PRIVACY POLICY

(Effective August 2018)

This document (the “Privacy Policy”) highlights Harbinger Group’s privacy practices regarding personal information that we collect and store through this website and for the personal information, other non-personally identifiable information that you provide us while interacting with us on our website, (hereinafter collectively referred to as the “Data”). Our Cookie Policy  describes what cookies we use and the purpose behind their use. This Privacy Policy should be read along with the Cookie Policy

“You” or “your” means any person who visits, browses, uses the Website.

“Services” shall mean the services or products provided by us Website.

“Harbinger,” “We,” “Company,” “us” and “our” means Harbinger Group of Companies comprising of Harbinger Knowledge Products Private Limited, Harbinger Interactive Learning Private Limited, Harbinger Tech ventures Private Limited, Harbinger Systems Inc., Harbinger Knowledge Products Inc., Exaltive Inc., Harbinger AI Inc.

Please read this Privacy Policy carefully.

For residents of the European Union (“EU”), please note that this Privacy Policy has been updated in accordance with the requirements of the EU General Data Protection Regulation (the “GDPR”).

For Non-EU residents, by continuing to use or accessing the Website, you agree to this Privacy Policy. If you do not agree with this Privacy Policy, you may not avail the use or access the Website.

DATA COLLECTION AND USE

What Data we collect?

Personal Information : Through the Website, we may collect your Personal Information, including but not limited to your age, sex, full name, address, email address, phone number, or other contents that can identify you as a person or any of your personal information as identified above which you may submit or share through the Website (“Personal Information”).

Non-Personally Identifiable Information: We may also automatically collect non-personally identifiable information to improve our Website and Services, such as pattern of your use of the Website, our Services, visits, material or information that you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information, IP address and date and time when you access or use Website. In the event you participate in any interactive features of the Website, promotion, third party social media sites or otherwise communicate with us, we collect the data you submit for such participation.

Accuracy of Information- Please make sure that any Personal Information you share with us is accurate and upto date. If you are sharing any Personal Information on behalf of a third person, you should ensure that you are authorized to do so. Please be aware that to ensure the accuracy and completeness of our information, and serve you better, we may periodically use third party information to validate the information you provide us.

What is the Use of your Personal Data

We may use your Data for the purposes including but not limited to the following:

    • To provide better usability, troubleshooting and Website maintenance;
    • To understand which parts of this Website are visited and how frequently;
    • To provide access to desirable content based on your preferences;
    • To process job applications (more details about which are available on corresponding portals of this website);
    • To provide information and Services as requested by you;
    • To assess queries, requirements, and process requests for products and services;
    • To perform client communication, service, billing and administration;
    • To conduct data analysis;
    • To operate, improve and maintain this Website, to prevent fraud and abuse;
    • To enhance the security of the Website;
    • To provide you with information about our products and services and / or our periodic newsletters;
    • To ensure that content from the Website is presented in the most effective manner for you and for your computer;
    • To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
    • To maintain leads;
    • To run marketing or promotional campaigns;
    • To create brand awareness;
    • To provide better services and generate demand;
    • To market products and services based on legitimate business interest under the applicable law; and
    • To conduct processing necessary to fulfil other contractual obligations for the individual.

The Data collected may also be used for machine learning purposes.

Data is collected and used for the specific purposes detailed above. If the Data is used for an unrelated purpose, we will notify you and explain the legal basis that allows its use.

HOW IS DATA COLLECTED

Personal Information about you is collected when you fill in the ‘contact us’ form on our Website or when you contact us. In general, you may browse our Website without providing any Personal Information about yourself. We do automatically collect certain information when you visit our Website such as the type of operating system, the type of browser you are using, your IP address in order to provide better usability and personalized experience. We (also) use cookies to collect non-personally identifiable information. To learn more about the cookies we use, please visit our Cookie Policy.

Legal Basis (for people from the EU)- We will not process your Personal Information without a lawful basis to do so. We will process your Personal Information only on the legal basis of consent [as provided in Art. 6 (1) (a) of the GDPR], contract [as provided in Art. 6 (1) (b) of the GDPR], or on the basis of our legitimate interests [as provided in Art. 6 (1) (f) of the GDPR], provided that such interests are not overridden by your privacy rights and interests.

Cookies

Please refer to the Cookie Policy.

Sharing of personal information

Personal Information shall be kept confidential. We do not sell, trade or rent the Personal Information however we may use the Personal Information for the purposes listed in this Privacy Policy. We may also share your Personal Information with trusted third parties who assist us in operating our Website, conducting our business, or servicing you, so long as these parties keep your information confidential. The information collected from you and other users may be analyzed in different manners.

We may share the Personal Information with the entity with whom we have a joint advertising arrangement or with business partners or with any other social media application developed by us or by third party. The joint advertisers shall safeguard the Personal Information and shall ensure that there would be no unauthorized or unlawful use of the Personal Information.

We share your Personal Information with:

Harbinger group companies;
Business partners;
Service vendors;
Authorized third-party agents; or
Contractors

Merger / acquisition: In addition to the above, we may transfer your Personal Information if we are acquired by another entity, or if we merge with another company or transfer a part of our business, including the website, to a third party. Any such third party or resultant entity that receives your Personal Information shall have the right to continue to use your Personal Information in line with the purposes set out herein.

Legal and Regulatory Authorities: We may need to disclose Personal Information as required by law or when we believe such disclosure is necessary to protect our rights or to comply with a govt. request or direction, judicial proceeding, court order, or legal process served on us.

Transfer of your personal information across borders (for EU residents)– The following applies only where your Personal Information originates from the EU:

We transfer Personal Data to countries outside the EU to third parties, including to countries which have different data protection standards to those which apply in the EU. Where service providers process your Personal Data in countries deemed adequate by the European Commission, we rely on the European Commission’s decision to protect your Personal Data.

For transfers to Harbinger group companies and service providers outside the EU, we use standard contractual clauses or other means permissible under the GDPR for such transfers.

Collection of information by any third party

Our website may connect to links to other websites whose privacy policies may differ from ours. You should consult the other websites’ privacy notices. We do not endorse or make any representations about third-party websites nor do we take any responsibility or liability for content and activities of such third-party links. We encourage you to be aware when you leave our website and visit other websites, to read the privacy statements of every such website.

DATA PROTECTION AND STORAGE

Appropriate security measures are in place to prevent Data from accidental loss, misuse, alteration, or unauthorized disclosure. Additionally, access to data is limited to those employees, agents, contractors, and third parties who are authorized to process the data on our behalf, under specific instruction, and subject to a duty of confidentiality.
We may anonymize personal data (to remove any association with personal identity) for research or statistical purposes.
All Personal Information is securely stored in a database in a server located in India. We also need to make you aware that although we provide appropriate firewalls and protections, our systems or website are not hack proof. You understand that the website and the Services may not be interruption free. Data pilferage due to unauthorized hacking, virus attacks, technical issues is possible, and Harbinger takes no liabilities or responsibilities for it. You are required to be careful to avoid “phishing” scams, where someone may send you an e-mail that looks like it is from us asking for your personal information.

DATA RETENTION

Your personal data will be retained only as long as necessary to fulfill the purpose(s) for which it was collected, including legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

RIGHT TO OPT OUT AND WITHDRAWAL

Harbinger group respects your privacy considerations and hence provides you an option to refuse to provide your Personal Information or information sought to be collected.

You also have the option to subscribe/opt-in to receive newsletters, new alerts and marketing content.

You can always opt-out by clicking the “unsubscribe” link at the bottom of an email newsletter received by you from us. Harbinger shall adhere to your preferences.

You can also assert your rights to withdraw/opt-out by contacting us at: complianceofficer@harbingergroup.com.

Subject to the local legal requirements, you have the right to access, correct, delete or transfer your Personal Data that we hold, including your profile and preferences. You also have the right to object to certain processing and, where we have asked for your consent to process your Personal Data, to withdraw this consent. Where we process your Personal Data because we have a legitimate interest in doing so (as explained above), you also have a right to object to this. These rights may be limited in some situations – for example, where we can demonstrate that we have a legal requirement to process your Personal Data. If you would like to exercise ANY of these rights, please contact us on complianceofficer@harbingergroup.com.

 Your rights (for EU residents)- You have the right to access your personal information in our possession, right to have us rectify or modify any such personal information, right to have us erase/delete your personal information, right to restrict us from processing such personal information, right to object to our use of your personal information. If you would like to exercise ANY of these rights, please contact us on complianceofficer@harbingergroup.com.

CHILDREN

Unless otherwise indicated, our website and Services are not intended for use by children under the age of 18.

CHANGES TO PRIVACY POLICY

We may update this Privacy Policy from time to time. You are encouraged to check this Privacy Policy on a regular basis to be aware of the changes made to it.This Privacy Policy was last modified on August 2018.

GOVERNING LAWS AND DISPUTE RESOLUTION

Statutory provision

This Privacy Policy is governed by the laws of India and is compliant with the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules 2011, (which is designed to protect Personal Information of the users of the website or of the Services); and other applicable rules and regulations related to privacy. For any persons in the EU, this Privacy Policy shall be governed by the provisions of the GDPR.

Dispute Resolution.  Any dispute arising, between you and Company shall be submitted to the arbitration and it will be held in Pune, India and the proceedings will be conducted in English language, by a sole arbitrator, who shall be appointed by the parties mutually and the award made in pursuance thereof shall be binding on the parties. The dispute resolution and arbitration process mentioned in this Section will not prohibit parties from approaching the courts for appropriate interim reliefs. Parties further agree that the courts in Pune, India shall have an exclusive jurisdiction over such disputes.

Limitation of liability. To the extent permissible under the law, we shall not be liable for any direct, indirect, incidental, special, consequential or exemplary damages, including but not limited to, damages for loss of profits, goodwill, data, information, or other intangible losses (even if we have been advised of the possibility of such damages), arising out of this Privacy Policy.

GRIEVANCE REDRESSAL / CONTACTING US

Any grievance or complaint, in relation to processing of information, should be sent to following email id: complianceofficer@harbingergroup.com. Grievance shall be redressed as expeditiously as possible.

If there are any questions regarding this Privacy Policy, you may contact us at complianceofficer@harbingergroup.com.

Harbinger Interactive Learning