Harmon Brothers
HARMON BROTHERS' GDPR POLICY
Last Updated 9/19/2018

I. Collection and Use of Personal Information. 

Harmon Brothers, LLC (also referred to herein as “Harmon Brothers”) may collect personal information from You. Personal information is information relating to an identifiable person who can, by virtue of such information, be directly or indirectly identified. You may be asked to provide Your personal information anytime You are in contact with Harmon Brothers or a Harmon Brothers affiliated company. Harmon Brothers and its affiliates may share this personal information with each other and use it consistent with this Privacy Policy. They may also combine it with other information to provide and improve our products, services, content, and advertising. You are not required to provide the personal information that we have requested, but, if you chose not to do so, in many cases we will not be able to provide You with our products or services or respond to any queries You may have.

II. What personal information we collect

When You create a Harmon Brothers User Account, purchase a product, download materials, or contact us, we collect a variety of information, including Your name, mailing address, phone number, e-mail address, and contact preferences. When payment, or payment information, is required, we will direct You to submit credit card information through a third-party such as Stripe.  

III. How we use Your personal information.

 The personal information we collect allows us to keep You posted on Harmon Brothers’ latest product announcements, content updates, and upcoming events. If You don’t want to be on our mailing list, You can opt out anytime by navigating to the unsubscribe link in the last e-mail You received from Harmon Brothers. You will have the option to unsubscribe from an individual list, or from all Harmon Brotherss lists. We also use personal information to help us create, develop, operate, deliver, and improve our products, services, content and advertising, and for loss prevention and anti-fraud purposes.  We may use Your personal information, including date of birth, to verify identity, assist with identification of users, and to determine appropriate services. For example, we may use date of birth to determine the age of Harmon Brothers University Account holders.  From time to time, we may use Your personal information to send important notices, such as communications about purchases and changes to our terms, conditions, and policies. Because this information is important to Your interaction with Harmon Brothers, You may not opt out of receiving these communications without severing any relationship between Yourself and Harmon Brothers. We may also use personal information for internal purposes such as auditing, data analysis, and research to improve Harmon Brothers’ products, services, and customer communications. 

IV. Collection and Use of Non-Personal Information. 

We also collect data in a form that does not identify any specific individual. We may collect, use, transfer, and disclose non-personal information for any purpose. The following are some examples of non-personal information that we collect and how we may use it:

We may collect information such as business, language, zip code, area code, unique device identifier, referrer URL, and the time zone where a Harmon Brothers product is used so that we can better understand customer behavior and improve our products, services, and advertising. We may collect information regarding customer activities on any of our websites. This information is aggregated and used to help us provide more useful information to our customers and to understand which parts of our website, products, and services are of most interest. Aggregated data is non personal information.  We may collect and store details of how You use our services. This information may be used to improve the relevancy of results provided by our services.  

V. Cookies and Other Technologies. 

Harmon Brothers’ websites, e-mail messages, and advertisements may use “cookies” and other technologies such as tracking, re-marketing tags, and pixels based on context, e.g., a search query, a channel You are reading, or inferred interests. These technologies help us better understand user behavior, tell us which parts of our websites people have visited, and facilitate and measure the effectiveness of advertisements and web searches. We treat information collected by cookies and other technologies as non personal information. We design and target advertising based on how You interact with Harmon Brothers. If You do not wish to receive ads targeted to Your interests from Harmon Brothers’, You can choose to limit ad tracking, which will opt Your Harmon Brothers ID out of receiving such ads regardless of what device You are using. You may still see ads based on context like a search query or a channel You are reading. Harmon Brothers and our partners also use cookies and other technologies to remember how You use our website and software. Our goal in these cases is to make Your experience with Harmon Brothers more convenient and personal, and provide You better customer service. To limit ad tracking, you may opt-out by clicking on this tool for (USA) or this tool for (EU) both of which are not directly Harmon Brothers-affiliated. You may also use Your browser’s settings to disable cookies and other tracking tools. Please note that certain features of the Harmon Brothers website may not be available once cookies are disabled. We gather some information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, and clickstream data. We use this information to administer the site, to learn about user behavior on the site, to improve our product and services, and to gather demographic information about our user base as a whole. Harmon Brothers may use this information in our marketing and advertising services.

In some cases we use a “click-through URL” linked to content on the Harmon Brothers website. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on our website. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our marketing communications. We also use it to account for Affiliate activity and pay Affiliate commissions and bonuses.

VI. Disclosure to Third Parties. 

At times Harmon Brothers may make certain personal information available to strategic partners that work with Harmon Brothers to provide products and services, or that help Harmon Brothers market to customers. Personal information will only be shared by Harmon Brothers to provide or improve our products, services and advertising; it will not be shared with third parties for their marketing purposes.

VIII. Retention of Personal Information. 

Harmon Brothers will retain Your personal information for as long as You have a Harmon Brothers account. After Your Harmon Brothers account is terminated, we will retain Your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.


IX. Access to Personal Information. 

You can help ensure that Your contact information and preferences are accurate, complete, and up to date by logging in to Your account in your Harmon Brothers account portal. For other personal information we hold, we will provide You with access (including a copy) upon Your request. We may decline to process requests that are frivolous, vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. Access, correction, or deletion requests can be made by contacting community@harmonbrothers.com.

X. Children & Education. 

We understand the importance of taking extra precautions to protect the privacy and safety of children using Harmon Brothers products and services. Children under the age of 18, are not permitted to create their own Harmon Brothers accountsl instead, a parent must obtain the account and provide the parent’s information to Harmon Brothers. If we learn that we have collected the personal information of a child under 18 we will delete the information as soon as possible.

XI. Third Party Sites and Services. 

Harmon Brothers websites, products, applications, and services may contain links to third-party websites, products, and services. Our products and services may also use or offer products or services from third parties. Information collected by third parties is governed by their privacy practices. We encourage You to learn about the privacy practices of those third parties.

XII. Your Rights Under the GDPR.

If You are a citizen or a resident of a country in the European Union, the GDPR grants You the following rights:

a. Access to Your Personal Data. You have the right to receive a copy of Your personal data that is subject to processing by Harmon Brothers. Ordinary requests will be granted without charge to You within one calendar month of when You make the request. In cases of excessive, unreasonable, or repeated requests Harmon Brothers may charge You a reasonable fee and may require additional time to grant Your request. Also, Harmon Brothers may use reasonable means to confirm Your identity before granting any request for data so as to prevent granting fraudulent requests. To request a copy of Your personal data, please contact us by e-mail at community@harmonbrothers.com. 

b. To have Your Data Corrected. If Your personal data is erroneous or outdated, You have the right to have it corrected. To do so, please contact Harmon Brothers via e-mail at community@harmonbrothers.com.

c. To be Forgotten. You have the right to be forgotten by Harmon Brothers. You may exercise this right by e-mailing us at community@harmonbrothers.com. We will comply with Your request, at no charge to You, within one calendar month by deleting Your account, along with all of Your personally-identifiable data that is subject to any Harmon Brothers processing. Naturally, after we grant Your request You will not have access to any Harmon Brothers products or services unless and until You open a new Harmon Brothers account. Harmon Brothers may use reasonable means to confirm Your identity before granting any request for data so as to prevent the granting of fraudulent requests.

d. To Restrict Processing of Your Data. You can request that Your data not be processed via Harmon Brothers partners. You can make that request by e-mailing us at ccommunity@harmonbrothers.com and, if you wish, you can even specify which third parties to restrict from processing Your data. We will respond to Your request, at no charge to You, within thirty (30) days from when You make Your request. Please be advised that some of our partners, e.g., Stripe, are essential to Harmon Brothers services, so that if You block processing by them, Harmon Brothers’ services may be unavailable to You.

e. Portability. You have the right to receive a copy of Your personal data that is subject to processing by Harmon Brothers in a portable format, or to have it transferred directly from Harmon Brothers to another party. Ordinary requests will be granted without charge to You within one calendar month of when You make the request. Harmon Brothers may use reasonable means to confirm Your identity before granting any request to transfer data to You or another party so as to prevent granting fraudulent requests. To request a copy of Your personal data in a portable format, or to request a direct transfer of Your data, please contact us by e-mail at community@harmonbrothers.com.

XIII. Your Responsibility Under GDPR. 

If You are a Harmon Brothers University student, then that probably means You are a business owner, using the Harmon Brothers methods to sell goods and services to Your customers. With respect to the customer data that You provide to Harmon Brothers, Harmon Brothers is a data processor and will comply with its obligations under the GDPR; but with respect to Your customers, You are probably a data controller, and if any of Your customers is a citizen or a resident of a country in the European Union, then You must ensure that You comply with Your obligations as a data controller under the GDPR; namely, You must ensure that You afford Your Customers the rights identified in section (a) above. Harmon Brothers sells training and advertising services; it does not provide legal advice or legal services, nor does it sell a “done-for-you” GDPR compliance package. Please consult legal counsel of Your own choosing for advice on what You need to do to comply with GDPR.

XIV. Our Companywide Commitment to Your Privacy. 

To make sure Your personal information is secure, we communicate our privacy and security guidelines to Harmon Brothers employees and strictly enforce privacy safeguards within the company.

XV. Privacy Questions. 

If You have any questions or concerns about Harmon Brothers’ Privacy Policy or data processing or if You would like to make a complaint about a possible breach of local privacy laws, please contact us at community@harmonbrothers.com. When a privacy question or an access or download request is received we have a team dedicated to addressing the specific concern or query which You are seeking to raise. In responding to Your request, we may need to request more information from You. If You are unsatisfied with the response You receive, You may refer Your complaint to the relevant regulator in Your jurisdiction. If You ask us, we will endeavor to provide You with information about relevant complaint avenues which may be applicable to Your circumstances. If You live in the European Economic Area, United Kingdom, or Switzerland, and You wish to contact us regarding questions or to exercise Your statutory rights, please contact us at community@harmonbrothers.com, or You may contact our Data Protection Officer, Jordan Allen, at jordan@harmonbrothers.com.

XVI. Updates to the Policy. 

Harmon Brothers may update its Privacy Policy and this GDPR Policy from time to time, as posted on our website.

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