The data controller is Société BIC, having its registered office 14 rue Jeanne d’Asnières, 92611 Clichy Cedex, France.
1. Privacy Statement
BIC requires personal information from users in order to use and gain access to any part of our App. Any personal information you may provide will be on a voluntary basis.
You may at any time withdraw or change your consent to our use or disclosure of your personal information, or request that we delete it from BIC’s files, subject to legal and contractual restrictions. However, if you do not provide personal information required to use the App, we may not be able to provide that service to you.
For California residents, see article “Your California Privacy Rights” regarding your rights under the California Consumer Privacy Act of 2018.
2. Use of personal information we collect from you
If you download, log-in and use the App, you will voluntarily provide us with your skin and hair characteristics, shaving habits, the month and year of birth and your photo, and we will record and store that information on our own and our service provider’s server. The information you provide is used to allow you to set up a user account and to be part of the BIC R&D Squad sampling the BIC® Smart Shave razor (“Product”). We (or an agency working on BIC’s behalf) will use this information only as necessary to operate our App and evaluate your use of the Product. If you contact us with questions regarding the App, we may use your name and email address in order to respond to your question. We will store your anonymised information indefinitely. Consequently, if you delete the App we may still have access to such information.
The information you provide to us via the dedicated email firstname.lastname@example.org that will be used by BIC and/or an agency working on BIC’s behalf to respond to your comments, questions or requests for information. Aside from replying to an e-mail sent by you, it is not our intention to contact you unless you request particular information. Although we will retain your contact information in our database, we will use it only to respond to your requests.
The personal data described above, as well as any other personal data you provide to us (for instance, the application to join the BIC R&D Squad), will be processed only for the apparent purpose for which it was collected (your participation) and/or as communicated to you upon the collection of your personal data.
We may also use your personal data for other purposes which are disclosed to you and to which you consent, or for such other purposes as permitted or required by applicable law.
3. What is our legal basis for processing your personal data?
We will only process your personal data where we have a legal basis to do so. Depending on the purposes for which we are processing your personal data (as explained in section 2 above), the legal basis will be one of the following:
- Performance of a contract: for example, where it is necessary for us to process your personal data to process your participation in the BIC R&D Squad.
- Your consent: for example, if you have given us your consent to provide your personal data to us or third parties for marketing purposes.
- For our or our third parties’ legitimate business interests: for example, where it is necessary for BIC to process personal data for the purposes of preventing fraud.
- Compliance with law: for example, where BIC is subject to a legal or regulatory obligation and needs to use your personal data in order to comply.
4. Retention period of the personal data we collect
We take steps to ensure that the personal data that you provide is retained for only as long as it is necessary considering the purpose for which it was collected. Personal data collected to apply to join the BIC R&D Squad made via our App will typically be retained for the duration of the contract plus an additional period, which will be in line with the statutory limitation period in the applicable jurisdiction.
Where we have collected your personal data based on your consent and we have no other lawful basis to continue with the processing, you may at any time withdraw or change your consent to our use or disclosure of your personal data subject to legal restrictions. The revocation of your consent will be valid for the future and will not affect the legality of the processing that was done based on your initial consent.
5. Disclosure to Third Parties
Except as specified herein or permitted or required by applicable law, we do not share personal information about you with any third party without your permission and we do not allow third parties to collect personally identifiable information from users on this App. This does not include trusted third parties who assist us in operating the App, conducting our business or serving you, so long as those parties agree to keep this information secure and confidential. Third party providers maintain the information they need to perform their designated functions and we do not authorize such parties to use or disclose personal information for their own marketing or other purposes.
We may release your personal information when release is permitted by or appropriate to comply with the law (for example, in response to a legally valid inquiry or order or otherwise required or permitted by applicable law), to enforce our App policies, to exercise or a defend legal claims or to protect ours or others rights, property, or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
If we become involved in a transaction to sell all or parts of our business or assets or merge with another business, as personal information may be part of such transactions, we may use or disclose such information to other parties involved in the transaction.
Please note that your personal information may be maintained and processed by service providers located in foreign jurisdictions, whose data protection laws may differ from the jurisdiction in which you live.
6. Security of your Personal Data
We have policies and procedures in place to protect your personal data from loss, unauthorized access, modification or disclosure. In addition, we have implemented technological safeguards including security software, passwords and firewalls intended to prevent unauthorized computer access. No claim is made as to the impenetrability of the system under unusual circumstance or its resilience to future attacks.
7. Do not track
We do not track your activity on any other App but ours. We do not use information obtained from this App to participate in activities commonly known as behavioural advertising and we, by default, do not track your activity on any other application.
8. Transfer and Storage of your Personal Data
9. Your California Privacy Rights
The California Consumer Privacy Act (CCPA) provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access Request Rights
You have the right to request that BIC disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you.
Sale of Personal Information
BIC does not sell your personal information.
Use of Personal Information
For information on how we use your personal information, see section Use of personal information we collect from you, above.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
Exercising Access and Deletion Rights
To exercise the access and deletion rights described above, please submit a verifiable consumer request to us by either:
- Completing the appropriate webform in the link below:
- If you downloaded the App and submitted any personal information as part of the “BIC R&D Squad”, fill out this webform..
- Emailing us at PIIrequest@bicworld.com.
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or deletion twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. In order to verify your identity, we may request that you provide us with your name, address or email address. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
You may also have a right to lodge a complaint with your local data protection authority however we recommend you contact us before doing so as we may be able to resolve any issues with you directly in a more efficient manner.
For inquiries from Canadian Citizens or Residents:
BIC Inc., Attn: Privacy Officer, Consumer Affairs, 155 Oakdale Road, Toronto, ON M3M 1W2. PrivacyOfficer.Toronto@bicworld.com
For inquiries from California Residents:
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: PIIRequest@bicworld.com.
Last updated May 2020
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