Privacy Policy

Last Modified:  December 20, 2019

The Harlequin Group of Companies (“Company,” “we,” “us”), including our affiliates, respect your privacy and understand that you care about your personal information and how it is used.  We value your trust in sharing your personal information with us and are dedicated to protecting your privacy, as further described in this Privacy Notice.

1.     SCOPE

This Privacy Notice (“Notice”) applies to personal consumer information collected by the Company through its websites, services and mobile applications (collectively, the “Services”). This Privacy Notice describes in detail the types of information we collect about you; how we use your information and with whom we share it; the choices and rights you have with regard to your information; how we protect your information; and how you can contact us about our privacy practices.

Most of the Services are intended for a general audience, and are not targeted to children under 16.

2.     INFORMATION WE COLLECT AND OBTAIN

We obtain personal information about you from a variety of sources.  This includes personal information you provide to us directly, information we obtain from other sources, and information we gather through automated means.

Information you provide to our Services.  When you register for or participate in certain services, purchase products, seek access to certain content or features, or directly correspond with us, we may collect certain types of information from you:

  • Contact information (such as name, postal address, email address and telephone and/or mobile numbers);
  • Certain biographical and product preference information that you provide, such as your date of birth, gender and/or reading preferences, to customize our Service for you;
  • Financial information (such as credit card or banking information required to pay for our products or services);
  • Username and password when you register through our Services;
  • Survey responses, reviews and/or comments; and
  • Other information you may provide to us, such as through our “Submit a Request” or “Contact Us” feature.

Information obtained from other sources. We may obtain personal information about you in connection with the Services from publicly and commercially available sources and from our Company affiliates and/or business partners, including:

  • Demographical data (such as gender, age range, educational level, household income range, number of children in household);
  • Purchasing data, including membership in loyalty programs or information about advertisements you have seen or acted upon, including your interaction with advertisers’ products and services;
  • Occupational data (such as profession, position, title, industry);
  • Preferences and shopping interests;
  • Geo-location;
  • Your activities on other Internet sites or mobile Apps; and
  • Your social media activities.

Information Collected by Automated Means Through Our Services.  We also gather by automated means (such as cookies, web beacons, web server logs, JavaScript and other similar technologies) certain information through our Services:

  • Your Internet Protocol (IP) address;
  • Device information, including unique identifiers and connection information, including mobile device advertising IDs (e.g., Apple’s IDFA or Google’s AAID) and the means of internet connection (e.g., WiFi connection, ISP) that can identify the physical location of such devices, in accordance with applicable law;
  • Your device type and settings, software used, browser type and operating system;
  • Language preferences;
  • Websites or other services you visited before and after visiting the Services (referring URL);
  • Web pages and advertisements you view and links you click on within, and what search queries you may have run on, the Services;
  • Viewing behavor, including the content you view, how long you watch a video, and advertisements you have been shown or interacted with;
  • Dates and times you access or use the Services; and
  • Location information, including the city, state and zip code associated with your IP Address, and precise location information from GPS-based functionality on your mobile Apps, with your consent;

For more information on the various types of automated means we use to gather information, please see our Cookie Notice.

3.     HOW WE USE THE INFORMATION WE OBTAIN

We, or service providers acting on our behalf, may use the information collected from and about you to:

  • Provide our products and services, including authorizing a purchase, or completing a transaction that you requested;
  • Create and manage online accounts;
  • Send promotional materials, alerts regarding available offers and other communications;
  • Communicate about, and administer participation in, special events, promotions, programs, offers, surveys, contests and market research;
  • Respond to inquiries from you and other third-parties, including inquiries from law enforcement agencies;
  • Anonymize or de-identify personal information to provide third parties with aggregated data reports showing anonymized information and other non-personal information;
  • Provide technical support;
  • Generate suggestions about the type of content you may enjoy;
  • Supplement your personal information collected directly from you and/or from automated means with additional information from publicly and commercially available sources, and/or information from Company affiliates and our business partners;
  • Associate your browser and/or device with other browsers or devices you use for the purpose of providing relevant and easier access to content, advertising across browsers and devices, and other operational/business purposes;
  • Operate, evaluate and improve our business (including developing, enhancing, analyzing and improving our Services; managing our communications; reviewing and processing employment applications, performing data and statistical analytics; and performing accounting, auditing and other internal functions);
  • Protect against, identify and prevent fraud and other unlawful activity, claims and other liabilities;
  • Comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our terms of service and other policies; and
  • In other ways for which we provide specific notice at the time of collection.

INTEREST-BASED ADVERTISING

As described in this Privacy Notice and/or our Cookie Notice, we, as well as our third-party service providers, may obtain information about your online activities to provide you with advertising about products and services tailored to your individual interests.  We and our third party service providers also may obtain information for this purpose from third party websites and apps.  We engage third-party advertising networks to help us target our messaging to visitors through interest-based and contextual means.

Through these ad networks, we can track your online activities (such as your visits to websites and your use of apps that serve our advertisements, including the pages or ads your view and actions you take on those sites or apps) over time and across third-party websites and apps by obtaining information through automated means, as described above.  This data collection takes place both on our sites, apps and emails and on third-party websites and apps that participate in these ad networks.  The networks use this information to show you advertisements on our Services or other third-party websites and apps that may be tailored to your individual interests.  This information also helps us track the effectiveness of our marketing efforts.  To the extent required by applicable law, we will obtain your consent before using your information for interest-based advertising.

The section below entitled Your Choices and Rights provides details on and explains how to exercise your choices regarding interest-based advertising.

4.     INFORMATION WE SHARE 

We may share your personal information with:

  • Our subsidiaries and affiliated businesses.  Our subsidiaries and affiliated businesses within the Harlequin Group of Companies may use your personal information consistent with this Privacy Notice.  Those businesses may also use your personal information for each of their own purposes, including marketing purposes.
  • With our Service Providers.  With our service who perform services on our behalf.
  • With our Clients or Business Partners.  Where permitted by law, with our third party clients or business partners, such as companies offering products or services of interest to our customers, advertising partners and other third parties for those third parties’ own commercial or marketing purposes, such as to serve targeted advertisements.
  • We may disclose information to law enforcement authorities or other government officials if we are required to do so to comply with subpoenas, court orders, legal process or other law enforcement or other government measures, and to comply with other legal obligations.  We may also disclose information if we believe disclosure is necessary or appropriate in connection with an investigation of suspected or actual fraudulent or illegal activity.
  • . We may disclose information to protect and defend the rights, interests and safety of the Services, our subsidiaries and affiliates, and their employees, contractors and agents; to protect the security and safety of our users of the Services, including when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss.
  • In the event of a proposed or completed sale or transfer of all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation).
  •   We may share your information with select third party partners with your consent, so they can send you promotions, ads or offers about their services or products that you may be interested in.  We also may give you the option to receive communications from one of our advertising partners, such as when we offer a joint promotion with that third party advertiser.  If you choose to opt in to receiving communications from that third party advertiser by providing your explicit consent, the third party advertiser will manage your personal information pursuant to their own privacy policy.
  • When the information collected from or about you is not defined as personal information under applicable law, we may share such non-personal, de-identified information or aggregated information with third parties at our discretion.

5.     YOUR CHOICES AND RIGHTS

We offer you certain choices and you also may have certain rights in connection with the personal information we collect about you.

A.      YOUR CHOICES

To ask us to remove your information from our marketing mailing lists, please contact us as outlined in the How To Contact Us Section below.  You also can unsubscribe from our marketing mailing lists by following the “Unsubscribe” link in our emails. Even if you unsubscribe from our marketing communications, we may still need to send you communications relating to your use of the Harlequin websites, such as service announcements or transactional documents where you are using our Service.

You also have choices about whether cookies and other similar technologies are placed on your computer or mobile device. For more information, visit our Cookie Notice.

We may use third-party analytics services on our Services, such as Google Analytics.  The analytics providers that administer these services use technologies such as cookies, web beacons and similar technologies to help us analyze your use of the Services, as further described in our Cookie Notice. To learn more about how to opt out of various analytics services, please visit the link below:

You may also choose to opt out of use of data that we or our third party service providers collect about your activities to provide you with tailored advertising about products and services of interest to you.  We and our third party service providers also may obtain information for this purpose from third-party websites or apps.  To learn more about how to opt out of ad network interest-based advertising, please see the How to Manage Your Cookies section of our Cookie Notice or visit the customer opt-out pages at http://www.aboutads.info/choices/ and http://www.networkadvertising.org/choices/.

B.      ACCESS, CORRECTION AND DELETION RIGHTS

Subject to applicable law, you may have certain rights to access, review, request delete, update, and/or correct inaccuracies in your personal information in our custody and control by emailing or writing to us via the How to Contact Us Section below.  We may request certain personal information for the purposes of verifying the identity of the individual seeking access to his/her personal information records.

C.      CALIFORNIA PRIVACY RIGHTS

For additional information for residents of the State of California click here.

        D.     INFORMATION FOR VISITORS FROM CANADA

For additional information about our privacy practices in Canada, please click here.

7.     HOW WE PROTECT PERSONAL INFORMATION

We maintain administrative, technical and physical safeguards designed to protect the personal information we have about you against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.  However, no data transmission or storage, or use of the Internet, can be guaranteed to be 100% secure.

8.     TRANSFERS OF INFORMATION 

The Services are hosted in and managed from the United States and Canada.  We may transfer the personal information we collect about you to another country, which may not be deemed to have the same data protection laws as the country in which you initially provided the information.  Applicable laws in the United States and/or other countries may allow the courts, law enforcement and national security authorities to access your personal information when in such country.

If you are a user located outside the United States or Canada or the country to which your information may be transferred, you understand (and, as permitted under applicable law, consent to) having any personal information processed in the United States and/or such country. When we transfer your information, we will protect that information as described in this Privacy Notice.

9.     LINKS TO THIRD-PARTY SITES, APPS AND SERVICES

For your convenience and information, our Services may provide links to third-party sites, apps and servicesthat may be operated by companies not affiliated with Harlequin.  These companies may have their own privacy notices or policies, which we strongly suggest you review.  We are not responsible for the privacy practices of any non-Harlequin sites, apps or services.

10.   CHANGES TO OUR PRIVACY NOTICE

From time to time, we may change our Privacy Notice to reflect changes to our privacy practices and Services.  If we modify the Privacy Notice, we will update the “Last Modified Date” and the changes will be effective as of the date we post such Notice.   For material changes, we will notify you by posting a prominent notice on our Services indicating at the top of the Privacy Notice when it was most recently updated or by other appropriate means.

11.   HOW TO CONTACT US

If you have any questions or comments about this Privacy Notice or the manner in which we or our service providers treat your personal information, would like to exercise your choices, or would like us to update information we have about you or your preferences, please contact us as follows:

By Email: privacy@harlequin.com

By Phone: 1-800-873-8635

You also may write to:

ATTN: Privacy Officer

Harlequin Enterprises ULC

Bay Adelaide Centre, East Tower

22 Adelaide St. W., 41st Floor

Toronto, Ontario, Canada, M5H 4E3

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