Harmon Privacy Policy

At Harmon we care about your privacy and the trust you place in us by providing Personal Information and we want to be transparent about how we use it and how we protect it.

Read this Privacy Notice (this “Privacy Notice”) with care. If you do not consent to the terms of the Privacy Notice please do not access or use the Services that Harmon and its affiliates (collectively referred to “Harmon,” “we,” “us,” or “our”) provide. This Privacy Notice will apply to you when you elect to use our Services.

This Privacy Notice (together with our Terms and Conditions and our Cookie Notice on www.joinharmon.com) describes how we collect, use, and share your Personal Information and the measures we take to keep it safe, your rights and choices with respect to your Personal Information, and how you can contact us if you have any questions or concerns.

Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).

This Privacy Notice applies anytime you connect with us – by visiting our website(s) or social media pages, or contacting us by phone, email, mail, or chat.

Content:

1. How to Contact Us
2. How we process your information
3. Sharing Your Information
4. Advertising and Analytics Services Provided by Others
5. Your Rights and Choices to Control Your Personal Data
6. Retention of Your Data
7. Privacy of Children
8. Safeguarding Your Information
9. Data Protection Authority
10. Privacy Notice Changes

1. How to Contact Us
   If you have questions about this Notice, or need help exercising your privacy rights, please contact hello@joinharmon.com.

   For the purpose of Regulation (EU) 2016/679 (the GDPR) and the UK-GDPR and the UK Data Protection Act 2018, together the “Data Protection Law” the data controller is Harmonbio Ltd, 33 Broadwick street, W1F0QD, London, UK. We are company number 13937817 registered in UK.

2. How we process your information
   The law requires us to determine the categories of data we process about you, to define the ways we process these, and to notify you of the basis for each category.

   If the basis changes, then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

   1. Information you chose to provide:
      NOTE: It is not standard Harmon practice to verify the provided personal data or the validity thereof. When providing an email address, all users assume responsibility that they are the exclusive user of the provided email address. For this reason, any liability for logins related to an email address shall be borne exclusively by the user who provided the email address.

      Type of Information	Examples of data collected	How we process your data
      Contact Details	Name, email. password	You may provide us with your contact details, when you register to submit a questionnaire on our website, or to create an account with us. We may use your contact details to send you administrative communications, such as, confirmation emails, technical notices, updates on policies, or security alerts. When you subscribe to receive our email newsletter updates, the information you provide is transferred to Mailchimp and Intercom for processing in accordance with their Privacy Policy and Terms. NOTE: you can unsubscribe any time using the unsubscribe link at the bottom of the communication. By sharing your information, you agree to Harmon’s Privacy Policy and to receive Harmon’s offers, promotions and other commercial messages. You may unsubscribe from our marketing emails at any time.
      Account Information	You may also choose to provide with your personal data, such as gender, age range or your address.	This information is required and is collected when you create a Harmon account to verify your identity for security purposes, provide you with our services, or to provide you with suggestions and advice on products, services.
      General health information	Completing our questionnaire	If you chose to complete our questionnaire, we will process the data you provide to provide you with suggestions and advice on products, services best suited to you.
      Social Media contents	Content to our website or other social media accounts	By using our Services, which shall include submitting content to our website or other social media accounts, you agree to be bound by the Terms and Conditions of Harmon. Anything that you upload is referred to as “User Content”. You retain all of your rights in all of the User Content you post to our Service, and you agree that all images, video, music, and narrative is your own content, and is non-confidential and non-proprietary. By uploading the content, you grant to us a non-exclusive, royalty-free, transferable, sublicensable, worldwide license to use, display, reproduce, re-post, modify (e.g., re-format), re-arrange, and distribute your User Content for the purposes of operating and providing the service(s) to you and to our other Users. You agree that content may be displayed or reproduced outside of the website, and may include posting on social media platforms, advertising (online, printed), newsletter posts, posters, booklets, and for editorial purposes. Nothing in these Termsthis Privacy Notice shall restrict HarmonJuvenescence rights under separate licenses to User Content.
      Aggregated data	Statistical or demographic data.	NOTE: aggregated data is derived from your Personal Information but is not Personal Information as this data will not directly or indirectly reveal your identity.

   2. Information we process based on your explicit consent:
      

      Type of Information	Examples of data collected	How we process your data
      Sensitive data	Medical information shared with us	We may obtain this data directly from you or through third party services you chose to avail to provide us with accurate medical information. We use this data to deliver services including testing and examinations, medical diagnoses, treatment, and the management of medication.

   3. Information we process through automated systems when you visit our website:
      NOTE: You may choose to adjust your device and bowser settings to collect information about you when you access our Services.

      Type of Information	Examples of data collected	How do we collect the data
      Device Information	The data collected varies depending on which device you use to access the Services. It may include IP addresses, geographical location, your internet provider, browser type, language, operating system	When your device accesses our website and services, data relating to your device is transferred from your device to our servers. This information is used by our security systems to track malicious activity on the website
      Usage Information	Network activity information, e.g., your interaction with the Services, for example, when you view or search content, create or log into your account, the referring web page, pages visited, and cookie information from aAnalytical, pPerformance and fFunctional cookies	When you access or use our Services, we receive certain usage or network We use anonymised information of this type in aggregate to assess the popularity of the webpages on our website and how we perform in providing content We use anonymised information of this type in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you
      Cookies	For detailed information please see our Cookie Notice	We may log information using cookies, which are small data files stored on your browser by the Website. We may use both session cookies, which expire when you close your browser, and persistent cookies, which stay on your browser until deleted, to provide you with a more personalized experience on the Website

3. Sharing Your Information
   Our website and our client database are hosted in the UK.

   Our newsletter subscription service and CRM are hosted in the United States of America.

   We take all steps reasonably necessary to ensure that any outsourced service providers implement appropriate safeguards to protect your personal information. We reserve the right to use service providers and host data outside of the UK however will comply with GDPR (and any applicable data protection legislation) in doing so, as further described in this section 3.

   1. Service Providers
      We may need to share your personal data with contracted laboratories, courier providers. Before any of your personal data can be sent outside of the UK or the EU, we must comply with strict conditions as laid down by the law.

      Additionally, the Website may use third-party service providers to service various aspects of the Website. Each third-party service provider’s use of your personal information is dictated by their respective privacy policies. For details of how our website uses Cookies, please see our Cookie Notice.

   2. Advertising and Marketing
      MailChimp – this service is used for delivery of email updates and newsletters. We store your name and email address for purposes of delivering such communications. Please refer to MailChimp’s privacy policy for further information. https://mailchimp.com/legal/privacy/

      Intercom – this service is used for delivery of email updates and newsletters. We store your name and email address, website events for purposes of delivering such communications. Please refer to Intercom’s privacy policy for further information.https://www.intercom.com/legal/privacy

      We may additionally use your data for the advertising of our services and content, promoting membership and network growth, engagement and our recommending other services which we believe may be relevant to you. We may combine information internally across our group of companies the different services covered by this Privacy Notice to help our services be more relevant and useful to you and others.

   3. Analytics
      Google Analytics – this service tracks Website usage and provides information such as referring websites and user actions on the Website. Google Analytics may capture your IP address, but no other personal information is captured by Google Analytics. https://policies.google.com/privacy
   4. Business Transfers
      If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider (collectively a “Transaction”), your Personal Information and other information may be shared in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate after the Transaction. In such events, we will continue to take measures to protect the confidentiality of personal information and give affected users notice before transferring any personal information to a new entity.
   5. Legally Required
      We may be required to disclose Personal Information pursuant to lawful requests, such as subpoenas, law enforcement investigations, or court orders, or in compliance with applicable laws. We also may release information to protect our rights, property, or other interests, including those of our customers or other third parties or to prevent illegal activities or violations of our Terms and Conditions. This may include sharing information with other companies, lawyers, agents, or government agencies.
   6. Social Sharing
      If you choose to contact or share information with Harmon on one of our social media platforms and/or use direct messaging to communicate with us via social media, we may contact you via direct message or use other social media tools to interact with you. In these instances, your interactions with us are governed by this Privacy Notice as well as the privacy notice of the social media platform you use.

      The website or its owners will never ask for personal or sensitive information through social media platforms. The website or its owners encourage users to contact them through primary communication channels such as by telephone or email.

4. Your Rights and Choices to Control Your Personal Data
   Depending on your jurisdiction, you may have a number of rights in relation to the personal data that we hold about you and we are committed to address these rights. These can be summarised as follows:
   1. You have the right to know what information we have collected about you and request a copy of the personal data we are processing about you. Under the Data Protection Act patients are entitled to receive a copy of their medical records. Upon request, we will provide this information to you in a structured, commonly used, and machine-readable format. Any applications should be made in writing. For your own privacy and security, in our discretion we may require you to prove your identity before providing the requested information.
   2. You have the rights to have your data corrected or removed or transferred to another service provider and to ask that we stop using your data.
   3. You have the right not to be subject to decisions that were made purely by machine, unless certain conditions apply.
   4. Where you have previously given your consent, you have the right to have that consent removed, unless a legal authority prevents us from doing this.
   5. You also have the right to be informed of certain security incidents which might have an impact on you.
   6. You have the right to raise a complaint with the data protection authority (supervisory authority). Please find their details below. Should you require access to your personal data you may make the request by using the link on our website or contacting us directly at hello@joinharmon.com
   7. You have the right to request that we erase or forget your personal data. To do so, please submit a request via email. Please note that we may need to retain certain information for record keeping purposes or to complete transactions, or when required by law.
5. Retention
   To determine the appropriate retention period for your Personal Information, we will consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we use your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

   Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:

   1. to provide you with the services you have requested;
   2. to comply with other law, including for the period demanded by our tax authorities;
   3. to honour your opt-out decisions from our marketing newsletter;
   4. to support a claim or defence in court.
6. Privacy of Children
   Our website is not intended for use by children or users under the age of 16 and we do not knowingly collect personal information from children without the consent of the parent or guardian. If a parent or guardian believes that the Website has personally identifiable information of a child under the age of 16 in its database, please contact us immediately via email and we will use our best efforts to promptly remove such information from our records.
7. Safeguarding Your Information
   At Harmon, we care greatly about the security of your Personal Information and are committed to protecting it against loss, misuse, or unauthorized access. To do this, we have implemented technical and organizational security measures, in an effort to safeguard the personal data in our custody and control. Such measures we have implemented include, for example, limiting access to personal data only to employees and authorized Service Providers who need to know such information for the purposes described in this Privacy Notice, as well as other administrative, technical, and physical safeguards such as encryption when receiving and transmitting information.

   However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect Personal Information, we cannot guarantee it is absolute security or confidentiality. We also encourage you to practice general internet safety guidelines, such as choosing a strong and unique password for your Harmon account, changing your password if you suspect it has been compromised, and signing out of your account when you are finished. Please note that Harmon will never ask for your credit card information over email.

8. Data Protection Authority
   Our Data Protection Authority is:
   Information Commissioner’s Office
   Wycliffe House Water Lane,
   Wilmslow
   Cheshire
   SK9 5AF Local
   0303 123 1113 Textphone – 01625 545860 international.team@ico.org.uk +44 1625 545 745 www.ico.org.uk
9. Privacy Notice Changes
   This Privacy Notice is subject to change without notice and was last updated on 16 May 2023. It is advised that you re-read this Privacy Notice from time to time to make sure you are happy with the various policies.