Privacy Policy

PRIVACY POLICY

Your Privacy Rights

Effective Date: February 2026

This Privacy Policy describes the types of information gathered by Biggar & Leith, ULC (“Company,” “us,” “our,” or “we”) in the process of providing, running, and maintaining https://www.biggarandleith.com, https://shankyswhip.eu, and https://shankyswhip.com (the “Sites”), and the data, services, information, tools, functionality, updates and similar or related materials (collectively, the “Service”), how we use the information, with whom the information may be shared, what choices are available to you regarding collection, use and distribution of information and our efforts to protect the information you provide to us through the Service.

By accessing the Sites, using the Service, or otherwise providing information to us, you hereby consent to allow us to collect, use, process, and disclose your information in accordance with this Privacy Policy. When accessing the Sites, please also refer to our Terms of Service, available here, https://www.biggarandleith.com/website-terms, which are incorporated into this Privacy Policy as if fully recited herein. Terms defined in the Terms of Service that are not defined herein shall have the same definition as in the Terms of Service.

This policy is subject to change. If our information retention or usage practices change, we will let you know by posting the Privacy Policy changes on the Sites and/or otherwise making you aware of the changes. Your continued use of the Sites, or Service, following our notice of changes to this Privacy Policy means you accept such changes. Please refer to the “Effective Date” above to see when this Policy was last updated.

Territoriality

Regardless of where our servers are located, your personally identifiable information, may be processed by us in the United States, where data protection and privacy regulations may or may not be to the same level of protection as in other parts of the world. BY VISITING THE SITES AND USING OUR SERVICE, YOU UNEQUIVOCALLY AND UNAMBIGUOUSLY CONSENT TO THE COLLECTION AND PROCESSING IN THE UNITED STATES OF ANY INFORMATION COLLECTED OR OBTAINED BY US THROUGH VOLUNTARY SUBMISSIONS, AND, TO THE EXTENT POSSIBLE, THAT U.S. LAW GOVERNS ANY SUCH COLLECTION AND PROCESSING.

This Privacy Policy may be subject to the provisions of the EU General Data Protection Regulation (“EU GDPR”), the UK General Data Protection Regulation (“UK GDPR”, and together with the EU GDPR, the “GDPR”), and other applicable privacy laws. If you are an individual who resides in the United Kingdom, the European Economic Area, or Switzerland (collectively, and for the purposes of this Privacy Policy, the “EEA”), you are a “Data Subject” with certain protected privacy rights concerning your “Personal Data” and we are a “Controller” according to the GDPR. We will take commercially reasonable steps to maintain compliance with GDPR, and all other applicable laws. Your Personal Data, combined with any other information that may identify you as a person, may be referred to in this Privacy Policy as Personally Identifiable Information (collectively, “PII”). If you are a Data Subject, read Sections 13 and 14 below. For the purpose of this Privacy Policy, PII does not include de-identified or aggregated information that does not identify you.

1. Collection and Use of Your Information.

We may collect certain PII from you when you visit or browse our Sites or use our Service. It is important to note that the type of information collected will depend on your location and your interaction with the Service.

Who Collects Your Information On Our Sites?

We do. We collect information from you when you visit or browse the Sites, use our Service, sign-up for our mailing list, sign-up to receive more information about the Company, or place an order. We are responsible for the protection of your information. We collect PII from three different sources: directly from you; from third-party sources; and automatically collected information.

What Information Do We Collect?

Personal Information.

We collect certain PII or data about you, which may be supplied when you sign-up for the Sites, when you complete a survey, when you use the Sites, when you fill out a form available on the Sites, when you make a purchase via the Sites, when you request the Service, when you link your to your social media account(s) via our optional integration, or otherwise when you submit such information. The types of PII we collect and save include:

  • Name, email address, mailing address, phone number, and in some cases, your date of birth; and
  • Technical information collected in our logs. Such information may include standard web log entries that contain your IP address, device identifiers, first-party Cookies (session, and persistent), third-party Cookies, web beacons, pixels, page URL and timestamp.

You may provide us with information when you interact with us through email, read an email from us, use our online chat or messaging functions within the Sites, Service, or otherwise when you interact with us. We may retain such information in order to provide you with the Service, and you agree that we may share this information as needed with other users in order to resolve any issues that may arise between you and another user of the Service.

The Service may offer you the option to be integrated with third-party social media platforms, such as Facebook, Instagram, and others (“Platforms”). If available, and you choose to interact with the Platforms through the Service, the Platforms may make additional PII about you available to us. The Service may use your mobile data plan in order to use certain features of the Service, such as communication with other users through the Service.

Non-Personal Information.

“Non-Personal Information” is information which doesn’t identify you and/or anonymous information about you, including but not limited to links and materials posted, purchase history, the type of device you used and its operating system, browser information, the pages accessed most frequently, how pages are used, applications downloaded, search terms entered, and similar Non-Personal Information.

Automatically tracking Internet Protocol (IP) addresses is one method of automatically collecting information about your activities online and information volunteered by you. An IP address is a number that is automatically assigned to your device whenever you surf the internet. Further, the Sites and Service may utilize web beacons, pixel tags, Cookies, embedded links, and other commonly used information-gathering tools. Through collecting your IP address, we may be able to approximate your geographic location, however, unless and until this information is paired with your PII, it cannot be used to identify you. If Non-Personal Information is paired to any of your PII, we will treat the Non-Personal Information as if it was PII.

Part of the purpose of the Sites is to share materials you make available. Anything you publicly post will not be considered PII.

Aggregate Information.

We may also collect anonymous, non-identifying and aggregate information, the date and time of any request, language preference, referring website, the website you go to after visiting our Sites, and the domain name of your Internet provider.

Financial Information.

Although it may appear that we collect financial information from you on the Service, it is actually collected and processed through our Payment Processor in order to process payments for the Service. The Payment Processor may collect financial information such as banking information, credit card number, name, CVV code, and/or Credit Card date of expiration, from you on the Service. We do not hold your financial information.

Why Is My Information Being Collected?

We accept and gather information in an effort to provide better services to you. We collect your PII so that we can respond to your requests for information or so that you can be added to our email lists, we can curate a personalized experience for you with the Services, and for us to process any payments made in connection with the Service. We also collect aggregate information to help us better design the Sites. We collect log information to help us diagnose problems with our servers, administer the Service, calculate usage levels, and otherwise provide services to you.

How Do We Use the Information We Collect?

PII.

We use the PII you provide for the purposes for which you have submitted it including:

  • Internal Uses. We may use your PII to respond to your inquiries, to fulfill your requests for information, track usage trends, conduct experiments, send you push notifications, develop and improve the Sites and any related services or offerings, perform research and analytics, compile usage statistics and other data regarding the use of our Sites and Service, ensure the security of the organization and our visitors, and abide by any applicable laws.
  • Personalizing Experience. We may use your PII to craft and personalize your experience with the Service including, but not limited to, targeted advertising.
  • Processing Orders and Payments. Our Payment Processor uses your PII to transfer funds from your Payment Method(s) when you purchase our Products from us, or through the Store.
  • Communicating With You About the Service. We may use your PII to send you information about, and notify you of, exclusive offers and provide you information regarding your recent purchases, and new Products.
  • Social Media Integration. If available, and you choose to integrate, we may use your PII to integrate your social media accounts with the Service, and to provide you the social media features of the Service.
  • Sending You Administrative and Promotional Emails. We may use your PII to send you emails to: (a) confirm your information and your other PII; (b) provide you with information regarding the Service; (c) inform you of changes to this Privacy Policy, our Terms of Service, or our other terms, conditions, or policies; (d) let you know about Products in our Store that might interest you; or (e) provide you with information about promotions, which may or may not be related to our other services and products, and which may be subject to additional terms and disclosures.
  • Serving You Targeted Advertisements. We may use PII to serve you advertisements with the Service, and other communications, that are targeted to your interests.
  • Sharing Information. We may disclose your PII with unrelated persons or entities as described below.
  • Mailing You Something. Upon placing an order, we, or the Store, may send you the ordered Products via USPS, courier, or another service, including, but not limited to when you purchase Products. Please be prepared to verify your age and identity when receiving the order. Please note you must be of the age required in your jurisdiction to purchase and/or consume alcohol in order to accept an order.

Anonymous Information.

We may use anonymous information that we collect to improve the design and content of our Sites, and to enable us to personalize your internet experience. We also may use this information in the aggregate to analyze how our Sites is used, as well as to offer you programs or services. We may use any anonymous, aggregate information, of which your information may be a part of or the basis of, without restriction.

Do We Share Your PII?

We will not share your PII except: (a) for the purposes for which you provided it; (b) with your consent; (c) as may be required by law or as we think necessary to protect our organization or others from injury (e.g., in response to a court order or subpoena, in response to a law enforcement agency request, or when we believe that someone is causing, or is about to cause, injury to or interference with the rights or property of another); (d) to unaffiliated partners that may help us facilitate the Services; or (e) with persons or organizations with whom we contract to carry out internal operations or business activities, for example, we may transfer your PII to a partner with whom we engage in targeted marketing/advertising across multiple, to create and administer unrelated websites/platforms, or to a carrier to deliver something to your address.

We may partner with third parties and third-party developed tools to optimize your experience with the Service. These third-party tools enable us to tailor our communications to you for a personalized experience with the Service. Pursuant to our partnership with these third parties, certain PII, including your name, address, phone number, and email address, may be shared with these third parties. From time to time, we may elect to engage different third parties to more efficiently and effectively communicate with you. Your elected data preferences and data privacy settings will be preserved and maintained any time we substitute or add a new third-party partner in providing the Service. If there are any material changes to how we share PII to our third-party partners, we will promptly notify you for your awareness.

We may also share aggregate information with others, including affiliated and non-affiliated organizations.

Finally, we may transfer your PII to a third party, or an actual or potential successor-in-interest, in relation to, or in the event of, an actual or potential merger, acquisition, sale of all or substantially all of our assets, reorganization, bankruptcy, or other change of control. After such disclosure or transfer, the third party or successor in interest may use the information in accordance with applicable law.

Are There Other Ways My PII Could Be Shared?

You may elect to share certain PII with individuals or with the public via your use of the Service. In this case, you will control such sharing via settings that we provide. For example, the Service may make it possible for you to publicly share information via Platforms such as Facebook, or Instagram. Be aware that when you choose to share information with friends, or with the public at large, you may be disclosing sensitive information, or information from which sensitive information can be inferred. Always use caution when sharing information through the Service. You understand and agree that we are not responsible for any consequences of your sharing of information through and beyond the Service.

You may choose to participate in activities offered through the Service that allow you to earn points. If you participate in these activities and accumulate points, we may include your username and point total on a leader board on the Service. We may also display the leader board at a particular event or activity which we are hosting or sponsoring, or in which we are participating.

How Can You Access and Control Your Information?

After becoming a user of the Sites, you may revise or edit your information by sending an email to info@shankyswhip.com. For instructions on how you can further access your PII that we have collected, or how to correct errors in such information, please send an e-mail to info@shankyswhip.com. To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access, making corrections or removing your information. At any time you can email us at info@shankyswhip.com with “Opt-Out” in the subject to opt out of any of the following activities with respect to your PII: using your PII for purposes other than it was provided for; including you in an online directory; and/or sending you promotional emails.

How Do We Store and Protect Your Information?

Storage.

After receiving your PII, we will store it on our servers for future use. While we have appropriate safeguards in place, unfortunately, no data transmission over the internet or data storage solution can ever be completely secure. As a result, although we take steps to protect your data, we cannot ensure or warrant the security of any information you transmit to or receive from us or that we store on our or our service providers’ systems.

Servers Location.

If you are visiting the Sites from outside of the USA, you understand that your connection will be through and to servers located in the USA, and the information you provide will be securely stored in our servers and internal systems located within the USA.

Security.

Please note that we protect PII in our possession with strong encryption (at rest and in transit); all data transfers are through secure http protocol, and as such are encrypted. We also restrict access to PII to key employees and log all instances of access to PII. Our Payment Processor is fully PCI-compliant and encrypts all payment transactions using Secure Socket Layer technology.

Retention.

We will only retain your PII for as long as is reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your PII for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for PII, we consider the amount, nature, and sensitivity of the PII, the potential risk of harm from unauthorized use or disclosure of your PII, the purposes for which we process your PII and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

We store our logs and other technical records indefinitely.

How Do We Use Cookies and Other Network Technologies?

Cookies.

To enhance your online experience with us, our web pages may presently or in the future use “Cookies.” Cookies are text files that our web server may place on your hard disk to store your preferences. Cookies, by themselves, do not tell us your e-mail address or other PII unless you choose to provide this information to us. Once you choose to provide PII, however, this information may be linked to the data stored in the cookie. Although it may be possible to turn off the collection of Cookies through your device or browser, certain features of the Sites may not function properly without the aid of Cookies.

Third-Party Partner Services.

Our Sites may use Google Analytics provided by Google Ireland Limited, Gordon House, 4 Barrow St, Grand Canal Dock, Dublin 4, D04 V4X7, Ireland (“Google”). Google Analytics uses Cookies and similar technologies to collect and analyze information about use of the Sites and report on activities and trends. This service may collect information regarding the use of other websites, apps and online resources. You may be able to opt-out of some or all of Google Analytics features by downloading the Google Analytics opt-out browser add-on. For more information about interest-based ads, or to opt-out of having your web browsing information used for behavioral advertising purposes, please visit http://optout.aboutads.info.

Pixel Tags.

The Company or its service providers may also use “pixel tags,” “web beacons,” “clear GIFs” or similar means (collectively, “Pixel Tags”) in connection with some of our Sites pages and HTML-formatted email messages for purposes of, among other things, compiling aggregate statistics about website usage and response rates. A Pixel Tag is an electronic image, often a single pixel (1x1), that is ordinarily not visible to website visitors and may be associated with Cookies on visitors’ hard drives. Pixel Tags allow us and our service providers to count users who have visited certain pages of our Sites, to deliver customized services, and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted email messages, Pixel Tags can inform the sender of the email whether and when the email has been opened.

Meta Pixel.

One such Pixel Tag that our Service uses is the Meta Pixel, a web analytics and advertising service, provided by Meta Platforms Ireland Limited, Merrion Road, Ballsbridge, Dublin 4, D04X2K5 Ireland (“Meta”). With its help, we can keep track of what users do after they see or click on a Facebook or Instagram advertisement, keep track of users who access our Service or advertisements from different devices, and better provide advertisements to our target audiences. Meta may use and disclose (including to Facebook and unaffiliated third parties that provide no services to us) your data collected by the Meta Pixel in accordance with its Data Policy. In addition, Meta can save and process your data, connect it with your Facebook and/or Instagram accounts, and use it for its own and others advertising purposes in accordance with the Facebook Data Policy.

Clickstream Data.

As you use the internet, you leave a trail of electronic information at each website you visit. This information, which is sometimes referred to as “clickstream data”, can be collected and stored by a website’s server. Clickstream data can reveal the type of computer and browsing software you use and the address of the website from which you linked to our Sites. We may use clickstream data as a form of Non-Personal Information to determine how much time visitors spend on each page of our Sites, how visitors navigate through the Sites, and how we may tailor our web pages to better meet the needs of visitors. We will only use this information to improve our site.

Do Not Track.

At present, the Sites does not specifically respond to browser do-not-track signals.

Collection of Information by Others.

Our Terms of Service document identifies certain third-party websites to which we may provide links, and that you may click on our Sites or in our Service. Please check the privacy policies of these other websites to learn how they collect, use, store and share information that you may submit to them or that they collect.

Children and Young People’s Information.

We do not knowingly collect any PII from anyone under the age of 16, and we comply with all applicable privacy laws including, but not limited to, the GDPR. If you have concerns about this Sites, wish to find out if your child has accessed our Services, or wish to remove your child’s PII from our servers, please contact us at info@shankyswhip.com. Our Sites will not knowingly accept PII from anyone under 16 years old in violation of applicable laws, without consent of a parent or guardian. If we discover that a child under the age of 16 has provided PII to us, we will make efforts to delete the child’s PII in accordance with applicable laws. If you believe that your child under 16 has gained access to our Sites without your permission, please contact us at info@shankyswhip.com.

General Privacy Rights and How to Exercise Them.

You have the following rights with respect to our practices regarding your PII:

  • The right of access. This is your right to be informed about what PII we are processing, why, and who else the data may be passed to.
  • The right to correct. This is the right to have your PII corrected or amended if what is held is incorrect in some way.
  • The right to deletion. Subject to certain exceptions, and limitations, this is the right to have your PII deleted.
  • The right to data portability. This is the right to ask for your PII to be provided to you in a structured, commonly used, and machine-readable format.
  • Right to Opt-Out of Automated Decisions. We do engage in automated decision making, but if we did, you would have the right to opt-out of any automated decision making. To the extent that the Company engages in automated decisions, you have the right to opt out of such practice(s).
  • Exercising Your Rights.

To exercise any of your rights under applicable privacy laws, please contact us at info@shankyswhip.com with “Privacy Rights Request” in the subject line. Please include enough detail for us to locate your file; at a minimum, your name, email, and username, if any. We will attempt to provide you with the requested information within thirty (30) days of receipt. We reserve our right not to respond to requests sent more than once in a calendar year, or requests submitted to an address other than the one posted in this notice. Please note, we may take additional steps to verify your information.

  • Right to Appeal Any Denial of Your Rights.

If we should deny your privacy right request, you may submit an appeal of that determination via email to info@shankyswhip.com. In the subject line of your appeal email, please include the file number provided with the initial denial of your privacy right request and the word “APPEAL”. In the body of your appeal email please detail (1) the nature of your request, (2) your state of residence; and (3) your reasoning for why the initial denial should be reversed. In the event we deny your request for appeal, you may be able to file a complaint with the Office of the Attorney General in the State in which you reside, please consult the website of your applicable Attorney’s General for more information.

EEA Privacy Rights.

If you are currently residing in the EEA and use the Service, the GDPR applies to your Personal Data, and you are a Data Subject. The GDPR requires that we, as a Controller, have a legal basis to process your Personal Data.

  • Personal Data Processing.

We process your Personal Data under one or more of the following legal bases:

  • Processing is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
  • To perform the contract that we are about to enter with you (e.g., our Terms of Service);
  • To comply with a legal obligation; and/or
  • If we have your consent to do so (which you have the right to withdraw at any time).
  • Your Rights.

In addition to the rights described in Section 13, under the GDPR, as a Data Subject you have the following rights:

  • The right to be informed. This is your right to be informed about what we are processing, why, and to whom the data may be disclosed.
  • The right to restrict processing. This is the right to ask for a temporary halt to processing of your Personal Data, such as in the case where a dispute or legal case has to be concluded, or the data is being corrected.
  • The right to object. This is the right to object to further processing your Personal Data if such processing is inconsistent with the primary purposes for which it was collected.
  • Rights in relation to automated decision making and profiling. This is the right to not be subject to a decision based solely on automated processing.
  • Right to Judicial Remedy. Notwithstanding anything to the contrary in this Privacy Policy, if you feel that we or one of our processors, if any, have infringed your rights under the GDPR, or that we are otherwise not in compliance with the GDPR with respect to your PII, you may bring a legal proceeding against us in a court (or file a complaint with a supervisory authority) located in the EEA country where you regularly reside.

If you wish to find out more about, or exercise any of, these rights, please contact us at info@shankyswhip.com. Our Data Protection Officer (“DPO”) may be contacted as follows:

Attn: Global DPO
10 Princeton Place
Montclair, NJ, 07043 USA
elwyn@shankyswhip.com

  • Third Countries.

In the event that we share, or otherwise transfer, PII covered by the GDPR and this Privacy Policy to a third party, or a country outside the EEA and/or UK, as applicable, which does not have an adequacy decision from the European Commission, or similar designation from the Information Commissioner’s Office, or similar regulatory authority (collectively, a “third country”), we will only do so if: (i) that third party, except in cases of government or law enforcement agencies, gives us contractual assurances that it will comply with the GDPR; and (ii) to the extent necessary, have in place a GDPR compliant procedure in place to protect the transfer, e.g. GDPR standard contractual clauses, available here, including any necessary assessments of the applicable third country, and supplemental measures designed to ensure you have essentially equivalent rights and remedies as you would in the EEA.

  • Privacy and Electronic Communications Regulations.

In addition to the UK GDPR, the Privacy and Electronic Communications Regulations (“PECR”) provides additional substantive rights to Data Subjects residing in the UK.

We offer users of the Service the option to sign up to receive the Company’s dedicated email contact list that provides users with promotional materials, exclusive sales, newsletters, and additional marketing materials. You may remove yourself from this dedicated email list at any time by either selecting “unsubscribe” to the relevant email, or following the directions to opt-out of such emails. We will not send the above-described marketing materials to any user unless they have opted into the dedicated email list, or to any user who has opted-out of the dedicated email list after previously consenting to be included in said list.

As described in Section 10, we utilize Cookies and Pixel Tags. Cookies and Pixel Tags that are labeled “strictly necessary” or “essential” are essential for enabling the basic functionalities of the Service. BY USING THE SERVICE, YOU CONSENT TO OUR USE OF ESSENTIAL COOKIES AND PIXEL TAGS AS DESCRIBED IN THIS PRIVACY POLICY. Upon the first time you use the Service, we will provide you the opportunity enable or disable non-essential Cookies and Pixel Tags. Disabling non-essential Cookies and Pixel Tags may affect your experience with the Service. You may alter your selection at any time by contacting us at info@shankyswhip.com.

  • Regional Representative Contact Information

Pursuant to Article 27 of the General Data Protection Regulation (GDPR), the addresses for our Representatives in the EU and UK are as follows:

  • Annefield House, Dublin Road, Portlaoise, Co. Laois, R32 Y6YF, Ireland; and
  • 41 Pulborough Road, Wandsworth, SW185UN United Kingdom

Changes to this Policy

Because our business needs may change over time, we reserve the right to modify this Privacy Policy. If at any time in the future we plan to use your PII in a way that differs from this Privacy Policy, we will revise the Privacy Policy as appropriate. In the event of a change to this Privacy Policy, we will email the updated policy to the email address that you provided to us. Your continued use of the Service, or other means of legal acceptance, following our notice of changes to this Privacy Policy means you accept such changes. Please refer to the “Effective Date” above to see when this Policy was last updated.

Contact Information

If you have any questions or suggestions regarding our Privacy Policy, please contact us via e-mail at info@shankyswhip.com.

Copyright © Biggar & Leith, ULC. All rights reserved. The Service is the property of Company, and is protected by United States and international copyright, trademark, and other applicable laws. This includes the content, appearance, and design of the Service, as well as the trademarks, product names, graphics, logos, service names, slogans, colors, and designs.