Effective Date: January 4, 2022
This policy applies to personal information about individuals and does not apply to the information collected, used or disclosed with respect to corporate or commercial entities. This policy does not impose any limits on our collection, use or disclosure of the information exempted under applicable privacy legislation, such as business contact information and certain publicly-available information.
QUICK GUIDE TO CONTENTS
2. HOW WE USE THE INFORMATION COLLECTED
6. SECURITY OF YOUR INFORMATION
7. OTHER SITES
8. CONSENT TO PROCESSING & INTERNATIONAL TRANSFERS
9. CHANGES & OTHER DSC PRIVACY POLICIES
10. CONTACT US
- INFORMATION COLLECTION
There are several ways we may obtain information about you:
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, phone number, mailing address, date of birth, gender, demographic information, and other information you may provide to us.
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 behavioural 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 have 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.
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 information may be collected in the following ways:
For example, we may automatically or passively collect certain non-personal information from you, including your browser type, mobile device manufacturer, mobile carrier, phone number, operating system, email client, activations, content, products or services you purchase or access, the page served and the preceding page views or websites visited, and any mobile device activity and configurations. We may also automatically collect information about your use of the DSC Services, including the date and time you visit the DSC Services or 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 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 information on our behalf.
Third-Party Analytic Technologies. We may use third parties’ analytics and tracking tools, such as Google Analytics, Adobe Marketing Cloud, Facebook Custom Audience 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 collect and store non-personal information. 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 advertising choices relating to the collection and use of your information, please see the Your Choices section below.
Information Received from Other Third Parties
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, information from public databases or data aggregators that may include your demographic information, media consumption, previous purchases, shopping habits, loyalty program information or lifestyle preferences. We may also receive 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, measure ad quality and responses, and for internal business analysis or other business purposes.
Combination of Information
- HOW WE USE THE INFORMATION COLLECTED
We may use the 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 orders (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 only 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;
- 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; and
- for other purposes as disclosed at the time you provide your personal information or otherwise with your consent.
For Advertising Customization and Analytics Purposes, such as to:
- perform market research, understand the effectiveness of our competition or promotions and DSC Services analytics and operations;
- personalize 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);
- provide you with localized or 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 the DSC Services, in emails and across third-party websites;
- link or combine your information 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; 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.
- SHARING OF INFORMATION
DSC or you may share the information collected or generated through your use of the DSC Services as described below.
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, participating 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. In light of this, please be careful when sharing such information in connection with using the DSC Services.
Sharing of Information by Us
We may share the information collected from or about you in the following ways:
With Our Affiliates. We may share your information with our subsidiaries and affiliated companies for internal reasons, primarily for business and operational purposes, and to fulfill the other purposes listed in section 2 above.
Third-Party Service Providers. We may share your 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 payments; analyze data; provide customer service; provide postal or delivery services, along with sponsors or other third parties that participate in or administer any promotions.
Other Third Parties. We may also share your information 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 along with product information. We may also share your information with third parties we identify at the time you provide your personal information or otherwise with your consent.
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, we may disclose your information to such entity as part of the due diligence process and transfer your information to such entity as one of the transferred assets. Also, if any bankruptcy or reorganization proceeding is brought by or against us, we may consider all such information an asset of ours and as such we may sell or transfer such information to third parties. Finally, we may also disclose the information described in this paragraph for due diligence purposes in connection with any proposed transaction described in this paragraph.
Aggregate or Anonymous Non-Personal Information. We may also share aggregate or anonymous non-personal information with third parties for their marketing or analytics uses.
- YOUR CHOICES AND OPT-OUT
Cookies, Tracking Options and Do Not Track Disclosures:
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, and to opt out of such collection and use for online behavioural advertising by United States companies that participate in the Digital Advertising Alliance (DAA), please visit: http://www.aboutads.info/choices/ and/or DAA AppChoices – http://www.aboutads.info/appchoices/. To opt out from the use of information about your online activities for online behavioural 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.
You may also 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 of 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.
Access and Updates to Your Information:
If you wish to verify, correct, or update any of your personal information, you may visit your Account Page or contact us at the address or e-mail in the “Contact Us” section below.
Unsubscribing from Non-Essential Purposes:
You may withdraw your consent to our collections, uses and disclosures of your personal information at any time, subject to legal, contractual and other restrictions, provided that you give us reasonable notice. When we receive your notice to withdraw of consent, we will inform you of the likely consequences of your consent withdrawal, which may include our inability to provide you with certain services that require that information.
- Send us an e-mail at [email protected],
- Contact our Club Pros or Privacy Officer by mail at Dollar Shave Club, P.O. Box 5688, Santa Monica, CA 90409, or
- Unsubscribe from our marketing email communications at any time by unsubscribing or following the instructions contained within the email.
Your Canadian Privacy Rights:
Upon written request and after verifying your identity, we will provide you with a summary of your personal information under our control, information about how we use that information, and a description of the individuals and organizations to whom we have disclosed that information. We will make the information available within 30 days or provide written notice where additional time is required to fulfill the request.
In some situations we may not be able to provide access to certain personal information. This may be the case where, for example, disclosure would reveal personal information about another individual, the personal information is protected by solicitor/client privilege, the information is prohibitively costly to provide, the information was collected for the purpose of an investigation or where disclosure of the information would reveal confidential commercial information that, if disclosed, could harm our competitive position. We may also be prevented by law from providing access to certain personal information. When we refuse an access request, we will notify you in writing, document the reasons for refusal and outline further steps which are available to you.
We will make a reasonable effort to ensure that personal information we use or disclose is accurate and complete. In most cases, we rely on you to ensure that your information is current, complete and accurate.
If you inform us that your personal information is inaccurate or incomplete, we will amend the information as required. If appropriate, we will send the amended information to third parties to whom we have disclosed the information. If we do not resolve a challenge regarding the accuracy of personal information to your satisfaction, we will annotate the personal information under our control with a note that the correction was requested but not made.
We will keep personal information used to make a decision affecting you for at least one year after using it to make the decision, unless otherwise permitted or required by law.
We will destroy, erase or make anonymous documents or other records containing personal information as soon as it is reasonable to assume that retaining the information does not serve the original purpose for collecting the information and retention is no longer necessary for legal or business purposes.
We will take due care when destroying personal information in and effort to prevent unauthorized access to the information, but we cannot guarantee your information’s security.
- 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 thirteen. If DSC learns that a child under the age of thirteen has provided personally identifiable information through the DSC Services, we will use reasonable efforts to remove such information from our files.
- SECURITY OF YOUR INFORMATION.
- 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 they may or may not have their own published privacy policies. You should 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).
- CONSENT TO PROCESSING & INTERNATIONAL TRANSFERS.
DSC is a global business and we, or our 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. We may disclose your personal information 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. You may contact our Privacy Officer (whose contact information is provided below) to obtain information about our policies and practices regarding our transfer of data or use of service providers outside of your country, or to ask questions about the collection, use, disclosure or storage of personal information outside of your country.
- CHANGES & OTHER DSC PRIVACY POLICIES
- CONTACT US
Attn: Member Services/Privacy Officer
E-Mail: [email protected]
Alternatively, please go to ca.dollarshaveclub.com, and click on the Contact Us link.