Welcome, and thank you for your interest in the Harbinger Strategy website at www.harbingerstrategy.com (the “Website”).  The Website is owned and operated by Harbinger Strategy, LLC (“Harbinger Strategy”, “we,” or “us”).  Our commitment to privacy is important to us. This Privacy Policy (the “Policy”) applies to your use of the Website (“User” or “you”), services provided by us and all other communications with individuals through written or oral means, such as email or phone (collectively, our “Service”).  This Policy describes the information that we gather on or through the Service, how we use and disclose such information, and the steps we take to protect such information.

1.  The Information We Collect on the Service.

We collect different types of information from or through the Service, non-personal data and personal data. “Personal Data” means any information relating to an identified or identifiable natural person.  The legal bases for Harbinger Strategy’s processing of personal data are primarily that the processing is necessary for providing the Service and that the processing is carried out in Harbinger Strategy’s legitimate interests, which are further explained in the “How We Use the Information We Collect” section of this Policy. We may also process data upon your consent, asking for it as appropriate.

1.1 User-provided Information. When you use the Service we may collect Personal Data. Examples of Personal Data include name, email address, mailing address and a mobile phone number.  Personal Data also includes other information, such as geographic area or preferences, when any such information is linked to information that identifies a specific individual. You may provide us with Personal Data in various ways on the Service. For example, when you use the Service, interact with other users of the Service through communication or messaging capabilities, or send us customer service -related requests.

1.2 “Automatically Collected" Information. When a User uses the Service, we may automatically record certain information from the User’s device by using various types of technology, including cookies, “clear gifs" or “web beacons.” This “automatically collected" information may include IP address or other device address or ID, web browser and/or device type, the web pages or sites visited just before or just after using the Service, the pages or other content the User views or interacts with on the Service, and the dates and times of the visit, access, or use of the Service. We also may use these technologies to collect information regarding a User’s interaction with email messages, such as whether the User opens, clicks on, or forwards a message. This information is gathered from all Users.

1.3 Integrated Services. You may be given the option to access or register for the Service through the use of your user name and passwords for certain services provided by third parties (each, an “Integrated Service”), such as through the use of your Google or Linkedin accounts, or otherwise have the option to authorize an Integrated Service to provide Personal Data or other information to us. By authorizing us to connect with an Integrated Service, you authorize us to access and store your name, email address(es), date of birth, gender, current city, profile picture URL, and other information that the Integrated Service makes available to us, and to use and disclose it in accordance with this Policy. You should check your privacy settings on each Integrated Service to understand what information that Integrated Service makes available to us, and make changes as appropriate. Please review each Integrated Service’s terms of use and privacy policies carefully before using their services and connecting to our Service.

1.4 Information from Other Sources. We may obtain information, including Personal Data, from third parties and sources other than the Service, such as our partners, advertisers, credit rating agencies, and Integrated Services. If we combine or associate information from other sources with Personal Data that we collect through the Service, we will treat the combined information as Personal Data in accordance with this Policy.

2. How We Use the Information We Collect

We use the information that we collect in a variety of ways in providing the Service and operating our business, including the following:

2.1 Operations

We use the information to operate, maintain, enhance and provide all features of the Service, to provide the services and information that you request, to respond to comments and questions and to provide support to users of the Service.

2.2 Improvements

We use the information to understand and analyze the usage trends and preferences of our Users and Users, to improve the Service, and to develop new products, services, features, and functionality.

2.3 Communications

We may use a Visitor’s or User’s email address or other information to contact that a User (i) for administrative purposes such as customer service, to address intellectual property infringement, right of privacy violations or defamation issues related to the Personal Data posted on the Service (ii) with a business transaction purpose; or (iii) updates on products, services, new licensing opportunities, materials, promotions and events, relating to products and services offered by us and by third parties we work with. You have the ability to opt-out of receiving any promotional communications as described below under “Your Choices.”

2.4 Cookies and Tracking Technologies

We use automatically collected information and other information collected on the Service through cookies and similar technologies to: (i) personalize our Service, such as remembering a User’s information so that the User will not have to re-enter it during a visit or on subsequent visits; (ii) provide customized advertisements, content, and information; (iii) monitor and analyze the effectiveness of Service and third-party marketing activities; (iv) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (v) track your entries, submissions, and status in any promotions or other activities on the Service. You can obtain more information about cookies by visiting http://www.allaboutcookies.org.

3. To Whom We Disclose Information

Except as described in this Policy, we will not intentionally disclose the Personal Data that we collect or store on the Service to third parties without the consent of the applicable User. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:

3.1 Unrestricted Information

Any information that you voluntarily choose to include in a Service, such as a public profile page, will be available to any User who has access to that content.

3.2 Service Providers

We work with third party service providers who provide website, application development, hosting, maintenance, and other services for us. These third parties may have access to, or process Personal Data as part of providing those services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information.

3.3 Non Personally Identifiable Information

We may make certain automatically-collected, aggregated, or otherwise non-personally-identifiable information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our Users’.’ interests, habits, and usage patterns for certain programs, content, services, and/or functionality available through the Service.

3.4 Law Enforcement, Legal Process and Compliance

We may disclose Personal Data or other information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a facially valid court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.

We also reserve the right to disclose Personal Data or other information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Service and any facilities or equipment used to make the Service available, or (v) protect our property or other legal rights, enforce our contracts, or protect the rights, property, or safety of others.

3.5 Change of Ownership

Information about Users, including Personal Data, may be disclosed and otherwise transferred to an acquirer, successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets and only if the recipient of the User Data commits to a Privacy Policy that has terms substantially consistent with this Privacy Policy.

4. Your Choices

4.1 Access, Correction, Deletion

We respect your privacy rights and provide you with reasonable access to the Personal Data that you may have provided through your use of the Services. If you wish to access or amend any other Personal Data we hold about you, or to request that we delete or transfer any information about you that we have obtained from an Integrated Service, you may contact us as set forth in the “How to Contact Us” section. At your request, we will have any reference to you deleted or blocked in our database.  Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

You may decline to share certain Personal Data with us, in which case we may not be able to provide to you some of the features and functionality of the Service.

At any time, you may object to the processing of your Personal Data, on legitimate grounds, except if otherwise permitted by applicable law. If you believe your right to privacy granted by applicable data protection laws has been infringed upon, please contact us at privacy@harbingerstrategy.com.  You also have a right to lodge a complaint with data protection authorities.

4.2 Opting out from Commercial Communications

If you receive commercial emails from us, you may unsubscribe at any time by following the instructions contained within the email or by sending an email to the address provided in the “How to Contact Us” section.

Please be aware that if you opt-out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten (10) business days for us to process your request. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the Service.

5. Third-Party Services

The Service may contain features or links to web sites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Service. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Service. We encourage you to learn about third parties’ privacy and security policies before providing them with information.

6. PRIVACY SHIELD

Harbinger Strategy’s US entity, Harbinger Strategy, LLC complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States.  Harbinger Strategy, LLC has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

In compliance with the Privacy Shield Principles, Harbinger Strategy commits to resolve complaints about our collection or use of your personal information.  EU or Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Harbinger Strategy at:

privacy@harbingerstrategy.com

Harbinger Strategy has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.jamsadr.com/ for more information or to file a complaint.  The services of JAMS are provided at no cost to you.

In any matters relating to the EU-U.S. Privacy Shield Framework, Harbinger Strategy is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

Under certain conditions, more fully described on the Privacy Shield website at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

Harbinger Strategy shall comply with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions. 

7. Your California Privacy Rights

We will not share any Personal Data with third-parties for their direct marketing purposes to the extent prohibited by California law. If our practices change, we will do so in accordance with applicable laws and will notify you in advance.

8. Do Not Track Policy 

Some browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference to the website or online service that a user visits, indicating that the user does not wish to be tracked. Because there is not yet a common understanding of how to interpret Do Not Track signals, we do not currently respond to Do Not Track signals. We continue to work with the online industry to define a common understanding of how to treat Do Not Track signals.

In the meantime, you may opt out of receiving interest based advertising from advertising networks that may be delivered on our platform and other websites by visiting the following websites. If you want to opt out of this online behavioral advertising, visit the following sites: http://www.aboutads.info/consumers and http://www.networkadvertising.org

This will opt you out of many – but not all - of the interest-based advertising activities in which we or third parties engage. Choices you make may be browser and device specific. If you delete your cookies or use a different browser or a different computer or device, you may need to update your opt-out choices. Other third-party Websites provide visitors with the ability to opt-out of receiving interest-based ads on their Websites that you need to control through your settings on that Website. For example, to opt out of Google’s use of your online behavior for advertising purposes, visit Google’s Ad Settings page.

9. Third Party Cookies

We allow third parties with which we have a separate agreement to use cookies and other technologies to collect information about your use of the Website. These third parties include (1) business partners, which collect information when you view or interact with one of their advertisements on the Website; and (2) advertising networks, which collect information about your interests when you view or interact with one of their advertisements.

The information gathered by these third parties is used to make predictions about your interests or preferences so that they can display advertisements or promotional material on this Website and on other sites across the Internet tailored to your apparent interests.

The business partners and advertising networks that serve interest-based advertisements on the Services have limited access to a small amount of information about your profile and your device, which is necessary to serve you advertisements that are tailored to your apparent interests. It is possible that they may reuse this small amount of information on other sites or services.

We do not share with these third parties any information that would readily identify you (such as email address); however, these third parties may have access to information about your device (such as IP or MAC address). We do not have access to, or control over, the technologies that these third parties may use to collect information about your interests, and the information practices of these third parties are not covered by this Privacy Notice. Other than as discussed in this document, we have no control over these third parties.

10.1 The Following Types of Cookies Are Used in the Website:

  • strictly necessary/essential cookies - These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies services you have asked for cannot be provided. These cookies don’t collect information that identifies a visitor.

  • performance cookies - These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and, therefore, anonymous. It is only used to improve how a website works.

  • functionality cookies - These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. For instance, a website may be able to provide you with local weather reports or traffic news by storing in a cookie the region in which you are currently located. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymized and they cannot track your browsing activity on other websites.

  • behaviorally targeted advertising cookies - These cookies are used to deliver adverts more relevant to you and your interests They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaigns. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organization.

10.2 The Following Cookies are Used in the Website: 

Service Provider // Cookie Name // Duration // Purpose:

Squarespace // Crumb // Session // Prevents cross-site request forgery (CSRF). CSRF is an attack vector that tricks a browser into taking unwanted action in an application when someone’s logged in.

Squarespace // RecentRedirect // 30 Minutes //Prevents redirect loops if a site has custom URL redirects. Redirect loops are bad for SEO.

Squarespace // CART // 2 Weeks // Shows when a visitor adds a product to their cart

Squarespace // hasCart // 2 Weeks // Tells Squarespace that the visitor has a cart

Squarespace // Locked // Session // Prevents the password-protected screen from displaying if a visitor enters the correct site-wide password.

Squarespace // SiteUserInfo // 3 Years // Identifies a visitor who logs into a customer account

Squarespace // SiteUserSecureAuthToken // 3 Years // Authenticates a visitor who logs into a customer account

Squarespace // Commerce-checkout-state // Session // Stores state of checkout while the visitor is completing their order in PayPal

Squarespace // squarespace-popup-overlay // Persistent // Prevents the Promotional Pop-Up from displaying if a visitor dismisses it

Squarespace // squarespace-announcement-bar // Persistent // Prevents the Announcement Bar from displaying if a visitor dismisses it

Squarespace // ss_cid // 2 Years // Identifies unique visitors and tracks a visitor’s sessions on a site

Squarespace // ss_cvr // 2 Years // Identifies unique visitors and tracks a visitor’s sessions on a site

Squarespace // ss_cvisit // 30 Minutes // Identifies unique visitors and tracks a visitor’s sessions on a site

Squarespace // ss_cvt // 30 Minutes // Identifies unique visitors and tracks a visitor’s sessions on a site

Squarespace // ss_cpvisit // 2 Years // Identifies unique visitors and tracks a visitor’s sessions on a site

Squarespace // ss_cookieAllowed // 30 Days // Remembers if a visitor agreed to placing Analytics cookies on their browser if a site is restricting the placement of cookies

11. Minors and Children’s Privacy

Protecting the privacy of young children is especially important. Our Service is not directed to children under the age of 18, and we do not knowingly collect Personal Data from children under the age of 18 without obtaining parental consent. If you are under 18 years of age, then please do not use or access the Service at any time or in any manner. If we learn that Personal Data has been collected on the Service from persons under 18 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 18 years of age has obtained an Account on the Service, then you may alert us at privacy@harbingerstrategy.com and request that we delete that child’s Personal Data from our systems.

The Service is not intended to be used by minors and is not intended to be used to post content to share publicly or with friends. To the extent that a minor has posted such content on the Service, the minor has the right to have this content deleted or removed using the deletion or removal options detailed in this Privacy Policy. If you have any question regarding this topic, please contact us as indicated in the “How to Contact Us” section. Please be aware that, although we offer this deletion capability, the removal of content may not ensure complete or comprehensive removal of that content or information.

12. Data Security

We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We maintain appropriate administrative, technical and physical safeguards to protect Personal Data against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Data in our possession. This includes, for example, firewalls, password protection and other access and authentication controls. We use SSL technology to encrypt data during transmission through public internet, and we also employ application-layer security features to further anonymize Personal Data.

However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store on the Service, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you believe your Personal Data has been compromised, please contact us as set forth in the “How to Contact Us” section.

If we learn of a security systems breach, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.

13. Data Retention

We only retain the Personal Data collected from a User for as long as the User’s account is active or otherwise as long as we need it to fulfill the purposes for which we have initially collected it, unless otherwise required by law. We will retain and use information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements as long as needed and in accordance with applicable laws.

14. Settings

Although we may allow you to adjust your privacy settings to limit access to certain Personal Data, please be aware that no security measures are perfect or impenetrable. We are not responsible for circumvention of any privacy settings or security measures on the Service. Additionally, we cannot control the actions of other users with whom you may choose to share your information. Further, even after information posted on the Service is removed, caching and archiving services may have saved that information, and other users or third parties may have copied or stored the information available on the Service. We cannot and do not guarantee that information you post on or transmit to the Service will not be viewed by unauthorized persons.

15. Data Transfer

We may transfer, process and store Personal Data we collect through the Services in centralized databases and with service providers located in the U.S. The U.S. may not have the same data protection framework as the country from which you may be using the Services. When we transfer Personal Data to the U.S., we will protect it as described in this Privacy Policy.

The Service is hosted in the United States. If you choose to use the Service from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you may be transferring your Personal Data outside of those regions to the United States for storage and processing by our service providers. We will comply with requirements providing adequate protection for the transfer of personal information from Europe to the U.S. Also, we may transfer your data to the EEA, or other countries or regions deemed by the European Commission to provide adequate protection of personal data in connection with storage and processing of data, fulfilling your requests, and operating the Service.

16. Changes and Updates to this Policy

Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify the Policy, we will make it available through the Service, and indicate the date of the latest revision, and will comply with applicable law. Your continued use of the Service after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of the Policy.

17. How to Contact Us

Please contact us with any questions or comments about this Policy, your Personal Data, our use and disclosure practices, your consent choices, or any concerns or complaints about this Policy or your Personal Data by email at privacy@harbingerstrategy.com.

Last update: September 4, 2018