Effective: July 05, 2012


HarQen, Inc. (the “Company”) utilizes its award-winning Intelligent Voice Services to improve meetings, interviews and other conversations with the goal of improving collaboration and enriching existing data management systems. In this context, the Company may work with clients based in the European Union (“EU”) or receive Personal Information (defined herein) from individuals located in the EU. Protecting consumer privacy is important to the Company. The Company adheres to the Safe Harbor Agreement concerning the transfer of personal data from the EU to the United States of America. Accordingly, we follow the Safe Harbor Principles published by the U.S. Department of Commerce (the “Principles”) with respect to all such data. If there is any conflict between the policies in this privacy policy and the Principles, the Principles shall govern. This privacy policy outlines our general policy and practices for implementing the Principles, including the types of information we gather, how we use it and the notice and choice affected individuals have regarding our use of and their ability to correct that information. This privacy policy applies to all Personal Information (defined herein) received by the Company whether in electronic, paper or verbal format.

To learn more about the Safe Harbor program, and to view HarQen’s certification, please visit http://www.export.gov/safeharbor/.


“Personal Information” means information that (1) is transferred from the EU to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) can be linked to that individual.

“Sensitive Personal Information” means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual’s health.



The Company shall inform an individual of the purpose for which it collects and uses the Personal Information and the types of non-agent third parties to which the Company discloses or may disclose that Information. The Company shall provide the individual with the choice and means for limiting the use and disclosure of their Personal Information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Information to the Company, or as soon as practicable thereafter, and in any event before the Company uses or discloses the Personal Information for a purpose other than for which it was originally collected. The Company has developed notice and accompanying opt-in policy that requires the individual whose Personal Information the Company will receive to specifically opt-in or, alternatively, refuse to consent to the collection of such data.


The Company will offer individuals the opportunity to choose whether their Personal Information is (1) to be disclosed to a third party or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. For Sensitive Personal Information, the Company will give individuals the opportunity to affirmatively or explicitly consent to the disclosure of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. The Company shall treat Sensitive Personal Information received from an individual with a similar level of care as the individual would treat it.

Onward Transfers

Prior to disclosing Personal Information to a third party, the Company shall notify the individual of such disclosure and allow the individual the choice of such disclosure. The Company shall ensure that any third party for which Personal Information may be disclosed subscribes to the Principles or are subject to law providing the same level of privacy protection as is required by the Principles and agree in writing to provide an adequate level of privacy protection. As part of the Company’s opt-in policy, the individual will be asked to consent to the transfer of certain Personal Information to the Company’s client.

Data Security

The Company shall take reasonable steps to protect the Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. The Company has put in place appropriate physical, electronic and managerial/administrative procedures to safeguard and secure the Personal Information from loss, misuse, unauthorized access or disclosure, alteration or destruction. Though the Company will take reasonable steps to ensure the privacy and security of the Personal Information, it cannot guarantee the security of Personal Information on or transmitted via the Internet. The Company shall make individuals aware of this limitation and to the extent data is transmitted via the Internet, the individuals will be asked to consent to such transmission.

Data Integrity

The Company shall only process Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, the Company shall take reasonable steps to ensure that Personal Information is accurate, complete, current and reliable for its intended use. The Company will take reasonable steps to correct any inaccurate or incomplete data it may find while processing the Personal Information and may ask the individual to update and/or supplement the Personal Information held by the Company.


The Company shall allow an individual access to their Personal Information and allow the individual to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated. The individual may not be granted access to work product of the Company, but will be given access to the Personal Information upon which the work product is based. An individual may submit Personal Information to the Company from time to time for certain specific purposes. The individual may not be able to access such Personal Information once it is submitted to the Company.


The Company uses a self-assessment approach to assure compliance with this privacy policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Principles. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information in accordance with the Principles.

In compliance with the US-EU Safe Harbor Principles, the Company commits to resolve complaints about your privacy and our collection or use of your personal information. European Union citizens with inquiries or complaints regarding this privacy policy should first contact the Company’s Privacy Officer at: support@harqen.com.

The Company has further committed to refer unresolved privacy complaints under the US-EU Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by the Company, please visit the BBB EU SAFE HARBOR web site atwww.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.


This privacy policy may be amended from time to time consistent with the Principles and the requirements of the Safe Harbor. We will post any revised policy athttp://harqen.com/policies/safeharbor.

Information Subject to Other Policies

The Company is committed to following the Principles for all Personal Information within the scope of the Safe Harbor Agreement. However, certain information is subject to policies of the Company that may differ in some respects from the general policies set forth in this privacy policy.

Contact Information

Questions, comments or complaints regarding the Company’s EU Safe Harbor Privacy Policy or data collection and processing practices can be mailed or emailed to:

HarQen, Inc.

Attn: Privacy Officer

1830 N. Hubbard St.

Suite 700

Milwaukee, WI 53212

Email: support@HarQen.com