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HARBOUR PRIVACY POLICY

Last Updated: March 6, 2023

Welcome! This Privacy Policy explains how Harbour Enterprises, Inc. (“Harbour”,
“we”, “us” or “our”) processes personal information (as defined below) in
connection with our websites and related products and services (collectively,
the “Services”) that link to this Privacy Policy. This Privacy Policy does not
address our privacy practices relating to Harbour personnel. 

Please note: This Privacy Notice does not apply to personal information that
Harbour processes on behalf of clients as a data “processor” under the European
Union General Data Protection Regulation (“GDPR”), as a “service provider” under
the California Consumer Privacy Act (“CCPA”), or in a similar role under other
data protection laws applicable to our clients. We encourage you refer to our
clients’ own privacy disclosures for more information about their practices. 
If you are a client that is considering entering into a Data Processing
Agreement with Harbour for compliance with the GDPR, CCPA or other data
protection laws, please contact us for more information.

 * I. WHAT IS PERSONAL INFORMATION?
 * II. OUR COLLECTION AND USE OF PERSONAL INFORMATION
 * III. OUR DISCLOSURE OF PERSONAL INFORMATION
 * IV. THIRD-PARTY DATA COLLECTION AND ONLINE ADVERTISING
 * V. CONTROL OVER YOUR INFORMATION
 * VI. CHILDREN’S PERSONAL INFORMATION
 * VII. LINKS TO THIRD-PARTY WEBSITES OR SERVICES
 * VIII. UPDATES TO THIS PRIVACY POLICY
 * IX. CONTACT US
 * X. REGION-SPECIFIC DISCLOSURES


I.    WHAT IS PERSONAL INFORMATION?

When we use the term “personal information” in this Privacy Policy, we mean any
data or information that identifies, relates to, describes, is capable of being
associated with, or could reasonably be linked, directly or indirectly, with a
particular individual or household.


II.    OUR COLLECTION AND USE OF PERSONAL INFORMATION

We collect personal information in a variety of ways. For example, you may
provide us your personal information when you register for an account, send us
messages or use another feature of our Services. 

As described in more detail below, we also collect some personal information
automatically, and obtain some personal information from third parties. In some
cases, we may combine personal information from multiple sources in order to
better identify you.

Personal Information Collected from You
We may collect the following categories of personal information from you
directly:

 * Contact Information, including first and last name, phone number, email
   address, and job title.
 * Content You Upload or Submit, such as contracts, e-signatures, images and
   videos that you upload or submit. Please do not upload or transmit
   information that you do not feel comfortable sharing with us or with other
   users.
 * Payment Information, such as billing details. Please note we use Stripe, a
   third-party provider, to process payments on our behalf and do not accept
   payment directly through our Services. You can read Stripe’s privacy policy
   here.
 * Inquiry and Communications Information, including information you send us
   when you submit an online form, email us or send us chat messages.
 * Preference Information, including information regarding your interests and
   communication preferences.
 * Job Applicant Information. If you apply for a job for us, we may collect your
   name and contact information, demographic information, and information about
   your qualifications, professional history, and educational background, as
   well as other information you choose to share with us in your application,
   interview, or supporting documentation.
 * Feedback.  We may also collect feedback you provide relating to our
   Services. 

Personal Information Automatically Collected
Our Services are designed to automatically capture, store, track, and make
searchable customer agreements, media, audit logs, and metadata. For example, we
automatically collect certain personal information when you visit or interact
with our online Services, such as:

 * Log and Usage Data, including diagnostic, usage, and performance information
   our servers automatically collect when you access or use our Services and
   which we record in log files. Depending on how you interact with us, this log
   data may include your IP address, device information, browser type, and
   settings and information about your activity in the Services (such as the
   date/time stamps associated with your usage, pages and files viewed,
   searches, and other actions you take such as which features you use), device
   event information (such as system activity, error reports (sometimes called
   "crash dumps"), and hardware settings).
 * Device Data, including information about your computer, phone, tablet, or
   other device you use to access the Services. Depending on the device used,
   this device data may include information such as your IP address (or proxy
   server), device and application identification numbers, location, browser
   type, hardware model, Internet service provider and/or mobile carrier, and
   operating system.
 * Location data, such as your latitude and longitude. How much location data we
   collect depends on the type and settings of the device you use to access the
   Services. For example, we may use GPS and other technologies to collect
   geolocation data that tells us your current location (based on your IP
   address). In addition, we may use the Google Maps API to gather information
   about your location. Google uses various technologies to determine your
   location, including IP address, GPS, and other sensors that may, for example,
   provide Google with information on nearby devices, Wi-Fi access points, and
   cell towers. More information about Google’s privacy practices is available
   here.  
   You can opt out of allowing us to collect location data either by refusing
   access to the data and by disabling your location setting on your device.
   However, if you choose to opt out, you may not be able to use certain aspects
   of the Services. 

We and our third-party providers may use (i) cookies or small data files that
are stored on your computer and (ii) other, related technologies, such as web
beacons, pixels, embedded scripts, location-identifying technologies and logging
technologies (collectively, “cookies”) to automatically collect this personal
information. For more information about these practices and your choices
regarding cookies, please see the Control Over Your Information section below. 

Personal Information from Third Parties
We also obtain personal information from third parties as follows:

 * Single Sign On Authentication: We use Single Sign-On (SSO) to allow users to
   login through their Google and Microsoft accounts. These providers will
   authenticate your identity and provide you the option to share certain
   personal information with us, such as your name, profile photo, and email
   address. The data we receive depends on the third party’s policies and your
   privacy settings on the applicable third-party service. 
   For example, if you choose to connect a Google account to our Services, we
   will receive your name, email address, language preference, and profile
   picture. We use this information to create and service your account.  We may
   also use this information to operate, maintain, and provide to you the
   features and functionality of the Services.
 * Other Users: We may receive your information from other users of our
   Services. For example, we may receive your name and email address if another
   user asks you to sign a contract using our Services.
 * Social Media: When you interact with our Services through social media
   networks, such as when you follow us or share our content on LinkedIn,
   Twitter, YouTube, Instagram, or other social networks, we may receive some
   information about you that you permit the social network to share with third
   parties. The data we receive depends on your privacy settings with the social
   network, and may include your username and other profile information that you
   choose to post publicly.
 * Information We Receive From Other Third Parties.  We may receive personal
   information about you or information about your business from other third
   parties. For example, our marketing service providers may send us your
   contact information. In addition, if you choose to connect your account to a
   third-party service (via API or Webhook), such as Slack, we may collect
   information about you and your business, including your profile information,
   information about other users, and any other information collected by the
   platform.
 * Other Sources: We may also collect Personal Information about individuals
   that we do not otherwise have from, for example, publicly available sources,
   third-party data providers or through transactions such as mergers and
   acquisitions. We use this information to operate, maintain, and provide to
   you the features and functionality of the Services, as well as to communicate
   directly with you, such as to send you email messages about products and
   services that may be of interest to you.  

The data we receive from third parties depends on the applicable third party’s
policies and the privacy preferences you have expressed to that third party.  
Uses of Personal Information

We use personal information to: 

 * Deliver the Services you have requested. For example, we process personal
   information when you sign a contract made available to you via our services.
 * Customize our Services for you. For example, we use preference information
   you provide to personalize our Services.
 * Communicate with you, including via email, live chat and social media. For
   example, we may use your personal information to investigate and respond to
   questions you ask us.
 * Manage our organization and its day-to-day operations.
 * Engage in marketing and advertising, including to send you information and
   updates on products or services we think that you may be interested in.
 * Conduct research and analytics on our customer and user base and our
   Services.
 * Test, enhance, update and monitor the Services, or diagnose or fix technology
   problems.
 * Help maintain the safety, security and integrity of our property and
   Services, technology assets and business.
 * To enforce our contractual rights (such as the rights in our Terms of
   Service), to resolve disputes, to carry out our obligations and enforce our
   rights, and to protect our business interests and the interests and rights of
   third parties.
 * Prevent, investigate or provide notice of fraud or unlawful or criminal
   activity.
 * Comply with contractual and legal obligations, and enforce our contractual
   and legal rights.
 * To facilitate the recruiting and hiring process, if you apply for a job with
   us.
 * To fulfill any other purpose for which you provide personal information.
 * For any other lawful purpose, or other purpose that you consent to.

Where you choose to contact us, we may need additional information to fulfill
the request or respond to inquiries. We may provide you with additional
privacy-related information where the scope of the inquiry/request and/or
personal information we require fall outside the scope of this Privacy Policy.
In that case, the additional privacy policy will govern how we may process the
information provided at that time.


III.    OUR DISCLOSURE OF PERSONAL INFORMATION

We may also make available personal information to third parties as follows: 

 * Other Users: If you are working on specific contracts or other documents on
   our Services, photos and videos that you upload in connection with those
   documents as well as your name, email address, and e-signature may be made
   available to other users who are also working on those documents.
 * Service Providers: We engage other third-party service providers that perform
   business or operational services for us or on our behalf, such as customer
   service, marketing, communications services, website hosting, infrastructure
   provisioning, IT services, analytics services, app connection services,
   payment processing services, and administrative services.
 * We use and transfer of information received from Google APIs. All transferred
   and received information form Google’s APIs to any other app will adhere
   to Google API Services User Data Policy, including the Limited Use
   requirements.
 * Ad Networks and Advertising Partners: We work with third-party ad networks
   and advertising partners to deliver advertising and personalized content on
   our Services, on other websites and services, and across other devices. These
   parties may collect information directly from a browser or device when you
   visit our Services through cookies or other data collection technologies.
   This information is used to provide and inform targeted advertising, as well
   as to provide advertising-related services such as reporting, attribution,
   analytics and market research. Please see the Third-Party Data Collection and
   Online Advertising section.
 * Business Transaction or Reorganization: We may take part in or be involved
   with a corporate business transaction, such as a merger, acquisition, joint
   venture, or financing or sale of company assets. We may disclose personal
   information to a third party during negotiation of, in connection with or as
   an asset in such a corporate business transaction. Personal information may
   also be disclosed in the event of insolvency, bankruptcy or receivership.  
 * Legal Obligations and Rights: We may disclose personal information to third
   parties, such as legal advisors and law enforcement:
   * in connection with the establishment, exercise, or defense of legal claims;
   * to comply with laws or to respond to lawful requests and legal process;
   * to protect our rights and property and the rights and property of others,
     including to enforce our agreements and policies;
   * to detect, suppress, or prevent fraud;
   * to protect the health and safety of us and others; or
   * as otherwise required by applicable law.
 * With Your Consent: We may disclose personal information about you to certain
   other third parties or publicly with your consent or at your direction. For
   example, with your consent or at your direction we may post a testimonial
   from you on our Services or related publications.


IV.    THIRD-PARTY DATA COLLECTION AND ONLINE ADVERTISING

We may participate in interest-based advertising and use third party advertising
companies to serve you targeted advertisements based on your browsing history.
We permit third party online advertising networks, social media companies and
other third-party services, to collect information about your use of our online
services over time so that they may play or display ads on our Services, on
other websites or services you may use, and on other devices you may use. For
example:

 * Social Media Platforms. We may display targeted advertising to you through
   social media platforms, such as LinkedIn and other social media forums. These
   companies have interest-based advertising programs that allow us to direct
   advertisements to users who have shown interest in our services while those
   users are on the social media platform, or to groups of other users who share
   similar traits, such as likely commercial interests and demographics. We may
   share a unique identifier, such as a user ID or hashed email address, with
   these platform providers or they may collect information from our website
   visitors through a first-party pixel, in order to direct targeted advertising
   to you or to a custom audience on the social media platform. These
   advertisements are governed by the privacy policies of those social media
   companies that provide them. If you do not want to receive targeted ads on
   your social networks, you may be able to adjust your advertising preferences
   through your settings on those networks.
 * Third Party Partners.  We work with a variety of third-party partners to
   provide analytics and advertising services. For example, we use Mixpanel and
   Google Analytics to recognize you and link the devices you use when you visit
   our Services, log in to your account on our Services, or otherwise engage
   with us.  We share a unique identifier, like a user ID or hashed email
   address, with these third parties to facilitate the service. Google Analytics
   and Mixpanel allow us to better understand how our users interact with our
   Services and to tailor our advertisements and content to you.  For
   information on how Google Analytics collects and processes data, as well as
   how you can control information sent to Google, review Google's website, “How
   Google uses data when you use our partners’ sites or apps” located at
   www.google.com/policies/privacy/partners/. You can learn about Google
   Analytics’ currently available opt-outs, including the Google Analytics
   Browser Ad-On here: https://tools.google.com/dlpage/gaoptout/.
 * Typically, though not always, the information used for interest-based
   advertising is collected through tracking technologies, such as cookies, web
   beacons, embedded scripts, location-identifying technologies, and similar
   technology, which recognize the device you are using and collect information,
   including click stream information, browser type, time and date you visited
   one of our websites, AdID, precise geolocation and other information. We may
   share a common account identifier (such as a hashed email address or user ID)
   with our third-party advertising partners to help identify you across
   devices. We and our third-party partners use this information to make the
   advertisements you see online more relevant to your interests, as well as to
   provide advertising-related services such as reporting, attribution,
   analytics and market research. We may also use services provided by third
   parties (such as social media platforms) to serve targeted ads to you and
   others on such platforms. We may do this by providing a hashed version of
   your email address or other information to the platform provider.

For more information about these practices and your choices regarding cookies,
please see the Control Over Your Information section below.


V.    CONTROL OVER YOUR INFORMATION

You may control your information in the following ways:

 * Email Communications Preferences.  You can stop receiving promotional email
   communications from us by clicking on the “unsubscribe” link provided in such
   communications.  You may not opt-out of service-related communications (e.g.,
   account verification, transactional communications, changes/updates to
   features of the Services, technical and security notices).
 * Modifying or Deleting Your Information. If you have an account for our
   Service, you have the ability to modify certain information in your account,
   including your profile information, through the account setting page or a
   similar option provided on the Service. If you have any questions about
   reviewing, modifying, or deleting your information, you can contact us
   directly at privacy@harbourshare.com. We may not be able to modify or delete
   your information in all circumstances.
 * Cookies: If you would prefer not to accept cookies, most browsers will allow
   you to change the setting of cookies by adjusting the settings on your
   browser to: (i) notify you when you receive a cookie, which lets you choose
   whether or not to accept it; (ii) disable existing cookies; or (iii) set your
   browser to automatically reject cookies.  Be aware that disabling cookies may
   negatively affect the functionality of this and many other websites that you
   visit.  Disabling cookies will usually result in also disabling certain
   functionalities and features of the Services.
   Depending on your device and operating system, you may not be able to delete
   or block all cookies. In addition, if you want to reject cookies across all
   your browsers and devices, you will need to do so on each browser on each
   device you actively use. You may also set your email options to prevent the
   automatic downloading of images that may contain technologies that would
   allow us to know whether you have accessed our email and performed certain
   functions with it.
 * Online Ads: To learn more about interest-based advertising and how you may be
   able to opt-out of some of this advertising, you may wish to visit the
   Digital Advertising Alliance’s (DAA) resources and/or the Network Advertising
   Initiative’s (NAI) online resources, at www.aboutads.info/choices  or
   http://www.networkadvertising.org/choices/. You may also be able to limit
   interest-based advertising through the settings menu on your mobile device by
   selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads”
   (Android).  You may also be able to opt-out of some — but not all —
   interest-based advertising served by mobile ad networks by visiting
   http://youradchoices.com/appchoices and downloading the mobile AppChoices
   app. 
   Please note that when you opt out of receiving interest-based advertisements,
   this does not mean you will no longer see advertisements from us or on our
   online services.  It means that the online ads that you do see from DAA
   program participants should not be based on your interests.  We are not
   responsible for the effectiveness of, or compliance with, any third-parties’
   opt-out options or programs or the accuracy of their statements regarding
   their programs. In addition, third parties may still use cookies to collect
   information about your use of our online services, including for analytics
   and fraud prevention as well as any other purpose permitted under the DAA’s
   Principles.


VI.    CHILDREN’S PERSONAL INFORMATION

Our Services are not directed to children under the age of 13, and we do not
knowingly collect or solicit personal information from children under the age of
13 or intend to do so. Younger children should not use our Services or otherwise
provide us with any personal information either directly or by other means. If a
child under the age of 13 has provided personal information to us, we encourage
the child’s parent or guardian to contact us to request that we remove the
personal information from our systems. If we learn that any personal information
we collect has been provided by a child under the age of 13, we will promptly
delete that personal information.


VII.    LINKS TO THIRD-PARTY WEBSITES OR SERVICES

Our Services may include links to third-party websites, plug-ins and
applications. Except where we post, link to or expressly adopt or refer to this
Privacy Policy, this Privacy Policy does not apply to, and we are not
responsible for, any personal information practices of third-party websites and
online services or the practices of other third parties. To learn about the
personal information practices of third parties, please visit their respective
privacy policies. 


VIII.    UPDATES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. When we make changes to
this Privacy Policy, we will change the date at the beginning of this Privacy
Policy. If we make material changes to this Privacy Policy, we will notify
individuals by email to their registered email address, by prominent posting on
our Services, or through other appropriate communication channels. All changes
shall be effective from the date of publication unless otherwise provided.


IX.    CONTACT US

If you have any questions or requests in connection with this Privacy Policy or
other privacy-related matters, please send an email to privacy@harbourshare.com.


X.    REGION-SPECIFIC DISCLOSURES

Please see below for additional information that may apply to you depending on
where you live

A.    CALIFORNIA
California residents that have an established business relationship with us have
rights to know how their information is disclosed to third parties for their
direct marketing purposes under California’s “Shine the Light” law (Civ. Code
§1798.83). Please free to contact us at privacy@harbourshare.com with the
subject line “Shine the Light” to submit such a request.

B.    NEVADA 
If you are a resident of the State of Nevada, Chapter 603A of the Nevada Revised
Statutes permits a Nevada resident to opt out of future sales of certain covered
information that a website operator has collected or will collect about the
resident. We do not currently sell covered information, but you are free to
contact us at privacy@harbourshare.com with the subject line “Nevada Opt Out
Request” to submit such a request.




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