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    Effective: July 18, 2022

    PRIVACY POLICY

    Introduction

    Hanks Belts (“Company”) is a  corporation with a principal place of business located at  3119 Pearl Street, Endicott, NY 13760 (United States).  This statement (“Privacy Policy”) sets forth the privacy standards that the Company utilizes to collect, retain, and use personal data obtained from or about individuals located in the United States and elsewhere in the world. It is the Company’s policy to respect, and protect, personally identifiable information obtained from individuals as set forth in this Privacy Policy.

    You should also review our Terms of Use of the website, which can be found at https://www.hanksbelts.com/policies/terms-of-service/ and is applicable and binding upon you with respect to your use of the website and is incorporated herein.

    1. What Is the Scope of this Statement?

    This Privacy Policy sets forth the principles under which the Company collects, uses, processes, retains, and discloses personal data and/or sensitive data in the United States or elsewhere from individuals, including by and through our website located at https://www.hanksbelts.com/, including use of our “Belt Finder” and “Lookbook” (together, the “website”) and information you provide to us based upon information from our website (i.e., if you send us an e-mail at an e-mail address identified on the website) or through our website (i.e., using the contact information provided).  This Policy covers information received in electronic and all other formats.

    Please do not visit or use this website from the United Kingdom, the European Union, European Economic Area, Switzerland or anywhere else whose laws may conflict with this Privacy Policy; this website is not intended for your use if you are attempting to use from any of these countries and you do not have permission to use the website.  Please note that this exclusion is solely because the laws of your country may not conform with our policies as set forth in this Privacy Policy.

    1. Terms

    The terms "we", "us" and "our" refer to the Company, and its officers, directors, owners, employees and agents.

    The term “personal data” means any data which relates to a natural person (as opposed to a business or corporate entity) that makes you identifiable.  As used herein and in connection with our business, the term personal data may include:

    • Names and contact information, including phone number, physical address, fax and e-mail, all only to the extent provided by you (or on your behalf) to us;
    • Your password if you create an account with us;
    • Any information you provide to us through our “Contact Us” page on the website, including any information you provide by calling us or providing to us in the “Question or Inquiry” box;
    • Any information you provide to us on or through any of our social media pages as linked on the website, including but not limited to Twitter®, Facebook®, YouTube® or Instagram®;
    • Your web browser, IP address, time zone, cookie information, what search terms you use and how you interact with the website;
    • Any other similar information provided to us by you in connection with our services or through the website.

    The term “processing” means any operation or set of operations performed on personal data.  Processing includes, but is not limited to, the collection of data, the organizing of data, the recording or saving/storage of data, the altering of data, the using of data, the disclosing or transfer of data, the deleting or destruction of data, or the making available of data.     

    1. What Information We Collect About You

    We may collect all types of personal data about you as described in Section 2 above under the definition of “personal data.”  

    You agree that we may collect and process all such personal data that you provide to us, or that you manifestly make public through publication or otherwise, to market and sell the goods and products, including belts, wallets and leather accessories, and provide the information identified and contained on the website and to provide services related thereto, including handling sales, returns and inquiries (collectively, the “Services”).  In addition, these Services may also include Services in connection with the use and management of the website and all content and services therein.

    You also hereby consent that we may use your personal data for the following additional purposes which may be included in, or part of, the Services:

    • Updating our records;
    • In connection with any application for employment with the Company;
    • Internal analysis for our business management purposes;
    • Any statutory or regulatory purpose which requires the processing of your personal data;
    • Legal and regulatory compliance;
    • Fraud and crime prevention;
    • Internal or external audits; and
    • Any other purpose for which valid consent is obtained.

    Please do not supply the following to us:

    • Any other person's personal data, unless the Company explicitly asks you to do so;
    • Any categories of your personal data that have not been explicitly requested by the Company;
    • Any confidential, proprietary, secret or legally protected information which you are not explicitly requested by the Company to provide; and
    • Any confidential, proprietary, secret or legally protected information which are under any legal obligation to not provide to or share with the Company.
    1. How We Collect Information About You

    We collect information about you (including personal data) when:

    • You Give Us Information - You may provide us information when:
    • you provide us information in connection with the purchase of any goods or products on or through the website;
    • you set up an account with us; you provide it to us by filling out forms;
    • you send us e-mail; you provide information via phone or in person;
    • you provide us with information in writing and send it to us other than via e-mail, phone or in person (i.e., mail, FedEx, etc.);
    • you provide information to or through our “Contact Us” page or on any of our social media pages on Twitter®, Facebook®, YouTube®, Instagram® or otherwise;
    • you provide us with documentation;
    • you provide us with information which may contain personal data;
    • you provide it to use through our Customer Login page;
    • you provide it when subscribing to receive the latest on sales, new releases, and other news or updates by and through the website; and/or
    • you provide us with information in connection with seeking employment with the Company.
    • We Collect Information Automatically – We automatically collect certain types of information when you visit our website (as explained below).
    • We Collect Information From Other Sources – We may also obtain information about you from outside sources. For example, we may obtain commercially available information about you from third-parties or purchase e-mail lists from third parties for advertising, marketing or informational purposes; or from any senior living provider, organization, facility, institution, business, or company in which you live, with whom you are affiliated in any way, or from or about which you seek information through any of our Services.  We may also receive information from third-parties who provide services for us through web-beacons and other technologies described in this Privacy Policy.
    1. Use of Cookies

                 About Cookies

    • A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
    • Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
    • Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
    • Shared local objects (commonly referred to as “FLASH cookies”) are cookies that are placed on your computer that are not removed through normal browser management tools. If we use FLASH cookies, we will only do so in a manner consistent with the purposes for which they were designed unless you are specifically notified that we intend to use them for a specific service.

                 Cookies That We Use

    We use cookies for the following purposes related to the services we provide for and to you and our users:

    • authentication - we use cookies to identify users of the website and/or the location of individuals accessing the website;
    • status - we use cookies to help us to determine if you are logged into our website;
    • personalization - we use cookies to store information about your preferences and to personalize the website for you;
    • security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;
    • advertising - to help us to display advertisements that will be relevant to you in connection with our Services;
    • analysis - we use cookies to help us to analyze the use and performance of our website and services; and
    • cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally.

    To learn more about cookies, please visit http://www.allaboutcookies.org.

    To learn more For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

                 Cookies Used By Our Service Providers And Vendors

    Our service providers and vendors may use cookies and those cookies may be stored on your computer when you visit our website.  These service providers and vendors may include, but may not necessarily be limited to:

    Google Analytics (see https://support.google.com/analytics/answer/6004245?hl=en and information therein).

     

    • You should review the privacy and cookie policies of the above website(s) to learn more about the cookies that are used in connection with the above.
    • The above website(s) and cookies may change from time to time as we use different vendors or service providers to provide some or all of the services offered or provided by the above services and websites, or additional services we decide to include. While we will periodically update our list of such vendors and service providers, the above list may not be complete at any given time.   

    Managing Cookies

    1. Use of Web Beacons, Clear-GIFs, Pixel Tags and JavaScript
    • Except as set forth herein, our use of web beacons, clear-gifs, pixel tags and JavaScript is critical to proper functionality our website, and disabling them may impact the functionality of the website and the services we provide.
    • We also may use “pixel tags” (also called “action pixels,” “web beacons” or “clear gifs”) and/or JavaScript plug-ins, placed on the website and in our emails to you.
    • These web beacons and plug-ins are small graphic images (typically that you cannot see) or code on a website or in an email message which are used for such things as recording webpages or advertisements clicked-on by a user, or for tracking the performance of email marketing campaigns. These devices help us analyze our users’ online behavior and measure the effectiveness of our website and our marketing.
    • We may also work with third-party service providers that help us track, collect, and analyze this information.  Third-party entities with whom we have agreements may place these devices on the website and/or in emails to use information obtained from them such as pages viewed, emails opened and items upon which you may click in emails.  These third-party providers may also place cookies onto your computer. Those third-party cookies may enable us to obtain aggregate demographic information and user statistics about you and your preferences from these third-party sources as well as our information we have about you. See above for more information on our cookies.
    1. Server Logs

    A web “server log” is a record of activity created by a computer that delivers certain webpages to your browser.  Certain activities that you perform on our website may record information in server logs. For example, if you enter a search term on the website or enter your login information, the server log may record the search term, the link you clicked on to bring you to our website and/or information about your browser, such as your IP address and the cookies set on your browser.

    1. Search Queries on Our Website

    We may provide you with options to search for information on our website.  If you enter information in a search query box, we may store that information and we may aggregate that information with other information we may have about the browser and/or IP address from which the search query originated.

    1. Social Media Platforms

    We may link to certain Company social media platforms on Twitter®, TikTok®, LinkedIn®, Reddit®, Facebook®, YouTube®, Instagram® or other platforms.  When you engage with our content at or through these social media platforms, you may be asked to share certain information about these interactions with us.  Please review the privacy policies/notices and privacy settings with each such social media platform you use so you understand how this data and information may be used, and to choose your options for the sharing of such data and information. 

    1. How We Use Your Personal Data
    • We process your personal data identified in this Privacy Policy to provide the Services as defined above.
    • We may process your personal data identified in this Privacy Policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings, alternative dispute resolution or in an administrative or out-of-court procedure.
    • We may process your personal data identified in this Privacy Policy where necessary for the purposes of managing risks, or obtaining professional advice.
    • We may process your personal data identified in this Privacy Policy where such processing is necessary or advisable for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
    • We may also use the information we collect internally in our business for many business purposes, such as to: (i) provide the Services you may seek or which are available on the website; (ii) provide aggregated or other data to third parties concerning the results of your reporting and monitoring on and through the website, with or without other aggregated data; (iii) analyze trends and conduct research; (iv) provide support and respond to questions from our users, website visitors and customers; (v) improve our website; (vi) learn about users’ and customers’ needs; (vii) contact users for research, informational, and marketing purposes, including customizing our website; (viii) track traffic patterns and website usage; (ix) provide customer service and technical support; (x) correlate information with other commercially available information to identify demographics, reporting and monitoring needs, trail conditions, user impact and any other service or information offered on or through the website; (xi) provide specific relevant marketing, promotional, or other information to you; (xii) address information security and/or privacy practices, network functioning, engineering, and troubleshooting issues; (xiii) investigate claims and/or legal actions, violations of law or agreements, and compliance with relevant applicable laws and legal process; (xiv) comply with law, or based on our good faith belief that it is necessary to conform or comply with the law, or otherwise to disclose information to prevent fraud to reduce credit risks, to cooperate with police and other governmental authorities, or to protect the rights, property or safety of visitors to the website, our partners or customers, or the public; and (xv) process or engage in a sale of all or part of our business/organization(s), or if we go through a reorganization or merger.
    • We may also share personal data and non-personally identifiable information externally with our affiliates as well as with other third-party service providers who help us provide operational services for the website, which might include, but is not necessarily limited to: business entities that provide e-mail address management and communication contact services, network equipment and application management providers and hosting entities, judicial, administrative and/or legal or financial accounting providers in the event that information must be reviewed or released in response to civil and/or criminal investigations, claims, lawsuits, or if we are subject to judicial or administrative process (such as a subpoena) to release your information or to prosecute or defend legal actions, and other service providers which may be involved in the other types of services and activities otherwise discussed in this Privacy Policy.
    1. Providing Your Personal Data To Others
    • We may disclose your personal data to our officers, directors, employees, and agents insofar as reasonably necessary for the purposes, and on the legal bases, set out in this Privacy Policy, including to provide or potentially provide Services to you or for your benefit.
    • We may disclose your personal data to our professional advisers insofar as reasonably necessary for the purposes of managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings, ADR or in an administrative or out-of-court procedure.
    • We may disclose certain of your personal data to our suppliers and subcontractors pursuant to separate consent provided by you to us.
    • We may disclose certain of your personal data to our vendors and subcontractors in connection with providing our Services or our other permitted uses as set forth herein.
    • We may disclose your personal data to any senior living provider, organization, facility, institution, business, or company in which you live, with whom you are affiliated in any way, or from or about which you seek information on or through the website or any of our Services.
    • The foregoing disclosures are made insofar as reasonably necessary, and only to the extent required, for assisting us in providing our Services to you, storing data and in connection with the administration of our business.
    • In addition to the specific disclosures of personal data set out in this Section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings, alternative dispute resolution, or in an administrative or out-of-court procedure.
    • We do not sell your personal data to 3rd party vendors.
    1. Retaining And Deleting Personal Data
    • This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
    • Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
    • We will retain your personal data:
    • to the extent your personal data that we hold was obtained from data you knowingly, intentionally and manifestly made public or which is in the public domain independent of any act or action of us, it will be retained in that form for as long as it is needed or required for the purposes for which we obtained the information from the public record, or as otherwise required by applicable law;
    • to the extent your personal data that we hold was pulled by us and separated from data you knowingly, intentionally and manifestly made public or which is in the public domain independent of any act or action of us, it will be retained by us for as long as required by us for the purpose for which it was obtained and as required by our contractual requirements with third-party clients or as otherwise required by applicable law.
    • In some cases, it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based upon the performance of our Services, and any applicable industry and governmental standards.
    • We may also retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
    1. Amendments
    • We may update this Privacy Policy from time to time by publishing a new version on our website.
    • You should check this page occasionally to ensure you are happy with any changes to this Privacy Policy.
    • We may notify you of significant changes to this Privacy Policy by email or through the private messaging system on our website.
    1. Your RightsFOR CALIFORNIA RESIDENTS ONLY

    Requests for Information

    • Under Section 1798.83 of the California Civil Code, residents of California have the right to request from a business, with whom the California resident has an established business relationship, certain information with respect to the types of personal information the business shares with third parties for those third parties' direct marketing purposes, and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. To exercise your rights, you may make one request each year by emailing us at with "Request for California Privacy Information" in the subject line and explicitly makes such request. Be sure to provide in the request sufficient information to properly identify you and/or the members of your family to whom the request applies.

    Do Not Track Disclosure

    • As required by Section 22575 of the California Business and Professions Code, the following disclosure is made to California residents and to residents of other states:

     

    Our website does not alter its behavior or change its services when it receives a “do-not-track” flag or signal from your browser. As described herein, we use cookies and other tools to collect information about you when you visit our Website to, among other things, better tailor the features, performance and support of our products, services and website. After you leave our website, we do not track your online activity on other web sites, but third parties (and their affiliates) may track your online activity to offer you advertisements. This tracking is anonymous and is not linked to your personal information.

     

    California Consumer Privacy Act of 2018 Rights

    1. Marketing
    • We collect various types of personal data about you during the course of your relationship with us. Under California law, if you are a resident of California, you may make a written request to us to disclose the categories or personal data of yours which we have shared with third parties, for the third parties’ direct marketing purposes during the prior year. In response to your written request, we are allowed to provide you with a notice describing the cost-free means to opt-out of our sharing your information with third parties with whom we do not share the same brand name, if the third party will use such information for its direct marketing purposes.
    • If you would like to exercise your rights under California law, please send your written request to the e-mail address or postal address below with the words “CALIFORNIA OPT-OUT” in ALL CAPS in the subject line or clearly set forth elsewhere. Please include your postal address in your request. Within thirty (30) days of receiving your written request, we will provide you with a Third-Party Direct Marketing Opt-Out Form so you may request that your personal data not be disclosed to third parties for their direct marketing purposes.

    E-mail Address:

     

    support@hanksbelts.com

    Attention: PRIVACY OFFICER

     

    Postal Address:

     

    Hanks Belts

    3119 Pearl Street

    Endicott, NY 13760 (United States)

    Attention: PRIVACY OFFICER

     

    Phone:

    888-229-2358

     

    1. Consumer Rights
    • To the extent the California Consumer Privacy Act is applicable, with certain exceptions and, including in connection with data subject to federal regulation (i.e., the Health Insurance Portability and Accountability Act (HIPAA), the Gramm-Leach Bliley Act California (GLBA), the Fair Credit Reporting Act (FCRA), or the Drivers’ Privacy Protection Act (DPPA)), contractual rights and obligations, and certain other exceptions, California residents have the following rights with respect to our data collection and data processing of California residents’ personal data which is collected in California, processed in California, or part of a transaction occurring in California:

    (1)          The right to know whether your personal data was collected by us. In large part, the personal data we collect is set forth above in this Privacy Policy.

    (2)          The right to request the categories and specific pieces of personal data that we have collected about you in the past 12 months, the categories of sources for which that information is collected, the business purposes for collecting or selling the information, and the categories of third parties with whom the information is shared. 

    (3)          The right to know what information we are collecting about you and the purposes for which it is being used.  In large part, the type of information we collect and the purpose for which it is collected is set forth above in this Privacy Policy.

    (4)          The right to not allow us to sell any of your personal data.  We do not sell your personal data.

    (5)          The right to have your personal information deleted, subject to certain exceptions.

    (6)          The right to not be discriminated against for exercising any of the above rights.  We will not discriminate against you if you exercise any of the above rights.  However, as explained, some or all of our Services necessarily require us to process your personal information, and share your personal information with certain third parties in connection with providing the Services.  Therefore, and as explained above, exercise by you of certain of the above rights may impact our ability to provide the Services to you.

    TO THE EXTENT APPLICABLE, AND TO EXERCISE ANY OF THE ABOVE RIGHTS, PLEASE CONTACT US AT ANY OF THE BELOW AND INCLUDE THE WORDSCCPA RIGHTSIN ALL CAPS IN THE SUBJECT LINE, OR BE CLEAR BY PHONE THAT YOU WANT TO EXERCISE YOUR CCPA RIGHTS andCLEARLY LET US KNOW WHAT RIGHTS YOU SEEK TO EXERCISE.

    Website:

             https://www.hanksbelts.com

    Postal Address:

    Hanks Belts

    3119 Pearl Street

    Endicott, NY 13760 (United States)

    Attention: PRIVACY OFFICER

     

    Phone:

    888-229-2358

     

    1. Your Choices About Information We Collect
    • If you do not consent to the way in which we may use your personal information, please do not submit any personal information to us. Please note that if you do not provide us with certain personal information the Company may be unable to provide you with its Services, or those Services may not be as good as they otherwise could be.
    • If you do not wish to receive other marketing materials from us and/or if you do not want us to share your personal information with other entities as stated in this Privacy Policy, please provide us with your exact name and address and advise us that you wish to opt-out for any information sharing or receiving information from us or both as the case may be.  Please note that de-identified and aggregate data including your personal information may still be shared, but it will not be identified or identifiable to you. Please direct your opt-out request to the following contacts:

    Hanks Belts

    3119 Pearl Street

    Endicott, NY 13760 (United States)

                                    Attention: PRIVACY OFFICER (support@hanksbelts.com)

                   

                    With a copy (including the words “HANKS BELTS - Privacy” in the subject line) to:

     

                                                    OlenderFeldman LLP

                                                    422 Morris Avenue

                                                    Summit, NJ 07901 (United States)

                                                    Attention: Michael J. Feldman, Esq.

                                                    (mfeldman@olenderfeldman.com)

     

    [ADDITIONAL OPTIONS] You may opt out of our various communications as follows:

    E-mail Communications:  (1) click the unsubscribe link located in our emails, or (2) by emailing us at support@hanksbelts.com with Unsubscribe request in the subject line, or (3) by calling us at 888-229-2358 and clearly setting forth your request.

    Third-Party Sharing: (1) e-mail us at support@hanksbelts.com with the words “THIRD-PARTY E-MAIL REMOVAL” in the subject line, or (2) by calling us at 888-229-2358 and clearly setting forth your request.

    • Note that removal from third-party lists may take up to 6 months to be effective.

    Text/SMS Message Consent and Opt-Out: If you choose, you can provide your mobile phone number to receive text message alerts from the Company. By providing your mobile phone,  you are consenting to receive automated marketing text messages from us, but you can always purchase products from the Website without providing this consent.  Message and data rates may apply, and you should check the rates of your mobile carrier. You can opt out from further text marketing communications by texting STOP to the SMS number used by the Company to contact you.

    We may share your mobile phone number with service providers with our service providers to help us with the above activities, but not for their own marketing. We do not guarantee availability or performance of this text/SMS service, including liability for transmission delays or message failures.

    Please note that even once we comply with any of your requests as set forth above, de-identified and aggregate data including your personal data may still be shared, but it will not be identified or identifiable to you.

    1. Privacy of Children Who Visit the Website

    We recognize the importance of children’s safety and privacy. The website is not designed to attract children, and is not intended for use by any children under the age of 18. We do not request, or knowingly collect, any personally identifiable information from children under the age of 18.  If you are under age 18, you do not have permission to use this website or our Services.

    1. Links

    For your convenience, the website may contain links to other websites. We are not responsible for the privacy practices, advertising, products, or the content of such other websites. None of the links should be deemed to imply that we endorse or have any affiliation with the links.  You should review the privacy policies and Terms of Use of all other websites or links you visit.

    1. Security

    We believe in providing a safe and secure experience for all of our online visitors. To that end, we have implemented security measures to protect the information collected from you. We maintain reasonable physical and electronic safeguards designed to limit unauthorized access to your personally identifiable information, and to protect you against the criminal misuse of that information.

    While we use the foregoing security measures to protect your information, please note that no data transmitted over the Internet or stored and utilized for business purposes can be guaranteed to be completely secure.  No security measures are perfect or impenetrable. We cannot guarantee that only authorized persons will view your information. We cannot ensure that information you share on the website will not become publicly available. You can reduce these risks by using common sense security practices such as choosing a strong password, using different passwords for different services, and using up to date antivirus software.

    1. Questions / Changes in Notice

    If you have questions or concerns with respect to our Privacy Policy, you may contact us at support@hanksbelts.com. We may elect to change or amend our Privacy Policy; in such event, we will post the changes in our Privacy Policy on the website.