Privacy Policy

Introduction

Freshine (“we,” “us,” “our,” or “Freshine”) respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website at freshinelife.com, use our custom curtain design and ordering services, or interact with us in any way (collectively, the “Services”).

Our Business: Freshine provides custom curtain design and online sales services from our U.S. showroom located at 43 Corporate Park #208, Irvine, CA 92606, United States.

Data Minimization Commitment: We limit our collection of personal information to what is adequate, relevant, and reasonably necessary for the purposes described in this Privacy Policy. We do not collect personal data beyond what is needed to provide and improve our Services.

1. Information We Collect

1.1 Categories of Personal Information

We collect the following categories of personal information:

Category	Examples
Personal Identifiers	Name, email address, phone number, billing address, shipping address, IP address, online identifiers, account username and password
Commercial Information	Purchase history, products viewed, items added to cart, order details, payment information (processed by secure third-party payment processors)
Custom Order Information	Window measurements, fabric preferences, design specifications, room dimensions, installation requirements
Communications Data	Email correspondence, chat transcripts (including AI chatbot interactions), SMS messages, customer service call recordings (only with your explicit consent)
Internet or Network Activity	Browsing history, search queries, clickstream data, referring URLs, time spent on pages, browser type, device type, operating system
Geolocation Data	General location derived from IP address
Audio/Visual Information	Recorded customer service calls (only with your explicit prior consent)
Inferences	Preferences, interests, and characteristics derived from your interactions with our Services, including product recommendations generated by our systems

1.2 How We Collect Information

Information You Provide Directly:
We collect personal information you voluntarily provide when you create an account, place an order for custom curtains, contact us via email, phone, chat, or SMS, provide window measurements and design preferences, participate in surveys or promotions, or subscribe to our marketing communications.

Information Collected Automatically:
When you visit or interact with our website, we automatically collect information through cookies and similar tracking technologies, third-party analytics and advertising tools, and server logs and error reports.

Information from Third Parties:
We may receive information about you from payment processors (for transaction verification), shipping carriers (for delivery confirmation), analytics providers, advertising and social media platforms, and business partners.

1.3 Sensitive Personal Information

We may collect the following categories of sensitive personal information: account login credentials (username and password combinations) and payment-related information (credit or debit card numbers combined with required security codes). We collect and use sensitive personal information only as reasonably necessary to provide our Services, process transactions, maintain account security, and comply with applicable law. We do not use or disclose sensitive personal information for purposes beyond those permitted under applicable law.

In accordance with the Maryland Online Data Privacy Act (MODPA), we do not sell sensitive personal information under any circumstances, regardless of consumer consent.

2. How We Use Your Information

2.1 Primary Purposes

We use your personal information for the following business purposes:

To Provide Our Services: Process and fulfill your custom curtain orders, create personalized curtain designs based on your specifications, communicate with you about your orders, measurements, and design choices (including via our AI-powered chatbot), arrange shipping and delivery, and provide customer support and respond to inquiries.

To Improve Our Services: Analyze usage patterns to enhance user experience, develop new products and features, conduct quality assurance and testing, and troubleshoot technical issues.

For Marketing and Communications: Send promotional emails about new products, special offers, and design tips, send SMS messages about order updates, abandoned cart reminders, and promotions (with your consent), personalize content and product recommendations, and measure the effectiveness of our marketing campaigns.

For Security and Legal Compliance: Verify your identity and prevent fraud, protect against unauthorized access and security breaches, comply with legal obligations and respond to lawful requests, and enforce our Terms of Service and other agreements.

2.2 Automated Decision-Making Technology (ADMT)

In compliance with the California Privacy Rights Act (CPRA) regulations effective January 1, 2026, we disclose the following:

AI-Powered Chatbot: We use an AI-powered chatbot to assist with customer inquiries, provide product recommendations, and answer frequently asked questions. The chatbot processes your messages and account information to generate responses. You may request to speak with a human representative at any time.

Product Recommendations: We use algorithmic systems to suggest curtain products, fabrics, and designs based on your browsing history, past purchases, and stated preferences. These recommendations are intended to enhance your shopping experience and do not produce legal or similarly significant effects.

Your ADMT Rights:

You have the right to opt out of automated decision-making technology that produces legal or similarly significant effects
You have the right to request information about our use of ADMT
You may request human review of any significant decision made by automated means
To exercise these rights, contact us at support@freshinelife.com

2.3 SMS and Email Marketing

SMS Marketing:
By providing your phone number and opting in, you consent to receive recurring automated text messages from Freshine, including order confirmations and shipping updates, abandoned cart reminders, promotional offers and new product announcements, and review requests.

Message Frequency: Varies based on your interactions with us.
Message and Data Rates: May apply based on your carrier plan.
Opt-Out: Reply STOP to any message to unsubscribe. Reply HELP for assistance.

Email Marketing:
We may send you promotional emails about our products, design inspiration, and special offers. You can unsubscribe at any time by clicking the unsubscribe link in our emails.

Important: We will never share your opt-in data or consent for SMS/email marketing with third parties for their own marketing purposes. Even if you opt out of marketing communications, we may still send you service-related messages such as order confirmations or customer support responses.

3. Custom Curtain Order Information

3.1 Measurement and Design Data

When you order custom curtains from Freshine, we collect detailed information to create your personalized products, including window measurements (width, height, depth, and other dimensional specifications), design preferences (fabric type, color, pattern, style such as grommet, rod pocket, etc.), room specifications (room type, lighting conditions, decor style), and installation details (mounting preferences, hardware requirements).

3.2 How We Use Custom Order Data

We use this data to manufacture curtains that fit your specific windows, provide design recommendations and guidance, maintain records for warranty and reorder purposes, and improve our product offerings based on customer preferences.

3.3 Data Retention for Custom Orders

We retain your custom order information for the following periods: active orders for the duration of order processing plus 7 years for tax and accounting purposes, design specifications for up to 3 years to facilitate reorders and warranty claims, and measurements for up to 2 years unless you request deletion.

4. Recorded Communications

4.1 Customer Service Call Recordings

Freshine may record customer service phone calls for quality assurance, training, dispute resolution, and legal compliance purposes.

IMPORTANT — Consent Requirement:

Call Recording:

When you contact our customer service by phone, please be aware that the call may be monitored or recorded for quality assurance, training, and security purposes. By continuing the conversation, you consent to such recording.

Because Freshine operates from California, which is an all-party consent state, and because we serve customers across the United States (including other all-party consent states such as Connecticut, Florida, Illinois, Maryland, Massachusetts, Montana, New Hampshire, Pennsylvania, and Washington), we follow the strictest consent standard:

Before any recording begins, an automated message will clearly inform you that the call may be recorded for quality assurance, training, and dispute resolution purposes
By remaining on the line after hearing the recording notice, you are providing your consent to the recording of the call. If you do not wish to be recorded, you may disconnect the call at that point
If you do not consent to recording, you may hang up and contact us through alternative channels (email at support@freshinelife.com or live chat on our website) where calls are not recorded. Your decision to decline recording will not affect the quality or availability of our services through these alternative channels
Your consent is documented by our phone system as part of our records

Recommendation: For your maximum protection under state law, we strongly recommend that you verbally confirm your consent when prompted. If at any point during the call you wish to stop the recording, please inform the representative and we will accommodate your request.

Use of Recordings: Recordings are used for quality assurance and customer service training, resolving disputes or misunderstandings, documenting order details and customer preferences, and legal compliance and protection.

Retention: Call recordings are retained for 90 days unless required for legal or dispute resolution purposes, after which they are securely deleted.

4.2 AI Chatbot Interactions

Our AI-powered chatbot collects and processes your messages, questions, and any information you provide during chat sessions. These chat transcripts are retained for customer service improvement, training, and quality assurance purposes. You may request deletion of your chat transcripts at any time by contacting us at support@freshinelife.com.

4.3 Email Communications

We retain email correspondence for customer service purposes. These communications may be reviewed to resolve customer issues, improve our services, train customer service representatives, and comply with legal obligations.

5. Cookies and Tracking Technologies

5.1 Types of Cookies We Use

Cookie Type	Purpose
Essential Cookies	Required for website functionality, account access, and order processing
Functional Cookies	Remember your preferences, saved designs, and cart contents
Analytics Cookies	Help us understand how visitors use our website
Marketing Cookies	Enable personalized advertising and measure campaign effectiveness

5.2 Third-Party Analytics and Advertising Technologies

We use third-party analytics and advertising tools on our website to understand how visitors use our Services, measure advertising effectiveness, build audiences for remarketing, and optimize our marketing campaigns. These tools may collect information such as pages visited, products viewed, items added to cart, purchases, session duration, and general location data.

These third-party providers may use the data they collect in accordance with their own privacy policies. You can manage your advertising preferences through the opt-out tools described in Section 5.5.

5.3 Currency Conversion

By using our website, you agree to allow third parties to process your IP address to determine your location for currency conversion purposes. Your selected currency is stored in a session cookie to maintain consistency while browsing.

5.4 Cart Abandonment Tracking

We use cookies to track items placed in your shopping cart, including abandoned checkouts. This information may be used to send cart reminder messages via email or SMS if you have opted in to receive such communications.

5.5 Your Cookie Choices

You can manage cookie preferences through our cookie consent banner, your browser settings, and third-party opt-out tools such as the Digital Advertising Alliance (aboutads.info/choices) and the Network Advertising Initiative (networkadvertising.org/choices).

Note: Disabling certain cookies may affect website functionality.

5.6 Global Privacy Control (GPC) and Universal Opt-Out Mechanisms

We honor Global Privacy Control (GPC) signals and other legally recognized universal opt-out preference signals. When we detect a GPC signal from your browser, we will treat it as a valid request to opt out of the sale or sharing of your personal information for cross-context behavioral advertising, as required by applicable state laws including those of California, Colorado, Connecticut, Montana, Texas, Oregon, Delaware, Nebraska, New Hampshire, New Jersey, Minnesota, and Maryland.

If you have enabled GPC in your browser, you do not need to take any additional action to opt out of data sharing for advertising purposes on our website.

For more information about GPC, visit globalprivacycontrol.org.

6. How We Share Your Information

6.1 Categories of Recipients

We may share your personal information with the following categories of recipients:

Service Providers: Payment processors (to process transactions securely), shipping carriers (to deliver your orders), manufacturing partners (to produce custom curtains), cloud hosting and data storage providers, email and SMS service providers, customer support platforms, and AI technology providers (for chatbot services).

Advertising and Analytics Partners: We share certain data with third-party analytics and advertising platforms for advertising measurement, remarketing, and analytics purposes. This sharing may be considered a “sale” or “sharing” under certain state privacy laws. See Section 7.4 for your opt-out rights.

Legal and Compliance: Law enforcement or government authorities when required by law, subpoena, court order, or government request. Parties involved in corporate transactions (mergers, acquisitions, reorganizations, or asset sales).

6.2 Data Sales and Sharing Disclosure

We do not sell your personal information for monetary consideration.

However, our use of third-party advertising and analytics tools may constitute “sharing” of personal information for cross-context behavioral advertising under certain state privacy laws. In the preceding 12 months, we may have shared the following categories of personal information with advertising partners: identifiers (such as IP address and device identifiers), internet or network activity (such as browsing history and products viewed), and commercial information (such as products purchased).

You have the right to opt out of this sharing. See Section 7.4 and Section 5.6 for details on how to exercise this right.

Maryland Residents: In accordance with the Maryland Online Data Privacy Act, we do not sell sensitive personal information under any circumstances.

6.3 International Data Transfers

Freshine is headquartered in Hong Kong. Your personal information may be transferred to and processed in the United States (for order fulfillment, customer service, and marketing operations), Hong Kong (for corporate management and administrative purposes), and other jurisdictions where our service providers operate.

We implement appropriate safeguards for international data transfers to ensure your personal information receives an adequate level of protection, including contractual data protection obligations with our service providers.

7. Your Privacy Rights

Depending on your state of residence, you may have the following rights regarding your personal information. We are committed to honoring these rights for all U.S. consumers regardless of state, where operationally feasible.

7.1 Right to Know/Access

You have the right to request information about the personal information we have collected about you, including the categories of personal information collected, the categories of sources, the business purposes for collection, the categories of third parties with whom we share information, and the specific pieces of personal information we have collected. Under the CPRA, this right extends to data collected on or after January 1, 2022.

7.2 Right to Delete

You have the right to request deletion of your personal information, subject to certain exceptions (e.g., for legal compliance, completing a transaction, exercising free speech, or internal uses reasonably aligned with your expectations).

7.3 Right to Correct

You have the right to request correction of inaccurate personal information we maintain about you.

7.4 Right to Opt-Out of Sale/Sharing

You have the right to opt out of the “sale” or “sharing” of your personal information for cross-context behavioral advertising. To exercise this right:

Click our “Do Not Sell or Share My Personal Information” link on our website
Email us at support@freshinelife.com
Enable Global Privacy Control (GPC) in your browser

We will confirm receipt of your opt-out request and process it promptly.

7.5 Right to Limit Use of Sensitive Personal Information

You have the right to request that we limit the use and disclosure of sensitive personal information to only what is necessary to provide our Services.

7.6 Right to Data Portability

You have the right to receive your personal information in a portable, readily usable, and machine-readable format.

7.7 Right to Non-Discrimination

We will not discriminate against you for exercising any of your privacy rights, including by denying services, charging different prices, offering a different level or quality of services, or otherwise penalizing you, except as permitted by applicable law.

7.8 Right to Opt-Out of Automated Decision-Making/Profiling

You have the right to opt out of automated decision-making technology and profiling that produces legal or similarly significant effects. This includes the right to request human review of significant automated decisions and the right to information about the logic involved in automated processing.

7.9 Right to Appeal

If we deny your privacy rights request, you have the right to appeal our decision. To file an appeal:

Email us at support@freshinelife.com with the subject line “Privacy Rights Appeal”
Include your original request details and the reason for your appeal
We will respond to your appeal within 60 days
If your appeal is denied, we will provide you with instructions on how to file a complaint with your state’s Attorney General or relevant data protection authority

8. State-Specific Privacy Rights

8.1 California Residents (CCPA/CPRA)

If you are a California resident, you have all rights described in Section 7, plus the following:

Shine the Light: You may request information about categories of personal information we have shared with third parties for their direct marketing purposes in the preceding calendar year.

Sensitive Personal Information: We collect account login credentials and payment-related information, which may be considered sensitive personal information under California law. We use this information only as reasonably necessary to provide our Services, process transactions, and maintain account security. We do not use or disclose sensitive personal information for purposes beyond those for which you cannot opt out under the CCPA.

Do Not Sell or Share My Personal Information: Our use of third-party advertising and analytics technologies may constitute “sharing” under the CCPA. To opt out, visit our “Do Not Sell or Share My Personal Information” page on our website, contact us at support@freshinelife.com, or enable GPC in your browser.

Automated Decision-Making Technology: As described in Section 2.2, we use AI chatbot and product recommendation systems. You have the right to opt out of ADMT and to request information about how these systems work.

Risk Assessments: We conduct regular risk assessments for processing activities that present significant risk to consumer privacy, in accordance with CPRA regulations.

Opt-Out Confirmation: When you submit an opt-out request, we will send you a confirmation that your request has been received and processed.

Verification: We will verify your identity before processing your request by matching information you provide with information in our records.

Authorized Agents: You may designate an authorized agent to make requests on your behalf. The agent must provide written proof of authorization, and we may require you to verify your identity directly.

8.2 Virginia Residents (VCDPA)

Virginia residents have the right to confirm whether we are processing their personal information, access their personal information, correct inaccuracies, delete personal information, obtain a copy of their personal information in a portable format, and opt out of processing for targeted advertising, sale of personal information, or profiling that produces legal or similarly significant effects.

8.3 Colorado Residents (CPA)

Colorado residents have rights similar to Virginia residents. We honor universal opt-out mechanisms (including GPC) as required by the CPA, and we conduct data protection assessments for processing activities that present a heightened risk of harm to consumers.

8.4 Connecticut Residents (CTDPA)

Connecticut residents have rights to know, access, delete, correct, and opt out of the sale of personal information and targeted advertising. We do not sell or share the personal information of consumers we know to be under 16 years of age.

8.5 Utah Residents (UCPA)

Utah residents have the right to know what personal information is being collected, delete personal information provided by the consumer, obtain a copy in a portable format, and opt out of the sale of personal information and targeted advertising. Effective July 1, 2026, Utah residents also have the right to correct inaccuracies in their personal data.

8.6 Texas Residents (TDPSA)

Texas residents have the right to confirm processing, access, correct, delete, and obtain a portable copy of their personal information. Texas residents may also opt out of processing for targeted advertising, sale of personal data, and profiling. We honor universal opt-out mechanisms as required by the TDPSA.

8.7 Oregon Residents (OCPA)

Oregon residents have rights similar to those under the VCDPA. We do not sell geolocation data that is accurate within 1,750 feet. Oregon provides additional protections for consumers under 16 years of age.

8.8 Maryland Residents (MODPA)

Maryland residents have enhanced privacy protections under the Maryland Online Data Privacy Act:

We do not sell sensitive personal information under any circumstances, regardless of consumer consent. This prohibition cannot be overridden.
We adhere to strict data minimization standards, collecting only data that is reasonably necessary for our stated purposes.
Maryland residents have all standard privacy rights including access, deletion, correction, and opt-out rights.
We honor universal opt-out mechanisms as required by MODPA.

8.9 Minnesota Residents (MNCDPA)

Minnesota residents have the right to access, delete, correct, and obtain a portable copy of their personal information. We provide clear, conspicuous, and accessible privacy notices in plain language. Minnesota residents may also opt out of targeted advertising, profiling, and the sale of personal data.

8.10 Rhode Island Residents (RIDTPPA)

Rhode Island residents have privacy rights under the Rhode Island Data Transparency and Privacy Protection Act. This law requires us to maintain a standalone, accessible privacy notice on our commercial website. Rhode Island does not provide a right to cure for violations, meaning enforcement may be immediate.

8.11 Other State Rights

Residents of Montana, Iowa, Tennessee, Indiana, Kentucky, Delaware, New Jersey, New Hampshire, and Nebraska have similar privacy rights under their respective state laws. These generally include the rights to access, delete, correct, and port personal data, as well as the right to opt out of targeted advertising and the sale of personal information. We honor universal opt-out mechanisms where required by these state laws.

8.12 Nevada Residents (SB 220)

Nevada residents have the right to opt out of the sale of their personal information. We will respond to verified opt-out requests within 60 days. To exercise this right, contact us at support@freshinelife.com.

9. How to Exercise Your Rights

9.1 Submitting Requests

To exercise your privacy rights:

Email: support@freshinelife.com
Customer Support: support@freshinelife.com
Phone: +1 (949) 691-6598
Online: freshinelife.com/pages/do-not-sell-or-share
Mail:
Freshine Privacy Office
43 Corporate Park #208
Irvine, CA 92606
United States

9.2 Verification Process

To protect your privacy, we will verify your identity before processing your request. We may ask you to provide information that matches our records (such as your name, email address, or order number). For requests involving sensitive information or deletion, we may require additional verification. Authorized agents must provide written proof of authorization.

9.3 Response Time

We will respond to verifiable consumer requests within the timeframes required by applicable law:

California (CCPA/CPRA): 45 days (with a possible 45-day extension upon notice)
Nevada (SB 220): 60 days
All other states: 45 days (with extensions as permitted by applicable law)

We will notify you if an extension is needed and explain the reason for the delay.

9.4 Fees

We do not charge a fee to process or respond to verifiable consumer requests unless they are excessive, repetitive, or manifestly unfounded.

10. Data Protection Assessments

In compliance with applicable state privacy laws (including those of California, Virginia, Colorado, Connecticut, and Kentucky), we conduct data protection impact assessments for processing activities that present a heightened risk of harm to consumers, including processing of sensitive personal data, processing for purposes of targeted advertising, processing for profiling that presents a reasonably foreseeable risk of unfair treatment or significant harm, and sale of personal data.

These assessments evaluate the benefits of the processing against potential risks to consumer privacy and are documented and maintained as required by law.

11. Data Security

11.1 Security Measures

We implement appropriate technical and organizational measures to protect your personal information, including encryption (TLS/SSL encryption for data in transit and encryption at rest for stored data), access controls (role-based access controls and multi-factor authentication), network security (firewalls, intrusion detection, and regular security monitoring), payment security (PCI DSS compliant payment processing through third-party providers), employee training (regular privacy and security training for all staff), and vendor management (security assessments of third-party service providers).

11.2 Payment Information

We do not store your full credit card or bank account information on our servers. All payment processing is handled by secure, PCI DSS compliant third-party payment processors.

11.3 Breach Notification

In the event of a data breach that affects your personal information, we will notify you and relevant authorities within the timeframes required by applicable state laws (including California’s requirement of notification within 30 days of discovering a breach). Notification will include a description of the breach, the types of information involved, steps we are taking to address the breach, and recommendations for protecting yourself.

12. Data Retention

We retain your personal information for as long as necessary to provide our Services, fulfill the purposes outlined in this Privacy Policy, comply with legal obligations (e.g., tax and accounting requirements), and resolve disputes and enforce our agreements.

Typical Retention Periods:

Account information: As long as your account is active, plus 30 days after deletion request
Order and transaction records: 7 years (for tax/accounting compliance)
Marketing data: Until you opt out or request deletion
Call recordings: 90 days (unless required for legal purposes)
Chat transcripts (including AI chatbot): 2 years
Custom design specifications: 3 years (to facilitate reorders)
Cookie and tracking data: As specified by each cookie type (session cookies are deleted when you close your browser; persistent cookies may remain for up to 13 months)

When personal data is no longer needed, we securely delete or anonymize it.

13. Children’s and Minors’ Privacy

Our Services are not intended for children under 16 years of age. We do not knowingly collect, use, or disclose personal information from children under 16. If we learn that we have collected personal information from a child under 16 without verification of parental consent, we will delete that information as quickly as possible.

Minors Under 16: In compliance with applicable state laws (including Connecticut, Oregon, and California):

We do not sell or share the personal information of consumers we know to be under 16 years of age
We do not process the personal information of known minors for targeted advertising purposes
We do not engage in profiling of known minors that could result in legal or similarly significant effects

If you believe a child under 16 has provided us with personal information, please contact us immediately at support@freshinelife.com.

14. Third-Party Websites and Services

Our website may contain links to third-party websites, including social media platforms, payment processors, shipping carrier tracking pages, and design inspiration websites.

This Privacy Policy does not apply to third-party websites. We are not responsible for the privacy practices of these websites. We encourage you to read the privacy policies of any third-party websites you visit before providing them with your personal information.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, or legal requirements.

When we make material changes, we will post the updated policy on this page, update the “Last Updated” date, and provide notice through our website or by email.

Your continued use of our Services after the effective date of the revised Privacy Policy constitutes your acceptance of the changes. If you do not agree with the updated Privacy Policy, please discontinue use of our Services and contact us to close your account.

16. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

Freshine Privacy Office

Address:
43 Corporate Park #208
Irvine, CA 92606
United States

Privacy Inquiries: support@freshinelife.com

Customer Support: support@freshinelife.com

Phone: +1 (949) 691-6598

17. Additional Disclosures

17.1 Categories of Personal Information Collected (Last 12 Months)

In the preceding 12 months, we have collected the following categories of personal information: identifiers, commercial information, custom order information, communications data, internet or network activity, geolocation data, audio/visual information, and inferences.

17.2 Categories of Personal Information Disclosed for Business Purposes (Last 12 Months)

We have disclosed the following categories of personal information to service providers for business purposes: identifiers, commercial information, internet or electronic network activity, geolocation data, and audio/visual information.

17.3 Categories of Personal Information Sold or Shared (Last 12 Months)

We do not sell personal information for monetary consideration. We have shared the following categories of personal information with third-party advertising and analytics partners for cross-context behavioral advertising: identifiers (such as IP address and device identifiers), internet or network activity (such as browsing history and products viewed), and commercial information (such as products purchased or viewed).