Scope. We take your privacy very seriously. Please read this privacy policy carefully, as it contains important information on who we are and how/why we collect, store, use, and share your personal information when you or we:

• Visit Thirty-One Gifts’ website or any of our iOS and Android applications (or similar mediums);

• Become a Thirty-One Consultant or are otherwise used as an independent contractor by Thirty-One;

• Receive information via a job application;

• Send us information via special programs or services we offer; and

• Information we receive regarding our current and former employees (and their beneficiaries).

It also covers our use and sharing of personal information collected through our Canadian websites, through mobile applications downloaded in Canada or personal information otherwise collected in Canada. It also explains your rights in relation to your personal information and how to contact us in the event you have a complaint.

You agree to this Privacy Policy by: using or accessing our Marketing Channels (as defined below); applying to become or if you are already a Thirty-One Gifts Consultant or are otherwise used as an independent contractor by Thirty-One; or when you apply for employment or are currently employed by Thirty-One.

Our Marketing Channels are directed to adults, not children under the age of 18. Consultants and employees must be 18 years of age or older. We do not knowingly collect personally identifiable information from anyone under the age of 18, except for minor dependents and beneficiaries identified by our employees.

We are subject to the investigative and enforcement authority of the United States Federal Trade Commission (FTC).

Definitions/Key Terms. It would be helpful to start by explaining some key terms used in this policy:

• We, us, or our - Thirty-One Gifts LLC and, with respect to Canadian, these terms refer to Thirty-One Gifts Canada Inc.

• Contact information if you have an issue or request – privacy@thirtyonegifts.com.

• Personal information – any information relating to an identified or identifiable individual

• Marketing Channels – our websites and mobile applications. In Canada, this also includes your interactions with us at Thirty-One Gifts parties or events, and by telephone, mail and email.

Personal Information We Collect About You. We may collect and use the following personal information that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

The above types of information may be provided by you through our Marketing Channels or when you otherwise provide it to us, such as through applications for employment or to be a Thirty-One Consultant.

Some of this information allows us to determine such things as which parts of our websites are most visited or used, what products are browsed or purchased, the effectiveness of our websites, possibly the location from which devices connect to our websites (down to the city level), and difficulties visitors may experience in accessing our websites. Cookies are also used to associate you with your Consultant, keep track of items you put into your Shopping Cart, and to tell us whether you have visited our websites in the past. Pixel tags in emails help us confirm if an end user has opened our emails.

This personal information is required to provide Thirty-One Gifts products to you or utilize you as a Thirty-One Consultant (or other type of independent contractor) or employee. If you do not provide personal information we ask for, it may delay or prevent us from providing products to you or utilizing your services as an employee or independent contractor.

How Your Personal Information is Collected. We collect most of this personal information directly from you—in person, by telephone, text, email, via our website and/or apps. We may ask you to provide personal information through our Marketing Channels, such as when you subscribe to and receive our emails or other communications; complete a request to host a party event; participate in a survey; enter contests or sweepstakes; fill out an application to become a Consultant, other independent contractor, or employee; fill out a request for support of a non-profit organization through Thirty-One Gives; or when you place an order with us online or through one of our Consultants.

However, we may also collect information:

• From publicly accessible sources (e.g., court records);

• Directly from a third party (e.g., sanctions screening providers, credit reporting agencies, or customer due diligence providers);

• From a third party with your consent (e.g., your bank);

• When a Consultant provides us information about individuals who are invited to host Thirty-One parties; and

• Via our internal IT systems, including:

  • Door entry systems and reception logs;

  • Automated monitoring of our websites and other technical systems, such as our computer networks (including employee emails) and connections, CCTV and access control systems, communications systems, email and instant messaging systems; and

  • any other relevant systems.

How we use Cookies, Web Beacons and other Technologies: We use these technologies to provide you a richer and more personalized consumer experience. We use internet cookies to collect, and store personal information and other technologies and provide you notice of their use via this Policy. See below for more detail.

Cookies: A cookie is a small file placed on your computer by a website that uses the cookie to store information about your use of the website. We use cookies to monitor how our sites are used and to help personalize your online experience. For example, when you register on our sites, we may store a unique code in a cookie on your computer. The next time you come back to the site from that computer, our servers use the cookie to recognize you. We can then use the information you provided when you registered combined with your activities on our sites to provide you a better website experience.

You can accept or decline cookies. Most browsers automatically accept cookies. To learn more about cookies, including how to refuse cookies on your computer, click these links:

• For Microsoft Edge: https://support.microsoft.com/en-us/microsoft-edge/learn-about-tracking-prevention-in-microsoft-edge-5ac125e8-9b90-8d59-fa2c-7f2e9a44d869

• For Google Chrome: http://support.google.com/chrome/bin/answer.py?hl=en-GB&answer=95647

• For Mozilla Firefox: https://support.mozilla.org/en-US/kb/block-websites-storing-cookies-site-data-firefox

• For Apple Safari: https://www.cookiesandyou.com/disable-cookies/macos/safari/

If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using our website, as some features and offerings may not work properly, if at all. Depending on your device and operating system, you may not be able to delete or block all cookies. In addition, if you want to reject cookies across all your browsers and devices, you will need to do so on each browser on each device you actively use. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.

Web Beacons: Web beacons are small bits of code embedded in web pages or in emails. We may use web beacons to deliver or communicate with cookies, to count users who have visited a web page, and to understand usage patterns. We also may include web beacons in e-mails to learn if messages have been opened.
You can disable the ability of web beacons to capture information in this manner by declining cookies as described above, or, in the case of pixel tags, see
https://www.youtube.com/watch?v=l-_fJ1u5igw&ab_channel=HelpCloud for more information on disabling.

Other Technologies: Examples of other technologies we may use to provide better service to you follow:

• Web Session Variables: Information that is passed from one web URL to another as you browse.

• Browser plug-ins/add-ons: Additional web components that may need to be installed to enable certain web features on our sites. You have the option not to install these components.

How and Why We Use Your Personal Information. We use the information collected to provide offers, products, and services to our customers and consultants. We also use employee information to allow us to meet legal requirements, pay our employees, provide them with benefits, and for any and all other legal reasons.

The following are specific ways we may use your collected information:

• To process orders, requests, and payments for our products;

• Improving, developing, and marketing our products, websites, and iOS and Adroid applications;

• To communicate with you via email, phone, or postal mail regarding promotional offers, new products, and other information we think may be interesting to you;

• Internal business purposes, such as analyzing your activity with us, including your interactions with our Marketing Channels and your purchases;

• Personalizing our communications to you and allowing you to communicate and interact with others on our websites and mobile applications;

• Helping you find an independent Thirty-One Consultant (including automatically assigning a new Consultant to you and sharing your personal information with that person if your current Consultant has discontinued selling and become inactive);

• Updating our records;

• To consider and potentially utilize your services as an employee or independent contractor;

• Where permitted by law, provide you with customized, unsolicited offers and information about our products and services through postal mail or email, including in connection with services provided to your Thirty-One Consultant;

• Understand how you arrived at our site and how you use the site so that we can make it better;

• Determine the effectiveness of our advertising;

• To provide benefits to you as an employee;

• To prevent and detect fraud against you or Thirty-One Gifts;

• Ensuring our business policies are adhered to, e.g., policies covering security and internet use;

• Responding to your inquiries;

• Statistical analysis to help us manage our business, e.g., in relation to our financial performance, customer base, product range, or other efficiency measures;

• Operational reasons, such as improving efficiency, training, and quality control;

• Facilitating the business activities of a Thirty-One Consultant;

• Create and manage your account and/or the account of your Thirty-One Consultant;

• Ensuring safe working practices, staff administration, and assessments;

• Conducting surveys, sweepstakes, or contests (please note that some of these activities may have additional rules, which could contain additional information about how we use and disclose your personal information, we recommend you read those rules carefully);

• To comply with any legal and regulatory obligations of Thirty-One Gifts;

• For our legitimate interests or those of a third party; or

• Where you have given consent.

Promotional Communications. We may use your personal information to send you updates by our Marketing Channels or post about our products, including exclusive offers, promotions or new products.

We have a legitimate interest in processing your personal information for promotional purposes (see above “How and Why We Use Your Personal Information”). This means we do not usually need your consent to send you promotional communications, except where prohibited by law. Where consent is needed, such as in Canada, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never sell or share it with other organizations outside of Thirty-One Gifts for marketing purposes, without your consent.

You have the right to opt out of receiving promotional communications at any time by:

• Contacting us at privacy@thirtyonegifts.com; or

• Using the “unsubscribe” link in emails.

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products in the future, or if there are changes in the law, regulation, or the structure of our business. If you choose to stop receiving message from us, we will honor your request. However, we will continue to send you service-related communications, as authorized by law. We may need to keep the information we have collected about you for record-keeping, analysis, or other reasons, to the extent permitted by law.

7. Who We Share Your Personal Information With. We may share personal information with:

• Your independent Thirty-One Gifts Consultant(s) with whom you indicate you have a relationship, as well as other Consultants we assign you to if your current Consultant has discontinued selling and become inactive. If you have never had a relationship with one of our Consultants, we will select one who is located near you and provide your contact information to that Consultant, so you may be contacted about your inquiry;

• Third-party service providers we use to help deliver our products to you, such as payment processors, warehouses, order fulfillment, infrastructure provision, information technology services, customer service, and delivery companies;

• Third-party service providers that assist us in such things as developing and administering our websites and mobile applications; data analysis; training; auditing; allow us to pursue available remedies or limit the damages we may sustain; conducting surveys, sweepstakes, or contests; sending and administering emails or text messages; performing marketing services; or other similar services. These provides will be supplied with, or have access to, your personal information for the purpose of providing these services to us or on our behalf;

• Other third parties we use to help us run our business, such as marketing agencies, website hosts, or security-providing entities;

• Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers;

• Another company that we may acquires or that acquires us;

• For current and former employees, our outside providers of insurances, benefits, and retirement plans for you and your beneficiaries, outside entities that assist with payroll, time-keeping, attendance monitoring, etc. and other entities of this type to assist in effectuating the employer/employee relationship.

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also use contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

Personal Information We Disclosed for a Business Purpose. In the preceding 12 months, we have disclosed to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

• Identifiers (e.g., a real name, alias, postal address, email address, social security number, or other similar identifiers);

• Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, social security number, physical characteristics or description, address, telephone number, , bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information;

• Characteristics of protected classifications under California or federal law;

• Commercial information;

• Internet or other electronic network activity information;

• Audio, electronic, visual, thermal, olfactory, or similar information;

• Geolocation data;

• Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);

• Internet or other electronic network activity information (e.g., information regarding a consumer’s interaction with an Internet Web site, application, or advertisement);

• Professional or employment-related information;

• Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA); and

• Any and all inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Where Your Personal Information is Held. Information may be held at our offices and those of our third party partners, service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information With”).

How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account (or are employed or utilized as an independent contractor) with us or while we are providing products to you. Thereafter, we will keep your personal information for as long as is necessary:

• To respond to any questions, complaints or claims made by you or on your behalf;

• To show that we treated you fairly; or

• To keep records required by law or internal company policy regarding to employee or Consultant record retention.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

Your Rights Under the CCPA. If you are a resident of California, you have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You:

You have the right to know:

• The categories of personal information we have collected about you;

• The categories of sources from which the personal information is collected;

• Our business or commercial purpose for collecting or selling personal information;

• The categories of third parties with whom we share personal information, if any; and

• The specific pieces of personal information we have collected about you.

• Please note that we are not required to:

• Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;

• Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or

• Provide the personal information to you more than twice in a 12-month period.

Personal Information Sold or Used for a Business Purpose:

In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know:

The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and

The categories of personal information that we disclosed about you for a business purpose.

You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale or disclosure of your personal information. If you exercise your right to opt-out of the sale or disclosure of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information. To opt-out of the sale or disclosure of your personal information, email privacy@thirtyonegifts.com.

Right to Deletion:

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

• Delete your personal information from our records; and

• Direct any service providers to delete your personal information from their records.

• Please note that we may not delete your personal information if it is necessary to:

• Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;

• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;

• Debug to identify and repair errors that impair existing intended functionality;

• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;

• Comply with the California Electronic Communications Privacy Act;

• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;

• Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;

• Comply with an existing legal obligation; or

• Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Protection Against Discrimination:

You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:

• Deny goods or services to you;

• Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;

• Provide a different level or quality of goods or services to you; or

• Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information.

Your Personal Information Secure. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. These measures include, but may not be limited to: firewall technology, limited access servers, and, in the case of online orders, we require use of web browsers that permit communication through Transport Layer Security (encryption technology that provides security for information as it is being sent over the Internet). We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Policy, please:

• Email us at privacy@thirtyonegifts.com or people@thirtyonegifts.com (“people” email address is for current and former employees of Thirty-One Gifts only); send regular mail to Legal Dept., Thirty-One Gifts LLC, 3948 Townsfair Way, Ste. 200, Columbus, Ohio 43219; following the unsubscribe instructions in any marketing email you receive; or adjust your preferences in our Email Subscription Center. Even if you opt-out of marketing emails, you may still receive emails related to your transactions, such as order confirmations and may still receive emails directly from your Thirty-One Gifts Consultant that we do not send on behalf of the Consultant.

• By texting JOIN to our short code, you consent to receive periodic autodialed marketing text messages with first notice of promotions/deals/specials or event reminders to the mobile number provided from Thirty-One Gifts. Consent is not required for purchase. You can text STOP to the short code to opt out of or end text communications from us. You can also call 1-866-443-8731 to opt out of receiving text messages. For help, text HELP to the short code. Message frequency may vary. Message and data rates may apply.

Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.

If you choose to contact directly by email you will need to provide us with:

• Enough information to identify you (e.g., your full name, address and customer or matter reference number);

• Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and

• A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

Changes to This Privacy Notice. This Privacy Policy was first effective on May 1, 2013 (California residents only), updated on July 18, 2016, and last updated and published on January 1, 2023.

We may change this privacy notice from time to time for any reason. When we do, we will post the new policy on this page so that you are always aware of the information we collect, how we use it, and under what circumstances we disclose it. Should there be a material change to our Privacy Policy, it will only be applied to information collective after the material change’s effective date.

How to Contact Us. Please contact us by email at privacy@thirtyonegifts.com or send regular mail to Legal Dept., Thirty-One Gifts LLC, 3948 Townsfair Way, Ste. 200, Columbus, Ohio 43219if you have any questions about this privacy policy or the information we hold about you.

Additional Provisions That Apply to Personal Information Collected in Canada. By providing us personal information and using our Marketing Channels, you consent to the collection, use and disclosure of information in accordance with the terms of this Policy.

We will make reasonable efforts to ensure that the personal information we collect, use, and share is accurate and complete. If you would like to review your personal information, or you believe that any information we are holding on you is incorrect or incomplete, then please contact us using the contact information above.

We store and process personal information in the United States. Our thirty-party service providers may also store and process your personal information in the U.S. and other countries. Such personal information may be subject to disclosure under the laws of these countries. If you have questions about this processing or storage outside of Canada, please contact us using the contact information above.

Postal or Telephone Marketing: if you do not wish to receive marketing materials directly from us via regular postal mail or through phone calls or messages directly from us, please email us at privacy@thirtyonegifts.com or mail us at the above address and tell us to remove you from our postal mailing or phone marketing list. Even if you opt out of these postal mailings or phone marketing made directly by us, you may still receive mailing and calls from your independent Consultant.

If you would like to make sure we do not disclose your personal information to our affiliates, please email us at privacy@thirtyonegifts.com or mail us at the above address and tell us that you do not want us to disclose your personal information to our affiliates.

For our Consultants. To become a Thirty-One Gifts Consultant, you will be required to enter into a separate agreement with us (“Independent Sales Consultant Application and Agreement”). If you have entered into the Independent Sales Consultant Application and Agreement, we may collect, use and disclose your personal information in accordance with this Policy and the terms of your Independent Sales Consultant Application and Agreement. We may also collect, use, and disclose your personal information as necessary to fulfill our obligations under the Independent Sales Consultant Application and Agreement. In the event of a conflict between this Policy and the Independent Sales Consultant Application and Agreement, the terms of this Policy shall apply.

We may disclose your information to other Consultants or leaders; as part of our sales leadership program for Consultants who are sales leaders; to current and potential. Consultants for our legitimate business purposes; and for any and all other uses consistent with our business relationship.

Do You Need Extra Help? If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).