Privacy Policy
Harpuun Privacy Policy
Effective: November 15, 2022
Harpuun, Inc. and its affiliates (collectively, “Harpuun”, “we”, “us”, or “our”) are committed to protecting your privacy and respecting your choices with respect to your personal information. This Privacy Policy (“Policy”) is applicable to personal information collected by us through our technology platform (“Technology”), service, mobile application, our website harpuun.com (the “Website”), and sales and technical support via email, chat or telephone.

This Policy describes the following:

1. About Harpuun

2. What information we collect and how it is collected;

3. How we use the information;

4. With whom we may share information;

5. Legal basis for processing the information;

6. Your rights and choices (including under GDPR and CCPA);

7. Security and storage of the information;

8. Third party websites and advertising on our Website;

9. Users outside the United States;

10. Google API Services Usage Disclosure

11. Changes to the Policy; and

12. Contact Information.



1. About Harpuun
Harpuun is a B2B SaaS tech platform as well as a targeted online advertising service headquartered in the Estonia which helps Sales teams target, engage and connect with their desired audiences who are interested or could benefit from the advertisers’ products.

Harpuun runs a buying platform for media and data. Our Technology allows our clients to buy ad space on websites for online advertising and allows for the use of proprietary and third party data in the purchase of that media. When ad space on a website is bought or sold (usually to an advertiser or ad agency by a web publisher) the Technology, as an agent for our clients, fulfills the transaction by delivering the ad to Internet users who visit that site. Generally, an Internet user’s computer comes into contact with Harpuun when a user views an ad delivered or serviced by, or with, our Technology.

If you would prefer not to have Harpuun serve you relevant ads, you may opt-out here: Opt Out of Relevant Advertising. Please see the section “Your Rights and Choices” below for more information.

2. What information we collect and how it is collected

2.1 We may collect personally identifiable information (“PII”) that visitors to our website voluntarily provide to us when contacting us with questions regarding our service, requesting a demonstration of our product, creating a user account for our products and services, requesting newsletters or applying for a position with us. Such information includes name, company name, email address, phone number, and payment card information and billing address when purchasing a service. Account holders must provide their email and password to log in to the application.

2.2 We may obtain personally identifiable information that is publicly available, such as from public databases, web pages and social media platforms. We may combine the information we obtain from such sources with information we otherwise collect. We apply this Privacy Policy to such combined information.

2.3 Our Website and Technology collect non-personally identifiable information (“Non-PII”), including, but not limited to, your IP host address, sites visited, ads seen, the date and time of the ad request, pages viewed, browser type, the referring URL, Internet Service Provider, search keywords and your computer’s operating system. We may also collect Non-PII from clients or other third parties. The collection tools for this Non-PII include the following:

-Cookies. Cookies are used by companies to collect and send information about a user’s website visit – for example, number of visits, average time spent, pages viewed, navigation history through the website, and other statistics. This information helps companies improve a user’s online experience in many ways: for example, by allowing companies to monitor website performance, making the website easier to use, measuring the effectiveness of their promotional placements, and tailoring their website (including the ads and offers they receive) to better match a user’s interests and preferences. Our website sends a small amount of data, including an anonymous unique identifier, to your browser (the “cookie”), in order to allow you to access or use our service (if you are a registered user), or to navigate through the pages of our website. The cookie is stored on your computer’s hard drive. If you disable your browser’s ability to accept cookies from our site, you may not be able to access or use our website or service. You can remove persistent cookies by following directions provided in your Internet browser’s “help” file. See also “Your Rights and Choices” below. If you reject cookies, you may still use our site, but your ability to use some areas of our site will be limited.

-Log Data. We may collect certain Non-PII through our Website regarding your use of the Website, such as IP addresses, browser types, domain names, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. Such Non-PII, however, may be linked to PII. Web Beacons. We may also use a “web beacon” (or clear gif) technology to help us understand your web browsing interest on our sites and interaction with our email marketing communications. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on web pages. We use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. Information collection by clear gifs may be linked to PII.

-Social Media Widgets. Some pages of our Website may include third party social media widgets that you may choose to use to allow the exchange of your information between those third party social media sites and our Website. These features may collect your IP address, which page you are visiting on our Website, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on our Website. Your interactions with these features are governed by the privacy policy of the company providing it.

2.5 Our Website, our services, and behavioral advertising are not directed to children under 18. We do not knowingly collect personally identifiable information from children under 18. Our Website does not collect any age identifying information. If you have reason to believe we may have the personal information of a minor, please email us at support@harpuun.com and we will remove such information from our systems.

2.6 We also do not collect or use financial account numbers, Social Security numbers, pharmaceutical prescriptions, medical records or any sensitive information about a specific individual for online behavioral advertising.

2.7 If you would prefer not to have Harpuun serve you relevant ads, you may opt-out here: Opt Out of Relevant Advertising. Please see “Your Rights and Choices” for more information.



3. How we use the information We use collected information: (i) to provide you with our products and services; (ii) for billing, identification and authentication purposes; (iii) to administer and improve our service and website; (iv) for internal research, benchmarking and product improvement; (v) to respond to your requests and queries; (vi) perform our contractual and legal obligations we have to our customers, governmental authorities or other third parties; and (vii) for other legitimate business purposes.

We use your email address to send to you service-related announcements on the rare occasion when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these communications, Ih are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.

Our Technology uses Non-PII to target and serve relevant advertising to consumers and to perform attribution analysis or other analytics regarding advertising audiences.

We use Non-PII collected from our Website visitors, subject to the users’ opt-out preferences, to analyze trends, administer the site, streamline website usability, track users’ movements around the site and to gather demographic information about our user base as a whole.

The use of cookies (including the information obtained by them and the use of the cookie-derived information) by our partners and service providers is not covered by this Policy. We do not have access or control over these cookies.



4. With whom we may share information

We may also disclose your personal information (within or outside your country of residence):

to companies that provide services to help us with our business activities such as sending email communications, processing billing and payments on our behalf or assisting us with our hiring of employees. These companies are authorized to use your personal information only as necessary to provide these services to us;

when we reasonably believe we are obligated to do so by law, such as to comply with a subpoena, or similar legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request; if we are involved in a merger, acquisition, or sale of all or a portion of its assets, including, without limitation, in the event of bankruptcy, where the transfer of your information to the new company occurs to continue providing you products and services.

We may share aggregated, non-personal information with clients in connection with reporting and accounting needs as well as with other unaffiliated third parties for various purposes such as statistical or educational analysis.

In some instances we may share client contact information in an offline process that includes PII—like name, email address and company—with select service providers and partners of Harpuun who provide relevant services for our clients. None of this PII is tied to any user activity in our Technology.



5. Legal basis for processing the information

We rely on the following legal grounds to process your personal information:

Consent. We may use your personal information as described in this Policy subject to your consent. To withdraw your consent, please contact us at support@harpuun.com. You may also (i) refrain from providing, or withdraw, your consent for cookies; (ii) close your Harpuun account; and (iii) unsubscribe from communications. Please see Your Rights and Choices below for more information.

Performance of a contract. We may need to collect and use your personal information, subject to any applicable opt-out preferences, to perform our contractual obligations.

Legitimate Interests. We may use your personal information, subject to any applicable opt-out preferences, for our legitimate interests to provide and improve our Website, Technology and services. We process information on behalf of our customers who have legitimate interests in operating their businesses. We may use technical information as described in this Policy and use personal information for our marketing purposes consistent with our legitimate interests and any choices that we offer or consents that may be required under applicable law.

Compliance with Legal Obligations. We may use your personal information as necessary to comply with our legal obligations.



6. Your rights and choices

6.1. General. This section is subject to specific disclosures on privacy set forth below. We are committed to facilitate the exercise of your rights granted by the laws of your jurisdiction, which may include the right to request the correction, modification or deletion of your personal information and the right to opt out of the sale or sharing of your personal information (as applicable). We will do our best to honor your requests subject to any legal and contractual obligations. If you would like to make a request, cancel your account or request we delete or no longer use your account information to provide you Services, please contact us.

Opt-Out From Cookies. If you would like to opt-out from having Harpuun collect your Non-PII in connection with our Technology, please click here. When you opt out, we will place an opt-out cookie on your computer. The opt-out cookie tells us not to collect your Non-PII to tailor our online advertising campaigns. Please note that if you delete, block or otherwise restrict cookies, or if you use a different computer or Internet browser, you may need to renew your opt-out choice. Please also note that if you choose to disable this function, your online experience may be diminished, and some features may not work as they were intended.

The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data and advertising partners. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at http://www.aboutads.info and at http://www.networkadvertising.org/choices/. Your browser’s help function should contain instructions on how to set your computer to accept all cookies, to notify you when a cookie is issued, or to not receive cookies at any time.

The Google Analytics service is provided by Google Inc. You can opt-out from Google Analytics service from using your information by installing the Google Analytics Opt-out Browser tool: www.tools.google.com/dlpage/gaoptout/. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: www.google.com/policies/privacy/.

Your Account. If you are a registered user, contact us at support@Harpuun.com to review, correct and edit your personal information associated with your online account.

Website Information. If you would like us to update, correct, delete, or deactivate any PII that you have provided to us on this Website, please resubmit your contact information on the Contact Us page or send your request to us at support@harpuun.com.

Communications. If we use your information to send you news, information, surveys or other communications about our products and services, you will have the option of opting out and/or unsubscribing from such communications. You may also contact us at support@harpuun.com. Generally, you may not opt-out of service-related communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.

Additional Rights. Subject to local law, you may have additional rights under the laws of your jurisdiction regarding your personal data, such as the right to complain to your local data protection authority and the right to appeal our decision regarding a data access request.

6.2. Your European Privacy Rights and Choices. If you are located in the European Union, the United Kingdom or another jurisdiction that has adopted laws substantially similar to GDPR, your privacy rights include the following:

Transparency and the right to information. Through this policy we explain how we use and share your information. However, if you have questions or need additional information you can contact us any time. Right of access, restriction of processing, erasure. You may contact us to request information about the personal data we collected from you and to request the correction, modification or deletion of such personal information, which requests we will do our best to honor subject to any legal and contractual obligations.

Right to withdraw your consent at any time. When we process your personal data based on your consent, you have the right to withdraw it at any time.

Right to object at any time. You have the right to object at any time to receiving marketing or promotional materials from us by either following the opt-out instructions in commercial e-mails or by contacting us, as well as the right to object to any processing of your personal data based on your specific situation. In the latter case, we will assess your request and provide a reply in a timely manner, according to our legal and contractual obligations. Some non-marketing communications are not subject to a general opt-out, such as communications about transactions and disclosures to comply with legal requirements.

Right to data portability. You have the right to data portability of your own personal data by contacting us.

Right not to be subject to an automated decision, including profiling. We do not make automated decisions using your personal data that may negatively impact you. Right to lodge a complaint with a supervisory authority. If you consider that the processing of your personal data infringes your privacy rights according the European Privacy regulation, you have the right to lodge a complaint with a supervisory authority, in the member state of your habitual residence, place of work, or place of the alleged infringement.



6.3. California Disclosures

California “Shine the Light” Information-Sharing Disclosure: California residents may request a list of all third parties with respect to which we have disclosed any information about you for direct marketing purposes and the categories of information disclosed. If you are a California resident and want such a list, please send us a written request by email to support@harpuun.com with “California Shine The Light Rights” in the subject line.

California Do Not Track Disclosure: Our website recognizes “Do Not Track” browser signals, and we do our best to honor your preferences. Depending on the browser you are using, you may be able to choose to block third party cookies or browse in a private browsing mode. The Website is accessible even when private browsing is turned on. The information we collect is governed by this Policy.

California Consumer Privacy Act Disclosures. Under the California Consumer Privacy Act, as amended by the California Privacy Rights Act effective January 1, 2023 (“CCPA”), California residents have the right to request:

The categories of personal information (including sensitive personal information if applicable) we have collected about you; The categories of sources from which the personal information is collected; The business or commercial purpose of collecting, selling or sharing personal information;

The categories of third parties with whom we share or sell personal information; The categories of personal information about you that we have disclosed; and The specific pieces of personal information we have collected about you. Additionally, you have the right:

To know the length of time we retain your personal information; To request deletion of your personal information; To request the correction of any inaccurate data; To opt out of the sale or sharing of your information (if applicable); To limit the use of sensitive personal information (if applicable); and To not be discriminated against for exercising any of your CCPA rights. In the twelve (12) months preceding the Effective Date of this Privacy Policy, we may have collected or received from you, from public sources or from third parties in connection with providing our services, information about California consumers in each of the following categories and disclosed the information to our service providers and customers for business purposes.

Personal Information Category Source of Personal Information Purpose for Collecting the Personal Information To whom we disclose the Personal Information Identifiers such as a name, address, unique personal identifier, email, phone number Information you provide to us; Information we collect automatically; Information collected from third party providers. See Sections 1, 2 and 3 above See Section 4 above Information described in 1798.80(e) (and not otherwise addressed in this table), including bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information We do not ask for this information, but we may have access to it if volunteered by you. Protected Classifications under California and federal law, including gender, age and citizenship. We do not ask for this information, but we may have access to it if volunteered by you. Commercial information such as records of products or services purchased, obtained, or considered, purchase histories and tendencies. We do not collect this information on the publicly available Website. Biometric information We do not collect this information Internet or other electronic network activity information, including browsing history and search history and interactions with an advertisement. Information you provide to us; Information we collect automatically See Sections 1, 2 and 3 above See Section 4 above Geolocation data that is sufficient to identify a precise physical location. We do not collect this information. Sensory data, such as audio, electronic, visual, or other similar information. We do not collect this information. Professional or employment-related information Information you provide to us; Information collected from third party providers (such as our job application hosting providers). See Sections 1 and 2 above See Section 4 above Education Information Information you provide to us; Information collected from third party providers (such as our job application hosting providers). See Section 2 above See Section 4 above Inferences about preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Information you provide to us; Information we collect automatically; Information collected from third party providers. See Sections 1 and 2 above See Section 4 above



Any sensitive data we collect is used by Harpuun only for a business purpose and not for the purposes of inferring characteristics of a consumer.



In the last 12 months preceding the effective date of this Privacy Policy, we have shared (as defined under CCPA) consumers’ personal information in the context of cross-context behavioral advertising. This sharing of information is not part of service and product offerings to our customers, but rather applies only to our marketing websites and our own use of cookies for website visitors. Therefore, a, ‘Do Not Sell or Share My Personal Information’ link is on our marketing websites. Please also see Section 6.1 above for more information on opting out of online behavioral advertising. The use of cookies by our partners and service providers is not covered by this Policy. We do not have access or control over these cookies.

7. Security and storage of the information

We take reasonable administrative, physical and technical precautions to protect your personal data and communications between us. This includes, when required or as we deem appropriate and feasible under the circumstances, written commitments from third parties that may have access to your data that they will protect the data with safeguards that are substantially equivalent to those used by us. No Internet or e-mail transmission is ever fully secure or error free, however. We therefore cannot guarantee absolute security of your data, and we are not responsible for processes and networks that we do not control and for unauthorized access to information by those who have gained access through illegal means.

We retain non-PII collected via our Technology for up to 180 days. After 180 days the data is stored in an aggregated format for up to three years. In instances where local laws are more stringent, we adhere to the local laws where we are doing business.

We will retain your PII collected from our website for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. PII and non-PII collected from our customer data sources is retained until the customer agreement is terminated or upon customer’s request.

Harpuun cookies are set to expire after one year; this expiration is a sliding window, meaning it resets itself after any interaction occurs.

8. Third party websites and Advertising



Links from our Website or service to third party sites are provided for your convenience. Any personal information you provide to such third party will be governed by that party’s privacy policy and not ours. While we endeavor to associate only with reputable entities, Harpuun is not responsible for the privacy practices of these other websites.

Subject to your opt-out preferences (see Your Rights and Choices above), we may also use third-party advertisers, ad networks, and other advertising, marketing, and promotional companies, to serve advertisements on our Website.

We do not endorse these third parties, their content, or any products and services they offer, and we are not responsible for the information practices of such third-party websites or applications.



9. Users outside the United States

Our business is headquartered in the United States. If you are an individual located in the European Economic Area, the United Kingdom, Canada or another jurisdiction outside of the United States with laws and regulations governing personal data collection, use, and disclosure that differ from United States laws, please be aware that information we collect (including cookies and other web technologies) will be processed and stored in the United States or in other countries where we or our third-party services providers have operations. By submitting your personal information to us, using our service, or consenting to our cookies, you expressly consent to having your personal data transferred to, and processed and stored in, the United States or another jurisdiction which may not offer the same level of privacy protection as those in the country where you reside or are a citizen.



10. Google API Services Usage Disclosure

Harpuun's Email Experiences use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.



11. Changes to the Policy

We may update this privacy policy from time to time to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a prominent notice on our Website. We encourage you to periodically review this page for the latest information on our privacy practices so that you will always know what information we gather and how we may use that information.



12. Contacting Us

Should you have any questions in regards to this policy or the privacy, security, and data practices of Harpuun, please contact us and we will be more than happy to clarify and assist you in any way possible: