Harrison French and Associates, Ltd. Privacy Policy
Published: July 7, 2022
Harrison French and Associates, Ltd. (“HFA”) recognizes the importance of protecting the privacy of your personal information, and we have prepared this Privacy Policy to provide you with important information about our privacy practices. This Privacy Policy applies when you use a HFA website, mobile or tablet application, or other online service (collectively, the “Services”) that links or refers to this Privacy Policy or HFA. It does not govern or apply to information collected or used by HFA through other means.
Information We Collect
We may collect personal information about our users in various ways. For example, we may collect information that you provide to us, information that we collect through your use of the Services, and information that we collect from publicly available sources or third parties.
Information You Provide to Us. When you register or otherwise interact with the Services, you may be invited to provide personal information to enhance your experience on the Services. For example, we collect User-Generated Content, such as when you comment on articles, participate in message boards, and submit images, photos, videos, or other content to the Services, or otherwise engage with the Services.
Automatically Collected Information. In addition to the information you provide to us directly, we may collect information about your use of the Services or your device. As discussed further below, we and our service providers (which are third party companies that work on our behalf), may use of cookies, web beacons, and other technologies, as detailed in the Online Tracking and Advertising section below, to assist in collecting this information.
For example, we may collect:
- Device information— such as your hardware model, IP address, other unique device identifiers, operating system version, browser type and settings, such as language and available font settings, and settings of the device you use to access the Services.
- Usage information— such as information about the Services you use, the time and duration of your use of the Services and other information about your interaction with content offered through a Service, and any information stored using cookies, mobile ad identifiers, and similar technologies that we have set on your device.
- Location information— such as your computer’s IP address, your mobile device’s GPS signal or information about nearby WiFi access points and cell towers that may be transmitted to us when you use certain Services.
Information From Third-Party Sources. We may receive information about you from publicly and commercially available sources, as permitted by law, which we may combine with other information we receive from or about you. For example, we may receive information about you from a social media site if you connect to the Services through that site, and we may obtain demographic or interest data from consumer data resellers. As set forth in the Online Tracking and Advertising section, we may receive information, such as usage information, from entities such as data analytics providers and advertising partners.
Other Information We Collect. We also may collect other information about you, your device, or your use of the services in ways that we describe to you at the point of collection or otherwise with your consent. You may choose not to provide us with certain types of information, but doing so may affect your ability to use some of the Services.
How We Use Information
To Provide and Manage the Services You Request. This includes, for example, enabling you to participate in the features provided by the Services. It also includes providing personalized content and recommendations to you, including by email. Through such features, we are able to bring you information and content tailored to your individual interests and needs.
To Contact You. We may periodically contact you with offers and information about the Services and our affiliates, including in connection with your accounts, online surveys, legal notices, news stories or marketing information, new features that you are entitled to access, and other important information. You may opt out of receiving commercial email messages from us by following the instructions contained in those email messages.
To Better Understand Our Readers and Users. We may conduct research on our users’ demographics, interests and behavior based on the information we collect. We do this to better understand and serve our users, and to improve our Services.
Bug detection and error reporting. We use information to understand and resolve technical issues, app crashes and other issues being reported.
To Protect the Rights of the Services and others. We may use your personal information as we believe is necessary or appropriate to secure, protect, enforce, or defend the legal rights, privacy, safety, or property of the Services, its employees or agents, or other users and to comply with applicable law.
Consent. We may otherwise use your information with your consent or at your direction.
Sharing of Information
The following provides information about entities with which we may share information. Our practices vary depending on the type of information.
Affiliates. We may share information within our family of affiliated companies.
Business Partners. We may also share your information with business partners to provide you with services that you request. For example, if you sign up for information that runs on our Services but that is sponsored or co-sponsored by another company, your information may be shared with that sponsor. HFA is not responsible for the privacy practices of these entities.
Service Providers. We may share the information we collect with vendors providing contractual services to us, such as hosting vendors and list managers (as described in further detail above). We also may share your information, including your payment information, as appropriate to process your payments for the Services or complete a transaction.
Other Parties When Required by Law or As Necessary to Protect Our Users and Services. We may share your personal information as we believe is necessary or appropriate to protect, enforce, or defend the legal rights, privacy, safety, or property of the Services, our employees or agents or users or to comply with applicable law or legal process, including responding to requests from public and government authorities.
Logging In Through Social Media Services. If you log into the Services with a social media service or if you connect a social media account with the Services, we may share your information with that social media service. The social media services’ use of the shared information will be governed by the social media services’ privacy policy and your social media account settings. If you do not want your information shared in this way, do not connect your social media service account with your Services.
Third Parties that Provide Content, Advertising, or Functionality. When you use our Services, third parties may collect or receive certain information about you and/or your use of the Services (e.g., hashed data, click stream information, browser type, time and date, information about your interactions with advertisements and other content), including through the use of cookies, beacons, mobile ad identifiers, and similar technologies, in order to provide content, advertising, or functionality or to measure and analyze ad performance, on our Services or other websites or platforms. This information may be combined with information collected across different websites, online services, and other linked or associated devices. These third parties may use your information to improve their own services and consistent with their own privacy policies.
Other Parties in Connection With a Corporate Transaction. We reserve the right to transfer any information we have about you in the event that we sell or transfer all or a portion of our business or assets to a third party, such as in the event of a merger, acquisition, or in connection with a bankruptcy reorganization.
Otherwise With Your Consent or At Your Direction. In addition to the sharing described in this Privacy Policy, we may share information about you with third parties whenever you consent to or direct such sharing.
We also may share other information with third parties in a manner that does not identify particular users, including, for example, aggregated data about how users are using our Services.
Embedded Content and Links to Third-Party Sites and Services
Our Services may embed content from, or link to, third-party websites and services, including social media platforms, that are outside of our control. We are not responsible for the security or privacy of any information collected by other websites or other services. This Privacy Policy does not govern these third party’s content or services, and we encourage you to review the privacy statements applicable to the third-party websites and services you use.
How to Access or Update Your Information & Other Privacy Choices Available To You
Email Promotions. You may opt out of receiving commercial email messages from us by following the instructions contained in those email messages.
Do-Not-Track Signals and Similar Mechanisms. Some web browsers may transmit “do-not-track” signals to the websites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. Because there currently is no industry standard concerning what, if anything, websites should do when they receive such signals, the Services currently do not take action in response to these signals. If and when a final standard is established and accepted, we will reassess how to respond to these signals. In the meantime, please see Online Tracking & Advertising for additional information about privacy choices that may be available to you with respect to targeted advertising.
Data Security
We have in place physical, electronic and managerial procedures to protect the information we collect online. However, as effective as these measures are, no security system is impenetrable. We cannot guarantee the security of our database, nor can we guarantee that the information you supply will not be intercepted while being transmitted to us over the Internet.
Children’s Privacy. We do not knowingly collect any personal information from children under the age of 16 without parental consent, unless permitted by law. If we learn that a child under the age of 16 has provided us with personal information, we will delete it in accordance with applicable law.
Online Tracking & Advertising
How We Use Cookies, Web Beacons, and Similar Technologies and How To Disable These Technologies
We, our service providers, and third parties that provide content, advertising, or functionality or measure and analyze ad performance on our Services, may use cookies, web beacons, mobile ad identifiers, and similar technologies to facilitate administration and navigation on the Site, to better understand and improve our Services, to determine and/or improve the advertising shown to you here or elsewhere, and to provide you with a customized online experience.
Cookies. Cookies are small files that are placed on your computer when you visit a website. Cookies may be used to store a unique identification number tied to your computer or device so that you can be recognized as the same user across one or more browsing sessions, and across one or more sites. Cookies serve many useful purposes. For example:
- Cookies can remember your sign-in credentials so you do not have to enter those credentials each time you visit a Service.
- Cookies can help us and third parties understand which parts of our Services are the most popular because the Cookies can help us and third parties understand which parts of our Services are the most popular because they help us see which pages and features visitors access and how much time they spend on the pages. By studying this kind of information, we are better able to adapt our Services and provide you with a better experience.
- Cookies help us and third parties understand which ads you have seen so that you don’t receive the same ad each time you access a Service.
Most browsers accept cookies automatically, but can be configured not to do so or to notify the user when a cookie is being sent. If you wish to disable cookies, refer to your browser help menu to learn how to disable cookies. If you disable browser cookies or flash cookies, it may interfere with the proper functioning of the Services.
Beacons. We, along with third parties, also may use technologies called beacons (or “pixels”) that communicate information from your device to a server. Beacons can be embedded in online content, videos, and emails, and can allow a server to read certain types of information from your device, know when you have viewed particular content or a particular email message, determine the time and date on which you viewed the beacon, and the IP address of your device. We and third parties use beacons for a variety of purposes, including to analyze the use of our Services and (in conjunction with cookies) to provide content and ads that are more relevant to you.
Local Storage & Other Tracking Technologies. We, along with third parties, may use other kinds of technologies, such as Local Shared Objects (also referred to as “Flash cookies”) and HTML5 local storage, in connection with our Services. We also may use unique identifiers associated with your device, such as mobile ad identifiers. These technologies are similar to the cookies discussed above in that they are stored on your device and can be used to store certain information about your activities and preferences. However, these technologies may make use of different parts of your device from standard cookies, and so you might not be able to control them using standard browser tools and settings. For HTML5 local storage, the method for disabling HTML5 will vary depending on your browser.
Privacy Information for California Residents
The following information applies to California residents regarding “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)). This information and the rights discussed below do not apply to information collected from or about our employees, former employees, candidates, contractors, service providers, or business contacts.
Categories of personal information we collect, use and disclose. Throughout this Policy, we discuss in detail the specific pieces of information we collect from you and other users (as described in Information We Collect above ) and discuss how we use (as described in How We Use Information above ) and share (as described in Sharing of Information above ) such information. The CCPA requires us to provide additional information about this collection and use.
- We may collect, use, and disclose for our business and commercial purposes, the following categories of information about you or your use of the Services: Identifiers (such as name, address, email address); commercial information (such as transaction data); financial data (such as credit card information); user-generated content; device information and identifiers (such as IP address); internet or other network or device activity (such as browsing history or app usage); professional and employment related information; location data; audio or visual information (such as if you participate in a phone survey or submit a photo); characteristics of potentially protected classifications (such as gender); inference data; and other information that identifies or can be reasonably associated with you.
- We use the above categories of information: to provide and manage the Services you request; to contact you; to deliver targeted advertising; to better understand our readers and users; for bug detection and error reporting; to audit consumer interactions on the Services; to protect the rights of the Services and with your consent. For more detail regarding the purposes for which we use information, please see How We Use Information above.
- Depending on the circumstances, we may share any of the above categories of information we collect with: our family of affiliated companies; business partners to provide you with services that you request; service providers such as hosting vendors, analytics and advertising service providers, and list managers; other parties, including government entities, when required by law or to protect our users and services; social media services pursuant to that service and your settings; and with your consent or in connection with a corporate transaction. In addition, we may share commercial information and financial data, including your payment information, with payment processors, and we share device information and identifiers and internet or other network or device activity with entities that provide content, advertising, and functionality
Sale of personal information. California law broadly defines “sale” in a way that may include the delivery of targeted advertising on the Services or other sites, including allowing third parties to receive certain information, such as cookies, IP address and/or browsing behavior. We may share the following categories of information for such advertising with advertising networks and providers, certain analytics providers, and social media networks, which may be considered a sale (as defined by California law):
- device information and identifiers, such as IP address, and unique advertising identifiers and cookies; usage information, such as browsing history or app usage; location information, such as city; and inference data.
If you are a California resident and would like to opt out of our use of your information for such purposes (to the extent this is considered a sale), you may do so as outlined on the following page: Do Not Sell My Personal Information. You can also control certain of this sharing through the choices outlined in Online Tracking & Advertising.
California Privacy Rights
CCPA Rights. California residents can make certain requests about their personal information under the CCPA. Specifically, if you are a California resident, you may request that we:
- provide you with information about: the categories of personal information we collect, disclose or sell about you; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we share personal information. Such information is also set forth in this Privacy Policy.
- provide access to and/or a copy of certain information we hold about you;
- delete certain information we have about you; and/or
- provide you with information about the financial incentives that we offer to you, if any.
Please note that certain information may be exempt from such requests under applicable law. For example, we may retain certain information for legal compliance and to secure our Services. We may need certain information in order to provide the Services to you; if you ask us to delete it, you may no longer be able to use the Services.
The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights under the CCPA.
If you would like information regarding your rights under applicable law or would like to exercise any of them, please email us at info@hfa-ae.com . To protect your privacy and security, we take reasonable steps to verify your identity and requests before granting such requests, including by verifying your account information, residency or the email address you provide.
Shine the Light Disclosure. California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of personal information to third parties for their direct marketing purposes in the preceding calendar year. We do not share personal information with third parties for their own direct marketing purposes.
California residents who are registered users of the Services and are under the age of 18 are entitled, in accordance with California law, to request and obtain removal of content and information that they themselves post on the Services. You may request such removal by emailing us at info@hfa-ae.com. In your request, please provide a description of the material that you want removed and information reasonably sufficient to permit us to locate the material, and include your name, email address and/or HFA website user name, year of birth, mailing address (including city, state, and zip code), and the subject line “California Removal Request” so that we can process your request. Please note that your request does not ensure complete or comprehensive removal of the material. For example, materials that you have posted may be republished or reposted by another user or third party.
Privacy Information for Nevada Residents
Under Nevada law, Nevada consumers who have purchased goods or services from us may opt out of the “sale” of “covered information” as such terms are defined under Nevada law. We do not engage in such activity, but if you have questions about this you can email us at optout@HFAdailynews.com.
Information for Certain Users Outside the United States
International Transfers. The Services are headquartered in the United States. Please be aware that information you provide to us or that we obtain as a result of your use of the Services may be collected in your country and subsequently transferred to the United States or to another country in accordance with applicable law. By using the Services, you consent to the collection, international transfer, storage, and processing of your information.
Purposes of processing and legal basis for processing. We process personal data consistent with our disclosures in this Privacy Policy. We process personal data on the following legal bases: (1) with your consent; (2) as necessary to perform our agreement to provide Services to you; and (3) as necessary for our legitimate interests in providing the Services where those interests do not override your fundamental rights and freedoms related to data privacy.
Transfers. Personal data we collect may be transferred to, and stored and processed in, the United States or any other country in which we or our affiliates or processors maintain facilities. We will ensure that transfers of personal data to a third country or an international organization are subject to appropriate safeguards.
Changes to Our Privacy Policy
We may modify this Privacy Policy from time to time. We will notify you of changes by posting changes here, or by other appropriate means. Any changes to the Privacy Policy will become effective when the updated policy is posted on the Services. Your use of the Services or your provision of personal information to use the Services following such changes indicates your acceptance of the revised Privacy Policy.
