Last revised: 21 December 2021
If you are a resident of California, please visit Additional Disclosures for California Residents (below) for more information about your rights.
To contact us, please
Personal Data that We Collect
When you visit our Site (or otherwise interact with us via the Site) or register for our Services, the personal data we collect falls into three general categories:
- Information you provide to us
- Information collected automatically
- Information we obtain from third parties.
Information You Provide to Us
When you sign up for our Services or make a purchase, communicate with or contact us, we collect personal data. The personal data we collect and process may include your name, IP addresses, passwords, email addresses, mailing addresses, telephone numbers, mental health professional status, transaction and traffic data. We do not currently collect sensitive personal information such as Social Security numbers, age, driver’s license numbers, usernames, or information on race, ethnicity, religious or philosophical beliefs.
Information We Collect Automatically via Cookies
When you visit, download, or interact with the Site and/or Services – even if you do not have an account – we (or authorized third parties engaged by us) automatically collect information about your use of the Site, which consists of:
- Device Information: information about the devices and software you use to access the Site – primarily the internet browser or mobile device that you use, the website or source that linked or referred you to the Site, your IP address or device ID (or other persistent identifier that uniquely identifies your computer or mobile device on the Internet), the operating system of your computer or mobile device, device screen size, and other similar technical information.
- Usage Information: information about your interactions with the Site and Services, including access dates and times, hardware and software information, device event information, log data, crash data, cookie data. This information allows us to understand the screens that you view, how you’ve used the Site and/or our Services (which may include administrative and support communications with us), and other actions on the Site. We, or our authorized third parties, automatically collect log data when you access and use the Site, even if you have not created an account or logged in. We use this information to administer and improve the Services, analyze trends, track users’ use of the Site, and gather broad demographic information for aggregate use.
- Location Information: based on this information, we are also able to determine general location information.
Information Collected From Third Parties
We use third-party payment processors to collect payment information – we will not collect or store your payment information other than the last 4 digits of your credit card and any associated transaction data. Neither New Harbinger nor any of our service providers keep credit card numbers, expiration dates, and/or security numbers on file.
We may also receive information from third parties assisting us with certain business activities, such as marketing or surveys.
How We Use Your Personal Data
- Performance of a contract – When your personal information is necessary to enter into or perform our contract with you.
- Consent – When you have consented to our use of your personal information via a consent form (online or offline).
- Legitimate interests – When we use your personal information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights.
- Legal obligation – When we need to use your personal information to comply with our legal obligations.
- Legal claims – When your personal information is necessary for us to defend, prosecute or make a claim.
(a) We use your personal data for the following purposes:
(i) Monitoring and maintaining the functionality of our Site to make sure it is operating correctly
(ii) Communicating with our customers and Site visitors and users
(iii) Market research and marketing of the products and services of New Harbinger
(b) Cardholder Data Security Policies: In order to minimize the risk of security incidents, we fully outsource all payment processing to Foxy.io. Foxy.io is PCI DSS (Payment Card Industry Data Security Standard) Compliant as a Level 1 Service Provider and is listed on both Visa and MasterCard's global registries. Anytime you submit payment information via our Site, you are submitting through Foxy.io's secure infrastructure. If you opt to save your payment information during checkout, that information is stored at Foxy. We don't have access to your payment details except for the last 4 digits, the card type, and the expiration date.
(c) We do not keep personal data any longer than is necessary for business purposes, and we delete personal data when it is no longer necessary in accordance with our retention schedules. In some cases, we may anonymize your personal data. We use the following criteria to determine our retention periods: the amount, nature and sensitivity of your information, the reasons for which we collect and process your personal data, the length of time we have an ongoing relationship with you and provide you with access to our Site and/or Services, and applicable legal requirements. We will retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to comply with applicable legal, tax or accounting requirements). Additionally, we cannot delete information when it is needed for the establishment, exercise or defense of legal claims (also known as a “litigation hold”). In this case, the information must be retained as long as needed for exercising respective potential legal claims.
(d) We use your personal data to communicate with you via our Site and by email to make you aware of the information, products and services that are available through New Harbinger, to provide customer service, and to conduct surveys.
When We Share Information
We disclose your personal information as described below. We do not buy or sell personal data, and we do not share personal data except in certain cases with our subsidiary, Praxis Continuing Education and Training. In these cases, notice will be given.
Third-Party Service Providers
New Harbinger discloses users’ information to our third-party agents, contractors, or service providers who are hired to perform services on our behalf. These companies do things to help us provide the Site and Services, and in some cases collect information directly. Below is an illustrative list of functions for which we may use third-party service providers:
- Hosting and content delivery network services
- Analytics services
- Social media platforms
- Customer relations
- Customer support services
- Chat feature provider
- Payment processor
- Hosting and content delivery network services
- Functionality and debugging services
- Professional service providers, such as auditors, lawyers, consultants, accountants and insurers
As we continue to grow, we may purchase websites, applications, subsidiaries, other businesses or business units. Alternatively, we may sell businesses or business units, merge with other entities and/or sell assets or stock, in some cases as part of a reorganization or liquidation in bankruptcy. As part of these transactions, we may transfer your personal information to a successor entity upon a merger, consolidation or other corporate reorganization in which New Harbinger participates, or to a purchaser or acquirer of all or a portion of New Harbinger’s assets, bankruptcy included. We may also disclose your personal information when such a transaction is being evaluated and before it is finalized. In such cases, we enter into confidentiality and similar agreements to ensure that your information is kept confidential and that such entity is restricted to reviewing the information for the purposes of evaluating the transaction.
Anonymized or Aggregate Information
In some instances, we share anonymized information, or aggregate, non-personal information with third parties for various purposes, including (i) compliance with reporting obligations; (ii) for business or marketing purposes; (iii) to assist us and other parties in understanding our users’ interests, habits and usage patterns for certain programs, content, services, marketing and/or functionality available through the Site and/or Services. We do not share personal information about you in this case.
Legal Obligations and Security
If we are required to disclose personal information by law, such as pursuant to a subpoena, warrant or other judicial or administrative order, our policy is to respond to requests that are properly issued by law enforcement within the United States or via mutual legal assistance mechanism (such as a treaty). However, if we receive information that provides us with a good faith belief that there is an exigent emergency involving the danger of death or serious physical injury to a person, we may provide information to law enforcement trying to prevent or mitigate the danger (if we have it), to be determined on a case-by-case basis.
Links to Third-Party Sites or Applications
Note that in some cases, for users in the European Economic Area, we are joint controllers with social media partners by virtue of maintaining an account and/or using certain products that they may offer.
We use third-party analytics services on our Site, including via Google, to track how often people gain access to or read our content. Provided you have opted-in to analytics cookies (if you are in the EEA or the U.K.), have not disabled analytics cookies through your browser settings, or have not disabled Google Analytics using the Google Analytics Opt-Out tool, we use this information in the aggregate to understand what content Site Visitors and customers find useful or interesting, so we can produce the most valuable content to meet your needs.
“Do Not Track”
We do not respond to Do Not Track (“DNT”) browser signals. For more information on DNT settings generally, please visit https://allaboutdnt.com.
How to Change Your Communication Preferences
To keep your information accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update any information in our possession that you have previously submitted via the Site and/or Services. Note that you may also manage your communications preferences and the receipt of any commercial communication by clicking the “unsubscribe” link included at the bottom of all emails from New Harbinger. You may also send firstname.lastname@example.org.
Access and Accuracy
We use reasonable efforts to keep your personal information accurate. If you would like to access, update or correct your personal information stored with us, please send an email to email@example.com.
Data Security and Integrity
We take steps that are reasonably necessary to securely provide our Site and Services. We have put in place reasonably appropriate security measures designed to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. We limit access to personal data only to those employees, agents, contractors and the third parties who have a business need-to-know.
We also have procedures in place to deal with any suspected data security breach. If required, we will notify you and any applicable regulator of a suspected data security breach. We also require those parties to whom we transfer your personal information to provide acceptable standards of security.
Notwithstanding, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Services may not be secure. Therefore, take special care in deciding what information you send to us via email.
Your Privacy Rights
Depending on what laws apply to your use of our Site and Services and our collection of personal data, which may change from time to time in the future, you may have the following rights regarding your personal data, and you may exercise any of the rights you have by contacting us at firstname.lastname@example.org or completing our Data Privacy Request Form.
(b) The right to withdraw your consent to the collection and processing of your personal data.
(c) The right to request a copy of your personal data that we have collected.
(d) The right to update, correct, change, block or erase your personal data.
(e) The right to transfer some or all of your personal data to another data controller.
(f) The right to opt out of automated decision-making technology such as “profiling.” New Harbinger uses automated decision-making technology for email subscribers only. You can unsubscribe or ask for your data to be deleted at any time.
(g) The right to access information about automated decision-making technology that may be used. New Harbinger uses automated decision-making technology for email subscribers only. You can always submit a Data Privacy Request Form to learn about your processed personal data.
(f) The right to require us to notify our subsidiary, Praxis Continuing Education and Training, to delete personal data that was shared with our subsidiary.
(g) The right to opt out of receiving marketing communications from us by email. You may unsubscribe at newharbinger.com/pages/unsubscribe.
(a) Our Site, and our products and Services, are intended for use by individuals 13 or older. We do not target or provide information, products or services directed to minors under the age of 13.
(b) We do not knowingly collect personal data from minors.
(d) If an individual under the age of 18 wishes to purchase goods and services at our Site, we will need the individual’s parent or guardian to provide verifiable written consent. Parents or guardians may contact us at email@example.com to provide consent.
Additional Disclosures for California Residents
Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or device (“personal information”). In particular, we have collected the following categories of personal information from Consumers within the last twelve (12) months:
|A. Identifiers.||A real name, postal address, unique personal identifier, online identifier, IP address, email address, account name.|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80[e]).||A name, signature, address, telephone number.
|D. Commercial information.||Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
|G. Geolocation data||General physical location via IP address.|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.|
|K. Inferences drawn from other personal information.||Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated Consumer information.
Sources of Information
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from Consumers. For example, from when you sign up with us.
- Indirectly. For example, via cookies on our website as explained here.
- From third parties. For example, from our payment providers.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes as explained here. In the preceding 12 months, we have disclosed all of the above categories of personal information to our service providers.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We disclose your personal information for a business purpose to the following categories of third parties:
- Our affiliates.
- Service providers.
- Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
In the preceding twelve (12) months, we have sold the following categories of personal information:
A (Identifiers), D (Commercial information) and F (Internet activity).
We do not “sell” your personal information as such term is defined in the CCPA.
Your Rights and Choices
The CCPA provides Consumers with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request we delete any of your personal information we collected from you and retained, subject to certain exceptions as set forth in the CCPA. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
Exercising Access, Data Portability, and Deletion Rights
Only you or a person registered with the California Secretary of State that you authorize 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.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest you may receive a different price or rate for goods or services or a different level or quality of goods or services.