Privacy Policy

Effective as of May __ 2026.  

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This Privacy Policy describes how Posh Group, Inc. (“Posh,” “we,” “us” or “our”) processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including as applicable, our https://posh.vip/ website, mobile application, social media pages, marketing activities, live events and other activities described in this Privacy Policy (collectively, the “Service”)). Posh may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information.

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NOTICE TO EUROPEAN USERS: Please see the Notice to European Users section for additional information for individuals located in the European Economic Area or United Kingdom (which we refer to as “Europe”, and “European” should be understood accordingly) below.

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Index

Personal information we collect

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Personal Information you provide to us. Personal information you may provide to us through the Service or that we may generate about you includes:

  • Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, and phone number.
  • Demographic data, such as your city, state, country of residence, and postal code.
  • Profile data, such as the username and password that you may set to establish an online account on the Service, biographical details, photograph or picture, links to your profiles on social networks, interests, phone number, preferences, and any other information that you add to your account profile.  
  • Communications data based on our exchanges with you, including when you contact us through the Service, communicate with us via chat features, social media, or otherwise.
  • Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
  • Payment data, such as payment card information needed to complete transactions, which is collected by our payment processor, Stripe. Posh does not receive your payment card information.
  • Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order numbers and transaction history.
  • User-generated content data, such as photos, images, music, videos, comments, questions, messages, works of authorship, information about your attendance at events, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data.
  • Contacts data, with your opt-in consent, you may choose to provide the Service with access to your contacts.
  • Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Event Organizer data. In addition to the categories of personal information identified above, we, our service providers, and our business partners may collect personal information from individuals who choose to create events through the Service (each, an “Event Organizer”), such as:

  • Event data, such as information relating to or needed to complete your creation of an event, including the name of your event, the name and address of the venue where your event is hosted, features of your event, registered attendees of your event, and a description of your event.
  • Business details data, ssuch as your business website, industry, terms of service link, representative name and email address, date of birth, bank account number, and other information you provide in connection with organizing an event.
  • Government-issued identification number data, ssuch as national identification number (e.g., Social Security Number or tax identification number), which is collected by our payment processor, Stripe, if you choose to participate in our Event Organizer onboarding process.
  • Capital advance data, such as information you provide when you apply for and/or participate in Posh’s capital advance program, including information about you and/or your company, the capital advance you request, your stated income, economic standing, bank account numbers, or bank statements, which is collected by our financial partner, Plaid.

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Note that for certain processing activities the Event Organizer may be the controller of your personal information. We therefore encourage you to read the privacy policies of the Event Organizer. We do not control the Event Organizer’s websites, mobile applications or online services operated by the Event Organizer, and we are not responsible for their actions.

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Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

  • Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
  • Marketing partners, such as online behavioral advertising companies, social media platforms, data providers, joint marketing partners and event co-sponsors.
  • Business transaction partners. We may receive personal information in connection with an actual or prospective business transaction. For example, we may receive your personal information from an entity we acquire or are acquired by, a successor, or assignee or any party involved in a business transaction such as a merger, acquisition, sale of assets, or similar transaction, and/or in the context of an insolvency, bankruptcy, or receivership.
  • Other users, such as your friends or contacts who may use the Service to invite you to use the Service yourself by providing us with certain of your contact details. See the “Data about others” section below.
  • Third-party services, such as social media services, that you use to log into, or otherwise link to your Service account. This data may include your username, profile picture and other information associated with your account on that third-party service that is made available to us based on your account settings on that service. For example, we may receive your personal data through Google’s YouTube API Services if you choose to embed a YouTube video on the Service. You can learn more about Google’s privacy practices by reviewing the Privacy Policy at http://www.google.com/policies/privacy.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

  • Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
  • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
  • Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

For more information concerning our automatic collection of data, please see the Tracking technologies section below.

Data about others. We may offer features that allow you to invite your friends or contacts to use the Service, and we may collect contact details about these invitees from you so we can deliver their invitations. Please do not refer someone to us or share their contact details with us unless you have their consent to do so.

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Tracking Technologies


Cookies and other technologies. Some of the automatic collection described above is facilitated by cookies and other technologies. For more information, see our Cookie Notice. We will also store a record of your preferences in respect of the use of these technologies in connection with the Service.For information concerning your choices with respect to the use of tracking technologies, see the Your choices section of our Cookie Notice.
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How we use your personal information

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We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. We may use your personal information to:

  • provide, operate and improve the Service and our business;
  • personalize the Service, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Service;
  • establish and maintain your user profile on the Service;
  • facilitate your invitations to friends who you want to invite to join the Service;
  • facilitate social features of the Service, such as by identifying and suggesting connections with other users of the Service and providing chat or messaging functionality;
  • enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
  • communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
  • communicate with you about events or contests in which you participate;
  • understand your needs and interests, and personalize your experience with the Service and our communications; and
  • provide support for the Service, and respond to your requests, questions and feedback.

Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services. For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en.

Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business and to develop new products and services.

Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:

  • Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.  
  • Interest-based advertising. Our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) with the Service, our communications and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the Your choices section below.

Compliance and protection. We may use your personal information to:

  • comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
  • protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
  • audit our internal processes for compliance with legal and contractual requirements or our internal policies;
  • enforce the terms and conditions that govern the Service; and
  • prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.  

Data sharing in the context of corporate events, we may share certain personal information in the context of actual or prospective corporate events – for more information, see How we share your personal information, below.

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To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you.  We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business. For more information on analytics, see our Cookie Notice.

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With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

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Retention


We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as 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.   When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.
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How we share your personal information

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We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.  

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, online chat functionality providers, email delivery, consumer research and website analytics).

Payment processors. Any payment card information you use to make a purchase or to pay fees on the Service is collected and processed directly by our payment processors, such as Stripe. Stripe may use your payment data in accordance with its privacy policy, https://stripe.com/privacy. You may also sign up to be billed by your mobile communications provider, who may use your payment data in accordance with their privacy policies.

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Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above.

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Third parties designated by you. Third parties where you have instructed us or provided your consent to do so. For example, we may share your personal information with the Event Organizer, e.g.: to send you messages on an event you signed-up for or future events. Moreover, if you are an Event Organizer, we may share your personal information with the third-party venues, DJs, photographers, security teams, or other third parties that you have chosen to provide services for your event. We will share personal information that is needed for these other companies to provide the services that you have requested.

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Business and marketing partners. Third parties with whom we co-sponsor events, with whom we jointly offer products or services, or whose products or services may be of interest to you.

Linked third-party services. If you log into the Service with, or otherwise link your Service account to, a social media or other third-party service, we may share your personal information with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account with the third-party service.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.

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Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Posh, financing of Posh, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Posh as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

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Other registered users. Your user-generated content data is visible to other registered users of the Service. For example, other registered users of the Service may have access to your information if you chose to make your profile or other personal information available to them through the Service, such as when you provide comments or share other content. This information can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information. Additionally, if you choose to register for an event through the Service, your personal information may be provided to the Event Organizer of that event.

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Your choices

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In this section, we describe the rights and choices available to all users. Users who are located in Europe can find additional information about their rights below.

Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account.

Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.  

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If you choose to receive text messages from us, you may opt out of receiving further text messages from us by replying STOP to our message. You may also text STOP to 42302.

Cookies and other technologies. For information about cookies and other technologies employed by the Website-Service and how to control them, see our Cookie Notice.

Blocking images/clear gifs. Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.

Mobile location data. You can disable our access to your device’s precise geolocation in your mobile device settings.

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Privacy settings. If you have an account on the Service, you can control whether your profile is public and other settings by visiting “Privacy Settings” within your account.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

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Delete your content or close your account. You can choose to delete certain content through your account. If you wish to request to close your account, please contact us.

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Other sites and services


The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
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Security


We employ technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information.
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International data transfer


We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.  Users in Europe should read the important information provided below about transfer of personal information outside of Europe.
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Children


he Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a minor from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a minor without the consent of the minor’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.
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SMS Data


We do not share your SMS originator opt-in or consent status with any third parties for their own marketing or advertising purposes. We may share this data with the third-party service providers that help support our business, including but not limited to platform providers, phone companies, and other vendors that help us provide our messaging services.
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Changes to this Privacy Policy


We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.
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How to contact us

U.S State Privacy Rights Notice at Collection

Except as otherwise provided, this section applies to residents of California and other states to the extent they have privacy laws applicable to us that grant their residents the rights described below (collectively the “State Privacy Laws”).
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This State Privacy Rights Notice at Collection is part of our full Privacy Policy. This section describes how we collect, retain, use, disclose, sell and share for the purposes of targeted advertising personal information of residents of these states and the rights these users may have with respect to their personal information. Please note that not all rights listed below may be afforded to all individuals and that if your state does not afford you these rights, you may not be able to exercise these rights. In addition, we may not be able to process your access, correction or deletion request if you do not provide us with sufficient detail to allow us to confirm your identity and understand and respond to your request.For purposes of this section, the term “personal information” means information that relates to an identified or identifiable natural person, or that is reasonably capable of being used to identify, contact, or precisely locate a natural person, household, or a particular computing system or device. We do not attempt to reidentify deidentified information derived from personal information, except for the purpose of testing whether our deidentification processes comply with applicable law.

Your privacy rights. You may request to exercise the rights listed below. We will respond to your request in accordance with applicable law. We may decline to honor your request where an exception applies.

Exercising your right to know, access, correction, deletion, and appeal. You may submit requests at [link to webform], or via email to support@posh.vip.  

We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
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Exercising your right to opt-out of/revoke your consent to the “sale” of your personal information or “sharing” of your personal information for targeted advertising purposes.  You can submit requests to opt-out of targeted advertising and other sales of personal information here:  support@posh.vip, or by broadcasting the Global Privacy Control signal. For information about how to use the Global Privacy Control, please visit https://globalprivacycontrol.org/. These signals set your opt-out preferences only for the particular browser or device you are using and any consumer profile that we associate with that browser or device unless you are logged into your account, in which case we will honor the signal with respect to that browser or device and your account.
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Verification of Identity; Authorized agents. We may need to verify your identity to process your know, access, correction, deletion, or appeal requests and reserve the right to confirm your residency. We may need to request your first and last name, phone number, and email address, in order to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to reauthenticate yourself before disclosing or deleting your personal information. If you make a request to delete, we may ask you to confirm your request before we delete your personal information.

Under some State Privacy Laws, you may enable an authorized agent to make a request on your behalf. However, we may need to verify your authorized agent’s identity and authority to act on your behalf. Depending on the kind of request you have made, we may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that your request is authorized, such as by providing your agent with written and signed permission to exercise your State Privacy Law rights on your behalf, the information we request to verify your identity, or confirmation that you have given the authorized agent permission to submit the request.

Personal information that we collect, use and disclose. We have summarized the personal information we collect and may disclose, sell to or share with third parties by reference below to both the categories of personal information defined in the “Personal Information we collect,” “How we use your personal information,” and “How we share your personal information” sections of this Policy above and the categories of personal information specified in state law. This table describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below.

See our full Privacy Policy for descriptions of each entry in this table.

Personal Information (“PI”) we collect
California  statutory category of PI
Business / commercial purpose for PI collection
Categories of third parties to whom we “disclose” PI for a business purpose
Categories of third parties with whom we “share” PI for cross-context behavioral advertising purposes
Categories of third parties to whom we “sell” PI
Contact data
  • Identifiers
  • Customer records
  • Service delivery and operations
  • Direct Marketing
  • Interest-based advertising
  • Compliance and protection
  • Analytics
  • Corporate transactions
  • Affiliates
  • Service providers
  • Payment processors
  • Ad partners / networks
  • Social media platforms
  • Third parties designated by you
  • Professional advisors
  • Authorities
  • Counterparties and advisors / professionals in corporate transactions
  • Other users and the public
  • Event organizers
  • Ad partners / networks
  • Social media platforms
Demographic data
  • Customer records
  • Service delivery and operations
  • Research and development
  • Direct Marketing
  • Interest-based advertising
  • Compliance and protection
  • Analytics
  • Corporate transactions
  • Ad partners / networks
  • Social media platforms
Profile data
  • Identifiers
  • Customer records
  • Sensitive personal information
  • Internet activity
  • Service delivery and operations
  • Research and development
  • Direct Marketing
  • Interest-based advertising
  • Compliance and protection
  • Analytics
  • Corporate transactions
  • Ad partners / networks
  • Social media platforms
Transaction data
  • Comerical information
  • Internet activity
  • Service delivery and operations
  • Research and development
  • Direct Marketing
  • Interest-based advertising
  • Compliance and protection
  • Analytics
  • Corporate transactions
  • Ad partners / networks
  • Social media platforms
Payment data
  • Customer record
  • Service delivery and operations
  • Corporate transactions
Communication data
  • Commercial information
  • Internet activity
  • Service delivery and operations
  • Research and development
  • Direct Marketing
  • Interest-based advertising
  • Compliance and protection
  • Analytics
  • Corporate transactions
  • Ad partners / networks
  • Social media platforms
Marketing Data
  • Commercial information
  • Internet activity
  • Service delivery and operations
  • Direct Marketing
  • Interest-based advertising
  • Compliance and protection
  • Analytics
  • Corporate transactions
  • Ad partners / networks
  • Social media platforms
  • Event organizers
User Generated Content
  • Internet activity
  • Service delivery and operations
  • Research and development
  • Direct Marketing
  • Interest-based advertising
  • Compliance and protection
  • Analytics
  • Corporate transactions
  • Ad partners / networks
  • Social media platforms
Device data
  • Identifiers
  • Internet activity
  • Geolocation data
  • Service delivery and operations
  • Research and development
  • Direct Marketing
  • Interest-based advertising
  • Compliance and protection
  • Analytics
  • Corporate transactions
  • Ad partners / networks
  • Social media platforms
Location Data(approximate)
  • Geolocation data
  • Service delivery and operations
  • Research and development
  • Direct Marketing
  • Interest-based advertising
  • Compliance and protection
  • Analytics
  • Corporate transactions
  • Ad partners / networks
  • Social media platforms
Communication interaction data
  • Commercial information
  • Internet actovity
  • Service delivery and operations
  • Research and development
  • Direct Marketing
  • Interest-based advertising
  • Compliance and protection
  • Analytics
  • Corporate transactions
  • Ad partners / networks
  • Social media platforms
Online activity data
  • Commercial information
  • Internet activity
  • Service delivery and operations
  • Research and development
  • Direct Marketing
  • Interest-based advertising
  • Compliance and protection
  • Analytics
  • Corporate transactions
  • Ad partners / networks
  • Social media platforms
Tracking technology data
  • Identifiers
  • Internet activity
  • Service delivery and operations
  • Research and development
  • Direct Marketing
  • Interest-based advertising
  • Compliance and protection
  • Analytics
  • Corporate transactions
  • Ad partners / networks
  • Social media platforms
Sensitive Personal Information
  • Identifiers
  • Customer record
  • Precise location data
  • See section above called “Sensitive Personal Information”
Inferences from the above kinds of personal information
  • Inferences
  • Service delivery and operations
  • Research and development
  • Direct Marketing
  • Interest-based advertising
  • Compliance and protection
  • Analytics
  • Corporate transactions
  • Ad partners / networks
  • Social media platforms

Consumers under 18. We do not have actual knowledge that we have collected, sold, or shared the personal information of residents who are under 18 years of age.

Retention Period for Personal Information. We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, including Sensitive Personal Information, we may consider factors such as the length of time we have an ongoing relationship with you and provide services to you; 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; whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); whether retention is advisable in light of our legal position, such as in regard to applicable statutes of limitations, litigation or regulatory investigations; and applicable legal requirements. For example, we will retain your personal information for as long as you have an account with us or keep using our services, and the length of time thereafter during which we may have a legitimate need to reference your personal information to address issues that may arise. When we no longer require the personal information we have collected about you, we may either delete it or de-identify it.

Additional information for Connecticut residents. We do not collect, use, or sell personal data for the purpose of training large language models (“LLMs”).

Contact Us. If you have questions or concerns about our privacy policies or information practices, please contact us using the contact details set forth in the How to contact us section, above.
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Notice to European Users

General

Where this Notice to European users applies. The information provided in this “Notice to European users” section applies only to individuals in the United Kingdom and the European Economic Area (i.e., “Europe” as defined at the top of this Privacy Policy).

Personal information. References to “personal information” in this Privacy Policy should be understood to include a reference to “personal data” (as defined in the GDPR) – i.e., information about individuals from they are either directly identified or can be identified.  

Controller. Posh is the controller in respect of the processing of your personal information covered by this Privacy Policy for purposes of European data protection legislation (i.e., the EU GDPR and the so-called ‘UK GDPR’ (as and where applicable, the “GDPR”)). See the ‘How to contact us’ section above for our contact details.

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Our GDPR Representatives. We have appointed the following representatives in Europe as required by the GDPR – you can also contact them directly should you wish:

Our Representative in the EU. Our EU representative appointed under the EU GDPR is EDPO. You can contact them:
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Our Representative in the UK. Our UK representative appointed under the UK GDPR is EDPO. You can contact them:

  • By using EDPO’s online request form: https://edpo.com/gdpr-data-request/
  • By postal mail to: EDPO UK Ltd, Unit 33, Waterside, Schooner Court, 44-48 Wharf Road, London, N1 7UX, United Kingdom

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Our Data Protection Officer. We have appointed a “Data Protection Officer”, this is a person who is responsible for independently overseeing and advising us in relation to our compliance with the GDPR (including compliance with the practices described in this Website Privacy Policy). If you want to contact our Data Protection Officer directly, you can email: dpo@posh.vip.

Our legal bases for processing

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In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a “legal basis” for that use.

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Our legal bases for processing your personal information described in this Privacy Policy are listed below.

  • Where we need to perform a contract, we are about to enter into or have entered into with you (“Contractual Necessity”).
  • Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your personal information for is set out in the table below.
  • Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
  • Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).  

We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your personal information – for more information on these Purposes and the data types involved, see ‘How we use your personal information’

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Purpose
Categories of personal information involved
Legal basis
Service delivery and operations
  • Contact data
  • Demographic data
  • Profile data
  • Communications data
  • Marketing data
  • Payment data
  • Transactional data
  • User-generated content data
  • Contacts data
  • Other data
  • Event Organizer data
  • Data from Third Party Services
  • Device data
  • Device data
  • Online activity data
  • Contractual Necessity.
  • Legitimate Interests. We have a legitimate interest in administering and operating our business (including associated analysis, adaptation and improvement).  
Security
  • Contact data
  • Payment data
  • Transactional data
  • User-generated content data
  • Event Organizer data
  • Data from Third Party Services
  • Device data
  • Compliance with Law.
  • Legitimate Interests. We have a legitimate interest in ensuring the ongoing security and proper operation of our Service and associated IT services, systems, and networks.
Service improvement and analytics and Research and Development
  • Profile data
  • Communications data
  • Marketing data
  • User-generated content data
  • Contacts data
  • Data from Third Party Services
  • Device data
  • Online activity data
  • Legitimate Interests. We have a legitimate interest in providing you with a good service, which is personalised to you and that remembers your selections and preferences.
  • Consent, in respect of any optional cookies used for this purpose.
Direct marketing
  • Contact data
  • Demographic data
  • Profile data
  • Communications data
  • Event Organizer data
  • Marketing data
  • Legitimate Interests. We have a legitimate interest in promoting our operations and goals as an organisation and sending marketing communications for that purpose.
  • Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given marketing communications.
Interest-based advertising
  • Communications data
  • Marketing data
  • User-generated content data
  • Contacts data
  • Other data
  • Data from Third Party Services
  • Device data
  • Online activity data
  • Legitimate Interests. We have a legitimate interest in providing you with a good service which is personalized to you and that remembers your selections and preferences.
  • Consent. Applicable in respect of any optional processing relevant to such personalization (including processing directly associated with any optional cookies used for this purpose).
Compliance and protection
  • Any and all data types relevant in the circumstances
  • Compliance with Law.
  • Legitimate interest. Where Compliance with Law is not applicable, we and any relevant third parties have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. We and any relevant third parties may also have a legitimate interest of ensuring the protection, maintenance, and enforcement of our and their rights, property, and/or safety.
Further uses
  • Any and all data types relevant in the circumstances
  • The original legal basis relied upon, if the relevant further use is compatible with the initial purpose for which the Personal Information was collected.
  • Consent, if the relevant further use is not compatible with the initial purpose for which the personal information was collected.

Other info

No sensitive personal information. We ask that you not provide us with any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the services, or otherwise to us. If you provide us with any sensitive personal information to us when you use the services, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our services.

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No Automated Decision-Making and Profiling. As part of the Service, we do not engage in automated decision-making and/or profiling, which produces legal or similarly significant effects.

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Your rights

General. European data protection laws give you certain rights regarding your personal information. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:

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Exercising These Rights. You may submit these requests by email to support@posh.vip or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions.  

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Your Right to Lodge a Complaint with your Supervisory Authority. In addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.

The Information Commissioner’s Office

Water Lane, Wycliffe House

Wilmslow - Cheshire SK9 5AF

Tel. +44 303 123 1113

Website: https://ico.org.uk/make-a-complaint/

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Data Processing outside Europe  

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We may share your personal information with third parties who are based outside Europe.

Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it by implementing one of the following mechanisms:

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe. You may have the right to receive a copy of the appropriate safeguards under which your personal information is transferred by contacting us at support@posh.vip.

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