CALIFORNIA NOTICE DISCLOSURES FOR CALIFORNIA RESIDENTS

Last Updated: September 2023

This privacy notice for California residents (the “CA Privacy Notice”) supplements the information contained in the Royal Robbins Privacy Notice and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this CA Privacy Notice in accordance with applicable California law, including the California Consumer Privacy Act of 2018 and the California Consumer Privacy Act of 2020, as both are amended from time to time (hereinafter “CCPA”). Any terms defined in the CCPA have the same meaning when used in this CA Privacy Notice. Any capitalized but undefined terms shall have the meanings set forth in the Privacy Notice.

Please note that as used in this CA Privacy Notice, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information does not include de-identified or aggregated consumer information, publicly available information from government records, or information outside of the CCPA’s scope.

Use the links below to toggle to each section.

Contents

SECTION 1 - Collection and Use of Personal INFORMATION

SECTION 2 - Retention of Personal INFORMATION

SECTION 3 - Disclosures of Personal INFORMATION for a Business Purpose

SECTION 4 - Sales or Sharing of Personal INFORMATION

SECTION 5 - Rights and Choices of California Residents

SECTION 6 - Exercising Access, Data Portability, Data Correction, and Deletion Rights

SECTION 7 - Response Timing and Format

SECTION 8 - Non-Discrimination

SECTION 9 - Notice of Financial Incentive

SECTION 10 - Other California Privacy Rights

SECTION 1 - Collection and Use of Personal Information

We have collected the following categories of personal information from our consumers within the last 12 months for the business or commercial purposes described below:

Description	Examples	Source	Primary Business or Commercial Purposes for Collection
Identifiers.	Real name, postal address, internet protocol address, email address.	Directly from the consumer Indirectly from the consumer (e.g., through our use of cookies on our webpage)	To maintain the Sites; To provide services and products to consumers
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	Name, address, telephone number, bank account number, credit card number, debit card number, or any other financial information.	Directly from the consumer Indirectly from the consumer (e.g., through our use of cookies on our Site)	To maintain the Site; To provide services and products to consumers
Protected classification characteristics under California or federal law.	Clothing preferences (including potentially gender, sex, etc.).	Directly from the consumer	To provide services and products to consumers
Commercial information.	Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Directly from the consumer; Indirectly from the consumer (e.g., through our use of cookies on our Site)	To maintain the Site; To provide services and products to consumers
Login information.	Username and password.	Directly from the consumer	To provide services and products to consumers
Internet or other similar network activity.	Browsing history, search history, or information on a consumer’s interaction with a website, application, or advertisement.	Indirectly from the consumer (e.g., through our use of cookies on our Site)	To maintain the Site; To provide services and products to consumers
Inferences drawn from other personal information.	Profile reflecting a consumer’s clothing preferences.	Directly from the consumer; Indirectly from the consumer (e.g., through our use of cookies on our Site)	To provide services and products to consumers

In addition to the primary business or commercial purposes set forth above, we also collect the above information for the reasons set forth in the Privacy Notice. We do not collect Sensitive Personal Information.

SECTION 2 - Retention of Personal Information

We may retain the above categories of information we collect, for as long as necessary, to provide the services on the Site or as required by applicable laws, regulations, or policies governing the Offerings. Specifically, for marketing and promotional purposes, we will retain such related personal information for up to 1 year. At the point in which such Personal Information is no longer necessary or as described by our policies, we will delete it.

SECTION 3 - Disclosures of Personal Information for a Business Purpose

We may disclose Personal Information to third parties in accordance with the Privacy Notice. In the preceding 12 months, we have disclosed the following categories of Personal Information for a business purpose:

California customer records.
Protected classification characteristics.
Commercial information.
Internet activity.

We disclose your Personal Information for a business purpose to the following categories of third parties:

Our affiliates.
Service providers.

SECTION 4 - Sales or Sharing of Personal Information

Our use of tracking technology, including cookies and related technology, may be considered a “sale” or “sharing” under CCPA. If you would like to opt out of the sale or sharing of your Personal Information you may click “Do not sell or share my personal information” (also found at the bottom of the page), or you email us at help@royalrobbins.com.

Although you may opt out of a sale or sharing of your Personal Information to third parties, please note that our Sites may be still tracked by us and our service providers. We do not knowingly sell or share any personal information of consumers under 16 years of age.

The following are categories of personal information that we sell or share: identifiers, personal information categories listed in the California Customer Records statute, commercial information, internet, or other similar network activity, and inferences drawn from other personal information.

The following are categories of third parties to whom personal information was disclosed that may be considered a “sale” or “sharing” under California law: advertisers, marketers, and analytics providers.

SECTION 5 - Rights and Choices of California Residents

The CCPA provides California residents with specific rights regarding their Personal Information. This section describes the rights of California residents under the CCPA, and explains how to exercise those rights. Certain requirements must be met for a California resident to exercise their rights (see Exercising Rights below for more information on what requirements must be met and how to exercise said rights).

Access to Specific Information and Data Portability Rights

California residents have the right to request that we disclose certain information to you about our collection and use of your Personal Information. You may request (see Exercising Access, Data Portability, Data Correction, and Deletion Rights) the following:

The categories of Personal Information we collected about you.
The categories of sources for the Personal Information we collected about you.
Our business or commercial purpose for collecting that Personal Information.
The categories of third parties with whom we share that Personal Information.
The specific pieces of Personal Information we collected about you, subject to certain limitations.
The Personal Information categories that have been disclosed or sold along with the categories of recipients for such disclosures or sales.

Upon request, to the extent possible, we will also transfer your Personal Information to another entity.

Deletion Rights

California residents have the right to request that we delete any of their Personal Information that we collect and retain from California residents, and may request that we share this request with third parties that have received your Personal Information, subject to certain exceptions. Once we receive and verify the California resident’s verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) their Personal Information from our records, unless an exception applies. These exceptions include situations where that information is necessary for us to: provide you with a product or service that you requested; perform a contract we entered into with you; maintain the functionality or security of our systems; comply with or exercise rights provided by the law; or use the information internally in ways that are compatible with the context in which you provided the information to us, or that are reasonably aligned with your expectations based on your relationship with us.

Data Correction Rights

California residents have the right to request that we correct inaccurate Personal Information that we collected from you and retained, taking into account the nature of the Personal Information and the purposes of processing the Personal information. Once we receive and confirm a California resident’s verifiable consumer request (see Exercising Access, Data Portability, Deletion, and Correction Rights), we will use commercially reasonable efforts to correct the inaccurate Personal Information.

SECTION 6 - Exercising Access, Data Portability, Data Correction, and Deletion Rights

To exercise the access, data portability, data correction, and deletion rights described above, please submit a verifiable consumer request to us by:

calling us at (800) 587-9044;
emailing us at help@royalrobbins.com; or
submitting a request by mail to:

Royal Robbins LLC
Attn: Privacy Compliance Officer
575 Sutter Street
San Francisco, CA 94102

Only California residents, or someone legally authorized to act on their behalf, may make a verifiable consumer request related to a California resident’s Personal Information. A California resident may also make a verifiable consumer request on behalf of their minor child. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify that the California resident is the person about whom we collected Personal Information or an authorized representative.
Describe the request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot comply with your request or provide a California resident with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to that California resident.

Making a verifiable consumer request does not require a California resident to create an account with us, but we may require authentication of the consumer that is reasonable in light of the nature of the Personal Information requested.

SECTION 7 - Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (for a maximum total of 90 days), we will notify the California resident. Any disclosures we provide will only cover the 12‑month period preceding the receipt of a verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide the California resident Personal Information that is readily useable and should allow him/her/them to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to a California resident’s verifiable consumer request unless the request is excessive or manifestly unfounded. If we determine that the request warrants a fee, we will tell the California resident why we made that decision and provide him/her/them with a cost estimate before completing the request. Alternatively, we may decline to respond to the request and notify the California resident of our reason for doing so.

SECTION 8 - Non-Discrimination

We will not discriminate against a California resident for exercising any of their CCPA rights. Unless permitted by the CCPA, we will not:

Deny a California resident goods or services.
Charge a California resident different prices or rates for goods or services, including through granting discounts or other benefits or imposing penalties.
Provide a California resident a different level or quality of goods or services, including denial of goods or services.
Suggest that a California resident may receive a different price or rate for goods or services or a different level or quality of goods or services.

SECTION 9 - Notice of Financial Incentive

We may offer you promotional campaigns such as sweepstake or contents (“Promotional Offers”). When you sign up for one of these Promotional Offers, we typically ask that you provide your email address along with any information that is specific to the Promotional Offers. You should review the terms and conditions of each Promotional Offer to view the full details of such Promotional Offer, including on how to participate. You may also withdraw from a Promotional Offer at any time by contacting us at help@royalrobbins.com.

These Promotional Offers may be considered a “financial incentive” under CCPA because it involves the collection of your Personal Information and we may use that Personal Information to offer you the perks in the Promotional Offers.

The value of your Personal Information to us is related to the value of the free or discounted products or services, or other benefits that you obtain or that are provided as part of the loyalty program, less the expense related to offering those products, services, and benefits to you.

SECTION 10 - Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us by:

calling us at (800) 587-9044;
emailing us at help@royalrobbins.com; or
submitting a request by mail to:

Royal Robbins LLC
Attn: Privacy Compliance Officer
575 Sutter Street
San Francisco, CA 94102