We take data protection and information security very serious. The effective management of all personal data, including security and confidentiality, is the heart of our business and naturally underpins our practices and processes.
This privacy notice informs you about the type, scope and purpose of the processing of personal data we collect, use and process as a part of our website and its functions and content as well as our external online presences, such as our Social Media Profiles (the “Services”).
This notice applies to you, the User of our Services and us the provider of the Services and governs the processing of your personal data in context of our Services and business.
This Policy last updated on 5 February 2021.
Name and contact details of the responsible person:
Russell's Shave Club,
19 Great Ormond St,, Holborn, London,
Greater London, England WC1N 3JB United Kingdom
Tel: 020 7438 2087
Russell's Shave Club proceeds with all data processing procedures (e.g. collection, processing and transmission) in accordance with the statutory provisions of the UK`s Data Protection Act 2018 and in line with Regulation (EU) 2016/679 (General Data Protection Regulation). The following provides you with an overview of the type of data collected and how it is used and passed on, the security measures Russell's Shave Club takes to protect your data and how you can exercise your rights.
Collection, use and storage of personal data
When you use the online offer, Russell's Shave Club collects different data from you, partly also so-called personal data. This is information that relates to an identified or identifiable natural person (hereinafter "data subject").
Visiting the Russell's Shave Club website in general
When visiting the Russell's Shave Club website, you transmit data to our web server (due to technical necessity) via your internet browser. The following data is recorded during an ongoing connection for communication between your internet browser and our web server:
Date and time of the request
Name of the requested file
Page from which the file was requested
Access status (file transferred, file not found, etc.)
Web browser and operating system used
complete IP address of the requesting computer
amount of data transferred
For reasons of technical security, in particular to defend against attempted attacks on our web server, this data is stored by us for a short period of time. It is not possible for us to draw conclusions about individual persons on the basis of this data.
The legal basis for the storage is Article 6 lit. f) GDPR.
Further personal information is only collected if you provide it voluntarily, for example in the context of an enquiry or registration. Depending on the area concerned, Russell's Shave Club uses the personal data provided by you to answer your enquiries, to process your order and for the purpose of technical administration of the websites. In detail, the use in the respective areas follows as follows:
When you place an order in our online shop, we store the following information in order to fulfil the contract concluded between you and Russell's Shave Club or to carry out pre-contractual measures in accordance with Article 6 lit. b) GDPR:
a) Order without setting up a customer account
When placing an order in the online shop, all data necessary for execution and processing are requested by means of mandatory fields: Your full name, your e-mail address, your address (billing address and, if applicable, different delivery address). Your data will only be used to process your order.
b) Customer account / registration
It is also possible for you to register for your purchase at Russell's Shave Club. For this purpose, you can choose a password together with your e-mail address, both of which will enable you to log in more easily without having to enter your data again when you make a purchase at a later date. Russell's Shave Club stores the data you enter to set up a customer account through which your orders are recorded, executed and processed. Russell's Shave Club will hold your data for further orders as long as you maintain your registration. You have the right to access, correct or delete your registration data at any time.
c) Retention of order data
If you submit data to Russell's Shave Club for an order, your data will be stored for as long as necessary for the processing of the purchase and mandatory according to the legal retention periods. The extended storage for the fulfilment of the storage obligations is carried out according to article 6 lit. c) GDPR.
If you contact Russell's Shave Club via a contact form on the Russell's Shave Club website, the data you provide will be stored so that your message can be forwarded to the correct contact person. This is done in accordance with Article 6 lit. b) GDPR to process your request. Your data provided via a contact form will not be used for any other purposes, in particular not for advertising.
Disclosure and deletion of personal data
Visiting the Russell's Shave Club website
The data stored during the mere visit of the Russell's Shave Club website will not be passed on to third parties.
a) Passing on of data
Your personal data will only be passed on to third parties within the scope of the online shop if it is necessary for the purpose of processing the contract, for accounting purposes or for the collection of the payment.
Only if your enquiry or comment concerns a different Russell's Shave Club than the one whose contact form you have used, will your message and the associated data be transmitted to the correct contact person within the company. The data you have entered in an Russell's Shave Club online contact form will not be passed on to other third parties unless you are specifically informed of this.
All your data collected on the Russell's Shave Club website for the purpose of market research will be used exclusively for Russell's Shave Club internal purposes and will not be passed on to third parties. They will be deleted when their knowledge is no longer necessary for market research.
Transfer to authorities and other public bodies
Your data will only be disclosed to third parties outside the Russell's Shave Club if the responsible public authority or governmental institution orders the disclosure in an individual case, in which case Russell's Shave Club is obliged to do so.
General technical organisational measures
The Russell's Shave Club website is behind a software firewall to prevent access from other networks connected to the Internet. In addition, only employees who need the information to perform a specific job are granted access to personally identifiable information. These employees are trained in security and privacy practices and treat your information confidentially.
Secure data transmission
The transmission of your personal information during an order transaction in the online shop is encrypted using industry standard Secure Socket Layer ("SSL") technology, (SSL encryption version 3).
Credit card information
Any credit card information you provide will not be stored by Russell's Shave Club, but will be encrypted and collected directly from the payment service provider via hypertext transfer protocol secure ("https").
You should never disclose your password for accessing our customer portal to any third party and you should change it regularly. If you want to leave your customer account in the online shop, you should press the logout and close your browser to prevent anyone from gaining unauthorised access to it.
What is a cookie?
Cookies are small pieces of data, stored in text files, that are stored on your computer or other device when websites are loaded in a browser. They are widely used to “remember” you and your preferences, either for a single visit (through a “session cookie”) or for multiple repeat visits (using a “persistent cookie”). They ensure a consistent and efficient experience for visitors, and perform essential functions such as allowing users to register and remain logged in. Cookies may be set by the site that you are visiting (known as “first party cookies”), or by third parties, such as those who serve content or provide advertising or analytics services on the website (“third party cookies”).
Both websites and HTML emails may also contain other tracking technologies such as “web beacons” or “pixels.” These are typically small transparent images that provide us with statistics, for similar purposes as cookies. They are often used in conjunction with cookies, though they are not stored on your computer in the same way. As a result, if you disable cookies, web beacons may still load, but their functionality will be restricted.
Our website uses the below technologies for advertising purposes. Those are modern, advanced analysis methods and tools to understand users’ habits on our website. This information helps us improve our products and services and provide relevant services and information. In principle, we use only anonymised data that does not allow us to identify the user.
Below we describe the analysis services and technology that we use for such purposes. Additionally, we show how you can prevent these services from analysis of your use of our website.
Cookies / usage-based advertising (Behavioural Advertising)
Based on Article 6 lit. f) GDPR Russell's Shave Club creates user profiles for the purpose of advertising, market research or for the demand-oriented design of the Russell's Shave Club online services if the user does not object to this. Your possibility to object is described in the individual technical measures.
Cookies are used on our website for so-called behavioural targeting. These are text files by means of which data with usage information (websites visited, number of visits, visiting times, time spent on individual pages, etc.), i.e. usage profiles, are stored on your hard disk. These usage profiles are anonymised and evaluated in a technical (statistical) evaluation process in order to later enable a selection based on the interests of the respective user when Internet advertising (e.g. banners) is displayed on other websites. Under no circumstances will personal data such as name, address or e-mail address be stored in the cookies.
You can also prevent the storage of cookies in principle via the settings of your browser. However, it may then not be possible to display all of Russell's Shave Club's Internet pages completely and/or correctly.
Online presence in social media
We maintain online presences within social media on the basis of our legitimate interests as defined in Art. 6 para. 1 lit. f. GDPR, we maintain online presences within social networks and platforms in order to be able to communicate with the customers, interested parties and users active there and to inform them about our services there. When calling up the respective networks and platforms, the terms and conditions and data processing guidelines of their respective operators apply.
Unless otherwise stated in our data protection declaration, we process the data of users if they communicate with us within the social networks and platforms, e.g. write posts on our online presences or send us messages.
Google will use this information on our behalf for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. In doing so, pseudonymous user profiles can be created from the processed data.
We only use Google Analytics with IP anonymisation activated. This means that the IP address of the user is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.
The IP address transmitted by the user's browser will not be merged with other data from Google. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent the collection of the data generated by the cookie and related to their use of the online offer to Google as well as the processing of this data by Google by downloading and installing the browser plugin available under the following link: https://tools.google.com/dlpage/gaoptout?hl=de.
For more information on Google's use of data, settings and opt-out options, please visit Google's websites: https://www.google.com/intl/de/policies/privacy/partners ("Data use by Google when you use our partners' websites or apps"), https://policies.google.com/technologies/ads ("Data use for advertising purposes"), https://adssettings.google.com/authenticated ("Manage the information Google uses to serve you ads").
Facebook Custom Audiences
Facebook Custom Audiences enables us to use existing datasets to compile groups and lists of users based on certain criteria in order to provide users with information and advertisements, tailored to their interests and preferences, on Facebook’s services. Before transmission to Facebook, the data is irreversibly encrypted in the form of hash values on our computers; Facebook can compare these against its user databases. You can opt out of this form of advertising by changing the settings at the Facebook settings page.
Facebook Lookalike Audiences
Facebook Lookalike Audiences enables us to use existing datasets to compile groups and lists of users based on certain criteria in order to provide users with similar interests and preferences with relevant information on Facebook’s services. Before transmission to Facebook, the data is irreversibly encrypted in the form of hash values (encrypted numeric values) on our computers. You can opt out of this form of advertising by changing the settings on the Facebook settings page.
Microsoft/ Bing MUID
These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator's permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
Below are the cookies that require prior consent from users to be installed:
You have a number of ‘Data Subject Rights’ below is some information on what they are and how you can exercise them. There is more information on the Information Commissioners website (www.ico.org.uk).
- ·information about the processing of your personal data.
- ·obtain access to the personal data held about you.
- ·ask for incorrect, inaccurate or incomplete personal data to be corrected.
- ·request that personal data be erased when it’s no longer needed or if processing it is unlawful.
- ·object to the processing of your personal data for marketing purposes or on grounds relating to your particular situation.
- ·request the restriction of the processing of your personal data in specific cases.
- ·receive your personal data in a machine-readable format and send it to another controller (‘data portability’).
- ·request that decisions based on automated processing concerning you or significantly affecting you and based on your personal data are made by natural persons, not only by computers.
- ·You also have the right in this case to express your point of view and to contest the decision
Where the processing of your personal information is based on consent, you have the right to withdraw that consent without detriment at any time through our contact form.
The above rights may be limited in some circumstances, for example, if fulfilling your request would reveal personal information about another person, if you ask us to delete information which we are required to have by law, or if we have compelling legitimate interests to keep it. We will let you know if that is the case and will then only use your information for these purposes. You may also be unable to continue using our services if you want us to stop processing your personal information.
We encourage you to get in touch if you have any concerns with how we collect or use your personal information. You do however also have the right to lodge a complaint directly with the ICO, their contact details can be found on their website (www.ico.org.uk).
The Supervisory Authority
The Information Commissioner’s Office (ICO) in the UK is the for us relevant authority in matters of data protection. You have the right to make a complaint at any time to the ICO (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by email at email@example.com or by mail using the details provided.