Privacy policy
PRIVACY POLICY
We are Harry's, and when you access or use this website (www.harrys.com/en/gb), or our mobile application, our blog, our branded pages on social media services, or any of the other sites, services, features, content or applications we offer in the United Kingdom (collectively, the "Services"), or register an account with us, purchase our products or contact us from anywhere in the United Kingdom, this Privacy Policy will tell you how Harry's, Inc. and its subsidiaries, including, without limitation, Harry's Grooming Limited and Harry's USA, Inc. (as applicable, "Harry's", "we", "us" or "our"), collect, use and share the personally identifiable information ("Personal Data") we collect about you.
We urge you to read this Privacy Policy in full, but wanted to mention a few things upfront:
• When you use the Services, even if you don't have an account with us or purchase our products, we may receive some Personal Data from you through your web browser, including your IP address, the type of device you're using and other similar information, and use it to understand where and how our Services are being used, among other purposes described in this Privacy Policy. If you do set up an account with us or purchase our products, we'll collect other Personal Data from you, and use it to verify your identity, fulfill your orders, market to you and for other purposes.
• In this Privacy Policy, we describe the various purposes for which we use your Personal Data, as well as the legal bases supporting those purposes. As you'll read below, the legal basis on which we rely for a given use of your Personal Data may be contractual necessity (i.e., where we need to use your Personal Data to complete a contract with you), consent freely given to us (which you can withdraw at any time) and/or certain legitimate business of ours or of others, but only where we have determined that those interests are not overridden by your own interests, rights and freedoms.
• You have certain rights regarding the Personal Data we collect from you, which you can learn about below.
• As noted in our Terms of Service, we do not knowingly collect or solicit Personal Data from anyone under the age of 18. If you are under the age of 18, please do not access or use the Services, or attempt to send us any Personal Data. If we learn that we have collected Personal Data from an individual under the age of 18, we will delete that information as quickly as possible.
• If you are based in the United Kingdom, Harry's Grooming Limited, our subsidiary based in the United Kingdom is the primary data controller of your information and, accordingly, is registered with the Information Commissioner's Office. Harry's Grooming Limited has a registered office at 5th Floor 101 St Martins Lane, London, United Kingdom, WC2N 4AZ. You can contact us there or at ukhelp@harrys.com, or contact our Data Protection Officer directly at security-council@harrys.com, if you have any questions or concerns about our collection and/or use of your Personal Data. If you are using the Services outside of the areas listed in this paragraph, a different privacy policy may apply to you instead.
• The Services are hosted and operated in the United States through Harry's, Inc. and certain of our service providers. By using the Services, you acknowledge that any Personal Data you provide to us will be hosted on United States servers. Harry's, Inc. and Harry's USA, Inc., both located at 75 Varick Street, New York, New York 10013, are registered under the EU-U.S. Data Privacy Framework. Please see below for more details.
• This Privacy Policy does not apply to the practices of third parties that we do not own or control, including, but not limited to, any third party websites, services, products or applications (each a "Third Party Service") that you elect to access and may interact with during your use of the Services, or to individuals that we do not manage or employ. We take steps to ensure that we only work with Third Party Services that share our respect for your privacy, but we cannot take responsibility for the content, products, services or privacy policies of those Third Party Services. We encourage you to carefully review the privacy policies of any Third Party Services you access.
PERSONAL DATA YOU PROVIDE US
REGISTRATION INFORMATION
We collect your email address and the password you enter when you register for an account with us, and we use them to verify your identity, based on our legitimate business interests in keeping your account secure and preventing fraudulent transactions.
We also use your email address:
• to send you confirmations, notifications and other information regarding your account, your shave plans and your purchases, as may be necessary to complete our contractual obligations to you. Without your email address, we wouldn't be able to provide you this information in a timely and effective manner;
• to send you information and materials about us, our products and our services that we think may be of interest to you, based on our legitimate business interest in marketing to individuals who have indicated an interest in our products and services. You can choose not to receive such information when you register an account with us, and you can decide to stop receiving this information at any time by emailing us at ukhelp@harrys.com; and
• to send you information and materials about third parties with whom we partner or do business and their products and services, but only where you have given us your consent to do so. You can opt in to receive such messages when you register an account with us and you can always decide to stop receiving these emails at any time by emailing us at ukhelp@harrys.com.
You may be able to register for or access the Services using Third Party Services, such as Facebook. If you've registered for an account with us through Facebook or another Third Party Service, we will collect and receive your login credentials for such Third Party Service in connection with providing you with the Services if you expressly provide us with such information. We will only use such login information for the purposes described above. In any case, we urge you to review your privacy settings on any Third Party Service and their associated privacy policies to understand more about disclosures of information from your applicable Third Party Services.
SHIPPING AND PAYMENT INFORMATION
When you subscribe to a shave plan or purchase products through the Services or over the phone with one of our customer service representatives, we collect and store your first and last name, your shipping address and your telephone number (collectively, "Shipping Information"), as well as certain payment information, including your billing address and your credit or debit card type, number, security code and expiration date (collectively, "Payment Information"), and we use this information in order to process, fulfill, confirm, or notify or inform you about your shave plans and purchase orders, as may be necessary to complete a contract with you. Without this information, we would be unable to complete your transaction with us and/or deliver your purchases to you.
All Payment Information regularly collected through the Services is encrypted and maintained using industry standard methods designed to ensure its security against loss or theft, including during transmission to our third party payment processing company ("Payment Processor"), which is currently Stripe, who processes your Payment Information on our behalf. Please note that your Payment Information is stored by our Payment Processor, not by us, and use and storage of that information by the Payment Processor is governed by the Payment Processor's applicable terms of service and privacy policy (available at: https://stripe.com/gb/legal and https://stripe.com/gb/privacy).
We also use your Payment Information to verify your identity when you manage your account, your shave plan or your orders, or make a new purchase, based on our legitimate business interests in keeping your account secure and preventing fraudulent transactions. As stated above, we do not store your Payment Information – our Payment Processor does, and we must collect your Payment Information from our Payment Processor and/or from you in order to use it to verify your identity or to process and fulfill your shave plans.
We use and store your Shipping Information to make it easier for you to make a purchase, or to sign up for a shave plan if you do not have one, based on our legitimate business interest in making the Services more convenient for your continued use.
We may also use your name and shipping address to mail you information and materials about us and our products and services that we think may be of interest to you, based on our legitimate business interest in marketing to individuals who have indicated an interest in our products and services. You can always choose not to receive such communications when you register an account with us, and you can stop receiving these communications at any time by emailing us at ukhelp@harrys.com.
If you indicate that you would like us to do so, we will share your name and shipping address, along with certain information regarding your transactions with us (including transaction date, value, amount, type, and order ID) with Epsilon Abacus, a provider of data cooperative and marketing services to a members-only group of retailers (such group the "Abacus Alliance" and such members the "Abacus Alliance Members"). Through Epsilon Abacus, this information will be shared with the Abacus Alliance Members, with any transactional information being aggregated so details of individual transactions are not shared. More specifically, we share this information with Epsilon Abacus so that it can analyze your buying patterns and determine what sort of products are likely to appeal to you, and Epsilon Abacus shares your name and shipping address with Abacus Alliance Members who may offer such products.
By agreeing to share such information with Epsilon Abacus and the Abacus Alliance, you agree to receive information and materials in the post regarding products offered by other Abacus Alliance Members. The list of retailers in the Abacus Alliance changes frequently, but it is limited to retailers in the clothing, collectables, food and wine, gardening, gadgets and entertainment, health and beauty, household goods and/or home interiors categories. You can opt in to share the above-described information with Epsilon Abacus and the Abacus Alliance and receive such materials in the mail when you register an account with us.
If you decide you would like to stop sharing this information and receiving materials in the post, you can email us at ukhelp@harrys.com. Additionally, if you would like to stop all unsolicited postal communications, we suggest that you register with the Mailing Preference Service (MPS), a free service funded by the direct mail industry that enables consumers to have their names and home addresses in the UK removed from lists used by the industry. For more information or if you wish to register with the MPS please visit their website www.mpsonline.org.uk.
INFORMATION YOU SHARE WITH US IN COMMUNICATIONS OR INTERACTIONS
When you communicate with us or our customer service representatives, including when you call us, email us or interact with us through the Services, we automatically record that communication, and use that record and the information you provide us in those communications, to address your questions and complaints about us, our products and our services, and to train our customer service representatives, based on our legitimate business interest in providing quality customer service. We also use the information you provide us to address your requests regarding your account, shave plans and purchase orders, as may be necessary to complete a contract with you. Without this information, we may not be able to address these requests.
When you respond to a survey we provide you, or leave a written comment or review on the Services about us, our products or the Services, we record that survey response, comment or review, and use the information you provide us in them, in order to assess and/or address your responses, comments or reviews regarding us, our products or our services, based on our legitimate business interest in providing quality products and customer service.
OTHER PERSONAL DATA WE RECEIVE ABOUT YOU
In addition to the information you directly provide us, we automatically receive and record certain information about you when you access or use the Services, or otherwise communicate or interact with us (including through other websites or mobile applications). Additionally, like many e-retailers, we collect certain information about you from third parties, including advertising and analytics companies.
LOCATION INFORMATION
When you access or use the Services, we collect information from your web browser, including your IP address and your device's settings and unique identifiers, and use that information to determine your general location, based on our legitimate business interests in reliably and accurately providing you with Services and information that apply to you, and in learning more about where the Services are being accessed or used.
COOKIE INFORMATION
When you access or use the Services, and with your consent, we and certain of our third party service providers automatically receive and record information from your web browser and your device using cookies and similar technologies such as pixel tags or web beacons (for the purposes of this Privacy Policy, we refer to these technologies individually and collectively as "Cookies"). Cookies are small files – usually consisting of letters and numbers – placed on your computer, tablet, phone or similar device, when you use that device to visit a website. Cookies can either be "session Cookies" or "persistent Cookies." Session Cookies are temporary Cookies that are stored on your device while you are accessing or using our Services, whereas "persistent Cookies" are stored on your device for a period of time after you leave our Services. The length of time a persistent Cookie stays on your device varies from Cookie to Cookie.
We use Cookies to collect information regarding your internet usage, including your IP address, internet service provider, browser type and version, the pages you visit and links you click on the Services, and the page referring you to the Services and/or the page you visit when you exit the Services, as well as device-specific information if you access the Services using a mobile device, such as unique device identifiers, network information and hardware model (collectively, "Cookie Information").
Necessary Cookies
Necessary Cookies enable you to access and use our website and other features or content on the Services that you request or seek to use based on our legitimate business interest in providing you with the Services. For example, Cookies that enable you to log into your account or use the "shopping cart" functionality on the Services are Necessary Cookies. Our Necessary Cookies include:
| Name | Description | Duration |
|---|---|---|
| h_cart | Notes the contents of your cart before you checkout so that if you navigate away from your basket and return to us, we will remember what was in your cart. | Persistent |
| h_sess | identifies you to our servers after you log in to your account; and | Persistent |
| flash | temporarily stores messages and alerts that we display on-screen to you. | Session |
| optout | Identifies if the visitor has deselected any cookies, trackers or other audience targeting t ools. |
Session |
| 1.gif | Used to count the number of sessions to the website, necessary for optimizing CMP product delivery. | Session |
| _dc_gtm_UA-38502581-1 | The cookie sets or reads an ID and then sends information about when such ID visited the site, what pages it saw and, in some cases, what products it interacted with, but no Personal data is sent. | 1 day |
| _pin_unauth | The cookie sets or reads an ID and then sends information about when such ID visited the site, what pages it saw and, in some cases, what products it interacted with, but no Personal data is sent. | 1 year |
| CookieConsent | Stores the user's cookie consent state for the current domain. | 1 year |
| rc::a | This cookie is used to distinguish between humans and bots. This is beneficial for the website, in order to make valid reports on the use of their website. | Persistent |
| _h_gdpr_cookie_agree | Remembers if a user agreed to be tracked via Cookies. | 1 year |
| h_locale | Specifies which locale the user is in. | 1 year |
| HV | This cookie is for versioning and split testing (the process of comparing two versions of a web page and measuring the difference in performance) on our website. It ensures Users remain on the appropriate versions of the site so they have a consistent experience. | 1 day |
| HX [X2] | This cookie is for versioning and split testing (the process of comparing two versions of a web page and measuring the difference in performance) on our website. It ensures Users remain on the appropriate versions of the site so they have a consistent experience. | 1 year |
| gdpr | Determines whether the visitor has accepted the cookie consent box. This ensures that the cookie consent box will not be presented again upon re-entry. | Session |
| m | Determines the device used to access the website. This allows the website to be formatted accordingly. | 400 days |
| __stripe_mid | This cookie is necessary for making credit card transactions on the website. The service is provided by Stripe.com which allows online transactions without storing any credit card information. | 1 year |
| __stripe_sid | This cookie is necessary for making credit card transactions on the website. The service is provided by Stripe.com which allows online transactions without storing any credit card information. | 1 day |
| _ab | This cookie is necessary for making credit card transactions on the website. The service is provided by Stripe.com which allows online transactions without storing any credit card information. | Session |
| eferrer, utm_source, h_p_utm_source, utm_medium, h_p_utm_medium, utm_campaign, h_p_utm_campaign, h_p_utm_term, h_p_utm_content and h_p_eid | identify from which campaigns visitors to our website originated; | 1 day |
| rc::c | This cookie is used to distinguish between humans and bots. | Session |
| _gcl_au | The cookie sets or reads an ID and then sends information about when such ID visited the site, what pages it saw and, in some cases, what products it interacted with, but no Personal data is sent | 3 months |
| _gtmeec | Pending | 3 months |
| Cart-harrys_de | Pending | Session |
| Invoice-harrys_de | Pending | Persistent |
| _uetsid [x2] | The cookie sets or reads an ID and then sends information about when such ID visited the site, what pages it saw and, in some cases, what products it interacted with, but no Personal data is sent | 1 day |
| opt_out | Used to detect if the visitor has accepted the marketing category in the cookie banner. This cookie is necessary for GDPR-compliance of the website. | 1 year |
| dicbo_id | Collects statistics concerning the visitors' use of the website and its general functionality. This is used to optimize and compile reports on the website for comparison through a third party analysis service. | 1 day |
| _mf | This cookie is necessary for making credit card transactions on the website. The service is provided by Stripe.com which allows online transactions without storing any credit card information. | Session |
| harrys.com-DE | Pending | Persistent |
Preferences Cookies
Preference Cookies enable us to provide you with a personalized browsing experience. These Cookies allow our website to remember information that modifies how the site behaves or appears, such as your preferred language or the region you're accessing the site from. Our Preferences Cookies include:
| Name | Description | Duration |
|---|---|---|
| @@scroll# | Pending | Session |
| harrys.com-DE | Pending | Persistent |
Statistical Cookies
Statistical Cookies understand how visitors use the Services by collecting information about the number of visitors to our website, what pages visitors view on our website and how long visitors are viewing pages on the website, based on your consent and our legitimate business interest in improving and maintaining the accessibility and functionality of our Services. Statistical Cookies may collect information about your online activity after you leave our Services. We also use these Cookies to help us measure the performance of our advertising campaigns, based on your consent and our legitimate business interest in improving our advertising campaigns and the content on the Services to better market to individuals who we think may be interested in our products and services. We use a number of third parties, as described below, to help deliver these Services. Our Statistical Cookies include:
| Name | Description | Duration |
|---|---|---|
| snowplowOutQueue_#_post2 | Registers statistical data on users' behaviour on the website. Used for internal analytics by the website operator. | Persistent |
| snowplowOutQueue_#_post2.expires | Registers statistical data on users' behaviour on the website. Used for internal analytics by the website operator. | Persistent |
| _sp_id.# | Collects data on the user's visits to the website, such as the number of visits, average time spent on the website and what pages have been loaded with the purpose of generating reports for optimising the website content. | 2 year |
| _sp_ses.# | Used by Snowplow Analytics to track how users are browsing and engaging with a website. | 1 day |
| collect | Used to send data to Google Analytics about the visitor's device and behavior. Tracks the visitor across devices and marketing channels. | Session |
| _dc_gtm_UA-# | Used by Google Tag Manager to control the loading of a Google Analytics script tag. | 1 day |
| _ga | Registers a unique ID that is used to generate statistical data on how the visitor uses the website. | 2 years |
| _ga_# | Used by Google Analytics to collect data on the number of times a user has visited the website as well as dates for the first and most recent visit. | 2 years |
| _gid | Registers a unique ID that is used to generate statistical data on how the visitor uses the website. | 1 day |
| td | Registers statistical data on users' behaviour on the website. Used for internal analytics by the website operator. | Session |
| FPID | Registers statistical data on users' behaviour on the website. Used for internal analytics by the website operator. | 400 days |
| FPLC | Registers a unique ID that is used to generate statistical data on how the visitor uses the website. | 1 day |
| _dd_s | Registers the website's speed and performance. This function can be used in context with statistics and load-balancing. | 1 day |
| dd_cookie_test_# | Registers data on visitors' website-behaviour. This is used for internal analysis and website optimization. | 1 day |
| _hjSession_# | Collects statistics on the visitor's visits to the website, such as the number of visits, average time spent on the website and what pages have been read. | 1 day |
| _hjSessionUser_# | Collects statistics on the visitor's visits to the website, such as the number of visits, average time spent on the website and what pages have been read. | 1 year |
| _hjTLDTest [x2] | Registers statistical data on users' behaviour on the website. Used for internal analytics by the website operator. | Sessioj |
| _hjAbsoluteSessionInProgress | Session time for HotJar Analytics, scroll/click tracking for website usage analytics, measures session length in time. | 1 day |
| _hjFirstSeen | Session timestamp for HotJar Analytics, scroll/click tracking for website usage analytics, measures session start time. | 1 day |
| _hjid | User Id for HotJar Analytics, unique id to track users’ clicks and scrolls. | 1 day |
| visitor-id | This cookie is used to collect information on the visitor. This information will be stored for internal analytics at the website's operator – Internal analytics is used by websites to optimize their domains. | 1 year |
| personalization_id | This cookie is set by Twitter - The cookie allows the visitor to share content from the website onto their Twitter profile. | 400 days |
| _pk_id# | Collects statistics on the user's visits to the website, such as the number of visits, average time spent on the website and what pages have been read. | 1 year |
| _pk_ses# | Used by Piwik Analytics Platform to track page requests from the visitor during the session. | 1 day |
| sp | Registers statistical data on users' behaviour on the website. Used for internal analytics by the website operator. | 1 year |
| _hp2_id.2002065820 | User ID for Heap Analytics, clickstream tracking for website usage analytics. | 1 year |
| _hp2_props.2002065820 | User Properties for Heap Analytics, clickstream tracking for website usage analytics. | 1 year |
| _hp2_ses_props.2002065820 | User Session Events for Heap Analytics, clickstream tracking for website usage analytics. | 1 day |
| 1 | Registers data on visitors' website-behaviour. This is used for internal analysis and website optimization. | Session |
| cksync.php [x2] | This cookie is used to determine if cookie data synchronization is enabled or disabled – cookie data synchronization is used to synchronize and gather visitor data on several domains. | Session |
Marketing Cookies
Marketing Cookies learn about the pages on our website and on Third Party Services that you visit, and thus enhance our understanding of your interests and preferences, so that we can serve you with advertisements for our products or services that we believe may be of interest to you (on the Services and elsewhere), based on your consent and our legitimate business interest in marketing to individuals we believe may be interested in our products and services. We use a number of third parties to help deliver these Services, including, for example, Google. Please see the section below titled "Additional information about interest-based advertisements" for more information. Our Marketing Cookies include:
| Name | Description | Duration |
|---|---|---|
| lastExternalReferrer | Detects how the user reached the website by registering their last URL-address. | Persistent |
| lastExternalReferrerTime | Detects how the user reached the website by registering their last URL-address. | Persistent |
| _fbp | Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers. | 3 months |
| C | Used to check if the user's browser supports cookies. | 30 days |
| pixel | Collects information on user behaviour on multiple websites. This information is used in order to optimize the relevance of advertisement on the website. | Session |
| demconf.jpg | Sets a unique ID for the visitor, that allows third party advertisers to target the visitor with relevant advertisement. This pairing service is provided by third party advertisement hubs, which facilitates real-time bidding for advertisers. | Session |
| demdex | Via a unique ID that is used for semantic content analysis, the user's navigation on the website is registered and linked to offline data from surveys and similar registrations to display targeted ads. | 180 days |
| dpm | Sets a unique ID for the visitor, that allows third party advertisers to target the visitor with relevant advertisement. This pairing service is provided by third party advertisement hubs, which facilitates real-time bidding for advertisers. | 180 days |
| anj | Registers a unique ID that identifies a returning user's device. The ID is used for targeted ads. | 3 months |
| setuid | This cookie is set by the audience manager of the website to determine the time and frequencies of visitor data synchronization - cookie data synchronization is used to synchronize and gather visitor data from several websites. | Session |
| uuid2 | Registers a unique ID that identifies a returning user's device. The ID is used for targeted ads. | 3 months |
| XANDR_PANID | This cookie registers data on the visitor. The information is used to optimize advertisement relevance. | 3 months |
| CMID | Collects visitor data related to the user's visits to the website, such as the number of visits, average time spent on the website and what pages have been loaded, with the purpose of displaying targeted ads. | 1 year |
| CMPRO | Collects data on visitor behaviour from multiple websites, in order to present more relevant advertisement - This also allows the website to limit the number of times that they are shown the same advertisement. | 3 months |
| CMPS | Collects visitor data related to the user's visits to the website, such as the number of visits, average time spent on the website and what pages have been loaded, with the purpose of displaying targeted ads. | 3 months |
| rum | Collects data related to the user's visits to the website, such as the number of visits, average time spent on the website and what pages have been loaded, with the purpose of displaying targeted ads. | Session |
| cto_bundle | Presents the user with relevant content and advertisement. The service is provided by third-party advertisement hubs, which facilitate real-time bidding for advertisers. | Persistent |
| cto_tld_test [x2] | Used to identify the visitor across visits and devices. This allows the website to present the visitor with relevant advertisement - The service is provided by third party advertisement hubs, which facilitate real-time bidding for advertisers. | 1 day |
| criteo_write_test | Sets a unique ID for the visitor, that allows third party advertisers to target the visitor with relevant advertisement. This pairing service is provided by third party advertisement hubs, which facilitates real-time bidding for advertisers. | 1 day |
| IDE | Used by Google DoubleClick to register and report the website user's actions after viewing or clicking one of the advertiser's ads with the purpose of measuring the efficacy of an ad and to present targeted ads to the user. | 1 year |
| pagead/landing | Collects data on visitor behaviour from multiple websites, in order to present more relevant advertisement - This also allows the website to limit the number of times that they are shown the same advertisement. | Session |
| test_cookie | Used to check if the user's browser supports cookies. | 1 day |
| pagead/1p-user-list/# | Tracks if the user has shown interest in specific products or events across multiple websites and detects how the user navigates between sites. This is used for measurement of advertisement efforts and facilitates payment of referral-fees between websites. | Session |
| callback | Collects data on visitor behaviour from multiple websites, in order to present more relevant advertisement - This also allows the website to limit the number of times that they are shown the same advertisement. | Session |
| car | Presents the user with relevant content and advertisement. The service is provided by third-party advertisement hubs, which facilitate real-time bidding for advertisers. | Session |
| cf | Sets a unique ID for the visitor, that allows third party advertisers to target the visitor with relevant advertisement. This pairing service is provided by third party advertisement hubs, which facilitates real-time bidding for advertisers. | Session |
| cip | Presents the user with relevant content and advertisement. The service is provided by third-party advertisement hubs, which facilitate real-time bidding for advertisers. | Session |
| cnac | Presents the user with relevant content and advertisement. The service is provided by third-party advertisement hubs, which facilitate real-time bidding for advertisers. | Session |
| gpp | Pending | Session |
| match | Sets a unique ID for the visitor, that allows third party advertisers to target the visitor with relevant advertisement. This pairing service is provided by third party advertisement hubs, which facilitates real-time bidding for advertisers. | Session |
| sync | Collects data on user behaviour and interaction in order to optimize the website and make advertisement on the website more relevant. | Session |
| data-c | Presents the user with relevant content and advertisement. The service is provided by third-party advertisement hubs, which facilitate real-time bidding for advertisers. | 30 days |
| data-c-ts | Collects data on the user across websites - This data is used to make advertisement more relevant. | 30 days |
| _uetsid | Used to track visitors on multiple websites, in order to present relevant advertisement based on the visitor's preferences. | Persistent |
| _uetsid_exp | Contains the expiry-date for the cookie with corresponding name. | Persistent |
| _uetvid | Used to track visitors on multiple websites, in order to present relevant advertisement based on the visitor's preferences. | Persistent |
| _uetvid_exp | Contains the expiry-date for the cookie with corresponding name. | Persistent |
| MSPTC | This cookie registers data on the visitor. The information is used to optimize advertisement relevance. | 1 year |
| MUID [x2] | Used widely by Microsoft as a unique user ID. The cookie enables user tracking by synchronising the ID across many Microsoft domains. | 1 year |
| suid/1017 | Presents the user with relevant content and advertisement. The service is provided by third-party advertisement hubs, which facilitate real-time bidding for advertisers. | Session |
| akaalb_Instance-1 | Pending | Session |
| #:session-data | Tracks the individual sessions on the website, allowing the website to compile statistical data from multiple visits. This data can also be used to create leads for marketing purposes. | Persistent |
| eng_mt | Tracks the conversion rate between the user and the advertisement banners on the website - This serves to optimise the relevance of the advertisements on the website. | Persistent |
| t_gid | This cookie assigns a specific visitor ID, when the visitor interacts with ads or content from the website - this allows the website to target the visitor with similar ads or content. | 1 year |
| t_pt_gid | Collects information on user preferences and/or interaction with web-campaign content - This is used on CRM-campaign-platform used by website owners for promoting events or products. | 1 year |
| taboola global:user-id | Sets a unique ID for the visitor, that allows third party advertisers to target the visitor with relevant advertisement. This pairing service is provided by third party advertisement hubs, which facilitates real-time bidding for advertisers. | Persistent |
| taboola_session_id | Creates a temporary session user ID to avoid the display of duplicate recommendations on the site | 1 day |
| um | Used to identify the visitor across visits and devices. This allows the website to present the visitor with relevant advertisement - The service is provided by third party advertisement hubs, which facilitate real-time bidding for advertisers. | Session |
| tv_UICR | Collects information on user behaviour on multiple websites. This information is used in order to optimize the relevance of advertisement on the website. | 30 days |
| tvid | Presents the user with relevant content and advertisement. The service is provided by third-party advertisement hubs, which facilitate real-time bidding for advertisers. | 1 year |
| xuid | Presents the user with relevant content and advertisement. The service is provided by third-party advertisement hubs, which facilitate real-time bidding for advertisers. | Session |
| 1/i/adsct [x2] | Collects data on user behaviour and interaction in order to optimize the website and make advertisement on the website more relevant. | Session |
| muc_ads | Collects data on user behaviour and interaction in order to optimize the website and make advertisement on the website more relevant. | 400 days |
| guest_id | Collects data related to the user's visits to the website, such as the number of visits, average time spent on the website and which pages have been loaded, with the purpose of personalising and improving the Twitter service. | 400 days |
| guest_id_ads | Collects information on user behaviour on multiple websites. This information is used in order to optimize the relevance of advertisement on the website. | 400 days |
| guest_id_marketing | Collects information on user behaviour on multiple websites. This information is used in order to optimize the relevance of advertisement on the website. | 400 days |
| uid [x2] | Registers a unique user ID that recognises the user's browser when visiting websites that use the same ad network. The purpose is to optimise display of ads based on the user's movements and various ad providers' bids for displaying user ads. | 2 months |
| receive-cookie-deprecation [x3] | Pending | 400 days |
| am_tokens | Presents the user with relevant content and advertisement. The service is provided by third-party advertisement hubs, which facilitate real-time bidding for advertisers. | 14 days |
| am_tokens_eu-v1 | Presents the user with relevant content and advertisement. The service is provided by third-party advertisement hubs, which facilitate real-time bidding for advertisers. | 14 days |
| am_tokens_invalidate-verizon-pushes | Presents the user with relevant content and advertisement. The service is provided by third-party advertisement hubs, which facilitate real-time bidding for advertisers. | 14 days |
| criteo | Presents the user with relevant content and advertisement. The service is provided by third-party advertisement hubs, which facilitate real-time bidding for advertisers. | 14 days |
| mv_tokens | Sets a unique ID for the visitor, that allows third party advertisers to target the visitor with relevant advertisement. This pairing service is provided by third party advertisement hubs, which facilitates real-time bidding for advertisers. | 14 days |
| mv_tokens_eu-v1 | Sets a unique ID for the visitor, that allows third party advertisers to target the visitor with relevant advertisement. This pairing service is provided by third party advertisement hubs, which facilitates real-time bidding for advertisers. | 14 days |
| mv_tokens_invalidate-verizon-pushes | Sets a unique ID for the visitor, that allows third party advertisers to target the visitor with relevant advertisement. This pairing service is provided by third party advertisement hubs, which facilitates real-time bidding for advertisers. | 14 days |
| ayl_visitor | This cookie registers data on the visitor. The information is used to optimize advertisement relevance. | 30 days |
| visitor/sync | This cookie is used to assign specific visitors into segments, this segmentation is based on visitor behavior on the website - the segmentation can be used to target larger groups. | Sessions |
Third Party Cookies
Some Cookies are placed by a third party on your device and may provide Cookie Information to that third party as well as to us, that indicate your browsing habits (such as your visits to our website or other Services, the pages you have visited and the links and advertisements you have clicked). These Cookies can be used to determine whether you have visited or used certain Third Party Services, to identify your interests, to retarget advertisements to you and to serve advertisements to you that we or others believe are relevant to you. For example, as indicated above, we use certain Google services including Google Analytics, which uses Cookies to analyze how users use our Services. Following a request by us, Google will use this information for the purpose of measuring your activity on our Services, compiling statistical reports on overall website activity for us and providing other services relating to such activity and internet usage. You can learn more about Google Analytics and their cookies here. If you are on the web, you can also opt out of Google Analytics by installing Google's opt-out browser add-on. We do not control third party Cookies.
Other third party websites that access and use Cookies on our website include: www.googletagmanager.com, cdn.heapanalytics.com, a3129410271.cdn.optimizely.com, logx.optimizely.com, static.hotjar.com, d.impactradius-event.com, data.adxcel-ec2.com, script.hotjar.com, sessions.bugsnag.com, www.googleadservices.com, static.criteo.net, static.ads-twitter.com, connect.facebook.net, storage.googleapis.com, bat.bing.com, b-code.liadm.com, collector-1778.tvsquared.com, s.pinimg.com, www.redditstatic.com, sc-static.net, cdn.taboola.com, cdn.pdst.fm, go.affec.tv, t.teads.tv, q.quora.com, ad.doubleclick.net, heapanalytics.com, vars.hotjar.com, t.co, sslwidget.criteo.com, gum.criteo.com, stats.g.doubleclick.net, www.facebook.com, alb.reddit.com, trc.taboola.com, us-central1-adaptive-growth.cloudfunctions.net, rp.liadm.com, tr.snapchat.com, www.google.com, www.google.co.uk, googleads.g.doubleclick.net, adservice.google.com, ct.pinterest.com, secure.adnxs.com, www.snapengage.com, adservice.google.co.uk, trc-events.taboola.com, fonts.googleapis.com, fonts.gstatic.com, cdn.siftscience.com, analytics.twitter.com and hexagon-analytics.co.m.
To the extent permissible under applicable laws, we disclaim any liability with regards to any third party’s compliance with its legal obligations.
Your browser may offer you a "Do Not Track" or "DNT" option, which allows you to signal to operators of Third Party Services that you do not wish such operators to track certain of your online activities over time and across different websites. However, because we collect browsing and persistent identifier data, our Services do not support DNT requests at this time, which means that we may collect information about your online activity both while you are using the Services and after you leave them. You should also know that certain Third Party Services may not support DNT requests either – you should check their respective privacy policies for more information.
You can decide whether or not to accept most Cookies. Most browsers allow you to delete Cookies and have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allowing you to decide whether to accept each new Cookie in a variety of ways. To explore what Cookie settings are available to you, look in the "preferences" or "options" section of your browser's menu. You can always choose to stop us from collecting your Cookie Information by turning off the Cookie feature on your browser or by ceasing to use the Services. However, if you do prevent us from collecting your Cookie Information, you should know that some of the Services may not work properly.
If you'd like to know more about Cookies, including information about how to manage, disable and delete them, you can visit https://commission.europa.eu/resources-partners/europa-web-guide/design-content-and-development/privacy-security-and-legal-notices/cookies-and-similar-technologies_en, https://ico.org.uk/for-the-public/online/cookies/, http://www.youronlinechoices.com/uk/ or http://www.allaboutcookies.org/.
ADDITIONAL INFORMATION ABOUT INTEREST-BASED ADVERTISEMENTS
We serve advertisements, and also allow third party ad networks, including third party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements are sometimes targeted to users who fit certain general profile categories or display certain preferences or behaviors (such advertisements, "Interest-Based Ads"). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, as outlined above, as well as derived from the usage patterns of particular users on the Services and/or Third Party Services over time. Such information may be gathered by us or our third party service providers through Cookies, which may include a file known as a "web beacon" from an ad network to you through the Services. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their website, allow them to serve Interest-Based Ads to you when you visit other websites, and also allow them to provide us and our advertisers with anonymized, aggregated auditing, research and reporting about advertisements.
Remember, you can always choose to stop us from collecting your Cookie Information by turning off the Cookie feature on your browser or by ceasing to use the Services. Also, you can opt out of Interest-Based Ads sourced by Google using Google's Ads Settings. For more information on how to make choices about Interest-Based Ads from participating third parties, and to learn how to opt out of receiving them from participating organizations, please visit the European Interactive Digital Advertising Alliance's user information website at http://www.youronlinechoices.eu/.
LINKS AND CONFIRMATIONS
When you open an email or an SMS, MMS or other text message, or a push notification (each, a "Message") sent by us, or click on any links in that Message, we receive a confirmation that you did so (and when), as well as Cookie Information. We also receive confirmation and Cookie Information when you click on any links elsewhere throughout the Services, including on our website and our branded pages on social media. We use the information described in this paragraph to assess the effectiveness of our Messages and associated marketing campaigns, to learn more about the audience for our Messages, and to better understand your preferences, all based on our legitimate business interest in marketing to individuals who may be interested in our services and products. You can stop receiving Messages from us at any time by emailing us at ukhelp@harrys.com.
Additionally, you should know that when you click on an advertisement for, or link to, a Third Party Service that appears anywhere on the Services, the Third Party Service or its advertiser may receive a confirmation and certain Cookie Information from you for the same purposes listed in the preceding paragraph, based on their own legitimate business interest in marketing to individuals who may be interested in their products and services. Remember, this Privacy Policy does not apply to your access or use of any Third Party Services, and we're not responsible for the content, products, services or privacy policies of those Third Party Services. We encourage you to carefully review the privacy policies of any Third Party Services you access.
INFORMATION FROM ADVERTISING AND ANALYTICS PARTNERS
We work with advertising and analytics companies that provide us with certain information about you, your interactions with us and the Services, and your usage of both the Services and Third Party Services, including your age or birthday, demographic or interest data, Cookie Information, hashed email addresses, unique identifiers assigned to you by our Advertising Partners, as well as pages or content you've viewed, links you've clicked or other actions you've taken on both the Services and on Third Party Services. We use this information in order to enhance our understanding of your interests and preferences, so that we can serve you with Interest-Based Ads and measure their effectiveness, based on our legitimate business interest in marketing to individuals who we think may be interested in our services and products. We sometimes attempt to direct Interest-Based Ads to individuals who fit a certain general category, and as a result of the information our advertising and analytics partners provide us, Interest-Based Ads or other advertisements or recommendations may appear on Third Party Services that you visit.
To collect the information described above, as well as to serve targeted advertisements to you, our advertising and analytics partners sometimes integrate their own Cookies, including web beacons, into the Services and/or into Third Party Services that you visit, as mentioned above. Remember, you can elect not to have these Cookies collect your information on the Services. Also, your browser or device may offer you a "Do Not Track" or "DNT" option, which allows you to signal to operators of Third Party Services (including, without limitation, behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites; however, we cannot and do not make any promises about how such Third Party Services will react when you set this signal on your browser.
You may also consider changing your settings to block third party Cookies generally, where possible. Again, if you'd like to know more about Cookies, including information about how to manage, disable and delete them, you can visit http://ec.europa.eu/ipg/basics/legal/cookies/index_en.htm, https://ico.org.uk/for-the-public/online/cookies/, http://www.youronlinechoices.com/uk/ or http://www.allaboutcookies.org/.
INFORMATION FROM OTHER SERVICE PROVIDERS
In addition to our advertising and analytics partners, we contract with various third party entities in order to operate our business and provide you with the Services and our products. These third parties provide us with various services described throughout this policy, including shipping and logistics, name and address verification, email distribution, market research, fraud prevention, promotions management and payment processing, and may share with us information about you that they have independently developed or acquired (in accordance with their own privacy policies and practices) for those purposes, as may be necessary for us to complete a contract with you or in furtherance of our legitimate business interests.
TRANSACTION DATA
We sometimes request and receive information about your transaction history from our Payment Processor in order to process your purchase orders and shave plans, or to enroll you in discount, rebate and other programs in which you have elected to participate and use it to verify your identity by combining it with information you provide us, based on our legitimate business interest in protecting against fraudulent transactions.
WHO WE SHARE YOUR PERSONAL DATA WITH
We share your Personal Data within our corporate family, including with our United States subsidiary, Harry's USA, Inc. We also share your Personal Data with third party vendors, service providers and agents, for the purposes and on the legal bases discussed herein, including:
• with shipping and logistics companies, our Payment Processor and others that we rely on to provide you with the Services or process and fulfill your shave plans and purchase orders, in each case, as may be necessary to complete a contract with you under our Terms of Service or your purchase orders or shave plans; and
• with advertising companies, analytics companies, marketing service providers, Epsilon Abacus and the Abacus Alliance Members (but only if you have indicated that you want us to do so), fraud detection and prevention service providers, name and address verification service providers, email providers, email verification and suppression service providers, hosting and database service providers, data security service providers, customer relationship management service providers and staff augmentation and contract personnel, in each case, based on various legitimate interests described in this Privacy Policy.
We seek to provide these third party vendors, service providers and agents with only the Personal Data they need to perform their services, and we work with them to help ensure that your privacy is respected and protected. Unless set forth in this Privacy Policy or otherwise communicated to you, these third parties do not have any rights to use your Personal Data beyond what is necessary to provide those services requested by us.
We also share your Personal Data with other third parties where you have given us your consent to do so, including for marketing purposes, based on your consent, which you may withdraw at any time, by emailing us at ukhelp@harrys.com. As stated above, you can always choose to stop receiving these messages from us by emailing us at ukhelp@harrys.com. Additionally, we share certain Cookie Information with Third Party Services where you have chosen to interact with them through the Services, such as by clicking on a link or advertisement on the Services.
PUBLIC INFORMATION
If you post information or content publicly on or through the Services (including when you submit comments or reviews of our shave plans, products or Services), or post content publicly elsewhere, including on your social media accounts, that relates to us or the Services, we may receive and share that public information with third parties, based on our legitimate business interest in marketing our products and services.
CHANGE OF OWNERSHIP OR CONTROL
If we are acquired by or merge with another company, go out of business or enter bankruptcy, or sell some or all of our assets, your Personal Data may be sold or transferred in connection with the transaction in question. If such events do take place, this Privacy Policy will continue to apply to your Personal Data.
LAWS AND SAFETY
We also reserve the right to access, read, preserve and disclose your Personal Data as we reasonably believe is necessary to:
• satisfy any applicable law, regulation, legal process or governmental request;
• enforce this Privacy Policy and our Terms of Service, including investigation of potential violations hereof or thereof; or
• protect our rights, property or safety, and those of our users, customers and the public.
However, nothing in this Privacy Policy is intended to limit your rights and remedies regarding your Personal Data, including your right to register a complaint with your local data protection authority.
HOW WE PROTECT YOUR PERSONAL DATA
We seek to protect your Personal Data using appropriate technical and organizational measures, taking into account the nature of the applicable Personal Data and processing activity. For example, all Payment Information regularly collected through the Services is encrypted and maintained using industry standard methods designed to ensure its security against loss or theft, including during transmission to our Payment Processor. However, we cannot and do not guarantee or warrant that such techniques will prevent unauthorized access to Personal Data or other information about you that we collect and store. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of such information at any time.
You can help us prevent unauthorized access to your account with us and your Personal Data by selecting and protecting your password appropriately and limiting access to your device and browser by signing off after you have finished accessing your account.
INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA
By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, may be provided to Harry’s affiliates and our authorized third party agents, vendors and service providers in the U.S. to process your Personal Data in accordance with this Privacy Policy.
In some circumstances, we may transfer your Personal Data to Harry’s, Inc. and Harry’s USA, Inc., as well as our authorized third party agents, vendors and service providers, in the U.S. pursuant (i) to a data processing agreement incorporating standard data protection clauses and/or (ii) the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”) and the UK Extension to the EU-U.S. DPF (“UK-U.S. DPF”) (collectively, the “DPF”). Harry’s complies with the DPF and has certified that it adheres to the DPF Principles (as defined below). Residents of the EU or the UK have additional rights provided by Harry’s with respect to Personal Data transferred to the U.S., as described more below.
EU and UK Resident Rights under the Data Privacy Frameworks
Harry’s complies with the DPF as set forth by the U.S. Department of Commerce and has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (“EU-U.S. DPF Principles”) with regard to the processing of all personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF (the EU-U.S. DPF Principles and the applicable principles under the UK-U.S. DPF, collectively, the “DPF Principles”). If there is any conflict between the terms in this Privacy Policy and the DPF Principles, the DPF Principles shall govern. To learn more about the DPF, and to view Harry’s, Inc.’s and Harry’s USA, Inc.’s certification, please visit https://www.dataprivacyframework.gov/.
The Federal Trade Commission has jurisdiction over Harry’s compliance with the DPF. This Privacy Policy describes the types of Personal Data we collect, the purposes for which we collect and use your Personal Data, and the purposes for which we disclose your Personal Data to certain types of third parties in the sections above. Pursuant to the DPF, EU and UK individuals have the right to obtain our confirmation of whether Harry’s maintains Personal Data relating to you in the U.S. Upon request, we will provide you with access to the Personal Data that Harry’s, Inc. and Harry’s USA, Inc. hold about you. You may also correct, amend, or delete such Personal Data. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the U.S. under the DPF, should direct their query to privacy@harrys.com. If requested to remove data, we will respond within a reasonable timeframe.
We will provide you with notice if Harry’s plans to process your Personal Data for a purpose other than those for which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your Personal Data, please submit a written request to privacy@harrys.com.
In addition to any other disclosures described in our Privacy Policy, in certain situations, Harry’s may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Harry’s accountability for Personal Data that it receives in the U.S. under the DPF and subsequently transfers to a third party acting as an agent on its behalf is described in the DPF Principles. In particular, Harry’s, Inc. and Harry’s USA, Inc. remain liable under the DPF Principles if their agents process Personal Data in a manner inconsistent with the DPF Principles, unless they are able to prove that they are not responsible for the event giving rise to the damage.
In compliance with the DPF, Harry’s commits to resolve DPF Principles-related complaints about its collection and use of your Personal Data. EU and UK individuals with inquiries or complaints regarding its handling of personal data received in reliance on the DPF should first contact Harry’s at privacy@harrys.com.
In compliance with the DPF, Harry’s commits to refer unresolved complaints concerning its handling of personal data received in reliance on the DPF to JAMS, an alternative dispute resolution provider based in the U.S. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/dpf-dispute-resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you.
If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Annex 1 of the DPF Principles, located at:
https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2.
WHAT YOUR RIGHTS ARE TO YOUR PERSONAL DATA, AND HOW YOU CAN EXERCISE THEM
You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request with respect to these rights, you can email ukhelp@harrys.com or otherwise exercise these rights through the methods set out below. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous, inaccurate or extremely impractical, if it jeopardizes the rights of others or if it is not required by law, but in those circumstances we will still respond to notify you of such a decision. In some cases, we may need you to provide us with additional information, which may include Personal Data, as necessary to verify your identity and the nature of your request.
RIGHT OF ACCESS
• Where permissible, you can request more information about the Personal Data we hold about you and you can request a copy of your Personal Data by accessing our Privacy Request Center. If you have an active account with us, you can also access your Personal Data by visiting your account settings on our website.
RIGHT OF RECTIFICATION
• If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such Personal Data. You can also correct some of this Personal Data directly by visiting your account settings on our website.
RIGHT OF ERASURE
• Where permissible, you can request that we erase some or all of your Personal Data from our systems by accessing our Privacy Request Center. You can also delete your account with us at any time by emailing us at ukhelp@harrys.com.
RIGHT TO WITHDRAW CONSENT
• If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent to this processing at any time, which you can do by emailing us at ukhelp@harrys.com. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
RIGHT TO OBJECT TO PROCESSING AND TO RESTRICT PROCESSING
• Where permissible, you can let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as marketing to you (to name one example), and you can also ask us to restrict further processing of your Personal Data.
RIGHT OF PORTABILITY
• Where permissible, you can ask for a copy of your Personal Data in a machine-readable format, and you can also request that we transmit the data to another controller where technically feasible.
RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY
• You have the right to lodge a complaint about our practices with respect to your Personal Data with the Information Commissioner’s Office. Please visit https://ico.org.uk/global/contact-us/ or call 0303 123 1113 for more information.
OUR PERSONAL DATA RETENTION POLICY
We retain your Personal Data for as long as you have a working account with us, or as otherwise necessary to provide you with the Services. In some cases we retain Personal Data for longer, if doing so is necessary to pursue our legitimate business interests (but only if those interests are not overridden by your own interests, rights and freedoms), comply with our legal obligations, resolve disputes or collect fees owed, conduct audits, or if doing so is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we dispose of your Personal Data securely, but may retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.
As stated above, you can delete your account with us at any time, by emailing us at ukhelp@harrys.com, and you can request us to erase some or all of your Personal Data from our systems by emailing us at ukhelp@harrys.com or visiting our Privacy Request Center.
ANY QUESTIONS OR CONCERNS?
If you have any questions or concerns regarding how we collect, use, protect or share your Personal Data, including, for example, about our legitimate business interests or the legitimate business interests of others that we describe above, please send a detailed message to ukhelp@harrys.com or to our Data Protection Officer directly at security-council@harrys.com. You can also reach out to Harry's Grooming Limited at its registered office located at 5th Floor 101 St Martins Lane, London, United Kingdom, WC2N 4AZ. We will make every effort to resolve your concerns.
EFFECTIVE DATE: MAY 2024