Last updated: July 15, 2020
By using our services, you agree to the collection, disclosure and use of your information as described in this policy. If you do not agree, please do not use our services.
Our goal is to help you understand how we collect, disclose and use your information to improve our content, advertisements and services. Our policy also explains how we safeguard your information and how you may access and control the use of your information.
information we collect
We collect your personal information when you give it to us, contact us, use our services (including visiting our site and our social media pages, whether you access our services on a computer, mobile device, tablet or other device (collectively, “device”), or view our advertisements. We also receive your personal information from other companies who obtained your consent to share or sell it, have ensured that other companies from whom they have received your information can share it with them and, in turn, with us and/or other companies or have collected the information when you visit their websites. Your “personal information” is any information that personally identifies you or that is reasonably capable of being associated with or linked to you or your household.
We may combine any and all of this personal information to help create better products, services, and consumer experiences.
We collect the following types of personal information from you and may have collected such personal information prior to the date our policy was last updated:
- identifiers and contact information: this includes your name, nickname, title, age, mailing address, email, phone numbers, username, password, contact information for related persons (including authorized users of your account), and unique identifiers (such as customer number, account number, subscription number, rewards program number, system identifiers (including username or online credentials), device advertisers, advertising IDs and IP address)
- government-issued identification information numbers: this includes information provided on your military identification card, such as your card color, branch identification, DOD identifier and similar information
- demographic information: this includes your age range, gender, marital and family status, languages spoken, shopping preferences, loyalty and rewards program data, household demographic data, data from social media platforms, education level and professional information, hobbies and interests and propensity scores from third parties (likelihood of purchase, experiencing a life event, etc.)
- geolocation data: this includes data about the location of the device you use to access our services as described in more detail below
- commercial information: this includes your customer account information, qualification data, purchase and usage history (including returns, product service records, records of payments, credits etc.), goods and service preferences, non-biometric data collected for consumer authentication (passwords, account security questions), customer service records, payment and account information, wallet balance and billing dates
- internet/electronic activity: this includes your IP address, web/app browsing and search history related to our services, and information related to your use of our services and interactions without advertising
- online and technical information: this includes network activity information such as IP address, MAC address, SSIDs or other device identifiers or persistent identifiers, online user ID, encrypted password, device characteristics (such as browser information), web server logs, application logs, browsing data, viewing data (TV, streaming), website and app usage, first party cookies, third party cookies, flash cookies, Silverlight cookies, web beacons, clear gifs and pixel tags
- audio-visual information: this includes text messages, audio recordings of messages and voicemails
- inferences: this includes inferences that we create from the above to create profiles to better identify which of our services may be of interest to you; and includes propensities, attributes and/or scores generated by internal analytics
how we collect your information
Your personal information is collected in many ways and from many sources. For example, we may collect your personal information from the following: internet service providers, data analytics providers, operating systems and platforms, social networks, data aggregators and directly from you. Some of the information we collect may include personal information that may identify you, such as your name, mailing address, email or telephone number. Some countries and states, like those in the EU or California, consider things like IP addresses or cookies and mobile device identifiers as personal information.
personal information you provide directly to us
We may ask you to provide certain personal information when you use our services and to provide you with our products. For example, we may ask you to provide your personal information 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. The personal information that we, our service providers or our business partners may collect may include information such 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 the personal information you provide to us when you participate in an online survey or as part of a research panel. 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
When 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 someone else
You may decide to provide us with someone else’s information (such as their name, email, mailing 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. The local laws of your location may require you to seek your contacts’ consent to provide their personal information to us or in connection with using our services. We will obtain the required consent from the person whose information you provided to us when we are required by law to do so.
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 our services. When you do this, we may automatically receive some of your personal information based on your social media privacy settings. This may include, but may not be limited to your name, user name, demographic information, updated address or contact information, location, interests, and publicly-observed data, such as from social media and online activity.
automatically collected personal information
Some of your personal information is collected automatically when you visit or interact with our site, our services, us, and any of our third-party advertisers or service providers.
For example, we may automatically collect your information, such as 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 your preceding page views or websites visited, your mobile device activity and configurations, and email client. We may also automatically collect information about your use of our services, such as the date and time you visit our site or use our services, use or click through to any of our sites or services, our site and service areas or pages that you visit, the amount of time you spend viewing or using our site or services, the number of times you return to our site or use our services, other click-stream or site usage data, emails that you open, forward or click-through to our services, and other sites that you may visit.
We, and our third-party advertisers and service providers, may use various technologies that automatically or passively collect information about your online activity. This personal information may be collected in the following ways:
- device information: we may automatically collect your IP address or other unique identifier (“device identifier”) for the device you use to access our services, including the hardware model and mobile network information so that we can provide our services, 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 re-target online and mobile advertisements to you across the devices you may use
- geolocation information: we may collect information about your device’s location when you access or use our services; and we may geolocation information when you use our mobile applications if you enable your Bluetooth, Wi-Fi or other geolocation functionality on your mobile device
- third-party service providers: we may use third-party service providers to support our services, and some of those third-party service providers may use technology such as cookies, web beacons, pixel tags, log files, or other technologies to receive, collect, and store your personal information on our behalf
To learn more about your advertising choices relating to the collection and use of your information, please see the Your Choices section below.
your personal information we receive from other third parties
We may obtain your personal information from other trusted third-party sources so that we can update or supplement your personal information. For example, we may receive your 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 your personal information from our partners and service providers (including, our 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 our 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 your personal information that we receive from you and about you, including the information that you provide to us and that we automatically collect through our services, as well as your personal information that is collected across other computers or devices that you may use, from other online or offline sources, and from third-party sources. We may use this combined personal information in any manner described by this policy.
how we use your personal information
We use your personal information for a variety of business purposes.
We may use your personal information for customer service and transactional purposes, such as to:
- perform services
- respond to your account and registration, and to troubleshoot issues, bugs or defects related to your account or activities
- respond to your questions, requests and to provide customer service
- validate, confirm, verify, deliver and track your order (including shipping arrangements, handling returns and refunds, and contacting you by phone, email or otherwise about your orders and related information)
- send marketing communications, coupons, samples, products, surveys and invitations
- verify your identity or communicate with you about your activities, use of our services and, in our discretion, changes to any of Leaf Shave’s policies
- use and disclose your payment information (including credit card, debit card, payment card or other financial information) to process payments and prevent fraud
- identify and authenticate you to our different marketing programs and websites
- interact with you over social media
We may also use your personal information for commercial and internal business purposes, such as to:
- perform market research, understand the effectiveness of our competition or promotions and our services analytics and operations
- provide customized content, advertisements, offers and promotions related to our (or our partners’ and affiliates’) services, or to provide other information we believe to be of interest to you on or outside of our services, including over email or third-party websites
- link or combine with your personal information that we receive from others to help us understand your needs, use for interest-based or targeted advertising or re-targeting on your devices, and to provide you with better service
- perform quality control, training, analytics, system administration and technology management (including optimizing our site and services)
- perform risk management, audits, investigations, reporting and for other legal and compliance reasons (including to detect threats and protect against malicious or fraudulent activity)
- maintain records and auditing interactions with consumers (including logs and records maintained as part of transaction information)
We may also use your personal information to better under our customers generally, including:
- for internal research
- to identify new prospective customers
- to design and develop new products or services and to enhance current products and services
how your personal information is shared
Both you and Leaf Shave may share your personal information that is collected by us or generated through your use of our services in the following ways:
personal information you share
Your activity in connection with our services, such as completing surveys, reviewing and rating products, inquiring about or purchasing products, participating in online communities, “liking” or “sharing” our content on your social media accounts or pages or otherwise interacting with our services, may be visible to other users of our services and in some cases, publicly available.
personal information we share
We may share your personal information that we collected 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 providers: we may share your personal information with third-party service providers that provide business, professional or technical support functions on our behalf (such as, service providers that host or operate our services; to process payment; to analyze data; to provide customer service; to provide postal or delivery services, and administer or participate in any promotions)
- sweepstakes, contests and promotions: when 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 to administer the Promotion, as required by law, as otherwise permitted by the Promotion’s official rules, or as otherwise in accordance with the terms of this policy
- business transfers: your personal information may be disclosed to an entity that merges with us or acquires us or all or substantially all of our assets, or those assets related to our services, as part of the due diligence process and will be transferred to such entity as one of the transferred assets; or to third parties as part of a transfer resulting from a bankruptcy or reorganization proceeding brought by or against us and in which your personal information is considered an asset of ours
- aggregate or anonymous non-personal information: aggregate or anonymous (de-identified) information is not personal information, and we may share such with third parties for their marketing or analytics uses
- other third parties: your personal information may be shared with our sponsors, partners, advertisers, advertising networks, advertising servers, and analytics companies or other third parties for to provide information on products and services, and for marketing, promotional and other offers; we may also share your personal information with third parties we’ve identified at the time you provide your personal information or with your consent
how we safeguard your personal information
We respect your personal information and use reasonable security measures to protect it from loss, misuse or alteration. Where appropriate, these measures may include technical measures (such as unique and complex passwords), as well as organizational and physical measures such as training on data processing obligations, identifying data incidents and risks, restricting access to your personal information and ensuring physical security.
While we take safeguarding your personal information seriously and have implemented reasonable security measures, no electronic measures can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information you provide to us. You use our services and provide us with your information at your own risk. We will use reasonable efforts to ensure that any third parties with whom we share your personal information secure and use only the information consistent with the terms of this policy.
your rights and choices
When you use our services, you have certain rights and choices regarding your personal information:
rights of EU residents
Those who live in the EU/EEA, or who are physically present in the EU/EEA, have the rights to access the personal information we hold about you, request that inaccurate, outdated or no longer necessary information be corrected, erased or restricted, and ask us to provide your data in a format that allows you to transfer it to another service provider. You may withdraw your consent at any time for personal information we collect and for which we rely on your consent. You may also object and ask us to stop using your personal information where that use is based on our legitimate interest and reason for using the data. More information about data protection and your personal information rights more generally are available on the European Data Protection Supervisor’s site at https://edps.europa.eu/data-protection/
If you are unhappy with our response to your requests, you may lodge a complaint with the data protection authority in your country. All requests regarding your personal information should be made by email to email@example.com
You can always tell us to stop emailing and sending text messages by following the opt-out instructions described in those communications. You can also opt-out of marketing emails, text messages or mailings by sending an email to: firstname.lastname@example.org
Please understand that to comply with your request, we may need to keep some of your personal information on file so that our systems will no longer send you marketing communications.
Through your account, you may be able to access, update or delete your information. If you cannot, or if you are having trouble doing so, you can send an email to: email@example.com
Cookies are files sent to your computer when you visit a website. These files provide information about your interactions with the websites you visit. Cookies identify your devices through a randomly assigned cookie ID (such as XYZ098765), and not by your name. Cookies do not collect information stored on your computer, device or located in your files, or which would otherwise directly identify you as a person.
- to serve you with relevant advertising
- to learn more about the way you interact with our content and services
- to help us improve your experience when you visit our site and use our services
- to remember your preferences, such as a language or a region, so there is no need for you to customize our site on each visit
- to identify errors and resolve them
- to analyze how well our site and services are performing
We use the following types of cookies:
- session cookies: these cookies remember you by using randomly assigned cookie ID like XYZ0987655 as you move from page to page so that you don’t have to provide the same information you’ve already given on the site. For example, session cookies are extremely helpful when shopping online because the items you place in your shopping cart would disappear by the time you reach the checkout without session cookies! These cookies are deleted as soon as you leave our site or close your browser.
- persistent cookies: these cookies allow sites to remember your preferences when you come back again to make your experience more convenient, efficient and user-friendly. For example, if you choose to read the site in French on your first visit, the next time you come back the site will appear automatically in French.
- advertising cookies: these cookies can learn about interests you generally might have, based, for example, on the websites you visit and the products you buy. This helps us to infer things about you, such as your age, marital status, and how many children you may have. This also allows us to send you ads for products and services that better fit the things you like or need, and to limit the number of times you see the same advertisement.
You can adjust your browser setting to refuse all cookies, to alert you when cookies are being sent to your computer, and to delete cookies every time you finish browsing. Limiting your browser’s ability to accept cookies may prevent our site and services from working properly.
We may use other technologies in addition to cookies to collect your personal information, such as:
- proximity-based beacons: send one-way messages to apps installed on your phone over very short distances that tell you, for example, what products are on-sale while you’re walking through a store. Beacons only send messages when you are close enough and after you’ve given consent within the mobile app associated with a particular beacon. These apps may then provide us location information to help customize advertising and offers to you. For example, when you are near a beacon in the personal care section of a supermarket, we may send you a $10 rebate.
- pixels: are invisible objects embedded into a web page. These are also called “tags,” “web bugs,” or “pixel gifs.” We use pixels to deliver cookies to your computer, monitor site activity, make logging into our sites easier, and for online marketing activity. We also use pixels in our promotional email messages or newsletters to determine if you open and act on them.
- precise geolocation: we may receive information about your exact location from things like global positioning system (GPS) coordinates when you use our site on your mobile device. You should understand that we will not always ask for consent to know generally that you are in a broader city, postal code, or province. For example, we do not consider it to be precise location if all we know is that you are somewhere in Chicago, Illinois.
When you visit our partner sites, we can show you ads or other content we believe you would like to see. Interest-based ads are based on the websites you visit on your devices. For example, you may receive advertisements for our Leaf Razor if we notice that you are visiting sites that sell razors. And from that information we may conclude that you need a new razor and therefore could well be interested in a plastic-free shave you can love. In this way, we intend to send you relevant information about our products that may be of benefit to you.
We may group you with consumers who show similar interests. For example, we may group you with other “razor aficionados” if we see that you frequently purchase razors online. We notice these things as you look at websites, links you click on our websites and other websites you visit, mobile applications you use, or our brand emails you view and links you click in those emails. We also group cookie and device IDs together to help us understand a consumer group’s general trends, habits or characteristics. This allows us to find and many others who are similar to the group. We can then send them what we believe will be relevant and beneficial product offers and information.
you can stop receiving interest-based ads
You can stop receiving Leaf Shave interest-based advertising by emailing us at firstname.lastname@example.org. In opting out of interest-based advertising, we will send an opt-out cookie to your browser so that it will tells us that you wish to stop receiving interest-based ads.
You can also stop receiving interest-based ads by declining cookies in your browser settings, declining the “access to data” requests that apps typically present when during installation, or by adjusting the ad tracking settings on your device. If you delete all of your cookies, your opt-out cookie will be deleted, and you will need to redo your opt-out again if you do not want to receive interest-based ads.
While we will stop sending you interest-based ads, you will still get contextual ads from our brands on your computer or mobile devices. Contextual ads are based on the context of the specific websites you are visiting. For example, you may still see an ad for our razors while looking at sites dedicated to grooming products because these sites traditionally have primarily served those interested in shaving products. We may still collect information from your computer or devices and use it for other purposes like evaluating how our websites work, for consumer research, or detecting fraud.
EU data processing, retention and transfers
This section aims to provide increased transparency into our processing, retention, and transfer of EU/EEA resident personal information that is in line with the letter and spirit of the General Data Protection Regulation.
we are a data controller of your personal information
We are the controller of some of your personal information. As a data controller we are the entity directing the processing activity and who is principally responsible for your personal information.
processing and retention of your personal information
We generally keep your data for the amount of time it takes us to complete the purpose for which it was collected, unless a longer time is required by law. We may also need to keep your personal information for longer than our specified retention periods so that we can honor your requests, including keeping you opted out of marketing emails, or as required by our legal or other obligations.
We’ve prepared the chart below to show you the type of data we collect, why we collect your data, why our uses comply with the law (i.e., our legal basis), and how long we generally keep your personal information (retention period):
|Type of Information||Why We Collect this Information||Our Legal Basis||Retention Period|
Name, email, phone number, mailing address, your affinities, your interests, your profession, your habits, what you bought, the photos or videos you upload, information about your children and your home, your family composition, the number of people in your household, your hair type, your skin type, your favorite scent, etc.
|To send you materials, such as advertisements, marketing our products or services or the products or services of our partners||Your consent for name, contact and account information; legitimate purposes for everything else||
Until you request that we delete your personal information or withdraw your consent.
Name, email, phone number, sometimes other information
|To provide participants with information about the contest, including announcement of the winner(s)||
Until you request that we delete your personal information or withdraw your consent.
Name, email, phone number, mailing address, billing address, payment information (including credit, debit or other payment card information, bank account information, Paypal or Apple Pay details), sometimes other information
To process your purchase of our products, cashback offers or warranties and to send relevant communications related to your purchase
Until you request that we delete your personal information or withdraw your consent.
Name, email, phone number, sometimes other data
To address the inquiries you make and to follow-up with you
Legitimate business interest in managing your inquiries and providing customer service; your consent for special category information collected in some adverse event cases
Until you request that we delete your personal information or withdraw your consent for personal information we collect with your consent.
Advertising cookies, device ID, demographic information such as gender and age, behavioral data such as page views, and sometimes other data
To learn about your internet interests and customize the ads we send you
Our legitimate business interests in serving you with relevant advertising in all EU/EEA countries, except for France and United Kingdom, where we rely on consent; we will obtain your consent for the deployment of cookies on our own websites in accordance with ePrivacy requirements
Until you request that we delete your personal information, opt-out or withdraw your consent for personal information we collect with your consent.
consent to processing and international transfers
Our business is global and, along with our service provides, we may process, transfer and store information about our users on servers located in several countries, such as the United States. This means that 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 governmental authorities or the judicial process in those countries in which we operate. By using our services, or by providing us with your 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 be less comprehensive than those in the county in which you live.
Our site may contain the following content, which may collect your personal information:
- plugins: we may include plugins (for example, the Facebook “Like” button”) on our site or apps from other companies, such as social media networks. These plugins may collect your information (such as the url of the page you visited) and send it back to the company that created them, even when you do not click on the plugin. These plugins are governed by the privacy policies of the company that created them even though they may be on our site. In collecting and the transmission of such information, we act as a controller of that information for our EU/EEA sites. Such plugins are non-essential cookies and will only work on our EU/EEA sites if you accept cookies.
- logins: we may allow you to login to our site or apps using another of your accounts with another company, for example a “Login with Facebook.” When you login in this manner, we can access only that information you have consented to based on your account settings with that other company’s account with which you are logging into our site.
- user content: we may allow you to upload your own content to our site or apps for contests, blogs, reviews, videos and other functions. Any information you submit or post is public information. We cannot control how others use content you submit or post on our site or apps, and are not responsible for any use of such information that may otherwise violate our policy, the law or your personal privacy and safety.
children’s personal information
We do not knowingly collect personal information directly from children under 18, except where we have consent of the parents or guardians. If you are a child under 18, please do not attempt to register for or otherwise use our services or send us any personal information without the consent of your parent or legal guardian. If we learn that we have collected personal information from a child under 13, we will use reasonable efforts to delete that information as quickly as possible. If you believe that a child under 13 may have provided us with personal information, please contact us at: email@example.com
Certain state law privacy rights
California residents: You have the right under California Civil Code Sections 1798.83-1798.84, to contact us to prevent disclosure of personal information to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at firstname.lastname@example.org
Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Our services do not support Do Not Track requests at this time. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com.
Nevada residents: You have the right to opt out of the sale of certain personal information to third parties who intend to license or sell your personal information. To exercise your right, contact us at email@example.com and provide us with your name and the email address associated with your account.
Our services may contain links to other sites that we do not own or operate, such as 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 send their own cookies to your device, independently collect data or solicit your 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 our services (including those linked to through an email or social networking page).
We may change our policy from time to time. Any changes we make to our policy will be posted on this page. You should check this page frequently for updates or changes to our policy. We always indicate the effective date of the policy on this page. If we make significant changes, we will provide a more prominent notice, which may include posting a notice on leafshave.com, by sending you an email or by other means.
If you have any questions or concerns about this policy, our collection and use of your personal information, or your rights regarding such use, please contact us at:
- Leaf Shave Company, 40 Taugwonk Spur Rd., Unit 30, Stonington, CT 06378
July 15, 2020