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OK, GOT IT


PRIVACY POLICY

We are Harry's, and when you access or use this website (www.harrys.com/en/gb),
or our mobile application, our blog, our branded pages on social media services,
or any of the other sites, services, features, content or applications we offer
in the United Kingdom (collectively, the "Services"), or register an account
with us, purchase our products or contact us from anywhere in the United
Kingdom, this Privacy Policy will tell you how Harry's, Inc. and its
subsidiaries, including, without limitation, Harry's Grooming Limited and
Harry's USA, Inc. (as applicable, "Harry's", "we", "us" or "our"), collect, use
and share the personally identifiable information ("Personal Data") we collect
about you.

Personal Data you provide us Other Personal Data we receive about you Who we
share your Personal Data with How we protect your Personal Data International
transfers of your Personal Data and Privacy Shield What your rights are to your
Personal Data, and how you can exercise them Our Personal Data retention policy
Any questions or concerns? We urge you to read this Privacy Policy in full, but
wanted to mention a few things upfront:

• When you use the Services, even if you don't have an account with us or
purchase our products, we may receive some Personal Data from you through your
web browser, including your IP address, the type of device you're using and
other similar information, and use it to understand where and how our Services
are being used, among other purposes described in this Privacy Policy. If you do
set up an account with us or purchase our products, we'll collect other Personal
Data from you, and use it to verify your identity, fulfill your orders, market
to you and for other purposes.

• In this Privacy Policy, we describe the various purposes for which we use your
Personal Data, as well as the legal bases supporting those purposes. As you'll
read below, the legal basis on which we rely for a given use of your Personal
Data may be contractual necessity (i.e., where we need to use your Personal Data
to complete a contract with you), consent freely given to us (which you can
withdraw at any time) and/or certain legitimate business of ours or of others,
but only where we have determined that those interests are not overridden by
your own interests, rights and freedoms.

• You have certain rights regarding the Personal Data we collect from you, which
you can learn about below.

• As noted in our Terms of Service, we do not knowingly collect or solicit
Personal Data from anyone under the age of 18. If you are under the age of 18,
please do not access or use the Services, or attempt to send us any Personal
Data. If we learn that we have collected Personal Data from an individual under
the age of 18, we will delete that information as quickly as possible.

• If you are based in the United Kingdom, Harry's Grooming Limited, our
subsidiary based in the United Kingdom, is the primary data controller of your
information and, accordingly, is registered with the Information Commissioner's
Office. Harry's Grooming Limited has a registered office at 5th Floor 101 St
Martins Lane, London, United Kingdom, WC2N 4AZ. You can contact us there or at
ukhelp@harrys.com, or contact our Data Protection Officer directly at
security-council@harrys.com, if you have any questions or concerns about our
collection and/or use of your Personal Data. If you are using the Services
outside of the areas listed in this paragraph, a different privacy policy may
apply to you instead.

• The Services are hosted and operated in the United States through Harry's,
Inc. and certain of our service providers. By using the Services, you
acknowledge that any Personal Data you provide to us will be hosted on United
States servers. Harry's, Inc. and Harry's USA, Inc., both located at 75 Varick
Street, New York, New York 10013, are registered under the EU-U.S. Privacy
Shield Framework. Please see below for more details.

• This Privacy Policy does not apply to the practices of third parties that we
do not own or control, including, but not limited to, any third party websites,
services, products or applications (each a "Third Party Service") that you elect
to access and may interact with during your use of the Services, or to
individuals that we do not manage or employ. We take steps to ensure that we
only work with Third Party Services that share our respect for your privacy, but
we cannot take responsibility for the content, products, services or privacy
policies of those Third Party Services. We encourage you to carefully review the
privacy policies of any Third Party Services you access.

PERSONAL DATA YOU PROVIDE US

REGISTRATION INFORMATION We collect your email address and the password you
enter when you register for an account with us, and we use them to verify your
identity, based on our legitimate business interests in keeping your account
secure and preventing fraudulent transactions.

We also use your email address:

• to send you confirmations, notifications and other information regarding your
account, your shave plans and your purchases, as may be necessary to complete
our contractual obligations to you. Without your email address, we wouldn't be
able to provide you this information in a timely and effective manner;

• to send you information and materials about us, our products and our services
that we think may be of interest to you, based on our legitimate business
interest in marketing to individuals who have indicated an interest in our
products and services. You can choose not to receive such information when you
register an account with us, and you can decide to stop receiving this
information at any time by emailing us at ukhelp@harrys.com or calling us at
0808-164-8618; and

• to send you information and materials about third parties with whom we partner
or do business and their products and services, but only where you have given us
your consent to do so. You can opt in to receive such messages when you register
an account with us and you can always decide to stop receiving these emails at
any time by emailing us at ukhelp@harrys.com or calling us at 0808-164-8618.

You may be able to register for or access the Services using Third Party
Services, such as Facebook. If you've registered for an account with us through
Facebook or another Third Party Service, we will collect and receive your login
credentials for such Third Party Service in connection with providing you with
the Services if you expressly provide us with such information. We will only use
such login information for the purposes described above. In any case, we urge
you to review your privacy settings on any Third Party Service and their
associated privacy policies to understand more about disclosures of information
from your applicable Third Party Services.

SHIPPING AND PAYMENT INFORMATION When you subscribe to a shave plan or purchase
products through the Services or over the phone with one of our customer service
representatives, we collect and store your first and last name, your shipping
address and your telephone number (collectively, "Shipping Information"), as
well as certain payment information, including your billing address and your
credit or debit card type, number, security code and expiration date
(collectively, "Payment Information"), and we use this information in order to
process, fulfill, confirm, or notify or inform you about your shave plans and
purchase orders, as may be necessary to complete a contract with you. Without
this information, we would be unable to complete your transaction with us and/or
deliver your purchases to you.

All Payment Information regularly collected through the Services is encrypted
and maintained using industry standard methods designed to ensure its security
against loss or theft, including during transmission to our third party payment
processing company ("Payment Processor"), which is currently Stripe who
processes your Payment Information on our behalf. Please note that your Payment
Information is stored by our Payment Processor, not by us, and use and storage
of that information by the Payment Processor is governed by the Payment
Processor's applicable terms of service and privacy policy (available at:
https://stripe.com/gb/legal and https://stripe.com/gb/privacy).

We also use your Payment Information to verify your identity when you manage
your account, your shave plan or your orders, or make a new purchase, based on
our legitimate business interests in keeping your account secure and preventing
fraudulent transactions. As stated above, we do not store your Payment
Information – our Payment Processor does, and we must collect your Payment
Information from our Payment Processor and/or from you in order to use it to
verify your identity or to process and fulfill your shave plans.

We use and store your Shipping Information to make it easier for you to make a
purchase, or to sign up for a shave plan if you do not have one, based on our
legitimate business interest in making the Services more convenient for your
continued use.

We may also use your name and shipping address to mail you information and
materials about us and our products and services that we think may be of
interest to you, based on our legitimate business interest in marketing to
individuals who have indicated an interest in our products and services. You can
always choose not to receive such communications when you register an account
with us, and you can stop receiving these communications at any time by emailing
us at ukhelp@harrys.com or calling us at 0808-164-8618.

If you indicate that you would like us to do so, we will share your name and
shipping address, along with certain information regarding your transactions
with us (including transaction date, value, amount, type, and order ID) with
Epsilon Abacus, a provider of data cooperative and marketing services to a
members-only group of retailers (such group the "Abacus Alliance" and such
members the "Abacus Alliance Members"). Through Epsilon Abacus, this information
will be shared with the Abacus Alliance Members, with any transactional
information being aggregated so details of individual transactions are not
shared. More specifically, we share this information with Epsilon Abacus so that
it can analyze your buying patterns and determine what sort of products are
likely to appeal to you, and Epsilon Abacus shares your name and shipping
address with Abacus Alliance Members who may offer such products.

By agreeing to share such information with Epsilon Abacus and the Abacus
Alliance, you agree to receive information and materials in the post regarding
products offered by other Abacus Alliance Members. The list of retailers in the
Abacus Alliance changes frequently, but it is limited to retailers in the
clothing, collectables, food and wine, gardening, gadgets and entertainment,
health and beauty, household goods and/or home interiors categories. You can opt
in to share the above-described information with Epsilon Abacus and the Abacus
Alliance and receive such materials in the mail when you register an account
with us.

If you decide you would like to stop sharing this information and receiving
materials in the post, you can email us at ukhelp@harrys.com or call us at
0808-164-8618. Additionally, if you would like to stop all unsolicited postal
communications, we suggest that you register with the Mailing Preference Service
(MPS), a free service funded by the direct mail industry that enables consumers
to have their names and home addresses in the UK removed from lists used by the
industry. For more information or if you wish to register with the MPS please
visit their website www.mpsonline.org.uk.

INFORMATION YOU SHARE WITH US IN COMMUNICATIONS OR INTERACTIONS When you
communicate with us or our customer service representatives, including when you
call us, email us or interact with us through the Services, we automatically
record that communication, and use that record and the information you provide
us in those communications, to address your questions and complaints about us,
our products and our services, and to train our customer service
representatives, based on our legitimate business interest in providing quality
customer service. We also use the information you provide us to address your
requests regarding your account, shave plans and purchase orders, as may be
necessary to complete a contract with you. Without this information, we may not
be able to address these requests.

When you respond to a survey we provide you, or leave a written comment or
review on the Services about us, our products or the Services, we record that
survey response, comment or review, and use the information you provide us in
them, in order to assess and/or address your responses, comments or reviews
regarding us, our products or our services, based on our legitimate business
interest in providing quality products and customer service.

OTHER PERSONAL DATA WE RECEIVE ABOUT YOU In addition to the information you
directly provide us, we automatically receive and record certain information
about you when you access or use the Services, or otherwise communicate or
interact with us (including through other websites or mobile applications).
Additionally, like many e-retailers, we collect certain information about you
from third parties, including advertising and analytics companies.

LOCATION INFORMATION When you access or use the Services, we collect information
from your web browser, including your IP address and your device's settings and
unique identifiers, and use that information to determine your general location,
based on our legitimate business interests in reliably and accurately providing
you with Services and information that apply to you, and in learning more about
where the Services are being accessed or used.

COOKIE INFORMATION When you access or use the Services, and with your consent,
we and certain of our third party service providers automatically receive and
record information from your web browser and your device using cookies and
similar technologies such as pixel tags or web beacons (for the purposes of this
Privacy Policy, we refer to these technologies individually and collectively as
"Cookies"). Cookies are small files – usually consisting of letters and numbers
– placed on your computer, tablet, phone or similar device, when you use that
device to visit a website. Cookies can either be "session Cookies" or
"persistent Cookies." Session Cookies are temporary Cookies that are stored on
your device while you are accessing or using our Services, whereas "persistent
Cookies" are stored on your device for a period of time after you leave our
Services. The length of time a persistent Cookie stays on your device varies
from Cookie to Cookie.

We use Cookies to collect information regarding your internet usage, including
your IP address, internet service provider, browser type and version, the pages
you visit and links you click on the Services, and the page referring you to the
Services and/or the page you visit when you exit the Services, as well as
device-specific information if you access the Services using a mobile device,
such as unique device identifiers, network information and hardware model
(collectively, "Cookie Information")

ESSENTIAL COOKIES Essential Cookies enable you to access and use our website and
other features or content on the Services that you request or seek to use -
based on our legitimate business interest in providing you with the Services.
For example, Cookies that enable you to log into your account or use the
"shopping cart" functionality on the Services are Essential Cookies. You can
disable Essential Cookies but doing so will encumber the performance of the
Services and may make certain of its features and services unavailable to you.
Our Essential Cookies include:

• 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; and

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

FUNCTIONALITY COOKIES Functionality Cookies determine whether you have
previously visited or otherwise used the Services, and if so, whether you
indicated any preferences during your previous visits or use, based on your
consent and our legitimate business interest in personalizing the Services for
repeat visitors.These are persistent Cookies and can be disabled, but doing so
will impair our ability to personalize the Services for you. Our Functionality
Cookies include:

• 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);

• followed_incentive_code: this Cookie is delivered by us to verify that a
referral link is genuine so that we can credit your account accordingly. Without
this Cookie, we cannot authenticate the code and the credit cannot be applied;

• h_geoip: determines from which country you are accessing the site so that we
can present a country-specific experience (e.g., currency, language, products,
shipping options);

• h_public: stores your public user ID which helps us serve a personalized site
experience;

• h_mobile: determines if you are on a mobile device to serve a mobile optimized
site experience;

• h_signed_once: remembers if you have logged in before to default your login
option to login instead of create account;

• h_user: identifies you as being logged-in;

• h_dc: remembers if you applied a discount code to apply that discount at
checkout;

• referrer, utm_source, h_p_utm_source, utm_medium, h_p_utm_medium,
utm_campaign, h_p_utm_campaign, h_p_utm_term, h_p_utm_content and h_p_eid:
identify from which campaigns visitors to our website originated;

• h_gdpr_cookie_agree: remembers if you agree to being tracked via Cookies; and

• multi_step_builder_state: remembers your progress in completing the checkout
experience for a subscription;

• h_membership_seen: remembers if you have seen the Core Membership program; and

• h_churn_redirected: remembers if you have already been redirected to profile
page upon visiting Harrys.com within the last 30 days.

RETARGETING AND ADVERTISING COOKIES Retargeting and Advertising Cookies learn
about the pages on our website and on Third Party Services that you visit, and
thus enhance our understanding of your interests and preferences, so that we can
serve you with advertisements for our products or services that we believe may
be of interest to you (on the Services and elsewhere), based on your consent and
our legitimate business interest in marketing to individuals we believe may be
interested in our products and services. Retargeting and Advertising are
persistent Cookies, through which we collect information about your online
activity after you leave our Services. We use a number of third parties to help
deliver these Services, including, for example, Google. Please see the section
below titled "Additional information about interest-based advertisements" for
more information.

PERFORMANCE / ANALYTICAL COOKIES Performance / Analytical Cookies understand how
visitors use the Services by collecting information about the number of visitors
to our website, what pages visitors view on our website and how long visitors
are viewing pages on the website, based on your consent and our legitimate
business interest in improving and maintaining the accessibility and
functionality of our Services. Performance / Analytical Cookies are persistent
Cookies, through which we may collect information about your online activity
after you leave our Services. We also use these Cookies to help us measure the
performance of our advertising campaigns, based on your consent and our
legitimate business interest in improving our advertising campaigns and the
content on the Services to better market to individuals who we think may be
interested in our products and services. We use a number of third parties, as
described below, to help deliver these Services. Our Performance / Analytical
cookies include, for example:

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

• h_custype: lets us know if you have purchased from us in the past, so that we
can show you relevant information on our website;

• ga: Google Analytics session information, a third party Cookie served by
Google; and

• gid: Google Analytics user identifier, a third party Cookie served by Google.

THIRD PARTY COOKIES Some Cookies are placed by a third party on your device and
may provide Cookie Information to that third party as well as to us, that
indicate your browsing habits (such as your visits to our website or other
Services, the pages you have visited and the links and advertisements you have
clicked). These Cookies can be used to determine whether you have visited or
used certain Third Party Services, to identify your interests, to retarget
advertisements to you and to serve advertisements to you that we or others
believe are relevant to you. For example, as indicated above, we use certain
Google services including Google Analytics, which uses Cookies to analyze how
users use our Services. Following a request by us, Google will use this
information for the purpose of measuring your activity on our Services,
compiling statistical reports on overall website activity for us and providing
other services relating to such activity and internet usage. You can learn more
about Google Analytics and their cookies here. If you are on the web, you can
also opt out of Google Analytics by installing Google's opt-out browser add-on.
We do not control third party Cookies.

Other third party websites that access and use Cookies on our website include:
www.googletagmanager.com, cdn.heapanalytics.com, a3129410271.cdn.optimizely.com,
logx.optimizely.com, static.hotjar.com, d.impactradius-event.com,
data.adxcel-ec2.com, script.hotjar.com, sessions.bugsnag.com,
www.googleadservices.com, static.criteo.net, static.ads-twitter.com,
connect.facebook.net, storage.googleapis.com, bat.bing.com, b-code.liadm.com,
collector-1778.tvsquared.com, s.pinimg.com, www.redditstatic.com, sc-static.net,
cdn.taboola.com, cdn.pdst.fm, go.affec.tv, t.teads.tv, q.quora.com,
ad.doubleclick.net, heapanalytics.com, vars.hotjar.com, t.co,
sslwidget.criteo.com, gum.criteo.com, stats.g.doubleclick.net, www.facebook.com,
alb.reddit.com, trc.taboola.com, us-central1-adaptive-growth.cloudfunctions.net,
rp.liadm.com, tr.snapchat.com, www.google.com, www.google.co.uk,
googleads.g.doubleclick.net, adservice.google.com, ct.pinterest.com,
secure.adnxs.com, www.snapengage.com, adservice.google.co.uk,
trc-events.taboola.com, fonts.googleapis.com, fonts.gstatic.com,
cdn.siftscience.com, analytics.twitter.com and hexagon-analytics.com.

To the extent permissible under applicable laws, we disclaim any liability with
regards to any third party’s compliance with its legal obligations.

Your browser may offer you a "Do Not Track" or "DNT" option, which allows you to
signal to operators of Third Party Services that you do not wish such operators
to track certain of your online activities over time and across different
websites. However, because we collect browsing and persistent identifier data,
our Services do not support DNT requests at this time, which means that we may
collect information about your online activity both while you are using the
Services and after you leave them. You should also know that certain Third Party
Services may not support DNT requests either – you should check their respective
privacy policies for more information.

You can decide whether or not to accept most Cookies. Most browsers allow you to
delete Cookies and have an option for turning off the Cookie feature, which will
prevent your browser from accepting new Cookies, as well as (depending on the
sophistication of your browser software) allowing you to decide whether to
accept each new Cookie in a variety of ways. To explore what Cookie settings are
available to you, look in the "preferences" or "options" section of your
browser's menu. You can always choose to stop us from collecting your Cookie
Information by turning off the Cookie feature on your browser or by ceasing to
use the Services. However, if you do prevent us from collecting your Cookie
Information, you should know that some of the Services may not work properly.

If you'd like to know more about Cookies, including information about how to
manage, disable and delete them, you can visit
http://ec.europa.eu/ipg/basics/legal/cookies/index_en.htm,
https://ico.org.uk/for-the-public/online/cookies/,
http://www.youronlinechoices.com/uk/ or http://www.allaboutcookies.org/.

ADDITIONAL INFORMATION ABOUT INTEREST-BASED ADVERTISEMENTS We serve
advertisements, and also allow third party ad networks, including third party ad
servers, ad agencies, ad technology vendors and research firms, to serve
advertisements through the Services. These advertisements are sometimes targeted
to users who fit certain general profile categories or display certain
preferences or behaviors (such advertisements, "Interest-Based Ads").
Information for Interest-Based Ads (including Personal Data) may be provided to
us by you, as outlined above, as well as derived from the usage patterns of
particular users on the Services and/or Third Party Services over time. Such
information may be gathered by us or our third party service providers through
Cookies, which may include a file known as a "web beacon" from an ad network to
you through the Services. Web beacons allow ad networks to view, edit or set
their own Cookies on your browser, just as if you had requested a web page from
their website, allow them to serve Interest-Based Ads to you when you visit
other websites, and also allow them to provide us and our advertisers with
anonymized, aggregated auditing, research and reporting about advertisements.

Remember, you can always choose to stop us from collecting your Cookie
Information by turning off the Cookie feature on your browser or by ceasing to
use the Services. Also, you can opt out of Interest-Based Ads sourced by Google
using Google's Ads Settings. For more information on how to make choices about
Interest-Based Ads from participating third parties, and to learn how to opt out
of receiving them from participating organizations, please visit the European
Interactive Digital Advertising Alliance's user information website at
http://www.youronlinechoices.eu/.

LINKS AND CONFIRMATIONS When you open an email or an SMS, MMS or other text
message, or a push notification (each, a "Message") sent by us, or click on any
links in that Message, we receive a confirmation that you did so (and when), as
well as Cookie Information. We also receive confirmation and Cookie Information
when you click on any links elsewhere throughout the Services, including on our
website and our branded pages on social media. We use the information described
in this paragraph to assess the effectiveness of our Messages and associated
marketing campaigns, to learn more about the audience for our Messages, and to
better understand your preferences, all based on our legitimate business
interest in marketing to individuals who may be interested in our services and
products. You can stop receiving Messages from us at any time by emailing us at
ukhelp@harrys.com or calling us at 0808-164-8618.

Additionally, you should know that when you click on an advertisement for, or
link to, a Third Party Service that appears anywhere on the Services, the Third
Party Service or its advertiser may receive a confirmation and certain Cookie
Information from you for the same purposes listed in the preceding paragraph,
based on their own legitimate business interest in marketing to individuals who
may be interested in their products and services. Remember, this Privacy Policy
does not apply to your access or use of any Third Party Services, and we're not
responsible for the content, products, services or privacy policies of those
Third Party Services. We encourage you to carefully review the privacy policies
of any Third Party Services you access.

INFORMATION FROM ADVERTISING AND ANALYTICS PARTNERS We work with advertising and
analytics companies that provide us with certain information about you, your
interactions with us and the Services, and your usage of both the Services and
Third Party Services, including your age or birthday, demographic or interest
data, Cookie Information, hashed email addresses, unique identifiers assigned to
you by our Advertising Partners, as well as pages or content you've viewed,
links you've clicked or other actions you've taken on both the Services and on
Third Party Services. We use this information in order to enhance our
understanding of your interests and preferences, so that we can serve you with
Interest-Based Ads and measure their effectiveness, based on our legitimate
business interest in marketing to individuals who we think may be interested in
our services and products. We sometimes attempt to direct Interest-Based Ads to
individuals who fit a certain general category, and as a result of the
information our advertising and analytics partners provide us, Interest-Based
Ads or other advertisements or recommendations may appear on Third Party
Services that you visit.

To collect the information described above, as well as to serve targeted
advertisements to you, our advertising and analytics partners sometimes
integrate their own Cookies, including web beacons, into the Services and/or
into Third Party Services that you visit, as mentioned above. Remember, you can
elect not to have these Cookies collect your information on the Services. Also,
your browser or device may offer you a "Do Not Track" or "DNT" option, which
allows you to signal to operators of Third Party Services (including, without
limitation, behavioral advertising services) that you do not wish such operators
to track certain of your online activities over time and across different
websites; however, we cannot and do not make any promises about how such Third
Party Services will react when you set this signal on your browser.

You may also consider changing your settings to block third party Cookies
generally, where possible. Again, if you'd like to know more about Cookies,
including information about how to manage, disable and delete them, you can
visit http://ec.europa.eu/ipg/basics/legal/cookies/index_en.htm,
https://ico.org.uk/for-the-public/online/cookies/,
http://www.youronlinechoices.com/uk/ or http://www.allaboutcookies.org/.

INFORMATION FROM OTHER SERVICE PROVIDERS In addition to our advertising and
analytics partners, we contract with various third party entities in order to
operate our business and provide you with the Services and our products. These
third parties provide us with various services described throughout this policy,
including shipping and logistics, name and address verification, email
distribution, market research, fraud prevention, promotions management and
payment processing, and may share with us information about you that they have
independently developed or acquired (in accordance with their own privacy
policies and practices) for those purposes, as may be necessary for us to
complete a contract with you or in furtherance of our legitimate business
interests.

TRANSACTION DATA We sometimes request and receive information about your
transaction history from our Payment Processor in order to process your purchase
orders and shave plans, or to enroll you in discount, rebate and other programs
in which you have elected to participate and use it to verify your identity by
combining it with information you provide us, based on our legitimate business
interest in protecting against fraudulent transactions.

WHO WE SHARE YOUR PERSONAL DATA WITH We share your Personal Data within our
corporate family, including with our United States subsidiary, Harry's USA, Inc.
We also share your Personal Data with third party vendors, service providers and
agents, for the purposes and on the legal bases discussed herein, including:

• with shipping and logistics companies, our Payment Processor and others that
we rely on to provide you with the Services or process and fulfill your shave
plans and purchase orders, in each case, as may be necessary to complete a
contract with you under our Terms of Service or your purchase orders or shave
plans; and

• with advertising companies, analytics companies, marketing service providers,
Epsilon Abacus and the Abacus Alliance Members (but only if you have indicated
that you want us to do so), fraud detection and prevention service providers,
name and address verification service providers, email providers, email
verification and suppression service providers, hosting and database service
providers, data security service providers, customer relationship management
service providers and staff augmentation and contract personnel, in each case,
based on various legitimate interests described in this Privacy Policy.

We seek to provide these third party vendors, service providers and agents with
only the Personal Data they need to perform their services, and we work with
them to help ensure that your privacy is respected and protected. Unless set
forth in this Privacy Policy or otherwise communicated to you, these third
parties do not have any rights to use your Personal Data beyond what is
necessary to provide those services requested by us.

We also share your Personal Data with other third parties where you have given
us your consent to do so, including for marketing purposes, based on your
consent, which you may withdraw at any time, by emailing us at ukhelp@harrys.com
or calling us at 0808-164-8618. As stated above, you can always choose to stop
receiving these messages from us by emailing us at ukhelp@harrys.com or calling
us at 0808-164-8618. Additionally, we share certain Cookie Information with
Third Party Services where you have chosen to interact with them through the
Services, such as by clicking on a link or advertisement on the Services.

PUBLIC INFORMATION If you post information or content publicly on or through the
Services (including when you submit comments or reviews of our shave plans,
products or Services), or post content publicly elsewhere, including on your
social media accounts, that relates to us or the Services, we may receive and
share that public information with third parties, based on our legitimate
business interest in marketing our products and services.

CHANGE OF OWNERSHIP OR CONTROL If we are acquired by or merge with another
company, go out of business or enter bankruptcy, or sell some or all of our
assets, your Personal Data may be sold or transferred in connection with the
transaction in question. If such events do take place, this Privacy Policy will
continue to apply to your Personal Data.

LAWS AND SAFETY We also reserve the right to access, read, preserve and disclose
your Personal Data as we reasonably believe is necessary to:

• satisfy any applicable law, regulation, legal process or governmental request;

• enforce this Privacy Policy and our Terms of Service, including investigation
of potential violations hereof or thereof; or

• protect our rights, property or safety, and those of our users, customers and
the public.

However, nothing in this Privacy Policy is intended to limit your rights and
remedies regarding your Personal Data, including your right to register a
complaint with your local data protection authority.

HOW WE PROTECT YOUR PERSONAL DATA We seek to protect your Personal Data using
appropriate technical and organizational measures, taking into account the
nature of the applicable Personal Data and processing activity. For example, all
Payment Information regularly collected through the Services is encrypted and
maintained using industry standard methods designed to ensure its security
against loss or theft, including during transmission to our Payment Processor.
However, we cannot and do not guarantee or warrant that such techniques will
prevent unauthorized access to Personal Data or other information about you that
we collect and store. Unauthorized entry or use, hardware or software failure,
and other factors may compromise the security of such information at any time.

You can help us prevent unauthorized access to your account with us and your
Personal Data by selecting and protecting your password appropriately and
limiting access to your device and browser by signing off after you have
finished accessing your account.

INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA AND PRIVACY SHIELD We sometimes
transfer your Personal Data outside of the United Kingdom to our authorized
third party agents, vendors and service providers. When we do so, it is our
practice to use contracts with standard provisions approved by the European
Commission that give Personal Data the same protection it has in Europe, or,
where we use third party agents, vendors and service providers based in the
United States, we may transfer data to them if they are part of the Privacy
Shield (more on this below), which requires them to provide similar protection
to Personal Data shared between Europe and the United States.

The Services are hosted and operated in the United States ("U.S.") through us
and our service providers, and if you do not reside in the U.S., laws in the
U.S. may differ from the laws where you reside. By using the Services, you
acknowledge that any of your Personal Data, regardless of whether provided by
you or obtained from a third party, is being provided to us in the U.S. and will
be hosted on U.S. servers, and you authorize us to transfer, store and process
your information to and in the U.S., and possibly other countries. You hereby
consent to the transfer of your data to the U.S. pursuant to the EU-U.S. Privacy
Shield Framework, the details of which are further set forth below.

Harry's, Inc. and our U.S. subsidiary, Harry's USA, Inc., have certified to the
EU-U.S. Privacy Shield Framework set forth by the U.S. Department of Commerce
regarding the collection and use of Personal Data transferred from the European
Union.

Although Harry’s, Inc. and Harry’s USA, Inc. do not rely on the Privacy Shield
Framework as a legal basis for transfers of Data in light of changes in law,
both are still self-certified to the Privacy Shield Principles and adhere to
them. To view Harry's, Inc.’s and Harry's USA, Inc.’s certification, please
visit privacyshield.gov/ .The Privacy Shield Principles require that we remain
potentially liable if any third party processing Personal Data on our behalf
fails to comply with these Privacy Shield Principles (except to the extent we
are not responsible for the event giving rise to any alleged damage). Our
compliance with the Privacy Shield is subject to the investigatory and
enforcement powers of the U.S. Federal Trade Commission.

In compliance with the Privacy Shield Principles, we commit to resolve
complaints about our collection or use of your personal information. UK and EU
individuals with inquiries or complaints regarding our Privacy Shield policy
should first contact us at security-council@harrys.com. 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 also resolve a Privacy Shield-related
complaint through JAMS, an alternative dispute resolution provider located in
the United States. You can visit https://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
complaints not resolved by other means. We are subject to the investigatory and
enforcement powers of the Federal Trade Commission (FTC) and the possibility,
under certain conditions, of your invoking binding arbitration. For the
avoidance of doubt, and as previously stated, we do not rely on the Privacy
Shield Framework as a legal basis for transfers of Data.

Except in the cases set out in this Privacy Policy, Harry’s only transfers
personal data to third parties without the User’s consent if so obliged by law
or by administrative or judicial directive.

WHAT YOUR RIGHTS ARE TO YOUR PERSONAL DATA, AND HOW YOU CAN EXERCISE THEM You
have certain rights with respect to your Personal Data, including those set
forth below. For more information about these rights, or to submit a request
with respect to these rights, you can email ukhelp@harrys.com. Please note that
in some circumstances, we may not be able to fully comply with your request,
such as if it is frivolous, inaccurate or extremely impractical, if it
jeopardizes the rights of others or if it is not required by law, but in those
circumstances we will still respond to notify you of such a decision. In some
cases, we may need you to provide us with additional information, which may
include Personal Data, as necessary to verify your identity and the nature of
your request.

RIGHT OF ACCESS • Where permissible, you can request more information about the
Personal Data we hold about you and you can request a copy of your Personal
Data. If you have an active account with us, you can also access your Personal
Data by visiting your account settings on our website.

RIGHT OF RECTIFICATION • If you believe that any Personal Data we are holding
about you is incorrect or incomplete, you can request that we correct or
supplement such Personal Data. You can also correct some of this Personal Data
directly by visiting your account settings on our website.

RIGHT OF ERASURE • Where permissible, you can request that we erase some or all
of your Personal Data from our systems. You can also delete your account with us
at any time by emailing us at ukhelp@harrys.com or calling us at 0808-164-8618.

RIGHT TO WITHDRAW CONSENT • If we are processing your Personal Data based on
your consent (as indicated at the time of collection of such data), you have the
right to withdraw your consent to this processing at any time, which you can do
by emailing us at ukhelp@harrys.com or calling us at 0808-164-8618. Please note,
however, that if you exercise this right, you may have to then provide express
consent on a case-by-case basis for the use or disclosure of certain of your
Personal Data, if such use or disclosure is necessary to enable you to utilize
some or all of our Services.

RIGHT TO OBJECT TO PROCESSING AND TO RESTRICT PROCESSING • Where permissible,
you can let us know that you object to the further use or disclosure of your
Personal Data for certain purposes, such as marketing to you (to name one
example), and you can also ask us to restrict further processing of your
Personal Data.

RIGHT OF PORTABILITY • Where permissible, you can ask for a copy of your
Personal Data in a machine-readable format, and you can also request that we
transmit the data to another controller where technically feasible.

RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY • You have the right to
lodge a complaint about our practices with respect to your Personal Data with
the Information Commissioner's Office. Please visit
https://ico.org.uk/global/contact-us or call 0303 123 1113 for more information.

OUR PERSONAL DATA RETENTION POLICY We retain your Personal Data for as long as
you have a working account with us, or as otherwise necessary to provide you
with the Services. In some cases we retain Personal Data for longer, if doing so
is necessary to pursue our legitimate business interests (but only if those
interests are not overridden by your own interests, rights and freedoms), comply
with our legal obligations, resolve disputes or collect fees owed, conduct
audits, or if doing so is otherwise permitted or required by applicable law,
rule or regulation. Afterwards, we dispose of your Personal Data securely, but
may retain some information in a depersonalized or aggregated form but not in a
way that would identify you personally.

As stated above, you can request us to erase some or all of your Personal Data
from our systems, and you can delete your account with us at any time, by
emailing us at ukhelp@harrys.com or calling us at 0808-164-8618.

ANY QUESTIONS OR CONCERNS? If you have any questions or concerns regarding how
we collect, use, protect or share your Personal Data, including, for example,
about our legitimate business interests or the legitimate business interests of
others that we describe above, please send a detailed message to
ukhelp@harrys.com or to our Data Protection Officer directly at
security-council@harrys.com. You can also reach out to Harry's Grooming Limited
at its registered office located at 5th Floor 101 St Martins Lane, London,
United Kingdom, WC2N 4AZ. We will make every effort to resolve your concerns.

EFFECTIVE DATE: May 2023

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