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Privacy PolicyUpdated a month ago

Last updated: June 3, 2024

This Privacy Policy applies to information collected by Dollar Shave Club, Inc. (“DSC,” “we,” “our” or “us”) in connection with the products and services that DSC offers.  This includes information collected online through our websites, branded pages on third party platforms (i.e., social networking services), our mobile applications, and through our direct marketing campaigns or other online communications, as well as offline through our Dollar Shave Club employees, events, and mobile messaging services (collectively, “DSC Services”). If you are a DSC employee, contractor, or job applicant, please refer to the Employee, Contractor, and Job Applicant Privacy Notice.

This Privacy Policy explains how information collected in connection with the delivery of the DSC Services may be used and disclosed, how we safeguard it, and how you may access and control its use in connection with our marketing communications and business activities. By using the DSC Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy.  If you do not agree, please do not use the DSC Services.

This Privacy Policy is hereby incorporated into the terms and conditions of use of the DSC Services. By using DSC Services, you also agree to the Terms of Use.

In addition to this Privacy Policy, there may be specific campaigns or promotions which will be governed by additional privacy terms or policies. We encourage you to read these additional terms or policies before participating in any such campaigns or promotions, as you will be required to comply with them if you participate. Any additional privacy terms or policies will be made prominently available to you. 

NOTICE TO CALIFORNIA RESIDENTS

We collect the categories of Personal Information (as defined in the California Consumer Privacy Act (CCPA)) listed in the table below.

Category of Personal Information Collected

Sold or Shared

Identifiers, including your name, phone number, postal and email address, IP address, username, unique identifiers, or other similar identifiers. 

Yes

Personal information categories listed in the California Customer Records statute, including email address.

Yes

Protected classification characteristics under California or federal law, including your gender, age, and parental status.

No

Commercial information, including your purchase and usage history, goods and services preferences, payment and account information, wallet balance, and billing dates.

Yes

Internet or other electronic network activity information, including your web/app browsing history, search history related to the DSC Services, and information regarding your interactions with the DSC Services, including via an application, chat bot, or advertisement.

Yes

Geolocation data, including the location of the device you use to access the DSC Services.

No

Professional or employment-related information, including information relating to your income level.

No

Education information, including information relating to your education level

No

Inferences, meaning inferences that we draw from the above categories of Personal Information to create a personalized profile so we can better identify goods and services that may be of interest to you.

No

Sensitive personal information, including your account log-in information in combination with the password allowing access to your account, your racial or ethnic origin.

No


As further described in the “How We Use the Personal Information Collected” section below, we generally collect and use the above-listed categories of Personal Information to best serve you and deliver, support, and market the DSC Services. 

As noted in the table above, we “sell” or “share” (as defined in the CCPA) certain categories of Personal Information and you may exercise your right to opt out of such disclosures by completing and submitting the form available here. Alternatively, where available, you may choose to enable an online tool that automatically communicates your opt-out preferences, such as the Global Privacy Control (“GPC”).  When detected, we will process such signals as a request to opt out.

We retain each category of Personal Information that we collect for as long as necessary to fulfill the purposes described in our Privacy Policy, including to satisfy legal or reporting requirements.

More information, including a description of your legal rights, can be found below in the “Your Privacy Rights” section.

QUICK GUIDE TO CONTENTS 

  1. PERSONAL INFORMATION COLLECTION
  2. HOW WE USE THE PERSONAL INFORMATION COLLECTED
  3. DISCLOSURE OF PERSONAL INFORMATION
  4. YOUR CHOICES
  5. YOUR PRIVACY RIGHTS
  6. ADDITIONAL INFORMATION FOR EEA, UK, AND SWITZERLAND RESIDENTS
  7. CHILDREN'S PRIVACY
  8. SECURITY OF YOUR PERSONAL INFORMATION
  9. INFORMATION RETENTION
  10. NOTICE OF FINANCIAL INCENTIVE
  11. OTHER SITES
  12. INTERNATIONAL TRANSFERS
  13. CHANGES TO THIS PRIVACY POLICIES
  14. CONTACT US

 

  1. PERSONAL INFORMATION COLLECTION

When information identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household, we refer to it as “Personal Information.” 

   - Identifiers: We may collect your name, postal and email address, IP address, phone number, username, unique identifiers, or other similar identifiers

   - Personal information categories listed in the California Customer Records statute: We may collect information including telephone numbers and credit and debit card information

   - Characteristics of Protected Classifications under Applicable Law: We may collect your gender, age, and parental status.  

 - Commercial Information: We may collect your purchase and usage history, goods and service preferences, payment and account information, wallet balance, and billing dates.

- Internet or other Electronic Network Activity Information: We may collect your web/app browsing history, search history related to the DSC Services, and information regarding your interactions with the DSC Services, including via an application, chat bot, or advertisement.

   - Geolocation Data: We may collect data about the location of the device you use to access the DSC Services, as more fully described below.

   - Professional or Employment-related Information: We may collect information relating to your income level.

   - Education Information: We may collect information relating to your education level. 

   - Inferences: We collect inferences that we draw from the above categories of Personal Information to create a personalized profile so we can better identify goods and services that may be of interest..

Depending on how you interact with us and the DSC Services, we may collect Personal Information from and about you as described below.

Personal Information You Provide To Us

We collect Personal Information from you as follows:   

Personal Information You Provide When You Interact with DSC.  When you engage with us, we may ask you to provide certain Personal Information to obtain or use the DSC Services.  For example, we may ask for Personal Information when you register to create an account; sign up for a membership or subscription; use certain features; access, upload, or download content; enter into sweepstakes or other promotions administered by us (or on our behalf); register or participate in a competition administered by us (or on our behalf); request customer support; report and adverse event or otherwise communicate with us.  

Personal Information You Provide When You Participate in an Online Survey or Other Research. We will collect Personal Information you provide us in connection with your participation in an online survey or a research panel administered by us (or on our behalf).  This may include, but is not 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.

Personal Information You Provide When You Make a Purchase. If you purchase products or services 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.

Personal Information You Provide about a Third Party. You may decide to provide us with another person's information (such as name, email address, physical address, or phone number) so that we may recommend or send products or services to such person, or so that we may facilitate your communication with other people.

Personal Information Collected Automatically

Whenever you visit or interact with the DSC Services online, 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. The types of Personal Information that may be collected and the manner in which such information may be collected are described below.

Usage InformationWe (and our partners and service providers) may use cookies, web beacons, pixel tags, mobile analytics software, log files, or other technologies to collect certain information about your interactions with the DSC Services. This allows us to keep track of analytics and certain statistical information which enables us to improve the DSC Services and provide you with more relevant content and advertising.

The types of information that we (and our partners and service providers) may automatically collect for these purposes include your browser type, mobile device manufacturer, mobile carrier, phone number, operating system, activations, content, products or services you purchase or access, the page served and the preceding page views or websites visited, any mobile device activity and configurations, and email client. We (and our partners and service providers)  may also automatically collect information about your use of the DSC Services, including the date and time you visit the DSC Services, use or click through to any of the DSC Services, the areas or pages of the DSC Services that you visit, the amount of time you spend viewing or using the DSC Services, the number of times you return to the DSC Services, and other click-stream or site usage data.  Additionally, if you receive an email from us, information may be collected about your interactions with the message (e.g., whether you opened, forwarded, or clicked through the Website).

Device Information. We (and our partners and service providers) may automatically collect your IP address or other unique identifier (“Device Identifier”) for the computer, mobile device, tablet, or other device (collectively, “Device”) you use to access the DSC Services as well as the Device  model and mobile network information. We may use a Device Identifier to, among other things, provide the DSC Services; help diagnose problems with our servers; analyze trends; track users’ web page, email, and mobile application movements/activities; help identify or gather broad demographic information for aggregate use; and retarget online and mobile advertisements to you across the computers or devices you may use.

Geolocation Information:We may collect information about the location of your Device when you access or use the DSC Services. In addition, if you choose to turn on your Bluetooth, Wi-Fi, or other geolocation functionality when you use our mobile applications, we may collect and use your geolocation information.

Third Party Service Providers. We may use third party service providers to support the DSC Services.  Some of these service providers may use technologies, such as cookies, web beacons, pixel tags, log files, or other technologies to receive, collect, and store Personal Information on our behalf.

Third Party Services and Technologies. We may use third party services, such as Google Analytics, Adobe Marketing Cloud services, and Meta Conversations API, Pixel, and Custom Audiences 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, on third party platforms and across the Internet. For these purposes, we share certain identifying information about you or your interactions with the DSC Services with these third parties. These third parties may also use technologies, such as cookies, web beacons, pixel tags, log files, Flash cookies, or other technologies to track online activity. They may also combine information they collect from your interaction with the DSC Services with information they collect from other sources. We may not have access to information these third parties collect using cookies or other tracking technologies.

To learn more about your  targeted advertising choices, please see the Your Choices section below.

Personal Information Received from Third Parties

We may obtain information about you from other trusted third party sources. This includes, for example, information from public databases or data aggregators or brokers that may include your demographic information and/or information about your media consumption, previous purchases, shopping habits, loyalty program information, or lifestyle preferences. We may also receive Personal Information about you from our partners and service providers (including, for example, business partners, analytics vendors, advertising networks, and search engine providers).    

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 Personal Information from the social media platform(s) based upon your privacy settings on those platforms. This may include your name, username, demographic information, updated address or contact information, location, interests, and publicly-observed data, such as from social media and other online activity.

We may use information that we receive about you from third-party sources to help us maintain the accuracy of the information we collect, personalize 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, measure the performance of advertisements delivered to you, conduct internal business analysis, and fulfill other business or commercial purposes.

Combination of Personal Information

We may combine the Personal Information we receive from and about you, including Personal Information you provide to us, Personal Information we automatically collect through the DSC Services, and information we collect offline. We may also combine Personal Information collected across the computers or devices that you may use and from third-party sources.  We use, disclose, and protect combined Personal Information as detailed in this Privacy Policy.

  1. HOW WE USE THE PERSONAL INFORMATION COLLECTED

We may use Personal Information for a variety of business and commercial purposes, including:

For Customer Service and Transactional Purposes, such as to:

   - provide you with the DSC Services and access to certain features (where applicable);

   - 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 or our products or services;

   - validate, confirm, verify, deliver, and track your order (including to arrange for shipping, handle returns and refunds, and contact you about your order, 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;

   - process your payments and fulfill your orders;

   - contact you with regard to your use of the DSC Services and, in our discretion, changes to any Dollar Shave Club policy;

   - develop new products or services and enhance current products and services; and

   - protect the security and integrity of the DSC Services and our business, such as by protecting against and preventing fraud, unauthorized transactions, claims, and other liabilities and managing risk exposure, including by identifying potential hackers and other unauthorized users.

For Commercial Purposes, such as to:

   - perform market research, understand the effectiveness of our competition or promotions and DSC Services analytics and operations;

   - provide you with customized content, advertisements, offers, and promotions offered by DSC or on behalf of our partners and affiliates on the DSC Services and/or across third-party services;

   - link or combine with Personal Information we receive from others to help understand your needs, and deliver targeted advertising to you on your computers or other devices, and to provide you with better service; and

  - communicate with you for DSC marketing and promotional purposes (including news and other information we think will be of interest to you) via emails, notifications, or other messages, consistent with any permissions you may have communicated to us.

We may also use Personal Information you provide to us for other purposes that are disclosed to you at the time you provide your Personal Information or otherwise with your consent.

Please note that we may also de-identify or aggregate information so that it will no longer be considered “Personal Information” and use such information for analytics purposes or other purposes consistent with those described in this Privacy Policy.

  1. DISCLOSURE OF PERSONAL INFORMATION  

We may disclose each of the categories of Personal Information we collected from and about you to the following categories of recipients:

  • 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 ProvidersWe may share your Personal Information with third party service providers that provide business, professional, or technical services to us. This includes, but is not limited to, hosting or operating the DSC Services; processing payments; analyzing data; providing customer service; providing postal or delivery services, and administering promotions.
  • Business Partners. We disclose your Personal Information to other companies with whom we partner to provide services or other offerings to you and carry out other related activities. For example, we may disclose your Personal Information to a third party that co-sponsors a sweepstakes or promotion (“Promotion”).
  • Research Partners. We disclose your Personal Information to our research partners, including those that administer surveys or conduct research projects in partnership with us or on our behalf.
  • Analytics Partners. We disclose your Personal Information to our partners that assist us in performing analytics and help us measure the effectiveness of this Website’s content and our marketing and advertising efforts.
  • Marketing and Advertising Partners. We disclose your Personal Information to third parties for marketing and advertising purposes, including social media platforms, third-party advertising networks, and other parties that assist us in serving and optimizing our advertisements.
  • Competent Governmental, Regulatory, and Public Authorities. DSC may transfer and disclose your Personal Information to third parties to comply with a legal obligation; when we believe in good faith that the law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce our Terms of Use  or other applicable policies; to detect and protect against fraud, or any technical or security vulnerabilities; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, users of the DSC Services, DSC, or the public.
  • Relevant Third Parties as Part of a Corporate Transaction. In the event that another entity acquires us or all or substantially all of our assets, or assets related to the DSC Services, your Personal 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 reorganization proceeding is brought by or against us, all such Personal Information may be considered an asset of ours and as such may be sold or transferred to third parties. Finally, Personal 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.
  • Other Third PartiesYour 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 Personal Information may also be shared with third parties we identify at the time you provide your Personal Information or otherwise with your consent.

We may disclose your Personal Information for other reasons that we will describe at the time of information collection or prior to disclosing your information.

Depending on your U.S. state residency, some of the disclosures described above constitute “sales” of Personal Information under applicable law. Details on how to exercise your legal rights with respect to such “sales” can be found in the “Your Privacy Rights” section below.

Please note that we may also share aggregate or anonymous (de-identified) information with third parties for their marketing or analytics uses. Such information does not contain Personal Information

  1. YOUR CHOICES

Cookies

Your browser may give you the ability to control cookies or other similar technologies or to reject cookies. Please refer to your browser’s “Help” section for more information on how to delete or reject cookies and/or control your tracking preferences.

Please note that because the options you select relating to cookies and other similar technologies are browser and device specific, you must exercise your choices on each browser and device you use.

Opt Out of Interest-Based Advertising

We, or other parties we do business with, may place or recognize unique cookies or other similar technologies on your browser when you visit the online DSC Services to collect information about your use of the DSC Services and your other online activities over time and across different websites and apps, and such information may be used to serve interest-based advertisements to you as you browse the Internet.

You may be able to opt out of receiving interest-based advertisements using the browser opt-out tools and consumer choice mechanisms provided by interest-based advertising self-regulatory groups by following the links below:

- If you reside in the United States, to opt out of interest-based advertising by the Digital Advertising Alliance (DAA) participating companies, please visit http://www.aboutads.info/choices/.

- If you reside in the United States, to opt out of interest-based advertising by NAI member companies, visit: http://www.networkadvertising.org/choices/.

- If you reside in Europe, to opt out of interest-based advertising by the European Interactive Digital Advertising Alliance (EDAA) participating companies, please visit https://youronlinechoices.eu/.

- If you reside in Canada, to opt out of interest-based advertising by Digital Advertising Alliance of Canada (DAAC) participating companies, please visit https://optout.aboutads.info/?c=3&lang=en

You will need to opt out separately on all of your browsers and devices, as each opt-out will apply only to the specific browser or device from which you opt out. If you delete or reset your cookies or mobile identifiers, change browsers, or use a different device, any opt-out cookie or tool may no longer work and you will have to opt out again.

You also have the ability to control whether you see interest-based advertisements on your mobile device in the following ways:

  • Your device operating system may provide mechanisms that allow you to opt in or opt out of the use of data about your usage of mobile apps to deliver interest-based advertising to your mobile device. For more information, consult your device settings.
  • The DAA offers a tool for opting out of the collection of cross-app data on a mobile device for interest-based advertising. To exercise your choices with respect to participating companies, please download the AppChoices tool here.

Please note that even if you choose to opt out of receiving interest-based advertising, you may still receive advertising, but the advertisements may be less relevant.

Some of our partners may provide you with additional choices with respect to interest-based advertising. For example, certain social media platforms allow you to control your advertising preferences directly through their services. Please review the privacy policies of the third-party services you use for more information.

If you reside in the United States, depending on your state residency, you may have additional choices with respect to our use and disclosure of your Personal Information for interest-based advertising purposes. Details on how to exercise your legal rights can be found in “Your Privacy Rights” below.

Access and Updates to Your Personal Information

If you wish to verify, correct, or update any of your Personal Information in your DSC account, you may visit your Account Page or contact us at the postal address or e-mail address in the Contact Us section below. California, Colorado, Connecticut, Utah, and Virginia residents may exercise their rights to access or delete Personal Information according to the instructions in the “Your Privacy Rights” section below.

Unsubscribe from Marketing and Promotional Communications

We provide you with the opportunity to opt out of receiving marketing and promotional communications from us at any time. To opt out of such communications, you may:  

Send us an e-mail at [email protected]

Write to us at Dollar Shave Club, 13335 Maxella Ave, Marina del Rey, CA 90292, or

- Follow the instructions contained within any marketing or promotional email you receive from us.

Note that even if you opt out of receiving marketing and promotional communications from us, you will still receive non-marketing or transactional messages from us, including messages about your account and responses to your inquiries/requests.

  1. YOUR PRIVACY RIGHTS:

Explanation of Applicable Privacy Rights

Depending on your U.S. state of residence, you may have certain rights in relation to your Personal Information, as described below:

  • Right of Access:  
    • You may ask us to confirm whether we are processing your Personal Information and, if so, details regarding our processing of the Personal Information.
    • You may also request that we provide your Personal Information in a portable and, to the extent technically feasible, readily usable format.
  • Right to Delete: Subject to certain exceptions, you may request that we delete your Personal Information. There are some reasons we will not be able to fully address your request, such as if we need to complete a transaction for you, to detect and protect against fraudulent and illegal activity, to exercise our rights, for our internal purposes, or to comply with a legal obligation.
  • Right to Correct:  Subject to certain exceptions, you may request that we correct inaccuracies in your Personal Information, subject to appropriate verification. We will take commercially reasonable efforts to make the corrections that you request.
  • Right to Opt-Out of the Sale or Sharing of Personal Information:You have the right to opt-out of the “sale” or “sharing” of your Personal Information, as such terms are defined in California privacy laws.  This means that, if you opt out, going forward, we will not sell or share your Personal Information with such third parties to use for their purposes, including cross-context behavioral advertising (as defined by California law), unless you later direct us to do so.                                                                                          


    If you are a resident of Connecticut, Colorado, Utah, or Virginia, you may take advantage of certain privacy rights, such as to request access, correction, deletion, or a copy of your Personal Information.  Because we may “sell” Personal Information as such term is defined in Connecticut and Colorado laws, or engage in “targeted advertising” as such term is defined in Connecticut, Colorado, Utah, and Virginia laws, you may also exercise your right to opt-out of such sales or targeted advertising where available.  You have the right to appeal a denial of your privacy rights.
  • Right to Revoke Consent: We may seek your affirmative consent to process your Personal Information for certain purposes. Where applicable, you may revoke your consent at any time.
  • Right to Limit Certain Processing Activities or to Object to Certain Processing Activities: Where we have not sought your affirmative consent to process your Personal Information, you may have the right to limit or object to our continued processing of that Personal Information

Where applicable, you also have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

If you exercise any of the foregoing rights, we will not discriminate against you, including by denying access to our products or services or restricting your access to products or services of a certain quality or price level.

How to Submit a Request

To take advantage of your right to know, delete, correct, or portability under California, Colorado, Connecticut, Utah, or Virginia law, or to submit an appeal of a denial of your privacy rights, please head to https://us.dollarshaveclub.com/?ketch_show=preferences. You may also contact us by email at [email protected], or by mail at Attn: Member Services/Privacy Officer, 13335 Maxella Ave, Marina del Rey, CA 90292.  We may request certain information about your interactions with DSC to verify your identity before we can respond to your access, deletion, correction, or portability requests.  DSC will confirm receipt of your request within 10 business days and will respond to your request within 45 calendar days, after proper verification, unless we need additional time, in which case we will let you know.

To take advantage of your right to opt out of the sale or sharing of Personal Information or to opt out of targeted advertising, please click on the Do Not Sell or Share My Personal Information link which also is on our website footer or email us at [email protected]. We will work to comply with your opt-out request within 15 business days. 

Submitting an opt-out request does not require you to create an account with us.

Alternatively, if you are a California resident, where available, you can use certain preference signals to exercise your sale and sharing opt-out right automatically with all businesses that you interact with online, including DSC Services. If you are a browser-based opt-out preference signal that complies with the CCPA, such as the Global Privacy Control (GPC), upon receipt or detection, we will treat the signal as a valid request to opt out of the sale or sharing of Personal Information linked to that browser and any consumer profile we have associated with that browser. Please note that if you use different browsers or browser profiles, you will have to enable the signal on each one that you use.

We value your privacy and will not discriminate in response to your exercise of your privacy rights.

Agent Requests

You may authorize someone to make a privacy rights request on your behalf (an authorized agent). Authorized agents will need to demonstrate that you’ve authorized them to act on your behalf or must demonstrate they have power of attorney pursuant to applicable probate law. DSC retains the right to request confirmation directly from you confirming that the agent is authorized to make such a request, or to request additional information to confirm the agent’s identity. An authorized agent is prohibited from using a consumer’s Personal Information, or any information collected from or about the consumer, for any purpose other than to fulfill the consumer’s requests, for verification, or for fraud prevention.

California Privacy Rights

The California Consumer Privacy Act (CCPA) provides California residents with certain rights in relation to their Personal Information. Pursuant to the CCPA, we are providing the following additional details regarding the categories of Personal Information that we collect, use, and disclose. This section also describes the rights available to you in relation to your Personal Information and how you can exercise your rights. 

Personal Information Collection and Disclosure

The following chart details which categories of Personal Information we have collected from and about California residents in the past twelve (12) months, the source(s) of each category of information, the categories of third parties to whom we have disclosed each category of information for a business purpose, and the categories of third parties to whom we have “sold” or with whom we have “shared” each category of information (as such terms are defined in the CCPA) (where applicable). Please note that the first column in the chart lists by category the types of information described in the “Information We Collect” section above, as required by the CCPA.

Category of
 Personal Information

Categories
 of Sources

Disclosures of Personal Information for a
 Business Purpose

Sale or Sharing of
 Personal Information

Identifiers, including your name, postal and email address, IP address, username, unique identifiers, or other similar identifiers.

Directly from consumers

 

Through automated means

 

Third-party sources

 

We have disclosed this category of information for a business purpose in the past 12 months to the following categories of third parties:

·  Our Service Providers

·  Our Business Partners

·  Our Research Partners

·  Our Analytics Partners 

We have sold or shared this category of information in the past 12 months to or with the following categories of third parties:

·  Business Partners

·  Analytics Partners

·  Marketing and Advertising Partners (including Media Partners, social media companies)

Personal information categories listed in the California Customer Records statute, including email address.

Directly from consumers

 

We have disclosed this category of information for a business purpose in the past 12 months to the following categories of third parties:

·  Our Service Providers

·  Our Business Partners

·  Our Research Partners

·  Our Analytics Partners 

 We have sold or shared this category of information in the past 12 months to or with the following categories of third parties:

·           Business Partners

·           Analytics Partners

·           Marketing and Advertising Partners (including Media Partners, social media companies)

Protected classification characteristics under California or federal law, including your gender, age, and parental status.

Directly from consumers

 

We have disclosed this category of information for a business purpose in the past 12 months to the following categories of third parties:

·  Our Service Providers

·  Our Business Partners

·  Our Research Partners

·  Our Analytics Partners

N/A

Commercial information, including your purchase and usage history, goods and services preferences, payment and account information, wallet balance, and billing dates.

Directly from consumers

 

Through automated means

 

We have disclosed this category of information for a business purpose in the past 12 months to the following categories of third parties:

·  Our Service Providers

·  Our Business Partners

·  Our Research Partners

·  Our Analytics Partners

We have sold or shared this category of information in the past 12 months to or with the following categories of third parties:

·  Business Partners

·  Analytics Partners

·  Marketing and Advertising Partners (including Media Partners, social media companies)

Internet or other electronic network activity information, including your web/app browsing history, search history related to the DSC Services, and information regarding your interactions with the DSC Services, including via an application, chat bot, or advertisement.

Directly from consumers

 

Through automated means

 

 

We have disclosed this category of information for a business purpose in the past 12 months to the following categories of third parties:

·  Our Service Providers

·  Our Business Partners

·  Our Research Partners

·  Our Analytics Partners

 

We have sold or shared this category of information in the past 12 months to or with the following categories of third parties:

·  Business Partners

·  Analytics Partners

·  Marketing and Advertising Partners (including Media Partners, social media companies)

Geolocation data, including the location of the device you use to access the DSC Services.

Directly from consumers

 

Through automated means

 

 

N/A

 

N/A

Professional or employment-related information, including information relating to your income level.

Third-party sources

 

N/A

N/A

Education information, including information relating to your education level

Third-party sources

 

N/A

N/A

Inferences, meaning inferences that we draw from the above categories of Personal Information to create a personalized profile so we can better identify goods and services that may be of interest to you.

Directly from consumers

 

Through automated means

 

Third-party sources

 

N/A

N/A

Sensitive Personal Information, including your account log-in information in combination with the password allowing access to your account, your racial or ethnic origin.

Directly from consumers

 

Through automated means

 

Third-party sources

 

N/A

N/A


Purposes for Collecting Personal Information

As described in more detail in the “Information Use” section above, we collect Personal Information to provide and manage the Services, fulfill our contractual obligations to you, and achieve a variety of legitimate business or commercial purposes.

Disclosures of Personal Information

As detailed in the “Information Disclosure” section above, we disclose Personal Information to fulfill the purposes described above. We will also disclose certain categories of Personal Information to competent governmental and public authorities and other third parties as necessary or appropriate, including when we have a legal or contractual obligation to disclose the information.

Sale and Sharing of Personal Information

As detailed in the chart above, we “sell” and “share” (as such terms are defined in the CCPA) certain categories of Personal Information to and with third parties and have “sold” and “shared” certain categories of Personal Information in the past twelve (12) months for analytics and advertising purposes. Please refer to the chart above for additional details.

We do not “sell” or “share” the Personal Information of individuals we know to be under 16 years of age.

Your California Legal Rights

You have the right to request that we:

  • Disclose to you the following information covering the twelve (12) months preceding your request:
    • the categories of Personal Information we have collected about you and the categories of sources from which we collected such information;
    • the specific pieces of Personal Information we have collected about you;
    • the business or commercial purposes for collecting, selling, or sharing your Personal Information;
    • the categories of third parties to whom we disclosed such Personal Information; and
    • if we sold, shared, or disclosed your Personal Information for a business purpose, two separate lists disclosing:
      • sales and shares, identifying the Personal Information categories that each category of receipt received; and
      • disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
  • Delete the Personal Information that we have collected from you, subject to certain exceptions.
  • Correct inaccurate Personal Information that we maintain about you, taking into account the nature of the Personal Information and the purposes of the processing.

We will not discriminate against you if you decide to exercise your rights under the CCPA.

If you are interested in exercising any of the above-listed rights, please head to https://us.dollarshaveclub.com/?ketch_show=preferences. You may also contact us by email at [email protected], or by mail at Attn: Member Services/Privacy Officer, 13335 Maxella Ave, Marina del Rey, CA 90292.  

To protect your privacy, we may require the matching of up to three pieces of Personal Information provided with your request with information we maintain to verify that it is you making the request. Where applicable, we will use the requested information for verification purposes only. Please note that we may decline a request where we are unable to verify your identity and confirm the Personal Information we maintain relates to you.

You may authorize someone to submit a privacy rights request on your behalf (an “authorized agent”). An authorized agent will need to demonstrate that you’ve authorized them to act on your behalf, unless you have provided the agent with power of attorney pursuant to applicable probate law. Depending on the evidence provided, we may also contact you to verify your identity with us or request confirmation from you that the agent is authorized to submit the request on your behalf.

Exercising Your Sale and Sharing Opt-Out Right

As detailed in the chart above, we “sell” and “share” certain categories of Personal Information to and with third parties. If you are 16 years of age or older, in addition to the rights described above, you have the right to direct us to not “sell” or “share” your Personal Information at any time. To exercise your opt-out right, you may submit a request to us by clicking on the Do Not Sell or Share My Personal Information link at the bottom of any of the Sites’ web pages and follow the instructions. Additionally, if you would like to opt out of the “selling” or “sharing” of your Personal Information via the cookies and other technologies present on the Sites, you can do so by visiting the cookie preferences in your browser or device. You can learn more about cookies in the “Your Choices” section. 

Upon receipt of your request, we will endeavor to honor it based on the information that we collect and maintain.

Alternatively, where available, you can use certain preference signals to exercise your sale and sharing opt-out right automatically with all businesses that you interact with online, including DSC. If you enable a browser-based opt-out preference signal that complies with the CCPA, such as Global Privacy Control (GPC), upon receipt or detection, we will treat the signal as a valid request to opt out of the sale or sharing of Personal Information linked to that browser and any consumer profile we have associated with that browser. Please note that if you use different browsers or browser profiles, you will have to enable the signal on each one that you use.

An authorized agent may also use the methods described above to submit a request to opt out on your behalf if you provide the agent with signed permission to do so. Please note that we may request from the agent documentation demonstrating that they have your authority to act on your behalf.

  1. ADDITIONAL INFORMATION FOR EEA, UK, AND SWITZERLAND RESIDENTS

Legal Basis for Processing

Applicable law in certain jurisdictions requires us to set out the “legal basis” that we rely on to collect and use your Personal Information. Where applicable, the legal bases upon which we rely in order to collect and use your personal information can be found below:

Australia: https://au-help.dollarshaveclub.com/en-US/privacy-policy-205785 

Canada: https://ca-help.dollarshaveclub.com/en-US/privacy-policy-205648

United Kingdom: https://uk-help.dollarshaveclub.com/en-US/privacy-policy-207391

At any time, you may subject a request to exercise the above-listed rights by emailing us at [email protected]. In order to protect your privacy, we may need to request specific information from you to help us confirm your identity. Where applicable, we will use the requested information for verification purposes only  

  1. CHILDREN'S PRIVACY 

Protecting children’s privacy is important to us. 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 child under the age of sixteen has provided Personal Information through the DSC Services, we will use reasonable efforts to remove such information from our files.

  1. SECURITY OF YOUR PERSONAL INFORMATION 

We use certain reasonable security measures to help protect your Personal Information. However, because 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, as detailed in this Privacy Policy, 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.

 

  1. INFORMATION RETENTION

We will retain your Personal Information as long as necessary to fulfill the purposes outlined in this Privacy Policy, including to satisfy our legal or reporting requirements, unless a longer retention period is required or allowed under law.

To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of Personal Information; the potential risk of harm from unauthorized use or disclosure of the Personal Information; the purpose for which we use the Personal Information; whether we can achieve the purposes through other means; and the applicable legal requirements.

If we de-identify information, we will maintain and use the information in de-identified form and not attempt to re-identify the information except as required or permitted by law.


10. NOTICE OF FINANCIAL INCENTIVE 

We may offer financial incentives to promote our products and services. These may include:

  • Razor Rewards, where you earn points for certain actions or purchases. You will receive perks for such point earnings, including, but not limited to:
    • Shipping benefits 
    • Early access to new products 
    • Invites to IRL events
    • Testing new products before launch 
    • Enhanced customer service

We may ask you to provide Personal Information in connection with these promotions, including the following Personal Information: your name, birthday, contact information (such as email address and telephone number), and zip code. Because these promotions involve the collection of Personal Information, they may be interpreted as “financial incentive” programs under California law or “bona fide loyalty programs” under Colorado law. We use this information for the purposes described above under the section titled “HOW WE USE THE PERSONAL INFORMATION COLLECTED,” including for targeted advertising. We may share your Personal Information with third parties as described in our “DISCLOSURE OF PERSONAL INFORMATION” section, including data analytics providers, advertising technology vendors, and social media platforms. 

Participation in any financial incentive is optional. To enroll, please click here https://us.dollarshaveclub.com/pages/rewards.You may withdraw from the program at any time by emailing [email protected]. If you ask us to delete your Personal Information, we will not be able to provide you with access to these programs.

The value of any financial incentive we offer is reasonably related to the value of any Personal Information you provide to us. We estimate the value of your Personal Information by considering, without limitation, the expenses we incur from collecting your Personal Information and/or providing the financial incentive to you, the revenue generated by your use of the financial incentive, and any improvements we can make to our products and services based on aggregating information obtained through the financial incentive program.

Please note that we may provide additional terms that apply to a particular financial incentive. If applicable, those terms will be presented to you at sign up.


11. OTHER SITES 


The DSC Services may contain links to other sites that we do not own or operate. This includes links from service providers, fulfillment companies, advertisers, sponsors, or other business partners that may use our logo(s) as part of a co-branding agreement. We are not responsible for these sites or their content, products, services, or privacy policies or practices. These other sites may place their own cookies on your Device and independently collect or solicit Personal Information from you. We encourage you to review the privacy policies of any third parties with which you engage. You should also assess the authenticity of any site which appears or claims that it is one of the DSC Services (including those linked to through an email or social networking page).


12. INTERNATIONAL TRANSFERS


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, including the United States. As a result, your Personal Information may be subject to data protection and other laws that differ from those in your country of residence. Additionally, your Personal Information may be disclosed in response to inquiries or requests from government authorities or to respond to judicial process in the countries in which we operate. By using the DSC Services, or by providing us with any Personal Information, you are acknowledging that such information may be transferred to the United States and other jurisdictions in which we operate. Where applicable, we will ensure that appropriate safeguards are in place to protect your Personal Information

If you are located in the European Economic Area, Switzerland, or the United Kingdom, please note that we may need to transfer your Personal Information to countries that have not been recognized as providing an adequate level of data protection. We generally use EU Standard Contractual Clauses (or other government-approved contracts) or other lawful data transfer mechanisms that provide appropriate safeguards for Personal Information that is transferred to countries that have not been recognized as providing an adequate level of protection. To learn more about the cross-border transfer of your Personal Information or the transfer mechanism we use to lawfully carry out such transfers, you can contact us as set forth in the “Contact Information” section below.

13.  CHANGES TO THIS PRIVACY POLICY

Any changes we may make to this Privacy Policy will be posted on this page. Please check back frequently to see any updates or changes to this Privacy Policy. If you do not agree or consent to these updates or changes, do not continue to use the DSC Services. If we make a material change to this Privacy Policy, we will provide appropriate notice to you. 


14. CONTACT US 

If you have any questions or concerns regarding this Privacy Policy or our information handling and privacy practices, please contact us at:

Attn:  Member Services/Privacy Officer
 Address: 13335 Maxella Ave, Marina del Rey, CA 90292   
 Re: DOLLAR SHAVE CLUB PRIVACY POLICY

E-Mail: [email protected] or [email protected].

Alternatively, please go to www.dollarshaveclub.com, and click on the Contact Us link

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