PRIVACY POLICY
Last updated 09/03/2023

Protecting your private information is our priority. This Statement of Privacy applies to www.palush.com and Pälùsh, LLC and governs data collection and usage. For the purposes of this Privacy Policy, unless otherwise noted, all references to Pälùsh, LLC including www.palush.com and Pälùsh; as well as, (“we,” “us,” or “our“), describes how and why we might collect, store, use, and/or share (“process“) your information when you use our services (“Services“). The Pälùsh website is an eCommerce site. By using the Pälùsh website, you consent to the data practices described in this statement.
Controller of Data
Pälùsh, LLC (or “Pälùsh”) is the controller of personal information we process, unless otherwise stated. To better understand on how your personal information is used, please refer to the privacy policy.
Data Protection Officer
The Data Protection Officer (DPO) for Pälùsh, LLC is Nick Desmond. He can be reached by contacting us anytime by submitting a message via our contact us.
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.
What personal information do we process?
When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.
Do we process any sensitive personal information?
We do not process sensitive personal information.
Do we receive any information from third parties?
We may receive information from public databases, marketing partners, social media platforms, and other outside sources. Learn more about information collected from other sources.
How do we process your information?
We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.
In what situations and with which parties do we share personal information?
We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.
What are your rights?
Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.
How do you exercise your rights?
The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.
Want to learn more about what we do with any information we collect? Review the privacy in full notice.
TABLE OF CONTENTS
- WHAT INFORMATION DO WE COLLECT?
- HOW DO WE PROCESS YOUR INFORMATION?
- WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
- DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
- HOW DO WE HANDLE YOUR SOCIAL LOGINS?
- IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
- HOW LONG DO WE KEEP YOUR INFORMATION?
- DO WE COLLECT INFORMATION FROM MINORS?
- WHAT ARE YOUR PRIVACY RIGHTS?
- CONTROLS FOR DO-NOT-TRACK FEATURES
- DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
- DO WE MAKE UPDATES TO THIS NOTICE?
- HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
- HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
In order to better provide you with products and services offered on our Site, Pälùsh may collect personally identifiable information, such as your:
– First and Last Name
– Mailing Address
– E-mail Address
– Phone Number
– Usernames
If you purchase Pälùsh’s products and services, we collect billing and credit card information. This information is used to complete the purchase transaction.
We do not collect any personal information about you unless you voluntarily provide it to us. However, you may be required to provide certain personal information to us when you elect to use certain products or services available on the Site. These may include: (a) registering for an account on our Site; (b) entering a sweepstakes or contest sponsored by us or one of our partners; (c) signing up for special offers from selected third parties; (d) sending us an email message; (e) submitting your credit card or other payment information when ordering and purchasing products and services on our Site. To wit, we will use your information for, but not limited to, communicating with you in relation to services and/or products you have requested from us. We also may gather additional personal or non-personal information in the future.
Sensitive Information.
We do not process sensitive information. All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Please keep in mind that if you directly disclose personally identifiable information or personally sensitive data through Pälùsh’s public message boards, this information may be collected and used by others.
Information automatically collected
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
Links
This website contains links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information.
2. HOW DO WE PROCESS YOUR INFORMATION?
Pälùsh collects and uses your personal information to operate its website(s) and deliver the services you have requested. We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. Pälùsh may also use your personally identifiable information to inform you of other products or services available from Pälùsh and its affiliates.
We process your personal information for a variety of reasons, depending on how you interact with our Services.
Security of your Personal Information
Pälùsh secures your personal information from unauthorized access, use, or disclosure. Pälùsh uses the following methods for this purpose:
– SSL Protocol
When personal information (such as a credit card number) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Sockets Layer (SSL) protocol.
We strive to take appropriate security measures to protect against unauthorized access to or alteration of your personal information. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, you acknowledge that: (a) there are security and privacy limitations inherent to the Internet which are beyond our control; and (b) security, integrity, and privacy of any and all information and data exchanged between you and us through this Site cannot be guaranteed.
3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
Pälùsh may share data with trusted partners to help perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from using your personal information except to provide these services to Pälùsh, and they are required to maintain the confidentiality of your information.
We may need to share your personal information in the following situations:
- Business Transfers
We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- Affiliates
We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
- Business Partners
We may share your information with our business partners to offer you certain products, services, or promotions.
Pälùsh may disclose your personal information, without notice, if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on Pälùsh or the site; (b) protect and defend the rights or property of Pälùsh; and/or (c) act under exigent circumstances to protect the personal safety of users of Pälùsh, or the public.
Pälùsh does not sell, rent or lease its customer lists to third parties.
4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.
Tracking User Behavior
Pälùsh may keep track of the websites and pages our users visit within Pälùsh, in order to determine what Pälùsh services are the most popular. This data is used to deliver customized content and advertising within Pälùsh to customers whose behavior indicates that they are interested in a particular subject area.
Automatically Collected Information
Information about your computer hardware and software may be automatically collected by Pälùsh. This information can include: your IP address, browser type, domain names, access times and referring website addresses. This information is used for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the Pälùsh website.
The Pälùsh website may use “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.
Google Privacy Policy
This website utilizes Google Analytics to get aggregate metrics on website usage. Pälùsh also utilizes Google reCaptcha on all contact forms and login/registration forms. Please refer to the following policies on Google’s website for more information:
- Google’s Privacy Policy
- Google Privacy Control
- Cookies & Google Analytics on Websites
- Opt out of Google Analytics Cookies
Use of Cookies
The Pälùsh website may use “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.
One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize Pälùsh pages, or register with Pälùsh site or services, a cookie helps Pälùsh to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same Pälùsh website, the information you previously provided can be retrieved, so you can easily use the Pälùsh features that you customized.
You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Pälùsh services or websites you visit. For specific information about how we use such technologies and how you can refuse certain cookies is set out in our cookie policy.
5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.
We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.
6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
Our servers are located in the United States of America (U.S.). If you are accessing our Services from outside, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?” above), in and other countries.
If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.
7. HOW LONG DO WE KEEP YOUR INFORMATION?
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
8. DO WE COLLECT INFORMATION FROM MINORS?
Children Under Thirteen
Pälùsh, LLC does not knowingly collect personally identifiable information from children under the age of thirteen. If you are under the age of thirteen, you are not authorized to use this website and the services we provide. If Pälùsh, LLC learns that a child under the age of thirteen has submitted personally identifiable information online, it will take reasonable measures to delete such information from its databases and to not use such information (except where necessary to protect the safety of the child or other as required or allowed by law). If you become aware of any personal information we have collected from children under thirteen, please contact us.
Children Under Eighteen
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us.
9. WHAT ARE YOUR PRIVACY RIGHTS?
Withdrawing your consent
If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Account Information
If you would at any time like to review or change the information in your account or terminate your account, you can:
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
E-mail Communications
From time to time, Pälùsh may contact you via email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication.
CAN-SPAM Act
The CAN-SPAM Act is a United States law that dictates a range of requirements for emails and other messages from commercial entities, like businesses, marketers, and nonprofit organizations. Emails subject to the law must follow rules regarding subject lines, disclosures, and headers. Further, the law establishes the right of recipients to request removal from email lists.
In accordance with the CAN-SPAM Act, if you would like to stop receiving marketing or promotional communications via email from Pälùsh, you may opt out of such communications by “replying STOP” or “clicking on the UNSUBSCRIBE button.” In addition to those methods, customers can also contact Pälùsh to be taken off the subscriber list.
10. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
If you are a resident of California, you are granted specific rights regarding access to your personal information.
California Consumer Privacy Act (CCPA)
The California Consumer Privacy Act (CCPA) is a state statute intended to enhance privacy rights and consumer protection for residents of California, United States.
Intentions of the Act
The intentions of the Act are to provide California residents with the right to:
- Know what personal data is being collected about them.
- Know whether their personal data is sold or disclosed and to whom.
- Say no to the sale of personal data.
- Access their personal data.
- Request a business to delete any personal information about a consumer collected from that consumer.
- Not be discriminated against for exercising their privacy rights.
If you live in California and have an established business relationship with Pälùsh, LLC, you can request a list of the personal information we have shared with third parties for their direct marketing purposes. We will also give you a list of the third parties that have received your information. You can make a request one time each year by contacting us. Please mention in your email that you are making a “California Shine the Light” inquiry. We will respond within 30 days.
Do Not Sell My Personal Information
Pälùsh, LLC does not sell any of our customers personal information. However, to be in accordance with the CCPA, you can request that your personal information not be sold. For further information, visit Do Not Sell My Personal Information.
California Civil Code Section 1798.83 – Shine The Light Law
The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. Pälùsh, LLC does not share your personal information with third parties for their own direct marketing purposes.
If you are a California resident, or an authorized agent acting on behalf of a California resident, and would like to exercise one of these rights, please visit our contact page to send an email. Please note that we may require additional information from you or the authorized agent acting on your behalf in order to fulfill your request, and there may be circumstances where we will not honor your request, as permitted under the CCPA.
To help protect your privacy and maintain security, we at Pälùsh, LLC will take steps to verify your identity before granting you access to your personal information or complying with your request. These steps will include requiring you to verify personal information, website account login information, and/or other additional steps to help maintain a secure and valid request.
12. DO WE MAKE UPDATES TO THIS NOTICE?
Pälùsh reserves the right to change this Privacy Policy from time to time. We will notify you about significant changes in the way we treat personal information by sending a notice to the primary email address specified in your account, by placing a prominent notice on our site, and/or by updating any privacy information on this page. Your continued use of the Site and/or Services available through this Site after such modifications will constitute your: (a) acknowledgment of the modified Privacy Policy; and (b) agreement to abide and be bound by that Policy.
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may contact us.
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please fill out and submit a data subject access request.
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us.