grüum Europe Limited Privacy Policy

Please read the policy carefully as it applies to the products and services we provide to you (such as toiletries, cosmetics, subscriptions and one-off purchases) and our websites.  It only applies to our consumer and partnership customers.

It also applies even if you’re not one of our customers and you interact with us, such as by:

• Using one of our products or services – paid for by someone else
• Entering a prize promotion
• Participating in a survey or trial
• Entering a competition
• Contacting our customer service via our helpdesk
• Making an enquiry on our website
• Starting but not completing an order
• Generally enquiring about our company, products and/or services

If you need to give us personal information about someone else in relation to our products and services, this privacy policy will also be applicable.

If we need the permission of the other person to use that information, we’ll ask you to check they are OK with this.

Why does Gruum Europe Limited have a Privacy Policy?

We have a legal obligation to let you know what personal information we collect about you, what we use it for and on what basis. We always need a good reason to collect it and we also have to explain to you your rights in relation to that information. You have the right to know what information we hold about you and to have a copy of it, and you can ask us to change or sometimes delete it. 

The reasons we collect information are set out in this privacy policy. However, we believe that it is very important for our customers to trust us with that information. We treat your data in the same way that we would expect others to treat ours with respect and we want you to be confident that we will keep it secure and always use in your best interests and lawfully.

Our privacy policy explains in detail how we use your personal information. It describes what we do (or what we may do) from the moment you register an interest in a service or product from us, when we may use your information to determine which products or services would best suit you, through to providing and billing such services or products. It also applies to marketing other products that we think will interest you and to seeking feedback from you to help us improve our service whether you are a customer or not.

But whatever we do with your information, we need a legal basis for doing it. We generally rely on one of three grounds (reasons) for our business processing information. Firstly, if you have ordered or take a service from us, we are entitled to process your information so that we can provide that service to you and bill you for it.

Secondly, if we want to collect and use your information for other purposes, we may need to ask for your consent (permission) and, if we do, that permission must always be indicated by a positive action from you (such as ticking a box) and be informed. You are also free to withdraw your permission at any time. We tend to need permission when what is proposed is more intrusive (for example, sharing your contact details with other organisations so they can market their own products and services to you).

But we do not always need permission. In some cases, having assessed whether our use would be fair and not override your right to privacy, we may come to the view that it falls within the third ground – our ‘legitimate interests’ to use the information in a particular way without your permission (for example, to protect our website against cyber-attacks). But when we do this, we must tell you as you may have a right to object. And if you object specifically to us sending you marketing material, or to ‘profiling you’ for marketing purposes, we must then stop.

This is all set out in detail in this policy, which focuses more on those items that we think are likely to be of most interest to you. As well as covering processing for business purposes, we give you information on circumstances in which we may have to, or can choose to, share your information.

Who we are:

We are Gruum Europe Limited, trading as grüum, located at Unit 3, Brookside Industrial Estate, Stockport, SK1 3BJ in the United Kingdom.

Checking & updating how we use your information:

We want to make sure that any personal information we hold about you is accurate. Therefore if you think your personal information is inaccurate, you can ask us to correct or remove it at no charge to you. Please contact us via our website and we will be happy to help.

Under General Data Protection Regulation, you have a right to know what personal information we hold about you. If you’d like a copy of the information you are entitled to please write to Gruum Europe Ltd., Unit 3, Brookside Industrial Estate, Stockport, SK1 3BJ, clearly identifying yourself and the information you require. We will ask you to provide identification to ensure we do not disclose your information to the wrong people. Please note that you can obtain previous order information free of charge on the ‘My Account’ section of our website.

You can always tell us that you do not wish to receive direct marketing communications from grüum. But remember, if you do not want us to get in touch, you may miss out on valuable and exciting offers. If you would prefer not to receive direct marketing communications from us, simply let us know at any time by contacting us as below or by following the opt-out instructions in the relevant communication. Please note that this will not stop you from receiving purchase information communications from us.

Please contact us through https://support.gruum.com/submit-ticket/

Please note that it may take up to 96 hours to process your opt-out request.

You can also make choices about the cookies and targeted advertising. For more information about this, please refer to our section on cookies.

The General Data Protection Regulation (GDPR) gives individuals the right to ask for their data to be deleted. If you would like us to delete your data please email us on [email protected] and we will action your request.

What kinds of personal information do we collect & how do we use it?

The personal information we collect depends on the products and services you have and how you use them. We’ve explained the different ways we use your personal information below.

To provide you with products & services

We’ll use your personal information to provide you with products and services. This applies when you register for or buy a product or service from us. Or if you register for an online account with us or download and register on one of our apps.

This means we’ll:

• Record details about the products and services you use or order from us
• Send you product or service-information messages (we’ll send you messages to confirm your order and tell you about any changes that might affect your service, like changes of products)
• Update you on when we’ll deliver your products
• Let you create and log in to the online accounts we run
• Charge you and make sure your payment reaches us
• Give information to someone else (if we need to for the product or service you’ve ordered to be billed for example our merchant account provider) or to a third party to help us improve our service to you (if we do this, we still control your personal information and we have strict controls in place to make sure it’s properly protected)

We use the following to provide products and services and manage your account:

• Your contact details and other information to confirm your identity and your communications with us. This includes your name, gender, address, phone number, date of birth (sometimes), email address, passwords
• Your payment and financial information.
• Your communications with us, including emails, webchats and phone calls. We’ll also keep records of any settings or communication preferences you choose
• Information from cookies placed on your connected devices that we need so we can provide a service.

We use this information to carry out our contract (or to prepare a contract) and provide products or services to you.  If you don’t give us the correct information or ask us to delete it, we might not be able to provide you with the product or service you ordered from us.

Because it is in our interests as a business to use your information:

We’ll use your personal information if we consider it is in our legitimate business interests so that we can operate as an efficient and effective business. We use your information to:

• Identify, and let you know about, products and services that interest you
• Share with our 3rd party providers for administrative purposes
• Create aggregated and anonymised information for further use
• Detect and prevent fraud; and
• Secure and protect our business

To market to you & to identify products & services that interest you

We’ll use your personal information to send you direct marketing and to better identify products and services that interest you. We do that if you’re one of our customers or if you’ve been in touch with us another way (such as entering a prize promotion or competition).

This means we’ll:

• Create a profile about you to better understand you as a customer and tailor the communications we send you (including our marketing messages);
• Tell you about other products and services you might be interested in;
• Recommend better ways to manage what you spend with us, like suggesting a more suitable product based on what you use;
• Try to identify products and services you’re interested in; and
• Show you more relevant online advertising and work with other well-known brands to make theirs more suitable too

We use the following for marketing and to identify the products and services you’re interested in:

• Your contact details. This includes your name, gender, address, phone number, date of birth and email address
• Your payment information
• Information from cookies and tags placed on your connected devices
• Information from other organisations such as aggregated demographic data, data brokers, our partners and publicly available sources like the electoral roll and business directories
• Details of the products and services you’ve bought and how you access them or contact us such browser type(including IP address) and device

We’ll send you information (about the products and services we provide) by phone, post, email, text message, online banner advertising. We also use the information we have about you to personalise these messages wherever we can as we believe it is important to make them relevant to you.  We do this because we have a legitimate business interest in keeping you up to date with our products and services, making them relevant to you.  We also check that you are happy for us to send you marketing messages by text or email before we do so. In each message we send, you also have the option to opt out.

We’ll only market other organisations’ products and services to you if you have said it is OK for us to do so.

You can ask us to stop sending you marketing information or withdraw your permission at any time, as set out in the ‘How to contact us and further details’ section below.

Read our cookie policy  https://www.gruum.com/cookies-policy for more details on how we use cookies.

To create aggregated & anonymised data

We’ll use your personal information to create aggregated and anonymised information. Nobody can identify you from that information and we’ll use it to:

• Make sure our website is working properly and continuously improve and develop our website and products and services for our customers
• Run management and corporate reporting, research and analytics, and to improve the business; and
• Provide other organisations with aggregated and anonymous reports

We use the following to generate aggregated and anonymised information.

• Your gender, address and date of birth
• Information about what you buy from us, how you ordered it and how you pay for it, for example, a plan for four 5 blades razor cartridges ordered online and paid for on a quarterly basis
• Information from cookies and tags placed on your computer
• Information from other organisations who provide aggregated demographic information, data brokers, our partners and publicly available sources like the electoral roll and business directories
• Details of the products and services you’ve bought and how you use them – including your browser (including IP address) and device records.

We have a legitimate interest in generating insights that will help us operate our network and business or would be useful to other organisations. 

To develop our business & build a better understanding of what our customers want:

This means we’ll:

• Maintain, develop and test our website (including managing the traffic on our network), products and services, to provide you with a better service
• Train our people and suppliers to provide you with products and services (but we make the information anonymous beforehand wherever possible)
• Create a profile about you to better understand you as our customer

We use the following information to do this:

• Your contact details
• Your payment and financial information
• Your communications with us, including emails, webchats and phone calls (and any recordings made)
• Information from cookies placed on your connected devices

If we use this information for market research, training, testing, development purposes or to create a profile about you, we do so because it is in our legitimate business interests of running an efficient and effective business which can adapt to meet our customers’ needs.

We create a profile about you based on what you have ordered from us, the frequency your order from us and how you communicate with us. This helps us tailor the offers we share with you. You can ask us to stop profiling you for marketing purposes at any time, as set out above.

To collect debt

If you don’t pay your bills, we might ask a debt-recovery agency to collect what you owe. We’ll give them information about you (such as your contact details) and your account (the amount of the debt) and may choose to sell the debt to another organisation to allow us to receive the amount due.

To meet our legal obligations

We might have to release personal information about you to meet our legal obligations.

Sharing your information

We use other providers to carry out services on our behalf or to help us provide services to you.

We also use them to:

• Provide customer-service, marketing, infrastructure, deliver our products, information-technology services;
• Personalise our service and make it work better;
• Process payment transactions;
• Conduct review and feedback of our service and/or products;
• Carry out fraud and credit checks and collect debts;
• Analyse and improve the information we hold (including about your interactions with our service); and
• Run surveys

Where we use another organisation, we still control your personal information. And we have strict controls in place to make sure it’s properly protected.

Finally, the section above describes the situations in which your personal information is shared to other organisations, government bodies and law-enforcement agencies. When we share your information with other organisations we’ll make sure it’s protected, as far as is reasonably possible.

If we need to transfer your personal information to another organisation for processing in countries that aren’t listed as ‘adequate’ by the European Commission, we’ll only do so if we have model contracts or other appropriate safeguards (protection) in place.

From time to time, we may expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Gruum Europe Limited. Data and information provided to us will, where it is relevant to any part of our business, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the information for the purposes for which it was originally supplied to us.

We may also disclose personal information to a prospective purchaser of our business or any part of it.

In the above instances, we will take steps with the aim of ensuring your privacy is protected.

Protecting your information & how long we keep it

How do we protect your personal information?

We have strict security measures to protect your personal information. We check your identity when you get in touch with us, and we follow our security procedures and apply suitable technical measures, such as encryption, to protect your information.

How long do we keep your personal information?

We’ll keep:

• A summary copy of your orders for up to six years from the date of the order
• Your contact details on file while you’re one of our customers, and for six years after; and
• Details relating to any dispute for six years after it was closed

In other cases we’ll store personal information for the periods needed for the purposes for which the information was collected or for which it is to be further processed. And sometimes we’ll keep it for longer if we need to by law. Otherwise we delete it. 

How to contact us & further details

You can get in touch with our data-protection controller by writing to them and marking it for their attention at the address. If you’d like any more details, or you have comments or questions about our privacy policy, write to us at: 

The Data Protection Controller, Gruum Europe Limited, Unit 3, Brookside Industrial Estate, Stockport, SK1 3BJ.

If you want to make a complaint on how we have handled your personal information, please contact our data protection controller who will investigate the matter and report back to you.  If you are still not satisfied after our response or believe we are not using your personal information in line with the law, you also have the right to complain to the Information Commissioner – https://ico.org.uk/.

Transfer rights

You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.

If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.

Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

This privacy policy is governed by and interpreted according to English law. All disputes arising under this privacy policy are subject to the exclusive jurisdiction of the English courts.

Finally, changes to this privacy policy

Gruum Europe Limited reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations.