Privacy Policy

Last updated: December 2nd, 2024

This Privacy Policy explains how information about you is collected, used, and shared by Harbinger Labs Inc, doing business as Clarative ("Company," " we," " us," and " our"). This Privacy Policy is intended to inform our users (“user(s)”, “you”, or “your”) about how we may collect and use the personal information that you provide through your use of and access to our website http://www.Clarative.ai, as well as its features and services (the “Site”), the manner in which we may use such information, how we protect it, and the choices available to you regarding our use of your personal information.

We may modify or supplement this Privacy Policy from time to time by posting those changes on this page. Any changes will become effective as of the date of posting. Please review this Privacy Policy often so you are always fully informed of any changes.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us or if you are aware that any personal data, we hold is inaccurate.This Privacy Policy is binding on all those who access, visit, and/or use the Site, whether acting as an individual or on behalf of an entity.  If you do not agree to be bound by this Privacy Policy, then do not access or use the Site.

This Privacy Policy is part of our Terms of Use, which govern your use of the Site. By using the Site, contacting us to inquire about the Site, or otherwise providing us with information, you consent to our Privacy Policy and agree to our Terms of Use.

1. THE DATA WE COLLECT

a. Personal Data

While using the Site, we may ask you to provide certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to email, name, birthdate, physical address, phone number, financial information, or transactional data.

b. Usage Data

Usage Data is data about how you use the Site and is collected automatically when using the Site and may include information such as your device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Site by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

We may also collect information that your browser sends whenever you visit the Site or when you access the Site by or through a mobile device.

c. Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on the Site and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze the Site. The technologies we use may include:
* Web Beacons. Certain sections of the Site and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
* Cookies or Browser Cookies. A cookie is a small file placed on your device. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some parts of the Site. Unless you have adjusted your browser setting so that it will refuse cookies, the Site may use cookies.Cookies can be "persistent" or "session" cookies. Persistent cookies remain on your personal computer or mobile device when you go offline, while session cookies are deleted as soon as you close your web browser.

We use both session and persistent cookies for the purposes set out below:

Necessary / Essential Cookies
Type
: Session Cookies
Administered by: Us
Purpose: These cookies are essential to provide you with services available through the Site and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.

Cookies Policy / Notice Acceptance Cookies
Type
: Persistent Cookies
Administered by: Us
Purpose: These cookies identify if users have accepted the use of cookies on the Site.

Functionality Cookies
Type
: Persistent Cookies
Administered by: Us
Purpose: These cookies allow us to remember choices you make when you use the Site, such as remembering your login details or language preference. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you use the Site.


2. USE OF YOUR PERSONAL DATA

We may use the Personal Data we collect for the following purposes:

- To provide and maintain the Site, including to monitor the usage of the Site.
- To manage your account.
- For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased or of any other contract with us through the Site.
- To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products, or contracted services, including the security updates, when necessary or reasonable for their implementation.
- To provide you with news, special offers and general information about other goods, services, and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.
- To manage your requests.
- For business transfers: We may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us about the Site users is among the assets transferred.
- For other purposes : We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve the Site, products, services, marketing and your experience.
- For compliance with legal or regulatory obligations.

3. HOW WE SHARE YOUR DATA

We may share your personal data in the following situations:

With service providers: We may share your data with service providers to monitor and analyze the use of the Site.
For business transfers: We may share or transfer your data in connection with, or during negotiations of, any merger, sale of our assets, financing, or acquisition of all or a portion of our business to another company.
With affiliates: We may share your data with our affiliates, in which case we will require those affiliates to honor this Privacy Policy.
With business partners: We may share your data with our business partners to offer you certain products, services or promotions.
With other users: When you share data or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
With your consent: We may disclose your data for any other purpose with your consent.

4. RETENTION OF YOUR DATA

We will only retain your personal data for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you

5. TRANSFER OF YOUR DATA

Your data, including personal data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside the United States and choose to provide data to us, please note that we transfer the data, including personal data, to the United States and process it there.

Your consent to this Privacy Policy followed by your submission of such data represents your agreement to that transfer.

We will take all the steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Policy and no transfer of your personal data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal data.

6. DATA SECURITY

We incorporate commercially reasonable safeguards to help protect and secure your personal information. However, no data transmission over the Internet, mobile networks, wireless transmission, or electronic storage of information can be guaranteed 100% secure. As a result, we cannot guarantee or warrant the security of any information you transmit to or from the Site, and you provide us with your information at your own risk.

If you have any questions about security on the Site or if you become aware of any unauthorized use of an account or suspect a security breach, notify us immediately via email at info@clarative.ai. If our security system is breached, we will notify you of the breach only if and to the extent required under applicable law.

7. CHILDREN’S PRIVACY

The Site does not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from anyone under the age of 18 without verification of parental consent, we take steps to remove that information from our servers.

If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent's consent before we collect and use that information.

8. LINKS TO OTHER WEBSITES

The Site may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the privacy policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

9. Your Data Protection Rights Under the General Data Protection Regulation (GDPR)

If you are a resident of or located within the European Economic Area (EEA), you have certain additional data protection rights. These rights include:

- The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your personal information directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
- The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
- The right to object. You have the right to object to our processing of your personal information.
- The right of restriction. You have the right to request that we restrict the processing of your personal information.
- The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
- The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your personal information.

Legal Basis for Processing Personal Information Under GDPR
Our legal basis for collecting and using the personal information described in this Privacy Policy depends on the personal information we collect and the specific context in which we collect it.
We may process your personal information because:
- We need to perform a contract with you;
- You have given us permission to do so;
- The processing is in our legitimate interests and it is not overridden by your rights; or
- To comply with the law.

Retention of Information
We will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your information to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

We will also retain usage data for internal analysis purposes. Usage data is data collected automatically either generated by the use of the Site or from the Site’s infrastructure itself (for example, the duration of a page visit). Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of the Site or we are legally obligated to retain this data for longer periods.

Disclosure of Personal Information

Disclosure for Law Enforcement - Under certain circumstances, we may be required to disclose your personal information if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

Legal Requirements

We may disclose your personal information in the good faith belief that such action is necessary to:
- To comply with a legal obligationTo protect and defend our rights or property
- To prevent or investigate possible wrongdoing in connection with the Site
- To protect the personal safety of users of the Site or the public
- To protect against legal liability

Security of Information
The security of your personal information is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

Please note that we may ask you to verify your identity before responding to such requests.

Should you wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority; however, we hope that we can assist with any queries or concerns you may have about our use of your personal information first.

For more information, please contact your local data protection authority in the EEA.

10. STATE PRIVACY RIGHTS

Under some U.S. state laws residents may have the rights listed below:

- Right to Know: The right to request the personal data that we collect, uses or discloses and information about our data practices;
- Right to Request Deletion: The right to request that we delete the personal data we have collected about a user;
- Right to Opt-Out of Data Sales: The right to restrict the sale to third parties of a user’s personal data that we have collected;
- Right to Non-Discrimination: The right to not be discriminated against for exercising any of these rights;
- Right to Correct Information: The right to update or correct the personal data that we collect;
- Right to Limit Use or Disclosure of Sensitive Personal Information: The right to limit the use and disclosure of Sensitive Personal Information (as defined under the CPRA);
- Right to Access Information Related to Automated Decision Making: The right to inquire about our logic involved in automated decision-making applied to personal data we collect; and
- Right to Opt-Out of Automated Decision-Making Technology: The right to request a user’s removal from having automated decision-making applied to a user’s personal data that we collect.

To request further information pursuant to a user’s “right to know” or to request deletion of personal data pursuant to the user’s “right to request deletion”, please contact us at admin@clarative.ai.

Only a user or an authorized agent may make a request related to such user’s personal data. Note that to respond to a user’s requests to access or delete personal data as outlined in applicable state laws, we must verify the user’s identity.

11. CHANGES TO THIS PRIVACY POLICY

We may update our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on the Site, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

12. CONTACT US

If you have any questions about this Privacy Policy, you can contact us:
By email: info@clarative.ai