This Privacy Policy explains how Flair Gifts llc, a company registered in the state of California, of 9027 Canoga Ave, Canoga Park, CA 91304 ( "Posh Paper", "the Site", "we", "us", or "our") collect, use, share and process your information as well as the rights and choices you have associated with that information. This Privacy Policy applies to all personal information collected during any written, electronic, and oral communications or collected online or offline through poshpaperwraps.com ("the Site").

Please read our Terms of Service and this Policy before accessing or using our website. If you cannot agree with this Policy or the Terms of Service, please do not access or use our website. Unless otherwise required by laws in your residence, by using our website, you accept the Terms of Service and accept our privacy practices described in this Policy.

We may modify this Policy at any time, without prior notice, and changes may apply to any personal information we already hold about you, as well as any new personal information collected after the Policy is modified. If we make changes, we will notify you by revising the date at the top of this Policy. We will provide you with advanced notice if we make any material changes to how we collect, use or disclose your personal information that impact your rights under this Policy. Unless otherwise required by laws in your residence, your continued access or use of our website after receiving the notice of changes, constitutes your acknowledgement that you accept the updated Policy.

In addition, we may provide you with real time disclosures or additional information about the personal information handling practices of specific parts of our website. Such notices may supplement this Policy or provide you with additional choices about how we process your personal information.

1. Personal Information We Collect

We collect personal information when you use our website, create an account with us or submit personal information when requested with the Site. Personal information generally is any information that relates to you, identifies you personally or could be used to identify you, such as your name, email address, phone number, address and payment account number. The definition of personal information varies by jurisdiction. Only the definition that applies to you based on your location applies to you under this Privacy Policy. Personal information does not include data that has been irreversibly anonymized or aggregated so that it can no longer enable us, whether in combination with other information or otherwise, to identify you.

The types of personal information that we may collect about you include:

Information You Directly and Voluntarily Provide to Us to execute the product purchase. We collect your personal information you give us when you use our website. For example, if you visit our Site and place an order, we collect information that you provide to us during the ordering process. This information will include your first and last name, mailing address, email address, phone number, payment account or credit card information. In some regions, passport information and tax number are also needed for customer clearance. We may also collect personal information when you communicate with any of our departments such as customer service, or when you complete online forms or surveys provided on the site. You may also choose to provide your email address to us if you would like to receive information about the products that Posh Paper offers, such as Posh Paper New released products.

Information You Post on the Site. If you post information on public areas of the Site, for example a customer review, that information may be collected and used by Posh Paper, users of the Site, and the public generally. We strongly recommend that you do not post any information through the Site that allows strangers to identify or locate you or that you otherwise do not want to share with the public.

Information You Provide to Participate in Loyalty Program. From time to time, we may ask you to complete a survey and/or offer you an opportunity to participate in promotions, programs (collectively, "Promotions") via the Site or through a third-party platform. If you choose to participate in a Promotion or Program, we will collect and store the personal information you provide in connection with your participation in the Promotion and Program, including, but not limited to, your name, email address, date of birth, and/or phone number. Such information shall be subject to this Privacy Policy unless otherwise stated in the official rules or guidelines of the Promotion and Program or in another privacy policy governing the Promotion and Program. Information we collect in connection with a Promotion and Program will be used to administer the Promotion and Program, such as by notifying winners and distributing prizes. As permitted by applicable law, your information may also be used by Posh Paper or the Promotion and Program sponsor for marketing purposes. Your entry into the Promotion and Program may result in the addition of your information to our mailing list as well as to the mailing list of our promotional partners. Acceptance of a prize may require you (unless prohibited by law) to allow us to post publicly some of your information via the Site, such as on a winner's page.

Information Automatically Collected Through the Site. We may automatically collect personal information about you when you use the Site. For example, if you access the Site through a computer, we will automatically collect information such as your browser type and version, computer and connection information, Internet Protocol ("IP") address and standard web log information. If you access the Site through a mobile device, we may also be able to identify the location of your mobile device. You may choose not to share your location details with us by adjusting your mobile device's location services settings. You may be able to adjust the settings of your device so that information about your physical location is not sent to us or third-parties by (a) disabling location services within the device settings; or (b) denying certain websites or mobile applications permission to access location information by changing the relevant preferences and permissions in your mobile device or browser settings. For instructions on changing the relevant settings, please contact your service provider or device manufacturer. Please see section 2 below to learn more about our automatic personal information processing activities. Please note that your location may be derived from your WiFi, Bluetooth, and other device settings. See your device settings for more information.

Combination and automated information. We may also combine the information we collect among our services and across your devices and use different technologies to process your information for the purposes described above. For example, we use automated systems that analyze your account status and payment information to detect the unsafe and unsecured payment. We also use automated systems to assess security of your account and provide you suggestion to improve the security of your account.

Additionally, Flair Gifts llc collects personal customer information which is shared with Meta (Facebook) in an effort to serve more relevant ads and improve our customer experience.

2. Cookies and Other Tracking Technologies

This Site contains plug-ins and tools, including analytics and advertising tools, that work with help of cookies. These tracking technologies allow our technology partners to collect information including your computer's IP address, your mobile device identifier, the type of internet browser you are using, operating system, referral URLs, date/time stamps, pages viewed, and simple keyword tags. Cookies or tags are bits of code that allow our technology partners to collect information including your computer's IP address, your mobile device identifier, the type of internet browser you are using, operating system, referral URLs, date/time stamps, pages viewed, and simple keyword tags. We also use web pixels to analyze usage patterns on our Site.

You can always enable or disable cookies at any time by changing your browser settings. To manage cookies, most browsers allow you to accept or reject all cookies or accept only certain types of cookies. Search for "cookies" under your web browser's "Help menu" for more information on cookie management features available to you. You can also find more detailed information about cookies at the All About Cookies and Your Online Choices websites. Please be aware that if you choose to disable some or all cookies, then not all features of our Site may operate as intended and you may be unable to complete certain activities on our Site or to correctly access certain parts of it. For example, without cookies enabled, you may need to "Sign In" upon each visit, instead of the cookie automatically filling these details in for you.

Please read our Cookie Policy for more details.

3. How We Use Your Personal Information

We will only use your personal information as described in this Privacy Policy or as disclosed to you prior to such processing taking place.

(A) To Provide You Our Products. We will use your personal information to provide information or perform Services that you request, including managing your request as a registered user of our Site. If the applicable information is to be provided or Service is to be performed by a third party, then we will disclose the applicable information to the third party providing the information or performing applicable Services. All third parties that we work with are contractually obligated to protect your information as disclosed in this Privacy Policy.

(B) For Internal Use. We use your personal information for the purposes of furthering our business, including improving our Site's content and functionality by analyzing where, on which types of devices and how our Site is used, how many visitors we receive, and where they click through to the Site from. We also use it to remember you in case you re-visit our Site, so we will know if you have already been served with surveys, or (where Site content is undergoing testing) which version of the content you were served.

(C) To Provide You with Service-Related Communications. We will send you administrative or account-related information to keep you updated about your account and the Services. Such communications may include information about Privacy Policy updates, confirmations of your account actions or transactions, security updates or tips or other relevant transaction-related information. We process your contact information to send you such communications. Service-related communications are not promotional in nature. You are not able to unsubscribe from such communications, otherwise you may miss important developments relating to your account or the Services.

(D) To Provide Customer Support or Respond to You. We collect any information that you provide to us when you contact us. Without your personal information, we cannot respond to you or ensure your continued use and enjoyment of the Services.

(E) To Communicate Information about our Events and Promotions (e.g. SMS, e-mail). We may collect your e-mail address, phone number or other electronic addresses that you voluntarily provide to us when you choose to participate in our promoting activities or subscribe for marketing communications. When you no longer wish to receive these marketing messages from us, you can opt out from receiving such marketing messages at any time by unsubscribing or following the instructions contained within such messages.

We may also collect and use your mobile advertising identifiers for the purpose of marketing campaigns. Please read our Cookie Policy for more details. To Ensure the Security of the Services. We care about keeping you secure and safe while using our Services. Keeping you safe requires us to process your personal information, such as your device information, activity information and other relevant information. We use such information to combat spam, malware, malicious activities or security risks; improve and enforce our security measures; and to monitor and verify your identity so that unauthorized users do not gain access to your information. We cannot ensure the security of our Services if we do not process your personal information for security purposes.

(F) To Enforce Compliance with Our Terms and Agreements or Policies. When you access or use our Services, you are bound to our Terms and Conditions. To ensure you comply with them, we process your personal information by actively monitoring, investigating, preventing and mitigating any alleged or actual prohibited, illicit or illegal activities on our Services. Subject to the applicable law, we may also process your personal information to: investigate, prevent or mitigate violations of our internal terms, agreements or policies and enforce our agreements with third parties and business partners.

(G) To Maintain Legal and Regulatory Compliance. Our Services are subject to certain laws and regulations which may require us to process your personal information. For example, we process your personal information to pay our taxes, to fulfill our business obligations, ensure compliance with employment and recruitment laws or as necessary to manage risk as required under applicable law. Without processing your personal information for such purposes, we cannot perform the Services in accordance with our legal and regulatory requirements.

4. Sharing Your Personal Information

Other than sharing your personal information so that you can use our website, or as required or permitted by law, we do not share personal information about you with non-affiliated third parties. We may disclose your personal information as described below.

(A) Within Our Corporate Organization. Posh Paper may share your personal information within our organization to provide you with the products and take actions based on your request.

(B) Third Parties. We may share your personal information with third-party service providers acting on our behalf to help us operate our website. Service providers and vendors provide us with support services such as credit card processing, website hosting, email and postal delivery, analytics services, conducting surveys and research, and performing network maintenance. These third parties can only use your data in accordance with our written instructions and must comply with the information security protections we have put in place.

(C) To Maintain Legal and Regulatory Compliance. We have the right to disclose your personal information as required by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator or any other legal process served on Posh Paper. If there is a takeover, sale or purchase of our business, we may disclose your personal information to the new (or prospective) owner of the business.

(D) Third Party Advertisers. In certain circumstances, and subject to the applicable law, we may share your personal information with third parties to market their products or services to you.

(E) Co-Branded Products and Features. Portions of our Site or Products may be offered as part of co-branded services and features. We will share your personal information with our co-branded partners based on your voluntary use of or participation in a co-branded service or feature. The co-branded partners will be identified on the co-branded feature or service, along with an applicable co-branded partner's privacy policy. Use of your personal information by a co-branded partner will be subject to a co-branded partner's privacy policy. If you wish to opt-out of a co-branded partner's future use of your personal information, you will need to contact the co-branded partner directly.

(F) Consent. We may disclose your personal information for any purpose with your consent.

5. Security Precautions

We maintain physical, electronic, and procedural safeguards designed to guard and prevent misuse of your personal information. Our security measures include industry-standard physical, technical and administrative measures to prevent unauthorized access to or disclosure of your information, to maintain data accuracy, to ensure the appropriate use of information, and otherwise safeguard your personal information. We restrict access to your non-public personal information to those employees and third parties who need such information to provide products.

Please recognize that protecting your personal information is also your responsibility. We ask you to be responsible for safeguarding your password, secret questions and answers and other authentication information you use to access our website.

If you feel that the security of your account or personal data has been compromised, please immediately contact us at following email address support@poshpaperwraps.com. Please be aware that, despite our best efforts, no security system is impenetrable. In the event of a security breach, we will promptly notify you and the proper authorities if required by law.

6. Your Rights

We take reasonable steps to ensure that your personal information is accurate, complete, and up to date. You have the right to access, correct, or delete the personal information that we collect, subject to certain exceptions. To protect the privacy and the security of your personal information, we may request data from you to enable us to confirm your identity and right to access such data, as well as to search for and provide you with the personal data we maintain. There are instances where applicable laws or regulatory requirements allow or require us to refuse to provide or delete some or all of the personal information that we maintain. You may Contact Us to exercise your rights.

7. Retention

We will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

If you send us correspondence, including emails, we retain such information electronically in the records of your account. We will also electronically retain customer service correspondence and other correspondence from Posh Paper to you. We retain these records to measure and improve our customer service and to investigate potential fraud and violations. We may, over time, delete these records as permitted by law.

Posh Paper will also retain Site and services usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Site, or we are legally obligated to retain this data for longer periods.

8. Third-Party Websites

Our Site may contain links to third-party sites. This Privacy Policy does not apply to those third-party sites. We recommend that you read the privacy statements of any other sites that you visit as we are not responsible for the privacy practices of those sites.

9. Children

Our Services are not directed to, and we do not knowingly collect personal information from, children under the age of 16. If you are under 16, please do not attempt to fill out our forms or send any personal information about yourself to us. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information from our files.

10. International transfers of personal information

When you access or use our website, your personal information may be transferred outside the country or region of your residence or nationality, mostly to the United States and China, in order to facilitate our global operations. Laws in these countries may differ from the laws applicable to your country of residence. Such countries or regions may have data protection laws that are less protective than the laws of the jurisdiction in which you reside. For those countries or regions, measures have been taken pursuant to data protection laws to protect personal information, including without limitation entering into contractual clauses with overseas recipient on personal information protection.

For individuals using or accessing our website while located in the European Economic Area, the United Kingdom, or Switzerland, please kindly note that, for these transfers, we rely on appropriate safeguards as permitted under the GDPR such as Standard Contractual Clauses, and/or we transfer the personal information pursuant to Article 49 (1) (b) GDPR to provide our product pursuant to the Terms & Conditions. If you do not want your information transferred to, processed, or maintained outside of the country or jurisdiction where you are located, you should immediately stop accessing or using the website. For further details about these transfers and the safeguards that we use to facilitate such transfers, contact us at support@poshpaperwraps.com.

11. Notice for California Residents

This section applies only to California residents. Pursuant to the California Consumer Privacy Act of 2018, as amended ("CCPA") and the California Privacy Rights Act ("CPRA"), below is a summary for the last twelve (12) months of the personal information categories, as identified and defined by the CCPA and the CPRA (see California Civil Code section 1798.140 (o)), that we collect, the reason we collect the personal information, where we obtain the personal information, and the third parties that we may share the personal information.

We generally collect the following categories of personal information when you use our website:

identifiers such as a name, address, unique personal identifier, email, phone number, your device's IP address, software, and identification numbers associated with your devices;

commercial information such as records of products or services purchased, obtained, or considered by you;

Internet or other electronic information regarding you browsing history, search history, the webpage visited before you came to our Site, length of visit and number of page views, click-stream data, locale preferences, your mobile carrier, date and time stamps associated with transactions, and system configuration information;

your geolocation, to the extent you have configured your device to permit us to collect such information;

audio recordings of your voice to the extent you call us, as permitted under applicable law;

inferences about your preferences, characteristics, behavior and attitudes.

We generally do not collect protected classifications about our users, bio-metric information, professional or employment-related information, or education-related information. For more information about the personal information we collect and how we collect it, please refer to sections 1 and 2 above.

We collect your personal information for the business purposes described in section 3. The CCPA and CPRA define a "business purpose" as the use of personal information for the business's operational purposes, or other notified purposes, provided the use of personal information is reasonably necessary and proportionate to achieve the operational purpose for which the personal information was collected or another operational purpose that is compatible with the context in which the personal information was collected.

The categories of third parties with whom we may share your personal information are listed above in section 4, above.

If you are a California resident, you have rights in relation to your personal information; however, your rights are subject to certain exceptions. For instance, Posh Paper cannot disclose specific pieces of personal information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the personal information, your account with us or the security of our network systems. To assert your right to know or your right to delete your personal information, please contact us by email at support@poshpaperwraps.com. To confirm your identity, we may ask you to verify personal information we already have on file for you. If we cannot verify your identity based on the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes.

Right Against Discrimination. You have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your right to know, delete or opt-out of sales.

Right to Know. You have the right to request in writing: (i) a list of the categories of personal information, such as name, address, email address, that a business has disclosed to third parties during the immediately preceding calendar year for the third parties' direct marketing purposes, and (ii) the names and addresses of all such third parties. In addition, you have the right to request: (i) the categories of personal information we have collected about you, (ii) the categories of sources from which personal information is collected, (iii) the business or commercial purpose for the information collection, (iv) the categories of third parties with whom we have shared personal information, and (v) the specific pieces of personal information we hold about an individual. You have the right to request a copy of the specific personal information we collected about you during the 12 months before your request.

Right to Delete. You have the right to request us delete any personal information we have collected from you or maintain about you, subject to certain exceptions.

Right to Opt-Out of Selling. You have the right to opt-out of having your personal information sold. We do not sell your personal information. The CCPA and CPRA broadly define "personal information" and "selling" such that sharing identifiers linked to you for a benefit may be considered a sale. You have the right to know the categories of personal information that we sold about you and the categories of third parties with whom we shared such information.

Right to Limit the Use of Sensitive Personal Information. Some of the information we collect and use in accordance with aforementioned sections 1 to 3 might fall into the scope of sensitive personal information as defined by CPRA. The use of such sensitive personal information will be limited to that use that is necessary for us to provide Services you or perform our duties as required by CCPA and CPRA. If we may use your sensitive personal information for any other purpose, we will inform you and you have the right to limit the use of your sensitive personal information. Upon your request, we will not use your sensitive personal information for the proposed additional purpose.

Right to Correct Inaccurate Personal Information: You have the right to request us to correct inaccurate personal information if and when you learn that we maintain inaccurate personal information about you.

In addition, California Civil Code Section 1798.83 permits customers of Posh Paper who are California residents to request certain information regarding our disclosure of personal information to third-parties for their direct marketing purposes. In your request, please specify that you want a "California Shine the Light Notice." Please allow 30 days for a response. To make the request, please contact us by email at support@poshpaperwraps.com. Do not sell my personal information.

12. Notice for Nevada Residents

If you are a Nevada resident and have provided us with any personal identifying information, you may opt-out of sharing your information with third parties if you submit an opt-out request to the following email address: support@poshpaperwraps.com. Please note we do not sell any of your personal information for profit, we do share some information with contracted third parties in order to provide better services and advertising to you. Please allow 60 days for completion of such request.

13. Notice to Individuals in the European Economic Area, the United Kingdom and Switzerland

This section only applies to individuals using or accessing our website while located in the European Economic Area, the United Kingdom, or Switzerland (collectively, the "European Countries") at the time of data collection. Pursuant to the EU's General Data Protection Regulation (GDPR), personal information is referred to as personal data. For the sake of clarity references to personal information in this Policy concerns personal data in the sense of the GDPR.

We may ask you to identify which country you are located in when you use or access some of the website pages, or we may rely on your IP address to identify which country you are located in. When we rely on your IP address, we cannot apply the terms of this section to any individual that masks or otherwise hides their location information from us so as not to appear located in European Countries. If any terms in this section conflict with other terms contained in this Policy, the terms in this section shall apply to individuals in a European Country.

Our Relationship to You. Your personal information is collected and processed by NAVAdeal Inc, which is operating the website and the sales of Posh Paper brand products. In other words, NAVAdeal Inc is the Controller of the data. This means that we are responsible for processing and protecting your personal data.

Our legal basis to process personal information for the following sections of this Privacy Policy is your consent.

Legal Bases for Processing Your Personal Information. We rely on the following legal bases under the GDPR in processing your personal information.

Section 2 In relation to mobile Advertising and third-party advertising and analytics cookies, that collect your personal information, as described in that Section.

Section 3(E) To Communicate Information about our Events and Promotions (e.g. SMS, e-mail)

Section 4(D) Third Party Advertisers

Section 4(F) Consent

Our legal basis to process personal information for the following sections of this Privacy Policy is to provide our Services to you. Our processing is based on our contract obligations or to take steps at the request of the individual prior to entering into a contract.

Section 3(A) To Provide You Our Products

Section 3(C) To Provide You with Product-Related Communications

Section 3(D) To Provide Customer Support or Respond to You

Section 4(A) Within Our Corporate Organization

Section 4(B) Third Parties

Section 4(E) Co-Branded Products or Features

Our legal basis to process personal information for the following sections of this Privacy Policy is our legitimate interest to better understand you, to maintain and improve the accuracy of the information we store about you, and to better promote or optimize our website. We will take necessary organizational and technical measures to appropriately safeguard the security of your personal information. We will only process your personal information to the extent mentioned in this Privacy Policy. We will not infringe on your basic rights or freedom.

Section 3(B) For Internal Use

Our legal basis to process personal information for the following sections of this Privacy Policy is to comply with our legal obligations, or your vital interest.

Section 3(F) To Ensure the Security of the Services

Section 3(G) To Enforce Compliance with Our Terms and Agreements or Policies

Section 3(H) To Maintain Legal and Regulatory Compliance

Section 4(C) To Maintain Legal and Regulatory Compliance

Marketing. We will only contact you if you are located in a European Country by electronic means (including email or SMS) based on our legitimate interests, as permitted by applicable law or your consent. If you do not want us to use your personal information in this way, please contact us at support@poshpaperwraps.com. You can object to direct marketing at any time and free of charge.

Individual Rights. We provide you with the rights described below when you use our website. We may limit your individual rights requests: (a) where denial of access is required or authorized by law; (b) when granting access would have a negative impact on other's privacy; (c) to protect our rights and properties; or (d) where the request is frivolous or unrealistic. If you would like to exercise your rights under applicable law, please contact us at support@poshpaperwraps.com.

You can request access or deletion of your personal information, subject to certain exceptions.

You can correct or update your personal information, object to processing of your personal information, ask us to restrict processing your personal information or request portability of your personal information.

If we collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of the processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

You have the right to complain to a data protection authority about our collection and use of your personal information.

If you believe we have infringed or violated your privacy rights, please contact us at support@poshpaperwraps.com. so that we may resolve your dispute directly.

Automated Decision-Making, including Profiling. We DO NOT make any decisions based on algorithms or other automated processing that significantly affect you.

14. Contact Us

We welcome questions, comments, and concerns about our privacy policy and privacy practices.

The products are provided by Flair Gifts llc. If you wish to provide feedback or if you have questions or concerns, or wish to exercise your rights related to your personal data, send us an email at support@poshpaperwraps.com. or sent us a mail to our Privacy Office at: 9027 Canoga Ave., Canoga Park California 91304

Last updated: June 26, 2024