Consumer Health Data Privacy Policy

The Procter & Gamble Company values your privacy. Our Global Privacy Policy explains how we handle personal information generally. This supplemental Consumer Health Data Privacy Policy focuses specifically on how we manage “Consumer Health Data” as defined under laws such as Washington’s My Health My Data Act, Nevada’s Consumer Health Data Privacy Law, Connecticut’s Data Privacy Act, and other similar U.S. health privacy laws. Consumer Health Data is broadly defined as personal information that is linked or reasonably linkable to you and relates to your past, present, or future physical or mental health status. This can include medical conditions, biometric data, information about non-prescription medication use, and health-related product usage. It does not cover information about individuals with whom we have an employment relationship.

If we make important updates to this Health Privacy Policy, we will notify you as required by law, either at the time we collect your Consumer Health Data or by updating this policy sooner than planned. We may amend this policy at any time at our discretion.

Categories of Consumer Health Data We Collect

We only collect, use, and disclose Consumer Health Data when necessary to provide you with requested products or services or with your consent. The categories we may collect include:

Product Interests. Information about your interest in health-related brands or products, such as when you visit our websites or mobile apps or purchase certain items.

Individual Health Conditions, Treatments, and Diseases. Details about your health history, symptoms, or treatments. Examples include pregnancy status, seasonal allergies, gingivitis, cold or flu treatments using over-the-counter products, or using products for dandruff prevention.

Bodily Function, Vital Signs, and Measurements. Information about internal body systems, such as digestion, metabolism, immune support, height, or weight.

Reproductive and Sexual Health Information. Data about your reproductive system or sexual well-being that you voluntarily provide, such as period tracking or pregnancy status.

Biometric Data. Measurements of biological characteristics, including photos or videos of your face, skin, or teeth for product recommendations or research studies.

Genetic Information. Data about your genetic characteristics, typically processed in research studies rather than marketing programs.

Research Programs. Information you provide when participating in research studies or surveys, covering any of the above categories related to physical or mental health, medical history, or other health-related topics.

Purposes for Collecting and Using Your Health Data

We may use your Consumer Health Data for several purposes. These include providing products and services you request, such as sending samples. We also use it for consumer management, including identifying and authenticating you across marketing programs, websites, and mobile apps. This also involves managing accounts, preferences, financial incentives, rewards, discounts, and loyalty programs. We help you manage website or app preferences and allow you to enter contests, sweepstakes, and leave product ratings and reviews.

For customer service and communications, we respond to your questions, send transactional messages like account statements or confirmations, and deliver marketing communications, surveys, and invitations. For payment and financial matters, we process payments for products you buy from us.

We use your data to serve relevant ads about our brands and programs, as well as to administer ads by measuring campaign effectiveness and carrying out accounting activities. For quality and safety, we conduct quality control, training, analytics, safety verification, system administration, and technology management to optimize our websites and apps. For security, we detect threats and protect against malicious or fraudulent activity. We also use your information for recordkeeping and auditing interactions with consumers, including maintaining transaction logs.

For legal and compliance reasons, we engage in risk management, audits, investigations, reporting, and other legal activities. Finally, we use your data for research and development, including internal research and designing new products, services, and programs.

Sources of Consumer Health Data

We collect Consumer Health Data from several sources. You provide it directly when you request health-related products or services, join email lists or loyalty programs, or volunteer information in surveys or promotions. We collect it through your interactions with us when you use health-related apps or browse our health brand websites. Our business and marketing partners share information about consumers viewing our content across websites or apps, purchasing our products, or using our promotions. We may also receive data from third-party sources such as data brokers who identify consumers interested in our products. Additionally, we may infer or derive Consumer Health Data by analyzing other non-health information we have about you or other consumers.

Disclosures of Consumer Health Data

We do not sell your Consumer Health Data. We also do not share it with any third parties or affiliates. We may disclose the categories of Consumer Health Data described above in certain circumstances. We share it with our data processors, service providers, and contractors who help us provide goods and services to you. These processors may only use the data as permitted by our contracts. This includes our P&G family of brands, all of which are bound by our Global Privacy Policy and committed to protecting your data.

We may also disclose Consumer Health Data as permitted by law. This includes disclosure with your consent, to protect your vital interests in a medical emergency or natural disaster, to an acquiring organization if we sell or transfer our business, to prevent or respond to security incidents, identity theft, fraud, harassment, or deceptive activities, to preserve system integrity or security, or to investigate or prosecute illegal actions.

Your Privacy Rights

You have specific rights regarding your Consumer Health Data. You have the right to know whether we are collecting, using, or disclosing it. You may access your Consumer Health Data and receive a list of entities with whom we have shared your information, although we currently do not sell or share it. You have the right to request deletion of your Consumer Health Data. If we are processing your data based on your consent, you may withdraw that consent. For cookie-related Consumer Health Data, you can do this through Cookie Preferences on our health-related websites or in the Settings menu of our mobile apps. Withdrawing consent for non-cookie health data will result in a deletion request.

We will not discriminate against you for exercising your rights. However, if you withdraw consent or request deletion, we may remove you from certain marketing programs that depend on your health data to provide services.

To exercise your rights, you may submit a request through our Consumer Health Data Preference Center. We will authenticate your requests and process them as required by law. Please allow up to 45 days for a response. If we deny your request, you may appeal that denial. If your appeal is unsuccessful, you may file a complaint with the relevant state government body, such as the Washington State Attorney General or the Nevada State Attorney General.

For any questions or concerns about your Consumer Health Data privacy or this policy, please contact us directly or write to our Data Protection Officer at our corporate address.