Privacy Policy

Updated: July 1, 2024

This Privacy Notice describes the information we collect about you when you interact with us through this website, in our stores, at our events (such as pop-ups), and through customer service (collectively our “Platforms”).

By submitting information through, or otherwise using, our Platforms, you acknowledge that we may collect, use and disclose information in accordance with this Privacy Notice, the privacy preferences you have made known to us, and as permitted or required by law. As used in this Privacy Notice, “Poshura”, “our”, “us”, and “we” means LINKERS CAPITAL, LLC, a corporation headquartered in the United States of America.

We reserve the right to modify this Privacy Notice at any time to keep it up to date with legal and regulatory requirements and the way in which we operate our business. We will place any updates on our website. Where permitted by law, your continued access to and/or use of our Platforms after any such changes constitutes your acceptance of, and agreement to our practices. Please periodically review this Privacy Notice so that you know what personal information we collect, how we use it, and with whom we may share it.

We are deeply committed to the relationship and trust we have with you, and we take our data protection responsibilities seriously.

YOUR PERSONAL INFORMATION

How We Collect, Use, and Share Your Personal Information

We collect data when you interact with us at different touchpoints, including information that can directly or indirectly identify you (your “Personal Information”). As a consumer goods company, we use Personal Information for a variety of business purposes including sharing it and combining it with other information we might receive from our partners, through technologies, and from other third parties. This section details the kinds of Personal Information we collect, how we use it, and describes the third parties with whom we share Personal Information.

Our website is hosted by Shopify, Inc. Shopify provides us with the online e-commerce platform that allows us to provide services to you, including purchase of our Products. Your Personal Information is stored through Shopify’s data store, databases and applications and when you shop with us online, Shopify’s Privacy Policy also applies to that activity. We encourage you to review Shopify’s Privacy Policy which is available here: https://www.shopify.com/legal/privacy.

CONTACT INFORMATION:

This includes identifying information like names, email addresses, phone numbers, shipping/billing/physical addresses, online identifiers you share in a public forum (like your social media handles), or nicknames.

How we collect this information:

Directly from you when you register on our website, sign up for our emails, order products from us online, purchase products in-store or otherwise provide us with your contact information

From third parties including product fulfillment or marketing list providers (where permitted under applicable laws)

Why we collect it:

To contact you, for example to send you relationship, transactional and commercial communications and other marketing and advertising (subject to choices you may make to opt in or opt out)

See "BUSINESS PURPOSE AND SHARING FOR ALL DATA TYPES" below

We share it with:

Third party social media platforms (including for advertising through platforms such as Meta or Amazon using pixels or custom audiences) (subject to choices you may make to opt in or opt out)

Business partners subject to your opt-in consent, such as through a cross-promotion activity

See "BUSINESS PURPOSE AND SHARING FOR ALL DATA TYPES" below

FINANCIAL INFORMATION:

This includes information such as the last four digits of your credit/debit card number, data used to authenticate your transactions, and information relating to the use of alternative payment methods or third party checkout platforms to complete your transaction. If you choose a direct payment gateway to complete your purchase, then Shopify stores your credit card data. It is encrypted according to the requirements of the Payment Card Industry Data Security Standard (PCI-DSS). Evidence of Shopify’s PCI-DSS compliance is available through their w3ebsite or by request at: https://help.shopify.com/en/questions/compliance#/reports.

How we collect this information:

Directly from you when you make a purchase

From third parties as needed to help securely process your requested transaction

Why we collect it:

To complete a transaction that you request

To maintain the safety, security, functionality, and integrity of our Platforms, your account and other assets or business

Prevent investigate, or take action regarding unlawful activity including but not limited to engaging third parties to screen transactions for suspected fraud or identity theft

Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred

Comply with law or a legally binding process, such as pursuant to subpoenas, court orders, to enforce our legal rights, or to protect you, us, or others against injury or harm including for security and loss prevention

We share it with:

Payment processors

See "BUSINESS PURPOSE AND SHARING FOR ALL DATA TYPES" below

OTHER IDENTIFYING INFORMATION:

This includes information that might reasonably be used to identify you, either by itself or when combined with other data such as general or specific demographic data, physical description such as your preferred clothing sizes, your age, gender, certain employment information (such as military or medical profession status), information you share in a public open forum including social media, or other information we collect from you after obtaining your prior consent.

How we collect this information:

Directly from you when you make a purchase from us or through other experiences

As described in a separate notice or consent, such as sign-up terms for a special event

From third parties including social media platforms, business partners and advertising service providers

Why we collect it:

To offer and administer special offers, contests, surveys, and sweepstakes

To send you relationship, transactional and commercial communications and other marketing and advertising (subject to choices you may make to opt in or opt out)

See "BUSINESS PURPOSE AND SHARING FOR ALL DATA TYPES" below

We share it with:

Marketing and Advertising providers

Customer Service providers

See "BUSINESS PURPOSE AND SHARING FOR ALL DATA TYPES" below

INFORMATION FROM OUR BUSINESS RELATIONSHIP:

This includes information you share through interactions on our website, with staff such as Customer Service or in-store stylists, including purchase and return data, survey responses, feedback, communications or information you share in a public forum like social media, choices you make with respect to communications we send to you or how we use your data (e.g., to opt in or opt out), and associated inferred data such as buying trends and preferences.

How we collect this information:

Directly from you

From third parties including social media platforms, business partners and advertising service providers

From technologies (such as apps running on our Shopify platform)

Why we collect it:

To administer, support, and improve our online and in-store presence and experience

To help us understand your interests, personalize our interactions with you, and develop our business relationship

To offer and administer special offers, contests, surveys, and sweepstakes

To send you relationship, transactional, and commercial communications, and other marketing and advertising (subject to choices you may make to opt in or opt out)

See "BUSINESS PURPOSE AND SHARING FOR ALL DATA TYPES" below

We share it with:

Marketing and Advertising providers

See "BUSINESS PURPOSE AND SHARING FOR ALL DATA TYPES" below

AUDIO, VISUAL, SENSORY, AND BIOMETRIC INFORMATION:

This includes data such as audio recordings, visual film or still images,. In some locations, this information is considered sensitive Personal Information and subject to additional protection.

How we collect this information:

Directly from you if you make a telephone call to our customer service number that is recorded, if you publicly post images or audio/video where you post and tag us or our brands

By CCTV cameras in our locations

As described in a separate notice or consent, such sign-up terms for a special event

Why we collect it:

See "BUSINESS PURPOSE AND SHARING FOR ALL DATA TYPES" below

We share it with:

See "BUSINESS PURPOSE AND SHARING FOR ALL DATA TYPES" below

ONLINE AND TECHNICAL INFORMATION:

This includes browsing data, data about how you interact with our Platforms and tools (including online ads, text messages and emails) and similar network activity, your IP address, and device identifiers (for example, advertising ID’s, device model, operating system, device locale, mobile platform, session time, developer ID and the like), referring site data, session history, and reproductions and recordings of interactions with the website captured during browsing sessions.

How we collect this information:

From your computer or device when you interact with our Platforms, for example, when you visit a Poshura website your IP address and other information is collected along with information on how you navigate through our site

Through cookies, web beacons, pixels, clear gifs, and similar tracking technologies (where you have opted in, if required by applicable law, unless collection is via strictly necessary cookies)

From actions you take in response to emails, including whether you open an email, unsubscribe or purchase a product promoted in that email

Why we collect it:

To make your interaction with us more convenient, for example, recognizing you and your devices, or allowing us to hold your shopping cart selections when you navigate away and then return to the order page

To send you relationship, transactional and commercial communications and other marketing and advertising including through behavioral advertising and cross-device tracking. Cross-device tracking refers to when data is used to make the inference that a user of one device, such as a computer, is the same person using another device, such as a mobile phone. We may then serve advertising on the browsers of both devices. These uses are subject to choices you make to opt in or opt out.

See "BUSINESS PURPOSE AND SHARING FOR ALL DATA TYPES" below

We share it with:

Marketing and Advertising providers

See "BUSINESS PURPOSE AND SHARING FOR ALL DATA TYPES" below

LOCATION DATA:

This includes data such as your approximate location (such as your zip code/postal code or state/province/territory) and the locations of stores where you have made purchases or shared visit information.

How we collect this information:

Directly from you

Through technologies, such as an IP address

As described in a separate notice or consent, such as sign-up terms for a special event

Why we collect it:

To enable you to locate nearby stores or products

To send you relationship, transactional and commercial communications and other marketing and advertising (subject to choices you may make to opt in or opt out)

See "BUSINESS PURPOSE AND SHARING FOR ALL DATA TYPES" below

We share it with:

Marketing and Advertising providers

See "BUSINESS PURPOSE AND SHARING FOR ALL DATA TYPES" below

INFERRED AND DERIVED INFORMATION:

This includes profiles based on buying trends, transaction patterns and preferences, characteristics, predispositions, behavior or attitudes.

How we collect this information:

Directly from you

Through technologies, such as an IP address

Creating summaries, profiles and segments using information collected from a variety of sources that are described in this Privacy Policy

From third parties including business partners and advertising service providers

Why we collect it:

For special offers and other marketing and advertising (subject to choices you may make to opt in or opt out) including through interest-based advertising and using cross-device tracking

See "BUSINESS PURPOSE AND SHARING FOR ALL DATA TYPES" below

We share it with:

Marketing and Advertising providers

Social Media platforms

See "BUSINESS PURPOSE AND SHARING FOR ALL DATA TYPES" below

CHILDREN AND MINORS’ INFORMATION:

We do not knowingly collect Personal Information of any user under 13 years of age on our Platforms. These offerings are intended for users who are 13 years old or older. If a user or their parent or legal guardian believes we have collected any Personal Information of a minor (under the age of 18), please contact us at contact@poshura.com for removal of that data.

BUSINESS PURPOSE AND SHARING FOR ALL DATA TYPES

In addition to the above, we may use any or all of the Personal Information described in this Privacy Notice for the following business purposes. Additionally, our business operations require that we share Personal Information with certain categories of third parties as are identified below.

We may use or share the Personal Information that we collect to:

Maintain the safety, security, functionality, and integrity of our Platforms, your account and other assets or business

Prevent investigate, or take action regarding unlawful activity including but not limited to engaging third parties to screen transactions for suspected fraud or identity theft

Perform testing, research, analytics, and product development

Administer, support, and improve our online presence, whether on our website or mobile app, including troubleshooting technical problems when they arise

Understand, improve, and provide customized and streamlined experiences with our Platforms, including by offering personalized recommendations, fit suggestions, and the like

Provide services in-store or on the website, including processing requested purchases, returns and exchanges, payments, orders, shipping products, and providing Customer Service

Conduct other business initiatives as described to you when collecting your Personal Information, with your consent or as otherwise permitted by law

To administer surveys and questionnaires, such as for consumer satisfaction purposes

We share your Personal Information with:

Service Providers, including operations outsourcing, such as for unique services or points of presence in a country, cloud service and technology providers, credit card processing, marketing and advertising, shipping and logistics, dispute resolution, fraud detection and prevention providers, data management, analytics providers and other third parties with whom we have contractual relationships,

With businesses controlling, controlled by, or under common control of our parent company, Linkers Capital LLC. (our “Affiliates”),

Auditors, consultants, lawyers, and other entities who use the data to provide us with professional services,

Government agencies, law enforcement, regulators, and courts where we are required to comply with applicable laws, regulations or rules, requests of law enforcement, regulators and other government agencies or a legally binding process, such as pursuant to subpoenas, court orders, to enforce our legal rights, or to protect you, us, or others against injury or harm

Business Transfers, if (i) we or our Affiliates are or may be acquired by, merged with, or invested in by another company, or (ii) if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may disclose or transfer Personal Information to a potential or actual third party purchaser or other relevant third party.

We may also anonymize, aggregate or otherwise strip any Personal Information we collect of all personally identifying characteristics and may use or share that aggregated, anonymized data with third parties for any purpose we deem appropriate.

YOUR CHOICES

We believe in giving you choices about how your Personal Information is used. Below are some ways that you may exercise these choices, including how to change or correct your Personal Information and how to unsubscribe from marketing.

We encourage you to review this entire Privacy Notice to fully understand the choices you may have, such as allowing or blocking cookies, online behavioral tracking and advertising, asking for your Personal Information to be deleted, or asking what Personal Information we have collected from you.

When you set up an account, sign in or log in on one of our Platforms, you can access, correct, or update your choices and settings. If you receive email marketing communications from us and want to opt out of receiving such communications in the future, you can opt out by clicking the “Unsubscribe” link at the bottom of the promotional email. Similarly, if you receive direct mail from us and wish to unsubscribe, you can opt out by e-mailing us at contact@poshura.com. Please be sure to include your full name, mailing address and e-mail address along with the types of information you do not want to receive. It may take up to 8 weeks to process an opt-out from direct mail.

Unless otherwise explained to you in advance, you are not obligated to provide your Personal Information to us. If you decide not to provide your Personal Information, we might, in some instances, not be able to provide you with a product or service. Additionally, if you have opted out of certain services, such as marketing communications, you may still hear from us for other purposes such as needed to fulfill your orders or responding to customer service inquiries.

SECURITY

Safeguarding Your Personal Information

We care about protecting your Personal Information, so we employ reasonable physical, technical, and administrative safeguards designed to help keep it safe, including encryption and in some cases techniques to reduce the ability to identify an individual. Personal Information may be accessed by persons within our organization, our third party service providers, or the other persons described in this Privacy Notice who require such access to carry out the purposes described in this Privacy Notice or that are otherwise permitted or required by applicable law. Unless otherwise noted in this Notice, Personal information we collect is managed from our headquarters in Culver City, California.

No data collection, storage, or transmission, including over the Internet or other network can be guaranteed to be 100% secure, so despite our efforts we cannot and do not guarantee the security of any data you transmit to us, including on, or through, our Platforms. When you communicate with customer service via email or chat, we ask that you not share sensitive Personal Information via these communication channels. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

When you register on one of our Platforms, you will need to set up a password to access your information on our site. If you want to cancel your password or change it, click on “Log In” from any page on the website, and you can access, correct, or update your choices and settings from within your account. Note that we don’t ask customers to confirm account or credit card details by email – if you receive an email claiming to be from us and asking for this information, don’t respond.

We store your Personal Information on the basis of applicable law and as required to satisfy the purpose for which the data is processed, unless a longer period is required for purposes such as complying with retention obligations, record keeping or other commercial requirements.

COOKIES, TRACKING AND ADVERTISING

Cookies, Tracking Technologies and Interest-Based Advertising

ABOUT COOKIES:

We may place, or allow to be placed, cookies, web beacons and similar technologies on our Platforms to give you the best experience, perform analytics, analyze traffic, personalize content, offer a range of features and functionality and offer ads that match your interest (as discussed above). These technologies include Google Analytics and similar providers. You can learn more about how Google uses the information collected through this service at: www.google.com/policies/privacy/partners/.

Cookies and web beacons are the technologies generally driving collection of browsing information. A "cookie" is a computer file that acts as an identification card for your computer. When you visit a site, unique cookies are placed on your browser. The purpose of the cookie is to distinguish your browser, and associated activities, from all other browsers. “Web beacons” interact with cookies to “read” the information contained on them. When you visit a site, web beacons recognize specific cookies that have been placed on your browser. By recognizing your browser, the site owner can serve you better. While we may recognize your browser through cookies we place, that does not mean that we can identify you by reference to your name, email or other specifically identifiable Personal Information.

We and our partners use cookies, web beacons, device identifiers and other technologies to collect information when you use our websites and mobile app such as your IP address, web browser, mobile network information, browsing and conversion information help to create an improved shopping experience – for example, allowing us to hold your shopping cart selections when you navigate away and then return to the order page, or save an item for later when you’re not quite ready to buy. Cookies also allow us to recognize you as an account holder when you return to our sites. We consider these types of cookies to be necessary for the successful operation of our business. Our use of cookies changes regularly depending on our business needs and operations.

Most browsers accept cookies automatically, but you can block or delete cookies at any time to prevent the collection of your browsing information for purposes of delivering interest-based ads and tracking visitor behavior. Please be aware that blocking or deleting cookies may also disable or interfere with shopping features on our sites and other sites that you may visit.

BEHAVIORAL OR INTEREST BASED ADVERTISING:

We permit our trusted business partners and third party advertising companies (including ad servers, ad agencies, technology vendors, or providers of sponsored content) to collect your browsing information and numerical identifiers associated with your browser or device in order to provide ads on our behalf that are tailored to your interests. These ads may appear on our website, and on other third party websites. Using tracking technologies, advertising technology companies collect data from a particular browser or device about a user’s web viewing behaviors over time, across unrelated websites, and in some cases combine such data with data collected from other browsers or devices associated with the same user or household, and use such data to predict user preferences and to deliver advertisements to that user which are calculated to target that user’s predicted preferences across devices. If you take steps to block advertising cookies or opt out of interest-based advertising, note that this does not mean that you will no longer receive ads from LS&Co., as these ads are only one form of digital advertising.

DO NOT TRACK:

Our systems do not recognize browser “Do Not Track” signals, but several of the third party advertising companies that utilize cookies on our websites to provide interest-based advertising enable you to opt out of those practices.

OPTING IN/OPTING OUT/BLOCKING COOKIES:

You can block or opt out of cookies or collection of data for interest-based advertising by adjusting settings within your browser. For instructions, check your browser’s technical information. If you are using a mobile device, your device may also include a feature (“Limit Ad Tracking” on iOS or “Opt Out of Ads Personalization” on Android) that allows you to opt out of having certain information collected through mobile apps used for behavioral advertising purposes. If you block cookies at a browser level or use a different computer or browser to access our platforms, you should review your cookie settings again.

The placement of cookies, pixels, gifs or web beacons may be subject to additional requirements by law depending on where you are located. These may include requiring us to share specific technical information, requiring you to opt in to their use, or supporting specific mechanisms for you to opt out.

THIRD PARTY LINKS & FEATURES

Social Media and Third Party Links

Social media provides tools that many of our consumers use and enjoy, and we include links to various social media platforms as part of our digital offerings. For your convenience and information, we may provide links to other sites, or add on features powered by third parties to our website or app, which may have privacy policies that differ from our own. We identify features and links that are provided by third parties, but are not responsible for the content or practices of any linked site. We recommend that you review the privacy policy of any site or feature that you access through our platforms before sharing your Personal Information and understand your privacy settings which will determine the degree to which your Personal Information is used, shared, or made public.

INTERNATIONAL PROCESSING

Transfers and Processing

Please be aware that your Personal Information may be transferred to and maintained on servers or databases located outside your state, province/territory, or country. If you are located outside of the United States, please be advised that as a global business we may we process, share and store Personal Information in countries other than your country of residence, including the United States.

By using our Platforms and unless such consent is prohibited by law, you are agreeing to the collection, use, transfer, and disclosure of your Personal Information, browsing information, and that communications will be subject to the applicable laws in the United States.

CONTACT US

If you have any questions or concerns about the Poshura Privacy Notice, please send an email to contact@poshura.com, call us toll free at 1-360-553-0114 (Poshura) or write to us at Linkers Capital LLC, Attn: Poshura Privacy, 5918 NE FOURTH PLAIN BLVD, VANCOUVER, WA 98661-6828.

To request a copy of the most recently replaced version of our Privacy Policy, send an email to contact@poshura.com.

NOTICE TO CERTAIN U.S. STATE RESIDENTS

Privacy Rights Under Certain U.S. State Privacy Laws

This Supplemental Notice applies solely to residents of the States of California, Colorado, Connecticut, Oregon, Montana, Texas, Utah, and Virginia who have interacted with us in the ways described in the introduction of this Privacy Policy, and who have certain privacy rights under the applicable laws in their state (“State Privacy Laws”). This section serves as our California notice at collection.

Personal Information We Collect, Use, and Disclose

To review the types of Personal Information we collect, the sources of this information and how we use and disclose this information, read the Section of this Privacy Policy titled “YOUR PERSONAL INFORMATION”. We will not collect additional categories, or use the Personal Information we collected, for materially different, unrelated, or incompatible purposes without providing you notice.

Sensitive Personal Information

We do not collect or process sensitive Personal Information as defined by State Privacy Laws.

Sharing, Selling and Targeted Advertising

As described in the “YOUR PERSONAL INFORMATION” and “COOKIES, TRACKING AND ADVERTISING” Sections of this Privacy Policy, we disclose certain categories of Personal Information for a variety of business purposes including to show you targeted ads on third-party properties (e.g., other websites or platforms). These disclosures may be considered “sales,” “sharing,” or use of Personal Information for “targeted advertising” under State Privacy Laws. The definition of “sale” of personal data refers to the sharing of that information in exchange for valuable consideration. In some states the consideration may be things other than money. What is considered “valuable consideration” may be hard to interpret and could cover many common business activities. LS&Co. does not sell your Personal Information for money to third parties for their independent business use, for example for their own marketing and advertising purposes.

In the last 12 months, we disclosed the following categories of Personal Information to advertising and marketing networks and to social networks:

Contact Information and Identifiers (g., email addresses, device identifiers)

Online and Technical Information (g., browsing data, advertising ID’s, cookie ID’s)

Inferred and Derived Information (g., approximate location derived from IP address or information drawn about your preferences based on your behavior)

To opt out of sales, sharing, or targeted advertising, follow the instructions in the “YOUR PRIVACY RIGHTS” Section below. We do not knowingly sell or share the Personal Information of consumers under 16 years of age.

YOUR PRIVACY RIGHTS

State Privacy Laws provide specific rights regarding your Personal Information. A full description of these rights and how to exercise them is included below. Only you, or someone legally authorized to act on your behalf and with written permission, may make a verifiable consumer request related to your Personal Information.

Opt Out of Sales, Sharing and Targeted Advertising

You may opt out of having your Personal Information sold, shared, or used for targeted advertising by clicking this link: Do Not Sell or Share My Personal Information here or in the website footer.

When opting out of cookie-based ad targeting, you may need to renew your opt-out choice if you use a different browser or device to access our Platforms, or if you clear your cookies.

Where we are required to honor these signals by law, you can also opt out by visiting our Platforms with a legally recognized universal choice signal enabled (such as the Global Privacy Control). If you are not logged into an account with us, our processing of this signal will be limited to cookie-based sales, sharing and targeted advertising for the specific browser or device that you are using.

Right To Know, Access, Correct, Delete

You have the right to (1) request to know more about and access your Personal Information, including in a portable format, (2) request deletion of your Personal Information, and (3) request correction of inaccurate Personal Information.

To request access, correction, or deletion of your Personal Information, you can submit your request by calling us at 1-800-872-5384, speaking with an onsite store manager at one of our U.S. store locations, or by clicking on this link: Exercise Your Consumer Privacy Rights.

To authenticate your request, you must provide, at a minimum, your name and an email address and respond to a confirmation email that will be sent to that address.

We will process your request in accordance with State Privacy Laws, including any exceptions that may apply in fulfilling your request. For example, we may not be able to fulfill your request if we cannot verify your identity.

Authorized Agents

If you are an authorized agent seeking to make an opt-out request for a consumer, please submit a request here: Do Not Sell or Share My Personal Information.

If you reside in California, you may also designate an authorized agent to submit an access, deletion, or correction request on your behalf. You may also make a verifiable consumer request on behalf of your minor child. We may ask authorized agents to submit proof of their authority to make a request, such as a valid power of attorney or proof that they have signed permission from the consumer who is the subject of the request. In some cases, we may be required to contact the individual who is the subject of the request to verify his or her own identity or confirm the authorized agent has permission to submit the request. If you are an authorized agent seeking to make an access, correction, or deletion request on behalf of a California resident, please use the following link: Authorized Agent Privacy Rights Request.

Additional Methods for Exercising Your Rights

To initiate these rights in one of our U.S. store locations, speak with an onsite store manager.

You may also call us toll-free at 1 360-553-0114.

If you wish to obtain the results of a Request to Know inquiry in hard copy (paper) format, please contact Customer Service at 1 360-553-0114 to submit your request.

Right To Appeal

If we were unable to fulfill your request, we will notify you. You may appeal our decision by emailing us at contact@poshura.com within fourteen calendar days, including “Appeal Request” in the subject line, with a detailed reason for your appeal, as well as your state of residence. If you are dissatisfied with our decision on your appeal, you may contact your applicable state Attorney General.

Non-Discrimination

You have a right not to be discriminated against for exercising any of your privacy rights.

Notice of Financial Incentives – California & Colorado Consumers

We may offer discounts, rewards, coupons, exclusive offers, and other benefits to customers how join our loyalty program or participate in certain promotional campaigns. These offerings may constitute “financial incentives” or “bona fide loyalty programs” under State Privacy Laws (for simplicity, we refer to these offerings as financial incentives throughout this Privacy Policy).

Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time. You can opt in to, or opt out of, our financial incentive programs at any time through the same means they are offered, or by contacting us through the contact methods described in the Contact Information section below. If you request that we delete Personal Information that is essential to providing you with the financial incentive, we will not be able to provide you with such benefits going forward. For example, if you ask us to delete your email address, we will no longer be able to email you discounts, coupons, or other exclusive offers or benefits.

The details of each financial incentive program are contained in the program offering. Our current programs can be found here. The financial incentives offered by Poshura from time to time in exchange for consumers’ Personal Information, such as identifiers (typically a promotional discount in exchange for an email address or for joining a member rewards program) are commonly percentage discount codes to be applied to a single purchase. The discounts may result in a range of savings to the consumer, depending on the details of the purchase, and are primarily offered to consumers as a way of introducing them to the Poshura product and brand, following which we are confident the quality of our products and service will turn a first-time purchaser into a loyal and delighted long-term Poshura consumer.

Incentives are not directly tied to, or exclusively based upon, a set value of any individual element of consumer data, but are reasonably based in good faith on the following considerations:

Most individuals first experience our brand online and offering an incentive provides a unique opportunity for them to explore our products.

The majority of Poshura's marketing and advertising activities are done online, and email communications are a key part of reaching existing and potential consumers in a manner which they both expect and that allows for them to exercise choices about how or whether or not to be contacted.

Discounts may also be affected by factors such as performance targets, geographic location, seasonality, and market trends.

The potential value to our business of any individual consumer’s Personal Information is dependent on a number of factors, including the ability to combine this information with a broader set of other consumers’ Personal Information, whether, and to what extent, a consumer takes advantage of or opts out of any offerings, and whether we are able to use the data as described here. Our ability to create any value from financial incentive programs is heavily based on the quantity of data ingested through these proprietary programs, and our ability to leverage it. The value of your Personal Information is reasonably related to the value of the offer or discount presented.

DATA RETENTION

We store your Personal Information as permitted by applicable law and as required to satisfy the purpose for which the data is processed, unless a longer period is required for purposes such as complying with retention obligations, record keeping or other commercial requirements.

CONTACT US

To request a copy of the most recently replaced version of our Privacy Policy, send an email to contact@poshura.com.