Privacy Statement

Effective: June 07, 2021

This Privacy statement describes how My Posh Way, Inc. and its Affiliates (as applicable, "My Posh Way") collects and manages your personal information (i.e. any information that relates to an identified or identifiable individual) as part of providing our Services (defined below). By using the My Posh Way website, you consent to the data practices described in this statement.

By using the Services and/or providing us with your personal information, you acknowledge that your personal information will be processed and used in the manner set out in this Privacy Statement. We may amend this Statement from time to time in line with the “Updates to this Privacy Statement” section below. To the extent permitted by law, your continued use of the Services and Websites constitutes your acceptance to those amendments and the updated Statement.

  1. Definitions
    For purposes of this statement, the terms below shall have the meanings set forth below.
    1. Affiliate” means any entity that directly or indirectly controls, is controlled by, or is under common control with the subject entity, where “control” refers to the power to direct or cause the direction of the subject entity, whether through ownership of voting securities, by contract or otherwise.
    2. Customer Personal Data” means any personal data contained within the data provided to or accessed by My Posh Way by or on behalf of Customer or Customer end users in connection with the Services.
    3. EEA” means the European Economic Area.
    4. EU” means the European Union.
    5. European Data Protection Legislation” means the GDPR and other data protection laws of the EU, its Member States, Switzerland, Iceland, Liechtenstein and Norway and the United Kingdom, applicable to the processing of Customer Personal Data under the Agreement.
    6. GDPR” means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.
    7. Services” means the services and/or products to be provided by My Posh Way to Customer under the Agreement.
    8. Term” means the period from the statement Effective Date until the end of My Posh Way's provision of the Services.

  2. Personal information we collect
    What personal information we collect will depend on the nature of your interaction with the Services and our Websites. While some information is collected automatically or through sources outside of My Posh Way, most is collected when you use our Services or our Websites. A breakdown of the collection has been provided in the sections below.
    1. Name
    2. Address
    3. Email
    4. Phone Number

  3. Information collected automatically
    We collect information automatically when you visit our Websites and use our services. Information collected automatically by cookies, web beacons or other similar technologies (described in the “Cookies and other tracking technologies” section of this Statement) may include:
    1. information about your device, such as your device type/model, number and device ID (e.g. MAC address);
    2. information about your browser, settings (e.g. language) and operating system;
    3. your internet protocol (IP) address (including in some instances, your perceived location);
    4. unique advertising identifiers;
    5. transactional and purchase information; and
    6. browsing and usage activity, such as the referring domain, what websites/content you have viewed or actions you have taken on a particular website.

    Depending on the Services being used or the websites you access, we may also collect geolocation information through your devices. This information may be collected via GPS, Bluetooth, cellular or WiFi technologies. You can adjust your settings at the device or browser level to disable the use of these technologies.

  4. How we use personal information
    We use personal information to:
    1. provide updates, support and training related to the Services;
    2. to determine the suitability of individuals in relation to their use of certain Services;
    3. for contracting and agreement purposes;
    4. to process transactions and payments through the Services;
    5. to provide online services, including verifying your identity, as well as diagnosing technical and service issues.
    6. analyzing the performance of our Services;
    7. research purposes, including the development of new products;
    8. assessing the effectiveness of Services;
    9. improving our Services and Websites.
    10. using analytics and profiling technology to personalize your online experience on our Websites.
    11. sending you marketing communications, either directly or through a third party, in relation to our existing or new Services that we think might interest you; and

    Any communications sent to you pursuant to this section shall either be permitted under the applicable law or with your consent. Please see the “Your rights and choices” section of this Statement for more details on opting out of these communications and updating your preferences.

  5. How we share information
    With third parties to provide, maintain, and improve our Services, including service providers who access information about you to perform services on our behalf, such as hosting and information technology services, payment services, identity verification and fraud prevention services, marketing and advertising services, data analytics and personalization services and customer support services. Also, if we believe it is necessary to:
    1. protect our rights or property, or the security or integrity of our Services or our Websites;
    2. enforce the terms of our terms of service or other applicable agreements or policies;
    3. protect us, users of our Services, or the public from harm or potentially prohibited or illegal activities;
    4. investigate, detect, and prevent fraud, security breaches; or
    5. comply with any applicable law, regulation, legal process, or governmental request.

    We may also share aggregated and/or anonymized information derived from the Services that does not directly identify you, including device information and information derived from cookies and log files with third parties for the purposes described in this Statement.

  6. Retention of personal information
    We retain personal information as long as reasonably necessary to provide the Services, carry out the purposes described in this Statement or as otherwise required in order to comply with our records retention periods (which reflect the applicable law). For example, we may retain information about users of our Services in order to comply with our legal and regulatory obligations or to protect our interests as part of providing the Services.

  7. Cookies and other tracking technologies My Posh Way, as well as third parties described in this Statement may use cookies, web beacons and other tracking technologies as part of providing the Services and for the purposes described in this Statement. This includes:
    1. Cookies: A small text file placed and saved in your browser when you access our Websites and potentially the websites of our Merchants, business partners and other third parties. We use both session cookies (i.e. cookies that are stored only for a specific website visit) and persistent cookies (i.e. cookies that are stored beyond a specific website visit) to provide the Services and for the purposes described in this Statement. These cookies may be set by us (first party cookies) or set by third parties that collect information on our behalf (third party cookies), such as Google Analytics.
    2. Web beacons: A small graphic file placed on a website (or websites) or email that tracks your activity and monitors your behavior. We use web beacons within our Services to collect usage and performance data.

    As part of using the Services, we use these technologies as well as similar technologies within our Services and across our Websites. Examples include:
    1. to uniquely identify you and/or your device;
    2. to store your preferences as part of providing the Services;
    3. for personalization and targeted advertising purposes (including across your devices and applications);
    4. for security and fraud-prevention purposes;
    5. to analyze and monitor the performance of our Services;
    6. to improve and develop new Services; and
    7. to understand your use of the Services over time.

    There are ways to control and/or reject the setting of cookies and similar technologies within your browser settings. As each browser is different, please consult the “help” menu within your browser. For additional information about cookies and how to control their use on various browsers and devices, you can visit http://www.allaboutcookies.org. Please be aware that depending on the Services being used, restricting cookies may prevent you from accessing and using all or part of the Services.

  8. Your rights and choices
    Depending on the Services you use, you may be able to access, change and update your information through an account created as part of the Services. If you would like to have your account deleted or have other questions, please contact hello@myposhway.com.

  9. Managing communications
    As part of providing the Services, My Posh Way (whether directly or through a third party), may send you:
    1. Marketing communications: Depending on the nature of our relationship and the Services being used, we may send you marketing and other promotional communications. You can opt out of or unsubscribe from any marketing communications by following the instructions in those messages, by changing your communications preferences within your account or through your device. You can also opt out by contacting us at hello@myposhway.com. Opting out of one communication will not necessarily opt you out of all marketing communications. Please note that you may still receive account-specific communications.

  10. Security
    We implement appropriate administrative, technical, and organizational security measures to protect your personal information against unauthorized access, disclosure, damage or loss. However, even though we have taken measures to protect your personal information, we cannot guarantee that the collection, transmission and storage of personal information will always be completely secure.

  11. Links to other websites
    This Privacy Statement only applies to information collected when visiting our Websites or otherwise using our Services. While visiting our Websites or using the Services, you may be directed through links to third-party websites or services that are not operated or controlled by us. We are not responsible for the privacy practices and policies of these third parties. As a result, we encourage you to review the privacy policies of these third-party websites as their practices may differ from ours.

  12. Children
    Our Services are not targeted or directed at children under the age of 13, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided personal information to us, we encourage the child’s parent or guardian to contact us as described in the “How to Contact Us” section of this Statement to request that we remove the information from our systems. If we learn that any personal information we collected has been provided by a child under the age of 13, we will promptly delete that personal information.

  13. How to contact us
    If you have questions or concerns about our Privacy Statement or our practices, you can reach us at:
    1. By email: hello@myposhway.com

  14. Changes to this Privacy Statement
    From time to time, we may revise this Privacy Statement in order to comply with the applicable law or our changing business practices. Unless we are required by the applicable law to provide a prescribed form of notice and/or obtain consent, updated versions of this Statement will be posted on this website

Addendum A – United States (California)

Last updated: June 07, 2021

  1. Privacy Statement for California Residents as required by the California Consumer Privacy Act of 2018 (“CCPA”)
    The provisions below supplement the information provided in the generally applicable portion of our Privacy Statement and apply solely to individuals that are residents of California and qualify as a “Consumer” under the CCPA. This California-specific Statement provides additional information about how we collect, use, disclose and otherwise process the personal information of these individuals, either online or offline, within the scope of the CCPA. Any terms defined in the CCPA or as otherwise defined in our Privacy Statement have the same meaning as used in this addendum.

    When we use the term “personal information” in this Statement, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
    The below table summarizes:
    1. The categories of personal information collected by My Posh Way in the past 12 months;
    2. The sources of collection of the personal information;
    3. How we use your personal information; and
    4. The categories of personal information disclosed for a business purposes by My Posh Way in the past 12 months.


  2. Entity Name Google Analytics (Google, LLC)
    Nature and Purpose Google Analytics is an analytics provider that My Posh Way uses to capture how users interact with the My Posh Way website. Google Analytics has access to Customer Personal Data for Customers that visit the My Posh Way Website.
    Entity Country United States

    Entity Name Stripe, Inc
    Nature and Purpose Stripe is an online payment processor that allows My Posh Way to charge Customer invoices by credit/debit card. Stripe has access to Customer billing information for the sole purpose of billing Customer.
    Entity Country United States


  3. Description of rights available to Consumers
    A number of individual rights are available to individuals under the CCPA relating to personal information that we have collected (subject to certain limitations at law), including:
    1. The right of access: you have the right to request that an in-scope business that collects personal information from you, disclose the following in relation to the preceding 12 month period, upon verification of your identity: (i) the categories of personal information collected about you, (ii) the categories of sources where the personal information was collected, (iii) the business or commercial purposes for collecting (or where applicable, selling) the personal information, (iv) the categories of personal information that we have disclosed to third parties for a business purpose along with the corresponding recipients, (v) the categories of personal information we have sold along with the corresponding recipients, and (vi) the specific pieces of personal information collected about you.
    2. The right of deletion: you have the right to request that an in-scope business delete personal information that it has collected from you, subject to certain exceptions.
    3. The right to opt out of personal information sales: you have the right to request that an in-scope business refrain from selling personal information it has collected about you to third parties now or in the future. If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales.
    4. The right against discrimination: you have the right to not be discriminated against as a result of exercising any of the above rights. However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you with our Services or engage with you in the same manner.

    5. Please note that your ability to invoke the rights above are limited pursuant to the scope and limitations of the CCPA, including any available exceptions. For example, an access request can only be made twice by a Consumer within a 12 month period.

  4. How to invoke your rights
    Individual rights requests can also be submitted to My Posh Way through the below channels:
    1. By email: hello@myposhway.com

    Once an individual rights request has been submitted, My Posh Way may ask you for additional information in order to verify your identity or to provide additional details to help us respond to your request. This may include your name, email address, phone number or other details related to your use of My Posh Way’s Services. Where applicable, these requests can be submitted by an authorized agent through the channels described above in accordance with the applicable law. Please note that in certain circumstances, we may refuse to act or impose limitations on your rights, as permitted by the applicable law.

  5. Updates to this statement
    We will update this Statement from time to time. When we make changes to this Statement, we will change the "Last updated" date at the beginning of this Statement. All changes shall be effective from the date of publication unless otherwise provided in the notification.

  6. California “Shine the Light” disclosure
    California residents that have an established business relationship with us have a right to know how their information is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law (Civ. Code § 1798.83). Please contact us through any of the communication channels within the “How to contact us” section in the main body of this Statement to invoke these rights.