Harri US LLC – Privacy Notice (Last updated on January 10, 2025)

This Privacy Notice describes the information collection, use, retention and sharing practices of Harri US LLC (“Harri”, “we”, “us”, “our”) and its affiliates and subsidiaries when you interact with us through our website, www.harri.com (the “Website”), or other digital products on which this Privacy Notice appears (collectively, the “Services”).

As used in this Privacy Notice, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person.

PERSONAL INFORMATION WE COLLECT, WHY AND FOR HOW LONG 

We collect personal information as you engage with our Services. 

If you are a job applicant, this includes when you:

• Create a Harri profile. When you create a Harri profile, we collect, from you, your personal identifiers (name, email address, phone number), visual information (photograph (if provided)), professional or employment-related information (resume, job history, professional references), education information (institution, location, qualifications, dates), and any additional information you choose to include in your Harri profile. We use this information to create and manage your account, authenticate you, add you to our Talent Community, and to make your profile searchable and contactable by employers who can invite you to apply for positions. If you do not provide this information, we will not be able to set up your Harri profile. We may also use this information to send you job postings that may be of interest to you. You may withdraw your consent (unsubscribe) at any time by clicking the “unsubscribe” link included at the bottom of each email we send to you. We retain this information as long as is legally required, or until the applicant formally submits a data deletion request, in which case we will delete or anonymize the information within two days of receiving the request.
• Engage with job boards. When you choose to engage with job boards, we share the information you provided to create your Harri profile with the relevant employer to facilitate your job application(s). As the controller for the recruitment/employment process, the employer will have access to your application and will be able to use it to assess your suitability as a candidate with them. For example, the employer can use Harri to schedule interviews, make recruitment notes and to ask you specific questions during the recruitment process. The processing of your information by each employer is subject to the employer’s terms of use and privacy notice. 

If you are a partner, this includes when you: 

• Request a Demo. When you request a Demo, we collect, from you, your personal identifiers (name, email address, telephone number), professional or employment-related information (job title, company), and the selected solution(s) you are interested in. We use this information to schedule your Demo and to provide additional information regarding the solution(s) you are interested in.
• Partner with us. When you partner with us, we collect, from you, your personal identifiers (name, email address, telephone number) and your professional or employment-related information (job title, company name, company URL). We use this information to contact you and to facilitate the business relationship between Harri and the company you represent.

If you are a website visitor, this includes when you: 

• Contact customer support. When you contact customer support, we collect, from you, your personal identifiers (name and email address) and any additional information you choose to include in your message. We use this information to respond to your questions or inquiries and to troubleshoot where necessary. We retain this information for 120 days, before the ticket information is archived in an internal folder.
• Interact with our AI chatbot. When you interact with our AI chatbot, we collect, from you, your internet or other electronic network activity informaiton (location, IP address, device identifiers) and any additional information you choose to provide in the chat. We use this information to respond to your questions or inquiries and troubleshoot where necessary. We only retain this information if you choose to provide your contact information, in which case we will retain this information until you request us to delete it. 
• Sign up for email communication. When you sign up for emails on our Website, we collect, from you, your personal identifiers (name, email address). We use this information to send you periodic updates about new products and features. You may revoke your consent at any time with effect moving forward by clicking the “unsubscribe” link included with each email. Our emails contain tracking technologies, to analyze whether a predefined action took place by a recipient, such as opening our emails and other engagement metrics such as timestamps, delivery status, click rate (of links within an email), bounce rate, and reply rate. We also use these metrics to better adapt and distribute our emails, as well as to identify top engaged email recipients. When you sign up to receive emails on our website, you will be automatically opted-in to the use of these technologies.
• Interact with us on social media. Interact with us on social media. When you interact with our social media pages on social networking websites, such as Facebook, X, LinkedIn, Instagram, and YouTube (each a “Social Media Page” and collectively, “Social Media Pages”), we collect basic engagement metrics and use it to tailor content and marketing and use it to improve user experience as set forth in this section. Please note that we do not control the use or storage of the information that you have posted to any social networking websites. This information is collected and processed by the social networking websites for their own purposes, including marketing. For more information on how Facebook, X, LinkedIn, Instagram, and YouTube use your personal information, please see Facebook’s Privacy Policy, X’s Privacy Policy, LinkedIn’s Privacy Policy, Instagram’s Privacy Policy, and YouTube’s Privacy Policy.

• • • Social Media Pages. When interacting with our Social Media Pages, we collect, from you, your personal identifiers (first and last name) and visual information (photograph (i.e., profile picture)), as well as any information that you provide when interacting with our Social Media Pages (e.g., commenting, sharing, and rating). We use this information to advertise our products, for events and invitations, and to communicate with users via the contribution and comment function. Because our Social Media Pages are publicly accessible, when you use them to interact with other users, for example by posting, leaving comments or liking or sharing posts, any personal information that you post in them or provide when registering can be viewed by others or used by them as they see fit. The content posted on our Social Media Pages or other public areas of social networking websites can be deleted in the same way as other content that you have created. If at any time you want content posted to be deleted, please email your request to us at DPO@harri.com.
    • Community Management. We collect, from you, your contact, including "likes", shares, messages and other interactions with the content, in order to analyze and evaluate how our content is perceived, to learn from it, and to improve our public relations efforts.
    • Page Insights. When you visit our Social Media Page, the applicable Social Network records your IP address and other information about your usage behavior on our Social Media Page. The Social Network collects this information through trackers in the browser of your device or via the advertising ID (IDFA from Apple or GAID from Google), when you open the Social Network app through your mobile device (e.g., smartphone or tablet). The Social Network uses this information to provide us with statistical evaluations of the use of our Social Media Page. We receive this information directly from Social Network, in the form of aggregated data and anonymous statistics regarding certain data points, such as: age; gender; city/country; device; inquiries from fans about other Social Media Pages; region and language settings of the users; proportion of men and women; the number of people reached; clicks on posts, ”likes” and reactions; comments and shared content; and total video views. We use this information to analyze and improve the advertising campaigns we conduct through our Social Media Pages. We do not collect or process any other personal information in connection with Social Network “Page Insights” function.

      We do not retain this information independently. For information on data protection and the storage period on the Social Network in relation to its Insights function, see the Social Network privacy policy linked above. It has been contractually agreed with the Social Network that the Social Network is responsible for providing you with information about the processing for Page Insights.

    • Information Processed Solely by Social Networks. We do not know how the Social Networks use personal information for their own purposes, how long the personal information is stored on the Social Networks or whether the Social Networks’ data is passed on to third parties. If you are currently logged in to a Social Network as a user, the Social Network automatically collects, through trackers on your device, your Social Network ID or a link between the Social Network ID and the advertising ID (IDFA from Apple or GAID from Google) when you open the Social Network app through your mobile device (e.g., smartphone or tablet). This enables the Social Network to understand that you have visited our Social Media Page along with other social media pages that you have clicked on, whether you clicked on Social Network buttons integrated into websites that partner with the Social Network, and other online interactions that report user data to the Social Network. Based on this data, content or advertising tailored to you can be offered. You can find more information about the personal information collected by Social Networks, how it is used and how long it is stored by visiting the Social Network’s privacy policies, linked above.

• Interact with the Services. In addition to the personal information you provide directly to us, if you consent to the deployment of cookies and other technologies, we will also collect information from you automatically as you use the Services via cookies, pixels, web beacons, and similar tracking technologies.
  
  

  We use essential, performance, marketing, and analytics cookies to collect your usage, device, and location information (determined through your IP address) when you interact with the Services. We use this information to: (i) enhance user experience on the Services; (ii) conduct analytics to improve the Services; (iii) prevent fraudulent use of the Services and detect unlawful activity; and (iv) diagnosis and repair website errors, and, in cases of abuse, track and mitigate the abuse. Analytics and advertising cookies may be considered a sale or sharing under the California Privacy Rights Act. To opt out, please visit Do Not Sell or Share My Personal Information.

  Particular third-party cookies to note on our Website include the following:

  • • Google Analytics. We use Google Analytics to collect information on your use of the Website for its improvement. To collect this information, Google Analytics installs cookies on your browser or reads cookies that are already there. Google Analytics also receives information about you from applications you have downloaded that partner with Google. 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 our Website or to another application which partners with Google is restricted by the Google Analytics Terms of Use and Privacy Policy. To prevent your data from being used by Google Analytics, you can download the Google Analytics opt-out browser add-on, which can be accessed here. To opt out, please visit Do Not Sell or Share My Personal Information.
    • Google Tag Manager. Google Tag Manager is a tag management system to manage tags used for tracking and analytics on our Website. Tags are small code elements that, among other things, are used to manage traffic and visitor behavior and to test and optimize websites. We utilize Google Tag Manager to manage and organize all third-party tags on our Website and to control when those tags are triggered. You can view more information about Google Tag Manager’s privacy practices here. To opt out, please visit Do Not Sell or Share My Personal Information.
    • DoubleClick. We utilize DoubleClick by Google to serve ads based on a user’s prior visits to our Website. Each visitor to our Website receives a different cookie, and the information collected by the cookie is used to generate conversion statistics and allows us to see the total number of individuals who clicked on our ads. DoubleClick enables Google and its partners to serve ads to you based on your visits to our Website in addition to other websites on the Internet. Please review Google’s Privacy Policy for additional information on how Google uses the information collected. Such sharing may be deemed a sale under the California Consumer Privacy Act. To opt out of targeted advertising by Google and this sharing, you can go to Google’s Ad Settings, or you can install the DoubleClick opt-out browser plugin. To opt out, please visit Do Not Sell or Share My Personal Information.
    • Meta Pixel. We use Meta Pixel to serve you ads on your social media based on your browsing behavior. Meta Pixel sets a cookie on your device that allows your behavior to be tracked after you have been redirected to the Website by clicking on a Facebook ad. This enables us to measure the effectiveness of Facebook ads for statistical and market research purposes and to provide targeted advertising. We do not have access to the information collected through the Meta Pixel. The information collected via Meta Pixel is stored and processed by Meta. Meta may link this information to your Facebook account and use it for its own promotional purposes in accordance with Facebook’s Data Usage Policy. You can opt out of displaying Facebook ads and sharing by visiting your Facebook Ad Settings. To opt out, please visit Do Not Sell or Share My Personal Information.
• Aggregate and anonymize data. We aggregate and anonymize the data we collect for benchmarking purposes and for internal analytics. We maintain and use this data in deidentified form. We will not attempt to reidentify the data, unless it is necessary to determine whether our deidentification processes satisfy applicable data protection laws.

Harri will also use the personal information we collect as described in this section to comply with the law, to efficiently maintain our business, and for other limited circumstances as described in HOW WE SHARE YOUR PERSONAL INFORMATION.

DATA RETENTION 

Unless otherwise stated in this Privacy Notice, we retain your personal information (i) for as long you maintain an account with us, (ii) until we no longer need your information to fulfill the purposes for which we collected it, or (iii) until we receive a valid request to delete the information, in which case we will delete or anonymize the information within two (2) days after receiving the request. However, we may need to use and retain your personal information for longer than the periods indicated above for purposes of:

• Compliance with our legal obligations. For example, retaining personal information where we are legally required to do so. 
• Meeting our safety and security commitments. For example, keeping our properties secure and preventing fraud.
• Exercising or defending legal claims. We also may need to retain personal information for longer than the periods indicated above in order to respond to legal process or enforceable governmental requests, or to enforce our contracts or Terms of Use including investigation of potential violations.

Additionally, if the Services are made available to you through an organization (e.g., your employer), we are the processor for that personal information. The retention period for such information is decided upon by the employer. If your account is deactivated, the information that you have given to your employer will be retained in accordance with the employer’s privacy policy. 

HOW WE SHARE YOUR PERSONAL INFORMATION

A. General Sharing

Harri shares personal information in the following instances: 

• Within Harri. We share your personal information within Harri for the legitimate business purposes of efficiently and effectively providing the Services, such as accounting and customer service support. Access to your personal information is limited to those on a need-to-know basis.
• In the event of a corporate reorganization. In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we would share personal information with third parties, including the buyer or target (and their agents and advisors) for the purpose of facilitating and completing the transaction. We will also share personal information with third parties if we undergo bankruptcy or liquidation, in the course of such proceedings.
• For legal purposes. We share personal information where we are legally required to do so, such as in response to court orders, subpoenas, governmental/regulatory bodies, law enforcement or legal process, including for national security purposes. We may share your information with our legal advisors or auditors to establish, protect, or exercise our legal rights or as required to enforce our terms of service or other contracts or to defend against legal claims or demands. We also share this information with third parties as necessary to: detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person; to comply with the requirements of any applicable law; or to comply with our legal obligations.
• With your consent. Apart from the reasons identified above, we may request your permission to share your personal information for a specific purpose. We will notify you and request consent before you provide the personal information or before the personal information you have already provided is shared for such purpose. You may revoke your consent at any time with effect moving forward and may do so by contacting us via email at DPO@harri.com.

B. Sharing in the Last Twelve (12) Months

For a business purpose. In the preceding twelve (12) months, Harri has disclosed the following categories of personal information for a business purpose to the following categories of third parties: 

• We have disclosed your personal information to service providers that assist us in providing the Services. These service providers assist us with the following: information technology (“IT”) support; website hosting; cloud storage; data analysis; customer service; email delivery; marketing; external auditors; payment processing; and similar services.
• We have disclosed your internet or other electronic network activity information collected by cookies to our IT support to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to identify and repair the Services and platform errors.
• We have disclosed your internet or other electronic network activity information collected by cookies to our IT support to update, improve, and maintain the Services.

C. Sale of Personal Information 

In the preceding twelve (12) months, Harri has shared your internet or other electronic network activity information collected via cookies and other tracking technologies with our data analytics providers and ad networks as described in PERSONAL INFORMATION WE COLLECT, WHY AND FOR HOW LONG to provide targeted advertising. Such sharing may be deemed a sale or sharing under state data privacy laws. To opt out of the sale or sharing through cookies, please visit Do Not Sell or Share My Personal Information.

YOUR INFORMATION CHOICES

You have the following choices with respect to your personal information: 

• Correct or View Your Information. You may access your account to correct or view certain personal information you have provided to us, and which is associated with your account.
• Opt Out of Google Analytics. To prevent your personal information from being used by Google Analytics, you can download the Google Analytics opt-out browser, which can be accessed here.
• Opt Out of DoubleClick. To opt out of targeted advertising by Google and this sharing, you can go to Google’s Ad Settings, or you can install the DoubleClick opt-out browser plugin.
• Opt Out of Meta Pixel. You can opt out of displaying Facebook ads and sharing by visiting your Facebook Ad Settings.
• Opt Out of Advertising Cookies. All session cookies are temporary and expire after you close your web browser. Persistent cookies can be removed by following your web browser’s directions. To find out how to see what cookies have been set on your computer or device, and how to reject and delete the cookies, please visit: https://www.aboutcookies.org/. Please note that each web browser is different. To find information relating to your browser, visit the browser developer’s website and mobile application. If you reset your web browser to refuse all cookies or to indicate when a cookie is being sent, some features of our website may not function properly. If you choose to opt out, we will place an "opt-out cookie" on your device. The "opt-out cookie" is browser specific and device specific and only lasts until cookies are cleared from your browser or device. The opt-out cookie will not work for essential cookies. If the cookie is removed or deleted, if you upgrade your browser or if you visit us from a different computer, you will need to return and update your preferences. By clicking on the “Opt-Out” links below, you will be directed to the respective third-party website where your computer will be scanned to determine who maintains cookies on you. At that time, you can either choose to opt out of all targeted advertising or you can choose to opt out of targeted advertising by selecting individual companies who maintain a cookie on your machine. Our use of third-party marketing and analytics cookies is considered a sale/sharing under certain state privacy laws and is also considered to be what is known as interest-based advertising (IBA). To opt out of the sale/sharing through cookies and IBA across various platforms, please visit the Digital Advertising Alliance’s YourAdChoices program tools (Your Ad Choices) or visit one of the links below.
  • • Network Advertising Initiative (NAI) Opt-Out: https://www.networkadvertising.org/managing/opt_out.asp 
    • Digital Advertising Alliance (DAA) Opt-Out: https://optout.aboutads.info 
    • European Union (EU) /European Economic Area (EEA) Opt-Out: http://www.youronlinechoices.eu
    • In general, you can also disable cookies by setting your browser to refuse cookies or indicate when a cookie is being sent.
• Opt Out of Email Tracking. You can disable this tracking by blocking automatic loading of images in your email.
• Opt Out of Marketing Communications. You may opt out of receiving marketing emails from us by clicking the “unsubscribe” link provided at the bottom of each email we send. Please note that we will continue to send you notifications necessary to the Services.

RIGHTS OF CALIFORNIA RESIDENTS

The California Consumer Privacy Act as amended by the California Privacy Rights Act (collectively, “CCPA”) entitle California residents to certain rights. To the extent the CCPA applies to our processing of your personal information, you are entitled to the following rights:

• Right to Access/Know. You have the right to request what personal information we have collected, used, disclosed, and sold about you, unless doing so proves impossible or would involve disproportionate effort.
• Right to Deletion. You have the right to request the deletion of your personal information that we collect or maintain, subject to certain exceptions. For example, if we are required by law to retain the information that you are asking to be deleted, we would not be able to delete the information until we are legally permitted to delete it.
• Right to Correct. You have the right to correct inaccurate personal information that we collect or maintain.
• Right to Opt Out of Sale/Sharing. You have the right to opt out of the sale or sharing of your personal information to third parties.
• Right to Non-Discrimination. You have the right to not receive discriminatory treatment if and when you exercise your privacy rights under the CPRA.
• Right to Limit Use of Sensitive Personal Information. You have the right to limit the use of your sensitive personal information when such use goes beyond that which is necessary for providing the Services or certain other permissible purposes like fraud, customer service or quality control. Sensitive information includes Social Security number, driver’s license number, biometric information, precise geolocation, and racial and ethnic origin. However, Harri does not process personal information in a manner that gives rise to this right.

If you are a California resident and wish to exercise your privacy rights, you may submit a Data Request Form through our Data Request Portal or contact us at 844-427-7443. You may also submit a request via email to DPO@harri.com. To exercise your right to opt out of the sale/share of your information via cookies, please visit Do Not Sell or Share My Personal Information. 

For requests submitted via telephone, you must provide us with sufficient information that allows us to reasonably verify you are the person about whom we collected the personal information and describe your request with sufficient detail to allow us to properly evaluate and respond to it. In doing so, we will take steps to verify your request by matching information provided by you with the information we have in our records, including, for example, information on your resume. If we are not able to verify your identity for access and deletion requests with the information provided, we may ask you for additional pieces of information. 

Only you, or a person that you authorize to act on your behalf may make a request related to your personal information. If you are an authorized agent making a request on behalf of another individual, you must provide us with signed documentation that you are authorized to act on behalf of that individual.

Additionally, regarding your rights with respect to personal information that we may process on behalf of your employer, you will need to submit your request to the employer directly. We will assist your employer in fulfilling your request to the extent we are legally or contractually obligated required to.  

NEVADA RESIDENTS

If you are a consumer in the State of Nevada, you may request to opt-out of the current or future sale of your personal information. We do not currently sell any of your personal information under Nevada law, nor do we plan to do so in the future. However, you can submit a request to opt-out of future sales by contacting us at DPO@harri.com regarding the sale of such information. Please include “Opt-Out Request Under Nevada Law” in the subject line of your message.

DO NOT TRACK

We do not respond to Do Not Track requests. Do Not Track is a preference you can set in your web browser to inform websites and mobile applications that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser. 

INFORMATION SECURITY 

Harri maintains ISO 27001 certification. We implement appropriate technical and organizational security measures, such as access controls and encryption, to protect the personal information that we collect and maintain from unauthorized access, destruction, use, modification, or disclosure. However, no security measure or modality of data transmission is 100% secure, and we are unable to guarantee the absolute security of the personal information we have collected from you. 

CHILDREN’S PRIVACY 

We collect information of individuals over age fourteen (14) who apply for job applications with our clients. The Services are not intended for individuals under the age of fourteen) years. If we learn that we have collected or received personal information from individuals under the age of (14), we will delete the personal information. If you believe we have personal information on individuals under the age of fourteen (14), please contact us at the contact information provided below.

CHANGES TO THIS PRIVACY NOTICE

We may amend this Privacy Notice in our sole discretion at any time. If we do, we will post the changes to this page, and will indicate the date the changes go into effect. We encourage you to review our Privacy Notice to stay informed. If we make changes that materially affect your privacy rights, we will notify you by prominent posting on the Website and/or via email, and obtain your consent, if required.

CONTACT US 

If you have any questions about this Privacy Notice or need to access this Privacy Notice in an alternative format due to having a disability, please contact us by email at DPO@harri.com (and use “Privacy Inquiry” in the subject line) or by writing a letter to: 

Harri (US) LLC 

665 Broadway, Suite 402

New York, NY 10013