The CCPA applies to personal information of California consumers, such as those who buy Fresh specialty skin care products or perfumes in stores or online, those who sign up for our programs or services, and those who browse our website. “Personal information” is defined broadly in the CCPA, and essentially encompasses any information that can be used directly or indirectly to identify a California resident.

The personal information that Fresh collects about California consumers depends upon the touchpoint of our interaction with you, and is also limited to that which is relevant and appropriate for the interaction and purpose of the collection. Please see our Website Privacy Statement (www.Fresh.com) for more details.

Fresh does not and will not ‘sell’ personal information of California residents (as that term is defined in the CCPA). To the extent that your personal information is accessible to our affiliated companies, or to third party who assist us with our services to customers (called “Service Providers” under the CCPA), they are also prohibited from “selling” your personal information as defined in that law.

As an added assurance to our customers against any future change in our practices in relation to ‘selling’ their personal information, we have also implemented a “Do Not Sell My Personal Information” Log along with surrounding processes to flag your personal data that we hold about you, so that it is never “sold” in the future. California residents can contact us by using one of the Contact Methods in this Notice (see below) to be added to our Do Not Sell Log.

Fresh will confirm to the California resident or, if applicable, their authorized agent, no later than 15 days from the date that we receive the request, that the California resident has been opted-out of the sale of his/her information under the CCPA, and that we have added him/her to the Do Not Sell My Information Log.

In accordance with the CCPA requirements, California residents may contact Fresh to exercise their right to know about the personal information that we hold about them as well as how the data was used, the categories of third parties with whom the data was shared, and the purpose(s) for the sharing of the information. They can do so by exercising that right via one of the options identified in the Contact Methods section of this Notice.

Fresh will acknowledge a right to know/access within 10 days of receipt. California residents or their authorized agents who seek to exercise this right are subject to comprehensive verification to minimize any risk to individuals of sharing their person information with an unauthorized individual. Fresh will deny the request if it is unable to verify the requestor and/or his/her authorized agent, and if so, we will inform the individual/authorized agent within 45 days of receipt of their request. Of course, Fresh can also deny the request if our company does not hold any personal information about the individual which falls within the scope of the CCPA.

Properly verified California residents and/or their authorized agents are entitled to receive information about (or a copy of) Personal Information collected by Fresh within the last 12 months before their request was made. Fresh will endeavor to fulfill those requests within 45 days, but may require an additional period of time (up to a total of 90 days) if necessary. If so, we will inform the requestor about the delay and the reasons therefore within the 45-day period.

California residents are limited to two such requests to know/access their data in any 12-month period (whether directly or via an authorized agent).

California residents have the right to request deletion of their personal information, and can make the request directly to us or via an authorized agent. They can do so by exercising that right via one of the options identified in the Contact Methods section of this Notice.

Fresh is not obligated to delete the personal information of the California resident if we are required or permitted to retain it in accordance with one of the exemptions in the CCPA.

Individuals who exercise their right to request deletion (directly or through an authorized agent) will be subject to verification in accordance with the CCPA requirements.

Fresh will acknowledge a request for deletion within 10 days of receipt, and will endeavor to fulfill the request within 45 days. If it becomes evident that Fresh is unable to delete all of the California resident’s data within the 45-day period, the company will inform the individual and/or the authorized agent within that period, and may take an additional 45-days to fulfill the request (i.e., a total of 90 days).

When Fresh processes a request for deletion from a California resident (which has been properly verified), it will delete the data from its systems in a secure and irreversible manner, to prevent the data from being restored.

To the extent that Fresh has entrusted any of the Personal Information of the California resident to a “Service Provider” (as that term is defined in the CCPA), it will also contact that Service Provider to process the deletion request and will confirm to the California resident (or his/her authorized agent, if applicable) that it has done so.

Fresh upholds the rights of California residents who are minors in relation to the collection and processing of their personal information. In accordance with the CCPA requirements, Fresh has also applied those rights to California residents between the ages of 13 and 16. We have also adopted practices to uphold the surrounding rights of parents and legal guardians of those minors.

Parents and legal guardians who seek to exercise the CCPA rights of their children will also be subject to authentication so as to prevent the release of any information pertaining to a minor to an unauthorized individual.

In accordance with the CCPA, Fresh does not discriminate against individuals, including those who choose to exercise their CCPA rights.

Fresh provides assistance to individuals with disabilities to communicate effectively with us. If you require these services, please contact us at privacy@fresh.com.

Fresh has put in place the following methods for California residents to exercise their rights under the CCPA.

• Toll-free number : 1 (833) 858-1115
• Email address: privacy@fresh.com

In accordance with the CCPA, Fresh allows California residents to exercise their CCPA rights via an authorized agent. California consumers must recognize that in those situations, Fresh requires authentication/verification of the authorized agent as well as the individual about whom the data relates, and we may deny the request if we are unable to obtain appropriate authentication/verification at either level. The authentication/verification requirements adopted by Fresh vary by right and take into consideration the potential risks to the individual of sharing their personal data with an unauthorized individual. Please see the specific rights (below), and general information about authentication/verification obligations associated with each of them.

California residents who have questions or who believe that Fresh has mismanaged their personal information or otherwise infringed their rights may contact us using the contact methods listed in this Notice.

For additional information about Fresh’s CCPA practices, please visit our website at www.Fresh.com or contact us via one of the options provided in the Contact Methods section of this Notice.

Fresh will review its CCPA notices and practices on at least an annual basis, and may also make updates to this Notice at other intervals, such as in relation to new information issued by the California regulators or in connection with changes to its business activities. We encourage you to review this Notice periodically to be sure you are aware of those changes. Any changes will serve to enhance or strengthen the privacy and security protections that are in place for personal information of California residents, and not diminish them.

Issued: Jan. 1, 2020

Copyright 2019. All rights reserved.