Privacy Policy
This U.S. State Privacy Notice applies to “Consumers” as defined under U.S. privacy laws, specifically the California Consumer Privacy Act, including as amended by the California Privacy Rights Act (“CCPA”), the Virginia Consumer Data Privacy Act (“VCDPA”),the Colorado Privacy Act, the Utah Consumer Privacy Act, Connecticut’s Act Concerning Personal Data Privacy and Online Monitoring, and any other U.S. privacy laws, as each are amended and as and when they become effective, and including any regulations thereunder (collectively, the “U.S. Privacy Laws”). This U.S. State Privacy Notice is a supplement to this Privacy Policy. In the event of a conflict between any other P&G policy, statement, or notice and this U.S. State Privacy Notice, this U.S. State Privacy Notice will prevail as to Consumers and their rights under the applicable U.S. Privacy Laws.
This U.S. State Privacy Notice is designed to provide you with notice of our recent personal data practices over the prior 12 months from the “Last Updated” date of this Privacy Policy. This U.S. State Privacy Notice will be updated at least annually. This U.S. State Privacy Notice also applies to our current data practices such that it is also meant to provide you with “notice at collection,” which is notice of personal data (also referred to in some of the U.S. Privacy Laws as “personal information”) we collect online and offline, and the purposes for which we process personal data, among other things required by the U.S. Privacy Laws. For any new or substantially different processing activities that are not described in this U.S. State Privacy Notice, we will notify you as required by the U.S. Privacy Laws, including by either notifying you at the time of collecting personal data, or by updating this U.S. State Privacy Notice earlier than required. We reserve the right to amend this U.S. State Privacy Notice at our discretion and at any time. To contact us about this U.S. Privacy Notice, please see the Contact Us section below.
Generally, we collect, retain, use, and disclose your personal data for our business purposes and commercial purposes, which are described above in the remainder of this Privacy Policy, including in “How We Gather & Use Personal Data,”and “How We Disclose Personal Data” (collectively, our “Processing Purposes”). The sources from which we collect personal data are set forth above in the “How We Gather & Use Personal Data.” Some of the Processing Purposes, as we discuss below in the table, implicate “Sale,” “Sharing”, and or “Targeted Advertising.” For more details on the meaning of Sale, Sharing, and Targeted Advertising, see the “Do Not Sell/Share/Target” section below. Please note that the Processing Purposes as shown in the table are categorical descriptions, to aid in readability and clarity. Please reference the “General Ways We Use Personal Data” section of the Privacy Policy above for the full description of each Processing Purpose.
The table below describes the categories of personal data we collect in the first column (starting on the left). The second column provides examples of data types within the applicable categories, which, in some instances, include the personal data types/categories listed above under “Types of Personal Data We Collect.” The third column states the categories of recipients that receive such personal data (including sensitive personal data or special category data) as part of disclosures for business purposes, as well as disclosures which may be considered a Sale or Share under certain U.S. Privacy Laws. Not all data indicated in the examples is “sold” to third parties. For example, in the “Identifiers and Contact Information” of the chart, we may collect “financial account data” or “government issues IDs” in order to provide services to you, but we do not “sell” it to third parties. However, we may sell “unique IDs” and account information to third parties. If any of your data is “sold” or “shared,” it will be done so according to applicable law. The fourth column provides the Processing Purposes that are applicable to each category of personal data. In the fifth column, we provide, on a per category of personal data basis, the applicable retention period.
|
Category of Personal Data |
Examples of Personal Data Types within Category |
Categories of Recipients |
Processing Purposes |
Retention Period |
|
1. Identifiers and Contact Information |
Contact information, Unique IDs & Accounts Details, Online and Technical Information, Financial Account Information, Government-issued IDs |
Disclosures for Business Purposes: |
• Products/Services |
After no longer needed for the processing purpose(s) or after a maximum of 50 months of non-activity unless required by law or contract to retain. |
|
2. Personal Records |
Contact information, Unique IDs & Accounts Details, Financial Account Information, Government-issued IDs |
Disclosures for Business Purposes: |
• Products / Services |
After no longer needed for the processing purpose(s) or after a maximum of 50 months of non-activity unless required by law or contract to retain. |
|
3. Personal Characteristics or Traits |
General Demographics & Psychographics, Data About Children, Inferred Information, Health-related information |
Disclosures for Business Purposes: |
• Products / Services |
After no longer needed for the processing purpose(s) or after a maximum of 50 months of non-activity. |
|
4. Customer Account Details / Commercial Information |
General Demographics & Psychographics, Transaction and Commercial Information, Online & Technical Information |
Disclosures for Business Purposes: |
• Products/Services |
After no longer needed for the processing purpose(s) or after a maximum of 50 months of non-activity. |
|
5. Biometric Information |
Biometric Information |
Disclosures for Business Purposes: |
• Products/Services |
After no longer needed for the processing purpose(s) unless required to retain for legal or regulatory compliance. |
|
6. Internet/App Usage Information |
Transaction and Commercial Information, Online & Technical Information, Smart Devices and Sensor Data |
Disclosures for Business Purposes: |
• Products/Services |
After no longer needed for the processing purpose(s) or after a maximum of 50 months of non-activity unless required by law or contract to retain. |
|
7. Location Data |
Imprecise Location Data, Precise Geolocation Data |
Disclosures for Business Purposes: |
• Products/Services |
After no longer needed for the processing purpose(s) or after a maximum of 50 months of non-activity. |
|
8. Audiovisual and Similar Information |
Audio Visual Information, Smart Devices and Sensor Data |
Disclosures for Business Purposes: |
• Products/Services |
After no longer needed for the processing purpose(s) or after a maximum of 50 months of non-activity unless required by law or contract to retain. |
|
9. Professional or Employment Information |
General Demographics & Psychographics |
Disclosures for Business Purposes: |
• Products/Services |
After no longer needed for the processing purpose(s) unless required by law or contract to retain. |
|
10. Non-public Education Records |
Not applicable in non-HR contexts (which are not within the scope of this notice) |
Not applicable in non-HR contexts (which are not within the scope of this notice) |
Not applicable in non-HR contexts (which are not within the scope of this notice) |
Not applicable in non-HR contexts (which are not within the scope of this notice) |
|
11. Inferences from Collected Information |
General Demographics & Psychographics, Inferred Information |
Disclosures for Business Purposes: |
• Products/Services |
After no longer needed for the processing purpose(s) or After no longer needed for the processing purpose(s) or after a maximum of 50 months of non-activity unless required by law or contract to retain. |
Sensitive Personal Data
|
Category of Sensitive Personal Data |
Examples of Sensitive Personal Data Types within Category |
Categories of Recipients |
Processing Purposes |
Retention Period |
|
1. Financial Information & Account Credentials allowing access to an account |
Financial Information. In addition, we may store your P&G account logins in combination with a password in our systems. |
Disclosures for Business Purposes: |
• Products/Services |
After no longer needed for the processing purpose(s) or after a maximum of 50 months of non-activity unless required by law or contract to retain or dispose of prior. |
|
Physical & Mental Health Data |
Physical and Mental Health data / condition / information that we may ask a consumer in connection with a research study or survey. It also includes information collected when consumer contacts us to report a complaint or an adverse occurring in connection with one of our products. |
Disclosures for Business Purposes: |
• Products/Services |
After no longer needed for the processing purpose(s). |
|
Precise Geolocation Data |
Precise geolocation data |
Disclosures for Business Purposes: |
• Products/Services |
After no longer needed for the processing purpose(s). |
|
Racial or Ethnic Origin |
General Demographics & Psychographics |
Disclosures for Business Purposes: |
• Products/Services |
After no longer needed for the processing purpose(s) or after a maximum of 50 months of non-activity unless required by law to retain. |
|
Processing of Biometric Information for the purpose of uniquely identifying a consumer |
Not applicable |
Not applicable |
Not applicable |
Not applicable |
|
Personal Data Concerning a Consumer’s Health*This personal data would not include health diagnostic information but is related to demographic or purchase data that may help us determine which products you may be interested in. |
Health-related Information |
Disclosures for Business Purposes: |
• Products/Services |
After no longer needed for the processing purpose(s) or after a maximum of 50 months of non-activity unless required by law to retain. |
|
Inferences from Collected Information |
Racial or Ethnic Origin |
Disclosures for Business Purposes: |
• Products/Services |
After no longer needed for the processing purpose(s) and deleted within a maximum of 24 hours after collection. |
We also may disclose each category of personal data and sensitive personal data in the table to the following categories of recipients in a manner that does not constitute Sale or Sharing:
- The Consumer or to other parties at your direction or through your intentional action
- Recipients to whom personal data is disclosed for legal and similar reasons
- In addition, our Vendors and the other recipients listed in the above table may, subject to contractual restrictions imposed by us and/or legal obligations, also use and disclose your personal data for business purposes. For example, our Vendors and the other categories of recipients listed in the table above may engage subcontractors to enable them to perform services for us or process for our business purposes.

