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Privacy Policy

Last updated: April 1, 2021

Privacy Policy

 

Effective Date and Last Updated: February 3, 2023

 

Hanky Panky Ltd. (“Hanky Panky”) understands that our customers and visitors to www.hankypanky.com and any other sites that we operate under the Hanky Panky® brand are concerned about how personal information is collected and used. Please be assured that we take privacy very seriously.  This notice describes our Privacy Policy, which covers the personal information that we collect on our website, from phone customers, and from other sources. By accessing and using our website or purchasing products from Hanky Panky, you are agreeing to our collection and uses of your personal information as described by this Privacy Policy. The Privacy Policy may be updated from time to time. You should check the date of the policy and review any changes since the last version.

 

While we strive to manage various privacy laws consistently, some terms, obligations, and rights only apply or may be available to those who live in certain jurisdictions. Use of the term “right” in this Privacy Policy (and any supplements) is not intended to and shall not confer any legal rights or remedies on any person or party, and any such rights or remedies shall only exist to extent expressly provided under applicable law.

 

California residents:  Please Click Here for supplemental information that may apply to you.

Email marketing:  To learn about our email marketing activities and how to unsubscribe, Click Here.

 

Information Collected & Sources

We may collect your:

  • Contact and registration information (such as name, email address, postal address, phone number, and birthday)
  • Physical characteristics (such as garment sizes that were ordered)
  • Payment information when you buy our products (such as the credit or debit card numbers and expiration dates),
  • Protected classification (your sex or gender, if you provide it to us)
  • Internet activity (including (a) how you interact with our sites, such as product searches, time spent browsing certain products, items you place into your cart, and pages that you visit; (b) information about your interactions on social media that identifies us through hashtags or using our social media handles, and (c) technical data received from your device, such as IP address of individuals that visit our site, referring websites, and similar technical data),
  • Geolocation data (your city and state it is apparent from the address you provide, the internet address from which you visit our sites, or the phone number used to call us), and
  • De-identified data. We may generate and use de-identified data (or anonymized or aggregate information) which cannot reasonably be used to identify you. We will maintain and use this data only in a de-identified form and will not attempt to re-identify such data, except as permitted by applicable law. The aggregated or anonymized data is no longer personal information governed by this Privacy Policy.
  • Commercial information. We may generate internal customer identifiers (like a customer or account ID) to keep track of and manage your transactions online or by phone and relationships with us and collect commercial information, such as records of products purchased, requested, considered, exchanged, or returned, and other purchasing or consuming histories and tendencies. We may draw inferences about you from the other types of information we collect reflecting your interests, preferences, online behaviors, and characteristics.
  • All of the above have been collected and disclosed to our service providers for a business purpose during the last 12 months, such as:
    • provide the products and services you purchase and request
    • respond to your inquiries and provide customer service
    • operate and improve online services
    • personalize online content and experiences
    • market and advertise
    • maintain safety in our stores and combat illegal activities
    • comply with legal obligations

We may collect your personal information from the following sources:

  • From you, when you provide it to us. We collect your information when you purchase our products online or over the phone, contact our customer support, fill out forms on our website, create an account with us, sign up for mailing lists, participate in promotions or surveys, or otherwise provide us your information. 
  • When someone else provides it to us. We may also receive your name and email from your friends who type them into our site’s “Email this style to a friend” and similar features, but we use this just to send the forwarding email without keeping your information.
  • When you use our branded sites. We use tools that help us improve our business by analyzing how our customers interact with us and our branded sites.
  • From our service providers and business partners. When you interact with our service providers and business partners, they may collect information from you and provide that information to us. We may then use that information according to this Privacy Policy.
  • When transmitted automatically by your browser or device. Internet-connected devices that visit our sites automatically transmit technical and device data, settings, software and hardware versions, referring websites, and unique device identifiers (depending on your settings).
  • Other third parties. Third-party data suppliers (such as data aggregators and data resellers) may supply us with internet and network activity information, demographic information, and other information that helps us recognize and learn more about you and other users of our online services.

 

Purposes for Collection and Use of Information

Hanky Panky collects information in an effort to improve your shopping experience and that allows us to communicate with you about our products, services, contests and promotions.  In the case of placing orders, we require your personal information because without it, we cannot process your order.  Providing us other information may be voluntary, and you can instruct us not to use your information for marketing purposes by following instructions in this Privacy Policy.   

 

We may use your personal information in the following ways:

- To process, confirm, fulfill, ship, track and secure payment for your order.  We may contact you via email, mail or phone if we have questions about your order or payment.

- To provide you a history of your purchases.

- To administrative our rewards program, Panky Points™.

- To remarket our products through advertising networks.

- If you joined our email marketing list, to communicate with you by email about our products, services, contests, and promotions.

- To administer and fulfill our contests and other promotions.

- To inform others of customer satisfaction with the quality of our products and services.

- To help us learn more about your general shopping preferences, personalize online content and experience.

- To help us improve and address problems with our site design, products and services.

- To enhance your shopping experience.

- To analyze trends and statistics.

- To protect the security and integrity of our websites and our business.

- To detect, protect against and investigate fraud, theft or threats to any individuals.

- For system administration.

- To contact you for reasonable business purposes, including for material changes to our privacy policy.

- To meet our legal obligations, protect our legal rights, respond to court orders and other legal process, and as permitted by law, make disclosures to address unlawful or other act that may endanger the health, safety or privacy of other customers or the general public.

 

If we use service providers outside the United States, then your personal information may be sent outside U.S. borders and may be subject to additional local laws regarding personal information. 

 

Request to opt-out of certain uses of your personal information:

We may share personal information with other parties to provide analytics services and serve ads on our behalf targeted to your interests and based on your online activities. Information may be linked to your browser or device (like cookies and similar tracking technologies) and related to you if you have a customer account or interact with us in other ways. These parties may use the information for their own marketing and to offer products and services on our online services.

 

Your personal information is not shared for money, but certain uses may be deemed the “sale” or “sharing” of personal information under applicable privacy laws.

 

Click "Do Not Sell or Share My Personal Info" located at the bottom of our websites and within our mobile apps, to opt-out of these uses of your personal information.

 

Third Party Service Providers; Disclosure for a Business Purpose

Our third party service providers are our vendors that provide services to us directly or to you on our behalf and that receive your personal information in order to provide those services.  We may share your information with third parties with your consent or at your request. For example, we run our online platform through a service provider that may receive your personal information to help us run our business.  We also provide your name and shipping information to one or more shipping services providers, so that they may deliver your order.  We use a third party payment provider to process your cardholder data when you make purchases online or over the phone.  We also use an e-mail list to conduct marketing for Hanky Panky® products, which may be shared with third party service providers that provide us email distribution, digital marketing, and other services.  (For more information on marketing, see the section below titled “Marketing email communications”.) If you've signed up for mobile text messaging offers, with your consent, we may send push notifications or alerts to your mobile device. If decide later you no longer wish to receive these offers, simply follow the opt-out instructions included in the mobile message. If you interact with social media widgets, share content using social media share buttons or access features of our online services that contain content or features provided by social media platforms, the relevant social media platforms may collect or have access to personal information. (Please review the privacy policies of the social media platforms you interact with as we are not responsible for their privacy policies.) We also use a third party service provider that performs website analytics that help make intelligent product recommendations for you while you use our site based on the pages and products you view.  We also engage advertising networks as service providers to provide online advertising and marketing services.  (For more information on online advertising, see the section below titled “Advertising Networks and Online Marketing”.)

 

Some of our third party service providers also provide services directly to consumers.   If you use any consumer-facing applications or services from businesses that collect personal information and also happen to be our service providers, this Privacy Policy will not apply to that information.  We encourage you to read the privacy notices of every business to which you provide your personal information.

 

We reserve the right to transfer any of the information we have about you to proceed with the consideration, negotiation, or completion of a sale or transfer of all or a portion of our business or assets to a third party, such as in the event of a merger, acquisition, or other disposition, or in connection with a bankruptcy reorganization, dissolution, or liquidation.

 

Children’s Privacy

Hanky Panky is protective of the privacy of young children and we do not knowingly collect any personal information from a child under 13. We do not sell products for purchase by children and any children's products that we may sell are for purchase only by an adult. Our website is not directed at children under 13 and does not knowingly collect any personal information from children under 13.  We reserve the right to delete without notice, obligation or liability all information of children that may be provided on our website.

Marketing email communications

Our website provides you the option to join our email list and receive information about our products, services and offers.  If you do not wish to receive Hanky Panky marketing emails, you may use any of several options to unsubscribe: click the “Unsubscribe” link in our marketing emails, call us toll-free at 877.447.4811 during regular east coast business hours, or email us at contact-us@hankypanky.com with the following:

 

  • The phrase "Unsubscribe" in the subject line
  • Your name and email address

 

You can also unsubscribe via postal mail by writing to:

 

Hanky Panky Ltd.

Customer Relations

373 Park Avenue South – 12th floor

New York, NY 10016

 

Please be aware that it can take several business days to remove you from our email marketing list. NOTE:  You will continue to receive order confirmation, shipping status or other transactional emails.

 

Use of ‘Cookies’

Hanky Panky uses cookies and other tools and code on our websites, for three purposes: (1) to help enhance your experience on our website, (2) use website analytics tools, and (3) to participate in personalized advertising.

What Are Cookies?

A cookie is a small data file stored on your hard drive by websites that sends information back to those websites to enable certain functionality, which may include a unique user ID to recognize you.  Related tools include a pixel tag, also known as a clear GIF or web beacon, which an invisible tag placed on certain pages of our site and can track your visits by placing and reading cookies on your computer.  Most web browsers allow you to refuse to accept cookies; refer to your browser’s help documentation for more information.  But note that if you turn off cookies or refuse to accept them, this is likely have a negative impact on the usability of our website and many other websites.  Your browser documentation can also help you delete existing cookies.

Enhance Your Website Experience.

We may use cookies to recognize your repeat visit, preserve the contents of your shopping bag, recognizing the accounts of our registered users, track your movement on our site, and measure activity on our site to determine our most popular areas and features.

Web Analytics

We use a service called Google Analytics to improve our understanding of how visitors interact with us online.  This service is provided by Google, Inc. and collects information and reports website trends without directly identifying individual visitors.  It uses cookies to help track how you use our website.  We can view a variety of reports about how visitors interact with our website so we can improve our website and how people find it.  Please click on the link to learn more about this service: http://www.google.com/analytics.  From time to time, we may use other service providers to help us with tracking cookies.

Advertising Networks and Online Marketing

Hanky Panky does not track your online activity across third party Web sites or online services. However, like many ecommerce businesses, we partner with third party advertising networks to support our marketing activities.  We currently use networks operated by Google (DoubleClick) and Microsoft.  The advertising networks use small bits of code called “cookies” or “pixels” that we place on our sites to enable the networks to help market our products online.  These use anonymous unique identifiers and Hanky Panky does not provide your name or other identified information to the advertising networks, and the networks do not send us information about your external online activity.  If you click an ad, the browser on your computer or device may tell us the website where you clicked the ad. 

 

You can avoid certain targeted marketing by disabling cookies in your browser for our site or for all sites.  However, you may lose functionality if you disable cookies.  If you leave cookies enabled, you consent to our use of such third party advertising vendors and services, to their placement of cookies onto your computer, and to the privacy policies of the third party advertising networks.  You agree that if you leave cookies enabled, Hanky Panky is not responsible for how the third party advertisers use your information.  Further, as new technologies are developed, we cannot promise that your online activity will never be tracked, such as by the company that developed your Internet browser.

 

If you desire to learn more about third party advertising networks, cookies, and opt-outs, please visit the Digital Advertising Alliance at http://optout.aboutads.info/ and https://www.networkadvertising.org/understanding-online-advertising/what-are-my-options/, and the Network Advertising Initiative at https://www.networkadvertising.org/understanding-online-advertising/what-are-my-options.

Do Not Track signals

Because there is no standard understanding of what a “Do Not Track” browser signal is supposed to mean, our website does not respond to those signals in any particular way.  To avoid tracking cookies, you may use an “incognito”, “private” or similar browser window to browse the Internet without tracking cookies.  However, the software manufacturer of your browser may still track your activity.

 

Security and SSL

Protecting your order information is a priority for us. We use Secure Sockets Layer (SSL) technology to protect the security of information you transmit to us through a web browser.  However, because of the inherent nature of the Internet, we cannot guarantee that data you exchange with us will always remain completely secure.  Third parties and bad actors may intercept or access transmissions or private communications unlawfully. While we strive to protect your personal information, neither Hanky Panky nor any of our service providers can ensure or warrant the security of any information you transmit to us over the internet. Any such transmission is done at your own risk.

 

Links to Other Sites

Our website may contain links to sites other than our own. Those sites may have their own privacy policies. Neither we nor any of our service providers shall have any responsibility for those sites and we provide these links solely for the convenience of our visitors. We encourage you to review the privacy policies and terms of use of any third-party sites or services before providing any of them with any of your personal information.

 

Accessing our web site from outside the U.S.

If you are visiting hankypanky.com from a location outside the United States, you will be connected through and to servers located within the United States. We currently accept online orders only from customers in the United States. By providing your information to us, you agree that all personal information will be used in accordance with this privacy policy and pursuant to U.S. law.

 

Privacy Policy Updates

We may update this Privacy Policy from time to time. Whenever we make a change, we will post the updated policy at this site and we encourage you to check our policy periodically.  Sometimes we may use an overlay or splash screen if we change our privacy policy.  If we make a material change to our privacy policy, we will at our option either honor our prior policy for information already collected, or we will ask for your consent to the change. If you have any questions or concerns regarding our privacy policy, please contact us:

 

  • By email: contact-us@hankypanky.com
  • By phone: 1.877.447.4811 during regular east coast business hours
  • By mail: Hanky Panky Ltd., 373 Park Avenue South – 12th floor, New York, NY 10016

 

Contacting Us

Please address any questions regarding our Privacy Policy or our practices concerning Personal Information by writing to:

 

Hanky Panky Ltd.

Attn: Privacy Officer

373 Park Avenue South -12th floor

New York, NY 10016

 

Please include information in your communication to us that will help us identify your account so we can assist you with your inquiry or request.

 

Applicable Law

The laws of the State of New York will govern this Privacy Policy without giving effect to any principles of conflict of law. By using our website, you agree to bring all claims and actions relating to or arising out of this website or your purchases exclusively in courts seated in or having jurisdiction over New York County in the State of New York in the United States.

 

California Privacy Disclosures and Rights Granted to California Residents

Your Rights Under California Law.  If you are a resident of California, you have the following rights concerning your personal information:

 

  • Right to be informed about the (1) types of personal information we collect about you, (2) specific pieces of information that we have collected about you, (3) sources and purposes of the collection, and (4) third parties that receive your data.
  • Right to request deletion of your data.
  • Right to know to whom we’ve sold or disclosed your data.
  • Right to opt out of the sale of your data.
  • Right against discrimination if you do not provide us your data, unless the goods and services we provide you are related to the value of the data you provide us.

 

Exercising Your Rights

Opting Out of “Sales” Information

We do not sell your personal information in exchange for monetary compensation. We may share your personal information by allowing certain third to collect your personal information via automated technologies on our Services for cross-context behavioral advertising purposes. This kind of sharing may be considered a “sale” under the CCPA/CPRA when the personal information is exchanged for non-monetary consideration. You have the right to opt out of these types of disclosures of your information. 

 

To specify your opt-out preferences, visit Do Not Sell or Share My Personal Info. We will not deny, charge different prices for, or provide a different level or quality of goods or services, if you choose to exercise these rights.

 

Opting Out of Information Disclosures to Unaffiliated Third Parties

In addition to the rights mentioned above under California law, we provide you with a 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 that third party will use it for its own direct marketing purposes.

 

If you would like to exercise this right under California law, please click here to fill out our online form to indicate your sharing preferences.

 

If you have general questions about your rights, contact us via:

  • Call us toll-free at 877.447.4811 during regular east coast business hours
  • Email us at contact-us@hankypanky.com with your request
  • Send us postal mail to: Hanky Panky Ltd., Attn: Privacy & Customer Relations,
  • 373 Park Avenue South – 12th Floor,
  • New York, NY 10016

 

Verification Process.  You may submit your California rights requests using any of the methods above.  However, for certain requests, California law permits or requires us to take additional steps to verify the identity and authority of the individual making certain requests information.  This is so we can protect your privacy and data.  Depending on the request or the sensitivity of the request, Hanky Panky may ask that you provide two, three or more pieces of personal information that matches information in our records, so that we may confirm your identity prior to processing your request. 

 

Authorized Agent.  If you wish to submit a request through an authorized agent, then you may designate your authorized agent in writing by contacting us using any of the methods above and providing the following information:

  1. Your full name and date of birth
  2. Current address and telephone number
  3. Name of the authorized agent
  4. State whether the requested information should be delivered to the agent or to you. Provide delivery instructions.
  5. State the types of requests that you authorize your agent to make, for example, Request to Know, Request to Delete, or Request to Opt-Out of Sales of Personal Information.
  6. Sign and date the agent authorization.

If any of the above information is missing or cannot be verified, then we may request the information before processing your request.  We may request additional verification information depending on the nature or sensitivity of the request. 

 

Third Party Marketing.  Under California law, customers of Hanky Panky who are residents of California may request certain information about our disclosure of personal information during the prior calendar year to third parties for their direct marketing purposes. During the last 12 months, we may have used the personal information we collect for the following business or commercial purposes:

Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing services, providing analytics services, providing storage or providing similar services

Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance

Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your current interaction with us

Helping to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for these purposes

Debugging to identify and repair errors that impair existing intended functionality

Undertaking internal research for technological development and demonstration

Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

 

To make specific request regarding disclosure of personal information, please write to us at the following address:

 

Hanky Panky Ltd.

Customer Relations

373 Park Avenue South – 12th floor

New York, NY 10016

 

Alternatively, you may send us an email at contact-us@hankypanky.com with the words "California Privacy Rights" in the subject line.

 

No Sale of Minor Information.  Hanky Panky does not have actual knowledge of any sale of the personal information of minors under 16 years of age.