Last Updated: 10/23/2024

This Privacy Policy describes how The Beard Club, Inc. (“The Beard Club,” we,” “us,” or “our”) collects, uses, and discloses your personal information when you visit or make a purchase from http://www.thebeardclub.com (the “Site”) or our other online or offline offerings which link to, or are otherwise subject to this Privacy Policy (collectively, the “Services”).

Disclosure Regarding the California Consumer Privacy Act (Notice at Collection). For information on our processing of personal information that is subject to the California Consumer Privacy Act (“CCPA”), please see Annex A – Supplemental CCPA Privacy Notice.

 PERSONAL INFORMATION WE COLLECT

A.  Personal Information You Provide Directly to Us

We collect personal information that you provide to us, personal information we collect automatically when you use the Services, and personal information from third-party sources, as described below.

We may collect personal information that you provide to us. 

·       Account Information. We may collect personal information in connection with the creation or administration of your account. This personal information may include, but is not limited to, your name, email address, phone number, and other information you store with your account. 

·       Order Information. When you make a purchase or attempt to make a purchase through the Site, we collect certain personal information from you, including your name, billing address, shipping address, email address, and phone number. Any payments made via our Services are processed by third-party payment processors. 

·       Your Communications with Us. We, and our service providers, may collect the information you communicate to us, such as through email or when you complete the quiz on our website. 

·       Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the survey. 

·    Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., messaging and chat features, commenting functionalities, forums, blogs, and social media pages).  Any information you provide using the public sharing features of the Services will be considered “public.”

·    Sweepstakes or Contests. We may collect personal information you provide for any sweepstakes or contests that we offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.

·       Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.

·       Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.

·       Job Applications. If you apply for a job with us, we will collect any personal information you provide in connection with your application, such as your contact information and CV.

 B. Personal Information Collected Automatically

 We may collect personal information automatically when you use the Services. 

·   Device Information. When you visit the Services, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device.

·    Usage Information. We may collect personal information about your use of the Services, such as the pages or products that you view, what websites or search terms referred you to the Services,  items that you search for, the types of content you interact with, information about the links you click, the frequency and duration of your activities, and other information about how you use or interact the Services.

·       Cookie Notice (and Other Technologies). We, as well as third parties, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect personal information through your use of the Services. For example, we may use such Technologies, to help keep track of items you put into your shopping cart including when you have abandoned your cart and this information is used to determine when to send cart reminder messages via SMS.

o  Cookies. Cookies are small text files stored in device browsers.

o  Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects personal information about use of or engagement with the Services. The use of a pixel tag allows us to record, for example, that a user has visited, a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

C. Personal Information Collected from Third Parties

We may collect personal information about you from third parties.  For example, if you access the Services using a Third-Party Service (defined below), we may collect personal information about you from that Third-Party Service that you have made available via your privacy settings. In addition, if another user refers you to the Services, we may receive information about you from that user.

HOW WE USE YOUR PERSONAL INFORMATION

We use personal information for a variety of business purposes, including to provide the Services, for administrative purposes, and to provide you with marketing materials, as described below.

A.    Provide the Services

We use personal information to fulfill our contract with you and provide the Services, such as:

·     Managing your information;

·   Providing access to certain areas, functionalities, and features of the Services;

·      Answering requests for support;

·      Communicating with you;

·   Sharing personal information with third parties as needed to provide the Services;

·    Processing your financial information and other payment methods for products and Services purchased;

·  Processing applications if you apply for a job we post on our Services; and

·     Allowing you to register for events.

B.    Administrative Purposes

We use personal information for various administrative purposes, such as: 

·    Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;

·  Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;

·       Carrying out analytics;

·       Measuring interest and engagement in the Services;

·       Improving, upgrading, or enhancing the Services;

·       Developing new products and services;

·       Creating de-identified and/or aggregated information. If we create or receive de-identified information, we will not attempt to reidentify such information, unless permitted by, or required to comply with, applicable laws;

·       Ensuring internal quality control and safety;

·      Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Policy;

·       Debugging to identify and repair errors with the Services;

·     Auditing relating to interactions, transactions, and other compliance activities;

·       Enforcing our agreements and policies; and

·   Carrying out activities that are required to comply with our legal obligations.

C.    Marketing

We may use personal information to tailor and provide you with both online and offline marketing and other content. We may provide you with these materials as permitted by applicable law. 

Some of our marketing activities may be considered a “sale” or “targeted advertising” under applicable privacy laws.

If you have any questions about our marketing practices, you may contact us at any time as set forth in the “Contact Us” section below.

D.    With Your Consent or Direction 

We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information, with your consent, or as otherwise directed by you.

HOW WE DISCLOSE YOUR PERSONAL INFORMATION

 We may disclose your personal information to third parties for a variety of business purposes, including the following: 

A.    Disclosures To Provide the Services 

·       Service Providers. We may share your personal information with third parties to third-party service providers that assist us with the provision of the Services 

For example, we use Shopify to power our online store--you can read more about how Shopify uses your personal information by reviewing the Shopify Privacy Policy. 

We also use Google Analytics to help us understand how our customers use the Site -- you can read more about how Google uses your personal information by reviewing the Google Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your personal information, please click here.

We also use Kount to assist with fraud prevention and related services. You can read more about how Kount uses your personal information by reviewing the Kount Privacy Policy.

·       Advertising Partners. We may share your personal information with third-party advertising partners and service providers to facilitate and personalize online and offline communication about products and services that may be of interest to you based on your activities on the site and other interactions with you. 

Some of these third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising”, “personalized advertising,” or “targeted advertising.” 

You can opt out of targeted advertising from the partners listed below by using the following links:

o   Facebook

o   Google

o   Bing 

For more information on how to opt-out of targeted advertising via Technologies, view the “Your Privacy Choices and Rights” section below.

In addition to targeted advertising, when you visit our Services, Technologies may be used by advertising partners we work with to associate your online activities with other personal information they or others have about you, including by association with your email or home address. We (or these advertising partners on our behalf) may then send communications and marketing to these email or home addresses.

·       Other Users You Share or Interact With. The Services may allow Beard users to share personal information of users of the Services (including the general public).

·       Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.

Once your personal information is shared with our business partner, it will also be subject to our business partner’s privacy policy. We are not responsible for the processing of personal information by our business partners. 

B.    Disclosures to Protect Us or Others

We may also share your personal information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights. 

C.    Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be disclosed, sold, or transferred as part of such a transaction.

YOUR PRIVACY CHOICES AND RIGHTS

A.    Your Privacy Choices. The privacy choices you may have about your personal information are described below

·       Email Communications. If you receive an unwanted email from us, you can use the unsubscribe functionality found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails. We may also send you certain non-promotional communications regarding us and the Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to this Privacy Policy).

·       Text Messages. If you subscribe to The Beard Club text notifications, you agree to receive automated marketing text messages from us about our products and services at the phone number you provided when you subscribed. Message frequency is recurring. You are not required to sign-up to receive text messages as a condition of purchase. Message and data rates may apply. 

You may opt out of receiving future text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us as set forth in the “Contact Us” section below.

·       “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers

·       Cookies. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, the Services may not work properly. 

Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of certain tracking on some mobile applications by following the instructions for Android, iOS, and others.

The online advertising industry also provides mechanisms that may allow you to opt out of receiving targeted ads from organizations that participate in self-regulatory programs. To learn more, visit the Network Advertising Initiative. 

B.    Your Privacy Rights.

In accordance with applicable law, you may have the right to:

·       Confirm Whether We Are Processing Your Personal Information; 

·       Request Access to or Portability of Your Personal Information;

·       Request Correction of Your Personal Information; 

·       Request Deletion of Your Personal Information; and 

·       Request to Opt-Out of Certain Processing Activities including, as applicable, if we process your personal information for “targeted advertising” (as “targeted advertising” is defined by applicable privacy laws),  if we “sell” your personal information (as “sell” is defined by applicable privacy laws), or if we engage in “profiling” in furtherance of certain “decisions that produce legal or similarly significant effects” concerning you (as such terms are defined by applicable privacy laws).

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. 

To opt out of our “sale” or “targeted advertising” activities which rely on cookies or similar technologies, you can install the Ghostery ad-blocker browser plug-in and block our use of advertising cookies via that tool or you can otherwise configure your Internet browser to prohibit advertising cookies from being set.

To opt out of our “sale” or “targeted advertising” activities that do not rely on the use of cookies or similar technologies, please contact us as set forth in “Contact Us” below.

We will process such requests in accordance with applicable laws.

Only you, or someone legally authorized to act on your behalf in certain jurisdictions, may make a request to exercise the rights listed above regarding your personal information. If your personal information is subject to a law that allows an authorized agent to act on your behalf in exercising your privacy rights and you wish to designate an authorized agent, please provide written authorization signed by you and your designated agent using the information found in “Contact Us” below and ask us for additional instructions.

To protect your privacy, we will take steps to verify your identity before fulfilling requests submitted under applicable privacy laws. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Examples of our verification process may include asking you to confirm the email address we have associated with you.

Some laws may allow you to appeal our decision if we decline to process your request. If applicable laws grant you an appeal right, and you would like to appeal our decision with respect to your request, you may do so by informing us of this and providing us with information supporting your appeal.

INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION 

All personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live.

CHANGES

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. If we do, we’ll let you know by posting the updated Privacy Policy on our website, and/or we may also send other communications.

CHILDREN’S PERSONAL INFORMATION

The Services are not directed to children under 16 (or other age as required by local law outside the United States), and we do not knowingly collect personal information from children.

If you are a parent or guardian and believe your child has uploaded personal information to the Services in violation of applicable law, you may contact us as described in “Contact Us” section below.

THIRD-PARTY WEBSITES/APPLICATIONS

The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

CONTACT US

If you have questions about our privacy practices, or to exercise your rights described in this Privacy Policy, please contact us at:

Email: privacy@thebeardclub.com

ANNEX A – SUPPLEMENTAL CCPA PRIVACY NOTICE

This Supplemental CCPA Privacy Notice supplements our Privacy Notice and only applies to our processing of personal information that is subject to the CCPA. 

NOTICE AT COLLECTION

At or before the time of collection, California residents have a right to receive notice of our privacy practices. California residents can find this information below.

·       Personal Information Collected. See the section of this Supplemental CCPA Privacy Notice titled “Overview of Personal Information Collected, Disclosed, Sold and/or Shared” for a list of personal information which may be collected. If we have previously collected personal information in the past 12 months, we may collect that personal information from you.

·       Uses of Personal Information. See the section of this Supplemental CCPA Privacy Notice titled “Uses of Personal Information” for a list of the purposes for which we use personal information.

·       Is Personal Information “Sold” or “Shared” for “Cross-Context Behavioral Advertising”? Yes. See the section of this Supplemental CCPA Privacy Notice titled “Overview of Personal Information Collected, Disclosed, Sold and/or Shared” for more details. If we have previously “sold” personal information or “shared” personal information for “cross-context behavioral advertising” in the past 12 months, we may “sell” or “share” that personal information if collected from you. See the section of this Supplemental CCPA Privacy Notice titled “Right to Opt Out of ‘Sales’ of Personal Information and/or ‘Sharing’ for ‘Cross-Context Behavioral Advertising’” for instructions on how to opt-out of these activities.

·       How Long is Personal Information Retained For? To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.

·       Additional Information. For more information on our privacy practices, please review this Supplemental CCPA Privacy Notice and our Privacy Notice. Importantly, the section of our Privacy Notice titled “Your Privacy Rights” includes important details about how you can exercise some of the rights which you have under the CCPA. 

CATEGORIES OF SOURCES FROM WHICH PERSONAL INFORMATION IS COLLECTED

We collect personal information that you provide to us, personal information we collect automatically when you use the Services, and personal information from third-party sources. 

OVERVIEW OF PERSONAL INFORMATION COLLECTED, DISCLOSED, AND/OR SHARED 

The CCPA provides California residents with the right to know what categories of personal information The Beard Club has collected about them, whether The Beard Club disclosed that personal information for a business purpose (e.g., to a service provider), whether The Beard Club “sold” that personal information, and whether The Beard Club “shared” that personal information for “cross-context behavioral advertising” in the preceding twelve months. California residents can find this information below:

USES OF PERSONAL INFORMATION

We may use and disclose the personal information that we collect for the following business and commercial purposes: 

·       Providing the Services as further described in our Privacy Policy;

·       Processing for administrative purposes as further described in our Privacy Policy;

·       Processing for marketing purposes as further described in our Privacy Policy;

·       Processing with your consent or direction as further described in our Privacy Policy;

·       Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;

·       Helping to ensure security and integrity to the extent the use of personal information is reasonably necessary and proportionate for these purposes;

·       Debugging to identify and repair errors that impair existing intended functionality;

·       Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your current interaction with The Beard Club;

·       Maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar Services;

·       Providing advertising and marketing services;

·       Undertaking internal research for technological development and demonstration;

·       Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by The Beard Club, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by The Beard Club. 

RIGHT TO OPT OUT OF "SALES" OF PERSONAL INFORMATION AND/OR "SHARING" FOR "CROSS-CONTEXT BEHAVIORAL ADVERTISING"

We “sell” your personal information or “share” your personal information for “cross-contextual behavioral advertising” to provide you with advertising about The Beard Club’s products and services.

California residents have the right to opt out of the “sale” of personal information and the “sharing” of personal information for “cross-context behavioral advertising.” 

California residents may opt out of our “sale” or “sharing” activities which rely on cookies or similar technologies, by installing the Ghostery ad-blocker browser plug-in and blocking our use of advertising cookies via that tool or they can otherwise configure their Internet browser to prohibit advertising cookies from being set.

California residents may opt out of our “sale” or “sharing” activities that do not rely on the use of cookies or similar technologies, by contacting us as set forth in “Contact Us” in the Privacy Policy.

DISCLOSURE REGARDING INDIVIDUALS UNDER THE AGE OF 16

The Beard Club does not have actual knowledge of any “sale” of personal information of minors under 16 years of age. The Beard Club does not have actual knowledge of any “sharing” of personal information of minors under 16 years of age for “cross-context behavioral advertising.”

DISCLOSURE REGARDING SENSITIVE PERSONAL INFORMATION

The Beard Club only uses and discloses sensitive personal information for the purposes set forth in Section 7027(m) of the CCPA regulations.

NON-DISCRIMINATION

California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

NOTICE OF FINANCIAL INCENTIVE

This Notice of Financial Incentives aims to inform you about any programs, benefits, and other financial incentive offerings, including price or service differences (collectively, “Incentive Offerings”), that we may provide in connection with the collection of your personal information so that you may make an informed decision on whether to participate in our Incentive Offerings. Such Incentive Offerings may be deemed “financial incentives” under the CCPA. 

The material aspects of any Incentive Offering, along with the personal information collected in connection with an Incentive Offering, will be described at the time you are presented with the Incentive Offering.

Examples of our Incentive Offerings may include: 

·       One-Time Discount. We may offer you a discount on your first order if you provide us your email address and agree to receive marketing emails in exchange for a one-time discount. 

·       Refer-a-Friend Program. We may offer a discount on your future purchase when you provide your personal information along with your friends’ or colleagues’ personal information, and they make a purchase. The referred party may also receive a reward in the form of a discount on the first order and/or a free service for making a purchase through your referral. 

You can opt-in to an Incentive Offering by following the instructions that accompany the presentation of the Incentive Offering. If you subsequently wish to withdraw from the Incentive Offering, you may request such withdrawal by contacting us as set forth in “Contact Us” above. 

Each Incentive Offering may be based upon our reasonable and good-faith determination of the estimated value of such offer to our business, taking into consideration the value of the offer itself and the anticipated revenue generation that may be realized.