SUREWAY PRIVACY & COOKIE POLICY

Part 1 — Privacy Policy

1. Who We Are

This policy explains how White Raven Trading – FZCO ("SUREWAY," "we," "us") collects and uses personal information when you visit mysureway.com, buy from us, or contact us.
White Raven Trading – FZCO is a Free Zone Company (FZCO) registered with IFZA under the Dubai Integrated Economic Zones Authority, Trade License No. 89439. Our registered address is IFZA Business Park, DDP, PO Box 342001, Dubai, United Arab Emirates.
This policy covers customers and Site visitors in the United States.
You can reach us at info@mysureway.com with any question about this policy.

2. At a Glance

If you only read one section, read this one.


3. Information We Collect


We do not knowingly collect government identifiers, financial account numbers, biometric data, or precise geolocation.

4. How and Why We Use It



5. A Note on Health-Related Information

SUREWAY is a personal care product. We are aware that the fact of buying it could, in some circumstances, allow someone to draw an inference about a customer. We treat that seriously, and we take the following approach:

• We do not ask you why you use the product, and we do not want to know.
• We do not create, buy, or infer health-related profiles about you.
• We do not use purchase history to place you in health-related advertising audiences.
• We describe the product to payment providers, couriers, and advertising platforms in neutral personal-care terms.

6. Emails We Send You

There are two kinds of email, and they work differently.
6.1 Order emails (not marketing). When you place an order, our store platform (Shopify) sends an order confirmation with your receipt to the email address you gave at checkout, from info@mysureway.com. When your order is dispatched, you receive a dispatch notice with tracking details. We send these because you ordered, and they are part of fulfilling your order, so you cannot unsubscribe from them while an order is open. They may include a short note about the order, for example how to reach us about it. They are not advertising.
6.2 Marketing emails. We will only send you marketing emails if you have asked us to. You can ask in two ways: by signing up on the Site, or by ticking the marketing box at checkout. The box is never ticked for you, and you do not have to agree to marketing to buy from us. We keep a record of when and how you signed up, so that we can show that you asked. You can withdraw your permission at any time by using the unsubscribe link in any marketing email, or by emailing info@mysureway.com. Each marketing email includes our postal address and an unsubscribe link. Withdrawing permission stops marketing emails; it does not affect order emails about an order you have already placed.
6.3 Waiting list. If you joined our waiting list, we will use your email address to tell you about new products, restocks, or availability, and to send the updates you agreed to receive. Nothing more.
6.4 Using your email address for advertising. If you have subscribed to marketing emails, we may share a scrambled (hashed) version of your email address with Google and Meta, so that they can show you our advertising or leave you out of it. We do this only for people who have subscribed to marketing emails, not for everyone who orders, and we do not share what you ordered for this purpose. You can opt out at any time by emailing info@mysureway.com with the words "Opt out" in the subject line (see Section 12).

7. Cookies and Similar Technologies
We use cookies, pixels, and similar technologies to make the Site work, understand how it is used, and measure our advertising. Part 2 of this page explains which ones we use and how to change your choices. You can change your cookie choices at any time with the "Cookie settings" link in the footer or in your browser settings (see Part 2, Section 6). To opt out of sharing your information for advertising, see Section 12 (Your Privacy Choices). We honor the Global Privacy Control (GPC) signal: if your browser or a browser extension sends it, we treat it as an opt-out request automatically.

8. Who We Share It With
We share personal information only with organizations that need it to provide a service to us, and only for that purpose. They act on our instructions and cannot use your information for their own purposes, except where noted below.


If our business is sold or reorganized, personal information may transfer to the buyer as part of that transaction, and the buyer will be bound to use it consistently with this policy.

9. Sending Information Outside Your Country

We sell to customers in the United States. White Raven Trading – FZCO, which runs SUREWAY, is based in the United Arab Emirates, and some of our service providers are located in other countries. Wherever your information is handled, we require the organizations we work with to protect it consistently with this policy and to use it only for the purposes described here.

10. How Long We Keep It


11. Keeping It Secure

We use encrypted connections across the Site, restrict access to personal information to people who need it, and require our providers to maintain appropriate security. Card details are handled by our payment provider and never reach our systems.
No system is perfectly secure. If a breach occurs that is likely to put your rights at risk, we will tell you and the relevant regulator as required by law.

12. Your Privacy Choices and Your Rights in the United States

Several US states give residents privacy rights. If you live in one of them, this section applies to you. It sits alongside, and does not replace, the rest of this policy.
12.1 Where these rights apply. These rights are currently available to residents of California, Colorado, Connecticut, Virginia, Utah, Texas, Oregon, Montana, Delaware, Iowa, Nebraska,New Hampshire, New Jersey, Minnesota, Maryland, Tennessee, Indiana, Kentucky, and Rhode Island, and any other state whose law applies to us.
12.2 What you can ask us to do.

• Know: what categories of personal information we have collected about you, where it came from, why we collected it, and who we disclosed it to.
• Access: get a copy of the specific pieces of personal information we hold.
• Correct: have inaccurate information about you fixed.
• Delete: have your personal information deleted, subject to exceptions such as completing an order or meeting a legal obligation.
• Opt out of sale, sharing and targeted advertising: see 12.3.
• Limit the use of sensitive personal information: we do not collect it for the purposes this right covers, but the request is available to you.
• Not be discriminated against: we will not charge you more, give you less, or refuse to serve you because you exercised a privacy right.

12.3 Sale, sharing and targeted advertising. We do not sell personal information for money. However, our use of advertising cookies and pixels means information about your visit is shared with advertising platforms so that they can show you our ads and tell us whether they worked. Under California and several other state laws, that counts as "sharing" for cross-context behavioral advertising, and in some states as a "sale."
To opt out, email info@mysureway.com with the words "Opt out" in the subject line, or turn on the Global Privacy Control signal in your browser. We honor that signal automatically for that browser, without you having to do anything else. You can also change your choice with the "Cookie settings" link in the footer. If you subscribed to marketing emails, the sharing of a hashed version of your email address with advertising platforms (see 6.4) is covered by the same opt-out.
12.4 How to make a request. Email info@mysureway.com with the words "US privacy request" in the subject line.

• We will confirm receipt within 10 business days and respond within 45 days. If we need more time we will tell you why and take up to 45 days more.
• We will ask you to verify your identity, usually by confirming information we already hold, such as the email address on your order. We use what you send us for verification only.
• An authorized agent may make a request for you. We will ask for written proof of their authority and, unless they hold power of attorney, we will also ask you to confirm it directly.

12.5 Appeals. If we refuse your request, we will tell you why, and you may appeal by replying to our response or emailing info@mysureway.com with "Appeal" in the subject line. We will decide the appeal within 45 days and explain our reasoning in writing. If we refuse the appeal, we will tell you how to contact your state Attorney General.
12.6 Personal information shared or disclosed in the past 12 months. This is the list California law asks for. It describes what we have shared and with whom.


We have not sold personal information for money. We also disclose identifiers, contact details, order information and payment details to service providers that run our business: Shopify, Shopify Payments, Stripe, Amazon (delivery), Omnisend and Gmail (email). Those disclosures are not "sales" or "sharing." We do not knowingly sell or share the personal information of anyone under 18.

13. People Under 18

SUREWAY is sold to adults. The Site is not directed at anyone under 18, and we do not knowingly collect personal information from anyone under 18. If you believe someone under 18 has given us personal information, email info@mysureway.com and we will delete it.

14. Changes to This Policy

We will update this policy when our practices change. The date at the top shows when it was last revised. If the change is significant, we will tell you by email or with a notice on the Site before it takes effect.

15. Contacting Us

• Email (privacy questions and requests, orders, returns and everything else): info@mysureway.com
• Post: White Raven Trading – FZCO, IFZA Business Park, DDP, PO Box 342001, Dubai, United Arab Emirates

Part 2 — Cookie Policy

1. What This Part Covers

This part explains what cookies and similar technologies we use on mysureway.com, what each of them does, and how you can change your mind at any time. Part 1 of this page (our Privacy Policy) explains what we do with the information collected.

2. What Cookies Are

A cookie is a small text file placed on your device when you visit a website. It lets the Site remember things between pages and between visits, such as what is in your basket or which language you chose.
We also use technologies that work in a similar way and which this policy treats the same:

• Pixels and tags: a tiny piece of code that loads when you view a page, used to measure whether an advertisement led to a visit or a purchase.
• Local storage: a way for the Site to store information in your browser, working much like a cookie but with more capacity.
• Software development kits (SDKs): code provided by another company that we include on our Site so that its service works.

Cookies set by us are called "first-party." Cookies set by another company through our Site, such as an analytics or advertising provider, are called "third-party." We use both.ost: White Raven Trading – FZCO, IFZA Business Park, DDP, PO Box 342001, Dubai, United Arab Emirates

4. The Categories We Use


5. Who Sets These Cookies

Cookies on our Site are set by us and by the following providers, each acting within the categories described in Section 4:

• Tilda: runs the website and keeps your session working (strictly necessary).
• Shopify: runs our shopping cart and checkout, keeps your order working, processes payment through Shopify Payments, and helps prevent fraud (strictly necessary).
• Stripe: processes payments and helps prevent fraud (strictly necessary).
• Google: measures how the Site is used (Analytics) and how our advertising performs (Ads).
• Meta: delivers and measures our advertising on Facebook and Instagram.

Each of these companies sets its own cookies and decides how long they last, under its own privacy and cookie policies. We do not control those specifics, only whether the cookie is allowed to run on our Site at all, which depends on the choice you make in Section 3.

6. Changing Your Mind

6.1 On our site. Select "Cookie settings" in the footer of any page. Your choices take effect immediately and apply to this browser on this device.
6.2 In your browser. Every major browser lets you block or delete cookies through its settings. Blocking strictly necessary cookies will stop parts of the Site working, including checkout. Deleting cookies also deletes the record of your choices, so we will ask you again on your next visit.
6.3 Global Privacy Control. If your browser or a browser extension sends a Global Privacy Control signal, we treat it as an instruction to opt out of advertising and analytics cookies for that browser. You do not need to do anything else. More information is available at globalprivacycontrol.org.
6.4 Do Not Track. Browsers also offer a "Do Not Track" setting. There is no agreed standard for how sites should respond to it, and we do not respond to it. We do respond to Global Privacy Control, described above.
6.5 Opting out with the advertising platforms directly. You can also manage advertising preferences with the platforms themselves through their own settings, and through the Digital Advertising Alliance (optout.aboutads.info) and the Network Advertising Initiative (optout.networkadvertising.org).

7. Keeping a Record of Your Choice

When you make a cookie choice, we store a record of what you chose and when, so that we can respect it and demonstrate that we asked. We keep that record for 12 months, after which we will ask you again.

8. Changes to This Part

We update this part when we add or remove a tool. The date at the top of this page shows when it was last revised.

9. Contact

Questions about cookies: info@mysureway.com