Privacy Policy
Effective Date: October 2025
Welcome to Pashion Footwear Inc.’s (“Pashion,” “we,” “our” or “us”) Privacy Policy. We value your privacy and are committed to protecting the personal information of our customers and website visitors. We’ve kept this Privacy Policy as simple as possible to let you know the how, why, and what of our data collection practices when you visit our Sites or buy our products[ET1] . It also tells you about your privacy rights and how the law protects you.
Please read this Privacy Policy carefully , together with our Terms and Conditions (“Terms”), before using our website ( www.pashionfootwear.com), any other website we operate (collectively, “Website”), or our services (together with the Website, the “Services”). This Privacy Policy does not apply to job applicants or Pashion personnel; please refer to our Personnel Privacy Policy for those activities.
By accessing and using our Services, you acknowledge that you have read and understand the content of this Policy. If you do not agree to the terms of this Policy, please discontinue use of the Services.
If you need this Privacy Policy in an alternative format due to a disability, please contact us at privacy@pashionfootwear.com. You may print a copy of this Privacy Policy.
Your Privacy Rights and How to Exercise Them
Depending on where you live, you may have the right to:
- Access the Personal Information we hold about you.
- Request correction of inaccurate Personal Information.
- Request deletion of your Personal Information.
- Opt out of the sale or sharing of your Personal Information, including for cross-context behavioral/targeted advertising.
- Opt out of profiling in furtherance of decisions that produce legal or similarly significant effects.
- Receive your Personal Information in a portable format, where technically feasible.
- Appeal a denial of privacy rights requests.
To exercise any rights that you might have, please submit a verifiable request by emailing privacy@pashionfootwear.com or by using our self-service tools in the footer of our Website. We will verify respond within the timelines required by applicable law. Authorized agents may submit requests as permitted by law.
We honor Global Privacy Control (“GPC” signals for opt-out of sale/sharing/targeting advertising to the extent required by applicable law.
We share information with service providers (e.g., payment processors, analytics services) only as needed for business operations. These partners are contractually required to use your data only as instructed by us and never for their own purposes. For step-by-step actions (download your data, correct information, or delete your account), visit our LINK for easy self-service tools.
Changes to this Privacy Policy
Pashion may update this Privacy Policy from time to time. We will post any changes on our Website and update the effective date. We encourage you to check regularly for any updates. If we make material changes, we may also notify registered users by email or other appropriate means. Your continued use of our Services after updates constitutes your acceptance of the revised Privacy Policy.
What Information Do We Collect?
Types of Data Collected
In this Privacy Policy, “Personal Information” means information that identifies, relates to, describes, or could reasonably to linked to a particular individual or household. It does not include deidentified or aggregated information.
At Pashion, we collect the following categories of Personal Information:
|
Category of Data |
What It Includes |
|
Identity Data |
First name, last name, login/password. |
|
Contact Data |
Billing address, shipping/delivery address, email address and telephone numbers. |
|
Financial Data |
Limited payment information provided by our payment processor(s) (e.g. the last 4 digits of your credit card and the expiration year). |
|
Transaction Data |
Details about payments to and from you and other details of products and services you have purchased from us. |
|
Profile Data |
Account details, purchase history, preferences, feedback and survey responses, and other profile data we derive (for example, using analytics). |
|
Technical Data |
IP address, device identifiers, browser type and settings, operating system, referring URLs, system configuration information. |
|
Usage Data |
Information about your interactions with our Website, products, and services. |
|
Tracking Data |
Information we collect from cookies, pixels, tags, SDKs, beacons, and similar tracking technologies. |
|
Marketing and Communications Data |
Your preferences in receiving marketing and your communication preferences. |
Aggregated Data
We also collect, use, and disclose Aggregated Data such as statistical or demographic data for any purpose. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. Aggregated Data may be derived from your Personal Information but is not considered Personal Information under the law as it does not directly or indirectly reveal your identity or the identity of anyone in your household.
Sensitive Information
We do not knowingly collect any “sensitive” Personal Information about you as defined by certain laws. This would include information about your racial or ethnic origin, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, biometric information, health information, genetic information, or precise geolocation. We do not knowingly collect any information about criminal convictions or offences.
Children’s Privacy
Pashion recognizes the privacy interests of children and we encourage parents and guardians to take an active role in their children’s online activities and interests. Pashion does not knowingly collect or solicit Personal Information from children under the age of 16 through our Website. Pashion does not target its Services to children under the age of 16. If you believe that your child under the age of 16 has submitted Personal Information to Pashion without prior consent, please contact us at privacy@pashionfootwear.com.
How We Collect Personal Information
We collect Personal Information about you in the following ways:
· Direct Interactions: You may give us Personal Information when you create an account, place an order, request information, sign up for product information, offers, or waitlists, subscribe to newsletters or SMS, contact customer service, leave reviews, or communicate with us via email and telephone.
· Automated Technologies: We automatically collect Technical, Usage, and Tracking Data when you interact with one of our advertisements or use the Website, including through cookies and similar tools.
· Third Parties: We may receive Personal Information from various third parties including third party service providers (e.g., hosting, analytics, advertising, payment processing), from your interactions with our social media pages and plugins, and from other partners that support our Services.
When you visit or log in to our Website, cookies and similar technologies may be used by our online data partners or vendors to associate these activities with other Personal Information they or others have about you, including by association with your email or home address.. We (or service providers on our behalf) may then send communications and marketing materials to these email or home addresses. You may opt out of receiving this advertising by visiting https://app.retention.com/optout
How We Use Your Personal Information
We use your Personal Information in a number of different ways. The tables below provide more detail, showing what we do with your Personal Information and why, but generally, we use your information for the following reasons and legal bases:
- In order to perform the contract we are about to enter into or have entered into with you. For example, when you purchase our products, that’s a contract. This may include disclosure to third parties who help us perform our end of the bargain, such as our shop hosting providers and shipping providers.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. For example, when we send newsletters or put you on a waiting list at your request.
- Where we need to comply with a legal or regulatory obligation. For example, keeping records of our sales for tax compliance.
|
Purpose/Activity |
Type of Data Non-Exhaustive |
Lawful Basis for Processing |
|
To register you as a new customer |
Identity; Contact |
Performance of a contract with you |
|
To process and deliver your order including:
|
Identity; Contact; |
Performance of a contract with you |
|
To manage our relationship with you which will include:
|
Identity; Contact; |
Required to perform a contract with you. |
|
To deliver direct, personalized marketing and promotional communications to you |
Identity; Contact; |
For most direct marketing communications, we rely on consent or consent implied from your past purchase of similar products from us; however, there are situations in which it is in our legitimate interests to use your Personal Information in this way |
|
To operate, secure, troubleshoot, test, maintain, and improve our Website and Services (including data analysis, support, reporting, and hosting of data) |
Identity; Contact; |
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise) |
|
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
Identity; Contact; |
Necessary for our legitimate interests (to study how customers use our products/ services, to develop them, to grow our business and to inform our marketing strategy) |
|
To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences |
Technical; Tracking; |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy) |
|
To make suggestions and recommendations to you about other products of ours that may be of interest to you |
Identity; Contact |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
|
To prevent and detect fraud, security incidents, and other malicious or illegal activity |
Identity; Contact; |
Necessary for our legitimate interests (to protect our business and our customers by way of undertaking fraud monitoring and suspicious transaction monitoring) |
|
To comply with applicable laws, regulations, legal processes, or enforceable governmental requests |
All relevant data categories, depending on the nature of the law, process, or claim. |
Necessary for legal obligations |
|
In order to resolve legal claims or disputes involving you or us |
All relevant data categories, depending on the nature of the allegation or claim |
Necessary to bring or defend a claim |
We do not use Personal Information for automated decision-making that produces legal or similarly significant effects without providing the notices and opportunities required by law.
Disclosing Your Personal Information
We may disclose your Personal Information to the third parties and third party services providers as follows:
- Service Providers: Companies that help us provide the Services, including delivering your orders to you, such as hosting service providers, payment processing providers, order fulfillment and delivery companies, fraud prevention agencies, customer engagement and support, analytics, and marketing providers;
- Professional Advisors: Professional service providers such as auditors, bankers, lawyers, accountants, insurers, marketing agencies, and advertising partners;
- Authorities: Governmental, regulatory, or law enforcement authorities, as required by law or to protect rights and safety;
- Social Media Platforms and Partners: If you choose to interact with pages or plugins, or if we jointly administer certain processing with them as described in this Privacy Policy; and
- Business Transfers: Buyers or other successors in interest in connection with a merger, acquisition, or sale of assets, subject to applicable law.
Currently, we disclose Personal Information to the following specific third parties:
- Shopify: for hosting and order processing. Please review their privacy policy to see how they use your Personal Information. By using our Website you consent to allow Shopify to collect Personal Information about you and for us to provide Personal Information about you to Shopify.
- Eleets 3PL: for warehousing of our products and shipping logistics. Please review their privacy policy to see how they use your personal data.
- Klaviyo for sending our newsletters, SMS and marketing. Please visit their privacy policy to see how they use your Personal Information.
For more information about third party service providers who perform advertising, retargeting, and analytics, please see the “Cookies” section below.
We require all third party service providers to respect the security of your Personal Information, to use it only as instructed by us, and to treat it in accordance with the law. We do not allow our third party service providers to use your Personal Information for their own purposes.
We may also disclose your Personal Information if the law otherwise allows it.
Social Media
Pashion maintains an online presence on social media platforms such as Instagram, Facebook, YouTube, TikTok, X (formerly Twitter), Pinterest, and other platforms that may be created in the future (collectively, “Social Media Platforms”). This presence allows us to communicate with users and provide information about our Services. When you interact with our pages or posts on Social Media Platforms, the platform may collect and process your Personal Information. Those Social Media Platforms have their own privacy policies, and you should review those prior to using the Social Media Platform. In some cases, we and the Social Media Platform are joint controllers, such as described below in the “EEA/UK Users” and “Facebook” sections.
Payment Information
Pashion uses third party payment processors, such as Shopify or ShopPay, to process payments. Your credit card details are communicated directly from your browser to these payment processors - Pashion does not see your full Permanent Account Number (PAN).
Advertising, Marketing and Your Communication Preferences
We may use your Identity, Contact, Technical, Tracking, Usage and Profile Data to form a picture of what we think may be of interest to you. This is how we decide which products, services and offers may be relevant for you and tell you about them. This is what we call direct marketing. We carry out direct marketing by email and, if you opt in, by SMS. You have the right at any time to opt out of marketing emails. The easiest way to opt out is to use the unsubscribe link that you will find at the bottom of each communication. You can opt out of SMS by following the instructions in the “Mobile Advertising” section.
If you see Pashion’s advertisements on third party websites and on Social Media Platforms, these may not be directed specifically at you; we might just have bid for the space. But we may specifically direct certain email promotions to you- for example if you live in a certain state, we may send you a marketing email for products related to that state.
We also work with third party service providers to try and promote the reach of our advertisements and use analytics and retargeting for this reason. We use Tracking Data to deliver relevant online advertising, including via websites [ET2] and social media. For more information on Tracking Data, and in particular cookies, which also help us deliver website and social advertising that we believe is most relevant to you and to potential new customers of Pashion, please see “Cookies and Similar Technologies” below.
Cookies and Similar Technologies
We and our third party service providers use cookies and similar technologies for essential Website functions, to measure the performance of different pages and features of our Website, to undertake analytics, to provide you with a more personalized experience, and for advertising, including retargeting. You can manage your cookie preferences, but if you disable certain cookies, some Website features may not function properly.
As you may be aware, there are different types of cookies:
Strictly Functional Cookies
First and foremost, certain “strictly functional” cookies help our websites work better. They help us work behind the scenes to make your customer experience easier. You’d miss a lot of these things if they were gone – like easily logging in and moving from page to page, and keeping products in your cart if you leave the website.
Performance Cookies
Other cookies collect information about how visitors use our Website, and measure how well the Website works – like whether a visitor gets an error message from our web pages. These “performance cookies” don't collect Personal Information that identifies a visitor. All of the information that “performance cookies” collect is aggregated and used to improve how our Website works.
Advertising Cookies
Finally, there are cookies that collect information about your browsing habits to make any advertising that is delivered to you more relevant to you and your interests. They are usually placed by advertising networks with our permission. They remember that you have visited a website and this information is then disclosed with other organizations such as advertisers. Quite often, targeting or “advertising cookies” will be linked to site functionality provided by the other organization. This is also why, when you’ve been on our Website, you might see some shoes that you previously looked at on the Website. “Advertising cookies” also enable retargeting. We use retargeting or remarketing services to advertise on third party websites to you after you visited our website. We and our third party vendors use cookies to inform, optimize and serve ads based on your past visits to our Website. Cookies can also tell us if you have seen a specific advertisement and how long it has been since you have seen it. This is helpful, because it means we can control the effectiveness of our advertisements and control the number of times people might be shown our advertisements. Cookies also help us understand if you’ve opened a marketing email - we don’t want to send you things that you don’t read.
Almost all cookies that relate to advertising are part of third party online advertising networks. If you’d like to read about how you can control which advertisements you see online, refer to opt-out programs established by the Digital Advertising Alliance (United States), the Digital Advertising Alliance of Canada, and the European Interactive Digital Advertising Alliance. We do not control cookies which are set by advertising networks.
You may opt out of these “advertising cookies” by accessing the cookie settings, through your browser settings, via industry tools such as the Digital Advertising Alliance (DAA), the Network Advertising Initiative (NAI), by [clicking here] or[ET3] by contacting us. You can also set your browser to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
We do not respond to browser “Do Not Track” signals. We honor GPC signals as required by applicable law to effectuate opt-out of sale, sharing, targeted advertising.
Facebook Remarketing.
Facebook remarketing service is provided by Facebook Inc. You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/ help/164968693837950. To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217.
You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings. For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation.
Google Analytics.
To provide better content and service, Pashion’s Website uses the Google Analytics web analytics service. You can learn more about Google Analytics’ use of cookies by visiting the Google Privacy and Terms page at http://www.google.com/policies/. You may opt out of being tracked by Google Analytics by:
1. Turning off cookies in the preferences settings in your browser
2. Downloading the Google Analytics opt-out browser add on available at: https://tools.google.com/dlpage/gaoptout/
3. Opting out of user interest and demographic categories in the Settings for Google Ads feature to manage or opt out of Google interest based ads; or
4. Managing cookies used for online advertising across multiple companies at the US based Network Advertising Initiative at http://www.networkadvertising.org/choices/.
Abandoned Cart Information.
The Website uses cookies and similar technologies to remember items in your cart and to receive notice when you have abandoned your cart. This information is used to determine when to send cart reminder messages via SMS, where permitted.
Session Replay and Chat Communications.
We may use session replay, chat, or similar tools to understand how users interact with our Website, provide support, and improve your experience. We disclose the use of these tools here to ensure transparency. These tools are configured to avoid capturing sensitive fields and may be subject to contractual restrictions with our third party service providers. Where required, we will obtain consent before using such tools and provide just-in-time disclosures near the chat interface. Please do not include sensitive Personal Information in chat or free-text fields.
If we combine or connect Aggregated Data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information, which will be used in accordance with this Privacy Policy.
Pashion may track your browsing habits across other third party websites.[ET4]
Mobile Advertising
See the “Mobile Terms of Service” below for details governing your receipt of SMS messages, including how to opt out. Message frequency varies and message and data rates may apply. We do not share your SMS opt-in with third parties for purposes unrelated to the messaging service. We may share your Personal Information, including SMS opt-in/consent status, with third party service providers who help us deliver text messages, as permitted by law and our contracts.
To opt out, text STOP to 82602 or use the unsubscribe link in any SMS message. For help, text HELP to 82602 or email info@pashionfootwear.com.
Third Party Links
The website may provide links to other websites (such as Google Forms or Social Media Platforms) or resources over which Pashion does not have control (collectively, “External Website”). Such links do not constitute an endorsement by Pashion of those External Website, and Pashion is providing these links to you only as a convenience. We are not responsible for the content of those External Website, and your use of External Website is subject to their respective terms of use and privacy policies. WE DO NOT ACCEPT ANY RESPONSIBILITY OR LIABILITY FOR THE CONTENT OR OPERATION OR INFORMATION PRACTICES OF SUCH EXTERNAL WEBSITES.
Data Security & Retention
We have put in place certain administrative, technical, and physical safeguards designed to protect your Personal Information against accidental or unlawful use, destruction, alteration, unauthorized disclosure, or access. For example, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to know.
We will only keep your Personal Information for as long as necessary to fulfill the purposes for which we collected it in the first place, as described in this Privacy Policy, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law, we have to keep basic information about our customers (including Contact, Identity, Financial, and Transaction Data) for seven years after a transaction for tax purposes and audit requirements. In some circumstances you can ask us to delete your Personal Information; see “Your Legal Rights” below for further information.
International Data Transfers
If you are located in the EEA or UK, your Personal Information may be transferred to and processed in countries that may not provide the same level of data protection as your home country, including the United States. Where required, we use appropriate safeguards for such transfers, such as the European Commission’s Standard Contractual Clauses, the UK International Data Transfer Addendum, and/or other lawful transfer mechanisms under applicable law. You may contact us for more information about these safeguards. We will not rely on consent or acceptance of Terms alone as a transfer mechanism where prohibited by law. More information about the Standard Contractual Clauses is available here https://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32010D0087.
EEA or U.K. Users
If the GDPR applies to you, you have certain rights in relation to your Personal Information, subject to certain conditions and exceptions:
- The right to be informed – that’s an obligation on us to inform you how we use your Personal Information (and that’s what we’re doing in this Privacy Policy);
- The right of access – that’s a right to make what’s known as a ‘data subject access request’ for a copy of the Personal Information we hold about you;
- The right to rectification – that’s a right to make us correct Personal Information about you that may be incomplete or inaccurate (though we generally recommend first making any changes in your Account Settings);
- The right to erasure (also known as the ‘right to be forgotten’) – that’s where in certain circumstances you can ask us to delete the Personal Information we have about you (unless there’s an overriding legal reason we need to keep it);
- The right to restrict processing – that’s a right for you in certain circumstances to ask us to suspend processing Personal Information;
- The right to data portability – that’s a right for you to ask us for a copy of your Personal Information in a common format (for example, a .csv file);
- The right to object – that’s a right for you to object to us processing your Personal Information (for example, if you object to us processing your Personal Information for direct marketing); and
- Rights in relation to automated decision making and profiling – that’s a right you have for us to be transparent about any profiling we do, or any automated decision making.
These rights are subject to certain rules around when you can exercise them. If you wish to exercise any of the rights set out above, please contact us (see “How to Contact Pashion About Privacy”).
Generally, you will not have to pay a fee to access your Personal Information (or to exercise any of the other rights) unless your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it.
We try to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Social Media and Joint Controllership for Individuals in the EEA
Sometimes, Pashion acts as a ‘joint controller’ with certain third parties, namely certain social media sites. When Pashion and a partner act as joint controllers, you (as a “data subject”) may exercise your rights against Pashion and/or the third party. For a list of our joint controller relationships, please contact us at privacy@pashionfootwear.com.
In order to market our websites and services and stay in touch with users, we maintain a Facebook page and use Facebook Pixel (“Facebook Products”). With respect to our use of these Facebook Products, we are jointly responsible with Facebook Ireland for the processing activities (“Joint Processing”):
Facebook Ireland Ltd.,
4 Grand Canal Square, Grand Canal Harbor
Dublin 2, Ireland
Information about the Personal Information that Facebook collects from you, as well as how and why Facebook processes it, can be found at https://www.facebook.com/about/privacy. Pashion and Facebook have entered into an agreement to determine the respective responsibilities for compliance with our obligations in connection with the Joint Processing within the meaning of the GDPR. This joint controller agreement, which sets out the reciprocal obligations, is available here.
Please note that Facebook Ireland is responsible for enabling data subjects’ rights under Articles 15-20 of the GDPR with regard to the Personal Information stored by Facebook Ireland in connection with the Joint Processing, as further described in Facebook’s privacy policy. To exercise your rights, please go to your Facebook settings or contact Facebook as set forth in its privacy policy.
Please note that some processing by Facebook Ireland Ltd. will also take place in the United States by Facebook Inc.
Representative in the EEA
We have appointed an EU representative who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the details in “How to Contact Pashion About Privacy” below.
Finally, you have the right to make a complaint at any time to the supervisory authority for data protection issues in your country of residence. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority so please contact us first.
How to Contact Pashion About Privacy
If you have any questions about this Privacy Policy, or would like to exercise any of your rights, even if you are not located in the European Economic Area, please contact us at:
Pashion Customer Service
Physical Address: 2950 Broad Street #1030 San Luis Obispo, CA 93401
E-Mail: privacy@pashionfootwear.com
Additional Information for Certain State Residents
Depending on where you live, your state might provide you with additional rights relating to Personal Data. For example, California (CCPA/CPRA) and certain other U.S. state laws (e.g., Virginia, Colorado, Connecticut, Utah) grant residents rights similar to those described above, including rights to access, delete, correct, portability, and to opt out of “sale,” “sharing,” or “targeted advertising.” As we have described, we may disclose Personal Information to third parties to provide analytics and advertising services. Under some state laws, such disclosures may be a “sale” or “share.” You can opt out by using the “Your Privacy Choices” link, our cookie settings tool, or via a GPC signal.
California Residents
This Privacy Notice for California Residents (“California Privacy Notice”) supplements the information contained in the Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“Consumers”). We have created this California Privacy Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act of 2020 (“CPRA”).
Categories of Information We Collect
Our services collect Personal Information (as that term is defined in CCPA). Within the last twelve (12) months, Pashion has collected the following categories of Personal Information from or about Consumers:
· Identifiers, such as a real name, unique personal identifier, online identifier, IP Address, email address, or account name
· Personal information categories listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e)), such as a name, signature or telephone number
· Commercial information, such as records of products purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
· Internet or other similar network activity, such as browsing history or information on a Consumer’s interaction with a website or application.
· Inferences drawn from other Personal Information, such as profile information reflecting a person’s preferences.
Personal information does not include:
· Publicly available information from government records.
· Deidentified or aggregated Consumer information.
· Certain other information that is already regulated by other laws or regulations.
· Information that is specifically exempt from the scope of the CCPA.
Categories of Sources of Personal Information
Pashion obtains the categories of Personal Information listed above from the following categories of sources:
Directly from you. For example, when you create an account or use our services. This includes the following categories of Personal Information:
· Identifiers
· Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
· Commercial information
Indirectly. For example, from observing your actions on our websites, including by the use of cookies or from third parties. This includes the following categories of Personal Information:
· Commercial information
· Internet or other similar network activity
· Geolocation data
· Inferences drawn from other Personal Information
By observing Consumers’ behavior through their purchases and activity on the websites. This includes the following categories of Personal Information:
· Internet or other similar network activity
· Inferences drawn from other Personal Information
Use of Personal Information
We may use, or disclose the Personal Information we collect for one or more of the following business purposes:
· Provide you access to, and use of, the websites, including registering you for an account and enabling purchases and orders
· Enable you to provide reviews
· Ensure that our websites and services are operational and optimized for user experience, as well as to enforce our terms and conditions with you if necessary
· Improve the content and general administration of the websites and our services
· Enhance user experience, including to provide you with customer support or to personalize your experience
· Detect fraud, illegal activities, harmful content, or security breaches
· Enable third parties to deliver advertising to you, and to enable you to participate in promotions and surveys, for monetization purposes
· Provide you with notices regarding goods or services that you have purchased or may wish to purchase in the future
· Perform system maintenance and upgrades, and enable new features
· Conduct statistical analyses and analytics
· Conduct research and development of our products and Services
· Provide information to regulatory bodies, as required by applicable law
Disclosure of Personal Information
Pashion may disclose your Personal Information to a third party for a business purpose. When we disclose Personal Information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the services for us. As explained in more detail above, we also disclose your Personal Information with certain categories of third parties who assist us in providing our services and with our business.
In the preceding 12 months, Pashion has disclosed the following categories of Personal Information for a business purpose:
· Identifiers
· Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
· Commercial information
· Internet or other similar network activity
· Inferences drawn from other Personal Information
Pashion will not collect additional categories of Personal Information (including sensitive Personal Information) or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Pashion does not collect protected classifications characteristics under California or federal law, such as biometric information, sensory data, professional or employment-related information, or non-public education information.
We disclose your Personal Information for a business purpose to the following categories of service providers or third parties:
· Companies that do things to help us provide the websites and/or services: hosting service providers, user engagement and customer support providers, certain analytics providers, payment service providers, communication tools;
· Professional service providers, such as auditors, lawyers, consultants, accountants and insurers.
Pashion is generally not in the business of selling your information; but, we may “sell” Personal Information under the broad definition of “sale” under California law. We also share Personal Information with or allow External Ad Partners to collect Personal Information about Consumers through our websites and/or services to assist us with advertising. If you would like to opt-out of our selling and sharing of your Personal Information with External Ad Partners for advertising purposes, please visit [Opt-Out URL].[ET5]
Your Rights and Choices
The CCPA provide Consumers with specific rights regarding their Personal Information, provided that we are able to verify their identities. This Section describes your rights and explains how to exercise those rights.
As explained above, if you would like to opt-out of us selling and sharing your Personal Information with External Ad Partners for advertising purposes, please visit [URL to Opt-Out].
Access to Specific Information and Data Portability Rights
You have the right to request that Pashion disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive your request and verify your identity (see Exercising Your Consumer Rights section below), we will disclose such information to you.
Deletion Request Rights
You have the right to request that Pashion delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive your request and verify your identity (see Exercising Your Consumer Rights section below), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) for certain reasons as permitted and set forth in the CCPA.
Right to Correction
You have the right to have corrected any inaccurate Personal Information that we have collected and retain.
Exercising Your Consumer Rights
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable Consumer request related to your Personal Information. You may also make a verifiable Consumer request on behalf of your minor child.
An authorized agent is a natural person or a business entity registered with the Secretary of State that a Consumer has authorized to act on his or her behalf. When a Consumer uses an authorized agent to submit a request to know, delete, or to correction, Pashion may require that the Consumer provide the authorized agent written permission to do so and verify his or her own identity directly with Pashion, unless the Consumer has provided the authorized agent with a valid power of attorney. Pashion may deny a request from an agent that does not submit proof that he or she has been authorized by the Consumer to act on his or her behalf.
To exercise the access/data portability, deletion, and correction rights described above, please submit a verifiable Consumer request to us by either:
· Logging into your Pashion account or
· emailing privacy@pashionfootwear.com.
You may only make a verifiable Consumer request for access or data portability twice within a 12-month period. The verifiable Consumer request must:
· Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
· Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
Making a verifiable Consumer request does not require you to create an account with us. Please note that the methods for verification are set forth in the CCPA, which also requires us to consider a number of factors, such as the type, sensitivity, and value of the Personal Information or the risk of harm posed by unauthorized access or deletion, on a case-by-case basis.
We will only use Personal Information provided in a verifiable Consumer request to verify the requestor’s identity or authority to make the request.
Response Timing
We endeavor to respond to a verifiable Consumer request within the timeframes set forth in the CCPA.
Any disclosures we provide will only cover the 12-month period preceding our receipt of the verifiable Consumer’s request. If applicable, in our response, we will also explain the reasons we cannot comply with a request. For data portability requests, we will select a format to provide your Personal Information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable Consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Where required, you may appeal our decision by following instructions in our response or by emailing privacy@pashionfootwear.com with “Appeal” in the subject line.
Sell and Share
Pashion does not sell your Personal Information to third parties for profit. Like most companies that operate websites, Pashion uses online analytics to measure the ways users engage with our websites, services, and to provide targeted marketing. These analytics, in turn, inform how we perform online advertising. In order to provide these analytics for cross-contextual behavioral advertising and facilitate online advertising, we use third parties that collect device identifiers and place tags, cookies, beacons, and similar tracking mechanisms on our digital properties and on third party digital properties as set forth in our [Cookie Notice link]. As such, California law may classify this limited sharing with contracted third parties as a “sale” or “share” of Personal Information. You may opt-out of our “selling” and “sharing” by accessing the cookie settings, by [clicking here], [ET6] or by contacting us.
Non-Discrimination and Notice of Financial Incentives
We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights. Please note that to use our websites or services, we do require the collection of your Personal Information – for example, to sign up for an account or to complete a paid transaction. While you may request to delete your Personal Information under CCPA, such deletions may affect Pashion’s ability to offer the services.
In addition, we may offer you financial incentives, including, in some cases, in the form of a discount, that are directly related to the value provided by the Personal Information for the collection, sale, retention, and use of your Personal Information as permitted by the CCPA. Please note that participating in incentive programs is entirely optional, you will have to affirmatively opt in to the program and you can opt out of each program by following the instructions in the applicable program description and terms.
We may add or change incentive programs and/or their terms by posting notices on the program descriptions and terms linked to the above so check them regularly.
Other California Privacy Rights
California residents may request information about our disclosures of certain categories of Personal Information to third parties for such third parties’ direct marketing purposes. California residents may make such requests to us at privacy@pashionfootwear.com. We will provide a list of the categories of Personal Information disclosed to such third parties for their direct marketing purposes during the immediately preceding calendar year, along with the names and addresses or these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the email specified in this section.
Do Not Track and GPC
We do not respond to browser Do Not Track (DNT) signals. For more information on DNT settings generally, please visit https://allaboutdnt.com. We will honor the Global Privacy Control signals where required by law.
Contact Us
If you have any questions regarding this California Privacy Notice, please contact Pashion at email: privacy@pashionfootwear.com.
Notice to Nevada Consumers
We do not sell your Personal Information within the scope of, and according to the defined meaning of a “sale” under, Nevada Revised Statutes Chapter 603A.
Mobile Advertising Terms of Service
The Pashion Footwear mobile message service (the "Mobile Service") is operated by Pashion. Your use of the Service constitutes your agreement to these terms and conditions (“Mobile Terms”). We may modify or cancel the Mobile Service or any of its features at any time, consistent with applicable law, and, if permitted, without notice to you. To the extent permitted by applicable law, we may also modify these Mobile Terms at any time and your continued use of the Mobile Service following the effective date of any such changes shall constitute your acceptance of such changes.
By consenting to receive SMS/text messages from us, you agree to receive recurring SMS/text messages from and on behalf of Pashion Footwear through your wireless provider to the mobile number you provided, even if your mobile number is registered on any state or federal Do Not Call list. Messages may be sent using an automatic telephone dialing system or other technology. Service-related messages may include order updates, account alerts, and other similar notifications. Promotional messages may include promotions, specials, and other marketing offers (e.g., cart reminders).
You understand that you do not have to sign up for the Mobile Service to make any purchases, and your consent is not a condition of any purchase with Pashion Footwear. Your participation in the Mobile Service is completely voluntary. We do not charge for the Service, but you are responsible for all charges and fees associated with text messaging imposed by your wireless provider. Message frequency varies. Message and data rates may apply. Check your mobile plan and contact your wireless provider for details. You are solely responsible for all charges related to SMS/text messages, including charges from your wireless provider.
You may opt-out of the Mobile Service at any time. Text the single keyword command STOP to 82602 or click the unsubscribe link (where available) in any text message to cancel. You'll receive a one-time opt-out confirmation text message. No further messages will be sent to your mobile device, unless initiated by you. If you have subscribed to other Pashion Footwear mobile message programs and wish to cancel, except where applicable law requires otherwise, you will need to opt out separately from those programs by following the instructions provided in their respective mobile terms.
For Service support or assistance, text HELP to 82602 or email info@pashionfootwear.com.
We may change any short code or telephone number we use to operate the Service at any time and will notify you of these changes. You acknowledge that any messages, including any STOP or HELP requests, you send to a short code or telephone number we have changed may not be received and we will not be responsible for honoring requests made in such messages.
The wireless carriers supported by the Service are not liable for delayed or undelivered messages. You agree to provide us with a valid mobile number. If you get a new mobile number, you will need to sign up for the program with your new number.
To the extent permitted by applicable law, you agree that we will not be liable for failed, delayed, or misdirected delivery of any information sent through the Service, any errors in such information, and/or any action you may or may not take in reliance on the information or Service.
We respect your right to privacy. To see how we collect and use your personal information, please see our Privacy Policy.
We will not share your opt-in to an SMS campaign with any third party for purposes unrelated to providing you with the services of that campaign. We may share your Personal Information, including your SMS opt-in or consent status, with third parties that help us provide our messaging services, including but not limited to platform providers, phone companies, and any other vendors who assist us in the delivery of text messages.
[ET1]Can they purchase anywhere other than the website?
[ET2]Is this intended to refer to our Websites? Or third party?
[ET3]This should be converted into a hyperlink
[ET4]Can you expand on what you mean by this? What activity is it describing and what third party tools are we using to gather this information?
[ET5]Nee link
[ET6]Nee link