Privacy Policy

Effective as of October 28, 2025.  

California Notice at Collection/State Privacy Rights: See the State Privacy Rights privacy rights section below for important information about your rights under applicable state privacy laws.

 

 

True Botanicals, Inc. ("True Botanicals," "we", “us” or "our") provides skincare products that are powered by the science of wellbeing. This Privacy Policy describes how True Botanicals processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including as applicable, our website and social media pages) as well as our marketing activities, live events and other activities described in this Privacy Policy (collectively, the “Service”)). True Botanicals may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information.

Index

Personal information we collect

Tracking Technologies

How we use your personal information

How we share your personal information

Your choices

Other sites and services 

Security

International data transfer

Children

Changes to this Privacy Policy

How to contact us

State Privacy Rights

Personal information we collect

 

Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:

• Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, professional title and company name, and phone number.
• Demographic data, such as your city, state, country of residence, postal code, and age.
• Profile data, such as the username and password that you may set to establish an online account on the Service, date of birth, redemption code, biographical details, photograph or picture, links to your profiles on social networks, interests, preferences, information about your participation in our contests, promotions, or surveys, and any other information that you add to your account profile.  
• Communications data based on our exchanges with you, including when you contact us through the Service, communicate with us via chat features, social media, or otherwise. 
• Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order numbers and transaction history. 
• Subscription data, such as information relating to or needed to service your subscriptions through the Service, including sign up date and subscription history. 
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
• User-generated content data, such as photos, images, videos, product reviews, and other content or information that you generate, transmit, or otherwise make available on the Service. 
• Payment data needed to complete transactions, including payment card information or bank account number.
• Promotion data, including information you share when you enter a competition, promotion or complete a survey. Please note that if you participate in a sweepstakes, contest or giveaway through the Service, we may ask you for your Contact Data to notify you if you win or not, to verify your identity, determine your eligibility, or to send you prizes. In some situations, we may need additional information as a part of the entry process, such as a prize selection choice. These sweepstakes and contests are voluntary. We recommend that you read the rules and other relevant information for each sweepstakes and contest that you enter.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may combine personal information we receive from you with personal information falling within one of the categories identified above that we obtain from other sources, such as:

• Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
• Data providers, such as information services and data licensors. 
• Partners, such marketing partners and event co-sponsors. 
• Customers.
• Service providers that provide services on our behalf or help us operate the Service or our business.
• Business transaction partners. We may receive personal information in connection with an actual or prospective business transaction. For example, we may receive your personal information from an entity we acquire or are acquired by, a successor, or assignee or any party involved in a business transaction such as a merger, acquisition, sale of assets, or similar transaction, or in the context of an insolvency, bankruptcy, or receivership.
• Third-party services, such as social media services, that you use to log into, or otherwise link to, your Service account. This data may include your username, profile picture and other information associated with your account on that third-party service that is made available to us based on your account settings on that service.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

• Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
• Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open or forward emails). We may do this through the use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails. 

For more information concerning our automatic collection of data, please see the Tracking technologies section below.

Data about others. We may offer features that help users invite their friends or contacts to use the Service, and we may collect contact details about these invitees so we can deliver their invitations. Please do not refer someone to us or share their contact details with us unless you have their permission to do so. 

 

 

Tracking & Other Technologies

Cookies and other technologies. Some of the automatic collection described above is facilitated by the following technologies:

 

• Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers place. 
• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications. 
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked. 

For information concerning your choices with respect to the use of tracking technologies, see the Your choices section, below.

How we use your personal information

 

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. We may use your personal information to:

• provide the Service and operate our business;
• enable security features of the Service;
• establish and maintain your user profile on the Service;
• facilitate your invitations to friends who you want to invite to join the Service;
• communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
• communicate with you about events or contests in which you participate; and
• provide support for the Service, and respond to your requests, questions and feedback
• Service personalization, which may include using your personal information to:
  • understand your needs and interests;
  • personalize your experience with the Service and our Service-related communications;
  • and remember your selections and preferences as you navigate webpages.

 

Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services. For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en.

Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:

• Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.
• Interest-based advertising. We, our service providers, and third-party advertising partners may use cookies and other technologies to collect information about your interaction (including the data described in the automatic data collection section above) with the Service, our communications and other online services over time, and use that information to serve online ads that we or they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the Your choices section below. 

 

Events, promotions and contests. We may use your personal information to: 

• administer promotions and contests;
• communicate with you about promotions or contests in which you participate; and
• contact or market to you after collecting your personal information at an event.

 

Compliance and protection. We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); 
• audit our internal processes for compliance with legal and contractual requirements or our internal policies; 
• enforce the terms and conditions that govern the Service; and 
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.  

 

Data sharing in the context of corporate events, we may share certain personal information in the context of actual or prospective corporate events – for more information, see How we share your personal information, below.

To create aggregated, de-identified or anonymized data. We may create aggregated, de-identified or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified or anonymized data by removing information that makes the data identifiable to you and we will not attempt to reidentify any such data. We may use this aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.  

Further uses, in some cases, we may use your personal information for further uses, in which case we will ask for your consent to use of your personal information for those further purposes if they are not compatible with the initial purpose for which information was collected.

 

How we share your personal information

 

We may share your personal information with the following parties (or as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection).  

Affiliates. Our corporate parent, subsidiaries, and affiliates.

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research and website analytics). 

Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, such as Shopify, PayPal, and Google Pay. 

• Shopify may use your payment data in accordance with its privacy policy, https://www.shopify.com/legal/privacy/consumers. 
• PayPal may use your payment data in accordance with its privacy policy, https://www.paypal.com/us/webapps/mpp/ua/privacy-full.
• Google Pay may use your payment data in accordance with its privacy policy, https://payments.google.com/payments/apis-secure/u/0/get_legal_document?ldo=0&ldt=privacynotice&ldl=en-GB. 

Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above. 

Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so. 

Business and marketing partners. Third parties with whom we partner, including parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.

Linked third-party services. If you log into the Service with, or otherwise link your Service account to, a social media or other third-party service, we may share your personal information with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account with the third-party service.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above. 

Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in us, financing of us, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares). For example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of us as part of any merger, acquisition, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

Other users and the public. Your profile and other user-generated content data are visible to other users of the Service and the public. For example, other users of the Service or the public may have access to your information if you chose to leave a review of or ask a question about a product.  This information can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information.

Your choices 

 

In this section, we describe the rights and choices available to all users.

Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account and selecting Account Details. 

Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails. If you receive text messages from us, you may opt out of receiving further text messages from us by replying STOP to our message. You may also text STOP to 90647.

Cookies and other technologies. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. You can also configure your device to prevent images from loading to prevent web beacons from functioning.

Blocking images/clear gifs. Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.

Advertising choices. You may be able to limit use of your information for interest-based advertising through the following settings/options/tools:

• Browser settings. Changing your internet web browser settings to block third-party cookies.
• Privacy browsers/plug-ins. Using privacy browsers or ad-blocking browser plug-ins that let you block tracking technologies. 
• Platform settings. Certain platforms offer opt-out features that let you opt-out of use of your information for interest-based advertising. For example, you may be able to exercise that option for Google and Facebook, respectively, at the following websites:
  • Google: https://adssettings.google.com/ 
  • Facebook: https://www.facebook.com/about/ads 

• Ad industry tools. Opting out of interest-based ads from companies that participate in the following industry opt-out programs: 

  • Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp 
  • Digital Advertising Alliance: optout.aboutads.info.   
  • AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which will allow you to opt-out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance. 

• Mobile settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

You will need to apply these opt-out settings on each device and browser from which you wish to limit the use of your information for interest-based advertising purposes.  

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Linked third-party platforms. If you choose to connect to the Service through your social media account or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.

Delete your content. You can choose to delete certain content through your account. 

Other sites and services

 

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security 

 

We employ technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information. 

International data transfer

 

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.  

Children  

 

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy 

 

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.

How to contact us

• Email: hello@truebotanicals.com
• Mail: 1 Lovell Ave. Mill Valley, CA 94941
• Phone: +1 888 416 0870

 

State privacy rights notice

 

Except as otherwise provided, this section applies to residents of California and Virginia, and other states to the extent they have privacy laws applicable to us that grant their residents the rights described below (collectively the “State Privacy Laws”).

This section describes how we collect, use, and share for the purposes of targeted advertising Personal Information of residents of these states and the rights these users may have with respect to their Personal Information. Please note that not all rights listed below may be afforded to all users and that if your state does not afford you these rights, you may not be able to exercise these rights. In addition, we may not be able to process your access, correction or deletion request if you do not provide us with sufficient detail to allow us to confirm your identity and understand and respond to your request.

For purposes of this section, the term “Personal Information” means information that relates to an identified or identifiable natural person, or that is reasonably capable of being used to identify, contact, or precisely locate a natural person, household, or a particular computing system or device. In some cases, we may provide a different privacy notice to certain categories of residents of certain states, such as job applicants, in which case that notice will apply instead of this section.

We do not re-identify personal information that is de-identified. 

Your privacy rights. You may request to exercise the rights listed below. We will respond to your request in accordance with applicable law.

Information. 

• The categories of Personal Information that we have collected.
• The categories of sources from which we collected Personal Information.
• The business or commercial purpose for collecting, selling, and/or sharing Personal Information for targeted advertising purposes.
• The categories of personal information that we sold or shared for targeted advertising purposes, and the categories of third parties to whom this information was sold or shared, categorized by the type of personal information for each type of third party.
• The categories of personal information that we disclosed for business purposes and the types of entities to whom this information was disclosed.
• The specific third parties to which we have disclosed personal information.
• You can request to know whether we process your personal information.
• You can request the following information about how we have collected and used your Personal Information during the past 12 months:
• Access. You can request a copy or representative summary of the Personal Information that we have collected about you. 
• Correction. You can ask us to correct inaccurate Personal Information that we have collected about you.
• Deletion. You can ask us to delete the Personal Information that we have collected from or about you.
• Revoke consent. You may have the right to revoke your consent to our processing of your personal information.
• Opt-out.
• Opt-out of certain processing for targeted advertising purposes. We may process Personal Information for targeted advertising purposes. You can opt out of the sharing of your Personal Information for targeted advertising purposes and any other processing deemed a sale under applicable law.
• Opt-out of profiling/automated decision making. We do not use your Personal Information to engage in automated processing or profiling Personal Information to evaluate, analyze, or predict personal aspects related to your economic situation, health, personal preferences, interests, reliability, behavior, location, or movements to make a decision that produces legal or similarly significant effects.   
• Consumers under 16. We do not have actual knowledge that we collect, sell or share the personal information of consumers under 16 years of age.
• California Residents: Sensitive Personal Information. We may collect certain categories of Sensitive Personal Information as described in this Privacy Policy. We use Sensitive Personal Information as necessary for certain business purposes, including providing goods or services as requested; ensuring safety, security; and integrity; countering wrongful or unlawful actions; short term transient use such as displaying first party, non-personalized advertising; performing services for our business, including maintaining and servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of our business; activities relating to quality and safety control or product improvement; and other collection and processing that is not for the purpose of inferring characteristics about an individual.
  While we process certain categories of Sensitive Personal Information as described in this Privacy Policy, we do not process Sensitive Personal Information for purposes beyond those listed above.
• Residents outside California: Sensitive Personal Information.  You can opt-out of our processing your Sensitive Personal Information by electing not to provide it to us or by notifying us of your opt-out.
• Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the State Privacy Laws.  
• Appeal. You can appeal our denial of any request validly submitted. 
• Exercising your right to information/know, access, correction, deletion, and appeal [and limit processing of Sensitive Personal Information]. You may submit requests at [webform], calling us toll free at +1 888 416 0870, or via email to hello@truebotanicals.com.  

Exercising your right to opt-out of the “sale” or “sharing” of your Personal Information.  While we do not sell personal information for money, like many companies, we use services that help deliver personalized content to you as described above. The State Privacy Laws may classify our use of some of these services as “selling” or “sharing” your Personal Information with the advertising partners that provide the services. You can submit requests to opt-out of tracking for targeted advertising purposes or other sales of Personal Information here: Do Not Sell or Share My Personal Information, via email to hello@truebotanicals.com or via phone by calling +1 888 416 0870, or by broadcasting the global privacy control signal. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

Verification of Identity; Authorized agents. We may need to verify your identity to process your information/know, access, correction, deletion, or appeal requests and reserve the right to confirm your residency. To verify your identity, we may require government identification, a declaration under penalty of perjury or other specific information that we think only you would have, where permitted by law.

Under some State Privacy Laws, you may enable an authorized agent to make a request on your behalf. However, we may need to verify your authorized agent’s identity and authority to act on your behalf. Depending on the kind of request you have made, we may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that your request is authorized, such as by providing your agent with written and signed permission to exercise your State Privacy Law rights on your behalf, the information we request to verify your identity, or confirmation that you have given the authorized agent permission to submit the request.

Personal information that we collect, use and disclose. We have summarized the Personal Information we collect and may sell or share to third parties by reference below to both the categories of Personal Information defined in the “Personal Information we collect” and “How we share your personal information” sections of this Policy above and the categories of Personal Information specified in state law. This table describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below.

Additional information for California residents.  

Notice of Financial Incentive. We may invite you to receive marketing emails from True Botanicals, which may constitute a “financial incentive” under the CCPA. If you choose to participate, you will receive marketing emails from us including exclusive offers such as a discount off your first order. We will invite you to participate via a popup notification during your shopping experience, and you can choose to participate by sharing your email address with us through that popup in advance of making your first order through the Service. By participating, you may provide us personal information including your Contact data, Device data, or Online activity data. You have the right to withdraw from this program at any time and may do so by following the unsubscribe link in our marketing emails. The value of any incentive is reasonably related to the value of your data, including as applicable: the benefit and insights that we realize and expect to realize from your participation in our programs (such as product preferences); the quantity and quality of information that you provide to us through your participation; your purchase history; sales directly or indirectly generated from your participation in the program; and any increased goodwill towards us.

Contact Us. If you have questions or concerns about our privacy policies or information practices, please contact us using the contact details set forth in the How to contact us section, above.