Last revised: July 2nd, 2021
Effective date: July 2nd, 2021
Harmony ContentBase Inc. (“Harmony CB” or “we” and its derivatives) is committed to safeguarding your privacy. This Privacy and Cookie Policy (the “Policy”) describes our policies and procedures regarding the collection, use and disclosure of information we obtain through the website at https://harmonycb.com or https://app.harmonycb.com , sites created by users and hosted by Harmony CB (“Harmony CB” Sites”), and any other online or mobile services we may provide (all the above, collectively, the “HarmonyCB Service”). Please read the following information carefully to understand our views and practices regarding your personal data and how we will treat it.
To use the HarmonyCB Service, you must consent to the terms of this Policy and the Harmony CB Terms of Service, which is incorporated by reference, by clicking the button “I agree” to accept the Harmony CB Terms of Service and Privacy Policy below.
1. DEFINITIONS
As used in this Policy, a “Direct User” is an individual who has an account with Harmony CB and can build a Harmony CB Site, and an “End User” is an individual who visits a Harmony CB Site or https://harmonycb.com , but who has not registered with Harmony CB. Except where specified below, this Policy applies equally to both Direct and End Users.
2. PARTICULARLY IMPORTANT INFORMATION
WHO WE ARE. For the purpose of applicable data protection legislation, the data controller of your personal data is Harmony ContentBase Inc., 405 Lexington Avenue, 26th Floor New York, NY 10174.
MUST READ SECTIONS: We draw your attention in particular to the sections entitled “INTERNATIONAL DATA TRANSFER” and “YOUR RIGHTS.”
CHANGES TO THIS POLICY: We will post any modifications or changes to the Policy on the HarmonyCB Service. We reserve the right to modify the Policy at any time, so we encourage you to review it frequently. The “Last Updated” legend above indicates when this Policy was last changed. If we make any material change(s) to the Policy, we will notify you via email or post a notice on our Site prior to such change(s) taking effect.
3. LEGAL BASES FOR PROCESSING EU PERSONAL DATA
We use your personal information only as permitted by law. Our legal bases for processing the personal data described in this Policy are as follows:
• Legal compliance: We may need to collect, use, and otherwise process your personal data to comply with our legal obligations, such as regulatory monitoring and reporting obligations.
• Legitimate interests: We may process your personal data where we have a legitimate interest in doing so, provided that our interests are not outweighed by any potential impact of the processing on you, or your fundamental rights and freedoms.
• Contract: We may need to process your personal data to perform a contract with you or to take steps that you have requested prior to entering into the contract.
• Necessity: We may need to process your personal data to protect your vital interests, or those of another person.
• Consent: In some cases, we may rely on your consent to process your personal data. Where we rely on your consent, you have the right to withdraw it at any time in the manner indicated when we requested the consent or by contacting us as described in this Policy.
4. HOW WE COLLECT YOUR INFORMATION
Information You Provide.
We collect personal data from Direct Users when they register to use the HarmonyCB Service, post content on the HarmonyCB Service (such as in forums), or communicate with us (e.g., through the “Contact” page on our site, or when requesting customer service or technical support), make purchases through theHarmonyCB Service, or provide us with feedback about the HarmonyCB Service.
We may also collect personal data at other points in the HarmonyCB Service when clearly identified.
We do not collect personal data directly from End Users unless they contact us (i.e., through the “Contact” page on our site or to provide feedback about the HarmonyCB Service). Each individual operator of a Harmony CB Site determines what End User information is required to operate their Harmony CB Site, is required to comply with all applicable laws respecting the treatment of such information and is responsible for all use of such information. However, because Harmony CB Sites run on our infrastructure, the “Information Collected via Technology” section below applies equally to End Users and Direct Users.
Registration. To create an account, Direct Users need to provide an email address and password. Direct Users may provide other optional information, such as profile photos, their location, or job title, and, if signing up for a paid account, will have to provide payment information to our third party payment provider, subject to the terms below. Direct Users may always go to the “My account” section of the HarmonyCB Service to update, change, or remove their information.
Forum Use. To post on our Forum, Direct Users need to provide their email address, password, a username and may provide other optional information, such as profile photos. Direct Users may always go to their “Account Preferences” page to update or change their information.
Harmony CB Sites. We do not collect or use End User personal data, except to provide customer support, respond to direct requests, or as automatically collected through technical means as set forth below. As noted above, the operators of Harmony CB Sites may collect and use the information of End Users of their sites, including personal data and content posted to Harmony CB Sites. Harmony CB does not control or monitor such collection and usage.
Information Collected via Technology
Information Collected by Our Servers. To make the HarmonyCB Service more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, which may include your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.
Log Files. As is true of most websites, we gather certain information automatically and store it in log files. This information may include IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, data typed into the site, and clickstream data. We use this information to analyze trends, administer the HarmonyCB Service, track users’ movements around the HarmonyCB Service, gather demographic information about our user base as a whole, and better tailor the HarmonyCB Service to our users’ needs. For example, certain information may be collected so that when you visit the HarmonyCB Service again, it will recognize you and remember preferences. Except as noted in this Policy, we do not link this automatically-collected data to personal data.
How We Respond to Do Not Track Signals. We do not currently respond to “do not track” signals or other mechanisms that might enable you to opt out of tracking on our site.
Mobile Services. We may also collect non-personal data from your mobile device if you access the HarmonyCB Service from your mobile device. This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include your geographic location and information about the type of device you use. In addition, if the HarmonyCB Service crashes on your mobile device, we may receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of the service. This information is sent to us as aggregated information and cannot be used to identify an individual.
Analytics Services. In addition to the tracking technologies we place, other companies may set their own Cookies or similar tools when you use the HarmonyCB Service. This includes third party analytics services, such as Google Analytics (“Analytics Services”), that we engage to help analyze how users use the HarmonyCB Service, as well as third parties that deliver content or offers. We may receive reports based on these parties’ use of these tools on an individual or aggregate basis. We use the information we get from Analytics Services only to improve the HarmonyCB Service. The information generated by the Cookies or other technologies about your use of the service (the “Analytics Information”) is transmitted to the Analytics Services. The Analytics Services use Analytics Information to compile reports on user activity. The Analytics Services may also transfer information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. Each Analytics Services’ ability to use and share Analytics Information is restricted by such Analytics Services’ Terms of Use and Privacy Policy. By using the HarmonyCB Service, you consent to the processing of data about you by Analytics Services in the manner and for the purposes set out above. We may also partner with ad companies to support our marketing efforts, including by serving you ads better tailored to your likely interests. If you don’t want to take advantage of these services, you can opt-out by visiting http://www.aboutads.info/ or http://networkadvertising.org/choices/, or if you are located in the EU, http://www.youronlinechoices.eu/.
Cookies
Like many online services, we use Cookies to collect information. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them).
We use two broad categories of Cookies: (1) first party Cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits the HarmonyCB Service; and (2) third party Cookies, which are served by service providers on the HarmonyCB Service, and can be used by such service providers to recognize your computer or mobile device when it visits other websites.
Harmony CB uses Cookies to verify that you are properly signed in, to display information for your primary location, and to provide information about your Harmony CB Sites (if applicable). We may also use Cookies from time to time to measure your response to new aspects of the HarmonyCB Service and/or emails in an effort to continually improve customer service and the HarmonyCB Service. Please be aware that a Cookie cannot spread computer viruses, retrieve any other data from your hard drive, or capture your email address.
Cookies we use. The HarmonyCB Service uses the following types of Cookies for the purposes set out below.
a. Essential Cookies. These Cookies are essential to provide you with services available through our Services and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Services and help the content of the pages you request load quickly. Without these Cookies, the services that you have asked for cannot be provided, and we only use these Cookies to provide you with those services.
b. Functionality Cookies. These Cookies allow our Services to remember choices you make when you use our Services, such as remembering your language preferences, remembering your login details and remembering the changes you make to other parts of Services which you can customize. The purpose of these Cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Services.
c. Analytics and Performance Cookies. These Cookies are used to collect information about traffic to Services and how users use our Services. The information gathered does not identify any individual visitor. The information is aggregated and anonymous. It includes the number of visitors to our Services, the websites that referred them to our Services, the pages they visited on our Services, what time of day they visited our Services, whether they have visited our Services before, and other similar information. We use this information to help operate our Services more efficiently, to gather broad demographic information and to monitor the level of activity on our Services.
We use Google Analytics, Mixpanel, and other third party analytics services for this purpose. Google Analytics and Mixpanel use their own cookies. They are only used to improve how our Services works. You can find out more information about Google Analytics Cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies. You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.
You can find out more information about Mixpanel cookies and how they protect your data here: https://mixpanel.com/legal/privacy-policy/.
You can prevent the use of Google Analytics relating to your use of our Services by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB.
You can prevent the use of Mixpanel Cookies relating to your use of our Services by filling out the Mixpanel opt-out form via this link: https://mixpanel.com/optout/.
d. Social Media Cookies. These Cookies are used when you share information using a social media sharing button or “like” button on our Services or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter, or Google+. The social network will record that you have done this.
Disabling Cookies. You can typically remove or reject Cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept Cookies until you change your settings.
Further information about Cookies, including how to see what Cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.
Direct Users must accept Cookies in order to access certain features of the HarmonyCB Service. You can erase or block Cookies from your computer if you wish to do so (your internet browser help screen or manual will thoroughly explain this process), but certain parts of the HarmonyCB Service will not work correctly or at all if your browser is set to not to accept Cookies.
Automated decision-making or profiling
We do not use your personal data for the purposes of automated decision-making. However, we may do so in order to fulfill obligations imposed by law, in which case we will inform you of any such processing and provide you with an opportunity to object.
5. HOW HARMONY CB USES YOUR INFORMATION
Personal Data. In general, we use personal data either to deliver the HarmonyCB Service or respond to requests that you make. We use your personal data in the following ways:
• facilitate the creation and securing of your account (Direct Users only);
• identify you as a user of the HarmonyCB Service;
• operate, maintain, and provide improved administration of the HarmonyCB Service;
• improve the quality of experience when you interact with the HarmonyCB Service;
• manage your account, including to send you administrative e-mail notifications, such as security or support and maintenance advisories (Direct Users only);
• respond to your comments and inquiries related to employment opportunities or other requests and to provide customer service; and with your consent, send newsletters, surveys, offers, including information about products and services offered by us and our affiliates, and other promotional materials related to the HarmonyCB Service and for other marketing purposes of Harmony CB to Direct Users. You may opt-out of receiving such information at any time: such marketing emails tell you how to opt-out. Please note, even if you opt-out of receiving marketing emails, we may still send you non-marketing emails. Non-marketing emails include emails about your account with us (Direct Users only) and our business dealings with you.
• process payments you make via the HarmonyCB Service
• as we believe necessary or appropriate (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others; and
• as described in the Section entitled “HOW HARMONY CB MAY SHARE YOUR INFORMATION” below.
Anonymous Data. We may create anonymous data about both Direct Users and End User by excluding information (such as your name) that makes the data personally identifiable to you. We use this anonymous data to analyze request and usage patterns so that we may enhance the content of the HarmonyCB Service. We may use anonymous data and aggregated and other de-identified information for any purpose and disclose anonymous data to third parties in our sole discretion.
6. HOW HARMONY CB MAY SHARE YOUR INFORMATION
With Third Parties designated by you. We may share your personal data with third parties where you have provided your consent to do so.
With Third Parties. We may share your personal data with third party service providers (“Subprocessors”) to provide you with the HarmonyCB Service, to conduct quality assurance testing, to facilitate creation of accounts, to provide technical support, to conduct data analysis, to process payments, to provide information technology and related infrastructure provision, customer service, email delivery, and/or to provide other services. These Subprocessors are only permitted to use your personal data to the extent necessary to enable them to provide their services to us. They are required to follow our express instructions and to comply with appropriate security measures to protect your personal data.
We use Stripe, a third party payment processor, to process payments made through the HarmonyCB Service. In connection with the processing of such payments, we do not retain any personally identifiable information or any financial information such as credit card numbers. Rather, all such information is provided directly to Stripe, whose use of your personal data is governed by their privacy policy, which may be viewed at https://stripe.com/us/privacy.
Posting on the HarmonyCB Service. You may share personal data with us when you submit user generated content to the HarmonyCB Service. Please note that any information you post or disclose on the HarmonyCB Service will become public information, and will be available to other users of the HarmonyCB Service and to the general public.
We urge you to be very careful when deciding to disclose your personal data, or any other information, on the HarmonyCB Service. Such personal data and other information will not be private or confidential once it is published on the HarmonyCB Service. Harmony CB is not responsible for how others use such information. If you post personal data, even if you later remove it, other individuals who saw that personal data may retain copies of it through other means than the HarmonyCB Service. We or our Direct Users may occasionally reproduce, publish, and distribute content from reviews.
If you provide feedback to us, we may use and disclose such feedback on the HarmonyCB Service, provided we do not associate such feedback with your personal data. If you have provided your consent to do so, we may post your first and last name along with your feedback on the HarmonyCB Service. We will collect any information contained in such feedback and will treat the personal data in it in accordance with this Policy.
With SNS. The HarmonyCB Service or a Harmony CB Site may also enable you to post content to an SNS. If you choose to do this, we will provide information to such SNS in accordance with your elections. You agree that you are solely responsible for your use of an SNS and that it is your responsibility to review the terms of use and privacy policy of such SNS.
As Required by Law. We may access, preserve, and disclose your personal data, other account information, and content if we believe doing so is required by law or if those actions are reasonably necessary to:
• comply with legal process, such as a court order or subpoena;
• enforce this Policy or our Terms of Service;
• respond to claims that any content violates the rights of third parties;
• respond to law enforcement;
• investigate and prevent unauthorized transactions or other illegal activities; or
• protect our or others’ rights, property, or personal safety.
Corporate Events. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction. We cannot control how such entities may use or disclose such information.
Other Disclosures. We may share personal data as we believe necessary or appropriate: (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others.
We may also disclose your personal data with your permission.
7. THIRD PARTY SITES
The HarmonyCB Service may contain links to third party websites and features. This Policy does not cover the privacy practices of such third parties. These third parties have their own privacy policies and we do not accept any responsibility or liability for their websites, features or policies. Please read their privacy policies before you submit any data to them.
8. SECURITY OF YOUR INFORMATION
We seek to use reasonable organizational, technical and administrative measures to protect personal data within our organization. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the internet is not completely secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us at “legal [at] harmonycb [dot] com” By using the HarmonyCB Service or providing personal data to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the HarmonyCB Service. If we learn of a breach of personal data, we may attempt to notify you electronically by posting a notice on the HarmonyCB Service or sending an email to you. You may have a legal right to receive this notice in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice), please notify us using “legal [at] harmonycb [dot] com”.
9. RETENTION
We will only retain your personal data as long as reasonably required for you to use the HarmonyCB Service and/or to provide you with the HarmonyCB Service unless a longer retention period is required or permitted by law (for example, for regulatory purposes).
10. INFORMATION ABOUT CHILDREN
We do not knowingly collect, maintain, or use personal data from children under 13 years of age, and no part of the HarmonyCB Service is directed to children under the age of 13. If you learn that a child has provided us with personal data without your consent, you should alert us using “legal [at] harmonycb [dot] com”. If we learn that we have collected any personal data about children under 13, we will delete such information as soon as reasonably practicable.
11. INTERNATIONAL DATA TRANSFER
If you are a non-U.S. user of the HarmonyCB Service or visitor to a Harmony CB Site, by providing us with data, you acknowledge and agree that your personal data may be processed for the purposes identified in this Policy. Your information, including personal data that we collect from you, may be transferred to, stored at and processed by us and other third parties outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By using the HarmonyCB Service, you agree to this transfer, storing or processing.
12. SENSITIVE PERSONAL DATA
Subject to the following paragraph, we ask that you not send us, and you not disclose, any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) (“Sensitive Personal Data”) on or through the HarmonyCB Service or otherwise to us.
If you send or disclose any Sensitive Personal Data to us when you submit user-generated content to the HarmonyCB Service, you consent to our processing and use of such Sensitive Personal Data in accordance with this policy. If you do not consent to our processing and use of such Sensitive Personal Data, you must not submit such user generated content to our Services.
13. YOUR RIGHTS
The following rights may be available to you:
• Opt-out. You may contact us anytime to request to opt-out of: (i) direct marketing communications; (ii) automated decision-making and/or profiling; (iii) our collection of Sensitive Personal Data; (iv) any new processing of your personal data that we may carry out beyond the original purpose, where we have requested your consent prior to such processing; or (v) the transfer of your personal data outside the EEA, where we rely on your consent for such transfer. Please note that your use of some of the HarmonyCB Service may be ineffective upon opt-out.
• Access. You may request to access the information we hold about you at any time via your account page or by contacting us directly.
• Amend. You can also contact us to request to update or correct any inaccuracies in your personal data.
• Move. You may contact us to request that we move your data to other service providers as you wish.
• Erase and forget. In certain situations, for example when the information we hold about you is no longer relevant or is incorrect, you can request that we erase your data.
If you wish to exercise any of these rights, please contact us using “legal [at] harmonycb [dot] com”. In your request, please make clear: (i) what personal data is concerned; and (ii) which of the above rights you would like to request to enforce. We may deny your request where permitted by applicable law. For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event, within one month of your request. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.
14. COMPLAINTS
We are committed to resolve any complaints about our collection or use of your personal data. If you would like to make a complaint regarding this Policy or our practices in relation to your personal data, please contact us at: legal [at] harmonycb [dot] com. We will reply to your complaint as soon as we can and in any event, within 45 days. We hope to resolve any complaint brought to our attention, however if you feel that your complaint has not been adequately resolved, you reserve the right to contact your local data protection supervisory authority.
15. CHANGES TO THIS POLICY
Any changes to this Policy will always be posted to this section of the website, along with the effective date of the updated Policy. You should check this page periodically to stay abreast of any such changes. For any material changes to the Policy, we will notify Direct Users via email or by placing a prominent notice on the homepage of our website.
16. CONTACT INFORMATION
We welcome your comments or questions about this Policy. Please use hello@harmonycb.com to contact us in writing at:
Harmony ContentBase Inc. 405 Lexington Avenue, 26th Floor New York, NY 10174 USA
legal@harmonycb.com
