Privacy Policy

This Privacy Policy describes the policies and procedures of Stirrdup, Inc. and its subsidiaries ) (“we”, “our” or “us”) on the collection, use and disclosure of personal information from those who use or access Stirrdup.com, our blog, our branded pages on social media services, or any of the other sites, services, features, content, applications and products we offer in the United Kingdom (“UK”) (collectively, the “Services”). If you are using the Services outside of the UK, a location-specific privacy policy may apply to you instead, so please check the applicable country-specific website. We receive information about you from various sources, including, without limitation: (i) when you visit our websites; (ii) if you register for the Services, through your user account on the Services (your “Account”); (iii) your use of the Services generally, including any purchases that you make on the Services; and (iv) from third party websites and services that interact with our Services.

CONSENT

When you visit Stirrdup.com or otherwise use the Services, you are consenting to the collection, storage, disclosure and other uses of your information as permitted by this Privacy Policy.

The Services are hosted and operated in the United States through Stirrdup’s, Inc. and its Business Partners (defined below). By using the Services, you acknowledge that any Personal Information (defined below) that you provide to us is being provided to us in the United States and will be hosted on United States servers. Stirrdup’s, Inc. is registered under the EU-US Privacy Shield Framework. Please see below for more details.

WHAT DOES THIS PRIVACY POLICY COVER?

This Privacy Policy covers our treatment of personally identifiable information (“Personal Information”) gathered when you are using or accessing the Services, as well as our treatment of any Personal Information that our partners, service providers and other persons and entities with whom we conduct business (“Business Partners”) share with us, or that we share with our Business Partners where permitted pursuant to the section titled “Information Shared with or by Our Business Partners” below. Please see below for more information on the categories of Business Partners with which we work.

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, although 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.

NOTICE OF EU-US PRIVACY SHIELD PARTICIPATION

We are headquartered in the U.S. Stirrdup’s, Inc. and its U.S. subsidiary, Stirrdup’s USA, Inc., both comply with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of Personal Information transferred from the European Union to the United States. We have certified to the Department of Commerce that we adhere to the seven Privacy Shield Principles of (1) notice, (2) consent, (3) accountability for onward transfer, (4) security, (5) data integrity and purpose limitation, (6) access and (7) recourse, enforcement and liability, in relation to any Personal Information that we receive from within the European Union (the “Privacy Shield Principles”). Principle 7, the recourse, enforcement, and liability principle, provides that we remain potentially liable if a third party processing Personal Information received from the European Union on our behalf processes that Personal Information in a manner that is inconsistent with the Privacy Shield Principles (unless we can prove that we are not responsible for the event giving rise to the damage). Stirrdup’s, Inc. and Stirrdup’s USA, Inc. are subject to the investigatory and enforcement powers of the Federal Trade Commission with respect to any failure to comply with the Privacy Shield Principles.

If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/. European Union individuals with inquiries or complaints regarding U.S. privacy practices should contact us at here, or can follow the process set forth below in the section titled “What if I Have Questions, Concerns, or Complaints?” below.

Notice of what information we collect and how we use it

We collect your Personal Information in connection with your use of the Services and process your information in accordance with this Privacy Policy at all times.

WHAT INFORMATION DO WE COLLECT?

In connection with certain aspects of the Services, we may request, collect, display and/or disclose some of your Personal Information. From time to time, we may also supplement information we collect from you with other information we collect or with information we receive from third parties, which may include associating non-personally identifiable information with Personal Information. The information we gather, including the types of information described below, enables us (or, as applicable, our Business Partners, pursuant to the section titled “Information Shared with or by Our Business Partners” below) to personalize, improve and continue to operate the Services or to provide you with information, products and services that we believe may be of interest to you (unless you indicate otherwise). Except as otherwise specified below, such information may be used by us (or, as applicable, our Business Partners, pursuant to the section titled “Information Shared with or by Our Business Partners” below) in connection with such purposes set forth in this Privacy Policy.

ACCOUNT INFORMATION:

We (directly or delivered through our Business Partners pursuant to the section titled “Information Shared with or by Our Business Partners” below) may use such Personal Information and any transaction data relating to your Account or other information relating to your use of the Services for purposes relating to our business or otherwise permitted by this Privacy Policy, including, without limitation, to send you information which we think you might find useful or of interest about our Services where you have indicated you do not object to receiving such information. You may choose not to receive these messages when you register an Account with us by selecting the check box to opt-out or you can unsubscribe from these messages by clicking the “Unsubscribe” link at the bottom of any email message from us or by contacting us directly here.

INFORMATION REGARDING YOUR SOCIAL NETWORKS:

As mentioned above, you may be able to register for or access the Services using Third Party Services, such as your social media accounts (e.g., Facebook, Twitter, etc.) (“Social Media Services”). Occasionally, you can also use your Account on our Services to interact with your accounts on Social Media Services. For example, you may be able to access posting and sharing tools on the Services that allow you to post information to your Social Media Services (“Share”) or interact with us through Social Media Services, such as by tagging us or our products on such services. When you use these tools or tag or mention us or our products, or otherwise interact with us through Social Media Services, you acknowledge and agree that some information and content relating to your account on the applicable Social Media Services may be transmitted to us, and that our use of such information is covered by this Privacy Policy, and you hereby allow us to use such information or content in connection with our business, including across our properties and for commercial purposes, or as otherwise permitted by this Privacy Policy. Furthermore, when you use these tools or post to our Services, we may share some of your information and content from our Services with certain Social Media Services, including through our branded pages on such Social Media Services, and such information, including how information is shared with us, and such content would be subject to the privacy policies of such Social Media Services and your privacy settings with such Social Media Services. Additionally, if a tool, such as the Share tool, is operated by a Third Party Service, the Third Party Service that operates the tool may collect information about your browser or online activity, which is subject to such Third Party Service’s privacy policy. Therefore, we encourage you to read the privacy policies, and other policies, of any Third Party Services, and review your privacy settings on such Third Party Services, including any applicable Social Media Services, that you use in connection with the Services.

We may also collect and receive your Social Media Services login credentials in connection with providing you with the Services, but only if you expressly provide us with such information. We will only use such login information as permitted by this Privacy Policy or as otherwise expressly authorized by you and your settings with such Social Media Services. Please review your applicable Social Media Services’ respective privacy settings and their associated privacy policies to understand more about disclosures of information from your Social Media Services.

USER CONTENT:

Some features of the Services may now or in the future allow you to provide content, such as written comments or reviews, to the Services, including through Social Media Services as described above. We may use or continue to disclose such content to Business Partners pursuant to the section titled “Information Shared with or by Our Business Partners” below, including, but not limited to, after you have finished using the Services as permitted by this Privacy Policy.

SHIPPING AND BILLING INFORMATION:

If you place an order through the Services, we will ask you for your shipping address, telephone number and credit card information and/or certain other Personal Information about you. We use this information for purposes such as processing and fulfilling your orders, notifying you of your order status and otherwise communicating with you in connection with the Services. We also retain this information as part of your Account for your convenience in making future purchases.

All credit card information and shipping 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 (the “Payment Processor”), which is currently Stripe. Please note that your financial information, such as your payment method (valid credit card number, type, expiration date or other financial information) is used and stored by our Payment Processor, 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 (for Stripe, available at: https://stripe.com/gb/legal and https://stripe.com/gb/privacy or any of its successor sites). We may from time to time request and receive information about you and the products you have bought or ordered from our Payment Processor or from you directly for the purposes of completing transactions you have initiated through the Services, enrolling you in discount, rebate, and other programs in which you elect to participate, protecting against or identifying possible fraudulent transactions, and otherwise as needed to manage our business.

COMMUNICATIONS WITH US:

We may collect Personal Information when you communicate with us. For example, if you choose to send us Personal Information by sending us an email, completing a survey or contacting our customer service department, we will keep a record of that communication and may collect and use Personal Information that you provide to us in accordance with this Privacy Policy. If we communicate with you via email, SMS, MMS or other text message (“Text Message”) or push notifications (to the extent you permit us to do so), we may collect information regarding such communications, such as confirmation when you open an email, read a Text Message or receive a push notification. We use this information for purposes such as to operate and improve our Services, including our customer service, or as otherwise permitted by this Privacy Policy.

COOKIES AND OTHER SIMILAR TECHNOLOGIES:

We and our third party service providers automatically receive and record information from your web browser when you interact with the Services, including your IP address, browser type, ISP, referring/exit pages and cookie information. This information may also include device-specific information if you access the Services using a mobile device, such as unique device identifiers, network information, and hardware model, as well as information about how the device interacts with our Services and information about where you access the Services from. This information is used for a number of purposes, including, without limitation, to deliver a personal, customized and streamlined service during your use of the Services and your online experience, to fight malware and to facilitate analyses of data concerning registered and unregistered users’ interaction with the Services (e.g., what links you have clicked on).

When you access the Services, we and our third party service providers and Business Partners collect information as described above from cookies, pixels and other similar technology. Cookies are pieces of text that may be provided to your computer through your web browser when you access a website. Your browser stores cookies in a manner associated with each website you visit. Some cookies last only for the duration of your web session and expire when you exit the browser, while other cookies may remember you when you return to our Services, as you continue your web session and after you exit the browser. We use cookies to enable our servers to recognize your web browser and tell us how and when you visit and otherwise use the Services through the Internet, to analyze trends, and to learn about our customers and user base, including by helping us to understand how effective our marketing initiatives are.

We may combine non-personally identifiable information collected through cookies with other Personal Information that we have about you, for example, to tell us who you are or whether you have an Account. We may also supplement the information we collect from you with information received from third parties in order to enhance our Services, or to offer you information that we believe may be of interest to you.

Most browsers 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. Most browsers allow you to block and delete cookies. However, if you do that, some of the Services may not work properly.

You can learn more about cookies by visiting www.allaboutcookies.org, which includes additional useful information about cookies and how to block cookies using different types of browsers.

We use different types of cookies on our Services:

Type of Cookies Description and Further Information
Essential Cookies Essential cookies are cookies that enable you to navigate and use all of the features provided through our Services. Without these, you would not be able to navigate between pages or use certain features.
Functionality Cookies Functionality cookies enable us to remember whether you have previously visited our site, including any preferences you may have previously selected, to help us give you a tailored experience.

For example:

h_cart : notes the contents of your cart before checkout so that if you navigate away from your basket and return to us, we will remember what was in your cart;

h_sess : identifies you to our servers after you log in to your Account;

flash: temporarily stores messages and alerts that we display on-screen to you;

h_personalization: identifies your relationship with us (e.g., whether you have previously made a purchase from us or signed up for a shave plan);

split: stores your participation variations in content we post so that we may show you different content and help us identify which content is most useful to you.

Performance and Analytical Cookies Performance and analytical cookies are used to help ensure that our Services can support the number of visitors we get and to help correct any errors on the Services.

They also help us understand if you have interacted with these Services before or if you are a unique visitor. We can also see which parts of the Services are the most popular.

We use third parties, such as Google Analytics, to analyse statistical information from users of our Services. Please see below for more information.

For example:

h_eph_sess: a short-lived unique identifier that we use to see if you arrive to the Site and whether this could be linked to any offline advertising like TV or radio advertisements;

ga: Google Analytics identifier, a third party cookie served by Google. Please see below for further detail.

Retargeting and Advertising Cookies Retargeting and advertising cookies collect information about the pages on our Site that you visit and other information about other websites you visit, in order to place you in a “market segment”. This information is collected by reference to the cookie or other unique identifier. This may result in your seeing advertisements for our products you may be interested when visiting other websites or apps.

We use a number of third parties as described below to help deliver these Services, such as Google (AdWords, Google Display Network, DoubleClick (including Noble Media)), BizoID and Optimizely. Please see below for further detail.

COOKIES ANALYTICS AND ADVERTISING SERVICES PROVIDED BY OTHERS AND THE USE OF WEB BEACONS:

We use third party companies such as ad servers, ad agencies, ad technology vendors and research firms (“adtech companies”) to serve advertisements on our behalf, to measure the effectiveness of our advertising and to identify people who are most likely to respond to our advertisements. Our advertisements may be targeted to users who fit a certain general profile category and may be based on (i) anonymized information inferred from information provided to us by a user, including Personal Information (e.g., gender or age); (ii) usage patterns with respect to the Services; or (iii) user activity on Third Party Services.

To increase the effectiveness of ad delivery, we may also deliver a file (known as a “web beacon”) from an adtech company to you. Web beacons allow adtech companies to provide anonymized, aggregated auditing, research and reporting for us and for other advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Because your web browser must request these advertisements and web beacons from an ad network’s servers, these adtech companies can view, edit or set their own cookies, just as if you had requested a web page from their site.

We may use one or more Third Party Services to provide audience measurement and analytics services to us, to serve ads across the Internet on our behalf, to track and report on the performance of those advertisements, and/or to collect information via the Services for marketing and advertising purposes. To do so, these Third Party Services may use information about your visits to the Services and other Third Party Service websites, your interaction with our products and the Services, and they may also use cookies, web beacons, pixel tags, SDKs, and other technologies to identify your device when you visit or use our Services, as well as when you visit other online sites and services, including your IP address, web browser, pages viewed, time spent on different pages, websites and apps, across various devices, links clicked and conversion information. As a result of some of these services, targeted or interest-based advertisements or recommendations may appear on other sites that you visit.

If you would like more information about this practice and how to opt out of having your web browsing information used for behavioral advertising purposes, please visit http://www.youronlinechoices.com/

At present, some of the third party cookies include:

  • Atlas Universal Tags:

These services allow us to measure the performance of our advertising network against purchases or other interactions customers have with our Services. You can opt out of the Atlas Universal Tags by visiting http://www.youronlinechoices.com/uk/.

  • Google:

We use a variety of Google services including: Google Analytics, a web analytics service provided by Google, Inc. (“Google”), which uses cookies to analyse how users use our Services. The information generated by the cookie about your use of the Services will generally be transmitted to and stored by Google on servers in the United States. 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. Google will not associate your IP address with any other data held by Google.

You can prevent the collection of the data generated by the cookies used by Google, as well as the processing of this data by Google, by downloading and installing the browser plug-in available from the following link: http://tools.google.com/dlpage/gaoptout.

Other Google Services include Advertising Features such as Adwords, Google Display Network Impression reporting and IDE for DoubleClick (including Noble Media).

DoubleClick and Adwords are advertising solutions provided by Google. These are services administered by Google for businesses wanting to display ads on Google and its advertising network. You can find out more and opt out of these Google services by visiting: https://support.google.com/ads/answer/2662922?hl=en-GB, https://www.google.com/settings/ads/plugin or https://support.google.com/ads#topic=7049263.

Google Display Network Impression allows us to see the effects of different ad types and whether or not customers make a purchase after having interacted with the ad. You can opt out of the Google Display Network Impression reporting by visiting https://support.google.com/ads/answer/2662922?hl=en.

 

 

Please note that even if you choose to opt out of having information collected for behavioral advertising purposes, you may still see advertisements while you are browsing online; however, such advertisements may be less relevant to you and your interests. Please note that if you opt out of targeted advertising, we may still track your visits to our Services for analytics, operations and security purposes.

onward transfer: HOW, AND WITH WHOM, IS MY INFORMATION SHARED?

In addition to the sharing of your information as set forth in the section titled “Cookies and Other Technologies, in delivering the Services to you, we may also share your information in the following ways:

PUBLIC INFORMATION ABOUT YOUR ACTIVITY ON THE SERVICES:

Some of your activity on and through the Services may be public, such as content that you have posted publicly in connection with the Services, including on your social media accounts. Registered users may have some of the information about their activity on and through the Services associated with their Accounts, such as reviews of our Services.

INFORMATION SHARED WITH OR BY OUR BUSINESS PARTNERS:

We contract with various Business Partners for services related to our business, including, among other services, shipping, name and address verification, email distribution, market research, third party advertising, fraud prevention, promotions management and payment processing (as discussed above). We provide these Business Partners with only the information they need to perform their services and we work closely with them to ensure that your privacy is respected and protected. With your consent, where required, we may also share your information, which may include Personal Information, with Business Partners in connection with providing you with information, products or services that we think may interest you, and such Business Partners may contact you about their products and/or services. For clarity, only those of our employees and Business Partners who need access to your credit card information in order to perform their duties are allowed such access.

Pursuant to our use of cookies as set forth in this Privacy Policy, we may share IP address and similar device or other automatically collected information with our Business Partners and as otherwise permitted by this Privacy Policy. For example, we may share information with our Business Partners who provide analytics, marketing, fulfillment, fraud detection and prevention and other services, or who may contact you about their products and Services. Such information may include: (i) Personal Information; (ii) information that is not Personal Information; and/or (iii) information that is derived from Personal Information but has been anonymized so that it no longer contains information from which you can directly be identified (“Non-Personal Information”). We use and share this type of data for purposes such as helping us and our Business Partners understand how and how often people use our and their respective services or websites, which facilitates improving our Services, their services and how our Services interface with their services. In addition, these Business Partners may share with us information about you that they have independently developed or acquired in accordance with their own privacy policies and practices, for instance, in order to enhance our understanding of your interests and preferences so that we can make our Services more relevant to you and provide you with information about products and service we think may interest you. We may use such information for any purpose permitted by this Privacy Policy.

Unless set forth in this Privacy Policy or otherwise communicated to you, our Business Partners do not have any rights to use Personal Information beyond what is necessary to provide those services requested by us. You hereby consent to our sharing of Personal Information with our Business Partners.

INFORMATION DISCLOSED PURSUANT TO BUSINESS TRANSFERS:

In some cases, we may choose to buy or sell assets. In these types of transactions, user information is often one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this Privacy Policy.

INFORMATION DISCLOSED FOR OUR PROTECTION AND THE PROTECTION OF OTHERS:

We also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to: (i) satisfy any applicable law, regulation, legal process or governmental request; (ii) enforce this Privacy Policy and our Terms of Service, including investigation of potential violations hereof or thereof; (iii) detect, prevent, or otherwise address fraud, security or technical issues; (iv) respond to user support requests; or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

INFORMATION WE SHARE WITH YOUR CONSENT:

In addition to the disclosures described in this Privacy Policy, we may also share your information, which may include your Personal Information, in additional ways if you consent to such sharing.

IS INFORMATION ABOUT ME SECURE?

Your Account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your Account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer, browser, and any other device you use to access your Account, and by signing off after you have finished accessing your Account.

We seek to protect Account information and take steps to ensure that it is kept private; however, we cannot guarantee the security of any Account information. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

We otherwise store all of our information, including your IP address information, using industry-standard techniques.

Access: WHAT INFORMATION OF MINE CAN I ACCESS?

If you are a registered user, you can access information associated with your Account by logging into the Services. Registered and unregistered users can access and delete cookies through their web browser settings. Please see the cookies section set out above for more information.

You have a legal right in the UK to a copy of all Personal Information about you held by us. Upon request, we will provide you with a copy of this information subject to a fee not to exceed the maximum amount permitted by law. You also have a right to correct any error in that information. Please send any such requests to us here

WHAT CHOICES DO I HAVE REGARDING MY INFORMATION?

  1. You can use some of the features of the Services without registering, thereby limiting the type of information that we collect.
  2. You can always opt not to disclose certain information to us, but please note that certain information may be needed to take advantage of some of our Services.
  3. You can update and/or delete the Personal Information in your Account profile by visiting Stirrdups.com/en/gb/profile.
  4. You can delete your Account. Please note that we will need to verify that you have the authority to delete the Account, and activity generated prior to deletion will remain stored by us.
  5. Your browser may offer you a “Do Not Track” or “DNT” option, which allows you to signal to operators of websites and web applications and 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. The Services do not support Do Not Track 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 our properties. Remember that this is just our Do Not Track policy, and we cannot and do not make any promises about how third parties react when you set this signal on your browser.
  6. You can choose to opt out of certain communications or communication methods at the time you register an account with us or at any time after you have created your Account; however, if you do so, you may not be able to take advantage of some of our Services, including our offers and latest Service updates.
  7. You can opt out of certain cookies and similar tracking tools by following the steps set forth in the Cookies section above at the section titled “Cookies Analytics and Advertising Services Provided by Others and the Use of Web Beacons” above. You can also visit http://www.allaboutcookies.org/ or http://www.youronlinechoices.com/uk/ to find out more about your choices and how to update your settings.

HOW CAN I DELETE MY ACCOUNT?

Should you ever decide to delete your Account, you may do so by emailing us here If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account.

WHAT HAPPENS WHEN THERE ARE CHANGES TO THIS PRIVACY POLICY?

We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is collected. If we make changes in the way we collect or use information, we will notify you by posting an announcement on the Services or sending you an email. Unless we notify you otherwise, each user is bound by any changes to the Privacy Policy when he or she uses the Services after such changes have been first posted.

WHAT IF I HAVE QUESTIONS, CONCERNS, or COMPLAINTS?

If you have any questions or concerns regarding privacy using the Services, please send us a detailed by emailing us here. We will make every effort to resolve your concerns.

In compliance with the Privacy Shield Principles (where applicable), we commit to resolve complaints about your privacy and our collection or use of your Personal Information. We have further committed to refer unresolved Privacy Shield complaints to Judicial Arbitration and Mediation Services (“JAMS”), an alternative dispute resolution provider located in the United States with offices in London. If you do not receive timely acknowledgment of your Privacy Shield-related complaint from us, or if we have not resolved your complaint, you may contact or visit JAMS by visiting www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint, at no cost to you. Under certain conditions, you may also be entitled to invoke binding arbitration for residual claims about whether we have violated our obligations to you under the Privacy Shield, and if that violation remains fully or partially un-remedied.

EFFECTIVE DATE:

Nov 22 2017