably practicable. Please note that opting-out as described above will not remove your information from our databases or the databases of Independent Consultants or third parties. If you wish to cease receiving marketing-related emails from such Independent Consultants or third parties, please contact such Consultants or third parties directly or utilize any opt-out mechanisms set forth in their respective privacy policies or marketing-related emails.
FOR CALIFORNIA RESIDENTS
This section describes how we handle the Personal Information of California residents. It describes how we collect and process such information in the context of providing services and selling goods to the extent the obligations imposed by the California Consumer Privacy Act of 2018 ("CCPA") apply to such information (hereinafter, CCPA Related Personal Information). This section also notifies California residents of their rights and obligations under the CCPA.
Capitalized terms not defined in this section shall have the meaning provided to them by the CCPA.
Notice at Collection
We collect the following categories of CCPA Related Personal Information from you:
- Identifiers: We collect identifiers such as real name, alias, postal address, unique personal identifiers, online identifier, Internet Protocol address (see “internet activity” below), email address, and account name.
- Internet/Electronic Network Activity: When you browse our sites or otherwise interact with us online, we may collect browsing history, search history, and other information regarding your interaction with our sites, applications, or advertisements.
- Customer Records: We collect Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) such as name, signature, description, address, telephone number, bank account number, or other financial information. Some Personal Information included in this category may overlap with other categories.
- Characteristics of Protected Classifications Under California or Federal Law: In some circumstances, we may collect information that is considered protected under California or federal law, such as age or information related to medical conditions, but only when that information is relevant for our business purposes (e.g., in relation to a promotion we are offering or ensuring the safety of visitors to our facilities.) We abide by the legal requirements imposed under applicable law in regards to such information.
- Sensory Data: In some circumstances, we collect audio information (e.g., records of calls made through our systems when call recording is activated), electronic and visual information (e.g., recordings from security cameras), or similar information.
- Geolocation Data: If you interact with us online we may gain access to the approximate location of the device or equipment you are using. If you visit our facilities, we may keep a record of the fact that you visited, the location visited, and the day/time.
- Biometrical Data: Although we do not generally collect biometric data such as DNA data, fingerprints, voice prints, we may, for specific products or in connection with a launch of new products or tools, we may collect data from which biometric data could be derived (such as voice recordings and pictures).
- Commercial Information: We collect commercial information such as records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Professional- or Employment-Related Data: Because we collect and handle information related to our Independent Consultants, we often collect from them professional information such as business names or aliases. However, our Independent Consultants are not employees of Rodan + Fields.
- Inferences: We may draw inferences from other information we collect about you. For example, if you are a client, we may create a client profile reflecting our understanding of your personal preferences.
- For our internal efforts to operate and improve our business.
- For advertising and marketing purposes.
- For our general administrative purposes.
- For social-media engagement.
- For security purposes, as necessary to help us protect against, identify, or investigate fraud or other criminal activity.
- For other legal purposes, if we have a legal obligation, or need to pursue or defend against legal claims, for which we need to process your information.
- For communication purposes, to get in touch with you in connection with any of the reasons listed above.
Collection and Sharing Practices in the Last Twelve (12) Months
In the last twelve (12) months, we have collected CCPA Related Personal Information for all of the categories outlined in the Notice at Collection section as described above.
- Directly from our customers, Consultants, suppliers, & partners (for example, the information provided through the Site or other communications with us).
- From consumers’ activity on the Site (for example, Site visit information collected directly or through third-party analytics providers).
- From a device’s GPS, Wi-Fi, Bluetooth, or IP address.
- From interaction through social media
- From third parties like consumer data resellers
- Service Providers
- Other members of our corporate group
- Governmental entities (when we are under a duty to disclose or as required to protect our rights or the rights of others)
- Third Parties, including Independent Consultants, to whom you expressly or implicitly authorized us to disclose your Personal Information in connection with products or services provided to you
- Other third parties as necessary to provide services to our clients
Your Rights Under California Law
If you are a California resident, you have the following rights under the CCPA:
Right to Know: You have the right to request that we disclose to you: (1) the specific Personal Information we collected about you; (2) the categories of Personal Information collected or shared; (3) the purposes for which we collected or shared your Personal Information; and (4) the categories of third parties to whom we have disclosed your Personal Information.
Right to Delete: You have the right to request deletion of the Personal Information that we received from you. As a general rule, we must delete the Personal Information at your request and require our vendors to do so as well. However, the law provides certain exceptions that allow us to retain the information even if you have requested that it be deleted. If we do not erase the information pursuant to one of those exceptions, we must inform you of that fact and of any rights you may have to appeal our decision. Information on how to submit a request to us is provided below.
In addition, if you are a California resident, you may:
- Opt-out of the sale or disclosure of your Personal Information, in some circumstances;
- Opt-out of receiving marketing communications from us; however, you may still receive administrative communications regarding the services;
- Opt-in to certain financial incentive programs we may offer related to the collection, sale, or deletion of your Personal Information; and
- You will not be discriminated against for exercising your rights under the CCPA.
Rodan + Fields does not generally respond to “do not track” signals.
How to Make a Request
You can make requests related to your California privacy rights at the attached links:
You may also make those requests by calling our toll free number 415-273-8000.
Please be aware that we do not accept or process requests through other means (e.g., via fax, chats, social media, email addresses, etc.).
When you make a request, we may ask you to provide verifying information, such as your name, email, or phone number. We will review the information provided and may request additional information via email or other means to ensure we are interacting with the correct individual. Please also be aware that making any such request does not ensure complete or comprehensive removal or deletion of Personal Information or content you may have posted, and there may be circumstances in which the law does not require or allow us to fulfill your request.
SOCIAL COMMERCE AND OTHER THIRD PARTIES
We work with trusted third parties, including social network sites such as Facebook, and with applications and developers who specialize in social commerce, so that we can connect to your social networks. Other social networks we use include Twitter, Pinterest, Instagram, Vine, and YouTube. All of these companies operate Third-Party Sites. We provide access to our Site by third parties and business partners so that we can generate interest in our products among members of your social networks and to allow you to share product interests with friends in your network. The use of any features made available to you on our Site by a third party may result in information being collected or shared about you by the third party or by us. If you do not want us to be able to access information about you from Third-Party Sites, you must instruct Third-Party Sites not to share the information. We cannot control how your data is collected, stored, used, or shared by Third-Party Sites or to whom it is disclosed. Please be sure to review the privacy policies and privacy settings on your social networking sites to make sure you understand the information they are sharing. If you do not want a Third-Party Site to share information about you, you must contact that site and determine whether it gives you the opportunity to opt-out of sharing such information. Rodan + Fields is not responsible for how these third parties may use information collected from or about you. However, we do identify any areas on our Site where third parties share information about you.
The Site is controlled and operated by Rodan + Fields from the United States and is not intended to subject Rodan + Fields to the laws or jurisdiction of any state, country, or territory other than that of the United States. Rodan + Fields does not represent or warrant that the Site, or any part thereof, is appropriate or available for use in any particular jurisdiction. Those who choose to access the Site do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules, and regulations. We may limit the Site's availability, in whole or in part, to any person, geographic area, or jurisdiction we choose, at any time and in our sole discretion.
If you have any questions, comments, concerns, or complaints about the Site's privacy practices, please contact us by email at email@example.com or visit the Contact Us section of our website. Please note that email communications will not necessarily be secure; accordingly, you should not include credit card information or other sensitive information in your email correspondence with us.