Privacy Policy

Who is responsible?

The controller for the processing of personal data on shaveindex.com and in the ShaveIndex newsletter is
Roman Pustina, Währinger Straße 99/8, 1180 Vienna, Austria
Email: contact@shaveindex.com

Principles

We only process what is needed to run the service. On the ShaveIndex website we use no third-party advertising or web analytics services, no tracking pixels and no social media plugins, and load no fonts or scripts from third-party servers. For the newsletter we use Brevo, including the sending and statistics functions described in the section "Newsletter". We do not sell personal data.

Visiting the website

Whenever a page is requested, the web server processes technically necessary data: IP address, time, requested address, browser identifier and referring page. This is needed to deliver the page and keep the service secure (Art. 6(1)(f) GDPR, legitimate interest). The access logs are kept by our host only as long as needed for operation and security and are then deleted automatically.

Search suggestions: When you type into a search field, the page asks our server for suggestions. We count these requests per IP address to limit misuse; we store the address only as a cryptographic hash and delete the count after two days at the latest.

Protection against mass scraping: We count how many pages an IP address requests within a short time and slow it down for a few minutes above a limit. We store the address only as a cryptographic hash and delete the count after two days at the latest. If a request claims to come from a search engine, we check this via the name of the requesting computer and remember the result for one day, also only as a hash (Art. 6(1)(f) GDPR).

Protection against copying the catalogue: When you are signed in, we count per account and day how many catalogue pages you open – including product, scent, base, brand and note pages –, how many of them within ten minutes, at what intervals and at night, and which product and scent pages you have seen; in addition the hashes of the IP addresses your account uses (never the address itself). This tells us whether an account is reading the catalogue automatically. Above a limit of detail pages per day we pause the account's access until the next day; the pages also contain an invisible link that only programs follow. We delete these counts after 90 days (Art. 6(1)(f) GDPR; our legitimate interest is protecting our database).

Language of the start page: When you open shaveindex.com without a language in the address and are not signed in, our server compares your IP address with a list of the address ranges of Austria and Germany stored on our server and sends you to the German or the English version. The address is neither stored for this nor passed on to anyone (Art. 6(1)(f) GDPR; our legitimate interest is showing you the right language). The country list is provided by DB-IP: IP Geolocation by DB-IP, licensed under CC BY 4.0.

Protection against bots in forms: The contact form and the sign-in contain an invisible field and a time stamp. If a program fills in the field or submits the form faster than a person can type, we do not accept it. We store nothing for this and set no cookie.

Our own usage statistics

To understand what is searched for and not found, we count ourselves – without cookies, without third-party services and without a profile of you (Art. 6(1)(f) GDPR):

• Searches and filters: search text, chosen filters and whether there were results. So that typing and ticking count as one search, we keep the ongoing search together with the hash of your IP address for a few minutes at most; afterwards only a daily count per search text and filter remains, with no link to you. We do not store search texts that look like an email address or phone number.
• Page views of products, scents, brands, bases and scent notes as a daily count per page.
• Clicks to makers: When you click a link to a maker, your browser reports only the target from our catalogue so that we can count clicks per product; the link itself goes straight to the maker.

Visits by administrators and recognisable bots are not counted. The daily counts contain no personal data and are not linked to your account.

Cookies

We only set cookies that are necessary to provide functions you expressly request or to handle sign-in and security (§ 165(3) Austrian Telecommunications Act 2021); no consent is required for them:

• si_theme – remembers whether you chose the light or dark theme (1 year).
• si_ansicht – remembers whether you want to see results as a gallery or a list (1 year).
• si_m – keeps you signed in until you sign out; with "stay signed in" at most 30 days after your last visit and at most 90 days in total, otherwise 12 hours.
• si_f – links the steps of a sign-in (30 minutes).
• si_c – protects forms against misuse by other websites (until you close the browser).

Should we ever use services that need cookies or similar techniques for advertising or statistics, we will ask for your explicit consent first; without it they are not loaded.

Contact form and emails to us

If you write to us via the contact form, we process the subject you chose, your name, your email address, your message, the language of the page and the time – only to answer your enquiry (Art. 6(1)(f) GDPR; where it concerns a contract, Art. 6(1)(b) GDPR). We store your name, email address and message encrypted (XChaCha20-Poly1305); only authorised administrators can read them. We reply by email. To stop anyone from using the form en masse, we count messages per IP address, only as a cryptographic hash, and delete the count after two days at the latest. If you email us directly, the same applies to your message and your address.

Member account

For an account we process your email address, your username, your member number, your language, your avatar (a pixel figure you design yourself; you start with a random one), your display preferences (light or dark theme, gallery or list, search suggestions and icons on or off), the time of registration and of your last sign-in, the version of the Terms of Use you agreed to and the version of this Privacy Policy shown to you at the time (the Privacy Policy informs you; it does not require consent), and during the closed beta your beta access. The legal basis is the performance of the user agreement (Art. 6(1)(b) GDPR). Your username is only publicly visible in the cases expressly described in this Privacy Policy, such as accepted corrections shown in a product's change log. We never show your email address.

Sign-in with a code: We send you a six-digit code by email. It is valid for 10 minutes and only once. We store it – and the address it was sent to – not in plain text but only as a cryptographic hash, and delete it as soon as it has been used or has expired, after one day at the latest.

Password (optional): If you set a password in your account settings, we store it only as an irreversible hash (Argon2id), never in plain text. We email you whenever it changes. You can remove it at any time; you can always sign in with a code as well.

Signed-in devices: For each sign-in we store a rough device description (such as "Firefox · Windows"), times and expiry – so that you can see your devices and sign them out. We do not store an IP address for this.

Protection against abuse: To stop anyone from requesting codes en masse or trying sign-ins, we count attempts per email address, per account and per IP address. We store them only as a cryptographic hash, never in plain text, and delete the counts after two days at the latest (Art. 6(1)(f) GDPR).

Collection, saved items and notes

What you add to your collection (own it, wishlist, favourite, saved for later, archive) and your private notes are visible only to you. We do not publish them and do not use them for advertising.

SOTD (shave of the day)

Your SOTD entries – date, title, products, private labels, blade usage and note – are private; only you see them, and there are no public SOTD pages. The image for sharing is created in your browser. A photo you choose for it never leaves your device: it is neither uploaded nor analysed nor stored.

Ratings, corrections and submissions

When you rate a product or scent, suggest corrections or submit a missing product or maker, we store your contribution with the time and your account (Art. 6(1)(b) GDPR). Every contribution is reviewed before it appears. A rating is only ever shown as part of an average; for accepted corrections the product's change log names your username, the field and the new value. Reasons, source links, the details of a submission and follow-up questions on a contribution are not public. We remove tracking additions such as "utm_…" from a source link.

Points, levels and badges

For using ShaveIndex – your daily visit while signed in, approved ratings, your own SOTD entries and a confirmed newsletter subscription – we keep a points balance with entries (occasion, points, time) and use it to unlock levels, badges and avatar figures. For the daily visit we only remember the day of your last visit. For accepted corrections and submissions we calculate contributor points from your contributions; they are not stored separately. You see points, levels and badges in your account; they do not affect how much a rating counts.

Messages

Messages between you and the ShaveIndex team – including questions about your contributions and announcements from the team – are stored encrypted (XChaCha20-Poly1305); the key is not kept in the database. This is not end-to-end encryption: authorised administrators can read messages in order to answer them. Who wrote when and the processing status are stored unencrypted because operations need them. Messages are never analysed by artificial intelligence.

Emails from us

We send sign-in codes, notices about your account and the confirmation email for the newsletter through our host's mail server from contact@shaveindex.com, as plain text and HTML. They contain no images from third-party servers, no tracking pixels and no tracking links. We use Brevo for sending and technically managing the newsletter (see below).

Newsletter

The ShaveIndex newsletter is an optional additional feature for members with a ShaveIndex account. You can create and use a ShaveIndex account without subscribing to the newsletter. A newsletter subscription is not a requirement for registering or using ShaveIndex.

You only receive the newsletter if you request it yourself through your account and confirm the subscription through the link in our confirmation email (double opt-in, Art. 6(1)(a) GDPR). It reports news from wet shaving and from ShaveIndex and may contain paid advertising, sponsored content and partner links; these are labelled.

Sending and management via Brevo: We use the Brevo service to send and technically manage the newsletter. Brevo processes the data required for this on our behalf (Art. 28 GDPR) under a data processing agreement. We transmit in particular your email address, your language, your member number, the status of your newsletter subscription and the information required for subscription, confirmation and unsubscription. Brevo also processes technical sending events, for example whether a message was sent, delivered, rejected or unsubscribed from. We need this information to provide reliable delivery and, in particular, to ensure that an unsubscription continues to be respected.

Newsletter statistics and tracking: Brevo can additionally record whether a newsletter email is opened and which links contained in it are clicked. Tracking pixels and individually assigned links may be used for this purpose. This can allow Brevo to associate an opening or click event with your newsletter contact. We use this information solely to understand which newsletter content is of interest to our readers and to improve our newsletters; we do not use it for third-party advertising or to create a general profile of you.

Recipient-specific measurement of opens and clicks only takes place if you have separately consented to it (Art. 6(1)(a) GDPR and, where applicable, § 165(3) Austrian Telecommunications Act 2021). This consent is voluntary and is not required in order to receive the newsletter. You receive the same newsletter without giving tracking consent. You can withdraw your tracking consent at any time with effect for the future through the option provided in the newsletter to change your tracking preferences, without having to unsubscribe from the newsletter itself. If you unsubscribe from the newsletter, all further newsletter tracking of you also ends.

Proof of consent: We store the times of the newsletter request, double opt-in confirmation and unsubscription, where they came from (your account or a link in the email) and the version of this Privacy Policy valid at the time. Where you have additionally consented to newsletter statistics, we also store the status, time and source of this consent and any subsequent withdrawal. This allows us to demonstrate your consents and serves our legitimate interest in documenting the lawfulness of the newsletter and the related processing (Art. 6(1)(f) GDPR). After you delete your account, your email address is retained for the required proof only as a cryptographic hash.

You can unsubscribe from the newsletter at any time and free of charge – via the unsubscribe link in every newsletter issue or in the signed-in area under "My account". You do not need to sign in to ShaveIndex to use the unsubscribe link in the newsletter. Unsubscribing only from the newsletter does not affect your member account.

If you delete your ShaveIndex account, any existing newsletter subscription is cancelled at the same time and with immediate effect.

Withdrawal does not affect the lawfulness of newsletters sent or processing carried out on the basis of your consent before withdrawal. We never pass your email address or newsletter interaction data to advertising partners.

Advertising, sponsored listings and partner links

ShaveIndex may be financed through advertising:

• Partner links (affiliate links): Links to makers or retailers may carry a partner identifier. If you buy something there after clicking, we may receive a commission; your price does not change. We do not transmit any data about you. What the retailer or its partner network records on its own website (such as a cookie that attributes the purchase to the link) is governed by its privacy policy.
• Sponsored listings, sponsored links and ads on the website and in the newsletter are labelled and chosen by the content of the page or the issue, not by a profile of you. We do not pass any personal data to advertising partners for this, and we do not load ads from third-party servers.
• We never use your collection, notes, SOTD, messages or ratings for advertising.

Should we ever use a service for advertising that sets cookies or builds a profile, we will ask for your explicit consent first (section "Cookies").

Artificial intelligence

To maintain the product catalogue we analyse publicly available texts by makers with an AI service (Anthropic, PBC, USA). If you submit a correction for a product, an administrator may pass the part of its text relevant to the product – without your name, email address or other account data – to the same service so that it can be matched to the product's specifications; only what the administrator has checked is written (Art. 6(1)(f) GDPR). Where this involves the transfer of personal data to the United States or another third country, we rely on the safeguards provided for under Chapter V GDPR, in particular the European Commission's Standard Contractual Clauses where required. We never pass your email address, account, collection, notes, messages, contact enquiries, SOTD or ratings to an AI service.

Hosting and recipients

The website is hosted by ALL-INKL.COM – Neue Medien Münnich, Hauptstraße 68, 02742 Friedersdorf, Germany. The host processes data on our behalf (Art. 28 GDPR) in data centres in Germany under a data processing agreement.

We use Brevo as a processor for the newsletter. According to Brevo, the hosting servers on which its databases are processed and stored are located within the European Union. Brevo may use subprocessors as part of providing its services.

Anthropic may be used for maintaining the product catalogue as described above. Where one of these service providers processes personal data outside the European Economic Area, this is based on the safeguards required under Chapter V GDPR, in particular an adequacy decision or Standard Contractual Clauses where required.

Retention

• Account: until you delete it. On deletion we immediately remove your collection, notes, messages, SOTD, ratings, points and signed-in devices and overwrite your email address and username. Any existing newsletter subscription is cancelled immediately at the same time. Only your member number remains as an empty entry so that it is not reassigned. Accepted corrections and submissions remain part of the catalogue and its change log – it then shows "deleted account" instead of your name.
• Newsletter: until you unsubscribe or delete your ShaveIndex account. A confirmation link is valid for seven days; we delete unconfirmed confirmation links 30 days after they expire. We keep proof of your newsletter consent and, where applicable, your tracking consent, including any respective withdrawals, for three years after they end so that we can demonstrate the lawfulness of the processing. Wherever possible, the email address is retained for this purpose only as a cryptographic hash.
• Newsletter sending and interaction data: Technical sending events and – where tracking consent has been given – opening and click events are processed by Brevo for the technical delivery and evaluation of the newsletter. After an unsubscription or withdrawal of tracking consent, no new recipient-specific interaction data are collected for this purpose. Personal newsletter data that are no longer required are deleted or anonymised as part of our deletion and synchronisation processes; technical event data may additionally be subject to Brevo's applicable platform retention rules.
• Contact enquiries: settled ones one year after they were settled, unprocessed ones two years after receipt at the latest.
• Sign-in codes: until used or expired, one day at most. Sign-in processes: 30 minutes. Abuse counters: two days at most. Expired or signed-out devices: one week afterwards.
• Conversations with the team: closed conversations one year after the last message; open ones remain until they are closed.
• Corrections and submissions: rejected ones with reasons, source link and follow-up questions six months after the decision. For accepted ones we delete the reasons, source link and notes after one year; the field and new value remain in the change log.
• Ratings: superseded, rejected and withdrawn versions six months; the current one until you delete it or your account.
• A daily deletion run on the server enforces these periods.
• Our host's backups are overwritten when their retention period ends; deleted data then disappears there as well.

Your rights

Subject to the applicable legal requirements, you have the right of access, rectification, erasure, restriction of processing, data portability and objection (Art. 15 to 21 GDPR), and the right to withdraw consent at any time with effect for the future. You can obtain access and portability yourself in your account settings with "Download my data", and delete your account there as well. For anything else, write to contact@shaveindex.com or use the contact form with the subject "Privacy".

If you believe that we process your data unlawfully, you can lodge a complaint with the Austrian Data Protection Authority: Barichgasse 40–42, 1030 Vienna, www.dsb.gv.at.

Changes

If our processing changes, we update this policy. Every version carries a number and a date.