Last updated: January 18, 2026

Overture Gifts operates this store and website, including all related information, content, features, tools, products and services, in order to provide you, the customer, with a curated shopping experience (the "Services"). Overture Gifts is powered by Shopify, which enables us to provide the Services to you. This Privacy Policy describes how we collect, use, and disclose your personal information when you visit, use, or make a purchase or other transaction using the Services or otherwise communicate with us. If there is a conflict between our Terms of Service and this Privacy Policy, this Privacy Policy controls with respect to the collection, processing, and disclosure of your personal information.

Please read this Privacy Policy carefully. By using and accessing any of the Services, you acknowledge that you have read this Privacy Policy and understand the collection, use, and disclosure of your information as described in this Privacy Policy.

Personal Information We Collect or Process

When we use the term "personal information," we are referring to information that identifies or can reasonably be linked to you or another person. Personal information does not include information that is collected anonymously or that has been de-identified, so that it cannot identify or be reasonably linked to you. We may collect or process the following categories of personal information, including inferences drawn from this personal information, depending on how you interact with the Services, where you live, and as permitted or required by applicable law:

• Contact details including your name, address, billing address, shipping address, phone number, and email address.
• Financial information including credit card, debit card, and financial account numbers, payment card information, financial account information, transaction details, form of payment, payment confirmation and other payment details.
• Account information including your username, password, security questions, preferences and settings.
• Transaction information including the items you view, put in your cart, add to your wishlist, or purchase, return, exchange or cancel and your past transactions.
• Communications with us including the information you include in communications with us, for example, when sending a customer support inquiry.
• Device information including information about your device, browser, or network connection, your IP address, and other unique identifiers.
• Usage information including information regarding your interaction with the Services, including how and when you interact with or navigate the Services.

Personal Information Sources

We may collect personal information from the following sources:

• Directly from you including when you create an account, visit or use the Services, communicate with us, or otherwise provide us with your personal information;
• Automatically through the Services including from your device when you use our products or services or visit our websites, and through the use of cookies and similar technologies;
• From our service providers including when we engage them to enable certain technology and when they collect or process your personal information on our behalf;
• From our partners or other third parties.

How We Use Your Personal Information

Depending on how you interact with us or which of the Services you use, we may use personal information for the following purposes:

• Provide, Tailor, and Improve the Services. We use your personal information to provide you with the Services, including to perform our contract with you, to process your payments, to fulfill your orders, to remember your preferences and items you are interested in, to send notifications to you related to your account, to process purchases, returns, exchanges or other transactions, to create, maintain and otherwise manage your account, to arrange for shipping, to facilitate any returns and exchanges, to enable you to post reviews, and to create a customized shopping experience for you, such as recommending products related to your purchases. This may include using your personal information to better tailor and improve the Services.
• Marketing and Advertising. We use your personal information for marketing and promotional purposes, such as to send marketing, advertising and promotional communications by email, text message or postal mail, and to show you online advertisements for products or services on the Services or other websites, including based on items you previously have purchased or added to your cart and other activity on the Services.
• Security and Fraud Prevention. We use your personal information to authenticate your account, to provide a secure payment and shopping experience, detect, investigate or take action regarding possible fraudulent, illegal, unsafe, or malicious activity, protect public safety, and to secure our services. If you choose to use the Services and register an account, you are responsible for keeping your account credentials safe. We highly recommend that you do not share your username, password or other access details with anyone else.
• Communicating with You. We use your personal information to provide you with customer support, to be responsive to you, to provide effective services to you and to maintain our business relationship with you.
• Legal Reasons. We use your personal information to comply with applicable law or respond to valid legal process, including requests from law enforcement or government agencies, to investigate or participate in civil discovery, potential or actual litigation, or other adversarial legal proceedings, and to enforce or investigate potential violations of our terms or policies.

How We Disclose Personal Information

In certain circumstances, we may disclose your personal information to third parties for legitimate purposes subject to this Privacy Policy. Such circumstances may include:

• With Shopify, vendors and other third parties who perform services on our behalf (e.g. IT management, payment processing, data analytics, customer support, cloud storage, fulfillment and shipping).
• With business and marketing partners to provide marketing services and advertise to you. For example, we use Shopify to support personalized advertising with third-party services based on your online activity with different merchants and websites. Our business and marketing partners will use your information in accordance with their own privacy notices. Depending on where you reside, you may have a right to direct us not to share information about you to show you targeted advertisements and marketing based on your online activity with different merchants and websites. You can exercise your rights to opt-out of those uses here .
• When you direct, request us or otherwise consent to our disclosure of certain information to third parties, such as to ship you products or through your use of social media widgets or login integrations.
• With our affiliates or otherwise within our corporate group.
• In connection with a business transaction such as a merger or bankruptcy, to comply with any applicable legal obligations (including to respond to subpoenas, search warrants and similar requests), to enforce any applicable terms of service or policies, and to protect or defend the Services, our rights, and the rights of our users or others.

Relationship with Shopify

The Services are hosted by Shopify, which collects and processes personal information about your access to and use of the Services in order to provide and improve the Services for you. Information you submit to the Services will be transmitted to and shared with Shopify as well as third parties that may be located in countries other than where you reside, in order to provide and improve the Services for you. In addition, to help protect, grow, and improve our business, we use certain Shopify enhanced features that incorporate data and information obtained from your interactions with our Store, along with other merchants and with Shopify. To provide these enhanced features, Shopify may make use of personal information collected about your interactions with our store, along with other merchants, and with Shopify. In these circumstances, Shopify is responsible for the processing of your personal information, including for responding to your requests to exercise your rights over use of your personal information for these purposes. To learn more about how Shopify uses your personal information and any rights you may have, you can visit the Shopify Consumer Privacy Policy . Depending on where you live, you may exercise certain rights with respect to your personal information here Shopify Privacy Portal Link.

Third Party Websites and Links

The Services may provide links to websites or other online platforms operated by third parties. If you follow links to sites not affiliated or controlled by us, you should review their privacy and security policies and other terms and conditions. We do not guarantee and are not responsible for the privacy or security of such sites, including the accuracy, completeness, or reliability of information found on these sites. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms may also be viewable by other users of the Services and/or users of those third-party platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators, except as disclosed on the Services.

Children's Data

The Services are not intended to be used by children, and we do not knowingly collect any personal information about children under the age of majority in your jurisdiction. If you are the parent or guardian of a child who has provided us with their personal information, you may contact us using the contact details set out below to request that it be deleted.As of the Effective Date of this Privacy Policy, we do not have actual knowledge that we "share" or "sell" (as those terms are defined in applicable law) personal information of individuals under 16 years of age.

Security and Retention of Your Information

Please be aware that no security measures are perfect or impenetrable, and we cannot guarantee "perfect security." In addition, any information you send to us may not be secure while in transit. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us.

How long we retain your personal information depends on different factors, such as whether we need the information to maintain your account, to provide you with Services, comply with legal obligations, resolve disputes or enforce other applicable contracts and policies.

Your Rights and Choices

Depending on where you live, you may have some or all of the rights listed below in relation to your personal information. However, these rights are not absolute, may apply only in certain circumstances and, in certain cases, we may decline your request as permitted by law.

• Right to Access / Know. You may have a right to request access to personal information that we hold about you.
• Right to Delete. You may have a right to request that we delete personal information we maintain about you.
• Right to Correct. You may have a right to request that we correct inaccurate personal information we maintain about you.
• Right of Portability. You may have a right to receive a copy of the personal information we hold about you and to request that we transfer it to a third party, in certain circumstances and with certain exceptions.
• Right to Opt out of Sale or Sharing for Targeted Advertising. Depending on where you reside, you may have a right to opt out of the "sale" or "share" of your personal information or to opt out of the processing of your personal information for purposes considered to be "targeted advertising", as defined in applicable privacy laws. You can exercise your rights to opt-out of those uses here. Please note that if you visit our website with the Global Privacy Control opt-out preference signal enabled, depending on where you are, we will automatically treat this as a request to opt-out for the device and browser that you use to visit the website. If we are able to associate the device sending the signal to a Shopify account, we will apply the opt out request to the account as well. To learn more about Global Privacy Control, you can visit https://globalprivacycontrol.org/. Other than the Global Privacy Control, we do not recognize other "Do Not Track" signals that may be sent from your web browser or device.
• Managing Communication Preferences. We may send you promotional emails, and you may opt out of receiving these at any time by using the unsubscribe option displayed in our emails to you. If you opt out, we may still send you non-promotional emails, such as those about your account or orders that you have made.

You may exercise any of these rights where indicated on the Services or by contacting us using the contact details provided below. To learn more about how Shopify uses your personal information and any rights you may have, including rights related to data processed by Shopify, you can visit https://privacy.shopify.com/en.

We will not discriminate against you for exercising any of these rights. We may need to verify your identity before we can process your requests, as permitted or required under applicable law. In accordance with applicable laws, you may designate an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us. We will respond to your request in a timely manner as required under applicable law.

Complaints

If you have complaints about how we process your personal information, please contact us using the contact details provided below. Depending on where you live, you may have the right to appeal our decision by contacting us using the contact details set out below, or lodge your complaint with your local data protection authority. For the EEA, you can find a list of the responsible data protection supervisory authorities here.

International Transfers

Please note that we may transfer, store and process your personal information outside the country you live in.

If we transfer your personal information out of the European Economic Area or the United Kingdom, we will rely on recognized transfer mechanisms like the European Commission's Standard Contractual Clauses, or any equivalent contracts issued by the relevant competent authority of the UK, as relevant, unless the data transfer is to a country that has been determined to provide an adequate level of protection.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time, including to reflect changes to our practices or for other operational, legal, or regulatory reasons. We will post the revised Privacy Policy on this website, update the "Last updated" date and provide notice as required by applicable law.

Contact

Should you have any questions about our privacy practices or this Privacy Policy, or if you would like to exercise any of the rights available to you, please call or email us at overturegifts@mail.com or contact us at 13300 Bothell Everett Hwy, Mill Creek, WA, 98012, US For the purpose of applicable data protection laws, we are the data controller of your personal information.

PRIVACY POLICY

Last Updated: [Insert Date]

This Privacy Policy (“Policy”) describes how Mount Everest Holdings, Inc. (“Company,” “we,” “us,” or “our”), doing business under the brand name Overture Gifts, collects, uses, discloses, and safeguards information when you visit OvertureGifts.store (the “Site”).

Overture Gifts is a brand division only and not a separate legal entity.

By using the Site, you consent to the practices described in this Policy.

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1. INFORMATION WE COLLECT

We collect information in the following categories:

A. Information You Provide

• Name

• Billing and shipping address

• Email address

• Phone number

• Payment information (processed by third-party processors)

• Order history

• Communications and inquiries

B. Automatically Collected Information

• IP address

• Device type

• Browser type

• Operating system

• Referring URLs

• Pages viewed

• Time spent

• Cookies and similar technologies

C. Transaction Information

• Products purchased

• Payment method (last four digits, if applicable)

• Order metadata

D. Marketing Preferences

• Email subscription status

• Interaction with promotional emails

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2. HOW WE USE INFORMATION

We may use information to:

• Process transactions

• Fulfill orders

• Provide customer service

• Detect fraud

• Prevent chargebacks

• Improve the Site

• Send marketing communications (where permitted)

• Enforce Terms & Conditions

• Comply with legal obligations

We reserve the right to use data for internal analytics, security monitoring, and operational improvements.

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3. PAYMENT PROCESSING

Payments are processed through third-party payment processors.

We do not store full credit card numbers.

We are not responsible for the privacy or security practices of payment processors.

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4. COOKIES & TRACKING TECHNOLOGIES

We use cookies and similar technologies to:

• Operate the Site

• Analyze traffic

• Remember preferences

• Improve functionality

You may disable cookies in your browser; however, portions of the Site may not function properly.

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5. HOW WE DISCLOSE INFORMATION

We may disclose information to:

• Payment processors

• Shipping carriers

• Fraud prevention providers

• IT service providers

• Marketing service providers

• Legal authorities when required

We do not sell personal information for monetary compensation.

We reserve the right to transfer information in connection with a merger, acquisition, or sale of assets.

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6. DATA RETENTION

We retain personal information as long as necessary to:

• Fulfill transactions

• Comply with legal obligations

• Enforce agreements

• Resolve disputes

• Prevent fraud

We may retain limited data for archival, compliance, or risk mitigation purposes.

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7. DATA SECURITY

We implement reasonable administrative, technical, and physical safeguards.

However, no system is completely secure. We do not guarantee absolute security.

You are responsible for maintaining the confidentiality of your account credentials.

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8. YOUR RIGHTS (U.S.-FOCUSED)

Depending on your jurisdiction, you may have the right to:

• Request access to your personal information

• Request deletion

• Request correction

• Opt out of marketing communications

Requests may be submitted to: [Insert Email]

We may verify identity before responding.

We reserve the right to deny requests as permitted by law.

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9. CALIFORNIA PRIVACY DISCLOSURE (CCPA/CPRA STYLE)

If you are a California resident, you may have additional rights, including:

• Right to know categories of information collected

• Right to request deletion

• Right to opt out of certain sharing

We do not sell personal information as defined by California law.

Requests may be submitted to: [Insert Email]

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10. INTERNATIONAL USERS

The Site is operated from the United States.

If you access the Site from outside the U.S., you consent to transfer of your information to the United States.

We make no representation that the Site complies with non-U.S. laws.

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11. CHILDREN’S PRIVACY

The Site is not directed to children under 13.

We do not knowingly collect information from children under 13.

If we become aware of such data, we will delete it.

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12. MARKETING COMMUNICATIONS

You may opt out of promotional emails by clicking “unsubscribe.”

Transactional communications may still be sent.

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13. THIRD-PARTY LINKS

The Site may contain links to third-party websites.

We are not responsible for their privacy practices.

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14. AI & AUTOMATED TOOLS

We may use automated systems for analytics, fraud detection, and operational decision-making.

We do not engage in automated decision-making that produces legal effects without human oversight.

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15. DO NOT TRACK

We do not respond to browser “Do Not Track” signals.

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16. ARBITRATION

Privacy-related disputes are governed by the arbitration provisions contained in our Terms & Conditions.

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17. CHANGES TO THIS POLICY

We may update this Policy at any time.

Changes are effective upon posting.

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18. CONTACT

Mount Everest Holdings, Inc.
[Insert Address]
Email: [Insert Email]

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Implementation Recommendations (Important)

For maximum defensibility:

• Link this Policy in website footer

• Require checkbox acceptance at checkout

• Maintain timestamped consent logs

• Use clear unsubscribe mechanism

• Maintain written data retention protocol

• Maintain internal breach response plan

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1. DATA PROCESSING ADDENDUM (DPA)

Last Updated: [Insert Date]

This Data Processing Addendum (“DPA”) forms part of the Terms & Conditions between Mount Everest Holdings, Inc. (“Company”) and any service provider or vendor (“Processor”) that processes Personal Data on behalf of the Company.

1. Scope

This DPA applies where Processor processes Personal Data in connection with services provided to the Company.

2. Definitions

• Personal Data: Information relating to an identified or identifiable individual.

• Processing: Any operation performed on Personal Data.

• Subprocessor: Any third party engaged by Processor.

3. Processor Obligations

Processor shall:

• Process Personal Data only on documented instructions

• Implement appropriate technical and organizational safeguards

• Ensure personnel confidentiality

• Not sell or share Personal Data

• Notify Company of any data breach within 48 hours

• Assist Company with data subject requests

• Delete or return Personal Data upon termination

4. Security Measures

Processor must maintain:

• Encryption in transit (TLS 1.2+)

• Access controls

• Incident response plan

• Logging and monitoring

• Secure development practices

5. Subprocessors

Processor may not engage Subprocessors without prior authorization and must impose equivalent obligations.

6. Audit Rights

Company may request documentation demonstrating compliance.

7. Indemnification

Processor shall indemnify Company against losses arising from noncompliance.

8. Governing Law

Governed by Washington law and subject to arbitration per the Terms.

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2. COOKIE POLICY

Last Updated: [Insert Date]

This Cookie Policy explains how Mount Everest Holdings, Inc. uses cookies and similar technologies.

1. What Are Cookies?

Small text files stored on your device.

2. Categories Used

• Strictly Necessary Cookies – Site functionality

• Performance Cookies – Analytics

• Functional Cookies – Preferences

• Marketing Cookies – Advertising (if applicable)

3. Third-Party Cookies

May include analytics providers and advertising platforms.

We are not responsible for third-party cookie practices.

4. Managing Cookies

Users may disable cookies via browser settings. Functionality may be impaired.

5. Consent

By using the Site, you consent to cookie usage as described.

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3. DATA BREACH RESPONSE FRAMEWORK (INTERNAL POLICY)

This internal protocol strengthens litigation defense posture.

1. Incident Identification

Security incidents must be reported internally within 24 hours.

2. Containment

• Isolate affected systems

• Revoke compromised credentials

• Engage forensic review

3. Investigation

• Determine scope

• Identify affected data categories

• Assess risk of harm

4. Notification

If legally required:

• Notify affected individuals

• Notify regulators

• Provide mitigation guidance

5. Documentation

Maintain incident logs for 5 years minimum.

6. Public Communications

All public statements must be approved by executive leadership and legal counsel.

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4. CHARGEBACK DEFENSE PROTOCOL (INTERNAL SOP)

This materially reduces fraud loss exposure.

1. Order Controls

• AVS verification

• CVV verification

• IP geolocation review

• Fraud scoring tools

2. High-Risk Order Review

Manual review required for:

• Large orders

• Expedited shipping

• Mismatch billing/shipping

• High-risk geographies

3. Evidence Retention

Maintain:

• Order confirmation

• Shipping confirmation

• Delivery confirmation

• IP logs

• Customer communications

4. Chargeback Response Timeline

Respond within processor-required deadlines with:

• Proof of authorization

• Proof of delivery

• Refund policy acknowledgment

5. Blacklisting

Reserve right to block customers who initiate fraudulent chargebacks.

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5. ENTERPRISE COMPLIANCE CHECKLIST

This operational checklist strengthens defensibility.

Corporate Governance

• Maintain corporate good standing

• Separate brand and corporate documentation

• Maintain board oversight documentation

Website Compliance

• Footer links to:

  • Terms

  • Privacy Policy

  • Cookie Policy

• Clickwrap acceptance required

• Timestamp logging

Payment Security

• PCI-compliant processor

• No storage of full card numbers

• Fraud monitoring enabled

Data Protection

• Encryption in transit

• Access controls

• Written retention policy

• Incident response plan

Marketing Compliance

• CAN-SPAM compliant unsubscribe

• No deceptive subject lines

• Physical mailing address in emails

Record Retention

Maintain:

• Customer transaction records

• Consent logs

• Chargeback documentation

• Vendor contracts

Arbitration Enforcement

• Clear conspicuous arbitration clause

• Separate checkbox at checkout recommended

Insurance (Recommended)

• General Liability

• Cyber Liability

• Directors & Officers coverage

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“It is our enduring pleasure to serve you.” — Steve Ford

 

Copyright © Overture Gifts 2026 - All rights reserved. Overture Gifts is a wholly owned subsidiary of Mount Everest Holdings, Inc.