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NEW PRIVACY POLICY

Last Updated: October 30, 2022


Your privacy is important to us. Rodan & Fields, LLC, including all its subsidiaries and affiliates ("Rodan + Fields," "we," "our," and "us"), created this Privacy Policy to inform you about how we collect, use, disclose, share, and protect information Personally Identifiable Information (or “PII”, defined below) and otherwise comply with applicable consumer privacy laws. We encourage you to read this Privacy Policy in its entirety before using https://www.rodanandfields.com/ or any other online service (e.g., website or mobile app) that posts a link to this Privacy Policy, opening our e-mails or otherwise submitting PII to us (collectively the “Service”).


By visiting or otherwise using the Service, you agree to the Service’s Terms and Conditions and consent to Rodan + Fields® data collection, use, and disclosure practices, and other activities as described in this Privacy Policy, and any additional privacy statements that may be posted on an applicable part of the Service or otherwise at collection. If you do not agree and consent, please discontinue use of the Service, and uninstall Service downloads and applications.


Your State Privacy Rights: California and Nevada residents have certain privacy rights detailed here. To the extent that there is a conflict between this Privacy Policy and the state privacy notices, the state privacy notice will control for residents of such states.


About Ads and Tracking: Learn about certain choices you have regarding Tracking Technologies, including certain sharing of activities for internet-based advertising, including Location-Based Advertising and Cross-Device Matching.


If you have any questions about this Privacy Policy https://www.rodanandfields.com/en-us/terms-and-conditions or our privacy practices, please contact us here.


Table of Contents of Navigation


SCOPE

UPDATES TO THIS PRIVACY POLICY

INFORMATION WE COLLECT ABOUT YOU

  1. Information We Collect Automatically
  2. Information You Provide to Us
  3. Third-Parties

HOW WE USE PII

  1. Process Transactions and Send Related Notices
  2. Provide Marketing and Newsletters
  3. Permit E-mails to Friends
  4. Send Administrative Communications Regarding The Site, Service-Related Announcements, Etc.
  5. Perform Additional Functions

HOW WE SHARE PII WITH OTHER THIRD-PARTIES

  1. Independent Consultants
  2. Friends
  3. Corporate Transactions
  4. Other Non-Affiliated Parties, Including Service Providers

USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES

  1. Cookies
  2. Web Beacons / Tracking Pixels
  3. In-app tracking methods
  4. How we use Tracking Technologies?
  5. Location-Based Services
  6. Cross-Device Matching
  7. Interest-Based Advertising

YOUR CHOICES REGARDING COOKIES AND TRACKING TECHNOLOGIES

  1. Tracking Technologies Generally
  2. Analytics, Interest-Based Advertising, and Tracking Technologies Opt-Out
  3. Device-Based Opt-Out
  4. Mobile Apps

TRANSFER OF INFORMATION OUTSIDE YOUR HOME COUNTRY

LAW ENFORCEMENT; EMERGENCIES; COMPLIANCE

CHILDREN

THIRD-PARTY SERVICES

HOW WE SECURE YOUR INFORMATION

MEASURES YOU CAN TAKE

UPDATING AND ACCESSING YOUR INFORMATION

OPT-OUT FOR MARKETING & PROMOTIONAL CORRESPONDENCE

YOUR STATE PRIVACY RIGHTS

  1. California Residents
  2. Nevada Residents

CONTACT US


SCOPE

This Privacy Policy governs our practices with regards to PII collected when you access or use the Services, including the Rodan + Fields® website (or any of our international websites or applications) and any products, services, software, tools, applications, features or functionality offered on or through the website or mobile application (including any Rodan + Fields independent sales consultant (“Consultant(s)”) personal web pages provided through the website) (collectively, the “Site”). You may be accessing our Services from a computer or mobile phone device (for example, through an iPhone or iPad application), or through a Rodan + Fields mobile application, and the provisions of this Privacy Policy apply to all such mobile access and use of mobile devices. From time to time, we may add additional products, services, software, tools, applications, features or functionality, offered through our Service, as we expand our offerings, and this Privacy Policy will govern those new products, services, software, tools, applications, features, or functionality when added.


PLEASE NOTE THAT THIS POLICY DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD-PARTIES, INCLUDING, WITHOUT LIMITATION, OUR INDEPENDENT CONSULTANTS AND THIRD-PARTY SERVICES.


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UPDATES TO THIS PRIVACY POLICY

Because our business and privacy laws will continue to evolve, our policies will be reviewed and may be revised from time to time. We may change this Privacy Policy at any time and will notify you by posting an updated version of the Privacy Policy. We recommend that you review this Privacy Policy from time to time during visits to the Site and note any changes before your continued use of the Service. Your continued use of the Service after we post any revisions to this Privacy Policy constitutes your acceptance of the revised terms and conditions as to such continued use. It is your responsibility to periodically check this page so that you are aware of what information we collect, how we use it, and under what circumstances we might disclose it.


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INFORMATION WE COLLECT ABOUT YOU

We collect the following types of data in order to provide the Services, help us personalize and improve your experience, and operate our business. The data we collect includes:


Personally identifiable information, which is information that identifies you personally (“Personally Identifiable Information” or “PII”), such as name, address, phone number, etc. The definition of “personal information” under certain state laws differs from the definition of PII used in this Privacy Policy. You can learn more about your state privacy rights here.


Demographic information, such as your gender, age, ZIP code, interests, and recent upcoming purchases (“Demographic Information”). Except to the extent required by applicable law, Demographic Information not linked to PII is “non-Personally Identifiable Information” or “non-PII” (i.e., data that is not Personally Identifiable Information under this Privacy Policy) PII and therefore, may be used or shared without obligation to you, except as prohibited by applicable law.


PII, once “de-identified” or “aggregated” (i.e., the removal or modification of the personally identifiable elements, or the extraction of non-personally identifiable elements) is also non-PII. Non-PII may be used or shared without obligation to you, except as prohibited by applicable law. For instance, we may aggregate general information such as our customers’ geographic locations, age groups, genders, product and/or cosmetic concerns, and brands and products used in a manner that removes Consumer identities so that the aggregated information is not linked or reasonably linkable to any Consumer or household. Such aggregated information does not constitute PII.


We collect PII and non-PII in a variety of ways, including:


  1. Information We Collect Automatically

We may collect information from you automatically when you interact with us, including, without limitation, as follows:


a. Location, device, and connection information

We may collect location data (including IP addresses), and 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. This number is identified and logged automatically in our server log files whenever you visit the Service, 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 Service usage levels, helping diagnose problems with servers, analyzing trends, including suspicious activity detection and prevention, administering the Service, tracking traffic patterns, and gathering geographic information for aggregate and other use. Collecting IP addresses is standard practice on the Internet and is done automatically by many websites. If you access the Service via a mobile device such as a smartphone, the collected information may also include your device identifiers, location, and other similar mobile device data.


b. 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 may be used to optimize functionality.


c. Cookies and other Tracking Technologies

We, and our service providers and other third parties, may use cookies, web beacons, and similar technologies (“Tracking Technologies”) to collect data while you use our Service. This data is typically collected from the devices (including mobile devices) that you use. Tracking Technologies may track your activities across time and locations. Please see the Cookies and Other Tracking Technologies section below for more information, including regarding choices you have regarding Tracking Technologies.


d. Communications

Additionally, for quality, training and other purposes we may monitor or record our telephone conversations with you or anyone acting on your behalf, as well as monitoring use of the Service. By communicating with Rodan + Fields, or by using our Site, you acknowledge that your communications and activities may be overheard, monitored, or recorded.


  1. Information You Provide to Us

We collect information you provide us when you use the Service or otherwise provide information to us, including:


  • When you decide to complete a user registration form, complete an online survey, or make a purchase, you may be asked to provide your contact information (e.g., name, e-mail address, mailing address, and telephone number).
  • When you place an order, we will also need to know your delivery and billing address, credit card number, and expiration date. Enrolling Consultants must also provide their date of birth, Social Security number, and other PII in order to begin a consultantship.
  • When you make a purchase, we collect from you the information required to complete your purchase — such as your full name, e-mail address, credit card number, shipping, and billing addresses.
  • When you communicate with us we collect information related to such communications.
    1. Third-Parties

We may collect information from or about you from other sources, including third parties, including our Consultants and third-party data providers. Please note that if you choose to share PII about yourself in an open format, such as through a Third-Party Service like Facebook or Twitter, some of that information could be deemed public.


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HOW WE USE PII

Rodan + Fields may use information about you, including PII, for any purposes not inconsistent with Rodan + Fields’ statements under this Privacy Policy, or otherwise made by us in writing at the point of collection, and not prohibited by applicable law. Our primary purpose in collecting PII is to operate our business and to provide you with a secure, smooth, efficient, and customized experience. We may use your PII to:


  1. Process Transactions and Send Related Notices

When you make a purchase, 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. 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. Rodan + Fields is not responsible for, and makes no representations regarding, the privacy practices and policies, and other policies or business practices, of any third parties.


  1. Provide Marketing and Newsletters

If you prefer not to receive commercial (i.e., primarily promotional) e-mails for us, please see the section below entitled Opt-Out For Promotional & Marketing Communications.


  1. Permit E-mails to Friends

We may provide the functionality to permit you to send messages regarding Site-related content or our products to a friend through the Service. If you wish to use this feature, you may provide us with your friend's e-mail 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.


  1. Send Administrative Communications Regarding The Site, Service-Related Announcements, Etc.

Sending these communications 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 not primarily promotional, you may not opt-out of receiving such communications.


  1. Perform Additional Functions
  • Provide sales support.
  • 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 e-mail messaging, as authorized by applicable law, our Terms and Conditions, and/or our agreement with Consultants (“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, our policies and procedures, or Consultant Agreement.
  • Otherwise operate our business except as may be inconsistent with the Privacy Policy, applicable notice at collection or applicable law.

We may use non-PII, including non-PII we create from PII, for any purpose not inconsistent with Rodan + Fields’ statements under this Privacy Policy, or otherwise made by us in writing at the point of collection, and not prohibited by applicable law.


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HOW WE SHARE PII WITH OTHER THIRD PARTIES

Except as restricted by applicable law, this Privacy Policy, or an applicable notice at collection, Rodan + Fields may share the PII we collect from you, including your name, contact details, and transactions and activities, in connection with our business, including without limitation:


Independent Consultants

Your PII, and other information, may be shared with Consultants, who conduct sales as independent businesses, if you choose to be associated with a Consultant, which will constitute your direction to share your information with your Consultant(s). If you so choose, we may share, for instance, your name, phone number, e-mail address, and other PII with Consultants, who may, in turn, share your PII with their upline organization (those Consultants who directly or indirectly sponsor the Consultant (an “Upline”). Consultants, including those in an Upline, may use this information for the purposes outlined in this Privacy Policy and their Consultant Agreement, including to follow up on orders you placed or contact you with other special offers about our products.


Friends

Please note that any PII you provide in connection with sending messages regarding us to a friend through the Service, such as your name and your e-mail address, and any message, will be disclosed to your friend.


Corporate Transactions

We reserve the right to transfer any and all information that we collect to a third-party in connection with any financing, reorganization, restructuring, bankruptcy, 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 due diligence related thereto).


Other Non-Affiliated Parties, Including Service Providers


a. Suspicious Activity Prevention and Risk Management

We may share PII to help prevent suspicious activity or assess and manage risk. For example, we may engage third-party vendors to assist us with fraud prevention.


Shipping

We may share PII in connection with shipping products you may have ordered through the Site. By selecting a third-party shipper you direct us to share your PII with them in connection with the shipping.


Other Service Providers

We may share PII to enable service providers under contract with us to support our business operations, such as bill collection, marketing, customer service, and technology services. In connection with digital advertising, analytics and other services, our service providers may also share your PII with other parties. See Use of Cookies and Other Tracking Technologies and State Privacy Rights for certain choices available with respect to cookies and related activities.


Please note that our employees and service providers may be located in foreign jurisdictions, and your PII may be subject to the laws of those foreign jurisdictions and accessible to law enforcement and other authorities.


Except as may be limited by applicable law, or our notice at collection, we may share non-PII for any purpose to any third-party.


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USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES

Like many other websites and applications, our Service may, directly or through trusted third-parties, use Tracking Technologies, such as cookies, web beacons (also known as “tracking pixels”), device recognition technologies, in-app tracking methods, device and activity monitoring and other tracking technologies now and hereafter developed, for the purposes described in this section and elsewhere in this Privacy Policy.


This section helps you understand what Tracking Technologies are, how we use them, and the options that you have. By using our Services you consent to the Tracking Technologies you may encounter; provided, however, that there are a number of ways explained below in which you can limit Tracking Technologies.


  1. Cookies

A cookie is a small text file that is stored on a user’s device, which may be session ID cookies or tracking cookies. Session cookies make it easier for you to navigate the Services and expire when you close your browser. Tracking cookies remain longer and help in understanding how you use the Service and enhance your user experience. Cookies may remain on your hard drive for an extended period of time. If you use your browser’s method of blocking or removing cookies, some but not all types of cookies may be deleted and/or blocked and as a result, some features and functionalities of the Service may not work. A Flash cookie (or locally shared object) is a data file which may be placed on a device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your device. HTML5 cookies can be programmed through HTML5 local storage. Flash cookies and HTML5 cookies are locally stored on your device other than in the browser and browser settings will not control them. To identify certain types of local shared objects on your device and adjust your settings, please visit: www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. The Service may associate some or all of these types of cookies with your devices. See the Your Choices Regarding Cookies and Tracking Technologies section below to learn more about how you can exercise cookie preferences.


  1. Web Beacons / Tracking Pixels

Tracking pixels are small graphic images, also known as “Internet tags” or “clear gifs,” embedded in web pages and e-mail messages. Tracking pixels may be used, without limitation, to count the number of visitors to the Service, to monitor how users navigate the Service, and to count content and e-mail views. We use tracking pixels 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.


  1. In-app tracking methods

There are a variety of Tracking Technologies that may be included in mobile applications, and these are not browser-based like cookies and cannot be controlled by browser settings. Some use device identifier, or other identifiers such as “Ad IDs,” or may use “SDKs,” to associate app user activity to a particular app and to track user activity across apps and/or devices. SDKs are blocks of code that may be installed in our mobile application by third-party companies with which we work. SDKs help us understand how you interact with our mobile application and collect certain information about the device and network you use to access our application, such as the advertising identifier associated with your device and information about how you interact with our application.


  1. How we use Tracking Technologies?

Tracking Technologies may be used, for instance, 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 PII 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 PII. We may also use these technologies to help us better manage content, such as by improving the user interface. Finally, we and third parties may use these technologies (directly or through other parties and sources) to build a better picture of the type of offers and products that you might be interested in, cross-device matching, and interest-based advertising. See the Your Choices Regarding Cookies and Tracking Technologies section below to learn more about how you can exercise preferences regarding certain uses.


  1. Location-Based Services

GPS (global positioning systems) software, geo-filtering and other location-aware technologies locate you, or make assumptions about your location, for purposes such as verifying your location and delivering or restricting content. Our website and app do not generally use location-specific advertising, except that our “Find a Consultant feature may access and use information about your device location (such as based on IP address or GPS, as applicable), or your account information, to suggest appropriate Consultants in your area. We may use location information to engage in interactive, real-time discussions with users, which we or the users may initiate. See the Your Choices Regarding Cookies and Tracking Technologies section below to learn more about how you can exercise preferences regarding certain uses.


  1. Cross-Device Matching

Technologies, including application of statistical probability to data sets, as well as linking a common unique identifier to different device use (e.g., Facebook ID), which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user or household) (“Cross-device Data”).


We may now or in the future use the data collected through Tracking Technologies (directly by us or by our service providers) and other data (i.e. deterministic data such as unique identifiers) to make educated predictions that give us the ability to match your devices. We may then, subject to the limitations otherwise set forth in this Privacy Policy and applicable law, display targeted advertisements to you across your devices (unless you have opted-out for a particular device as described in the options section below.)


  1. 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 PII such as your e-mail address), and from other sources, 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 advertising that is more relevant to you. Our partners may place or recognize a Tracking Technology placed on your computer, device, or directly in our e-mails/communications, and we may share PII with them for interest-based advertising purposes. Our partners may 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. Rodan + Fields is not responsible for, and makes no representations regarding, the policies or business practices of any third parties, including, without limitation, analytics Service Providers and Tracking Technologies associated with the Service. 


See the Your Choices Regarding Cookies and Tracking Technologies section below to learn more about how you can exercise preferences regarding interest-based advertising.


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YOUR CHOICES REGARDING COOKIES AND TRACKING TECHNOLOGIES

  1. Tracking Technologies Generally

Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options, so you may need to set them separately. In addition, tools from commercial browsers may not be effective with regard to Flash cookies (also known as locally shared objects), HTML5 cookies or other Tracking Technologies. For information on disabling Flash cookies, go to Adobe’s website http://helpx.adobe.com/flash-player/kb/disable-third-party-local-shared.html.


You may choose to decline Tracking Technologies by adjusting your browser preferences. To address your cookie preferences you can contact us by email at privacy@rodanandfields.com or visit the Contact Us section of our website. Note that doing either may affect your use of the Service and your ability to access certain features or engage in certain transactions through the Service. If you delete your cookies, change browsers, or change devices, cookies that the Service may have used in the past (or an opt-out cookie) may no longer work.


Some app-related Tracking technologies in connection with non-browser usage (e.g., most functionality of a mobile app) can only be disabled by uninstalling the app. To uninstall the app, follow the instructions from your operating system or handset manufacturer. Apply and Google mobile device settings have settings to limit ad tracking, and other tracking, but these may not be completely effective.


Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many online services, Rodan + Fields’ currently does not alter Rodan + Fields’ practices when Rodan + Fields’ receives a “Do Not Track” signal from a visitor’s browser.


Some third parties may offer you choices regarding their Tracking Technologies. One way to potentially identify cookies on our web site is to add the free Ghostery plug-in to your browser (www.ghostery.com), which according to Ghostery will display for you traditional, browser-based cookies associated with the web sites (but not mobile apps) you visit and privacy and opt-out policies and options of the parties operating those cookies. Rodan + Fields’ is not responsible for the completeness or accuracy of this tool or third-party choice notices or mechanisms. For specific information on some of the choice options offered by third-party analytics and advertising providers, see the next section. We may, from time-to-time, offer or point you to tools that allow you to exercise certain preferences regarding cookies and other Tracking Technologies associated with the Services, but such tools rely on third-parties and third-party information so we do not guaranty that the tools will provide complete and accurate information or be completely effective. For instance, here is where you can find cookie controls for popular browsers:



We do not represent that these third-party tools, programs or statements are complete or accurate. You will need to do this on each browser that you use to access our Services, and clearing cookies on your browser(s) may disable your preference settings. In addition, our Site may not function properly or as intended if you block all or even certain cookies. Accordingly, you may want to consider the more limited opt-out choices noted in the next section.


  1. Analytics, Interest-Based Advertising, and Tracking Technologies Opt-Out

You may exercise choices regarding certain use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on. 


As described in this Privacy Policy, 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 Site 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, and are treated by us as Third-party Services under this Privacy Policy. You may choose whether to receive some interest-based advertising by submitting opt-outs. 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. For Canada, you can visit https://optout.aboutads.info/?c=3&lang=en, which is the site offered by Digital Advertising Alliance of Canada (“DAAC”), that includes information on how Consumers may opt-out of interest-based advertising for companies participating in the DAAC. 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. Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use a different device or web browser or use a non-browser-based method of access (e.g., mobile app), your NAI / DAA browser-based opt-out may not, or may no longer, be effective. Rodan + Fields supports the ad industry’s Self-regulatory Principles for Online Behavioral Advertising and the Canadian Self-Regulatory Principles for Online Behavioural Advertising. We expect that ad networks we directly engage to serve you Interest-based Advertising will do so as well, though we cannot guaranty their compliance. We are not responsible for effectiveness of, or compliance with, any third parties’ opt-out options or programs or the accuracy of their statements regarding their programs.


  1. 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.


  1. Mobile Apps

With respect to Rodan + Fields’ Apps, you can stop all collection of data generated by use of the app by uninstalling the app. Also, you may be able to exercise specific privacy choices, such as enabling or disabling certain features (e.g., tracking across apps and websites owned by other online services, location-based services, push notifications, accessing calendar/contacts/photos, etc.), by adjusting the permissions in your mobile device and/or the app’s settings. For example, to limit receiving Interest-based Advertising on your mobile device, for iOS 14, go to “Settings,” select “Privacy,” select “Tracking,” and then toggle off “Allow Apps to Request to Track.” For earlier versions of iOS dating back to iOS 6, go to “Settings,” select “Privacy,” select “Advertising,” and toggle on “Limit Ad Tracking.” For Android, go to “Settings,” select “Privacy,” select “Ads,” and then toggle on “Opt out of Ads Personalization.” Beware that if GPS precise location services are disabled, other means of establishing or estimating location (e.g., connecting to or proximity to Wi-Fi, Bluetooth, beacons, or our networks) may persist. To learn more about how you can control location permissions using your mobile device’s operating system settings, please visit the following links depending on which device you use:


Android:
For Android 6.0 and above: https://support.google.com/googleplay/answer/6270602?hl=en
For earlier versions of Android: https://support.google.com/googleplay/answer/6014972


iOS: https://support.apple.com/en-us/HT207056


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Rodan + Fields is headquartered in the United States. The Services and information we and our service providers collect and process is governed by the laws of the United States. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored, and used in the U.S., or to other countries or places in which we maintain offices or do business, including Australia, Canada, and Japan. Data protection laws in those jurisdictions may be different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer, processing, usage, sharing, and storage of your information, including Personally Identifiable Information, to the U.S. or elsewhere, as set forth in this Privacy Policy.


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Notwithstanding any other provision of this Privacy Policy to the contrary, we reserve the right to disclose your PII to others as we believe to be appropriate: (a) to comply with legal process; (b) to respond to governmental requests; (c) to enforce our Terms and Conditions; (d) to protect our operations; (e) to protect the rights, privacy, safety or property of Rodan + Fields, you or others; and (f) to permit us to pursue available remedies or limit the damages that we may sustain. We may disclose any information we deem necessary, in our sole discretion, to comply with any applicable law, regulation, legal process, or governmental request.


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The Service is intended for a general audience and not directed to children less than 13 years of age. 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 Service.


Rodan + Fields does not intend to collect personal information as defined by the U.S. Children’s Online Privacy Protection Act (“COPPA”) (“Children’s Personal Information”) in a manner that is not permitted by COPPA. If we obtain knowledge that we have collected Children’s Personal Information in a manner not permitted by COPPA, we will delete such data to the extent required by COPPA.


As described more below California residents under the age of eighteen (18) who have registered to use the Service, and who posted content or information on the Service, can request removal by contacting Rodan + Fields here, detailing where the content or information is posted and attesting that you posted it. Rodan + Fields will then make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third-parties may have republished or archived content by search engines and others that Rodan + Fields does not control.


We may interact with to you on, or the Site may contain or link to third-party services, including social network and/or commerce providers, and you may interact with R+F independent Consultants on and off of our Site (“Third-party Services”). The use of any features made available to you on our Site by a Third-party Service (e.g., a “like” button or social media plug-in, visiting our branded pages on Third Party Services (e.g., InstagramFacebookTikTok, TwitterPinterest, and YouTube), or your providing information to Consultants, including through their pages on our Site, may result in information being collected or shared about you by the third-party or by us. Third-party Services are not under Rodan + Fields' control and we are not responsible for the privacy or other practices, or the contents of, any such Third-party Service. We provide links or access to Third-party Services only as a convenience, and the inclusion of a link or plug-in on the Site does not imply endorsement of the Third-party Service by Rodan + Fields.


Please read the privacy policies of third-party services because the information they collect and the posts they may publish will be governed by their privacy policies respectively. Except to the extent you provide or disclose your PII to us (e.g., via a private messaging function on a third-party service), our Privacy Policy does not govern third-party service activities.


We realize that our customers trust us to protect their PII. We take that task seriously and take reasonable measures to protect PII we collect from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. We maintain physical, electronic, and procedural safeguards to protect your PII. 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.


Data transmission over the Internet or in a data storage system cannot be guaranteed to be 100% secure. There is always a risk that third-parties may unlawfully intercept transmissions or otherwise access data. 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 e-mailing us at privacy@rodanandfields.com.


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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.


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We will post any changes to this Privacy Policy to the website. The changes will apply prospectively, not retrospectively.


You have the ability to change and/or correct the PII that you provide us by e-mailing us at privacy@rodanandfields.com. Under applicable law, you may have the right to ask in writing whether we hold any PII about you, to see that information, and request additional details as to how we collect, use or disclose your PII. See the Your State Privacy Rights section below for more 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 PII requested. You may request that we deactivate your account by e-mailing us at privacy@rodanandfields.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 promotional communications in accordance with applicable laws.

You can make changes to your account profile information through “Account Settings.” This will only change your account profile and not other records. Residents of some states have additional rights as set forth in the State Privacy Notice


You may opt-out of receiving future commercial (i.e., promotional) e-mails from Rodan + Fields. Please note that this opt-out only applies to Rodan + Fields promotional e-mails. You may opt-out of receiving promotional e-mails by using the opt-out mechanism in the footer of the e-mail itself or by e-mailing us at optout@rodanandfields.com. You may also opt-out of receiving text communications (e.g., SMS) by following the instructions provided in text messages from Rodan + Fields to text the word, “STOP.” If you are using our app and would like to opt-out of push notifications, you may turn off push notifications on the settings of your device and/or the app, as applicable.


We will endeavor to comply with your request as soon as reasonably practicable. Please note that your opt-out is limited to the e-mail address or phone number used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other communications may continue. Even if you opt-out of receiving promotional communications, Rodan + Fields may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, or Rodan + Fields’ ongoing business relations with you. In addition, opting-out as described above will not remove your information from our databases or the databases of Consultants or third-parties. If you wish to cease receiving marketing-related e-mails from such Consultants or other 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 e-mails.


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YOUR STATE PRIVACY RIGHTS

1. California Residents


a. California Consumer Privacy Act ("CCPA")


This section describes how we handle the “Personal Information” of California residents (defined as “Consumers”) as regulated by the CCPA. This section does not apply to the PI we maintain about our employees, independent contractors, and job applicants. A separate notice is available from our human resources department for our job applicants, current and former employees and independent contractors (“Personnel”). It does not apply in the context of business-to-business (“B-to-B”) communications data, including our Consultant’s personal information, which is currently exempt under the CCPA. Capitalized terms not defined in this section shall have the meaning provided to them by the CCPA.


(i) Notice at Collection

We collect the following categories of Personal Information:


  • Identifiers: We collect identifiers such as real name, alias, postal address, unique personal identifiers, online identifier, Internet Protocol address (see “internet activity” below), e-mail address, and account name.
  • Personal 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.
  • Personal Characteristics or Traits: 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 (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.
  • Customer Account Details/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.
  • Internet Usage Information: 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.
  • Geolocation Data: If you interact with us online we may gain access to the approximate location of the Device or equipment you are using.
  • Sensory Data: In some circumstances, we collect audio information (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.
  • 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.

There may be additional information that we collect that meets the CCPA’s definition of Personal Information but is not reflected by one of the categories above, in which case we will treat it as Personal Information as required by the CCPA, but will not include it when we are required to describe our practices by category of Personal Information.


As permitted by applicable law, we do not treat Deidentified data or Aggregate Consumer Information as Personal Information and we reserve the right to convert, or permit others to convert, your Personal Information into Deidentified data or Aggregate Consumer Information, and may elect not to treat publicly available information as Personal Information.


Use of Personal Information: 

Generally, Rodan + Fields collects, retains, uses, and shares your Personal Information to provide you services and as otherwise related to the operation of our Business, including for one or more of the following Business Purposes:


  • Processing Interactions and Transactions;
  • Managing Interactions and Transactions;
  • Performing Services (e.g., to provide customer service and fulfill your orders);
  • Research and Development;
  • Quality Assurance (e.g., to improve the services we provide to you);
  • Security (e.g., to help us protect against fraud or other criminal activity); and
  • Debugging.

Additional Business Purposes for which we collect, retain, use and/or disclose Personal Information, including sharing Personal Information with third-parties for other than a Sale (e.g., at your direction, such as to Consultants and shippers) or, as permitted by applicable law, to the government or private parties to comply with law or legal process, and to the Consumer or other parties at the Consumer’s request, for the additional purposes explained in our Privacy Policy, and to assignees as part of a merger or asset sale (“Other Business Purposes”). 


Subject to restrictions and obligations under the CCPA and applicable law we may collect, retain, use and disclose your Personal Information for Other Business Purposes. Note that our Service Providers may themselves engage subcontractors to enable them to perform services for us, which for purposes of certainty, is an additional Other Business Purpose for which we are providing you notice.


As described in the Your CCPA Rights section below, the collection of Personal Information by some third-party cookies, such as by some interest-based advertising cookie operators, may be considered a “commercial purpose” and a “sale” by us.


(ii) Collection and Sharing Practices in Calendar Year 2021


In calendar year 2021, we collected and disclosed Personal Information to our Service Providers, other members of our corporate group, government entities (when we are under a duty to disclose or as required to protect our rights or the rights of others), Third-Parties (e.g., Consultants to whom individual has expressly authorized Rodan + Fields to disclose the individual’s Personal Information in connection with products and services provided to the individual), and/or any other third-parties as necessary to provide services to our clients for all of the categories of Personal Information outlined in the Notice at Collection section, for all of the Business Purposes and commercial purposes described therein. Below we describe our sharing practices:


Category of PI


Categories of Recipients


1. Identifiers


Business Purpose Disclosure:


· Service Providers (e.g., data analytics providers, payment processors, and marketing services providers)


· other members of our corporate group


· governmental entities (making requests pursuant to law or legal process)


· Third-Parties (e.g., Consultants)


· Other third-parties as necessary to provide services to our clients (e.g., shippers)


Sale: N/A.


2. Personal Records


Business Purpose Disclosure:


· Service Providers (e.g., data analytics providers, payment processors, and marketing services providers)


· other members of our corporate group


· governmental entities (making requests pursuant to law or legal process)


· Third-Parties (e.g., Consultants)


· Other third-parties as necessary to provide services to our clients


Sale: N/A


3. Personal Characteristics or Traits


Business Purpose Disclosure:


· Service Providers (e.g., marketing services providers)


· Other members of our corporate group


· Third-Parties (e.g., Consultants)


· Other third-parties as necessary to provide services to our clients


Sale: N/A


4. Customer Account Details / Commercial
Information


Business Purpose Disclosure:


· Service Providers (e.g., operations and administrative vendors, cloud services providers, and data storage services)


· Other members of our corporate group


· Third-Parties (e.g., Consultants)


· Other third-parties as necessary to provide services to our clients


Sale: N/A


5. Internet Usage Information


Business Purpose Disclosure:


· Service Providers (e.g., data analytics providers)


· Other members of our corporate group


· Third-Parties (e.g., Consultants)


· Other third-parties as necessary to provide services to our clients


Sale: Cookie Operators (but see Do Not Sell section below).


6. Geolocation Data


Business Purpose Disclosure:


· Service Providers (e.g., data analytics providers)


· Other members of our corporate group


· Third-Parties (e.g., Consultants)


· Other third-parties as necessary to provide services to our clients


Sale: N/A.


7. Sensory Data


Business Purpose Disclosure:


· Service Providers (e.g., security vendors and call centers)


· Other members of our corporate group


· Third-Parties (e.g., Consultants)


· Other third-parties as necessary to provide services to our clients


Sale: N/A


8. Inferences from PI Collected


Business Purpose Disclosure:


· Service Providers (e.g., marketing services providers)


· Other members of our corporate group


· Other third-parties as necessary to provide services to our clients


Sale: N/A



    Your CCPA Rights


    Your California Consumer privacy rights are as follows:


    Right to Know: You have a Right to Know (1) the categories; and (2) specific pieces of Personal Information maintained by a Business about you.


    (1) Right to Know (Categories): You have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date:

    • The categories of PI we have collected about you.
    • The categories of sources from which we collected your PI.
    • The Business Purposes or Commercial Purposes for our collecting or selling your PI.
    • The categories of third-parties to whom we have shared your PI.
    • A list of the categories of PI disclosed for a Business Purpose in the prior 12 months and, for each, the categories of recipients, or that no disclosure occurred.
    • A list of the categories of PI sold about you in the prior 12 months and, for each, the categories of recipients, or that no sale occurred.

    (2) Right to Know (Specific Pieces): You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your Personal Information that we have collected in the 12 months prior to the request date and are maintaining.


    For your specific pieces of information, as required by the CCPA, we will apply the heightened verification standards set forth in the How to Submit a Request Under the CCPA section below.


    To make a Right to Know (Categories) or Right to Know (Specific Pieces) request, follow the instructions at our Consumer Rights Request page here email us at privacy@rodanandfields.com, and respond to any follow up inquiries we make. We will respond to your request as outlined in the How to Submit a Request Under the CCPA section below. Please note that Personal Information is retained by us for various time periods, so we may not be able to fully respond to what might be relevant going back 12 months prior to the request.


    Do Not Sell: We do not believe that we “sell” your Personal Information as such is defined under the CCPA and, subject to our treatment of “Cookie Operators,” described below, do not offer an opt-out of Sale. However, excepting our treatment of Cookie Operators below, we will not sell Personal Information that we collected without having given you notice and obtained your affirmative consent. 


    Although we do not believe that we sell Personal Information collected by cookie operator third-party services (“Cookie Operators”), we will treat Personal Information (“other identifiers” (e.g., cookie ID, IP address, and other online IDs) and “internet or other electronic activity information”) collected by Cookie Operators, where not limited to acting as our Service Provider, as a Sale and subject to a Do Not Sell opt-out request. We offer a cookie management tool that enables you to exercise your Do Not Sell opt-out request and enable certain cookie preferences on your Device. You must exercise your preferences on each of our websites you visit and from each browser and on each Device that you use. Since your opt-out is designated by a cookie, if you clear or block cookies, your preferences will not be effective and you will need to enable them again via our cookie management tool. Also, if you use ad blockers the display of the automatic display of the cookie management tool may be blocked and you may have to click on the link above to access it.


    See the Your Choices Regarding Cookies and Tracking Technologies section of our Privacy policy for other ways to exercise preferences regarding Cookie Operators.


    We do not knowingly sell the Personal Information of Consumers under 16, unless we receive affirmative authorization (“opt-in”) from either the Consumer who is between 13 and 16 years old, or the parent or guardian of a Consumer who is less than 13 years old. If you think we may have unknowingly collected Personal Information of a Consumer under 16 years old, please Contact Us.


    We may disclose your Personal Information for the following purposes, which are not a sale: (i) if you direct us to share Personal Information; (ii) to comply with your requests under the CCPA; (iii) disclosures amongst the entities that constitute Company as defined above, or as part of a merger or asset sale; and (iv) as otherwise required or permitted by applicable law.


    Right to Delete: Except to the extent we have a basis for retention under CCPA, you may request that we delete your Personal Information that we have collected directly from you and are maintaining. Our retention rights include, without limitation:


    • to complete transactions and services you have requested;
    • for security purposes;
    • for legitimate internal Business Purposes (e.g., maintaining Business records);
    • to comply with law and to cooperate with law enforcement; and
    • to exercise or defend legal claims.

    Note also that we are not required to delete your Personal Information that we did not collect directly from you.


    To make a Right to Delete request follow the instructions at our Consumer Rights Request page here, email us at privacy@rodanandfields.com, and respond to any follow up inquiries we make. We will respond to your request as outlined in the How to Submit a Request Under the CCPA section below. 


    Non-Discrimination

    We will not discriminate against you in a manner prohibited by the CCPA for your exercise of your CCPA rights. We may charge a different price or rate, or offer a different level or quality of good or service, to the extent that doing so is reasonably related to the value of the applicable data. 


    Notice of Financial Incentive Programs

    We may offer discounts or other rewards (“incentives”) from time-to-time to customers that provide us with Personal Information, such as your name, phone number, email address, IP address and location. Each program may have additional terms, which are available on our Promotional Terms and Conditions page, or at program sign-up. The incentives will be described in the Promotional Terms and Conditions or at program sign-up. We measure the value your Personal Information collected in these programs by the cost of operating the applicable program (excluding incentive costs) and/or the cost of providing the incentive. We deem the value of the Personal Information to be reasonably related to the value of the incentive, and by subscribing to these programs you indicate that you agree. If you do not, do not subscribe to the programs. If you subsequently wish to withdraw from the programs, the method for doing so will be explained in the program terms. For the email marketing program you may opt-out by following the unsubscribe instructions on our commercial emails. You may opt-out of marketing text messages by texting STOP to any text message you receive from us.


    (iv) How to Submit a Request Under the CCPA


    California Consumers have the right to exercise CCPA rights. You may submit a request to exercise your CCPA rights (1) as an individual; or (2) via an authorized agent who meets the agency requirements of the CCPA and related regulations. 


    As described more below, in accordance with the CCPA, any request you submit to us is subject to an identification verification process (“Verifiable Consumer Request”).


    Methods to Submit Request:To submit a request to exercise your CCPA rights, or to submit a request as an authorized agent, please follow the instructions at our Consumer Rights Request page here, email us at privacy@rodanandfields.com and respond to any follow up inquiries we make.


    Your Request Must be a Verifiable Consumer Request. As permitted by the CCPA, any Right to Know or Right to Delete request you submit to us must be a Verifiable Consumer Request. This means that your request is subject to an identification verification process. We will not fulfill your Right to Know (Categories), Right to Know (Specific Pieces), or Right to Delete request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected Personal Information.


    You are not required to create a password-protected account with us to make a Verifiable Consumer Request. We will use Personal Information provided in a Verifiable Consumer Request only to verify your identity or authority to make the request and to track and document request responses, unless you also gave it to us for another purpose.


    We verify each request as follows:

    • Right to Know (Categories): If you do not have a password-protected account, we are required to verify a Consumer’s request to know categories of Personal Information to a reasonable degree of certainty, which may include matching at least two data points provided by the Consumer with data points maintained by us, which we have determined to be reliable for the purpose of verifying the Consumer.
    • Right to Know (Specific Pieces): If you do not have a password-protected account, we are required to verify a Consumer’s request to know specific pieces of Personal Information to a reasonably high degree of certainty, which may include matching at least three data points provided by the Consumer with data points maintained by us, which we have determined to be reliable for the purpose of verifying the Consumer If you fail to provide the data points we will be unable to verify you sufficiently to honor your request, but we will then treat it as a Right to Know (Categories) request.
    • Do Not Sell: No specific verification required unless we suspect fraud.
    • Right to Delete: If you do not have a password-protected account, we are required to verify a Consumer’s request to delete to a reasonable degree of certainty, which may include matching at least two data points provided by the Consumer with data points maintained by us, or to a reasonably high degree of certainty, which may include matching at least three data points provided by the Consumer with data points maintained by us, depending on the sensitivity of the PI and the risk of harm to the Consumer posted by unauthorized deletion.

    If you fail to provide the data points specified above, we will be unable to verify you sufficiently to honor your request. The information you send for us to verify your identity will be used for this purpose only.


    Agent Requests. You may use an authorized agent to make a request for you, subject to our verification of the agent, the agent’s authority to submit requests on your behalf, and of you. You can learn how to do this by contacting us at privacy@rodanandfields.com. Once your agent’s authority is confirmed, they may exercise rights on your behalf subject to the agency requirements of the CCPA.


    Our Responses. Some Personal Information we maintain about Consumers is not sufficiently associated with enough Personal Information about the Consumer for us to be able to verify that it is a particular Consumer’s Personal Information when a Consumer request that requires verification pursuant to the CCPA’s verification standards is made (e.g., clickstream data tied only to a pseudonymous browser ID). As required by the CCPA we do not include that Personal Information in response to those requests. If we cannot comply with a request, we will explain the reasons in our response. 


    We will make commercially reasonable efforts to identify Consumer Personal Information that we collect, process, store, disclose and otherwise use and to respond to your California Consumer privacy rights requests. In some cases, particularly with voluminous and/or typically irrelevant data, we may suggest that you receive the most recent or a summary of your Personal Information and give you the opportunity to elect whether you want the rest or not. We reserve the right to direct you to where you may access and copy responsive Personal Information yourself. We will typically not charge a fee to fully respond to your requests; provided, however, that we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded or overly burdensome. If we determine that the request warrants a fee, or that we may refuse it, we will give you notice explaining why we made that decision. You will be provided a cost estimate and the opportunity to accept such fees before we will charge you for responding to your request.


    Consistent with the CCPA and our interest in the security of your Personal Information, we will not deliver to you certain sensitive data (e.g., credit card number), but we will let you know in our response to your request what types of your sensitive data we may have.


    (v) Our Rights and Rights of Others


    Notwithstanding anything to the contrary, we may collect, use and disclose your Personal Information as required or permitted by applicable law and this may override your CCPA rights. In addition, we are not required to honor your requests to the extent that doing so would infringe upon our or another person’s or party’s rights or conflict with applicable law.


    b. Additional California Notices


    In addition to the CCPA, certain Californians are entitled to certain other notices, including:


    (i) Online Privacy Practices


    This Privacy Policy and the State Privacy Notice therein provides information on our online practices and your California rights specific to our online services. Without limitation, Californians that visit our online services and seek to acquire goods, services, money or credit for personal, family or household purposes are entitled to the following notices of their rights:


    (1) Tracking and Targeting


    When you visit our online services, we and third-parties may use tracking technologies to collect usage information based on your device for a variety of purposes, including serving you advertising, based on your having visited our services or your activities across time and third-party locations. Some browsers may enable you to turn on or off a so-called “Do Not Track” signal. Because there is no industry consensus on what these signals should mean and how they should operate, we do not look for or respond to “Do Not Track” signals. For more information on tracking and targeting and your choices regarding these practices, see our Privacy Policy.


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    (2) California Minors


    Although our online service(s) are intended for an audience that has reached the age of majority, any California residents under the age of eighteen (18) who have registered to use our online services, and who posted content or information on the service, can request removal by contacting us, detailing where the content or information is posted and attesting that you posted it. We will then make reasonably good faith efforts to remove the post from prospective public view or anonymize it, so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third-parties may have republished or archived content by search engines and others that we do not control.


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    (ii) Shine the Light


    California residents may request a list of all third parties to which we have disclosed certain personal information (as defined by California’s Shine the Light law), collected via our online service, during the preceding year, for those third parties’ own direct marketing purposes, without your consent or direction. We do not do so. When you choose a Consultant, you direct us to provide your personal information to the Consultant. If you want to confirm this you may contact us at privacy@rodanandfields.com or at RODAN + FIELDS HEADQUARTERS, 60 Spear Street, Suite 600, San Francisco, CA 94105 and put the statement “Shine the Light Request” in the body of your request. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. Please note that we will not accept Shine the Light requests via telephone or by facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.


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    1. Nevada Residents

    Nevada law allows customers to “opt-out” of the sale of certain personal information, called “covered information.” Although we do not “sell” “covered information” of Nevada “consumers” as those terms are defined by Chapter 603A of the Nevada Revised Statutes, you may contact us by e-mail at privacy@rodanandfields.com and provide your name, Nevada resident address, and e-mail address to be verified and exercise your opt-out rights in the event we do sell covered information under that law in the future. If your contact information changes at any point, contact us in the same manner to update your contact information. For more information about our data collection and sharing practices, please review this Privacy Policy. We may share your data as explained in this Privacy Policy for different purposes, such as to make your experience and our services better, and those activities are separate from the opt-out request.


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    CONTACT US

    If you have any questions, comments, concerns, or complaints about the Site's privacy practices, please contact us by e-mail at privacy@rodanandfields.com or visit the Contact Us section of our website. Please note that e-mail communications will not necessarily be secure; accordingly, you should not include credit card information or other sensitive information in your e-mail correspondence with us.


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