Privacy Policy (Rev. 133C579) 1 / 8

State of North Carolina Rev. 133C579



Version Date: May 01, 2018


Hankins Holdings LLC. DBA Hankins & Associates (“Company” or “we” or “us” or “our”) respects the

privacy of its users (“user” or “you”) that use our website located at,

including other media forms, media channels, mobile website or mobile application related or connected

thereto (collectively, the “Website”). The following Company privacy policy (“Privacy Policy”) is designed

to inform you, as a user of the Website, about the types of information that Company may gather about or

collect from you in connection with your use of the Website. It also is intended to explain the conditions

under which Company uses and discloses that information, and your rights in relation to that information.

Changes to this Privacy Policy are discussed at the end of this document. Each time you use the

Website, however, the current version of this Privacy Policy will apply. Accordingly, each time you use the

Website you should check the date of this Privacy Policy (which appears at the beginning of this

document) and review any changes since the last time you used the Website.

The Website is hosted in the United States of America and is subject to U.S. state and federal law. If you

are accessing our Website from other jurisdictions, please be advised that you are transferring your

personal information to us in the United States, and by using our Website, you consent to that transfer

and use of your personal information in accordance with this Privacy Policy. You also agree to abide by

the applicable laws of applicable states and U.S. federal law concerning your use of the Website and your

agreements with us. Any persons accessing our Website from any jurisdiction with laws or regulations

governing the use of the Internet, including personal data collection, use and disclosure, different from

those of the jurisdictions mentioned above may only use the Website in a manner lawful in their

jurisdiction. If your use of the Website would be unlawful in your jurisdiction, please do not use the





Users of the Website Generally

“Non-Personally-Identifying Information” is information that, without the aid of additional information,

cannot be directly associated with a specific person. “Personally-Identifying Information,” by contrast, is

information such as a name or email address that, without more, can be directly associated with a specific

person. Like most website operators, Company gathers from users of the Website Non-Personally-

Identifying Information of the sort that Web browsers, depending on their settings, may make available.

That information includes the user’s Internet Protocol (IP) address, operating system, browser type and

the locations of the websites the user views right before arriving at, while navigating and immediately after

leaving the Website. Although such information is not Personally-Identifying Information, it may be

possible for Company to determine from an IP address a user’s Internet service provider and the

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geographic location of the visitor’s point of connectivity as well as other statistical usage data. Company

analyzes Non-Personally-Identifying Information gathered from users of the Website to help Company

better understand how the Website is being used. By identifying patterns and trends in usage, Company

is able to better design the Website to improve users’ experiences, both in terms of content and ease of

use. From time to time, Company may also release the Non-Personally-Identifying Information gathered

from Website users in the aggregate, such as by publishing a report on trends in the usage of the


Web Cookies

A “Web Cookie” is a string of information which assigns you a unique identification that a website stores

on a user’s computer, and that the user’s browser provides to the website each time the user submits a

query to the website. We use cookies on the Website to keep track of services you have used, to record

registration information regarding your login name and password, to record your user preferences, to

keep you logged into the Website and to facilitate purchase procedures. Company also uses Web

Cookies to track the pages that users visit during each Website session, both to help Company improve

users’ experiences and to help Company understand how the Website is being used. As with other Non-

Personally-Identifying Information gathered from users of the Website, Company analyzes and discloses

in aggregated form information gathered using Web Cookies, so as to help Company, its partners and

others better understand how the Website is being used. COMPANY USERS WHO DO NOT WISH TO






Third-Party Advertisers

We may use third-party advertising companies to serve ads when you visit the Website. These

companies may use information (not including any Personally-Identifying Information) about your visits to

the Website and other websites that are contained in Web Cookies in order to provide advertisements

about goods and services of interest to you. Using a tool created by the Network Advertising

Initiative, you can opt out of several third-party ad servers’ and networks’ Web Cookies simultaneously. If

you would like more information about this practice and to know your choices about not having this

information used by these companies, please follow the following


or Please contact us if you would like to know the identity of the thirdparty

advertising companies we are currently using to serve ads.

We may allow advertisers to choose the characteristics of users who will see their advertisements, and

we may use any of the Non-Personally Identifying Information we have collected (including information

you may have decided not to show to other users, such as your birth year or other sensitive personal

information or preferences) to select the appropriate audience for those advertisements. We do not

identify you to the advertiser.

Web Beacons

A “Web Beacon” is an object that is embedded in a web page or email that is usually invisible to the user

and allows website operators to check whether a user has viewed a particular web page or an email.

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Company may use Web Beacons on the Website and in emails to count users who have visited particular

pages, viewed emails and to deliver co-branded services. Web Beacons are not used to access users’

Personally-Identifying Information. They are a technique Company may use to compile aggregated

statistics about Website usage. Web Beacons collect only a limited set of information, including a Web

Cookie number, time and date of a page or email view and a description of the page or email on which

the Web Beacon resides. You may not decline Web Beacons. However, they can be rendered ineffective

by declining all Web Cookies or modifying your browser setting to notify you each time a Web Cookie is

tendered, permitting you to accept or decline Web Cookies on an individual basis.


We may use third-party vendors, including Google, who use first-party cookies (such as the Google

Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize

and serve ads based on your past activity on the Website, including Google Analytics for Display

Advertising. The information collected may be used to, among other things, analyze and track data,

determine the popularity of certain content and better understand online activity. If you do not want any

information to be collected and used by Google Analytics, you can install an opt-out in your web browser

( and/or opt out from Google Analytics for Display Advertising

or the Google Display Network by using Google’s Ads Settings (

Aggregated and Non-Personally-Identifying Information

We may share aggregated and Non-Personally Identifying Information we collect under any of the above

circumstances. We may also share it with third parties and our affiliate companies to develop and deliver

targeted advertising on the Website and on websites of third parties. We may combine Non-Personally

Identifying Information we collect with additional Non-Personally Identifying Information collected from

other sources. We also may share aggregated information with third parties, including advisors,

advertisers and investors, for the purpose of conducting general business analysis. For example, we may

tell our advertisers the number of visitors to the Website and the most popular features or services

accessed. This information does not contain any Personally-Identifying Information and may be used to

develop website content and services that we hope you and other users will find of interest and to target

content and advertising.

Mobile Device Additional Terms

 • Mobile Device. If you use a mobile device to access the Website or download any of our

applications, we may collect device information (such as your mobile device ID, model and

manufacturer), operating system, version information and IP address.

 • Geo-Location Information. Unless we have received your prior consent, we do not access or

track any location-based information from your mobile device at any time while downloading or

using our mobile application or our services, except that it may be possible for Company to

determine from an IP address the geographic location of your point of connectivity, in which case

we may gather and use such general location data.

 • Push Notifications. We send you push notifications if you choose to receive them, letting you

know when someone has sent you a message or for other service-related matters. If you wish to

opt-out from receiving these types of communications, you may turn them off in your device’s


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 • Mobile Analytics. We use mobile analytics software to allow us to better understand the

functionality of our mobile software on your phone. This software may record information, such as

how often you use the application, the events that occur within the application, aggregated usage,

performance data and where the application was downloaded from. We do not link the

information we store within the analytics software to any Personally-Identifying Information you

submit within the mobile application.


We may provide you the option to connect your account on the Website to your account on some social

networking sites for the purpose of logging in, uploading information or enabling certain features on the

Website. When logging in using your social network credentials, we may collect the Personally-Identifying

Information you have made publicly available on the social networking site, such as your name, profile

picture, cover photo, username, gender, friends network, age range, locale, friend list and any other

information you have made public. Once connected, other users may also be able to see information

about your social network, such as the size of your network and your friends, including common friends.

By connecting your account on the Website to your account on any social networking site, you hereby

consent to the continuous release of information about you to us. We will not send any of your account

information to the connected social networking site without first disclosing that to you. Each social

network may further allow you to set privacy controls around your information on their system, and our

collection of information will always follow such controls and permissions. This feature is subject to

continuous change and improvement by us and each social networking site involved, and therefore the

available features and shared information are subject to change without notice to you.

We may use hyperlinks on the Website which will redirect you to a social network if you click on the

respective link. However, when you click on a social plug-in, such as Facebook’s “Like” button, Twitter’s

“tweet” button or the Google+, that particular social network’s plugin will be activated and your browser

will directly connect to that provider’s servers. If you do not use these buttons, none of your data will be

sent to the respective social network’s plugin provider. So for example, when you click on the Facebook’s

“Like” button on the Website, Facebook will receive your IP address, the browser version and screen

resolution, and the operating system of the device you have used to access the Website. Settings

regarding privacy protection can be found on the websites of these social networks and are not within our



Website Registration

As defined above, Personally-Identifying Information is information that can be directly associated with a

specific person. Company may collect a range of Personally-Identifying Information from and about

Website users. Much of the Personally-Identifying Information collected by Company about users is

information provided by users themselves when (1) registering for our service, (2) logging in with social

network credentials, (3) participating in polls, contests, surveys or other features of our service, or

responding to offers or advertisements, (4) communicating with us, (5) creating a public profile or (6)

signing up to receive newsletters. That information may include each user’s name, address, email

address and telephone number, and, if you transact business with us, financial information such as your

payment method (valid credit card number, type, expiration date or other financial information). We also

may request information about your interests and activities, your gender, age, date of birth, username,

 Privacy Policy (Rev. 133C579) 5 / 8

hometown and other demographic or relevant information as determined by Company from time to time.

Users of the Website are under no obligation to provide Company with Personally-Identifying Information

of any kind, with the caveat that a user’s refusal to do so may prevent the user from using certain Website





Online Postings

Certain Personally-Identifying Information collected from users may be disclosed as a matter of course as

a result of your use of the Website. We may provide areas on the Website where you can post reviews

and other information relating to your activities on the Website. Such postings are governed by our Terms

of Use. In addition, such postings may appear on other websites or when searches are executed on the

subject of your posting. Also, whenever you voluntarily disclose personal information on publicly-viewable

web pages, that information will be publicly available and can be collected and used by others. For

example, if you post your email address, you may receive unsolicited messages. We cannot control who

reads your posting or what other users may do with the information you voluntarily post, so we encourage

you to exercise discretion and caution with respect to your personal information. USERS ASSUME ALL



Company Communications

We may occasionally use your name and email address to send you notifications regarding new services

offered by the Website that we think you may find valuable. We may also send you service-related

announcements from time to time through the general operation of the service. Generally, you may opt

out of such emails at the time of registration or through your account settings, though we reserve the right

to send you notices about your account, such as service announcements and administrative messages,

even if you opt out of all voluntary email notifications.

Company Disclosures

Company will disclose Personally-Identifying Information under the following circumstances:

 • By Law or to Protect Rights. When we believe disclosure is appropriate, we may disclose

Personally-Identifying Information in connection with efforts to investigate, prevent or take other

action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the

rights, property or safety of Company, our users, our employees or others; to comply with

applicable law or cooperate with law enforcement; to enforce our Terms of Use or other

agreements or policies, in response to a subpoena or similar investigative demand, a court order

or a request for cooperation from a law enforcement or other government agency; to establish or

exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such

cases, we may raise or waive any legal objection or right available to us.

 • Third-Party Service Providers. We may share your Personally-Identifying Information, which

may include your name and contact information (including email address) with our authorized

service providers that perform certain services on our behalf. These services may include fulfilling

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orders, providing customer service and marketing assistance, performing business and sales

analysis, supporting the Website’s functionality and supporting contests, sweepstakes, surveys

and other features offered through the Website. We may also share your name, contact

information and credit card information with our authorized service providers who process credit

card payments. These service providers may have access to personal information needed to

perform their functions but are not permitted to share or use such information for any other


 • Business Transfers; Bankruptcy. Company reserves the right to transfer all Personally-

Identifying Information in its possession to a successor organization in the event of a merger,

acquisition, bankruptcy or other sale of all or a portion of Company’s assets. Other than to the

extent ordered by a bankruptcy or other court, the use and disclosure of all transferred

Personally-Identifying Information will be subject to this Privacy Policy, or to a new privacy policy

if you are given notice of that new privacy policy and are given an opportunity to affirmatively optout

of it. Personally-Identifying Information submitted or collected after a transfer, however, may

be subject to a new privacy policy adopted by the successor organization.

Changing Personally-Identifying Information; Account Termination

You may at any time review or change your Personally-Identifying Information by going to your account

settings (if applicable) or contacting us using the contact information below. Upon your request, we will

deactivate or delete your account and contact information from our active databases. Such information

will be deactivated or deleted as soon as practicable based on your account activity and accordance with

our deactivation policy and applicable law. To make this request, either go to your account settings (if

applicable) or contact us as provided below. We will retain in our files some Personally-Identifying

Information to prevent fraud, to troubleshoot problems, to assist with any investigations, to enforce our

Terms of Use and to comply with legal requirements as is permitted by law. Therefore, you should not

expect that all your Personally-Identifying Information will be completely removed from our databases in

response to your requests. Additionally, we keep a history of changed information to investigate

suspected fraud with your account.

General Use

Company uses the Personally-Identifying Information in the file we maintain about you, and other

information we obtain from your current and past activities on the Website (1) to deliver the products and

services that you have requested; (2) to manage your account and provide you with customer support; (3)

to communicate with you by email, postal mail, telephone and/or mobile devices about products or

services that may be of interest to you either from us, our affiliate companies or other third parties; (4) to

develop and display content and advertising tailored to your interests on the Website and other sites; (5)

to resolve disputes and troubleshoot problems; (6) to measure consumer interest in our services; (7) to

inform you of updates; (8) to customize your experience; (9) to detect and protect us against error, fraud

and other criminal activity; (10) to enforce our Terms of Use; and (11) to do as otherwise described to you

at the time of collection. At times, we may look across multiple users to identify problems. In particular, we

may examine your Personally-Identifying Information to identify users using multiple user IDs or aliases.

We may compare and review your Personally-Identifying Information for accuracy and to detect errors

and omissions. We may use financial information or payment method to process payment for any

purchases made on the Website, enroll you in the discount, rebate, and other programs in which you

elect to participate, to protect against or identify possible fraudulent transactions and otherwise as needed

to manage our business.

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Company contractually prohibits its contractors, affiliates, vendors and suppliers from disclosing

Personally-Identifying Information received from Company, other than in accordance with this Privacy

Policy. However, third parties are under no obligation to comply with this Privacy Policy with respect to

Personally-Identifying Information that users provide directly to those third parties, or that those third

parties collect for themselves. These third parties include advertisers, providers of games, utilities,

widgets and a variety of other third-party applications accessible through the Website. Company neither

owns nor controls the third-party websites and applications accessible through the Website. Thus, this

Privacy Policy does not apply to information provided to or gathered by the third parties that operate

them. Before visiting a third party, or using a third-party application, whether by means of a link on the

Website, directly through the Website or otherwise, and before providing any Personally-Identifying

Information to any such third party, users should inform themselves of the privacy policies and practices

(if any) of the third party responsible for that website or application, and should take those steps

necessary to, in those users’ discretion, protect their privacy.


We take the security of your Personally-Identifying Information seriously and use reasonable electronic,

personnel and physical measures to protect it from loss, theft, alteration or misuse. However, please be

advised that even the best security measures cannot fully eliminate all risks. We cannot guarantee that

only authorized persons will view your information. We are not responsible for third-party circumvention of

any privacy settings or security measures.

We are dedicated to protect all information on the Website as is necessary. However, you are responsible

for maintaining the confidentiality of your Personally-Identifying Information by keeping your password

confidential. You should change your password immediately if you believe someone has gained

unauthorized access to it or your account. If you lose control of your account, you should notify us



Company may, in its sole discretion, change this Privacy Policy from time to time. Any and all changes to

Company’s Privacy Policy will be reflected on this page and the date new versions are posted will be

stated at the top of this Privacy Policy. Unless stated otherwise, our current Privacy Policy applies to all

information that we have about you and your account. Users should regularly check this page for any

changes to this Privacy Policy. Company will always post new versions of the Privacy Policy on the

Website. However, Company may, as determined in its discretion, decide to notify users of changes

made to this Privacy Policy via email or otherwise. Accordingly, it is important that users always maintain

and update their contact information.


The Children's Online Privacy Protection Act ("COPPA") protects the online privacy of children under 13

years of age. We do not knowingly collect or maintain Personally-Identifying Information from anyone

under the age of 13, unless or except as permitted by law. Any person who provides Personally Privacy

Policy (Rev. 133C579) 8 / 8

Identifying Information through the Website represents to us that he or she is 13 years of age or older. If

we learn that Personally-Identifying Information has been collected from a user under 13 years of age on

or through the Website, then we will take the appropriate steps to cause this information to be deleted. If

you are the parent or legal guardian of a child under 13 who has become a member of the Website or has

otherwise transferred Personally-Identifying Information to the Website, please contact Company using

our contact information below to have that child's account terminated and information deleted.


California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who

are California residents to request and obtain from us, once a year and free of charge, information about

the Personally-Identifying Information (if any) we disclosed to third parties for direct marketing purposes in

the preceding calendar year. If applicable, this information would include a list of the categories of the

Personally-Identifying Information that was shared and the names and addresses of all third parties with

which we shared Personally-Identifying Information in the immediately preceding calendar year. If you are

a California resident and would like to make such a request, please submit your request in writing to our

privacy officer as listed below.


Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or

setting you can activate to signal your privacy preference not to have data about your online browsing

activities monitored and collected. Because there is not yet a common understanding of how to interpret

the DNT signal, the Website currently does not respond to DNT browser signals or mechanisms.


If you have any questions regarding our Privacy Policy, please contact our Privacy Officer at:

Hankins Holdings LLC. DBA Hankins & Associates

Attn: Privacy Officer

240 Laura Ave

Archdale, NC 27263


Phone: (336) 252-5329

Fax: (336) 858-5794