Privacy and Cookie Policy

Last Updated: December, 2019

This Privacy Policy and Notice (we refer to it as our “Privacy Notice”) describes how Wahl Clipper Corporation and its subsidiaries (“Wahl” or “we” or “us” ) collect, use, share, retain, and protect information about you that we receive when you (1) visit us at https://wahl.comhttp://wahlpro.comhttp://wahlusa.comhttp://www.somahaircare.comhttps://wahlbarberbattle.comhttps://wahlanimal.com, or http://wahlglobal.com (the “Websites”); (2) communicate with us or the Websites via email, text message, and other electronic messages; (3) interact with our advertisements or applications on third-party websites and services; and, (4) interact with us offline, such as on the telephone, in writing, or in-person, including at trade shows and other events. We adopt this Privacy Notice to fulfill our commitment to you and comply with legal obligations1 as we process personal information, described below, in order to fulfill our service commitment to you.

This Privacy Notice does not apply to information collected or used by any third party or affiliate, including those that may link to or can be accessible via the Websites. Please review their policies. Wahl is not responsible for the content or the privacy policies or practices of third-parties, their websites, or their apps.

Before accessing, using, or interacting with the Websites you should carefully review this Privacy Notice and our Terms of Service (http://us.wahlglobal.com/Home/Legal.aspx), which are incorporated by reference and also govern use of the Websites. We may change our Privacy Notice and Terms of Service from time to time and encourage you to review them whenever you interact with us.

User Consent: By choosing to interact with Wahl, including through our Websites, advertisements, applications, contests, sweepstakes, products, services and events, and by communicating with us via email, telephone, or in person, you consent to the collection and use of information as described in this Privacy Notice and you represent that you are at least 16 years old. If you are under the age of 16 or you do not consent to the collection, use and/or disclosure of your personal information as set forth in this Privacy Notice, please exit and do not use our Websites or other services.

California Users: If you are a resident of the State of California, see the California Privacy Notice for additional information about your rights and our disclosures. The California Privacy Notice is in addition to this Privacy Policy.

 


1 For California Residents, we adopt this Notice, in part, to comply with our obligations under the California Consumer Privacy Act of 2018 (“CCPA”). The portions of this Notice that specifically reference “California Residents” or describe rights created by the CCPA, apply solely to visitors, users, and others who are consumers residing in the State of California as defined by the CCPA and in Section 17014 of Title 18 of the California Code of Regulations. For California Residents, any terms defined in the CCPA have the same meaning when used in this Notice.

What Personal Information Does Wahl Collect?

We collect and store information that you give us directly. For example, when you:

  • Register an account (a “Website[s] Account”), we may collect your, email, username, password, address, orders, downloadable products, wish list, telephone, and fax number
  • Register a product, we may collect your name, address, email, income, gender, product name, model number, price, date and store of purchase
  • Request product support, we may collect your name, email contact information, phone number, and any other information you choose to provide to us regarding your request
  • Enter or sign-up for a sweepstakes or contest, we may collect your name, email, address, birthday, telephone, and any additional information that you provide (i.e., pictures or videos)
  • Email us, sign up for notifications, subscribe to our newsletters or mailing lists, we may collect your name, email, phone number, and address
  • Enroll in the Wahl Ambassador Program, we may collect your name, email, telephone number, state, professional license number, and state of licensure
  • Attend a tradeshow, we may collect your name, email, address, telephone number, employment information, and information regarding your preferences to serve you better
  • Make a direct purchase, as a distributor, from Wahl, we may collect and store the items purchased, your payment method and information, billing and shipping information, telephone number, and email
  • Make a purchase through Wahl’s website, your payment method or information (e.g., debit and credit card number and information), billing and shipping information, and other purchase information are collected and maintained by our third-party service providers, including Braintree, Authorize.net, and MAI, which specialize in the secure capture and processing of credit/debit card transactions and order fulfillment. Wahl does not collect, or store, credit card information you provide at the time of an online purchase

 

We also receive and store certain types of information automatically when you interact with us online or with the Websites. For example, we use:

  • Cookies2 , web beacons3 , links, and other tracking technologies to gather Information regarding your use and interaction with the Websites, our email correspondence, third party services, client applications, and certain other online activities (including sites you visit, your browser type, operating system, and interactions with our content and emails)
  • Third Parties, who manage our advertising on other sites, provide us information regarding your browsing activities and interests

 


2 "Cookies" are small bits of information that are stored on your hard drive or in connection with your Internet browser. Cookies remember information about your activities on the site and provide a customized experience when you visit our Websites. If you've chosen to disable cookies on your browser, some of the functionality of our website may be lost. Certain of our web page, particularly those that require a login and password, require that cookies be enabled in your browser and cannot be used when you have disabled cookies in your browser.

3 “Web beacons” are small images embedded into websites or emails that send information about your computer, tablet, phone, or other device when you visit our website or open an email we send to you

4 A unique identifier is an automatically assigned string of characters that can be used to uniquely identify a browser, app, or device. Different identifiers vary in how permanent they are, whether they can be reset by users, and how they can be accessed.

  • Unique Identifiers (such as a universally unique identifier or “UUID”)4
  • Data and Mobile Analytics to collect information about your website usage, performance data, app errors, and debugging information from where the Websites were downloaded
  • Log File Information to learn your IP address, browser type, access times, domain names, operating system, the referring web page(s), pages visited, location, mobile carrier, device information (including IDs), search terms, and cookie information

Wahl also learns about you through information you make publicly available, such as on a social network. Please note, any content or information you share with or provide to third parties regarding Wahl, your communications with Wahl, or using or related to the Websites may not be private or confidential and is not the responsibility of Wahl.

 

How Does Wahl Use Information About Me?

Wahl may use and process information about you for one or more of our legitimate business purposes. For example, Wahl (and/or our Service Providers) may use your information to:

  • Fulfill or meet the reason your information was collected or provided
  • Deliver communications, information or services, and promotions
  • Provide support to you and other users
  • Present, optimize, and maintain the security of our Websites and their contents
  • Register, maintain, and provide notifications to you about your Websites Account
  • Detect and prevent fraud or other crimes
  • Respond to law enforcement requests and as required by applicable law or court order
  • Research, test, analyze, and develop our products, Websites, and services
  • Fulfill orders (i.e. taking payment, providing updates, shipping, and managing any issues, including but not limited to refunds and returns)
  • Allow you to participate in interactive features on our Websites
  • Personalize your Websites experience and to deliver content, product and service offerings relevant to your interests, including targeted offers through our Websites, third-party sites, and via email or text message (with your consent, where required by law)

 

Does Wahl Share the Information It Receives About Me?

Wahl does not and will not sell your personal information. We may share information about you, including personal information, with subsidiaries who are subject to this Privacy Notice or follow practices at least as protective as those described here, or with Service Providers with whom we have entered into contracts that require personal information be kept confidential and prohibit the retention, use, or disclosure of personal information for any purpose other than the services specified. Wahl does not share or disclose information for commercial purposes without your consent, except as described below:

  • Within the Wahl Family: We may share personal information internally within Wahl and with our subsidiaries and affiliates. Wahl’s personnel may have access to personal information as needed to provide and operate the Websites in the normal course of business
  • Service Providers: We employ other companies and individuals to perform functions on our behalf, including fulfilling orders, delivering packages, sending mail, analyzing data (such as Google Analytics), providing marketing assessments, providing analytics information, processing payments, providing data hosting (as specified below). They have access to personal information needed to perform their functions, but not for other purposes.
  • Business Transfers: If we purchase other businesses or their assets, sell our business assets, or are involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information, including any category of personal data collected by Wahl, may be among assets sold or transferred and may be subsequently used by a third-party.
  • Lawful Requests and Safety: We release personal information when we believe it is appropriate to comply with the law, it is necessary to protect our interests, to prevent fraud or other illegal activity, and to protect the safety of any person. Nothing in this Privacy Notice is intended to limit any legal defenses or objections that you may have to a third party’s, including a government’s, request to disclose your information.
  • Business and Marketing Partners: We may disclose de-identified, aggregated, non-personal data received from providing the Websites with certain trusted business partners, without restriction. Wahl does not share non-aggregated information or information that has not been de-identified with third-party business partners.

 

How Does Wahl Store Information About Me?

The information Wahl gathers about you may be transferred, processed, maintained on and/or accessed by us outside of your state or in a jurisdiction with different, and less protective, privacy laws. If you are in the European Economic Area ("EEA") or other regions with laws that may differ from the United States and choose to allow us to collect information about you, please be aware that Wahl (or our Service Providers) may transfer, process, and store that information in the United States, or another jurisdiction that does not have the same data protection laws.

Website Hosting

Wahl works with various web hosting services providers, including, for example: Amazon Web Services to host wahl.comwahlUSA.com, and wahlglobal.com; Azure to host wahlglobal.com; Digital Ocean to host wahlpro.comsomahaircare.com, and wahlbarberbattle.com; and, Mindfire Communications, Inc. to host wahlanimal.com.

Data Hosting

Wahl works with various data hosting services providers, including, for example: Drupal, Perch and Magento for wahl.com and wahlUSA.com; Kentico for wahlglobal.com; Digital Ocean for wahlpro.comsomahaircare.com, and wahlbarberbattle.com; and, Mindfire Communications, Inc. for wahlanimal.com.

Data Retention

We generally retain the information we collect only for as long as necessary to fulfill the purposes for which it was collected, to fulfill our contractual and legal obligations, or as otherwise required by law. Following termination or deactivation of a Website Account, we may either retain your information and content for a commercially reasonable time for backup, archival and audit purposes or may delete your personal data from our systems as part of a data retention plan and cyber-hygiene policies.

 

How Secure Is the Information About Me?

We realize that you trust us to protect your personal information. We take that trust seriously and maintain physical, electronic and procedural safeguards that are consistent with industry standards, to help protect the privacy, accuracy, and reliability of personal information and to protect it from loss, misuse, unauthorized access, disclosure, acquisition, exfiltration, alteration and destruction. We also take reasonable steps to ensure that our Service Providers reasonably protect your information. If Wahl becomes aware that a Service Provider is using or disclosing information improperly, we will take commercially reasonable steps to end or correct such improper use or disclosure.

While we attempt to protect the information in our possession, and account for the protection of information provided to our Security Providers through us, no security system is perfect and we cannot promise that information about you will remain secure in all circumstances. Please do your part to help us keep your information secure. You are responsible for maintaining the confidentiality of your password and Website Account(s), and for all activities that occur under your password or Website Account. Wahl specifically reserves the right to terminate your access to the Websites and any contract you have with Wahl related to the Websites in the event it learns or suspects you have disclosed your Websites Account or password information to an unauthorized third party.

 

What Choices Do I Have?

Wahl seeks to ensure all individuals are provided with the rights mandated by their governing jurisdiction. Not all of the rights discussed herein will apply to everyone and, depending upon your jurisdiction, may not apply to you. For example, the CCPA provides California Residents the right, under certain circumstances, to request that Wahl disclose or delete their personal information. Certain other rights are specific to individual data subjects residing in the European Union (“EU”), including: the right to access (GDPR, Article 15); the right to rectification (GDPR, Article16); the right to erasure (GDPR, Article 17); the right to restrict processing (GDPR, Articles 18); the right of object (GDPR, Article 21); and if applicable, the right to data portability (GDPR, Article 20). You may also have a right to lodge a complaint with an appropriate data privacy regulatory authority (GDPR, Article 77).

We welcome you to contact us at privacy@wahlclipper.com regarding how we communicate with you and the information we have collected about you, including how we use that data, the nature and accuracy of that data, to request an update, modification, or deletion, or to opt-out of certain uses. Under certain circumstances, you may also request to withdraw consent previously provided. We will endeavor to accommodate your request to the extent feasible and where required by law.

Communications from Wahl

Users may opt-out or object to receiving certain communications from Wahl by following the unsubscribe process described in our communications, changing your account settings, or by contacting us via the contact information provided below. Please note that such requests may take some time to fulfill and that certain product and Website-related communications, including but not limited to account verification, changes or updates to features of the Websites, or technical and security notices are non-optional.

Advertising

You may opt out of online ads at http://www.aboutads.info/choices/. You also may limit certain tracking by disabling cookies in your web browser. Where we use your data for direct marketing purposes, you can always object by following the unsubscribe process in such communications or changing your account settings.

Do Not Track

Wahl does not currently employ a process for automatically responding to “Do Not Track” (DNT) signals sent by web browsers, mobile devices, or other mechanisms. Per industry standards, third parties may be able to collect information, including personal data, about your online activities over time and across different websites or online services when you use Websites.

Accessing, Modifying, or Deleting Information About Me

If you would like to access personal information about you, you may make a request at privacy@wahlclipper.com or via the Contact Information, specified below. You may also request to restrict or limit how we: use such information; its deletion; or, even, ask for information in an easily accessible format. However, if you do so, certain features, including but not limited to access to the Websites, may no longer be available. Please note that requests to delete your information do not necessarily ensure complete or comprehensive removal of that content or information because removed information may persist in backup copies indefinitely.

 

Notice to California Residents of Their Rights Under the CCPA

The CCPA provides California Residents (please see Note 1, above) with specific rights regarding their personal information. These rights apply solely to visitors, users, and others who reside in the State of California or another jurisdiction that has adopted the same or similar requirements. The following sections describe your CCPA rights and explain how to exercise those rights.

What Categories of Personal Information Has Wahl Gathered in the Past Year?

For this California Notice, unless we indicate otherwise, “personal information” means information that identifies, relates to, describes, references, is reasonably capable of being associated with or could reasonably be linked, directly or indirectly, with a person or household (“personal information”). Personal information does not include: publicly available information from government records; de-identified or aggregated consumer information; and, information excluded from the CCPA’s scope.

In the past twelve (12) months, we have collected one or more pieces of personal information that falls into eleven of the categories of personal information defined in the CCPA and as indicated below.

Categories of Personal Information Wahl Has Gathered in the Past Year
Category Definition Collect? What
A. Identifiers Real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, drivers license number, passport number or other similar identifiers YES All but not passport #, drivers license #
B. Customer Records5 Name, signature, physical characteristics or description, address, telephone number, bank account number, credit card number, debit card number, or other, similar information that is not publicly available from state, government or local government records YES Name, Address,Phone #
C. Classification Characteristics Protected By Law Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex/gender, pregnancy or childbirth, sexual orientation, veteran or military status, genetic information YES Age Sex
D. Commercial Information Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies YES All but not passport #, drivers license #
E. Biometric Information as Defined in the CCPA An individual’s physiological, biological or behavioral characteristics, deoxyribonucleic acid (DNA), that can be used, singly or in combination with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information YES only as specified in fn 6 Photos Videos see fn 6
F. Internet or Other Network Activity Browsing history, search history, information on a consumer’s interaction with an internet website, application, or advertisement YES Cookie tracking
G. Geolocation data Physical location or movements YES  
H. Sensory data Audio, electronic, visual, thermal, olfactory, or similar information YES Photos Videos; see fn 6
I. Professional Employment Related Data Current or past job history YES  
J. Non-public Education Information 7 Education records directly related to a student maintained by an educational institution or party acting on its behalf NO  
K. Inferences Drawn from Personal Information Information that may be used to create a profile about a consumer reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes YES  

5 Including the categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Some personal information included in this category may overlap with other categories.

6 Our collection of data that is categorized as “sensory” or “biometric” for purposes of the CCPA is limited to photographs and voluntarily provided video, such as those submitted during the Wahl Man of the Year, and eye tracking technology. We do not collect sensory or biometric data as defined by other laws, including, without limitation, the Illinois Biometric Information Privacy Act.

7 Per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)

 

How Has Wahl Shared Personal Information over the Past Year?

Wahl has not sold personal information in the past twelve (12) months. We have shared the following categories of personal information with other members of the Wahl Family, our service providers and third parties with which you have agreed we can share your information, in the past twelve (12) months:

  • Identifiers
  • Customer records
  • Commercial information
  • Internet or other network activity
  • Geolocation data
  • Inferences drawn from personal information

Access to Specific Information and Data Portability Rights

The CCPA gives California Residents the right to ask us about our collection and use of the personal information we have collected, used, and disclosed over the past twelve (12) months. To do so, you can submit a verifiable consumer request (a “Request to Know”). Once we receive and confirm the verifiable consumer request, we will make a disclosure to you about:

  • Categories of personal information we collected about you;
  • Categories of sources for the personal information we collected about you;
  • Our business or commercial purpose for collecting the personal information;
  • Categories of third parties with whom we share that personal information;
  • Certain, specific pieces of personal information we collected about you (“Data Portability Request”); or,
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: (1) sales, identifying the personal information categories that each category of recipient purchased; and, (2) disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Requests to Modify or Delete Personal Data

California Residents have the right to request that we delete the personal information we have collected and retained (“Requests to Delete”) about you. Upon Wahl’s receipt of a verifiable request to delete personal information (see Exercising Access, Data Portability, and Deletion Rights, below), we will delete your personal information from our records and direct service providers to also delete your personal information.

Note that Wahl may deny your deletion request and, then, won’t comply with your request (so we wouldn’t ask service providers to comply with the request, either) if retaining the information is necessary to perform certain functions or commitments as follows: completing the transaction for which the personal information was collected; providing a service requested; otherwise performing our contract with you or taking reasonably anticipated actions within the context of our ongoing business relationship with you; detecting security incidents and protecting against malicious, deceptive or otherwise illegal activity or to prosecute those responsible for those activities; complying with a legal obligation or otherwise using the personal information, internally, in a lawful manner; complying with the California Electronic Communications Privacy Act; fulfilling the terms of a written warranty or product recall conducted in accordance with federal law; or, for a purpose otherwise contemplated by Cal. Civ. Code Section 1798.105(c)-(d) and as amended.

How to Exercise Your Access, Data Portability, And Deletion Rights Under the CCPA

You may make a verifiable customer request for access or data portability twice within a 12-month period. To exercise the access, data portability and deletion rights described above, please submit a verifiable consumer request to us by either:

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 the personal information about you. If the request is made through an agent, we reserve the right to require a signed authorization or verification of the agent’s identify from you in order protect the privacy of the personal information requested. You may also make a verifiable consumer request on behalf of your minor child.

Should you call us or visit the website we’ve shown above, you will access the form we have for making a verifiable request. But, generally, your verifiable request must:

  • Provide sufficient information to allow us to reasonably verify you are the person about whom we collected personal information or that you are the authorized representative of that person;
  • Describe your request with sufficient detail to allow us to understand, evaluate and respond to it.

Here’s the thing: we can’t provide you with the information sought in a Request to Know, or comply with a Request to Delete, if we can’t verify your identity or authority to make the request and/or can’t confirm the personal information relates to you. We’re trying to avoid any unauthorized access of your data. So, we reserve the right to require additional information from you to verify your request before we respond. Any information provided to us in a verifiable customer request will be used only to verify the requestor’s identity or authority to make the request. We also reserve the right to refuse a Request to Know or a Request to Delete if we reasonably believe that the request may be fraudulent or may compromise the security of personal information. Where we refuse a Request, we’ll let you know and explain the reasons for refusing.

Response Timing and Format

We’ll let you know that we received your request within ten (10) days of receipt and give you information regarding how we will process your request. We’ll try to respond to a verifiable consumer request within forty-five (45) days of its receipt. And, if we require more time to provide a response, we will write to you and give you the reason for the extra time and amount of extra time. For example, if you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the twelve (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. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to send the information from one entity to another entity without problems. Know that we don’t charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive or manifestly unfounded. If we determine that the request warrants a fee, we’ll tell you why and provide you with a cost estimate before completing your request.

As mentioned above, we may collect or process sensitive data as needed or required to deliver services you have requested, to inform you of other products or services, and to contact you via surveys to conduct research about your opinions. You may request that we delete this information, subject to certain exceptions as provided by the CCPA.

Other California Privacy Rights

Under California Civil Code Section 1798.83 (known as the "Shine the Light" law), residents of California may request certain information about our disclosure of personal information during the prior calendar year to third parties for their direct marketing purposes. To make such a request, please write to us at the address below or at privacy@wahlclipper.com with "Request for California Privacy Information" on the subject line and in the body of your message. We will comply with your request within thirty (30) days or as otherwise required by the statute. Please be aware that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing will be included in our response.

Non-Discrimination

We will not discriminate against you for exercising any of the rights conferred by California statute, including the CCPA. Unless permitted by law, we will not: deny you goods or services; charge you different prices or rates; provide you a different level or quality of goods or services; or suggest that you may receive a different price or rate or a different level or quality of goods or services. We may offer 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.

 

Children’s Personal Information & Safety

Despite Wahl’s safety and privacy controls, we cannot guarantee the Websites are entirely free of illegal, offensive, or otherwise inappropriate material, or that you will not encounter inappropriate or illegal conduct from other users when using the Websites. You can help Wahl by notifying us of any unwelcome contact by using the information below to get in touch with us.

Children under the age of sixteen (16) may not use or provide information on our Websites. We will delete, immediately, any information from or about a child under the age of sixteen (16). Please notify us at privacy@wahlclipper.com if we might have collected data from or about a child under the age of sixteen (16).

Changes to Our Privacy Notice

Wahl may modify this Privacy Notice from time to time. The most current version of this Privacy Notice will govern our use of your information and will be located at https://www.wahl.com/privacy. We will notify you of material changes to this policy by posting a notice at the Websites or by emailing you at an email address associated with your Websites Account, if applicable, and provide an “at a glance” overview of any changes.

Contact for More Information

Wahl Clipper Corporation is located at 2900 North Locust Street, Sterling, Illinois 61081. Should you have any comments or questions about how we collect and use your personal information, communication can be directed to Wahl’s postal address, via email to privacy@wahlclipper.com or by telephone to (844) 999-0307.

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