Privacy Policy

Last modified: November 16, 2020  


JCB Ventures LLC d/b/a Sugarpak (“Sugarpak,” or “we”) is an online fashion retail company that designs, sources, markets, and sells women’s and men’s apparel, children’s clothing, and accessories (collectively, the “Products”). 

Sugarpak respects your privacy and is committed to protecting it through our compliance with this Privacy Policy. This Privacy Policy describes the types of information we may collect from you or that you may provide when you visit the website (the “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information. 

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use the Website. By accessing or using the Website, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Section 11. Changes to Our Privacy Policy). Your continued use of the Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates. 

Personal Information We Collect 

We collect personal information when you purchase our Products, browse our Website, create an account with us, or submit personal information when requested through the Website. Personal information generally is any information that relates to you, identifies you personally or could be used to identify you, such as your name, address, email, phone number, payment account, or credit card information. 

The types of personal information that we may collect about you include: 

Information You Provide to Us When Purchasing Products.  We collect your personal information that you give us when you purchase our Products. For example, if you visit our Website and place an order, we collect information that you provide to us during the ordering process. This information will include your first and last name, mailing address, email address, phone number, payment account or credit card information.  

Information You Post on the Website.  If you post information on public areas of the Website, for example a customer review, that information may be collected and used by Sugarpak, users of the Website, and the public generally. We strongly recommend that you do not post any information through the Website that allows strangers to identify or locate you or that you otherwise do not want to share with the public. 

Information Automatically Collected Through the Website.  We may automatically collect personal information about you when you use the Website. For example, if you access the Website through a computer, we will automatically collect information such as your browser type and version, computer and connection information, Internet Protocol (“IP”) address and standard web log information. We use technologies, such as cookies and web beacons (described below), to collect information about the pages you view, the links you click and other actions you take on our Website. 

Use of Cookies.  Our Website uses “cookies,” which are small text files placed on your hard disk by a Web server. Cookies contain information that can later be read by a Web server in the domain that issued the cookie to you.  One of the primary purposes of cookies is to store your preferences and other information on your computer in order to save you time by eliminating the need to repeatedly enter the same information and to display your personalized content and targeted advertising on your later visits to these sites. You have the ability to accept or decline cookies. If you choose to decline cookies, you may not be able to sign in or use other interactive features of our Website that depend on cookies, and some advertising preferences that are dependent on cookies may not be able to be respected.  By agreeing to accept our use of cookies, you are giving us, and third parties we partner with, permission to place, store, and access some or all the cookies described below on your computer: 

Strictly Necessary Cookies.  These cookies are necessary for proper functioning of the website, such as displaying content, logging in, validating your session, responding to your requests, and other functions. Most web browsers can be set to disable the use of cookies. However, if you disable these cookies, you may not be able to access features on our Website correctly or at all. 

Performance Cookies.  These cookies collect information about the use of the Website, such as pages visited, traffic sources, users’ interests, content management, and other website measurements. 
Functional Cookies.  These cookies enable the Website to remember a user’s choices such as their language, username, and other personal choices – while using the Website. They can also be used to deliver services, such as letting a user make a post, listen to audio, or watch videos on the Website. 
Media Cookies.  These cookies can be used to improve the Website’s performance and provide special features and content. They can be placed by third parties who provide services to us or by our company. 

Session Cookies.  These cookies allow the Website to link the actions of a user during a browser session. They may be used for a variety of purposes, such as remembering what a user has put in their shopping cart as they browse the Website. Session cookies also permit users to be recognized as they navigate the Website so that any item or page changes they make are remembered from page to page. Session cookies expire after a browser session; thus, they are not stored long term. 

Persistent Cookies.  These cookies are stored on a user’s device in between browser sessions, which allows the user’s preferences or actions across a site (or, in some cases, across different sites) to be remembered. Persistent cookies may be used for a variety of purposes, including remembering users’ choices and preferences when using a website or to target advertising to them. 

Use of Web Beacons. Our Website may contain electronic images known as Web beacons  sometimes called single-pixel gifs – that may be used to assist in delivering cookies on our sites and allow us to count users who have visited those pages. We may include Web beacons in promotional e-mail messages or our newsletters to determine whether messages have been opened and acted upon. We may also employ Web beacons from third parties to help us compile aggregated statistics regarding the effectiveness of our promotional campaigns or other operations of our website. We prohibit Web beacons on our sites from being used by third parties to collect or access your personal information. 

Google Analytics. On our Website we use Google Analytics, a web analysis service of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (“Google”). Google will analyze your use of our Website on our behalf. To this purpose we use, among others, the cookies described in more detail above. The information collected by Google in connection with your use of our Website (e.g. the referring URL, our webpages visited by you, your browser type, your language settings, your operating system, your screen resolution) will be transmitted to a server of Google in the US, where it will be stored and analyzed. The respective results will then be made available to us in anonymized form. Your usage data will not be connected to your full IP address during this process. We have activated on our Website the IP anonymizing function offered by Google, which will delete the last 8 digits (type IPv4) or the last 80 bits (type IPv6) of your IP address.  

You may revoke your consent to the use of Google Analytics at any time by installing a deactivation add-on for most current browsers that provides you with more control over what data Google can collect on websites you access. The add-on tells the JavaScript (ga.js) used by Google Analytics not to transmit any information about website visits to Google Analytics. You can find additional information on how to install the browser add-on referenced above here. 

Further information on Google Analytics is available in the Google Analytics Terms of Use, the Privacy and Data Protection Guidelines of Google Analytics, and in the Google Privacy Policy. 

How We Use Your Personal Information 

We will only use your personal information as described in this Privacy Policy or as disclosed to you prior to such processing taking place. 

To Deliver Products. We will use your personal information to deliver you the Products purchased through the Website. If the Products are to be delivered to you by a third party, such as our vendors or logistics partners for delivery, we may provide them with your personal information necessary for such deliveries, such as your name and your mailing address. All third parties that we work with are contractually obligated to protect your personal information as disclosed in this Privacy Policy. 

For Internal Use. We use your personal information for the purposes of furthering our business, including improving our Website’s content and functionality by analyzing where, on which types of devices and how our Website is used, how many visitors we receive, and where they click through to the Website from. We also use it to remember you in case you re-visit our Website, so we will know if you have already been served with surveys, or (where Website content is undergoing testing) which version of the content you were served. 

For Administrative Communications. We will send you administrative or account-related information to keep you updated about your account or orders. Such communications may include information about Privacy Policy updates, confirmations of your account actions or transactions, security updates or tips or other relevant transaction-related information. We process your contact information to send you such communications.  

For Customer Support. We collect any information that you provide to us when you contact us. Without your personal information, we cannot respond to you or ensure your continued use of our Website. 

To Enforce Compliance with Our Terms and Conditions. When you access our Website or purchase our Products, you are bound to our Terms and Conditions. To ensure you comply with them, we process your personal information by actively monitoring, investigating, preventing, and mitigating any alleged or actual prohibited, illicit or illegal activities on our Website. Subject to the applicable law, we may also process your personal information to: investigate, prevent or mitigate violations of our internal terms, agreements or policies and enforce our agreements with third parties and business partners. 

To Maintain Legal and Regulatory Compliance. Our Website and Products are subject to certain laws and regulations which may require us to process your personal information. For example, we process your personal information to pay our taxes, to fulfill our business obligations, ensure compliance with employment and recruitment laws or as necessary to manage risk as required under applicable law. Without processing your personal information for such purposes, we cannot operate the Website and sell our Products in accordance with legal and regulatory requirements. 

Sharing Your Personal Information 

Other than sharing your personal information so that you can browse our Website and purchase our Products, or as required or permitted by law, we do not share personal information about you with non-affiliated third parties. We may disclose your personal information as described below. 

Third Parties. We may share your personal information with third-party service providers acting on our behalf to deliver you our Products purchased through the Website. If the Products are to be delivered to you by a third party, such as our vendors or logistics partners for delivery, we may provide them with your personal information necessary for such deliveries, such as your name and your mailing address. All third parties that we work with are contractually obligated to protect your personal information as disclosed in this Privacy Policy. We also engage third party service providers that help us with support services such as credit card processing, website hosting, analytics services, conducting surveys and research, and performing network maintenance. These third parties can only use your data in accordance with our written agreements 

Processing Payments. Your payment information is collected by the Website in an encrypted form and is passed on to Sugarpak’s merchant services provider Stripe, Inc., 510 Townsend Street San Francisco, CA 94103 (“Stripe”) for purposes of obtaining payment between yourself and Sugarpak. Stripe only receives information necessary to verify that any payments between yourself and Sugarpak are authorized. Stripe will use encrypted tools to communicate with your bank, your credit card provider, PayPal, or whatever other account you use to pay for orders to the Sugarpak. Your credit card information or other payment information is not retained by the Sugarpak except as provided below. Sugarpak does not maintain records of your credit card number or other payment information, except that if your billing address is the same as your shipping address and you instruct the Website to enter the same billing address as your payment address, the Website will use your stored shipping address as your billing address. Stripe may receive requests from your bank, credit card provider, PayPal, or other payment provider to verify your transactions. Stripe may therefore periodically ask the Sugarpak to confirm certain of your order information, which Sugarpak will provide if the Sugarpak believes that an order has been placed by you. 

You should review Stripe’s privacy policy at: to understand how they process and retain your payment information. You can contact Stripe at:, or at  

Maintaining Legal and Regulatory Compliance. We have the right to disclose your personal information as required by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator or any other legal process served on Sugarpak. If there is a takeover, sale, or purchase of our business, we may disclose your personal information to the new (or prospective) owner of the business. 

Security of Your Personal Information   

We are committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. We have appropriate organizational safeguards and security measures in place to protect your data from being accidentally lost, used, or accessed in an unauthorized way, altered or disclosed. 

The communication between your browser and our Website uses a secure encrypted connection wherever your personal data is involved. We require any third party who is contracted to process your personal data on our behalf to have security measures in place to protect your data and to treat such data in accordance with the law. 

If a password is used to help protect your personal information, it is your responsibility to keep your password confidential. Do not share this information with anyone. If you are sharing a computer with anyone you should always log out before leaving a site or service to protect access to your information from subsequent users.  

Your Rights 

We take reasonable steps to ensure that your personal information is accurate, complete, and up to date. You have the right to access, correct, or delete the personal information that we collect, subject to certain exceptions. To protect the privacy and the security of your personal information, we may request data from you to enable us to confirm your identity and right to access such data, as well as to search for and provide you with the personal data we maintain. There may be instances where applicable laws or regulatory requirements allow or require us to refuse to provide or delete some or all of the personal information that we maintain. You may contact us to exercise your rights at 


We will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies. 

If you send us correspondence, including emails, we may retain such information electronically in the records of your account. We will also electronically retain customer service correspondence and other correspondence from Sugarpak to you. We retain these records to measure and improve our customer service and to investigate potential fraud and violations. We may, over time, delete these records as permitted by law. 

Sugarpak will also retain the Website usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Website, or we are legally obligated to retain this data for longer periods. 

Third-Party Websites 

Our Website may contain links to other websites. These websites are not under our control and are not subject to our Privacy Policy. These websites will likely have their own privacy policies. We have no responsibility for these websites, and we provide links to these websites solely for your convenience. You acknowledge that your use of and access to these websites are solely at your risk. It is your responsibility to check the privacy policies of these websites to see how they treat your personal data. 


Our Website is not directed to, and we do not knowingly collect personal information from, children under the age of 16. If you are under 16, please do not attempt to fill out our forms or send any personal information about yourself to us. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information from our files. 

Notice for California Residents 

Pursuant to the California Consumer Privacy Act (the “CCPA”), if you are a California resident, you have certain rights in relation to your personal information. These rights include: 

Right to Revoke Your Consent. You have the right to revoke your consent for us to use your personal information at any time. Such an opt-out will not affect disclosures otherwise permitted by law, including but not limited to: (i) disclosures to affiliates and business partners, (ii) disclosures to third-party service providers that provide certain services for our business, such as credit card processing, computer system services, shipping, data management services, (iii) disclosures to third parties as necessary to fulfill your requests, (iv) disclosures to governmental agencies or law enforcement departments, or as otherwise required to be made under applicable law, (v) previously completed disclosures to third parties, or (vi) disclosures to third parties in connection with subsequent contests or promotions you may choose to enter, or third-party offers you may choose to accept. If you want to revoke your consent for us to use your personal information, send us an email with your request at 

Right to Know. You have the right to request in writing: (i) a list of the categories of personal information, such as name, address, email address, that a business has disclosed to third parties during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (ii) the names and addresses of all such third parties. In addition, you have the right to request: (i) the categories of personal information we have collected about you, (ii) the categories of sources from which personal information is collected, (iii) the business or commercial purpose for the information collection, (iv) the categories of third parties with whom we have shared personal information, and (v) the specific pieces of personal information we hold about an individual. You have the right to request a copy of the specific personal information we collected about you during the 12 months before your request. 

Right Against Discrimination. You have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your right to know, delete or opt-out of sales. 

Changes to Our Privacy Policy 

We reserve the right to change this Privacy Policy at any time. If our company decides to change this Privacy Policy, we will post those changes on our Website so that our users and customers are always aware of what information we collect, use, and disclose. These changes will be effective immediately upon posting at [INSERT LINK]. Your continued use of our Website after any change to this Privacy Policy will constitute your acceptance of such change. 

Contacting Us 
If you have any questions or concerns about Sugarpak’s Privacy Policy, its implementation, or your personal information, please contact us via email at