Privacy Policy

Effective Date:  [April 2024]

Welcome to Pashion Footwear Inc.’s (“Pashion,” “we,” “our” or “us”) Privacy Policy. We understand the importance of respecting your privacy, and we’re committed to protecting the personal information of our customers and site visitors.

Please read this Privacy Policy carefully and in conjunction with our Terms and Conditions, and ensure that you understand this Privacy Policy and such terms before you start to use our website or our services. This Privacy Policy does not apply to job applicants or Pashion personnel (see our Personnel Privacy Policy). By accessing and using our website or services, you acknowledge that you have read and understood the content of this Policy.  Accordingly, if you do not agree to the terms of this Policy, do not use our website or services.

We’ve kept this Privacy Policy as simple as possible, in order to let you know the how, why and what of our data collection practices when you visit any of our websites or buy our products. Note that in this Privacy Policy we use the term “personal information” interchangeably with the term “personal data.”

It also tells you about your privacy rights and how the law protects you.

To be clear, when we refer to our “websites” throughout this Privacy Policy, we mean the following: www.pashionfootwear.com or any other website that is or may become a part of our growing corporate family.

You may print a copy of this Privacy Policy by clicking here. If you have a disability, you may access this Privacy Policy in an alternative format by contacting us at privacy@pashionfootwear.com.

IF YOU ARE AN INDIVIDUAL LOCATED IN THE EEA OR THE U.K.: If you are an individual located in the European Economic Area (“EEA”) or the United Kingdom (“U.K.”), this entire Policy applies to you. However, please see the section titled EEA or U.K. Users below, which provides more information about which rights you have regarding the processing of your personal information.

IF YOU ARE CALIFORNIA RESIDENT: If you are a resident of California, this entire Privacy Policy applies to you. However, please see the section titled “Additional Information for California Residents” below, which will inform you in detail about our information collection practices and your specific rights.

IF YOU ARE A RESIDENT OF NEVADA: If you are a resident of Nevada, this entire Privacy Policy applies to you. However, please see the Section titled “Notice for Nevada Consumers” below, which will also apply to you. If you have any questions about our Privacy Policy, feel free to drop us a line at privacy@pashionfootwear.com. Thanks for reading!

Changes to this Privacy Policy

Pashion may need to update this Privacy Policy from time to time. If so, Pashion will post its updated Privacy Policy on our websites so Pashion encourages you to review this Privacy Policy regularly for any updates. If we make material changes, we may also send registered users of our services a notice that this Privacy Policy has been changed.. Your continued use of this website and/or services and/or your continued provision of personal data to us after the posting of such notice will be subject to the terms of the then-current Privacy Policy.

What Information Do We Collect?

Types of Data Collected

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). At Pashion, we collect a variety of information about our customers and visitors to the Pashion websites in order to provide a better customer experience. This personal data falls into these categories:

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 data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.

To provide better content and service, Pashion’s websites use 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/.

If we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

Pashion tracks your browsing habits across other third-party websites.

Sensitive Information

We do not (and do not want to) collect any sensitive data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and 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 data from children under the age of 16 through our websites. Pashion does not target its services or this website 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 Use Your Information

We use your information in a number of different ways. The tables below provide more detail, showing what we do with your information and why, but generally, we use your information for the following reasons:

• 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.

How Is Your Data Collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by phone or email. This includes personal data you provide when you:

• sign up to receive product information or offers;
• make inquiries or request information be sent to you;
• create an account on our websites;
• signup for our waitlist;
• order our products;
• ask for marketing or newsletters to be sent to you;
• contact customer services; or
• provide comments or reviews on our products

Automated technologies or interactions. As you interact with us via our websites, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may also collect Tracking Data when you use our websites, or when you click on one of our advertisements (including those shown on third party websites).

Third parties or publicly available sources. We may receive personal data about you from various types of third parties, including:

• Technical Data and/or Tracking Data from analytics providers, advertising networks and search information providers;
• any personal data you include in social media posts that tag us from social media plugin’s; and
• Contact, Financial, Tracking, Usage and Transaction Data from providers of website hosting provider services.

We will only use your personal data when the law allows us to.

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 to these email or home addresses. You may opt out of receiving this advertising by visiting https://app.retention.com/optout

Disclosing Your Personal Data

We may disclose your personal data with the third parties set out below as an essential part of being able to provide our services to you, as set out in this Privacy Policy:

• Companies that assist us in providing our services and getting your purchases to you, such as hosting service providers, payment service providers, and delivery companies;
• Professional service providers, such as auditors bankers, lawyers, accountants and insurers, marketing agencies, advertising partners and website hosts, who help us run our business;
• Governments, regulators, law enforcement and fraud prevention agencies, so we can help tackle and comply with law enforcement; and
• Companies approved by you, such as social media sites (if you choose to link your accounts to us).

For example, we disclose personal data with the following specific third parties:

• Shopify for hosting and order processing. Please visit their Privacy Policy to see how they use your personal data. By using our website you consent to allow Shopify to collect personal data about you and for us to provide personal data about you to Shopify.
• Eleets 3PL for warehousing of our products and shipping. Please visit their Privacy Policy to see how they use your personal data.
• Mailchimp for sending our newsletters and marketing. Please visit their Privacy Policy to see how they use your personal data.

We also disclose data with third parties connected to advertising, retargeting and analytics. Please see the Cookies section below, including the cookie list, for more information about who those third parties are.

We may disclose data with third parties to whom we choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We may also disclose your personal data if the law otherwise allows it.

Social Media

Pashion maintains an online presence on social media platforms (“Social Media Platforms”) such as Instagram, Facebook, YouTube, TikTok, X (formerly Twitter) or Pinterest, to provide information about our services and communicate with users and/or visitors to those pages or accounts. When you interact or post to our account, we process your personal information. In some cases, the Social Media Platforms are service providers or processors. In other cases, such as Facebook, we are jointly responsible for the processing, as explained in the section titled Facebook.

Payment Information

Pashion uses third-party payment processors, such as Shopify, 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. 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.

If you see Pashion’s advertisements on websites and in social media, 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 with a certain team’s logos.

We also work with partners 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 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 below.

Cookies

You can see from the Advertising, Marketing and Your Communication Preferences section above that cookies are a tool that we – and everyone one else who operates online – use for advertising. However, advertising is just one of the many reasons why cookies are used, and as you can see below, there are different types of cookies.

Strictly Functional Cookies

First and foremost, cookies help our websites work better. They help us work behind the scenes to make your customer experience a lot 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 websites, and measure how well the websites work – like whether a visitor gets an error message from our web pages. These cookies don't collect information that identifies a visitor. All of the information that these types of cookies collect is aggregated and used to improve how our websites work.

Advertising Cookies

And of course, there are cookies that collect information about your browsing habits in order 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 one of our websites, you might see some shoes that you previously looked at on our websites. This includes 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. You may opt out of these advertising cookies by accessing the cookie settings, [clicking here] or by contacting us.  

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.

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 the 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, see 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 can also set your browser to refuse all or some browser cookies, or 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.

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 Websites”). Such links do not constitute an endorsement by Pashion of those External Websites, and Pashion is providing these links to you only as a convenience. We are not responsible for the content of those External Websites, and your use of External Websites 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 appropriate security measures designed to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.

We will only keep your personal data for as long as necessary to fulfil the purposes for which we collected it in the first place, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data 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), generally for seven years after a transaction for tax purposes.
In some circumstances you can ask us to delete your data; see Your Legal Rights below for further information.

International Transfers

The information you enter on the website or otherwise provide to Pashion may be transferred and processed outside of the European Economic Area to the United States of America, which does not offer an equivalent level of protection to that of the European Union. The European Union's General Data Protection Regulation (“GDPR”) allows for transfer of personal data from the European Union to a third country in certain situations. By agreeing to the terms of use and this Privacy Policy, you agree to the transfer of all such information to the United States of America and to the processing of that information by Pashion on servers located in the United States of America as described in this Privacy Policy. We may adopt other means, such as entering into Standard Contractual Clauses, and other lawful methods available to us under applicable law, or enter into different certification programs such as the Data Privacy Framework under applicable law, in order to ensure adequate safeguards under the GDPR. 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 because you are in the European Economic Area, you have certain rights in relation to your personal data:

• The right to be informed – that’s an obligation on us to inform you how we use your personal data (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 data we hold about you;
• The right to rectification – that’s a right to make us correct personal data 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 data 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 data;
• The right to data portability – that’s a right for you to ask us for a copy of your personal data 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 data (for example, if you object to us processing your data 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 data (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 data (or to exercise any of your other rights). This is a security measure to ensure that personal data 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.

Facebook

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 data 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 in order 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 data 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 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 in order 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].

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.

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 behavorial 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, [clicking here] 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 may tracks users’ use of our website or services, but do not track users across third-party websites. We will 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 signal.

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.