Privacy Policy

Introduction

Harbor Sphere ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our AI-powered investing platform and related services.

Information We Collect

How We Use Your Information

Information Sharing

We do not sell, trade, or rent your personal information to third parties. We may share your information only in the following circumstances:

• With your explicit consent
• To comply with legal obligations or court orders
• To protect our rights, property, or safety
• With trusted service providers who assist in our operations
• In connection with a business transfer or merger

Cookies and Tracking Technologies

We use cookies, web beacons, and similar tracking technologies to collect and store information about your use of our platform. These technologies help us:

You can control cookies through your browser settings. However, disabling certain cookies may limit your ability to use some features of our platform. For more information, please see our Cookie Policy.

Third-Party Services

We may use third-party services that collect, monitor, and analyze information about your use of our platform. These services may include:

• Analytics providers (e.g., Google Analytics)
• Cloud hosting and storage providers
• Payment processors
• Customer support platforms
• Marketing and advertising partners
• Security and fraud prevention services

These third-party services have their own privacy policies governing the collection and use of your information. We encourage you to review their privacy policies.

Data Security

We implement comprehensive security measures to protect your information from unauthorized access, alteration, disclosure, or destruction:

Despite our efforts, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

Data Retention

We retain your personal information for as long as necessary to:

• Provide our services to you
• Comply with legal obligations
• Resolve disputes and enforce our agreements
• Maintain security and prevent fraud

When we no longer need your personal information, we will securely delete or anonymize it, unless we are required by law to retain it for a longer period.

International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. These countries may have data protection laws that differ from those in your country.

When we transfer your information internationally, we take appropriate safeguards to ensure your information receives adequate protection, including:

• Standard contractual clauses
• Adequacy decisions by relevant authorities
• Other appropriate safeguards as required by law

Children's Privacy

Our platform is not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately. If we become aware that we have collected personal information from a child under 18, we will take steps to delete such information.

Your Privacy Rights

Depending on your location, you may have the following rights regarding your personal information:

To exercise these rights, please contact us using the information provided in the "Contact Us" section below. We will respond to your request within a reasonable timeframe and in accordance with applicable law.

California Privacy Rights

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

• Right to Know: Request information about the categories and specific pieces of personal information we collect, use, disclose, and sell
• Right to Delete: Request deletion of your personal information (subject to certain exceptions)
• Right to Opt-Out: Opt-out of the sale of your personal information (we do not sell personal information)
• Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights
• Right to Correct: Request correction of inaccurate personal information
• Right to Limit: Request limitation of use and disclosure of sensitive personal information

California residents may exercise these rights by contacting us at the email address provided below. We may need to verify your identity before processing your request.

EU/UK GDPR Rights

If you are located in the European Union or United Kingdom, you have additional rights under the General Data Protection Regulation (GDPR):

• Right of Access: Obtain confirmation of whether we process your personal data and access to that data
• Right to Rectification: Request correction of inaccurate or incomplete personal data
• Right to Erasure: Request deletion of your personal data under certain circumstances
• Right to Restrict Processing: Request limitation of processing your personal data
• Right to Data Portability: Receive your personal data in a structured, commonly used format
• Right to Object: Object to processing of your personal data for certain purposes
• Right to Withdraw Consent: Withdraw consent where processing is based on consent
• Right to Lodge a Complaint: File a complaint with your local data protection authority

To exercise these rights, please contact us. We will respond within one month (may be extended by two months for complex requests).

Data Breach Notification

In the event of a data breach that may affect your personal information, we will:

• Investigate the breach and take immediate remedial action
• Notify affected users and relevant authorities as required by law
• Provide information about the nature of the breach and steps taken to address it
• Offer guidance on steps you can take to protect yourself

Do Not Track Signals

Some browsers include a "Do Not Track" (DNT) feature that signals websites you visit that you do not want to have your online activity tracked. Currently, there is no standard for how DNT signals are interpreted. We do not currently respond to DNT browser signals, but we do respect your preferences regarding cookies and tracking technologies as described in our Cookie Policy.

Updates to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other reasons. We will notify you of any material changes by:

• Posting the updated Privacy Policy on our platform
• Sending an email notification to the address associated with your account
• Displaying a prominent notice on our platform

The "Last updated" date at the top of this Privacy Policy indicates when the most recent changes were made. Your continued use of our platform after such changes constitutes acceptance of the updated Privacy Policy.

Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of assets, your personal information may be transferred to a third party. We will notify you of any such transfer and any choices you may have regarding your personal information. The acquiring entity will be required to maintain the same level of privacy protection as set forth in this Privacy Policy.