Privacy policy - Harbr Data

Harbr respects privacy and is committed to protecting personal data. This privacy policy explains how we look after personal data and sets out privacy rights.

We last updated our privacy policy on 27 March 2024.

1. Important information and who we are

Purpose of this privacy policy

This privacy policy gives information on how Harbr collects and processes personal data through direct interactions and the use of this website, including contact details of those requesting to receive insights or book a demo.

Our platform and services are intended for business users.

Harbr’s role

Harbr Group Limited (Company No.10671007) of 41 Luke Street, London EC2A 4DP is the controller and is responsible for personal data described in this privacy policy (referred to as “Harbr”, “we”, “us” or “our” in this privacy policy).

Harbr is made up of two different legal entities:

Harbr Group Limited (Company No.10671007) of 41 Luke Street, London EC2A 4DP; and
Harbr USA, Inc. with offices at 185 Alewife Brook Parkway Ste 210 Cambridge MA 02138

Harbr Group Limited is the controller of the personal data in this privacy policy. Harbr USA, Inc. may act as a processor of Harbr Group Limited from time to time, as would be usual within a group of companies. As between Harbr Group Limited and Harbr USA, Inc., there is a Data Sharing Agreement in place.

This privacy policy does not apply to the extent Harbr processes personal data in the role of a processor or service provider on behalf of its customers (including where Harbr offers its data commerce platform (DCP) to customers). When Harbr acts as a processor or service provider, the privacy policy of the customer who uses the DCP applies, instead of this privacy policy, and Harbr’s processing of such personal information is governed by Harbr’s agreements with such customers. For more information on the personal data Harbr processes on behalf of a customer, please contact the customer directly.

Contact details

If you have any questions about this privacy policy or our privacy practices, including any requests to exercise your legal rights, please contact our data privacy manager in the following ways:

Full name of legal entity: Harbr Group Limited

Email address: privacy@harbrdata.com

Postal address: Harbr Group Limited, 41 Luke Street, London EC2A 4DP

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review and may update it from time to time.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us (for example, if you move to a new organization and would like to continue receiving insights).

2. The data we collect about you

Personal data is any information about someone from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, store, and use different kinds of personal data which we have grouped together as follows:

Category of personal data	Description
Contact Data	Full name, company/entity, business unit/division, office location, job title/role, email address, phone number, including as part of sales & marketing and recruitment
Website User Data	In addition to Contact Data entered by the website user, internet protocol (IP) address, online identifiers/cookie, browser type and version, time zone setting and location, browser plug-in types and versions, operating system
Marketing & Communications Data	Preferences for receiving marketing communications from us; this may also include data about interactions with us via online and offline events
Transaction Data	Products/services supplied by us or to us, and invoicing & payment information
Platform User Data	Username and password, and information about how our DCP is used – more information on data use when using a DCP supplied by us to a client of ours is available from the applicable client whose DCP you are accessing
Recruitment Data	In addition to Contact Data, compliance data (e.g. proof of identity and right to work) and career data (e.g. education, qualification and work history). As part of the recruitment process you may be provided with additional privacy notices which show in greater detail how we use personal data for interviewing, assessment and for employees

In some circumstances we may anonymize personal data (so that it can no longer be associated to an individual and is therefore no longer personal data) for research or statistical purposes. In which case we may use this information indefinitely without further notice.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from personal data but, as long as it is not combined with other data to identify an individual, is not considered personal data in law as this data will not directly or indirectly reveal someone’s identity. For example, we may aggregate Website User Data to calculate the percentage of users accessing a specific website feature.

In our role as controller, we do not collect any special categories of personal data (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.

Note that this website is not intended for children and we do not knowingly collect data relating to children.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you (this does not include a contract with the company you represent), and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. We will notify you if this is the case.

3. How is your personal data collected?

We use different methods to collect personal data, including through:

Direct interactions. We may collect Contact Data, Marketing & Communications Data and Transaction Data if someone fills in forms on our website or corresponds with us by post, phone, email or otherwise. This includes personal data provided when someone:

makes an enquiry into our DCPs, or requests information be sent to them;
creates an account on our website or platform;
subscribes to our DCP or our publications;
requests marketing to be sent to them;
gives us their information at an event;
enters a competition, promotion or survey; or
gives us feedback or otherwise contacts us (including by post, phone or email)

Automated technologies or interactions. As someone interacts with us, including via our website and insight emails, we will automatically collect Website User Data about their equipment, browsing actions and patterns. We collect this personal data by using cookies, web tags, email pixels and other similar technologies. We may also receive Website User Data if someone visits other websites employing our cookies. Please see our cookie policy for further details.

Third parties or publicly available sources. We will receive personal data from various lawful sources, including:

Website User Data and Marketing & Communications Data from the following parties:

analytics providers;
advertising networks;
marketing services providers; and
search information providers.

Contact Data and Transaction Data from providers of technical and payment services.
Contact Data from data brokers or aggregators.
Contact Data from business-to-business marketing list providers.
Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK/EU.

4. Purposes for which we will use your personal data

We will only use personal data when the law allows us to. Most commonly, we will use personal data in the following circumstances:

Where it is necessary for our legitimate interests (or those of a third party) and the individual’s interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.
Where we need to perform a contract we are about to enter into or have entered into with the individual.

Generally, we do not rely on consent as a legal basis for processing personal data other than when someone requests us to send them communications. Where our legal basis is consent, they have the right to withdraw consent at any time by contacting us.

We have set out below a description of all the ways we may use personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. On request, we will always provide an explanation as to how the processing for the new purpose is compatible with the original purpose. If we need to use personal data for an unrelated purpose, we will notify those concerned and we will explain the legal basis which allows us to do so.

We may process personal data without the individual’s knowledge or consent where this is required or permitted by law.

We may process personal data for more than one lawful ground depending on the specific purpose for which we are using that data. On request, we will always provide details about the specific legal ground we are relying on to process personal data where more than one ground has been set out in the table below.

Activity/ Purpose	Categories of data	Lawful basis for processing including legitimate interest
Board & investor activities	Contact Data Transaction Data Platform User Data Website User Data Marketing & Communications Data Recruitment Data	Legitimate interest to relationship manage investors, to drive the success of the group of companies and how the value of Harbr Group is determined
Company administration activities	Contact Data	Compliance with a legal obligation Legitimate interest to ensure that any additional information related to the administration of the company is complete and for accurate reporting
Direct marketing activities	Contact Data Transaction Data Platform User Data Website User Data Marketing & Communications Data	Legitimate interests: to market our DCP/services to take leads and existing clients and sell DCPs to them
Finance activities	Contact Data Transaction Data	Legitimate interests: to ensure Harbr Group clients pay on time, to pay consultants, contractors and suppliers to undertake checks to ensure we know our clients, contractors and suppliers to mitigate the risk of fraud Compliance with a legal obligation
Legal & compliance	Contact Data Transaction Data Platform User Data Website User Data Marketing & Communications Data Recruitment Data	Compliance with a legal obligation Legitimate interests: to ensure we obtain professional advice where it would be appropriate to do so to be able to gather information and evidence, and to take advice, in connection with bringing and defending legal claims
Management & reporting activities	Contact Data Transaction Data Platform User Data Website User Data Marketing & Communications Data Recruitment Data	Legitimate interests: to ensure that leadership and board have complete and accurate reporting to ensure that any additional information related to the administration of the company is complete and for accurate reporting to ensure that our group of companies is properly administered (including structuring, tax planning, compliance, etc)
Marketing & events activities	Contact Data Platform User Data Website User Data Marketing & Communications Data	Legitimate interests: to market our DCP/services to take leads and existing clients and sell DCPs to them to better understand website & email engagement to better understand how our platform is used
Platform delivery activities	Contact Data Transaction Data Platform User Data	Legitimate interests: to negotiate, sign and administer contracts with clients of the Harbr Group to deliver the platform to clients and users to be able to support users of our platform to better understand how our platform is used to negotiate, sign and administer contracts with resellers of the Harbr Group
Procurement & supplier activities	Contact Data Transaction Data	Legitimate interest to negotiate, sign and administer contracts with suppliers to the Harbr Group
Product & engineering activities	Contact Data Platform User Data Website User Data	Legitimate interests: to be able to develop and iterate our technology to better understand website & email engagement to better understand how our platform is used to be able to manage documentation and know-how (in particular documentation relating to data exchanges and training and support materials, including content like videos/webinars)
Sales & business development activities	Contact Data Transaction Data Platform User Data Website User Data Marketing & Communications Data	Legitimate interests: to take leads and existing clients and sell DCPs to them to negotiate, sign and administer contracts with resellers of the Harbr Group to negotiate, sign and administer contracts with clients of the Harbr Group to relationship key stakeholders at partners of the Harbr Group, to drive the success of Harbr’s DCPs in the market to relationship key stakeholders at clients of the Harbr Group, to drive the success of Harbr’s DCP in the market to manage the success of the group, to drive the success of the group of companies (which affects talent, investment and overall value of Harbr Group)
Security & IT administration activities	Contact Data Platform User Data Website User Data	Legitimate interests: to have good IT and security to be able to react to events and retain Harbr’s ‘corporate memory’

5. Advertising, marketing, and communications preferences

We may use Contact Data, Website User Data, Marketing & Communications Data, Transaction Data and Platform User Data to form a view on what we think may be of interest to someone or their organization.

Our platform is a business-to-business product. We may share our insights via email if you have requested them, or if we think they may be of value to your organization or someone in your role.

Third party marketing

We will get express opt-in consent before we share personal data with any third party for marketing purposes.

Opt-out

Anyone can ask us or third parties to stop sending them marketing messages at any time by contacting us or using the link at the bottom of our emails.

Cookies and similar technologies

Anyone can set their browser to refuse all or some browser cookies, or to alert them when websites set or access cookies. If cookies are refused or disabled, some parts of our website may become inaccessible or may not function properly. For more information about the cookies we use, please view our cookie policy.

6. Disclosures of your personal data

We may share personal data with the parties set out below for the purposes set out in this privacy policy (or if the law otherwise allows it).

Suppliers and service providers including IT, analytics providers, and system administration services.
Auditors and professional advisers including lawyers, bankers, auditors and insurers.
Harbr group companies (for example, Harbr Group Limited may share data with Harbr USA, Inc)
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use the personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use personal data for their own purposes and only permit them to process personal data for specified purposes and in accordance with our instructions.

7. International transfers

Our processing of personal data is governed by the United Kingdom’s (UK) version of the GDPR (UK GDPR) and the Data Protection Act 2018.

Many of our external third parties are based outside the UK so their processing of personal data will involve a transfer of data outside the UK. Our group company in the US also processes personal data as part of our intragroup operations.

Whenever we transfer personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the safeguards permitted under the UK GDPR is used. These may include:

Transfer to countries or organizations that have officially been deemed to provide an adequate level of protection for personal data by the ICO, which currently includes the EEA (see here for an up-to-date list)
Using a specific contract approved by the EU/ICO – the EU Standard Contractual Clauses and the International Data Transfer Addendum. We currently use this contract for our transfers to the US (including to Harbr USA, Inc). However, with effect from 12 October 2023 the UK has established a data bridge for the “UK Extension to the Data Privacy Framework” that allows certified US companies to be able to receive UK personal data through the framework. Harbr US intends to sign up to this framework and, once it has, transfers to Harbr US will be on the basis of this data bridge. If any other third parties in the US, that we currently use the approved contract with, sign up to the framework, we will also rely on this data bridge to transfer them data.

Please contact us if you want further information on the specific mechanism used by us when transferring personal data out of the UK.

8. Data security

We have put in place appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify data subjects and any applicable regulator of a breach where we are legally required to do so.

9. Data retention

How long will you use my personal data for?

We will only retain personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to that individual.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data, the purposes for which we process personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

10. Your legal rights

Under certain circumstances, individuals have rights under data protection laws in relation to their personal data. Please contact us to find out more about these rights:

Request access to their personal data (commonly known as a “data subject access request”).
Request correction of their personal data.
Request erasure of their personal data.
Object to processing of their personal data in certain situations.
Request restriction of processing of their personal data.
Request the transfer of their personal data to them or a third party.
Right to withdraw consent at any time where we are relying on consent to process their personal data

If you wish to exercise any of these rights, please contact us.

No fee is usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

11. Third party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

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Harbr Privacy Policy