Privacy Policy

DOLLAR SHAVE CLUB PRIVACY POLICY

Effective Date: May 25, 2018

Updated Date: 11 January 2024

This Privacy Policy applies to personal information collected and used by Dollar Shave Club (“DSC,” “we,” “our” or “us”) in connection with the products and services that DSC offers. The DSC site is owned and operated by DSC who is the data controller over the personal information. This includes information collected online through our websites, branded pages on third party platforms (i.e., social networking services), mobile applications, and through our direct marketing campaigns or other online communications, as well as offline through our Member Services Team, events, and mobile messaging services (collectively, “DSC Services”).

This Privacy Policy explains what information may be collected through the DSC Services, how such information may be used and/or shared with others, how we safeguard it and how you may access and control its use in connection with our marketing communications and business activities.

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1. WHO IS DSC?
We are an awesome company that sells razors, grooming supplies, and other personal care products.
DSC sells shaving razors, grooming supplies, and other personal care products to end-user customers who make one-time purchases and 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).

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.

For information about our use of cookies and other similar technologies, you can read our Cookie Policy. In addition, please note that we automatically collect the following information about you:

Device. We may automatically collect your IP address and other unique identifiers for the computer, mobile device, tablet or other device you use to access the DSC Services, including the hardware model and mobile network information. This data may be used to help diagnose problems with our servers, analyse trends, track 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, 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

We may combine the information we receive from you and about you, including information you provide to us and information we automatically collect through the DSC Services, as well as information collected across other computers or devices that you may use, from other online or offline sources, and from third party sources. This combined information may be used in any manner detailed in this privacy policy.

3. HOW DO WE USE THE INFORMATION WE COLLECT?

We may use the information about you for a variety of business purposes; in general, to provide the services, improve customer experience and engagement and develop DSC and its Services. We are committed to protecting and maintaining the privacy of your information, and will process your data only in accordance with applicable data protection law and this Privacy Policy.

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;
contact you with regard to your use of the DSC Services and, in our discretion, with regards to changes to our privacy policy;
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.

Profiling/Automated Decision-Making

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 legal or similarly 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.
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.
- Sweepstakes, Contests, and Promotions. If you choose to enter into one of our sweepstakes, contests, or other promotions we may disclose your information to third parties or the public in connection with the administration of such Promotion, as required by law, as otherwise permitted by the Promotion’s official rules, or otherwise in accordance with the terms of this Privacy Policy.
- 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. 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, you may do so by clicking ‘Your Privacy Choices’ in the footer of our website. You may also 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.
Further information and advice about your rights can be obtained from the data protection regulator in your country (which is the ICO in the UK). For information about our use of cookies and other similar technologies, you can read our Cookie Policy.
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.
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.
We use certain reasonable security measures to help protect your personal information. However, no electronic data transmission or storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information you transmit to us. You use the DSC Services and provide us with your information at your own risk. If we share information with a third party we shall use all reasonable efforts to ensure that they keep the information secure and only use the information consistent with the terms of this privacy policy.
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, 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.
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. 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 Model Clauses or, where applicable, the UK Extension to the EU-U.S. Data Privacy Framework. 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, 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.
Any changes we may make to our privacy policy will be posted on this page. If we make a material change to this privacy policy, we will provide appropriate notice to you and ask for your consent to any new activity carried out with your personal information where appropriate. In addition to this Privacy Policy, there may be specific campaigns or promotions which will be governed by additional privacy terms or policies. Any additional privacy terms or policies will be made prominently available to you.
11. HOW CAN I CONTACT DSC IF I HAVE QUESTIONS ABOUT THIS POLICY?
If you have any questions or concerns regarding this Privacy Policy or our privacy practices, please contact us.
- Send us an e-mail at [email protected].
- Contact us by mail at Dollar Shave Club, The Broadgate Tower Third Floor, 20 Primrose Street, London, United Kingdom, EC2A 2RS.

Privacy PolicyUpdated 3 months ago

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