Privacy Statement

Last Updated: 15th Feb. 2022

Posh Virtual Receptionists, LLC (“Posh”) takes the privacy of our customers and website visitors seriously. This privacy statement (“Privacy Statement”) outlines how we use and disclose information that we collect from you or about you when you use https://posh.com/ (the “Site”) or when you interact with us through the Posh virtual receptionist service (collectively with the Site, the “Services”). Before submitting Personal Information to us or using the Sites, please review this Privacy Statement carefully.

WHO WE ARE

When we collect and process your Personal Information in order provide our Services to other businesses (our “Clients”), we are a data processor acting on behalf of a data controller (i.e., our Client).

When we collect and process your Personal Information through your use of the Site and in your interactions with us in order to inquire about the Services and to receive our Services as our Client, we act as a data controller.

COLLECTION OF PERSONAL INFORMATION

For purposes of this Privacy Statement, “Personal Information” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household.

When we provide our Services to our Clients, we collect Personal Information about customers of our Clients (referred to as “Users”) on our Clients’ behalf. Such Personal Information could include Users’ names, contact information, account-related information (if applicable), and any other Personal Information Users provide to us. In our role as a service provider and processor, we collect, use, and disclose such Personal Information in order to provide our Services to our Clients and process such Personal Information in accordance with our Clients’ instructions.

We will treat Personal Information collected from third-party sources in accordance with this Privacy Statement but we are not responsible or liable for the accuracy of the information provided by third parties or for the third-party’s policies or practices.

The categories of Personal Information that we collect from you depend on your interactions with us. For example, we collect:

Information you provide directly to us:

  • Direct identifiers. When you inquire about our Services or request a trial of our Services, we collect your name, email address, and phone number. If you are a User, we also collect this information in order to provide our Services to our Clients.
  • Professional and Employment-Related information. When you inquire about our Services or request a trial of our Services, we collect information about your current employer.
  • Payment information. We collect payment information in order to process payments. We process payments through our third-party payment processor, Stripe.

Information we collect through your use of the Site:

  • Commercial information. When you purchase the Services, we collect your purchase history. If you are a User, we collect commercial information related to your interactions with our Client in order to provide our Services to our Client.
  • Device and Analytics information. When you visit and use the Site, we collect your IP address, browsing history, search history, which pages you visit on the Sites, other pages you visit on the Internet, and which browser you used to view the Sites. Please review the “Cookies and Other Technologies” section to learn more about our use of cookies and tracking technologies. We may collect this information to understand your use of the Site and to administer and improve our Site and Services.

Information we collect from third parties:

  • Social media information. When you interact with us through your social media accounts, we collect your [insert categories].

We do not as a practice collect Sensitive Data about our Clients or Users. “Sensitive Data” includes data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, and health data. If you choose to provide Sensitive Data to us, we will process it only with your consent and we will only store it for as long as we need it.

HOW WE USE YOUR PERSONAL INFORMATION

The table below explains how we use each category of personal information that we collect and our legal basis for each use. The legal bases we rely on include:

  • Performance of a contract. We process personal information as required or allowed under contracts, for example, to provide services to you or complete transactions.
  • Legitimate interests. We might have a business interest in using your personal information for certain justified purposes.
  • Compliance with a legal obligation. We might need to use your personal information to comply with legal requirements.
Purpose for using your information Legal basis for use Categories of personal information used
Fulfilling your request for a trial of our Services and providing our Services
  • Performance of a contract
  • Our legitimate interest in providing the Services to you
  • Direct identifiers
  • Professional and employment-related information
  • Payment information
Responding to inquiries about our Services
  • Performance of a contract
  • Our legitimate interest in providing the Services and related customer service
  • Direct identifiers
  • Professional and employment-related information
Improving our Services and your experience on the Site
  • Our legitimate interest in improving our Services
  • Device and Analytics information
Customizing your experience on our Site and administering our Site
  • Our legitimate interest in providing the Services to you
  • Device and Analytics information
Complying with our legal obligations and defend our rights or the rights of others
  • Compliance with legal obligations
  • Our legitimate interest in complying with our legal obligations
  • Direct identifiers
  • Professional and employment-related information
  • Commercial information
  • Device and analytics information

HOW WE DISCLOSE YOUR PERSONAL INFORMATION

We do not sell your Personal Information to third parties. We may share your Personal Information in the following circumstances:

Recipients Categories of personal information disclosed Purposes
Our Clients
  • Direct identifiers
  • Commercial information
If you are a User, we share and make your Personal Information available to the relevant Client as part of our Services to our Client. We also share your Personal Information in accordance with our Client’s instructions and requests.
Our service providers

(hosting providers, payment processing, customer service, shipping services, etc.)

  • Direct identifiers
  • Professional and employment-related information
  • Commercial information
  • Device and analytics information
  • Payment information
We share your Personal Information with our service providers in order to assist us with the administration and operation of the Services. Our policy is to inform our service providers not to use or disclose your Personal Information for any purpose other than for providing services to us.
Administrative, regulatory, or government agencies, judicial authorities
  • Direct identifiers
  • Professional and employment-related information
  • Commercial information
  • Device and analytics information
  • From time to time, we may be required to provide Personal Information to a Third Party in response to a court order, subpoena, government investigation, or as otherwise required by law or legal process.
  • We may share your Personal Information with Third Parties, such as law enforcement agencies, other government agencies, or health authorities (i) when we, in good faith, believe you or others are acting unlawfully, (ii) when we believe it is necessary or appropriate to satisfy any law, regulation or other governmental request, (iii) to operate our Services properly, (iv) to protect or defend our rights or the rights or well-being of our users, even without a subpoena, warrant or court order, or (v) we believe disclosure is necessary to protect the health and safety of our personnel, clients, and the general public.
Other third parties
  • Direct identifiers
  • Professional and employment-related information
  • Commercial information
  • Device and analytics information
  • We may, as a result of a sale, merger, consolidation, change in control, transfer of assets, reorganization or liquidation of our company (a “Reorganization Event”), transfer or assign your Personal Information to parties involved in the Reorganization Event. You acknowledge that such transfers may occur and are permitted by and subject to this Privacy Statement.

COOKIES AND OTHER TECHNOLOGIES

We may use “cookies” to keep, and sometimes track, information about you on our Sites. Cookies are small data files that are sent to your browser or related software from a Web server and stored on your computer’s hard drive. Cookies track where you travel on the Sites and what you look at. In doing so, a cookie may enable us to relate your use of the Sites to your Personal Information. Many other websites use cookies for very similar purposes.
Most Web browsers can be set to inform you when a cookie has been sent to you and provide you with the opportunity to refuse that cookie. Additionally, your Flash player can be set to reject or delete Flash cookies. Refusing a cookie will generally not interfere with your use of the Sites. However, refusal of a cookie may, in some cases, preclude you from using or negatively impact the display or function of the Sites or certain areas or features of the Sites.

We may also use web beacons (a.k.a. clear GIFs, web bugs or pixel tags) to personalize your experience on the Sites, to generate information about Site traffic and trends, and to verify your viewing and/or receipt of communications. Web beacons collect information automatically, such as the type of browser that you use and your IP address. Web beacons may be used alone or in conjunction with cookies. When web beacons are used with cookies, they may link this information to other Personal Information that you have provided to us. Web beacons usually are not visible to you.

For more information about how POSH uses cookies, please see our Cookie Policy.

“DO NOT TRACK” SIGNALS

Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many digital service operators, including Posh, do not recognize or respond to DNT signals.

YOUR DATA PRIVACY AND PROTECTION RIGHTS

Our Clients may afford Users with various data privacy and protection rights. If you are a User and make a request under any potential rights afforded to you, we will forward your request to the appropriate Client. Because we collect and handle your Personal Information at our Client’s requests, we do not process such requests without the relevant Client’s instruction. For example, if a User directly requests us to delete their Personal Information, we forward your request to the appropriate Client and will only delete such information upon the Client’s instruction.

NOTICE FOR EUROPEAN AND UNITED KINGDOM RESIDENTS

Transfers Outside of Europe and the United Kingdom

We are a global company with operations outside of Europe and the UK. While processing your Personal Information, we may transfer it to a country outside of Europe or the UK. If we transfer your information to countries outside of Europe or the UK, we will do so on a lawful basis, such as by using the Standard Contractual Clauses approved by the European Commission or the UK Information Commissioner’s Office.

Your Rights
If you are a European or United Kingdom resident and have provided Personal Information directly to us, you are entitled to certain privacy rights. As described in “Your Data Privacy and Protection Rights,” we will forward requests from European and United Kingdom Users to the appropriate Client and will process the requests in accordance with our Client’s instructions.

If you are not a User or our Client and have provided us with your Personal Information, you are entitled to the following privacy rights:

  • To request access to your Personal Information;
  • To request the rectification of your Personal Information;
  • To request the deletion of your Personal Information;
  • To request the restriction of the processing of your Personal Information, in certain circumstances;
  • To object to the processing of your Personal Information, in which case Posh will no longer process your Personal Information, and may not be able to provide you with the Services;
  • To request a copy of your Personal Information in a machine-readable format;
  • To lodge a complaint with a supervisory authority concerning our processing of your Personal Information.

You may exercise any of these rights by contacting us at uksupport@posh.com. If you choose to exercise any of these rights, Posh will not discriminate against you in any way. If you do exercise certain rights, understand that you may be unable to use or access certain features of the Services.

NOTICE FOR CALIFORNIA RESIDENTS

If you are a California resident and have provided Personal Information directly to us, you may be entitled to certain privacy rights. As described in “Your Data Privacy and Protection Rights,” we will forward requests from California Users to the appropriate Client and will process the requests in accordance with our Client’s instructions.

If you are not a User or our Client and have provided us with your Personal Information in your individual capacity (i.e., not in your role as an employee or other professional personnel for a company), you may be entitled to the following privacy rights:

  • The right to know and access the following information about our data collection practices in the last 12 months: (i) the categories of Personal Information we have collected about you; (ii) the categories of sources from which we have obtained your Personal Information; (iii) our business purposes for collecting your Personal Information; (iv) the categories of any third parties with whom we have shared your Personal Information; and (v) the specific pieces of Personal Information we have collected about you.
    • Within the preceding 12 months, Posh has collected the categories of Personal Information detailed in “Collection of Your Personal Information?” above.
    • Within the preceding 12 months, Posh has disclosed for a business purpose the categories of Personal Information detailed in “How We Disclose Your Personal Information” above.
  • The right to request deletion of your Personal Information.
  • The right to opt-out of sale of your Personal Information. But as we’ve stated above, we do not sell Personal Information.

You may exercise any of these rights by contacting us at uksupport@posh.com. If you choose to exercise any of these rights, Posh will not discriminate against you in any way. If you do exercise certain rights, understand that you may be unable to use or access certain features of the Services.

In addition, California residents are entitled to request and obtain from us once per calendar year information about any of your Personal Information shared with third parties for their own direct marketing purposes, including the categories of information and the names and addresses of those businesses with which we have shared such information. To request this information and for any other questions about our privacy practices and compliance with California law, please contact us at uksupport@posh.com.

SECURITY

We have implemented reasonable safeguards designed to protect your information from loss, misuse, alteration, or destruction. We also take reasonable steps designed to ensure that third parties who work with us agree to protect the Personal Information.

Even with these safeguards, we cannot guarantee the security of any information you transmit to us. Therefore, we urge you to keep your Personal Information in a safe place and to use caution when sending sensitive personal information to us.

RETENTION

We retain your Personal Information for as long as necessary for the purposes set out in this Privacy Policy, unless required by our legal obligations to retain it for longer. To determine the appropriate retention period for information, we consider the amount, nature and sensitivity of information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we process the information, whether we can achieve those purposes through other means, and all applicable legal requirements.

In particular:

  • the information we collect in order to provide Services to our Clients will be kept for as long as we provide the Services to you;
  • the information we collect to respond to your requests and inquiries will be kept until their complete processing.

We will also keep your Personal Information for:

  • the applicable statutes of limitation for evidence purposes; and
  • applicable legal retention periods, in particular regarding commercial and regulatory matters.

THIRD PARTY LINKS

This Site may contain links to other sites that are not owned or controlled by us. Please be aware that Posh is not responsible for the privacy practices of other such sites. We encourage our users to be aware when they leave our Site to read the privacy statements of each and every website that collects personally identifiable information. This Privacy Statement applies solely to information collected by Posh.

CHILDREN’S PRIVACY

We do not knowingly collect any Personal Information from children under 13 without prior verifiable parental consent. If Posh learns that a child under the age of 13 has submitted Personal Information without parental consent, we will take all reasonable measures to delete the information as soon as possible and to not use such information for any purpose, except where necessary to protect the safety of the child or others as required or allowed by law.

UPDATES TO THIS PRIVACY STATEMENT

We may occasionally update this Privacy Statement to reflect changes in our practices. When we post modifications to this Privacy Statement, we will revise the “Last Updated” date at the top of this web page. If the changes are material, we will post a notice on our Site along with the updated Privacy Statement. If you object to any modification, your sole recourse is to notify us that you do not agree and to stop using the Sites and providing us with your Personal Information.

QUESTIONS

If you have any questions or concerns or would like more information on the privacy policies of Posh Virtual Receptionists, LLC, please email uksupport@posh.com.