Last updated: [09/06/2023]

This Privacy Policy ("Privacy Policy" or "Policy") explains how Phlur (The Center Brands LLC d/b/a Phlur) ("Phlur" or "we" or "our") collects personal information based on your online interactions with us, including when we offer, sell or ship products through our website (the "Service"). This Policy governs our collection and use of personal information and describes the rights you may have with respect to your personal information. By using the Website and otherwise interacting with us, you agree to our Terms of Service, including this Policy.

This Policy does not cover personal information we collect about employees, independent contractors or job applicants.

Notice at Collection: Personal Information We Collect

Personal identification information: name, email address, home or billing address, telephone number, customer number, account name and password, information related to customer reviews, IP address

Commercial and financial information: records of products ordered or considered; other purchasing or spending history; and payment information

Internet or other electronic activity information: your device and browser type, your browsing and search history on our website, and information about your interactions with our website and advertisements

We have collected the same categories of personal information in the 12 months prior to the date of this Privacy Policy.

Notice at Collection: Purposes for Collecting Personal Information

We collect your personal information to provide you with our products and fulfill customer orders; to contact you from time to time; to provide you with information about our business; for customer support; to provide advertising and marketing promotions and offers for products we think may interest you; to respond to your inquiries; to customize your experience; and to review and analyze the delivery and effectiveness of our advertising and other marketing campaigns.

We also use personal information to monitor or improve our website; conduct internal business analysis; prevent fraud, violations of our Terms of Service or other contracts, or illegal activity; and protect our rights and the rights and safety of our users or others.

For those who interact with us in a business capacity, we use your personal information to conduct business transactions with the entity you represent and to conduct marketing or due diligence to the entity you represent.

Notice at the time of collection: Categories of personal information we sell or share and related information

When we engage in digital advertising, we may sell the following categories of personal information (as defined broadly under certain state privacy laws) or we may share this information for cross-context behavioral advertising purposes: personal identifiers (IP addresses); and Internet or other electronic activity information.

These categories of personal information are sold or shared with advertising networks and other companies that provide digital advertising services for cross-context behavioral advertising. We engage in such sales and sharing to facilitate digital advertising to reach the people who are most likely to be interested in the services we offer. We allow third parties to place cookies or other tracking technologies on our website that may collect information about your online activities over time and across different websites or applications. For more information on the use of cookies and other tracking technologies, please see the “Our Use of Cookies and Analytics” section below.

To opt-out of the sale and sharing of such personal information, please see the “Do Not Sell/Share My Information” link in the footer.

We do not sell or share any other categories of personal information we collect for cross-context behavioral advertising.

Notice at Collection: Retention Period

We retain the categories of personal information we collect for as long as necessary to provide our services (including any warranty service) and to comply with legal obligations or protect our legal rights.

We collect personal information directly from our customers, website users, and representatives of entities with whom we do business or may do business. We also collect personal information from our advertising partners.

We do not use or disclose sensitive personal information to create profiles or for any purpose other than to provide our services.

Disclosures of Personal Information for a Business Purpose in the Past 12 Months

The following table describes the categories of personal information we disclosed to third parties for a business purpose in the 12 months prior to the date of this policy:

Categories of third parties to whom we disclose personal information for a business purpose

Personally Identifiable Information: Name, email address, home or billing address, phone number, customer number, information associated with customer reviews, IP address

Service providers who process payments, verify customer information, manage customer information and provide customer service (including through our call centers), facilitate email communications, provide security services and cloud-based data storage, host our website and assist with other IT-related functions, advertise and market our products, provide analytical information, and provide legal and accounting services.

Service providers who process payments, verify customer information, manage customer information and provide customer service (including through our call centres), provide security services and cloud-based data storage, host our website and assist with other IT-related functions, advertise and market our products, and provide analytical information

Commercial and Financial Information: records of products ordered or considered; other purchasing or spending history; and payment information

Service providers who process payments, verify customer information, manage customer information and provide customer service (including through our call centres), facilitate email communications, provide security services and cloud-based data storage, host our website and assist with other IT-related functions, advertise and market our products, provide analytical information, and provide accounting services

Internet or other electronic activity information: your device and browser type, your browsing and search history on our websites, and information about your interaction with our websites and advertisements. 

Service providers who provide security services and cloud-based data storage, host our website and assist with other IT-related functions, advertise and market our products, and provide analytical information.

We disclose the above categories of personal information to the categories of third parties identified above for the following purposes: managing customer, vendor, and supplier accounts and relationships; processing payments; verifying customer identities; fulfilling orders and transactions; engaging in advertising and marketing; operating our IT systems and protecting our systems; preventing fraud and other illegal activities; and obtaining professional advice on legal and accounting matters.

Additional Information About How We Disclose Personal Information and for Which We Disclose It

We may also share your personal information as required or permitted by law, including to law enforcement, judicial and regulatory agencies, to comply with a subpoena or similar legal process or governmental request, or when we believe in good faith that disclosure is required by law or is necessary to protect our rights and property or the rights, property or safety of others. We may also share your personal information with third parties to help detect and prevent fraud or data security breaches. And, we may share or transfer your personal information with third parties in the event of an actual or potential sale, merger, reorganization, or other reorganization of our entities.

We may use cookies, pixel tags, web beacons, and other similar tracking technologies (“Tracking Technologies”) to automatically collect information through our Sites. Tracking technologies are essentially small data files placed on your computer, tablet, mobile phone or other device to record certain information when you visit our website. We may use these tracking technologies to help identify violations, prevent fraudulent activity and improve security, while enabling you to save your preferences and helping us understand how you interact with our website.

We also allow third parties to use tracking technologies on our website for analytics and ad serving. These technologies help display ads, tailor ads to your interests, and assist in determining if you need help or are having trouble navigating our website. Some of these third parties use tracking technologies to collect information about your interactions with other websites and ads on the Internet in order to provide ads tailored to your interests, which may appear on our website or on other websites or platforms.

You can set your browser to notify you when you receive a cookie. Many web browsers also allow you to block cookies. You can disable cookies on your computer system by following the instructions on your browser or by visiting www.youradchoices.com.

We use Google Analytics to evaluate the use of our website. Google Analytics uses cookies and other identifiers to collect information such as how often users visit the website, the pages they visit when they do, and other websites they visited prior to coming to our website. For information about Google's privacy practices, please see the Google Privacy Policy: https://policies.google.com/privacy?hl=en-US#infocollect .

Our products and websites are not directed to minors under the age of 13, and we do not knowingly sell or share personal information of minors (including those under the age of 16) for behavioral advertising purposes.

"Do Not Track" ("DNT") is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals. [We honor the global privacy control signals [for California IP addresses]. 

We implement and maintain reasonable security measures appropriate to the nature of the personal information we collect, use, retain, transfer or otherwise process. However, there are no perfect security measures, and reasonable security measures are a process that involves risk management rather than risk elimination. While we strive to maintain a reasonable information security program, no program can be perfect; in other words, all risks cannot be reasonably eliminated. Data security incidents and breaches may occur due to factors that cannot be reasonably prevented. Therefore, we cannot assume that the occurrence of any particular incident or breach was caused by our failure to implement and maintain reasonable security measures.

We may review and update this Policy from time to time. If there are any changes, we will update the Privacy Policy and reflect the date of the changes above. If the changes are material, we will notify you by email or website notification.

We are committed to ensuring that our communication tools are accessible to people with disabilities. To make an accessibility-related request or report any barrier, please contact us at sevensangwei@outlook.com.

If you have any questions about this Privacy Policy or need a copy of this Privacy Policy in an alternative format, you can contact us at sevensangwei@outlook.com.

Some U.S. state laws give residents of that state specific rights regarding the collection of their personal information. See below for more information.

If you are a California resident, the California Consumer Privacy Act (“CCPA”) and other laws provide you with the following rights regarding your personal information:

You have the right to know what personal information we collect

You may request the following information about the personal information we collected about you in the 12 months prior to receiving your request:

The specific pieces of personal information we collected about you;

The categories of personal information we collected about you;

The categories of sources from which such personal information was collected;

The categories of personal information about consumers that a business sold or disclosed for a business purpose;

The categories of third parties to whom the personal information was sold or disclosed for a business purpose; and

The business or commercial purpose for collecting or selling your personal information.

You have the right to request deletion of your personal information that we collected

Upon your request, and subject to exceptions provided by law, we will delete your personal information that we collected. You may request deletion by following this link or by emailing sevensangwei@outlook.com.

You have the right to request correction of your personal information that we hold

You have the right to request that we correct personal information that we hold about you that you believe is inaccurate. We will take steps to determine the accuracy of the personal information you request to be corrected and consider all circumstances surrounding the personal information you identify as inaccurate in the process. We may ask you to provide documentation of your request for correction to assist us in evaluating the request.

You have the right to ask us not to sell or share your personal information that we collect

You have the right to opt out of the sale and sharing of personal information that we sell or share with third parties for cross-scenario behavioral advertising. You can do so by clicking on this link or by emailing sevensangwei@outlook.com.

California Civil Code Section 1798.83 (also known as the “Shine the Light” law) permits California residents to request, once a year and free of charge, information about the personal information disclosed to third parties for their direct marketing purposes in the preceding year, if any. You can make a request by clicking on this link or by emailing sevensangwei@outlook.com.

We will continue to treat you fairly if you exercise any of the rights described in this Privacy Policy. If you exercise your rights under this Privacy Policy, we will not deny you goods or services, charge you a different price or rate, or provide you with a different level or quality of goods or services than others.

To exercise your rights to access, delete, or correct your personal information, please visit this link or contact us at sevensangwei@outlook.com for consultation. For such requests, we will confirm receipt within 10 business days of receiving your request. We will then respond to your request as soon as possible (usually within 45 days of receiving your request). However, in some jurisdictions or specific circumstances, it may take us longer to process your request. If we anticipate that it will take longer than normal to process your request, we will let you know.

You can ask us not to sell your personal information or use it for cross-scenario behavioral advertising through the "Do Not Sell/Share My Information" link in the footer of the website. For such requests, we will implement them within 15 business days of receiving your request.

We will generally act on requests and provide information free of charge, but in some cases we may charge a reasonable fee to cover our administrative costs of providing the information. In some cases, the law may allow us to refuse to act on certain requests. In this case, we will try to explain to you why.

We will ask you to provide two pieces of personal information and try to match them with the information we hold about you.

If we cannot verify your identity with the required degree of certainty, we will not be able to respond to the request. We will notify you and explain the reasons for the refusal.

You may designate an agent to submit requests on your behalf. An agent may be a natural person or a business entity.

If you would like to designate an agent to act on your behalf, both you and the agent will need to follow our verification process:

Requests to Know, Delete or Correct Personal Information: If an agent submits a request, the agent will need to provide us with a signed authorization from you indicating that the agent is authorized to submit the request on your behalf. We will also ask you to verify your identity directly to us or confirm to us that you have authorized the agent to submit the request.

Requests to Opt Out of Sales or Sharing: If an agent submits a request to opt out of the sale of your personal information or the sharing of your personal information for cross-context behavioral marketing purposes, the agent will be required to provide us with your signed permission indicating that the agent is authorized to submit the opt-out request on your behalf.

Please note that this paragraph does not apply if the agent is authorized to act on your behalf pursuant to a valid power of attorney. Any such request will be processed in accordance with California law regarding powers of attorney.