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Privacy Policy

Last updated:  May 13, 2020

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), 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 how information may be used, disclosed, or collected through the DSC Services, 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, 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.

 

QUICK GUIDE TO CONTENTS 

  1. PERSONAL INFORMATION COLLECTION
  2. HOW WE USE THE PERSONAL INFORMATION COLLECTED 
  3. SHARING OF PERSONAL INFORMATION 
  4. YOUR CHOICES AND OPT-OUT
  5. CHILDREN'S PRIVACY 
  6. SECURITY OF YOUR PERSONAL INFORMATION 
  7. OTHER SITES 
  8. CONSENT TO PROCESSING & INTERNATIONAL TRANSFERS 
  9. CHANGES & OTHER DSC PRIVACY POLICIES 
  10. CONTACT US 

 

1. PERSONAL INFORMATION COLLECTION

When information identifies or 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.” This Personal Information includes the following categories: 

   - Identifiers/Contact Information: These include your name, age, postal and email address, phone   number, username, encrypted password, and unique identifiers that may identify your device or   browser but not you by name.

   - Protected Classifications: Your gender and parental status.

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

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

   - Internet/Electronic Activity: Your IP address, web/app browsing and search history related to our   Services, and information regarding your interaction(s) with the Services or DSC advertising.

   - Education and Professional Information: Education level and income level.

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

As provided in more detail below, we collect Personal Information from a variety of sources, including from:

   - Internet service providers

   - Data analytics providers

   - Operating systems and platforms

   - Social networks

   - Data Aggregators, and

   - From you directly

Personal Information You Provide To Us

When you use the DSC Services, we may ask you to provide certain Personal Information to obtain our products or use our services.  For example, we may ask for Personal Information when you register to create an account, update your Personal 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 Personal Information that relates to yousuch as your name, e-mail address, telephone number, mailing address, date of birth, gender, and demographic information.     

Personal Information You Provide When You Participate in an Online Survey or Other Research.  We may also collect Personal 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. 

Personal 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.

Personal Information You Provide about a Third Party. You may decide to provide us with another person's information (such as name, email, 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. Local law may require you to seek the consent of your contacts to provide their Personal Information to DSC (or in connection with using the DSC Services), which may in turn use that information in accordance with the terms of this Privacy Policy. Where required by law, we will obtain the required consent from the person whose information you provided to us.

Personal 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 Personal 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.

Personal 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. This Personal Information may be collected in the following ways:

Usage Information: We may use cookies, web beacons, pixel tags, mobile analytics software, log files, or other technologies to collect certain information about your online activity, and interactions with our emails, online and mobile advertisements, and to allow us to keep track of analytics and certain statistical information which enables DSC to improve the DSC Services and provide you with more relevant content and advertising offered by DSC, or through or linked from the DSC Services.

For example, we may automatically collect certain information from you, including 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 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, other click-stream or site usage data, emails that you open, forward or click-through to our DSC Services, and other sites that you may visit.

Device Information. We 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, including the hardware 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 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 technology such as cookies, web beacons, pixel tags, log files, or other technologies to receive, collect, and store Personal Information on our behalf.

Third Party Analytic Technologies. We may use third parties’ analytics and tracking tools, such as Google Analytics, Adobe Marketing Cloud services, Facebook Custom Audience 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. These tools may use technology 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 do not have access to, or control over, these third parties’ use of cookies or other tracking technologies.

To learn more about your advertising choices relating to the collection and use of your information, please see the Your Choices section below.

Personal Information Received from Other Third Parties

We may obtain information about you from other trusted third party sources to update or supplement your Personal Information. This includes, for example, information from public databases or data aggregators or brokers that may include your demographic information, 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 information providers).  

We may use this information 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, to measure ad quality and responses, and for internal business purposes.

Combination of Personal Information

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

 

 2. HOW WE USE THE PERSONAL INFORMATION COLLECTED

We may use the Personal Information about you for a variety of business purposes, including for example:

 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;

   - to use and disclose your credit, debit, or payment card or other financial information to process payments and prevent fraud;

   - 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 to enhance current products and services; and

   - protect the security or 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, and provide news and other information we think will be of interest to you on or outside of the DSC Services, in emails and across third-party websites;

   - link or combine with Personal 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; and

  - communicate with you, either directly or through one of our partners (e.g., through Facebook Custom Audience, Google Customer Match, Twitter Match, etc.) for DSC marketing and promotional purposes 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 as disclosed at the time you provide your Personal Information or otherwise with your consent.

 

 3. SHARING OF PERSONAL INFORMATION 

The Personal Information collected or generated through your use of the DSC Services may be shared by you or by us as described below.    

Sharing of Personal 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.

Sharing of Personal Information by Us

We may share the Personal Information collected from or about you for the following business purposes:

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 support functions on our behalf. This includes, but may not be limited to, service providers that host or operate the DSC Services; process payment; analyze data; provide customer service; provide postal or delivery services, and administer or participate in any promotions.

Sweepstakes, Contests, and Promotions. If you choose to enter into one of our sweepstakes, contests, or other promotions (a “Promotion”) we may disclose your Personal 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 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.

Legal Disclosures; Safety. 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.

Aggregate or Anonymous Non-Personal Information. 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. We may also share your information for the following limited commercial marketing purposes:

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 Personal Information may also be shared with third parties we identify at the time you provide your Personal Information or otherwise with your consent.

 

 4. YOUR CHOICES AND OPT-OUT

Certain parts of the DSC Services require cookies. You are free to set your browser or operating system settings to limit certain tracking or to decline cookies, but by doing so, you may not be able to use certain features through the DSC Services or take full advantage of all of our offerings. Please refer to your Web browser’s or operating system’s website or “Help” section for more information on how to delete and/or disable your browser or operating system from receiving cookies or controlling your tracking preferences. On your mobile device, you may also adjust your privacy and advertising settings to control whether you want to receive more relevant advertising.

Our system may not respond to Do Not Track requests or headers from some or all browsers. We may use cookies or other technologies to deliver more relevant advertising and to link data collected across other computers or devices that you may use.  

We, or other parties we do business with, may place or recognize unique cookies or other technologies on your browser when you visit the 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 may use that information to serve interest-based advertisements to you as you browse the Internet. To learn more about such interest-based advertising, please review the information below:

- To opt-out of such collection and use for online behavioral advertising by the Digital Advertising Alliance (DAA) participating companies in the United States, please visit: http://www.aboutads.info/choices/; DAA AppChoices http://www.aboutads.info/appchoices/.  

- To opt-out from the use of information about your online activities for online behavioral advertising by NAI member companies, visit: http://www.networkadvertising.org/choices/. Please note that even if you opt-out, you may still receive advertisements from DSC that are not customized based on your Usage Information. 

- To learn how to manage privacy and storage settings for Flash cookies, please visit: https://www.adobe.com/support/documentation/en/flashplayer/help/settings_manager.html

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 address or e-mail in the Contact Us section below. California residents may exercise their rights to access or delete Personal Information according to the instructions in the “Your California Privacy Rights” Section below.

Unsubscribing from Communications by Us:

We provide our customers with the opportunity to opt-out of having their Personal Information used for purposes not directly related to placement, processing, fulfillment, or delivery of a product order or servicing of your product. To opt-out of marketing communications, you may:  

- Send us an e-mail at members@dollarshaveclub.com,  

- Contact us by mail at Dollar Shave Club, 13335 Maxella Ave, Marina del Rey, CA 90292, or

- Unsubscribe from our marketing email communications at any time by unsubscribing or following the instructions contained within the email.

 

Your California Privacy Rights:

Categories of Personal Information Sold

In the last 12 months, DSC has sold the following categories of Personal Information:

   - Identifiers/Contact information, sold to Media Partners and Influencers; and

   - Internet/Electronic Activity, sold to sold to Media Partners and Influencers.

We do not knowingly sell Personal Information about persons under the age of 16.

Categories of Personal Information Disclosed

In the last 12 months, DSC has disclosed the following categories of Personal Information for a business purpose (such as with our service providers who are restricted from using your Personal Information outside the scope of their services for DSC):

   - Identifiers/Contact Information, disclosed to Billing Service Providers, Email/SMS Service Providers, Customer Service and Intelligence Platforms, Network Security and Fraud Protection Services, Campaign Optimization Service Providers, and Cloud Data Storage Providers;

   - Protected Classification Information, disclosed to Billing Service Providers, Email/SMS Service Providers, Customer Service and Intelligence Platforms, Network Security and Fraud Protection Services, and Cloud Data Storage Providers;

   - Commercial Information, disclosed to Billing Service Providers, Email/SMS Service Providers, Customer Service and Intelligence Platforms, Network Security and Fraud Protection Services, Campaign Optimization Service Providers, and Cloud Data Storage Providers;

   - Internet/Electronic Activity, disclosed to Billing Service Providers, Email/SMS Service Providers, Customer Service and Intelligence Platforms, Network Security and Fraud Protection Services, Campaign Optimization Service Providers, and Cloud Data Storage Providers;

   - Geolocation, disclosed to Billing Service Providers, Email/SMS Service Providers, Customer Service and Intelligence Platforms, Network Security and Fraud Protection Services, and Cloud Data Storage Providers; and

   - Inferences, disclosed to Billing Service Providers, Email/SMS Service Providers, Customer Service and Intelligence Platforms, Network Security and Fraud Protection Services, and Cloud Data Storage Providers.

Access and Deletion Requests

California residents have the right to know what Personal Information that DSC collected, disclosed, and sold about them.  In particular, they may:

Request, up to two times each year, that we disclose to you:

   - the categories and specific pieces of Personal Information that we collected about you in the preceding 12 months, the business purpose for such collection, and corresponding categories of sources from which we collected the information,

   - the categories of Personal Information, and the categories of third parties to whom we disclosed your Personal Information in the preceding 12 months, and the business or commercial purpose for such disclosure,

   - the categories of Personal Information and the categories of third parties to whom we sold your Personal Information in the preceding 12 months, and the commercial purpose for such sale.

Request that we delete any Personal Information that we have collected from or about you.  Note that 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.

To take advantage of these rights, please contact us at by email at ccpa.compliance@dollarshaveclub.com, by phone at 1-833-371-0353, or by mail at Attn: Member Services/Privacy Officer, 13335 Maxella Ave, Marina del Rey, CA 90292.  We may request certain information to verify your identity before we can respond to your access and deletion requests.  We value your privacy and will not discriminate in response to your exercise of your privacy rights. 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.

Opt-Out Requests

You also may request to opt out of DSC’s sale of your Personal Information to third parties, and to our affiliated companies that do not share the same brand name, for their commercial use. This means that, if you opt out, going forward, we will not share your Personal Information with such third parties to use for their purposes unless you later direct us to do so. To effect the opt out, please click on the Do Not Sell My Info link which also is on our website footer. We will comply with your opt-out request within 15 business days.

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, and that they are registered with the California Secretary of State to conduct business in California, 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. 

 

5. 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.

 

 6. SECURITY OF YOUR 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, 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.

 

 7. 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 web sites may send their own cookies to your Device, they may independently collect data or solicit Personal Information and may or may not have their own published privacy policies. You should also independently 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).

 8. CONSENT TO PROCESSING & 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 may differ from your country of residence. 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 information, you consent to the collection, processing, maintenance and transfer of such information in and to the United States and other applicable territories in which the privacy laws may not be as comprehensive as, or equivalent to, those in the country where you reside and/or are a citizen.

 

 9. CHANGES & OTHER DSC PRIVACY POLICIES 

 

Any changes we may make to our Privacy Policy will be posted on this page. Please check back frequently to see any updates or changes to our 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.

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. 

 

10. CONTACT US  

If you have any questions or concerns regarding this Privacy Policy, 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: members@dollarshaveclub.com or ccpa.compliance@dollarshaveclub.com.

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

 

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