HARMON.IE PRIVACY POLICY

Last Updated: January 18 2022

In order to ensure transparency and give you more control over your personal information, this privacy policy (“Privacy Policy”) governs how we, harmon.ie Corporation and our affiliates (together, “harmon.ie” “we”, “our” or “us”) use, collect and store personal data we collect or receive from or about you (“you”) such as in the following use cases:

1. When you make use of, or interact with, our software applications: harmon.ie for Outlook, hamron.ie App for Office, Email TeamMate ("TeamMate") harmon.ie for iOS – harmon.ie Pro, harmon.ie Lite, harmon.ie for BlackBerry, harmon.ie for ME, harmon.ie for Android – harmon.ie Pro, harmon.ie Lite and any other mobile software application that we license (each individually, and collectively, “Software”)
2. When you browse or visit our websites - https://harmon.ie (“Website”);
3. When you make use of, or interact with, our Website
   1. When you request a free trial
   2. When you purchase a subscription to our Software
   3. When you subscribe to our blog
   4. When you register for our events
   5. When we process your job application
   6. When you contact us (e.g. contact sales, support team, need help, submit a request)
4. When you attend a marketing event and provide us with your personal data
5. Personal data of our customers (e.g. contact details)
6. Personal data of our resellers, distributors, agents and/or finders (e.g. contact details)
7. Personal data of our service providers (e.g. contact details)
8. When you interact with us on our social media profiles (e.g., Facebook, Twitter, LinkedIn)

We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to personal data. “Personal data” or “personal information” means any information that can be used, alone or together with other data, to uniquely identify any living human being. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. For example, the legal basis in the table below is only relevant for GDPR-protected individuals

Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement.

Table of contents:

1. What information we collect, why we collect it, and how it is used
2. How we protect and retain your personal data
3. How we share your personal data
4. Additional information regarding transfers of personal data
5. Your privacy rights
6. Use by children
7. Interaction with third party products
8. Log files
9. Analytic tools
10. Specific provisions applicable under California privacy law
11. How to contact us

This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy. If we implement significant changes to the use of your personal data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.

1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

Specific personal data we collect	Why is the personal data collected and for what purposes?	Legal basis (GDPR only, if applicable)	Third parties with whom we share your personal data	Consequences of not providing the personal data
When you make use of, or interact with, our Software
Email address Usage data about types of activities you perform using the Software	To create an account To allow you to use our Software To perform/execute the agreement To verify your identity when you log in to our Software	Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. Legitimate interest (e.g., to create an account)	Google Analytics (US): Web analytics service, used in harmon.ie Outlook and in harmon.ie app for Outlook & Office MixPanel (US): Business analytics service, used in harmon.ie Mobile	Cannot create an account Cannot allow you to use our Software Cannot perform the agreement Cannot verify your identity when you log in to our Software
When you browse or visit our Website
Cookies and analytic tools For more information, please read our cookies policy https://harmon.ie/legal/cookie-policy	In order to improve our Website and enhance your user experience. Read more about the purposes of each cookie here https://harmon.ie/legal/cookie-policy	Consent Legitimate interest (essential cookies)	Analytics Tools: Google Analytics, Hotjar	Certain Website features may not be available. Cannot provide the best website experience.
When you make use of, or interact with, our Website
When you request a free trial
Full name Job title Work mail address Company name Company size Country Additional question regarding the licenses that you want to purchase	To provide a free trial To receive and respond to your request	Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. Legitimate interest (e.g., to provide a free trial)	Marketo (US): Marketing automation platform Salesforce (US): Sales CRM Constant Contact (US) Email marketing platform Prismic (France): Content management system	Cannot provide a free trial Cannot receive and respond to your request
	To send you marketing communications	Consent Legitimate interest (e.g., to provide you information about harmon.ie)		Cannot send you marketing communications
When you purchase a subscription to our Software
Full name Job title Email address Phone Number Address Legal company name Number of employees Payment and billing Information	To purchase a subscription to our software	Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. Legitimate interest (e.g., to send you a price quote)	Drupal (US): Web content management Stripe (US): Online payment processing PayPal (US): Online payment processing	Cannot purchase a subscription to our software
When you subscribe to our blog
Email address	To allow you to sign up for the latest news from our blog	Legitimate interest (e.g to allow you to receive news from our blog)	Prismic (France): Content management system	Cannot receive the latest news from our blog
	To send you marketing communications	Consent Legitimate interest (e.g., to provide you information about harmon.ie)		Cannot send you marketing communications
When you register or attend our events
Full name Work email Job title Company Country	To allow you to register to our events To contact you in connection with our events	Legitimate interest (e.g., to allow you to register for our events)	Marketo (US): Marketing automation platform Salesforce (US): Sales CRM Constant Contact (US): Email marketing platform LogMeIn (US): Webinar Platform	Cannot register for our events Cannot contact you in connection with our events
	To send you marketing communications	Consent Legitimate interest (e.g., to provide you information about harmon.ie)		Cannot send you marketing communications
When we process your job application
Full name Email address CV / cover letter Any other information that you decide to provide/supply us	To assess you as a candidate To analyse your application	Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract Legitimate interest (e.g. to assess you as a candidate)		Cannot assess you as a candidate Cannot analyse your application
When you contact us (e.g. contact sales, support team, need help, submit a request)
Full name Job title Work email address Company name Company size Phone number Country Any other information that you decide to provide/supply us	To process and answer questions To assist you when you need to contact our sales team To assist you when you need to contact our support team To provide support (e.g., to solve problems, bugs or issues) To customize your experience	Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. Legitimate interest (e.g., to process and answer your questions)	Marketo (US): Marketing automation platform Salesforce (US): Sales CRM Prismic (France): Content management system	Cannot process and answer questions Cannot assist you when you need to contact our sales team Cannot assist you when you need to contact our support team Cannot provide support (e.g., to solve problems, bugs or issues) Cannot customize your experience
	To send you marketing communications	Consent Legitimate interest (e.g., to provide you information about harmon.ie)		Cannot send you marketing communications
When we use the personal data of our customers (e.g. contact details)
Full name Business email Company name Job title Phone number Number of employees Any other data you decide to provide	To provide our products and services To perform the applicable agreement To communicate with our customers/clients	Processing is necessary for the performance of a contract to which our customer is a party. Compliance with a legal obligation (e.g. tax laws, bookkeeping laws, etc.). Legitimate interest (e.g. send you contract-related communications)	Marketo (US): Marketing automation platform Salesforce (US): Sales CRM Constant Contact (US): Email marketing platform	Cannot provide our products and services Cannot perform the applicable agreement Cannot communicate with our customers/clients
Personal data of our resellers, distributors, agents and/or finders (e.g. contact details)
Full name Business email Company name Job title Phone number Number of employees Any other data you decide to provide	To perform the applicable agreement To communicate with our resellers, distributors, agents and/or finders	Processing is necessary for the performance of a contract to which our reseller, distributor, agent and/or finder is a party. Compliance with a legal obligation (e.g. tax laws, bookkeeping laws, etc.). Legitimate interest (e.g. send you contract-related communications)	Marketo (US): Marketing automation platform Salesforce (US): Sales CRM Constant Contact (US): Email marketing platform	Cannot perform the applicable agreement Cannot communicate with our resellers, distributors, agents and/or finders
Personal data of our service providers (e.g. contact details)
Full name Business email Company name Job title Phone number Number of employees Any other data you decide to provide	To receive your products and services To perform the applicable agreement To communicate with our service provider	Processing is necessary for the performance of a contract to which our service provider is a party. Compliance with a legal obligation (e.g. tax laws, bookkeeping laws, etc.). Legitimate interest (e.g. send you contract-related communications)	Marketo (US): Marketing automation platform Salesforce (US): Sales CRM Constant Contact (US): Email marketing platform	Cannot receive your products and services Cannot perform the applicable agreement Cannot communicate with our service provider
When you interact with us on our social media profiles (e.g., Facebook, Twitter, LinkedIn)
Full name Social media handle Any other data you decide to provide/supply	To respond to your requests in our Social Media Channels	Legitimate interest (e.g., to interact with you, when requested by you, on social media channels)	N/A	Cannot respond your request in our Social Media Channels

Finally, please note that some of the abovementioned personal data will be used for fraud detection and prevention, and for security purposes. The abovementioned personal data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize your personal data. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).

2. HOW WE PROTECT AND RETAIN YOUR INFORMATION
   1. Security. We have implemented appropriate technical, organizational and security measures designed to protect your personal data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
   2. Retention of your personal data. In addition to the retention periods mentioned above, in some circumstances we may store your personal data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your personal data or dealings. We have an internal data retention policy to ensure that we do not retain your personal data perpetually. Regarding retention of cookies, you can read more in our cookie policy https://harmon.ie/legal/cookie-policy. However, harmon.ie does not store or retain credit card or payment card numbers after they have been forwarded to its billing and payment processor(s), unless it is necessary for providing the Software.
3. HOW WE SHARE YOUR PERSONAL DATA
   In addition to the recipients described above, we may share your personal data as follows:
   1. To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
   2. If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your personal data to such third party (whether actual or potential) in connection with the foregoing events;
   3. In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your personal data in connection with the foregoing events; and/or
   4. Where you have provided your consent to us sharing or transferring your personal data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).
   If you want to receive the list of the current recipients of your personal data, please make your request by contacting us to privacy@harmon.ie.
4. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA
   1. Storage: Microsoft Azure: United States, subject to the Privacy Shield certification of Microsoft
   2. Access from Israel: Access from Israel is covered by the European Commission’s Adequacy Decision regarding Israel. You can read more here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.
   3. Access from EU (UK and Germany): Access from EU does not need any further transfer mechanisms in place.
   4. Internal transfers: Transfers within the harmon.ie group will be covered by an internal processing agreement entered into by members of the harmon.ie group (an intra-group agreement) which contractually obliges each member to ensure that personal data receives an adequate and consistent level of protection wherever it is transferred to.
   5. External transfers: Where we transfer your personal data outside of EU/EEA (for example to third parties who provide us with services), we will obtain contractual commitments from them to protect your personal data. Some of these assurances are well recognized certification schemes like the EU - US Privacy Shield for the protection of Personal Data transferred from within the EU to the United States.
5. YOUR PRIVACY RIGHTS. HOW TO DELETE YOUR ACCOUNT
1. Rights: The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):
   • You have a right to access personal data held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
   • You have the right to request that we rectify any personal data we hold that is inaccurate or misleading;
   • You have the right to request the erasure/deletion of your personal data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your personal data, for example for the establishment, exercise or defence of legal claims;
   • You have the right to object, to or to request restriction, of the processing;
   • You have the right to data portability. This means that you may have the right to receive your personal data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
   • You have the right to object to profiling;
   • You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
   • You also have a right to request certain details of the basis on which your personal data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;
   • You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.
   You can exercise your rights by contacting us at privacy@harmon.ie. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
2. Deleting your account: Should you ever decide to delete your account, you may do so by emailing privacy@harmon.ie. If you terminate your account, any association between your account and personal data we store will no longer be accessible through your account. However, given the nature of sharing on certain services, any public activity on your account prior to deletion will remain stored on our servers and will remain accessible to the public.
6. USE BY CHILDREN
   We do not offer our products or services for use by children and, therefore, we do not knowingly collect personal data from, and/or about children under the age of eighteen (18). If you are under the age of eighteen (18), do not provide any personal data to us without involvement of a parent or a guardian. For the purposes of the GDPR, we do not intend to offer information society services directly to children. In the event that we become aware that you provide personal data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at privacy@harmon.ie.
7. INTERACTION WITH THIRD PARTY PRODUCTS
   We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.
8. LOG FILES
   We use log files when you send us your log files for support, in order to provide you with support in connection with your use of the software.
9. ANALYTIC TOOLS
   • Google Analytics. The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with personal information. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at http://www.google.com/analytics/terms/us.html/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.
   • Mixpanel. We collect personal information such as your email address and your user activity through the use of Mixpanel. Mixpanel’s ability to use and share information is governed by the Mixpanel Terms of Use, available at https://mixpanel.com/terms/, and the Mixpanel Privacy Policy, available at https://mixpanel.com/privacy/. You can opt-out of Mixpanel’s services by clicking on the following link: https://mixpanel.com/optout/.
   • Hotjar. The Website uses Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular device's IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our Website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy at https://www.hotjar.com/legal/policies/privacy. You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our Website and Hotjar’s use of tracking cookies on other websites on this link https://www.hotjar.com/legal/compliance/opt-out.
   We reserve the right to remove or add new analytic tools.
10. SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA PRIVACY LAW
    1. California Privacy Rights: California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@harmon.ie. Please note that we will respond to one request per customer each year, unless otherwise required by law.
    2. Our California Do Not Track Notice: We do not track consumers over time and across third party websites and therefore do not respond to Do Not Track signals. We do not allow third parties to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Website.
    3. Deletion of Content from California Residents: If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or personal information you have publicly posted. If you wish to remove such content or personal information and you specify which content or personal information you wish to be removed, we will do so in accordance with applicable law. Please be aware that after removal you may not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or personal information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.
11. CONTACT US
    If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at privacy@harmon.ie.

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