Effective Date: May 25, 2018
Updated Date: January 3, 2022
QUICK GUIDE TO CONTENTS
- WHO IS DSC?
- WHAT INFORMATION DO WE COLLECT?
- HOW DO WE USE THE INFORMATION WE COLLECT?
- WHO MIGHT WE SHARE YOUR INFORMATION WITH?
- HOW LONG DO WE KEEP HOLD OF YOUR INFORMATION?
- WHAT ARE YOUR RIGHTS?
- WHAT ABOUT CHILDREN'S PRIVACY?
- HOW DO WE SECURE YOUR INFORMATION?
- DO WE TRANSFER DATA INTERNALLY?
- HOW DO WE COMMUNICATE CHANGES TO OUR PRIVACY POLICIES?
- HOW CAN I CONTACT DSC IF I HAVE QUESTIONS ABOUT THIS POLICY?
1. WHO IS DSC?
We are an awesome company that sells razors, grooming supplies, and other personal care products. (Click to see more)
DSC sells shaving razors, grooming supplies, and other personal care products to end-user customers who purchase a recurring membership plan to have the products shipped regularly on a schedule of their choosing.
DSC is the “data controller” with respect to information that we collect from or about you. This means that we are responsible for deciding how we hold and use personal data about you.
2. WHAT INFORMATION DO WE COLLECT?
There are several ways we may obtain personal information about you, including through (A) information you provide to us directly; (B) information that we automatically collect; and (C) information we receive from third parties. Personal information is data that identifies you personally whether directly (i.e. your name) or indirectly (i.e. information about your online use). (Click to see more)
A. Information You Provide To US
When you use the DSC Services, we may ask you to provide certain personal information. For example, we may ask for information when you register to create an account, update your information, sign up for a membership or subscription, use certain features, access, upload or download content, purchase Products or services, enter into sweepstakes or other promotions, register or participate in a competition, fill out a survey, request customer support, or otherwise communicate with us.
We (or our service providers or business partners) may collect information that relates to you, including personal information, such as your name, e-mail address, telephone or mobile number, mailing address, date of birth, gender, and demographic information. You are not required to provide DSC with your personal information, but if you choose not to do so, we may not be able to provide you with our products or services, or with a high quality of service or respond to any queries you may have.
Information You Provide When You Participate in an Online Survey or Other Research. We may also collect information you provide us in connection with participating in an online survey or as a research panel participant. This may include, but may not be limited to, information about your shopping habits, lifestyle preferences, interests and hobbies, health, physical or behavioral characteristics, or other demographic information, as well as photos, videos, and other user-generated content.
Information You Provide When You Make a Purchase. If you make a purchase from us, you will be required to provide a credit/debit card number and related financial information (such as CVV, expiration date, and billing address), or other payment information (such as via PayPal or Apple Pay), depending on the form of payment you choose.
Information You Provide Through Social Media. You may also be given the option to link to your Facebook or other social media accounts through the DSC Services. When you do, we may automatically receive certain information from you based upon your privacy settings on those sites. This may include, but may not be limited to, name, user name, demographic information, updated address or contact information, location, interests, and publicly-observed data, such as from social media and online activity.
B. Information Collected Automatically
Whenever you visit or interact with the DSC Services, DSC, as well as any third-party advertisers and/or service providers, may use a variety of technologies that automatically or passively collect information about your online activity.
- Device. We may automatically collect your IP address or other unique identifier for the computer, mobile device, tablet or other device you use to access the DSC Services, including the hardware model and mobile network information. The data may be used to help diagnose problems with our servers, analyse trends, track users’ web page, email and mobile application movements/activities (such as for fraud prevention purposes and to support our marketing efforts), help identify or gather broad demographic information for aggregate use, and retarget online and mobile advertisements to you across computers or devices you may use.
- Location. We collect general information about where traffic and purchases on our site are coming from around the world. This is used at an aggregate level (that does not identify individual users) to create reports to better understand our engagement with users.
- Third Party Service Providers. We may use third party service providers to support the DSC Services. Some of these service providers may use technology such as cookies, web beacons, pixel tags, log files, or other technologies to receive, collect, and store information on our behalf.
- Third Party Analytic Technologies. We may use third parties’ analytics and tracking tools, such as Google Analytics, Adobe Marketing Cloud, Facebook Custom Audience, Facebook Conversion API and others, to help us track, segment and analyze usage of the DSC Services, and to help us or those third parties serve more targeted advertising to you on the DSC Services and across the Internet.
To learn more about your advertising choices relating to the collection and use of your information, please see the Your Rights section below.
C. Information Received from Other Third-Party Sources
DSC may receive your personal information as follows:
- We may obtain information about you from other trusted third-party sources to update or supplement the information that you provide or that we collect automatically. This includes, for example, public databases or data aggregators (that may include your demographic information, media consumption, previous purchases, shopping habits, loyalty program information or lifestyle preferences).
- DSC partners and service providers (including, for example, business partners, analytics vendors, advertising networks and search information providers).
We may use this information to help us maintain the accuracy of the information we collect, personalise your experience with the DSC Services, target our communications so that we can inform you of Products and services or other offers that may be of interest to you, to measure ad quality and responses, and for internal business analysis or other business purposes.
D. Combination of Information
3. HOW DO WE USE THE INFORMATION WE COLLECT?
We will have a lawful basis for processing your data if:
- we need to process your information in order to provide you with the Products or service you have requested or to enter into a contract;
- you have consented to such processing – e.g., when you sign up to receive promotional emails or other electronic communications from us;
- we have a legitimate interest for processing your data – e.g., for fraud prevention and abuse tracking; direct marketing; network and information systems security; data analytics; website content delivery; enhancing modifying or improving our services; identifying usage trends; determining the effectiveness of promotional campaigns; and personalisation of the service using data to make it easier and faster for you to place orders; and/or
- we are legally obliged to process it.
We may use your personal information for Customer Service and Transactional Purposes, such as to:
- respond to your questions or requests and provide customer service;
- manage your account and registration;
- troubleshoot issues, bugs or defects related to your account or activities;
- provide you with access to certain features of the DSC Services;
- validate, confirm, verify, deliver, and track your order (including to arrange for shipping, handle returns and refunds, and contact you about your orders, including by telephone), and send you related information, coupons, Products or samples;
- verify your identity or communicate with you about your activities with respect to the DSC Services;
- use your credit, debit or payment card or other financial information only to process payments and prevent fraud;
- develop new Products or services and to enhance current Products and services;
- protect the security or integrity of the DSC Services and our business., such as by protecting against and preventing fraud, unauthorised transactions, claims and other liabilities, and managing risk exposure, including by identifying potential hackers and other unauthorised users; and
- for other purposes as disclosed at the time you provide your personal information or otherwise with your consent.
We may use your personal information for Advertising Customisation and Analytics Purposes, such as to:
- perform market research, understand the effectiveness of our competition or promotions and DSC Services analytics and operations;
- personalise and improve the DSC Services and our Products, services, offers and advertising made available on or outside the DSC Services (including on other sites/ applications that you visit). For example, we may provide personalised or localised content, recommendations, features, and provide content or features that match your interests and preferences;
- provide you with customised content, advertisements, offers and promotions offered by DSC or on behalf of our partners and affiliates;
- link or combine with information we receive from others to help understand your needs, use for interest-based or targeted advertising or re-targeting on your computers or other devices, and to provide you with better service;
- communicate with you, either directly or through one of our partners (e.g., through Facebook Custom Audience, Google Customer Match, Twitter Match, our social media pages etc.) for DSC marketing and promotional purposes via emails, notifications, or other messages, consistent with any consents you have given to us.
This processing may involve the use of your personal data to create profiles or audiences, by analyzing the information about your online surfing, searching and buying behavior, interests, demographic or location-based information, and your interactions with DSC communications by building segments (i.e., creating groups that have certain common characteristics) and by placing your personal data in one or more segments. DSC may use this information to market and customize your experience on the DSC website or mobile app, and across other sites, apps, and services. DSC may also anonymize this information for use in customer acquisition, including by creating segments to target customers with similar profiles across other sites, apps, and services.
In some instances, DSC processes your personal data for the profiling purposes described above using automated or semi-automated means. An automated decision is a decision which is made solely by automatic means, where no humans are involved in the decision-making process related to your personal data. We will not make any decisions based solely on automated or semi-automated decision-making that have a significant impact on you.
4. WHO MIGHT WE SHARE YOUR INFORMATION WITH?
The information collected or generated through your use of the DSC Services may be shared by you or by us as described below. (Click to see more)
A. Sharing of Information by You
The DSC Services offer many ways to find, enjoy, and share content.
Your activity in connection with the DSC Services, such as filling out surveys, reviewing and rating Products, inquiring about or purchasing Products, participation in online communities, “liking” or “sharing” DSC content to your social media accounts or pages or otherwise interacting with the DSC Services, may be visible to other users of the DSC Services and in some cases, publicly available.
B. Sharing of Information by Us
We may share your personal information with:
- Our Affiliates. We may share your personal information with our subsidiaries and affiliated companies for internal reasons, primarily for business and operational purposes.
- Third Party Service Providers. We may share your personal information with third-party service providers that provide business, professional or technical support functions on our behalf. This includes, but may not be limited to, service providers that host or operate the DSC Services; process payment; analyse data; provide customer service; postal or delivery services, and sponsors or other third parties that participate in or administer any promotions. We are not responsible for these sites or their content, products, services or privacy policies or practices. These other web sites may send their own cookies to your device and may independently collect data or solicit personal information and may or may not have their own published privacy policies. We may also transfer or disclose your personal information to another data controller to be used for similar purposes, at that data controller’s discretion and you hereby consent to such transfer or disclosure.
- Other Third Parties. Your personal information may also be shared with our sponsors, partners, advertisers, advertising networks, advertising servers and analytics companies or other third parties in connection with marketing, promotional, and other offers, as well as product information. Your information may also be shared with third parties we identify at the time you provide your personal information or otherwise with your consent. You have the option to opt-in to receive direct marketing from these selected third parties. With your consent, we will also share your information with members of our corporate family who will use your personal information to send you marketing communications. You can change your mind and opt-out at any time as detailed in Your Rights below.
- Social media platforms. We may collect information and insights from your use and interactions with pages or accounts we operate on third party platforms (for example Facebook Fan Pages) and to administer those accounts. For such pages, both we and the third party platform are data controllers of any insight data and for Facebook fan pages, we are required to enter into a contract with Facebook to reflect joint controllership. You can download this contract here: https://www.facebook.com/legal/terms/page_controller_addendum. It contains further details and explanations on the joint controllership with Facebook in the context of fan page insights. Otherwise with social media platforms, we may provide an ID or hashed data to tailor communications on those platforms (subject to your settings with that platform) or to understand the effectiveness of any campaigns run on those platforms.
- Business Transfers. In the event that another entity acquires us or all or substantially all of our assets, or assets related to the DSC Services, your information may be disclosed to such entity as part of the due diligence process and will be transferred to such entity as one of the transferred assets. Also, if any bankruptcy or reorganisation proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties. Finally, information described in this paragraph may also be disclosed for due diligence purposes in connection with any proposed transaction of the sorts described in this paragraph.
- Legal obligations. In limited circumstances, we may transfer and disclose your information to law enforcement and government authorities to comply with our legal obligation.
5. HOW LONG DO WE KEEP HOLD OF YOUR INFORMATION?
We keep your personal information for as long as we need it for the purpose it is being processed for; afterwards, we may take steps to securely delete or otherwise anonymize or aggregate your personal information. (Click to see more)We will keep your personal information for as long as we need it for the purpose it is being processed for. For example, we will retain your information for as long as your account is active or as needed to provide you services you request; and after that, we will keep the personal information for a period of time which enables us to handle or respond to any complaints, queries or concerns relating to your account. Your information may also be retained so that we can continue to improve your experience with us. After this we may take steps to securely delete your personal information or otherwise anonymize or aggregate such information, when there is no longer a legal, business, or consumer need for it to be retained.
6. WHAT ARE YOUR RIGHTS?
By law, you have a number of rights when it comes to your personal data. If you wish to exercise these rights with regards to your personal information that we hold, please send an email to [email protected] or contact us using the details set out in the Contact Us section below. Please include the statement “Data Subject Request” in the subject line.
- The right to be informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we are providing you with the information in this Policy.
- The right to rectification. You are entitled to have your information corrected if it is inaccurate or incomplete. You can do this through your account page or by contacting us at the email address below.
- The right to erasure. This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there is no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
- The right to restrict processing. You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
- The right to data portability. You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.
- The right to object to processing. You have the right to object to certain types of processing, including processing for direct marketing (i.e., if you no longer want to be contacted with potential opportunities).
- The right to lodge a complaint. You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator.
- The right to withdraw consent. If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes. You can do this by using the details set out in the Contact Us section below.
Pursuant to applicable data protection law, we may be entitled to refuse to act on the request.
7. WHAT ABOUT CHILDREN’S PRIVACY?
Our Services are not directed to children, and we do not knowingly collect information from children under 16. (Click to see more)
We do not direct the DSC Services to, nor do we knowingly collect any personal information from, children under the age of sixteen. If DSC learns that a minor has provided personal information through the DSC Services, we will use reasonable efforts to remove such information from our files.
8. HOW DO WE SECURE YOUR INFORMATION?
While no data collected on the internet is 100% secure, we use reasonable security measures to help protect your personal information. (Click to see more)
9. DO WE TRANSFER DATA INTERNATIONALLY?
DSC is a global business and it, or its service providers, may process, transfer, and store information about our users on servers located in a number of countries outside the UK and European Economic Area (EEA), including to the United States. Since we are committed to protecting your information, we take reasonable steps to ensure that there are appropriate safeguards in place when we transfer that data. (Click to see more)
In some locations where your data is stored by DSC or its service providers, the data protection laws may be less stringent than in the UK or EEA. To ensure that your data is adequately protected, we only transfer your data subject to adequate and appropriate safeguards being in place, such as through the use of approved standard UK/EU Model Clauses. We also make sure that any such transfers are conducted in accordance with applicable data protection laws.
To find out more about how we safeguard your information (including obtaining a copy of such safeguards) in relation to transfers outside the UK and EEA, please contact us via the details provided in the ‘Contact Us’ section below.
10. HOW DO WE COMMUNICATE CHANGES TO OUR PRIVACY POLICIES?
If we make changes, we’ll post it on this page. If the changes are material, we’ll provide appropriate notice to you. (Click to see more)
11. HOW CAN I CONTACT DSC IF I HAVE QUESTIONS ABOUT THIS POLICY?
- Send us an e-mail at [email protected]
- Contact us by mail at Dollar Shave Club, 100 Victoria Embankment, Blackfriars, London EC4Y 0DY.