dōTERRA Privacy Notice


Effective Date: July 1, 2020

dōTERRA International, LLC (“dōTERRA”) respects your concerns about privacy. This U.S. Privacy Notice describes the types of personal information we obtain, including through dōTERRA’s websites and mobile applications listed here (collectively, the “Sites”), how we may use the information, with whom we may share it and the choices available regarding our use of the information. The Notice also describes the measures we take to safeguard the personal information we obtain and how individuals can contact us about our privacy practices.

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Information We Obtain

We obtain certain personal information in connection with the products and services we provide. The types of personal information we obtain include:
  • contact information, such as name, phone and fax number, and email and postal address;
  • information used to create your account to access the Sites, such as birth date, spouse’s name, photo, preferred language, Enroller ID, Sponsor ID, online password, and, if you are a Wellness Advocate, Social Security number (or equivalent) or Tax ID number;
  • payment information, such as name, billing address and payment card details, including card number, expiration date and security code, which is collected and stored by our third-party payment processor on our behalf;
  • information you submit in connection with a career opportunity at dōTERRA, such as contact details, information in your résumé (including work history, education, language skills, certifications/licenses and work eligibility status) and details about your current employment; dōTERRA uses a third-party service provider to host its Career Opportunities pages and related personal information is obtained by this service provider; and
  • ​​​​​​​other personal information contained in content you submit to us, such as through the “Feedback” feature, public forums or customer support tools on the Sites.

Information We Obtain by Automated Means

When you interact with the Sites, we obtain certain information by automated means, such as cookies, web server logs, web beacons and other technologies. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s web browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server.

We may use these automated technologies to collect information about your equipment, browsing actions and usage patterns. The information we obtain in this manner may include your device IP address, other identifiers associated with your devices, web browser characteristics, device characteristics, language preferences, referring/exit pages, clickstream data, and dates and times of Site visits. These technologies help us (1) remember your information so you will not have to re-enter it; (2) track and understand how you use and interact with our products, services and Sites; (3) tailor our products, services and Sites around your preferences; (4) measure the usability of our products, services and Sites and the effectiveness of our communications; and (5) otherwise manage and enhance our products, services and Sites.

Your web browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of our Sites. For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your mobile device. To the extent required by applicable law, we will obtain your consent before using cookies or similar tools.

How We Use The Information We Obtain

We may use the information we obtain about you to:
  • provide our products and services to you;
  • send promotional materials, newsletters and other communications about our products and services;
  • establish and manage your account with dōTERRA;
  • process and fulfill orders in connection with our products and services and keep you informed about the status of your order;
  • identify and authenticate you so you may order our products and access and use the Sites;
  • communicate about, and administer participation in, special events, programs, promotions, offers surveys, focus groups and market research;
  • provide Wellness Advocate and customer support and respond to inquiries;
  • increase and maintain the safety and security of our products and services and prevent misuse;
  • perform data analytics (including market research, trend analysis, financial analysis, and anonymization and aggregation of personal information);
  • manage career opportunities, including for recruitment purposes, employee onboarding and other Human Resources purposes;
  • operate, evaluate, develop, manage and improve our business and the Sites (including operating, administering, analyzing and improving our products, services and Sites; developing new products and services; managing and evaluating the effectiveness of our communications; performing accounting, auditing, billing reconciliation and collection activities and other internal functions);
  • protect against, identify and prevent fraud and other criminal activity, claims and other liabilities; and
  • comply with and enforce applicable legal requirements, relevant industry standards and policies, including this U.S. Privacy Notice and other dōTERRA terms of use and related documents.
We also may use the information we collect about you in other ways for which we provide specific notice at the time of collection and obtain your consent if required by applicable law.

Third-Party Analytics Services

We use third-party web analytics services on the Sites, including Google Analytics and Facebook Pixel. These service providers use automated technologies to collect data (such as IP addresses) to evaluate use of the Sites. To learn more about Google Analytics and how to opt out, please visit https://www.google.com/intl/en/analytics/learn/privacy.html. To learn more about Facebook Pixel and how to opt out, please visit https://www.facebook.com/help/164968693837950?helpref=faq_content.

Online Tracking and Interest-Based Advertising

We may collect information about your online activities to provide you with advertising about products and services tailored to your interests. Where required by applicable law, we will obtain your consent for the processing of your personal information for direct marketing purposes.

You may see our ads on other websites or mobile apps because we participate in advertising networks. Ad networks allow us to target our messaging to users considering demographic data, users’ inferred interests and browsing context. These networks track users’ online activities over time by collecting information through automated means, including through the use of cookies, web server logs, web beacons and other similar technologies. The networks use this information to show ads that may be tailored to individuals’ interests, to track users’ browsers or devices across multiple websites or apps, and to build a profile of users’ online browsing activities. The information our ad networks may collect includes data about users’ visits to websites and apps that participate in the relevant ad networks, such as the pages or ads viewed and the actions taken on the websites or apps. This data collection takes place both on the Sites and on third-party websites and apps that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts.

The Sites are not designed to respond to “do not track” signals received from browsers. To learn how to opt out of ad network interest-based advertising in the United States, please visit www.aboutads.info/choices, http://www.networkadvertising.org/choices/ and http://preferences-mgr.truste.com/.

Information Sharing

We do not sell or otherwise share personal information about you except as described in this U.S. Privacy Notice. We may share your personal information with (1) our affiliates and subsidiaries and (2) our service providers who perform services on our behalf, such as order fulfillment, customer support, payment processing and data analytics. We do not authorize our service providers to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements.

If you are a dōTERRA account holder, we also share your personal information with the account’s sales organization (including upline and downline distributors) for the purpose of administering sales, distribution of dōTERRA products, and providing reports of activities to other dōTERRA account holders.

We also may disclose information about you (1) if we are required to do so by law or legal process (such as a court order or subpoena); (2) in response to requests by government agencies, such as law enforcement authorities; (3) to establish, exercise or defend our legal rights; (4) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; (5) in connection with an investigation of suspected or actual illegal activity; or (6) otherwise with your consent.

We reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation).

Your Choices

We offer you certain choices in connection with the personal information we obtain about you. To update your preferences, limit the communications you receive from us, or submit a request, please contact us as specified in the How to Contact Us [Insert hyperlink] section of this U.S. Privacy Notice. You also may make changes to the personal information used to create your account with dōTERRA by logging into your account.

Other Online Services and Third-Party Features

The Sites may provide links to other online services for your convenience and information, and may include third-party features such as apps, tools, payment services, widgets and plug-ins (e.g., Facebook, Twitter, Instagram, YouTube and Pinterest buttons). These online services and third-party features may operate independently from us. The privacy practices of the relevant third parties, including details on the information they may collect about you, is subject to the privacy statements of these parties, which we strongly suggest you review. To the extent any linked online services or third-party features are not owned or controlled by us, dōTERRA is not responsible for these third parties’ information practices.

How We Protect Personal Information

We maintain administrative, technical and physical safeguards designed to protect personal information against unauthorized access, disclosure or use.

Children's Personal Information

The Sites are designed for a general audience service and are not directed to children. dōTERRA does not knowingly collect or solicit personally identifiable information from children under the age of 13. If we learn that we have collected personal information from a child under age 13, we will promptly delete that information. If you believe that a child under age 13 may have provided us with personal information, please contact us at privacy@doterra.com.

Updates To This U.S. Privacy Notice

This U.S. Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will indicate at the top of the notice when it was most recently updated.

How To Contact Us

If you have any questions about this U.S. Privacy Notice, or if you would like us to update information we have about you or change your preferences, or if you would like to exercise other applicable data protection rights, please contact us by e-mail at privacy@doterra.com or write to us at:

​​​​​​​dōTERRA International, LLC
Attn: Legal Department
389 South 1300 West
Pleasant Grove, Utah 84062

Appendix A

This U.S. Privacy Notice applies to dōTERRA’s processing of U.S. personal information, including through the following websites and mobile apps:

​​​​​​​www.doterra.com
www.doterradiamondclub.com
www.doterrapresidentialclub.com
www.sourcetoyou.com
www.aromatouch.com
www.labs.doterra.com
www.marketplace.doterra.com
www.spa.doterra.com

dōTERRA Daily Drop Mobile App (available at https://www.doterra.com/US/en/university/living/daily-drop)
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dōTERRA International, LLC

California Consumer Privacy Statement

This California Consumer Privacy Statement (“Statement”) supplements the dōTERRA U.S. Privacy Notice [Insert Hyperlink] and applies solely to California consumers.  The Statement does not apply to doTERRA personnel.
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This Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).
 

1. Notice of Collection and Use of Personal Information


We may collect (and may have collected during the 12-month period prior to the effective date of this Statement), the following categories of personal information about you: 
  • Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers;
  • Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information;
  • Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status; 
  • Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies;
  • Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements; 
  • Geolocation Data;  
  • Sensory Information: audio, electronic, visual, thermal, olfactory, and similar information;
  • Employment Information: professional or employment-related information; and 
  • Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We may use (and may have used during the 12-month period prior to the effective date of this Statement) your personal information for the purposes described in our U.S. Privacy​​​​​​Notice and for the following business purposes specified in the CCPA:
  • performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services;
  • auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;
  • short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction;
  • detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
  • debugging to identify and repair errors that impair existing intended functionality; 
  • undertaking internal research for technological development and demonstration; 
  • undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us; and
  • managing career opportunities with dōTERRA. 

2. Sources of Personal Information

During the 12-month period prior to the effective date of this Statement, we may have obtained personal information about you from the following categories of sources: 
  • from you, for example, when you create an account on the Site, attend a convention or purchase a dōTERRA product, or if you become a Wellness Advocate;
  • your friends, through their use of our services, such as by sending an article or product information directly to you;
  • our affiliates and subsidiaries;
  • social media networks; 
  • data analytic providers; and 
  • online advertising services and advertising networks.

3. Sale of Personal Information

We do not sell your personal information in exchange for monetary compensation.  We may allow certain third parties (such as online advertising services) to collect your personal information via automated technologies on our Sites in exchange for non-monetary consideration.  We share the categories of personal information listed above for online advertising purposes and to provide third-party social network features and functionality on our Sites as described in our Privacy Notice.  You have the right to opt out of this disclosure of your information, which may be considered a “sale” under California law.

During the 12-month period prior to the effective date of this Statement, we may have sold the following categories of personal information about you to online advertising services and social networks: 
  • Identifiers
  • Commercial Information
  • Online Activity
  • Inferences
We do not have actual knowledge that we sell personal information of minors under 16 years of age.
 

4. Sharing of Personal Information

During the 12-month period prior to the effective date of this Statement, we may have shared your personal information with certain categories of third parties, as described below.
 
Category of Personal Information Category of Third Party
Identifiers affiliates, vendors who provide services on our behalf, account holders, third party marketers, and data analytics providers
Additional Data Subject to Cal. Civ. Code § 1798.80 Law affiliates and vendors who provide services on our behalf
Protected Classifications affiliates and vendors who provide services on our behalf
Commercial Information affiliates, vendors who provide services on our behalf and account holders
Online Activity affiliates, vendors who provide services on our behalf, account holders, third party marketers, and analytics providers
Geolocation data affiliates and vendors who provide services on our behalf
Sensory Information affiliates and vendors who provide services on our behalf
Employment Information affiliates and vendors who provide services on our behalf
Inferences affiliates,  vendors who provide services on our behalf and analytics providers 
 ​​​​​​​​​​​​​

5. California Consumer Privacy Rights

You have certain choices regarding your personal information, as described below:

Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.  

Deletion: You have the right to request that we delete certain personal information we have collected from you. 

Opt-Out of Sale: You have the right to opt out of the sale of your personal information. 

Shine the Light Request: You also may have the right to request that we provide you with (a) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (b) the identity of those third parties.

How to Submit a Request. To submit an access or deletion request, click here or call us at 1-800-411-9151.  To submit a Shine the Light request, email us at privacy@doterra.com.  To opt-out of the sale of your personal information, click here or email us at privacy@doterra.com . If you designate an authorized agent to make an access, deletion, or opt-out of sale request on your behalf, we may require you to provide the authorized agent written permission to do so and to verify your own identity directly with us (as described below).  For questions or concerns about our privacy policies and practices, please contact us as described in the Contact Us section of our U.S. Privacy Notice.

Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request.  If you have an account with us, we may verify your identity by requiring you to sign in to your account.  If you do not have an account with us and you request access to or deletion of your personal information, we may require you to provide any of the following information: certain order information, address and phone number.  In addition, if you do not have an account and you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.
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Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us.  To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

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