PRIVACY & SECURITY POLICIES

Effective June 14, 2012
Your privacy is very important to us at BACOR, Inc. and Handbag Handcuff® and we are committed to protecting it. We created this Privacy & Security Policy and it applies only to HandbagHandcuff.com (the “Site”) and the products and services that are available from our Site, and does not apply to other websites to which we may link.

A more detailed description of our policies and practices follows below.

Your Consent to Accept the Terms of this Privacy & Security Policy

“Handbag Handcuff®,” “us,” “our” or “we” means BACOR, Inc. and its subsidiaries and affiliates. By using the Site, you are agreeing to this Privacy & Security Policy. If you do not agree with the terms of this Privacy & Security Policy, then you are not authorized to use this Site.

We will take reasonable steps to protect the security of the personal information we collect from you, however, if you do not agree with the terms of this Privacy & Security Policy, then please do not provide any personal information to us. You have the option to withhold or withdraw your consent, or abstain from providing us with certain required personal information, however, this may result in our not being able to provide you with products or services.

What Is My Personal Information?

Your personal information means your name, email and mailing addresses, telephone number, billing and account information, shipping address and other incidental information needed to provide you with products or services (for example address information needed for verification during the credit card authorization process). Your personal information may also include email address information about others that you have referred to be a friend of our Site.

How Do I Access and Update My Personal Information and Preferences?

If you are a registered user of the Site, you can access and update your personal information in My Account from the top navigational bar on our home page once you have logged onto our Site. My Account contains your name, email address, and other information that may be stored for ease of use in navigating the Site. You can modify your preferences in My Account, such as choosing to receive email or other communications from us by selecting or de-selecting the options presented to you. Please visit My Account to review your personal information.

When Is Personal Information Collected?

You can visit certain areas of HandbagHandcuff.com without revealing your identity or needing to create an account or log in.

Online Registration Process

If you decide to create an account with us, you must first complete the online registration process. During the registration process, you will need to input certain personal information, such as your name and email address. You also must choose a password, which will be required to gain access to the My Account section of our Site reserved for registered users. If you purchase a product from our Site, you will be required to provide your phone number, billing and shipping addresses and preferences, and credit card information. We will only collect the personal information that is necessary to process your transaction.Please keep in mind that when you submit personal information to us, you are giving your assent for us to collect, use and disclose your personal information in accordance with the terms of this Privacy & Security Policy and as permitted and/or required by law.

Email Communication

Once you complete and submit your registration, you can opt in to receive email communications from Handbag Handcuff® about our products and services and you will be able to sign up for promotional updates. You may, at any time, elect to opt out of future email delivery by following the removal instructions, which are located at the bottom of each message. Asking to be removed from our email list will not bar you from receiving email communications relating to any online order that you have or may place on our Site or relating to any other operational matters.

Customer Service

When you contact Customer Service, it may be necessary to obtain your contact information in order to assist you.

Third Parties’ Personal Information

We will retain in your My Account the personal information of individuals for whom you have ordered product or to whom we have shipped product on your behalf.

Referring a Friend

Should you choose to use refer a friend to our Site, you will be required to provide their email address in order for us to send them a link to our Site. We may also ask you to provide your name and email address so that they can be notified that you referred them to us. We will send your friend(s) a one-time email about our Site. We will not permanently store the name or email address of your referred friend(s) unless they elect to register with us themselves.

Will My Personal Information Be Collected If I Participate in a Contest or Promotion on the Site?

We may sponsor a contest or promotion on our Site or team up with a third party for a joint promotion. If you choose to participate, we will only collect personal information such as your name, email or mailing address. If it is necessary to notify you about the results of a contest or promotion, additional personal information may then need to be collected. We may send you additional communications only if you have specifically requested to receive our emails, e-newsletters, personalized offers or other promotional materials on a contest or promotion form. If a third party administers the contest, your participation may be subject to additional terms and conditions and that third party’s privacy policy.

Is My Usage Information Collected Using Cookies and Pixels?

When you visit our Site, we automatically collect usage information known as Session Data through the use of cookies, pixel tags (web beacons) and other like technologies. The Session Data allows us to better understand how users navigate our Site, improve our content, and helps us create a better experience for you.Session Data tells us the type of Internet browser and computer operating system that a visitor uses, the domain name of the Internet Protocol addresses from which they connect to our Site, the date, time and duration of the visit to specific pages and the frequency of visits to our Site, as well as the variety of searches of our Site’s database.

When you access our Site, our computer may seek to place cookies or pixel tags on your computer to collect Session Data. A cookie is a small text file that contains a unique identification number that identifies the visiting browser. Your computer sends the cookie back to us each time you make a request from our Site.

A pixel tag is a tiny, often transparent graphic image that is similar to a cookie and is utilized to monitor the behavior of the user visiting the Site or sending the email to which the tag is affixed. Use of pixel tags allows us to understand the efficacy of our communications.

Cookies and pixel tags are used to help us recognize you when you visit our Site again or to help us customize your online experience. Unless you specifically inform us of your identity by registering with us, we will not know your identity.

Most Internet browsers automatically accept cookies. Generally, you can edit the options in your browser to prevent it from accepting cookies or to notify you before accepting a cookie from the sites you visit. You can obtain further information about the use of cookies by visiting allaboutcookies.org.

If you decide not to accept our cookies, you will only be able to access those parts of our Site that are available to the general public, but you will not be able complete an online transaction or access certain of our products or services.

How Will My Personal Information Be Used?

The personal information we collect may be used to administer your account, which includes for customer service purposes, invoicing, payment collection and processing, shipping, tracking your transactions and account history, and, if needed, to evaluate credit standing and to match credit bureau or credit reporting agency information. In the event that it is necessary to provide your personal information to third parties to assist us in servicing your account, fulfill orders, or host the Site, we will take all reasonable steps to ensure that they comply with the practices set forth in this Privacy & Security Policy.

The information we collect may also be used to enhance your experience on our Site by implementing your preferences, personalizing communications with you about our products and services, notifying you about promotions we may be having on the Site, improving our Site’s content, informing you about new features that may be available, or diagnosing any technical problems you may have with the Site.

We reserve the right to disclose your personal information without obtaining your consent should we be legally required to do so or if we believe, in good faith, that the release is necessary for some of the following reasons:

• To monitor compliance with our policies and contractual obligations;

• To investigate, detect and protect our Site, our employees and ourselves or others against fraud, theft, credit risk, error, negligence, breach of contract, illegal activity or as otherwise required in a criminal investigation; or where it is necessary to permit us to pursue available remedies or limit any damages that we may sustain;

• If required to comply with a subpoena or warrant issued or an order made by a court, administrative or governmental body with jurisdiction to compel the production of information or to comply with the rules of a court relating to the production of records;

• In the event of an emergency that threatens the life, health, security or property of an identifiable person or group of people;

• In connection with the proposed or actual sale, merger, spin-off or other corporate reorganization of BACOR, Inc. (in which case we would require the person or entity to which the information is being transferred to protect the information pursuant to their Privacy Policy); or

• To comply with any legal or regulatory requirements.

We will not use your personal data for any other purpose.

How Is Your Personal Information Protected?

We are committed to protecting your information, but it is a joint effort. Although your account is protected by both a user name and password, you should always take precautions to limit access to your computer and personal information. It is advisable to log off My Account after you are finished accessing our Site and then to log off the Internet, power down and turn off your computer. On our end, we will follow reasonable technical, administrative and management practices to help protect the confidentiality, security and integrity of your personal information and data stored on our system. When your personal information is sent to our service providers, they are contractually obligated to protect all personal information in a manner consistent with the principles articulated in this Privacy & Security Policy.

We encrypt your credit card data using secure socket layer (SSL) technology that provides for the secure transmission of the information from your PC to our servers. In addition, only those employees and third parties who need access to your information in order to perform their duties are allowed such access.

While no computer system is completely secure, we believe the measures we have implemented reduce the likelihood of security problems to a level appropriate to the type of data involved.

Please keep in mind that any information transmitted to us via the Internet might not be secure and, as such, we can assume no liability for the loss of information that you transmit this way.

In communicating with you, we may send email as unencrypted plain text because we are aware that most registered users cannot readily process encrypted email. This is done for your convenience.

How Do You Retain and Store My Personal Information?

We will retain your personal information in our databases in compliance with applicable laws. This period may extend after you have closed your account so that we will have the necessary information that we need to respond to any future issues that may arise. We may also need to retain your personal information for legal reasons, as more fully set forth above in the section entitled How Will My Personal Information Be Used?

Please be assured that your personal information will be stored on our secure servers which are located either at our offices or at the offices of our service providers as described above in the section titled How Is Your Personal Information Protected?

Should I Be Concerned About Phishing?

“Phishing” is a term used to describe a scam devised to steal your personal information, such as your password, user name, and/or secure details about your payment information and credit card(s). Many phishing scams are attempted over the Internet. We will not approach you in an unsolicited manner and ask that you disclose your password, user name or other personal information to us outside the scope of a transaction that you have initiated with us. Please use your best judgment and err on the side of caution by refraining from disclosing information to anyone if the circumstances are suspect and do not feel right to you. Identity theft scams can include credit card aliasing, spoofing, or the misappropriation of your name or identity. For your reference, the Federal Trade Commission has published a valuable Consumer Alert entitled “How Not to Get Hooked by a ‘Phishing’ Scam” which can be found at http://www.ftc.gov/bcp/edu/pubs/consumer/alerts/alt127.

What Is the Policy on Children’s Privacy and Parental Controls?

To ensure compliance with federal law, we do not solicit, knowingly collect or maintain any personal information from any minor under the age of 13, and will not use this information if we discover that it has been provided by a minor. If you are a minor, you are not authorized to provide us with your personal information. Minors are not eligible to purchase products. There are parental control tools available that can be used to prevent minors from submitting information online without parental permission or from accessing material that is harmful to them.

What is the Policy on Advertising?

Handbag Handcuff® will not permit third-party advertising on our Site.

How Do I Opt-Out?

As part of the registration process, we give you the ability to receive via email or direct messaging information about our products and services, updates to our Site and promotions or contests available on our Site. We send this information directly ourselves or via third-party service providers.

If you do not opt-out from receiving these communications about our Site, we will send them to you.

At any time you may change which of the communications you wish to receive or not receive by changing your preferences as described in How Do I Access and Update My Personal Information and Preferences?

In addition, in our emails and other communications, we will include instructions on how to unsubscribe and inform us of preferences if you decide you do not want to receive any future marketing or promotional emails from us.

We will take commercially reasonable steps to implement your opt-out requests promptly, but you may still receive communications from us for up to ten (10) business days as we process your request.

How Do I Close My Account?

If you wish to close your account, you can do so by contacting us via email at info@handbaghandcuff.com or by mail at 137 North Larchmont Boulevard, #219, Los Angeles, CA 90004, Attention: Privacy Manager. We will do our best to respond to all such requests within thirty (30) days following receipt at the email or mailing address stated above, to the extent possible. Please remember that we may not be able to honor your request if we are legally obligated to retain your information, or for other reasons described above in the section entitled How Do You Retain and Store My Personal Information?

What If There Are Changes to this Privacy & Security Policy?

In the event that we need to modify this Privacy & Security Policy, the revision will be dated and posted here for your reference. The changes will apply to the information collected from the date we post the revised Privacy Policy to our Site, as well as to existing information held by us. Your continued use of the Site indicates your assent to the terms of the Privacy & Security Policy.

If we decide to change this policy in a material way, we will obtain the necessary consents required under applicable privacy laws if we seek to collect, use or disclose personal information for purposes other than those to which consent has been obtained, unless otherwise required or permitted by law. If we make any material changes, we will notify you by email (at the email address specified in your account) or by means of a notice on our Site prior to the change becoming effective. Should you have questions about changes to the Privacy & Security Policy, you may direct them to us at 137 North Larchmont Boulevard, #219, Los Angeles, CA 90004, Attention: Privacy Manager. If any proposed change is unacceptable to you, you may close your account at any time, as described in the above section entitled How Do I Close My Account?.

Special Privacy Disclosure Information for California Residents

Under Civil Code section 1798.83, our customers who are California residents have privacy rights under California’s “Shine the Light” law which regulates the sharing of your Personal Information with third parties for direct marketing purposes. While it is our policy not to disclose your Personal Information to third parties for the third parties’ direct marketing purposes, we may disclose your Personal Information for the purposes outlined in this Privacy & Security Policy. Under Civil Code section 1798.83, non-exempt businesses must comply with detailed notice requirements and respond in writing to requests for information regarding the way in which Personal Information is shared. California residents may request information about the disclosures of certain enumerated categories of their Personal Information by submitting such requests to us in writing either by email to info@HandbagHandcuff.com with Attn: Privacy Manager listed in the email subject line or by mail at:

BACOR, Inc.
c/o 137 North Larchmont Boulevard, #219
Los Angeles, CA 90004
Attention: Privacy Manager

Upon our receipt of your request, we will provide a list of categories of Personal Information disclosed to third parties during the immediately preceding calendar year, along with the names and addresses of such third parties. You may make such a request once per calendar year. Civil Code Section 1798.83 can be reviewed at: http://www.leginfo.ca.gov/cgi-bin/displaycode?section=civ&group=01001-02000&file=1798.80-1798.84

Contact Information

If you have any questions or concerns about (a) this Privacy & Security Policy, (b) the collection, use, management or disclosure of your personal information, or (c) accessing, modifying or closing your account, please contact us at info@HandbagHandcuff.com and we will respond to your questions or concerns promptly.

Email: info@HandbagHandcuff.com

Mail: BACOR, Inc.
c/o 137 North Larchmont Boulevard, #219
Los Angeles, CA 90004
Attention: Privacy Manager