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Privacy Policy - Posh Plum Consulting LLC

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This Privacy Policy (herein referred to as “Policy”) explains how Posh Plum Consulting LLC (herein referred to as the “Company,” “we,” “us,” or “our”) processes Personal Data that we collect from you (herein referred to as the “Subscriber”) as a Controller.

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DEFINITIONS

(a) “Controller” means the natural or legal person, public authority, agency, or other body, which alone or jointly with others, determines the purposes and means of processing Personal Data.

 

(b) “Personal Data” means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

 

(c) “Service(s)” means Consulting Services, Strategic Staffing Engagements, Ad Hoc Projects, Seasonal Bakery Services, etc.

(i) “Subscriber” means the natural or legal person who has subscribed to the Service(s) by agreeing to the Terms.

(ii) “Terms” means the binding contract between the Company and Subscriber that governs the Subscriber's access and use of the Service(s).

 

(d) "Seasonal Bakery Services" means the sale and delivery of handcrafted baked goods and other sweet items.

 

DATA COLLECTION

The Subscriber directly provides the Company with most of the data we collect. The Company collects Personal Data from the Subscriber from the following sources: 

  • Contact Request form

  • Free Consultation Booking Form (via Calendly)

  • Kibako Change Gauge tool (Lite & Full versions)

  • PMO Health Guide Access Form

  • Emails received at info@posh-plum.com and orders@posh-plum.com

  • ​Seasonal Bakery Services mailing list sign-up form

  • Online order forms for products

 

PROCESSING OF PERSONAL DATA

(a) The Company processes the Subscriber’s Personal Data for various purposes, including:

  • Engaging directly with Subscribers:

    • This includes scheduling and conducting free consultations (facilitated by Calendly), responding to contact requests, and delivering assessment reports.

  • Fulfilling and managing orders for Seasonal Bakery Services, including processing payments and arranging for hyperlocal delivery or pickup.

  • Sending marketing and promotional communications about our products, services, and seasonal offerings.

  • Analyzing the effectiveness of our online and offline marketing efforts.

  • Developing and improving our products, services, and marketing programs.

  • Assessing a subscriber's organization's readiness for change and providing a personalized assessment report (e.g., via the Kibako Change Gauge).

 

(b) The Company will generally collect Personal Data from Subscribers only where it needs to create a contract with the Subscriber, where the processing is in the Company’s legitimate interests and not overridden by the Subscriber’s data protection interests or fundamental rights and freedoms, or where the Company has the Subscriber’s consent. In some cases, the Company may also have a legal obligation to collect Personal Data from the Subscriber.

 

(c) If the Company processes Personal Data with the Subscriber’s consent, the Subscriber may withdraw their consent at any time.

 

SHARING OF PERSONAL DATA

(a) The Company may share the Subscriber’s Personal Data with its group companies and third-party service providers to offer our Service(s) and/or send information or updates about the Service(s).

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For certain functions, we use third-party service providers who act as Data Processors on our behalf, helping us deliver our services efficiently and securely. For these specific services, we act as the Data Controller, determining the purpose and means of processing your Personal Data.

 

  • Online Scheduling (Calendly): We use Calendly, an online scheduling platform, to manage bookings for our free consultations. When you book a consultation, Calendly collects your name, email address, and any other information you provide directly on the booking form. Calendly processes this data on our behalf to facilitate scheduling and send appointment confirmations. You can review Calendly's Privacy Notice [link to https://calendly.com/legal/privacy-notice] and learn about their security measures [link to https://calendly.com/security].

  • Intelligent Forms (Tally): We use Tally, a third-party service provider, to create, distribute, and collect responses from our intelligent forms, including the Kibako: Change Gauge (Lite and Full versions). Tally processes electronic identification data and form data on our behalf.

  • Online Store and Payments (Talech & Zelle): We use third-party platforms to process payments and manage online orders for our Seasonal Bakery Services, including local delivery and pickup arrangements. These providers collect your name, shipping address, payment information, and other details necessary to complete a transaction.

 

For each of these processors, we have appropriate data processing agreements (such as a Data Processing Addendum) in place to ensure your data is handled securely and in compliance with applicable data protection laws.

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(b) When the Company processes the Subscriber’s order, it may send the Subscriber’s Personal Data and use the resulting information from credit reference agencies to prevent fraudulent purchases.

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(c) The Company shares Personal Data in the following instances disclosure of information to law enforcement agencies or others if we are legally required to do so. In addition, certain statutory authorizations may allow us to disclose personal information in emergency situations. In conjunction with due diligence for or completion of a merger, reorganization, or sale to a third party of our company or a major portion of its assets, we may disclose, transfer, or sell the personal information collected through our website.

 

INTERNATIONAL DATA TRANSFERS

As Posh Plum Consulting LLC is based in the United States, and some of our third-party service providers (like Calendly and Tally) also operate globally or are based in the U.S., the Personal Data we collect may be transferred to and processed in the United States or other countries outside of your country of residence.

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If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, we ensure that such international transfers are protected by implementing appropriate safeguards, such as:

  • Relying on Data Privacy Frameworks (EU-US, UK Extension to EU-US, Swiss-US Data Privacy Framework) when applicable, which provide a mechanism for the transfer of personal data to organizations in the U.S. that have self-certified to the frameworks.

  • Implementing Standard Contractual Clauses (SCCs) approved by the European Commission, and where applicable, the UK Addendum, which are contractual commitments between the data exporter and data importer designed to safeguard personal data during transfer.

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By providing your Personal Data, you acknowledge and agree to such transfers as described in this Policy.

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YOUR DATA PROTECTION RIGHTS

As a Subscriber, you have certain rights regarding your Personal Data. We are committed to helping you exercise these rights. Depending on your location and applicable data protection laws, these rights may include:

  • The right to access: You have the right to request copies of your Personal Data that we hold.

  • The right to rectification: You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete information you believe is incomplete.

  • The right to erasure: You have the right to request that we erase your Personal Data, under certain conditions.

  • The right to restrict processing: You have the right to request that we restrict the processing of your Personal Data, under certain conditions.

  • The right to object to processing: You have the right to object to our processing of your Personal Data, under certain conditions (e.g., for direct marketing).

  • The right to data portability: You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

  • The right to withdraw consent: If we are relying on your consent to process your Personal Data, you have the right to withdraw that consent at any time.

 

To exercise any of these rights, please contact us at privacy@posh-plum.com. We will respond to your request within the timeframe required by applicable law.

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RETENTION OF PERSONAL DATA

(a) Company retains the Personal Data when an ongoing legitimate business requires retention of such Personal Data.

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(b) In the absence of a need to retain Personal Data, the Company will either delete or aggregate it. If this is not possible, the Company will securely store your Personal Data and isolate it from any further processing until it is deleted.

 

SECURITY OF PERSONAL DATA

The Company uses appropriate technical and organizational measures to protect the Personal Data it collects and processes. These measures are designed to provide a high level of security appropriate to the risk of processing the Subscriber’s Personal Data. If you are a Subscriber and have any concerns about the security of your Personal Data, please contact us immediately.

 

MODIFICATION

The Company keeps this Policy under regular review and may update this webpage at any time. This Policy may be amended at any time, and the Subscriber shall be notified only if there are material changes to this Policy.

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Last updated: September 22, 2025

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CONTACT DETAILS

If you have any concerns about this Policy, please get in touch with us at privacy@posh-plum.com.

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