iHerb, LLC
EU/Swiss-U.S. Privacy Shield: Consumer Privacy Policy
Last Updated: June 25, 2019iHerb, LLC (“iHerb”) respects your concerns about privacy. iHerb participates in the EU-U.S.
and Swiss-U.S. Privacy Shield frameworks (collectively, the “Privacy Shield”) issued by theU.S. Department of Commerce. iHerb commits to comply with the Privacy Shield Principles
with respect to Consumer Personal Data the company receives from the EU, UK and Switzerland
in reliance on the Privacy Shield. This Policy describes how iHerb implements the Privacy
Shield Principles for Consumer Personal Data.
“Consumer” means any natural person who is located in the EU, UK or Switzerland, but
excludes any individual acting in his or her capacity as an Employee.
“Controller” means a person or organization which, alone or jointly with others, determines thepurposes and means of the processing of Personal Data.
“Employee” means any current, former or prospective employee, contractor, intern or temporary
worker of iHerb or any of its EU, UK or Swiss subsidiaries or affiliates, or any related individual
whose Personal Data iHerb processes in connection with an employment relationship, who islocated in the EU, UK or Switzerland.
“EU” means the European Union and Iceland, Liechtenstein and Norway.
“Personal Data” means any information, including Sensitive Data, that is (i) about an identified
or identifiable individual, (ii) received by iHerb in the U.S. from the EU, UK or Switzerland, and(iii) recorded in any form.
“Privacy Shield Principles” means the Principles and Supplemental Principles of the EU-U.S.
and Swiss-U.S. Privacy Shield frameworks.
“Processor” means any natural or legal person, public authority, agency or other body thatprocesses Personal Data on behalf of a Controller.
“Sensitive Data” means Personal Data specifying medical or health conditions, racial or ethnic
origin, political opinions, religious or philosophical beliefs, trade union membership (including
trade union-related views or activities), sex life (including personal sexuality), information onsocial security measures, the commission or alleged commission of any offense, any proceedings
for any offense committed or alleged to have been committed by the individual or the disposal ofsuch proceedings, or the sentence of any court in such proceedings (including administrativeproceedings and criminal sanctions).
“UK” means the United Kingdom.
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iHerb’s Privacy Shield certification, along with additional information about the Privacy Shield,
can be found at https://www.privacyshield.gov/. For more information about iHerb’s processingof Consumer Personal Data with respect to information collected on its website, please visit
iHerb’s Privacy Policy at https://www.iherb.com/info/privacy.
Types of Personal Data iHerb Collects
iHerb obtains Personal Data about Consumers in various ways. For example, iHerb collects
Personal Data directly from Consumers when they interact with iHerb’s website and mobile apps
(collectively, the “Services”). The company may use this information for the purposes indicatedin iHerb’s Privacy Policy at https://www.iherb.com/info/privacy.
The types of Personal Data iHerb collects directly from Consumers include:
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contact information (such as name, email address, shipping and billing address, andtelephone number);login credentials to create an account on the Services (such as email address andpassword);
information contained on social media public profiles, to the extent Consumers decide tocreate an account on the Services using their social media accounts;
information Consumers choose to submit on their personalized public profile “My Page”,
including web address name, user name, photograph, links to social media accounts andany other information they choose to submit on the “Page Description” section of “MyPage”;
user-generated content related to product reviews, comments, questions and answers;
payment information, such as name, billing address, account number, and payment carddetails (including card number, expiration date and security code) for payments processedby iHerb;bank account and tax information related to any company programs that may offer
customer payouts (such as the Rewards program);order history, including information about products purchased or viewed on the Services;
details Consumers provide through contests, sweepstakes and surveys;
social media information, such as social media handles, content and other data sharedwith iHerb through third-party features that Consumers use on the Services (such as apps,tools, payment services, widgets and plugins offered by social media services like
Facebook, Google+, Instagram, LinkedIn, Pinterest, Twitter and YouTube) or posted onsocial media pages (such as social media pages or other pages);other personal information contained in content Consumers submit on the Services, suchas through the “Contact Us” feature or other customer support tools;
information you submit in connection with a career opportunity at iHerb, such as contact
details, information in your resume and cover letter, and details about your current
employment;
country/region and language preference based on mobile device settings and/or IP; andIP address, device, operating system, and browser information.

2In addition, iHerb obtains Personal Data, such as contact information and financial account ofrepresentatives of its vendors (such as payment processors and shipping carriers). iHerb uses thisinformation to manage its relationships with these parties, process payments, and carry out
iHerb’s contractual obligations.
iHerb also may obtain and use Consumer Personal Data in other ways for which iHerb provides
specific notice at the time of collection.
iHerb’s privacy practices regarding the processing of Consumer Personal Data comply with thePrivacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data
Integrity and Purpose Limitation; Access; and Recourse, Enforcement and Liability.
NoticeiHerb provides information in this Policy and the company’s Privacy Policy about its Consumer
Personal Data practices, including the types of Personal Data iHerb collects, the types of third
parties to which iHerb discloses the Personal Data and the purposes for doing so, the rights andchoices Consumers have for limiting the use and disclosure of their Personal Data, and how tocontact iHerb about its practices concerning Personal Data.
Relevant information also may be found in notices pertaining to specific data processing
activities.
ChoiceiHerb generally offers Consumers the opportunity to choose whether their Personal Data may be(i) disclosed to third-party Controllers or (ii) used for a purpose that is materially different fromthe purposes for which the information was originally collected or subsequently authorized by
the relevant Consumer. To the extent required by the Privacy Shield Principles, iHerb obtains
opt-in consent for certain uses and disclosures of Sensitive Data. Consumers may contact iHerb
as indicated below regarding the company’s use or disclosure of their Personal Data. UnlessiHerb offers Consumers an appropriate choice, the company uses Personal Data only for
purposes that are materially the same as those indicated in this Policy.
Sharing of Consumer Personal DataiHerb shares Consumer Personal Data with its affiliates and subsidiaries, which may include any
entity within the iHerb network of companies, for purposes of operating iHerb’s business andproviding iHerb products and services. iHerb also may share Consumer Personal Data withthird-party Processors the company retains to perform services on its behalf, such as payment
processing and authorization, order fulfillment, transportation, customs clearance, marketing,data analytics, customer support, and fraud prevention. These third-party Processors may use
Consumer Personal Data only on iHerb’s behalf and pursuant to iHerb’s instructions, for the
purpose of providing services to iHerb such as those described above. iHerb may disclose
Consumer Personal Data without offering an opportunity to opt out, and may be required todisclose the Personal Data, (i) to third-party Processors the company has retained to perform
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services on its behalf and pursuant to its instructions, (ii) if it is required to do so by law or legal
process, or (iii) in response to lawful requests from public authorities, including to meet nationalsecurity, public interest or law enforcement requirements. iHerb also reserves the right to transfer
Personal Data in the event of an audit or if the company sells or transfers all or a portion of its
business or assets (including in the event of a merger, acquisition, joint venture, reorganization,dissolution or liquidation).
Accountability for Onward Transfer of Personal Data
This Policy and iHerb’s Privacy Policy describe iHerb’s sharing of Consumer Personal Data.
Except as permitted or required by applicable law, iHerb provides Consumers with anopportunity to opt out of sharing their Personal Data with third-party Controllers. iHerb requires
third-party Controllers to whom it discloses Consumer Personal Data to contractually agree to (i)only process the Personal Data for limited and specified purposes consistent with the consent
provided by the relevant Consumer, (ii) provide the same level of protection for Personal Data as
is required by the Privacy Shield Principles, and (iii) notify iHerb and cease processing Personal
Data (or take other reasonable and appropriate remedial steps) if the third-party Controller
determines that it cannot meet its obligation to provide the same level of protection for Personal
Data as is required by the Privacy Shield Principles.
With respect to transfers of Consumer Personal Data to third-party Processors, iHerb (i) enters
into a contract with each relevant Processor, (ii) transfers Personal Data to each such Processor
only for limited and specified purposes, (iii) ascertains that the Processor is obligated to provide
the Personal Data with at least the same level of privacy protection as is required by the Privacy
Shield Principles, (iv) takes reasonable and appropriate steps to ensure that the Processor
effectively processes the Personal Data in a manner consistent with iHerb’s obligations under thePrivacy Shield Principles, (v) requires the Processor to notify iHerb if the Processor determinesthat it can no longer meet its obligation to provide the same level of protection as is required by
the Privacy Shield Principles, (vi) upon notice, including under (v) above, takes reasonable andappropriate steps to stop and remediate unauthorized processing of the Personal Data by theProcessor, and (vii) provides a summary or representative copy of the relevant privacy provisionsof the Processor contract to the Department of Commerce, upon request. iHerb remains liable
under the Privacy Shield Principles if the company’s third-party Processor onward transfer
recipients process relevant Personal Data in a manner inconsistent with the Privacy ShieldPrinciples, unless iHerb proves that it is not responsible for the event giving rise to the damage.
Security
iHerb takes reasonable and appropriate measures to protect Consumer Personal Data from loss,
misuse and unauthorized access, disclosure, alteration and destruction, taking into account therisks involved in the processing and the nature of the Personal Data.
Data Integrity and Purpose LimitationiHerb limits the Consumer Personal Data it processes to that which is relevant for the purposes of4the particular processing. iHerb does not process Consumer Personal Data in ways that areincompatible with the purposes for which the information was collected or subsequently
authorized by the relevant Consumer. In addition, to the extent necessary for these purposes,
iHerb takes reasonable steps to ensure that the Personal Data the company processes is (i)reliable for its intended use, and (ii) accurate, complete and current. In this regard, iHerb relies
on its Consumers to update and correct the relevant Personal Data to the extent necessary for thepurposes for which the information was collected or subsequently authorized. Consumers may
contact iHerb as indicated below to request that iHerb update or correct relevant Personal Data.
Subject to applicable law, iHerb retains Consumer Personal Data in a form that identifies orrenders identifiable the relevant Consumer only for as long as it serves a purpose that iscompatible with the purposes for which the Personal Data was collected or subsequently
authorized by the Consumer.
AccessConsumers generally have the right to access their Personal Data. Accordingly, whereappropriate, iHerb provides Consumers with reasonable access to the Personal Data iHerb
maintains about them. iHerb also provides a reasonable opportunity for those Consumers tocorrect, amend or delete the information where it is inaccurate or has been processed in violationof the Privacy Shield Principles, as appropriate. iHerb may limit or deny access to Personal Data
where the burden or expense of providing access would be disproportionate to the risks to theConsumer’s privacy in the case in question, or where the rights of persons other than theConsumer would be violated. Consumers may request access to their Personal Data bycontacting iHerb as indicated below.
Recourse, Enforcement and Liability
iHerb has mechanisms in place designed to help assure compliance with the Privacy ShieldPrinciples. iHerb conducts an annual self-assessment of its Consumer Personal Data practices toverify that the attestations and assertions iHerb makes about its Privacy Shield privacy practices
are true and that iHerb’s privacy practices have been implemented as represented and inaccordance with the Privacy Shield Principles.
Consumers may file a complaint concerning iHerb’s processing of their Personal Data. iHerb
will take steps to remedy issues arising out of its alleged failure to comply with the Privacy
Shield Principles. Consumers may contact iHerb as specified below about complaints regarding
iHerb’s Consumer Personal Data practices.
If a Consumer’s complaint cannot be resolved through iHerb’s internal processes, iHerb will
cooperate with JAMS pursuant to the JAMS Privacy Shield Program, which is described on theJAMS website at https://www.jamsadr.com/eu-us-privacy-shield. JAMS mediation may becommenced as provided for in the JAMS rules. Following the dispute resolution process, themediator or the Consumer may refer the matter to the U.S. Federal Trade Commission, which
has Privacy Shield investigatory and enforcement powers over iHerb. Under certain5

circumstances, Consumers also may be able to invoke binding arbitration to address complaints
about iHerb’s compliance with the Privacy Shield Principles.
How to Contact iHerb
To contact iHerb with questions or concerns about this Policy or iHerb’s Consumer Personal
Data practices:
iHerb, LLC
Attn: Data Processing Officer
301 North Lake Avenue, Suite 600
Pasadena, CA 91101
E-mail: privacy@iherb.com

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