Privacy policy

INFORMATION WE COLLECT

When you access or use Our Services, We may, either directly or by using Our service providers, gather, collect, record, hold, distribute, share, disclose or otherwise use personal information about you which you provide to Us. Personal information is any information that relates to you, identifies you personally, or could be used to identify you including, but not limited to: your name, mailing address, email address, telephone number, or any other information. Personal information does not include anonymized or aggregated information. The types of personal information that we may collect about you are described below.

1.1. INFORMATION YOU VOLUNTARILY PROVIDE TO US. We collect personal information that you voluntarily provide to Us when you:

• complete forms on the Site, or in relation to our Services, or you contact Us via telephone;
• create an account with Us;
• purchase or otherwise request any of the Company’s products or services;
• request any customer support;
• request any exchange or return of any of the Company’s products or services;
• request any information from or about the Company, such as a newsletter, e-alert, or any other information about Our products, services, events or business partners;
• communicate with any other representative of our Company;
• communicate with Us via third-party social media sites;
• participate in any contest, promotion or sweepstakes offered by Us;
• apply for a job with the Company; or
• otherwise communicate with Us in any other way.

In these instances, the types of personal information that We may collect from You may include:

• Your name;
• Mailing address and/or billing address;
• E-mail address;
• Phone (or mobile) number;
• Date of birth or age;
• Credit or debit card number and other information about the same (if you make a payment either directly to Us or by using a third-party payment provider that handles payments and will receive your payment card information);
• Information about your bank or checking account (if you make a payment through your bank transfer);
• Gift card information or related gift information;
• Information you provide when you purchase any of our goods or services, including product or service parameters or preferences you provided when making a purchase
• Information you provide when you report a problem with our Site or an online purchase or other transaction with Us by email, Our Site, telephone, in writing or through other means.
• Records and copies of your correspondence (including email addresses), if you contact Us.
• Information relating to your participation in a contest, sweepstakes, promotion, or surveys that We may ask you to complete for research purposes.
• Employment and background-related information provided to Us as a part of the prospective job application process; or
• Information you provide or is otherwise involved in the return or exchange of a product, such as information about the transaction, product details, purchase price, and the date and location/media of the transaction.

1.2. INFORMATION WE COLLECT BY OTHER MEANS

1.2.1. INFORMATION AUTOMATICALLY COLLECTED

When you access or otherwise use Our Site or Services, We automatically collect certain personal information about you, including:

• Device Information. We (or our service providers) may collect information about the computer, tablet, phone or other device you use to access any of the Services, including the Internet Protocol address, hardware models, operating system and version, mobile network information and other unique device identifiers.
• Cookies and other Web-based Tracking Technologies: We (or our service providers) may use different technologies such as cookies, web beacons, or other types of small temporary files or web-based tracking technologies to gather certain information. A cookie is a small data file stored by your web browser on your computer or mobile device (hard drive) that helps Us to improve the way We deliver our Services to you, helps Us improve your overall experience using Our Services, and/or helps Us analyze the areas and features of our Services that are most popular or to detect fraud. Web beacons are electronic images that may be used in Our Services or emails and help deliver cookies, count visits, and understand usage. Like many other websites, cookies and these other web-based tracking technologies may be used by Us (or our service providers) during your visit to the Sites or other Services in order to improve your individual experience as a user of Our Site and Services, or to generally improve or enhance the overall functionality of the Services. For more information on Cookies, please see our Cookie Policy.
• Geo-location Data: Subject to your device permissions, We (or Our service providers) may be able to collect information about the precise location of your device or may gather other general location data based on GPS data, mailing address, and/or billing address (hereinafter collectively referred to as “Geo-location Data”), to customize our Services based on your location. You can prevent your device from sharing precise location information, including without limitation some or all of the Geo-Location Data, at any time through your device’s operating system settings.
• Social Media Information. If any of Our Services offer any social media features, such as the Facebook Like buttons or similar social media interactive mini-programs, these features may collect your Internet Protocol address, which page you are visiting on Our Site, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third-party or hosted directly on Our Services. Your interactions with these features maybe governed by the privacy policies of the company providing it.

1.2.2. INFORMATION WE RECEIVE FROM THIRD PARTIES IF APPLICABLE TO FURTHER INFORMATION

We receive information about you from other sources to help us correct or supplement our records, improve the quality or personalization of Our Services to you, and prevent or detect fraud.

We may also collect personal information about you that we receive from our partners, group members or other third parties. For example, if you make a purchase from Us, we may receive information about your creditworthiness from Our financial service providers; or if you visit one of Our social media accounts, the respective provider may provide Us with statistical information regarding your use of Our account. By gathering additional information about you, we can correct inaccurate information, enhance the security of your transactions, and give you product recommendations and special offers that are more likely to interest you.

HOW WE USE YOUR INFORMATION

2.1. PRIMARY WAYS WE USE YOUR INFORMATION.

We will only use your personal information as described in this Privacy Policy or as disclosed to you prior to such processing taking place. The purposes for which we may use your personal information include to:

• Process your purchase transactions, fulfill your orders, process exchanges and returns and send shipping notifications;
• Send support and administrative messages, and respond to your comments, questions, and customer service requests;
• Communicate with you about products, services, offers, and events offered by Us and others, and provide news and information We think will be of interest to you, subject to the applicable law;
• Monitor and analyze trends, usage, and activities in connection with Our Services;
• Conduct credit card screenings or to otherwise protect against fraud or unauthorized transactions, including by identifying potential unauthorized users or hackers;
• Personalize your experience and the advertisements and content you see when you use any Services based on your preferences, interests, and browsing and purchasing behavior;
• Comply with applicable laws or regulations or as requested by any judicial process or governmental agency (including without limitation for Company’s tax reporting), or as may be requested under any subpoena;
• Keep you secure and safe while using Our Services, which requires Us to process your personal information to combat spam, malware, malicious activities or security risks;
• Improve and enforce Our security measures;
• Facilitate your use of various social media sharing features or other integrated tools (such as the Facebook “Like” button) which you may use as part of social media pages;
• Facilitate any contests, sweepstakes, or promotions and process and deliver entries and rewards;
• Process your information to evaluate your application if you apply for a job; or
• Carry out any other purpose described to you at the time your personal information is collected.
• Use with, or otherwise distribute, share or disclose to, any government agencies or third parties in order to comply with, or otherwise pursuant to, any subpoena, court order, or other governmental order, law or regulation (including without limitation tax reporting).

SHARING AND DISCLOSURE OF INFORMATION

We may share or disclose your personal information in the following circumstances, and in all countries mentioned in Section 7 hereof:

• Affiliates and Subsidiaries. We may disclose your information with Our affiliates or subsidiaries for any of the purposes described herein.
• Service Providers. We may share or disclose your personal information with Our service providers or other third-party vendors that We retain in connection with the provision of the Services, including without limitation the following types of service providers that We may engage:
  • Email, internet or other telecommunication service providers;
  • Cloud, other data storage, or other hosting service providers;
  • Third-party payment service providers, including without limitation third-party credit card processors (see Third-Party Application Providers below);
  • Analytics companies who assist Us with various types of data analytics (see Analytics Partners below);
  • Third party shippers; or
  • Other third-party contractors we engage to assist Us in providing Our Services.
• Third Party Application Providers. If a third-party application is used to support Our Services We may share or disclose your information to such third-party application providers, including without limitation third-party credit card processors or other third-party payment service providers.
• Analytics Partners. We may use analytics services provided by a third-party analytics service provider or by using one of their tools, such as but not limited to Google Analytics, to collect and process certain analytics data. These services may also collect data about your use of other websites, apps, and online resources. Google Analytics is a web analytics service offered by Google LLC, a corporation domiciled in the USA (“Google”) that tracks and reports Site traffic. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: policies.google.com/privacy. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics, available at: tools.google.com/dlpage/gaoptout.
• Advertising Partners. We may work with third-party advertising companies (collectively, “Advertising Partners”) to provide you with advertisements or other information that We think may interest you. These Advertising Partners may set or access their own cookies, pixel tags or similar technologies on Our Site and Services or they may otherwise collect or have access to data about you which they may collect over time and across different online services. These Advertising Partners may also provide Us with their own independent data about potential customers and such data could include data about you previously collected by the Advertising Partner.
• Social Media Features. Our Services may offer social media features, including certain sharing tools or other integrated tools (such as the Facebook “Like” button), which let you share actions that you take on Our social media pages. Your use of such features enables the sharing of Personal Information with the public, depending on the settings you establish with the entity that provides the social sharing feature.
• Merger, Sale, or Other Asset Transfers. We may share or disclose or otherwise transfer your personal information to the Company’s professional advisors such as attorneys or accountants (“Outside Professionals”), other advisors, potential transactional partners, or other third-parties in connection with the consideration, negotiation, or completion of a corporate transaction in which We are acquired by or merged with another company or We sell, liquidate, or transfer all or a portion of Our assets. The use of your personal information following any of these events will be governed by this Privacy Policy.
• As Required By Law, Subpoena or Similar Government Order. We may access, preserve, share, or disclose your personal information if We believe doing so is required or appropriate to: (i) comply with all laws or regulations, including any tax reporting requirements of the Company; (ii) comply with any other law enforcement requests or legal process, such as a court order or subpoena; (iii) respond to your requests; or (iv) protect your, Our, or others’ rights, property, or safety. We may be required to disclose your information to (a) taxing authorities as part of our tax reporting requirements, or (b) law enforcement authorities or other governmental agencies or via subpoena;
• Company’s Outside Professional Advisors. We may share or disclose your personal information with any of the Company’s Outside Professionals to facilitate the professional advice from those Outside Professionals;
• Consent. We may also share or disclose your personal information with your permission.

YOUR CHOICES

4.1. COMMUNICATION PREFERENCES

To provide Our Services to you We may send you communications related to your transactions, security, or the administration of the Site. From time to time We may also send you other messages or updates about Groomie Club, our Site, and promotions or other activities. If you do not wish to receive non-transaction/non-security related communications from Us, you may opt-out by clicking the “unsubscribe” link in the communication you received from Us, or send an email message to privacy@groomie.club stating that you no longer want to receive these communications directly from Us (“Opt-Out”). Users from the EEA, the UK, Switzerland, Singapore, South Africa, Saudi Arabia, the United Arab Emirates, or Canada will, if required by applicable law, receive such communications only after having consented hereto. Please note that Opt-Out and “unsubscribe” requests may not take effect immediately and may take a reasonable amount of time to receive, process and apply, during which time your information shall remain subject to the prior Groomie Club Privacy Policy. Additionally, you should be aware that any information provided to third-parties prior to your election to Opt-Out or unsubscribe will not be retrieved or rescinded, unless required by applicable law.

4.2. CORRECTION

You have the right to correct your personal information that you shared with Us on our Site or Services. We are committed to ensuring that your personal information is kept accurate and up to date. However, it is up to you to update it with any changes. You are solely responsible for correcting, updating, or modifying any and all of your personal information as it appears in, and as otherwise stored by Our Services.

4.3. DO NOT TRACK: SPECIAL ADDITIONAL NOTICE TO CALIFORNIA RESIDENTS

Some Internet browsers, such as Internet Explorer, Firefox, and Safari include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT" signals have not been adopted, Our Site does not currently process or respond to “DNT” signals.

CHILDREN

This Site and Our Services are not directed to children under the age of 16, and We do not knowingly collect any personal information from children under the age of 16. We ask that minors under the age of 16 not submit any personal information to Us. If you have reason to believe a child under the age of 16 has provided Us with personal information, please contact us at privacy@groomie.club and request that such information be deleted from Our records.

DATA SECURITY

We have implemented reasonable technical and organizational measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. All personal information you provide to Us is stored on Our secure servers behind firewalls. Any payment transactions will be encrypted using SSL or other encryption technology, or will use Our third-party payment processors, who will use appropriate security procedures.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of Our Site, you are responsible for keeping this password confidential. You should not share your password with anyone. We urge you to be careful about giving out information in public areas of the Site like message boards. The information you share in public areas may be viewed by any user of the Site.

Unfortunately, the transmission of information via the internet is not completely secure. Although We do our best to protect your personal information, We cannot guarantee the security of your personal information transmitted to Our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

Your personal information may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside the United States and choose to provide information to Us, please note that We transfer the data, including personal information, to the United States and/or the EEA and process it there.

We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Policy and no transfer of your personal information will take place to an organization or a country unless there are appropriate safeguards in place as required under the applicable data protection laws and ensuring the security of your personal information maintained. If you do not want your information transferred to or processed or maintained outside of the country or jurisdiction where you are located, you should not use the Site or Services.

ADDITIONAL NOTICE TO CALIFORNIA RESIDENTS

This section applies only to California residents. Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), below is a summary of the “Personal Information” categories, as identified and defined by the CCPA (see California Civil Code section 1798.140 (o)), that We collect, the reason We collect your personal information, where we obtain the personal information, and the third-parties with whom we may share your personal information.

We generally collect the following categories of personal information about you when you use Our Site or Services:

• Identifiers such as a name, address, unique personal identifier, email, phone number, your device’s IP address, software, and identification numbers associated with your devices.
• Commercial information such as records of products or services purchased, obtained, or considered by you.
• Internet or other electronic information regarding your browsing history, search history, the webpage visited before you came to our Site, length of visit and number of page views, click-stream data, locale preferences, your mobile carrier, date and time stamps associated with transactions, and system configuration information.
• Your geolocation, to the extent you have configured your device to permit us to collect such information.
• Audio recordings of your voice to the extent you call us, as permitted under applicable law.
• Professional or employment-related information.
• Inferences about your preferences, characteristics, behavior and attitudes.

We generally do not collect biometric, or education-related information. For more information about the personal information we collect and how we collect it, please refer to Section 1, above, and our Cookie Policy.

We collect your personal information for the business purposes described in Section 2, above. The CCPA defines a “business purpose” as the use of personal information for the business’s operational purposes, or other notified purposes, provided the use of personal information is reasonably necessary and proportionate to achieve the operational purpose for which the personal information was collected or another operational purpose that is compatible with the context in which the personal information was collected.

The categories of third-parties with whom we may share your personal information are listed in Section 2, above.

8.1. PRIVACY RIGHTS

California residents have the following rights listed below. Your Right to Access and Right to Deletion are not absolute and are subject to certain exceptions. For instance, We cannot disclose specific pieces of personal information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the personal information, your account with us or the security of the business’s systems of networks.

Right Against Discrimination. You have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your right to know, delete or opt-out of sales.

Right to Access. You have the right to request that We disclose certain information to you about the Company’s collection and use of your personal information over the past 12 months. Specifically, you can request the following information:

• 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.
• If We sold or disclosed your personal information for a business purpose; two separate lists disclosing:
  • sales (if any), identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
• You have the right to request a copy of the specific personal information We collected about you during the 12 months before your request.

Right to Deletion. 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. We may deny your deletion request if retaining the information is necessary for the Company or its service provider(s) to:

• Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of Our ongoing business relationship with you, or otherwise perform Our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with Us.
• Comply with a legal obligation.
• Make other internal or lawful uses of that information that are compatible with the context in which you provided it.

Right to Opt-Out of Selling. As described in this Privacy Policy, in certain situations We may share your personal information with our partners, third-parties or affiliates for marketing or other purposes and could receive a benefit for such sharing. To the extent such sharing is considered a “sale” under the CCPA, as a California resident you have the right to opt-out of such sharing. CLICK HERE for the Company’s notification to California residents about their right to opt-out of any such “sale”, if any such “sales” exist:

8.2. EXERCISING YOUR RIGHTS

To exercise your right to access, data portability, and deletion rights, you must submit a verifiable consumer request to Us by either:

• Using our web form here; or
• Emailing the Company at: privacy@groomie.club

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 to the Company 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 data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows the Company to reasonably verify that you are the person about whom We collected personal information or an authorized representative, and
• Describe your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it.
• We cannot respond to your request if We cannot verify your identity or authority to make the request and confirm the personal information relates to you.

ADDITIONAL NOTICE TO INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA (EEA), THE UNITED KINGDOM AND SWITZERLAND.

This Section provides additional information to individuals located in the EEA, the United Kingdom or Switzerland at the time their personal information is collected by Us. All capitalized terms in this Section have the meaning as defined in the General Data Protection Regulation (GDPR) and/or, as applicable, the GDPR as it is saved and incorporated into United Kingdom law following Brexit (UK-GDPR) or the Swiss Data Protection Act (including, but not limited to “Personal Data”, “Processing”, “Controller”, “Processor”, “Data Subject”, “Consent”).

9.1. Data Controller, Data Protection Officer and EU Representative

The Controller for the Processing described in this Privacy Policy is:

Groomie Club., 10054 Old Grove Road, San Diego, CA 92131, privacy@groomie.club.

You can contact the Company’s Data Protection Officer using: privacy@groomie.club.

For Data Subjects in the EU and the UK: We value your data subject rights under GDPR and UK-GDPR and therefore appointed the following entities as representatives according to Art 27 GDPR and Art. 27 UK-GDPR in order to provide you with an easy way to submit to us privacy related request like a request to access or erase your personal data. If you want to make use of your data subject rights, please visit: gdpr-rep.eu/q/13529322

PrighterGDPR-Rep by
Maetzler Rechtsanwalts GmbH & Co KG
Attorneys at Law
c/o Groomie Club
Schellinggasse 3/10, 1010 Vienna, Austria
Please add the following subject to all correspondence:
GDPR-REP ID: 13529322

PrighterUK-Rep by
Prighter Ltd
c/o Groomie Club
Kemp House 160 City Road, London EC1V 2NX, UK
Please add the following subject to all correspondence:
GDPR-REP ID: 13529322

9.2. Legal Basis of Our Processing. The Legal basis of Our Processing of your Personal Data within the scope of application of the GDPR, the UK-GDPR or the Swiss Data Protection Act is as follows:

• Contract (Art. 6 (1) b GDPR), where we Process your purchase transactions (e.g. orders, exchanges and returns, shipping notifications) and answer your support and customer service requests as this is necessary for the performance of Our contract with you;
• Legitimate Interests (Art. 6 (1) f GDPR):
  • In our legitimate interest in providing a secure Website user experience, we Process Your Personal Data to administer Our Programs and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; further information can be found in Our Cookie Policy;
  • For an appealing surfing experience, we Process your Personal Data to allow you to participate in interactive features of our Website or our social media accounts, when you choose to do so;
  • Responding to your comments and questions is part of Our legitimate business interests in providing you with first class services;
  • To protect Our financial interests or to otherwise protect Ourselves against fraud or unauthorized transactions, we Process your Personal Data, e.g. we conduct credit card screenings, and perform monitoring to identify potential unauthorized users or hackers;
  • Our legitimate interest in promoting Our business is the purpose for Processing your Personal Data to facilitate any contests, sweepstakes, or promotions and process and deliver entries and rewards;
  • If you want to work with Us and apply for a job, We Process your Personal Data to evaluate your application;
  • To protect Our rights and interests (e.g. protect the Company against legal claims) we can use your data with, or otherwise distribute, share or disclose your Personal Data to any of the Company’s professional advisors such as attorneys or accountantli in order to facilitate their professional advice.
• Consent (Art. 6 (1) a GDPR):
  • Unless consent is not required under applicable law, we send you promotional communication about Our products, services, offers, and events offered by Us and others, and provide news and information We think will be of interest to you only after you have consented to such communication. You can withdraw your consent at any time with future effect, e.g. by clicking the unsubscribe-link in each promotional email;
  • We request your explicit consent to monitor and analyze your usage of Company Programs and advertising to understand their effectiveness, and to personalize your experience when you use a Company Program. Further information can be found in Our Cookie Policy;
  • We also request your consent to facilitate your use of various social media sharing features or other integrated tools (such as the Facebook “Like” button) which you may use as part of social media pages.
• Compliance with Legal Obligations (Art. 6 (1) c GDPR):
  • We Process your Personal Data for compliance purposes as may be required by applicable laws or regulations or as requested by any judicial process or governmental agency (including without limitation for Company’s tax reporting) or as may be requested e.g. under any subpoena or court order.

9.3. Social Media Accounts

We maintain accounts with various social media networks. When you visit these social media networks, a variety of Data Processing operations are triggered. We use your Personal Data when you visit Our profiles on these social media networks, or when you click on the like-button on one of our social media advertisements. When you visit Our profiles, your Personal Data is not only used by Us but also by the social network provider, regardless of whether you have a profile in the social network or not. The individual Processing and its scope differ from provider to provider, and they are not completely transparent to Us. Details about the Processing of the social network providers can be found in the relevant social media network’s Privacy Policy:

• Facebook by Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland: facebook.com/about/privacy
• Instagram by Facebook Ireland Ltd., 4 Grand Canal Square, Dublin 2 Ireland: help.instagram.com/519522125107875
• Twitter by Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland, twitter.com/en/privacy
• YouTube by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland: policies.google.com/privacy?hl=en-UK
• Pinterest by Pinterest Europe Ltd., Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Ireland: policy.pinterest.com/en/privacy-policy
• TikTok by TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland: tiktok.com/legal/privacy-policy?lang=en
• Spotify by Spotify AB, Regeringsgatan 19, 111 53 Stockholm, Sweden: spotify.com/ie/legal/privacy-policy/

The social network providers collect your usage information to provide us with usage statistics. To learn more about how such tracking takes place and to understand how we use social media plugins on our Site please read our Cookie Policy.

9.4. International Transfers We may share your Personal Data with recipients (including our group members, service providers or business partners, as described in this Policy), located in the EEA, the UK and Switzerland; or in the United States and/or otherwise in countries outside the EEA, the UK and Switzerland which do not provide for an adequate level of data protection from an EU or Swiss law perspective. For such transfers, we will ensure that the recipients are subject to appropriate safeguards as permitted under the applicable data protection laws, e.g. by entering into appropriate data transfer agreements on the basis of EU standard contractual clauses issued by the Commission, or by reliance upon the Article 49 GDPR derogations or corresponding derogations under the Swiss Data Protection Act, as applicable. A copy of the respective appropriate safeguards is available upon request.

9.5. Duration of Our Data Processing We retain Personal Data you provide to Us for as long as necessary for the purpose such Personal Data was originally collected or otherwise processed for, e.g. in order to meet Our contractual obligations towards you, until you withdraw your consent, or as long as you maintain a customer account with Us. If required under applicable law, We will store your Personal Data for a period of up to ten more years (e.g. under tax law). Apart from that We can further store your Personal Data for the establishment, exercise or defense of legal claims.

We may also retain aggregate information beyond this time for research purposes and to help us develop and improve Our Services.

9.6. Your Data Protection Rights under the GDPR You have the following rights pursuant to the GDPR, where applicable, which can be exercised using the contact details of the Controller listed above:

• Right of Access, pursuant to GDPR Article 15, to obtain from Us confirmation as to whether or not Personal Data has been Processed and, if so, access to that Personal Data and additional information about the categories of Personal Data and its source, and how it has been Processed, e.g. the purpose, the categories of recipients, the planned retention period, the existence of the Data Subject’s rights;
• Right to Rectification, pursuant to GDPR Article 16, to request the correction of incorrect Personal Data or any completed Personal Data stored by Us;
• Right to Erasure, pursuant to GDPR Article 17, to request the deletion of the Personal Data stored by Us, except for the allowed continued uses permitted by the GDPR;
• Right to Restriction, pursuant to GDPR Article 18, to demand the restriction of the Processing of the Personal Data where one of the following applies: (i) as far as the accuracy of the Personal Data is disputed by you; (ii) the Processing of the Personal Data is unlawful, but you reject its deletion; (iii) We no longer need the Personal Data, but you require it to exercise or defend legal claims; or (iv) you have objected to the Processing in accordance with GDPR Article 21;
• Right to Data Portability, pursuant to GDPR Article 20, to receive your Personal Data as provided to Us, in a structured, common and machine-readable format or to request the transfer to another Controller;
• Right to Withdrawal, pursuant to GDPR Article 7(3), you have the right to withdraw, at any time, your once granted consent. As a result, We are no longer allowed to continue the Processing based on that consent for the future, but such withdrawal does not affect the lawfulness of the Processing based on such consent before such withdrawal; and
• Right to Lodge a Complaint with a Supervisory Authority, pursuant to GDPR Article 77, to complain to a Supervisory Authority (e.g. that of Your usual place of residence or work or place of the alleged infringement). You can find details of EEA Supervisory Authorities here: https://edpb.europa.eu/about-edpb/board/members_en. The Supervisory Authority in the UK is the Information Commissioner’s Office (ICO): casework@ico.org.uk or 0303 123 1113 / +44 1625 545 700; www.ico.org.uk.

ADDITIONAL NOTICE TO INDIVIDUALS IN CANADA.

This Section provides additional information to individuals located in Canada at the time their personal information is collected by Us.

You may request details about Our privacy practices, access or correct your personal information, or make a complaint by contacting Our privacy officer in writing:

Groomie Club, 10054 Old Grove Road, San Diego, CA 92131, privacy@groomie.club

If you are not satisfied with Our response to your inquiry, you may contact the Office of the Privacy Commissioner of Canada: 1-800-282-1376 (toll-free) or priv.gc.ca

ADDITIONAL NOTICE TO INDIVIDUALS IN AUSTRALIA.

This Section provides additional information to individuals located in Australia at the time their personal information is collected by Us.

You may request to correct or update any of your personal information in our files. We may provide you with the ability to update some or all of your personal information directly via Our Services or by contacting us via privacy@groomie.club. If you request that your information be corrected, and we do not agree that it is incorrect, we may refuse to update that information. In such a scenario, we will provide written notice of our refusal to do so within 30 days and upon your request, will place a statement of what you allege is correct where your personal information is kept and accessed.

ADDITIONAL NOTICE TO INDIVIDUALS IN NEW ZEALAND.

This Section provides additional information to individuals located in New Zealand at the time their personal information is collected by Us.

You have the right to request access to any personal information we hold about you, by emailing us at privacy@groomie.club

We retain Personal Data you provide to Us for as long as necessary for the purpose such Personal Data was originally collected or otherwise processed for, e.g. in order to meet Our contractual obligations towards you, until you withdraw your consent, or as long as you maintain a customer account with Us. If required under applicable law, We will store your Personal Data for a period of up to ten more years (e.g. under tax law). Apart from that We can further store your Personal Data for the establishment, exercise or defense of legal claims. We may also retain aggregate information beyond this time for research purposes and to help us develop and improve Our Services

ADDITIONAL NOTICE TO INDIVIDUALS IN SINGAPORE.

This Section provides additional information to individuals located in Singapore at the time their personal information is collected by Us.

You can contact the Company’s Data Protection Officer at: privacy@groomie.club

ADDITIONAL NOTICE TO INDIVIDUALS IN SOUTH AFRICA.

14.1. Data Retention This paragraph sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

Your personal, account, transaction, usage, data is held in Our website database OR will be stored on the servers of our hosting services providers. Personal data that We process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

We will retain your personal information as follows for a minimum period of 5 years following the date of the most recent contact between you and Us, and for a maximum period of 6 years following that date.

Notwithstanding the other provisions of this paragraph and any other provisions of this Privacy Policy, We may keep some or all of your personal data if and for as long as (i) We are required or permitted by law, a code of conduct, or a contract with you to keep it; (ii) We reasonably need it for lawful purposes related to our functions and activities; (iii) We reasonably need it for evidentiary purposes; or (iv) you agree to us keeping it for a specified further period.

14.2. International Transfers We may share your information with recipients (including our group members, service providers or business partners, as described in this Policy), located in the EEA, the UK and Switzerland; or in the United States and/or otherwise in countries outside South Africa which do not provide for an adequate level of data protection from a South African law perspective. For such transfers, we will ensure that the recipients are subject to appropriate safeguards as permitted under the applicable data protection laws, e.g. by entering into appropriate data transfer agreements that contain the safeguards prescribed by applicable data protection legislation.

14.3. Your RightsIn this paragraph, we have listed the rights that you have under data protection law. Your principal rights under data protection law are:

• the right to access - you can ask for copies of your personal data;
• the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
• the right to erasure - you can ask us to erase your personal data;
• the right to restrict processing - you can ask us to restrict the processing of your personal data;
• the right to object to processing - you can object to the processing of your personal data;
• the right to data portability - you can ask that we transfer your personal data to another organization or to you;
• the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
• the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

As far as the law allows, We may charge a fee for attending to any of your requests above and may also refuse to carry out any of your requests in whole or in part. You may exercise any of your rights in relation to your personal data by written notice to Us, using the contact details set out below. You must let us know if any information we have about you is incorrect, incomplete, misleading or out of date, by notifying us at the contact details below. Where required by law We will take reasonable steps to correct or update the relevant information, accordingly, having regard to the purpose for which the information was collected or used.

14.4. Most Pertinent Terms We have a duty under the Consumer Protection Act 68 of 2008, to bring certain important terms to your attention. In accordance with this obligation, We hereby notify you that Sections 3, 4.1 and 6 as well as this Section 14 are important terms that should be carefully reviewed by you, as these terms may (i) limit our liability to you or another person; or (ii) constitute an assumption of risk or liability by you; or (iii) be an acknowledgement of fact by you.

ADDITIONAL NOTICE TO INDIVIDUALS IN SAUDI ARABIA AND THE UNITED ARAB EMIRATES.

We only process your personal information after obtaining your consent. You may have certain rights in relation to such processing under applicable law. To know more about any such rights and how to exercise them, please contact us at privacy@groomie.club.

We retain your personal information for as long as necessary for the purposes such personal information was collected as described in this Privacy Policy.

COMMUNICATING WITH THE COMPANY.

We welcome your questions and comments about this Privacy Policy. You can contact Groomie Club by emailing us at: privacy@groomie.club.