Privacy Policy

HARPPA and its affiliated companies ("HARPPA," "we," "our," or "us") are committed to protecting your privacy and ensuring the security of your information. This Privacy Policy describes how we collect, use, and disclose your information through our websites, mobile applications, products, customer support, and other services ("Product," "Products," or "Services"), as well as any third-party services or products linked to this Privacy Policy.

By accepting this Privacy Policy during your account setup or by using our Products, or any third-party services or products linked to this Privacy Policy, you consent to the processing of your information as described in this Privacy Policy.

Please note that when you access external links from our website, they may have their own specific privacy policies. We encourage you to read all applicable privacy policies.

This Policy describes:

1. What Information We Collect

At HARPPA, we believe that you can have great products and great privacy. This means that we strive to collect only the personal data that we need. We may collect a variety of information, including:

Account Information: This includes your HARPPA account details, such as contact phone number, email address, passwords, social account information, and third-party avatar.
Device Information: We may collect data that can identify your device, such as Wi-Fi List Information, Mac address, CPU information, memory information, SD card information, and operating system version.
Contact Information: When you place an order or reach out to our customer service, we may collect your name, email address, shipping address, and phone number.
Photo and Video: In certain situations, we may require you to upload personal photos and videos to address specific issues and update personal information.
Location Information: We may need your location information to activate your HARPPA hardware products, establish Bluetooth connections, set time zones, and analyze data (latitude, longitude, and altitude) for improved marketing and promotional services.
Other Information You Provide to Us: This includes details such as the time, topic, and content of your communications with HARPPA.
Your Data, Secured with SSL Technology：We prioritize the security of your personal information, including credit card numbers, by utilizing SSL-protected pages for the safe collection of data.

You are not required to provide the personal data that we have requested. However, if you choose not to do so, in many cases we will not be able to provide you with our products or services or respond to requests you may have.

2. How Do We Collect Your Information

At HARPPA, we value transparency and respect your privacy. We collect your information through consent-based methods, including:

A.Directly Collection from You

We collect personal information directly from you when you provide it to us. This includes details such as your name, birthday, contact phone number, email address, shipping address, passwords, social media account information, device location, location information, as well as your photos and videos.

B.Automatically Collection

We automatically collect information about your devices within the necessary scope. This includes device location information, Wi-Fi List Information, Mac address, CPU information, memory information, SD card information, and operating system version.

C.Third-Party Sources

We also collect and use information obtained from Third-Party Accounts, such as Facebook and Google, which you may use to log in to our Services. This may include your name, username, avatar, social account information, and other details available on your Third-Party Account profile. Please note that we do not have access to your Third-Party Account passwords.

D.Devices Permission

To collect and use the personal information mentioned above, we may request certain permissions on your mobile device. By granting these permissions, you authorize us to collect and use relevant personal information to provide you with the Services you expect.

You have the option to modify the scope of your consent or withdraw your authorization at any time. If you choose to withdraw your authorization, we will no longer collect personal information associated with those permissions, and we will be unable to provide you with the corresponding Services.

However, please note that your decision to withdraw consent or authorization does not affect the collection and use of personal information we obtained based on your prior authorization. If we intend to use your information for purposes not specified in this Policy, we will seek your prior consent.

3. How Will We Use Your Information

HARPPA uses personal data to power our Services, to process your transactions, to communicate with you, for security and fraud prevention, and to comply with law. We may also use personal data for other purposes with your consent.

HARPPA adheres to valid legal grounds for processing your personal data, including:

Fulfillment of contractual obligations: We process personal information to fulfill our contractual obligations to you, enabling you to sign up for our services and facilitating the provision of our Services.
Consent-based processing: In certain cases and as required by law, we handle personal information based on your implied or express consent.
Legitimate interests: We process personal information to further our legitimate interests in commercial activities, provided they do not override the rights and freedoms of individuals. This includes operating our business and services, ensuring security across our websites, products, software, and applications, marketing efforts, receiving payments, preventing fraud, and identifying our customers.
Compliance with legal obligations: We use and disclose personal information in accordance with legal obligations, such as sharing data with tax authorities.

At HARPPA, your personal data is solely utilized for the following purposes:

A.Provide Our Services

We use your information to fulfill our agreements with you and provide you with our Services. We process your personal information as necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract, including but not limited to:

Managing your information and accounts, including registration
Providing access to specific areas, functionalities, and features of our Services
Addressing customer or technical support requests
Communicating important updates regarding your account, activities on our Services, and policy changes

B.Administrative Purposes:

We use your information for various administrative purposes, including but not limited to:

Pursuing our legitimate interests, including direct marketing, research and development, network and information security, and fraud prevention
Detecting and preventing security incidents and fraudulent activities, while taking appropriate legal action
Measuring engagement and interest in our Services
Enhancing, upgrading, or improving our Services
Developing new products and Services
Ensuring internal quality control and safety
Authenticating and verifying individual identities, including processing requests related to your rights under this policy
Debugging to identify and rectify errors with our Services
Conducting audits related to interactions, transactions, and compliance activities
Sharing information with necessary third parties for the provision of Services
Enforcing our agreements and policies
Complying with legal obligations

C.Other Purposes

Utilizing your information as per your requests or as permitted by applicable law
Employing personal information for disclosed purposes, either at the time of collection or with your consent

Automated Decision Making: We may engage in automated decision making, including profiling. However, any automated decision that significantly impacts you will not be made solely based on automated processing, unless it is necessary for a contract, has your consent, or is permitted by law. If you have any inquiries regarding our automated decision making, please contact us at care@harppababy.com.

De-identified and Aggregated Information: We may use personal information and other data to generate de-identified and/or aggregated information, such as anonymized demographic and location data, device-related information, or other analytical insights.

For any further clarification on our privacy practices, kindly reach out to us at care@harppababy.com.

4.How We Store Your Information

The information that we collect from you will be processed primarily in the EU and the United States but may be transferred to and stored at/processed in other countries.

We retain personal data only for the duration necessary to fulfill the purposes for which it was collected, as outlined in this Privacy Policy and our service-specific privacy notices, or as mandated by applicable law.

We will retain your personal data for the period necessary to fulfill the purposes outlined in this Privacy Policy and our service-specific privacy summaries. When assessing retention periods, we first carefully examine whether it is necessary to retain the personal data collected and, if retention is required, work to retain the personal data for the shortest possible period permissible under law.

5. Marketing

You have the option to control the use of your information by HARPPA for performance-based advertising. To opt out, please refer to the latest published instructions in your mobile device settings. By limiting ad tracking, you will still receive advertisements, including those from HARPPA's network, but we will no longer utilize the personal information described in Section 1 above to provide you with more relevant ads.

Furthermore, the advertising identifier (along with any associated information) previously assigned to you will be dissociated. This means that if you choose to opt back in at a later time, none of your past information will be used for advertising purposes, and you will essentially be treated as a new user within our system.

Please note that this information is subject to periodic updates. We encourage you to review our Privacy Policy periodically for the latest details on how we handle marketing practices at HARPPA.

6. Share and Transfer

A. Share

We do not share your personal information with any company, organization, or individual other than HARPPA, except in the following circumstances:

Sharing with explicit consent: We will share your personal information with other parties only after obtaining your explicit consent.
Compliance with legal obligations: We may share your personal information externally in accordance with applicable laws, regulations, or mandatory requirements from government authorities.
Disclosures to protect us or others: In certain situations, we may access, preserve, and disclose any stored information associated with you to external parties if we have a good faith belief that doing so is necessary to comply with law enforcement or national security requests, legal processes such as court orders or subpoenas, protect your, our, or others' rights, property, or safety, enforce our policies or contracts, collect amounts owed to us, or assist with the investigation or prosecution of suspected or actual illegal activity.
Disclosure in the event of merger, sale, or other asset transfers: If HARPPA is involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such transactions, in accordance with applicable laws and/or contracts.
Sharing with our affiliates: With your consent and where permitted by law, we may share your information with our affiliates to provide you with HARPPA products and services. We will only share necessary personal information for the purposes stated in this Privacy Policy. If an affiliated company intends to change the purpose of processing personal information, it will seek your authorization again.
Sharing with authorized partners: Some of our Services may be provided by authorized partners solely for the purposes stated in this policy. We may share some of your personal information with these partners to enhance customer service and user experience. We will only share your personal information for legal, legitimate, necessary, specific, and explicit purposes, and only share personal information necessary to provide the services. Our partners are not authorized to use the shared personal information for any other purpose. Typically, our partners include:

Third-party service providers: They assist us with payment facilitation, package shipping, application development, electronic message processing, and other services. Some of your personal information may be collected directly by these third-party service providers and is subject to their privacy policies.
Third-party SDK service providers: To ensure the stable operation and functionality of our application and to provide you with a wider range of services and features, we may integrate third-party SDKs (Software Development Kits) into our application.

For details, see the following list of third-party service providers:

Third-party service providers	Purpose of use	Type of information	Third Party Privacy Policy Links
Google	users can log in through Google account authorization	User's third-party avatar, username, social account	https://policies.google.com/privacy?hl=en
Facebook	users can log in through Facebook account authorization	User's third-party avatar, username, social account	https://developers.facebook.com/terms/dfc_platform_terms/#privacypolicy
Shopify	to provide the online e-commerce platform to support and process orders, risk and fraud screening, identity verification, payments	order information: name billing address shipping address email address phone number payment information device and browser information: network connection IP address browsing history	https://www.shopify.com/legal/privacy

B.Transfer

We will not transfer your personal information to any company, organization, or individual unless we obtain your express consent. In the event of a merger, acquisition, or bankruptcy liquidation where personal information transfer is involved, we will ensure that the new holder of your personal information is bound by this Privacy Policy. If necessary, we will require the company or organization to seek your authorization and consent again.

International Data Transfers. We will not transfer your personal information to any company, organization, or individual unless we obtain your express consent. In the event of a merger, acquisition, or bankruptcy liquidation where personal information transfer is involved, we will ensure that the new holder of your personal information is bound by this Privacy Policy. If necessary, we will require the company or organization to seek your authorization and consent again.

We take the necessary measures to ensure that any transfer of your personal information is conducted in accordance with applicable laws and regulations, and that adequate safeguards are in place to protect your data during international transfers.

7. Your Rights

We value your privacy and respect your rights under data privacy legislation. You have several rights that you can exercise under certain circumstances:

Request access to your personal data

You have the right to request access to the personal data we hold about you and receive certain information about how we process it.

Request correction of your personal data

If you find that any of the personal data we hold about you is inaccurate or incomplete, you have the right to request its correction. You can update your personal data at any time by logging into your account and updating your details directly, or by contacting us at care@harppababy.com.

Request erasure of your personal data

You can request the deletion of your personal data if there is no legitimate reason for us to continue processing it. Please note that there may be specific legal reasons or obligations that prevent us from complying with your request, which we will notify you of, if applicable.

Request restriction of processing of your personal data

Request the transfer of your personal data

You have the right to receive a digital copy of your personal data or request its transfer to another company. This right applies to automated data that you provided consent for or when we used the data to perform a contract with you.

Object to processing of your personal data

You can object to the processing of your personal data if we rely on legitimate interests as our basis for processing (as explained above). You also have the right to object to the use of your personal data for direct marketing purposes. In some cases, we may demonstrate compelling legitimate grounds that override your rights and freedoms.

Request human intervention for automated decision making and profiling

If we carry out automated decision making when processing your personal data, you have the right to request human intervention. This type of processing is allowed when necessary for our contract with you, provided appropriate safeguards are in place or your explicit consent is obtained.

We aim to respond to all legitimate requests within one month. If your request is complex or if you have made multiple requests, it may take longer to process. We will notify you and keep you updated in such cases. To ensure the security of your personal data, we may need to request specific information from you to confirm your identity and verify your right to exercise any of the above rights.

Right to lodge a complaint

If you wish to exercise any of these rights or have any questions, please email us at care@harppababy.com. We are here to assist you.

8. Cookies

Cookies are small text files that are sent to or accessed from your web browser or your computer’s hard drive. Cookies typically contains the name of the domain (internet location) from which the cookies originated, the “lifetime” of the cookies (i.e., when it expires) and a randomly generated unique number or similar identifier. Cookies also may contain information about Device, such as: user settings, browsing history, and activities conducted while using the Services.

Our services make use of the following types of cookies:

Strictly necessary cookies: These cookies are essential for the proper functioning of our services. Without them, for example, you would not be able to access your account.
Analytical/performance cookies: We employ these cookies to recognize and count the number of visitors, understand how visitors navigate through our services, and enhance their performance.
Functionality cookies: These cookies enable us to recognize you when you return to our services, allowing for a personalized user experience.

If you would like to learn more about cookies and web beacons, please feel free to contact us at care@harppababy.com. We are here to provide further information and address any inquiries you may have.

9. Security of Your Information

At HARPPA, we prioritize the security of your information and take appropriate measures to ensure its confidentiality and integrity in accordance with this Privacy Policy. However, it is important to note that no system can guarantee absolute security, and we cannot provide a full guarantee regarding the security of the information you provide. We have implemented suitable safeguards to protect your personal information, and we require our third-party service providers and partners to employ adequate security measures as well. To the maximum extent permitted by applicable law, we do not accept liability for any unauthorized disclosure of your information.

By using our services or providing your personal information to us, you consent to receive electronic communications from us regarding security, privacy, and administrative matters related to your use of our services. In the event of a security breach, we will make reasonable efforts to notify you electronically by posting a notice on our services, sending a notification by mail, or sending an email to you.

10. Children’s Information

Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to actively observe, participate in, and monitor their children's online activities.

HARPPA does not knowingly collect any personally identifiable information from children under the age of 13 in the EU, or under the age of 14 in the US (or any other age as required by local law). If you believe that your child has provided us with personal information without your consent, please contact us immediately, and we will take necessary steps to remove such information from our records.

If we become aware that we have collected personal information from a child without parental consent, we will promptly take reasonable measures to delete the information, unless we have a legal obligation to retain it. Additionally, we will terminate the child's account in such cases.

11. Supplemental Notice for California Residents

This Supplemental California Privacy Notice only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information HARPPA has collected about them and whether HARPPA disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:

Category of Personal Information Collected by HARPPA

Category of Third-Party Information is Disclosed to for a Business Purpose

Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.

· Service providers

· Advertising networks

· Social networks

Internet or other electronic network activity

Browsing history, search history, information on a consumer's interaction with an internet website, application, or advertisement.

· Service providers

· Advertising networks

· Government entities

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

A name, signature, physical characteristics or description, address, telephone number, education, employment, employment history, bank account number or other financial information. Personal Information does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records. Note: Some personal information included in this category may overlap with other categories.

· Service providers

· Advertising networks

· Government entities

Geolocation data

Physical location or movements.

· Service providers

· Advertising networks

· Government entities

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in Section 1 to 3 above, respectively.

“Sales” of Personal Information under the CCPA

For purposes of the CCPA, HARPPA does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.

Additional Privacy Rights for California Residents

Non-Discrimination.California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
Authorized Agent.Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us as set forth in “Contact Us” below and provide written authorization signed by you and your designated agent.
To protect your privacy, we will take steps the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include asking you for additional proof of identity and asking questions regarding your account and use of our Services.

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

California Shine the Light.The California “Shine the Light” law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties.
Right for minors to remove posted content.Where required by law, California residents under the age of 18 may request to have their posted content or information removed from the publicly-viewable portions of the Services by contacting us directly as set forth in “Contact Us” below or logging into their account and removing the content or information using our self-service tools.

12. Supplemental Notice for Nevada Residents

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. Please note that we do not currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A.

If you have any questions or wish to make a request to opt-out of any future sale of your information, please contact us and use the subject line "Nevada Do Not Sell Request" to ensure a prompt response to your request.

13. Privacy Policies of Third-Party Websites/Applications

Our Services may contain links to third-party websites or applications, and other websites or applications may contain links to our Services. Please note that these third-party services are not under our control, and we encourage our users to review the privacy policies of each website and application you interact with. We do not endorse, screen, or approve these third-party services, and we are not responsible for their privacy practices or content. Therefore, any personal information you provide to these third-party websites or applications is at your own risk.

14. Changes to Our Privacy Policy

By using our website, you consent to the collection and use of your personal information as described in this privacy policy. If we make any changes to our privacy policy and procedures, we will update them on our website. We recommend reviewing the privacy policy each time you use the website to stay informed about any modifications.

15. Questions about Our Privacy Policy:

f you have any questions or concerns regarding our website or this privacy policy, please don't hesitate to reach out to us at care@harppababy.com. We appreciate your feedback and are committed to addressing any inquiries you may have about the protection of your personal information.

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Privacy Policy

This Policy describes:

4.How We Store Your Information

15. Questions about Our Privacy Policy: