Health Data Notice

Last Updated: March 24, 2024

This policy governs the websites (each a “Site”), apps (each an “App”), offline locations or services (collectively, the “Services”) owned and operated by REN LTD (referred to herein as “Ren Clean Skincare,” “we,” “us,” or “our” as applicable) that display, reference, or link to this Health Data Notice. This policy supplements the Ren Clean Skincare Privacy Notice and applies to “consumer health data” under US state privacy laws, including Washington’s My Health My Data Act and Nevada’s consumer health privacy law.

CONSUMER HEALTH DATA WE COLLECT

We collect the following categories of consumer health data, as defined by MHMDA.

• Information about your health-related conditions, symptoms, status, diagnoses, testing, procedures, or treatments, including information related to your skincare routine.
• Information that could identify your attempt to seek health related services.
• Your biometric data.
• Other information that may be used to infer or derive data related to the above or other health information.

SOURCES OF CONSUMER HEALTH DATA

As described further in the “Sources of Personal Information” section of the Privacy Notice, we collect consumer health data directly from you, from your interactions with our Services, and from third parties.

WHY WE COLLECT AND USE CONSUMER HEALTH DATA

We may use the categories of consumer health data described above for the following purposes:

• To Provide and Manage the Platform and the Services. We use your consumer health data to provide, administer, and manage the Platform (and its features) and as otherwise necessary to provide the Services and to operate our business.
• To Process and Fulfill Your Order(s). Where applicable, we use your consumer health data to process and fulfill your orders and requests for our products or services. We may also use your consumer health data to process your returns or inform you of any product recall.
• To Identify Usage Trends and Make Improvements. We use your consumer health data to understand how you use the Platform and identify usage trends. We also use your consumer health data to identify issues, test new features or changes in our features, and improve the Platform, the Services, and our products.
• To Understand Your Interests and Personalize Your Experience. We use your consumer health data to help us understand which parts of the Platform and/or which of our products are of interest to you. We also use your customer health data to customize or personalize your experience with us.
• To Communicate with You. We use your consumer health data to communicate with you about your account or our relationship; to respond to your submissions, requests, and inquiries; and to request information or feedback from you.
• To Determine Your Eligibility. We may use your consumer health data to verify your identity or determine your eligibility for some of our products, services, and promotions.
• To Conduct Research and Analytics. We use your consumer health data to help us conduct research and analytics and to otherwise measure the effectiveness of the Platform’s content and our online and offline marketing and advertising efforts.
• To Maintain Security and Prevent Fraud. We use your consumer health data to help monitor and maintain the security and integrity of the Platform as well as our systems and networks. Additionally, we use your consumer health data to detect; prevent; investigate; and protect you, our business, and others from fraud, unauthorized transactions, and other unlawful or unsafe activity.
• To Satisfy Our Legal Obligations. We use your consumer health data to comply with applicable law and respond to lawful requests and communications from law enforcement authorities and other government officials.
• To Carry Out Sales and Business Transactions. We may use your consumer health data in connection with the evaluation, negotiation, and/or completion of a business transaction (e.g., a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets), whether as a going concern or as part of any bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred or is otherwise relevant to the evaluation, negotiation, or completion of the transaction.
• As Otherwise Permitted, Necessary, or Appropriate. We use your consumer health data as otherwise described in this policy or as explained to you at the point of information collection. We will also use your consumer health data at your direction or with your consent. Finally, we will use your personal information as we believe necessary or appropriate to protect our rights, privacy, safety, property, and/or those of others.

WITH WHOM DO WE SHARE CONSUMER HEALTH DATA

As defined by MHMDA, we share consumer health data with the categories of third parties listed below. We will obtain your consent before sharing your consumer health data.  

• Our Affiliates. We may disclose your consumer health data within the Unilever Group of companies and brands for purposes consistent with this policy and other business and operational purposes.
• Our Business Partners. We disclose your consumer health data to other companies with whom we partner to offer products and services and carry out other related activities. For example, we may disclose your consumer health data to a third party that co-sponsors a contest or promotion.
• Our Research Partners. We disclose your consumer health data to our research partners, including those that perform surveys or research projects in partnership with us or on our behalf.
• Competent Governmental and Public Authorities. We disclose your consumer health data as necessary pursuant to a court order or subpoena or to cooperate with a government agency or investigatory body request.
• Other Parties. We disclose your consumer health data to other parties at your direction or with your consent. Finally, we disclose your consumer health data to other parties as we believe necessary or appropriate either to: (i) comply with applicable law; (ii) protect our operations and those of any of our affiliates; (iii) investigate and prevent against fraud; (iv) protect our rights, privacy, safety, or property and/or those of others; or (v) allow us to pursue available remedies or limit damages that we may sustain.

We may disclose your consumer health data for other reasons that we will describe at the time of collection or prior to disclosing your consumer health data.

HOW TO EXERCISE YOUR RIGHTS

MHMDA provides covered individuals with certain rights to access, delete, or withdraw consent relating to their consumer health data, subject to certain exceptions. 

If you would like to exercise the rights outlined above, you can do so, by either clicking “Do Not Sell or Share My Personal Information” in the footer of our website and following the instructions on the window that pops up or Sending an email to privacy@renskincare.com with the subject line “Do Not Sell or Share My Personal Information. If you send a request by email, please write “Washington Consumer Health Data Request” in the subject line and state which rights you seek to exercise in the body of your message. We may take steps to verify your identity before responding to your request by asking you a series of questions about your previous interactions with us.

REVISIONS TO THIS PRIVACY POLICY

We reserve the right, at our sole discretion, to change, modify, add, remove, or otherwise revise portions of this policy at any time. When we do, we will post the change(s) on our Services. Your continued use of our products and Services following the posting of changes to these terms means you accept these changes. If we change this policy in a material or substantive way, we will provide appropriate notice to you.

HOW TO CONTACT US

If you have any questions or concerns about this policy or the practices described herein, you may contact us at customerserviceUSA@renskincare.com, by calling 310-356-4144, or by mail to 2121 Park Place, Ste 100, El Segundo California 90245, United States.