Privacy Statement

Last updated April 15, 2026

This Privacy Statement for Harbor Global, LLC and its affiliates and subsidiaries (“Harbor”, “we”, “us”, or “our”) describes how and why we may access, collect, store, use, and/or share (“process”) your personal data in the course of its business operations and describes your rights with respect to the personal data processed, in accordance with Harbor’s obligations under applicable privacy and data protection laws, including the Regulation (EU) 2016/679 (GDPR), the UK Data Protection Act 2018, and the California Consumer Privacy Act.

For the purposes of this Privacy Statement, “Personal Data” in this Privacy Statement means any information which identifies an individual person or information when combined with other data and information may identify an individual person.

Harbor may process personal data for many different purposes in the course of its business, including where we may collect information through its website, where you may submit information directly to Harbor, and through business activities, including direct communications with you or Harbor’s clients, events, and through Harbor’s services. Harbor commits to process your personal data as described in this Privacy Statement and to comply with all applicable laws and regulations. Please see further information detailed below regarding the purposes which Harbor may process personal data and your rights regarding personal data processed.

Questions or concerns? If you have any questions regarding this Privacy Statement, please contact [email protected] and we will ensure your questions are directed to the appropriate personnel to address your question.

1. How do we access or collect your information?
2. What information does Harbor process and why do we process your information?
3. What legal bases do we rely on to process your personal information?
4. When and with whom do we share your personal information?
5. Do we use cookies and other tracking technologies?
6. International transfers
7. How long do we keep your information?
8. How do we keep your information safe?
9. Do we collect information from minors?
10. What are your privacy rights?
11. Controls for Do-Not-Track features
12. Do we make updates to this notice?
13. How can you contact us about this notice?
14. How can you review, update, or delete the data we collect from you?

1. How do we access or collect your information?

The personal information that we may access or collect depends on the context of your interactions with us. Harbor may collect your personal data either by obtaining information directly, through the course of its services, automatically collecting such information, or through third parties and publicly available information. Where Harbor collects information on behalf of Harbor, Harbor is acting as a data controller or joint data controller or similar terms under applicable privacy and data protection laws.

Information provided directly to Harbor

Harbor may process certain contact related information (ex. name, email address, phone number) received from you through correspondence with Harbor staff, either in person, by phone, or electronic communication. This information would be obtained in the following situations:

when you contact us via our website;
when you contact or engage Harbor’s staff directly regarding Harbor’s services;
when you correspond with Harbor online on a third party website, such as social media;
apply for an employment opportunity with Harbor, either by online submission through a third-party website or through a staffing agency;
if you register for a Harbor organized or sponsored event; and
if you have subscribed to any marketing email newsletters from Harbor.

Services

With respect to Harbor’s professional services, except for business points of contact to facilitate correspondence, in most cases Harbor does not require nor desire clients to obtain or share personal data of individuals and any access of personal data is ancillary to Harbor’s services. Where Harbor provides legal technology support services to its customers, it will be required in most instances for Harbor to have access to client systems to provide those services and those systems may contain client data, including potentially personal data. Harbor would only access data necessary to provide services and if you are a client of Harbor’s, it will generally be obvious what personal data may be in that system that Harbor would not purposefully access. Harbor would not export any personal data in a client’s system without express permission of the client. Where Harbor processes personal data as part of its provision of services to a customer, it acts as a processor under GDPR and a service provider under CCPA and other US state legislation and its processing is governed by its contractual terms with each customer and not by this Privacy Statement.

For direct software offerings from Harbor, Harbor may collect and further process personal data. For software services that Harbor offers, Harbor would process personal data to set up user accounts and may automatically track user activity for the purposes set forth below.

Harbor may additionally solicit feedback with its services, often in the form of surveys, in order to monitor service performance and improve services. Additionally, Harbor may gain information regarding legal trends and insights through feedback. Harbor may share that feedback with other clients for collective client benefit, but only in an anonymized format that will not identify the feedback provider.

Information automatically collected

We automatically collect certain information when you visit, use, or navigate the website or Harbor’s software offerings to its clients. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our website and Services, and other technical information. This information is primarily needed to maintain the security and operation of our website and Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Policy.

The information we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).

Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration.

Location Data. We may collect approximate location data, such as information about your device’s location that accesses and uses our website.

Third parties and publicly available information

We may obtain personal data from third parties or from publicly available information in the following situations:

Harbor’s clients and partners may provide business contact data of personnel of prospective clients, clients, and other third parties to Harbor during the course of Harbor’s business operations;

Harbor may identify and research business contact data from publicly available information; and

Harbor may receive employment and background information, along with contact data, from recruitment agencies and an applicant’s and/or employee’s prior employers.

2. What information does Harbor process and why do we process your information?

Harbor may process your personal data for a variety of purposes. The table below specifies the types of personal data that may be processed through various activities and the legal bases for processing such personal data.

Activity	Types of Personal Data	Legal Bases for Processing
Professional Service Engagements	(a) Names; (b) Contact information (ex. email address, job title); (c) other personal data that may be contained in a client’s system.	(a) Processing is necessary for the performance of a contract; (b) Processing is necessary for compliance with a legal obligation; (c) Necessary for legitimate interests (performing or obtaining services)
Software Services	(a) Names; (b) Contact information (ex. names, email addresses, job titles); (c) IP addresses; and (d) Usage information, such as activity logs, if the software is a hosted service.	(a) Processing is necessary for the performance of a contract; (b) Necessary for legitimate interests (provision of software services and for data security purposes)
Prospective Customer Engagements	(a) Names; and (b) Contact information (ex. email address, job title).	(a) Necessary for legitimate interests (marketing of Harbor’s service offerings, registration of prospective customers) (b) Consent, if you have given your consent
Vendor Procurement	(a) Names; and (b) Contact Information.	(a) Processing is necessary for the performance of a contract (b) Necessary for legitimate interests (obtaining services for Harbor’s business operations)
Recruiting and Staffing	(a) Names; (b) Contact Information; (c) Information collected through identification documents, such as personal address, date of birth, social security number, driver’s license information, state identification card information, and passport information; (d) Prior employment and educational information; (e) Other resume/CV information that is submitted; (f) Background Check results, including criminal history; (g) Demographic and sensitive information, including ethnicity, citizenship, nationality, age, race, and gender information; (h) Veteran status; (i) Reference contact information; and (j) Financial Information (bank account information for payment processing).	(a) Processing is necessary for the performance of a contract (b) Processing is necessary for compliance with a legal obligation (c) Necessary for legitimate interests (Recruiting and staffing for our business)
Payment Processing	(a) Names; (b) Contact information (ex. email address, job title); and (c) Financial information (bank account information for payment processing).	(a) Processing is necessary for the performance of a contract (b) Processing is necessary for compliance with a legal obligation (c) Necessary for legitimate interests (Recruiting and staffing for our business)
Website Visitors	(a) IP Addresses.	(a) Necessary for legitimate interests (Monitoring and data security of Harbor’s website)

3. What legal bases do we rely on to process your personal information?

For personal information collected about you which originated in the EU/EEA, the UK, and other relevant jurisdictions, we may rely on the following legal bases to process your personal information:

Consent. We may process if you have given us permission (i.e., consent) to your personal information for a specific purpose. You can withdraw your consent at any time by emailing [email protected].

Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

Legitimate Interests. We may process your information in order to communicate with you and for legitimate business purposes in the course of operating our business to provide services and to develop our products and services, as specified in Section 2.

Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situation involving the potential threats to the safety of any person.

Contractual Performance. We may process your information in order to perform contractual requirements either with you or pursuant to our contractual engagements with customers, suppliers, and business partners.

4. When and with whom do we share your personal information?

Vendors, Consultants, and Other Third Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (“third parties”) who perform services for us or on our behalf and require access to such information that do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information, unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. Additionally, Harbor may need to share personal information if we are compelled to by a law, including a legal order, or are requested to by a enforcement or a competent authority. We may need to share your personal information with the following third parties:

Our Staff. Harbor will share information with only those staff that have a need to know basis and for the appliable purpose(s) outlined above.

Subcontractors and Partners. To the extent necessary as part of service performance, as part of contractually procured services to provide your company or firm with certain products or services, we will share your personal data, only to the extent necessary and in accordance with any contract with your company or firm.

Staffing Agencies and Recruiting Partners. Harbor will process shared personal data with staffing and recruiting partners.

Marketing Service Providers. Harbor may share your personal data with marketing service providers as part of Harbor’s marketing analysis and outreach.

Event Sponsors. With your consent, Harbor may share information with sponsors of Harbor events.

Professional Advisors. Harbor may share personal data as part of legitimate interests related to its company operations with accountants, attorneys, and other professional advisors.

Harbor does not provide personal data to any third party to contact or market their goods or services without your consent.

5. Do we use cookies?

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.

6. International transfers.

Harbor may transfer personal data that originated in either the UK or the EEA to either our staff or third parties outside of those locations, including in particular in the United States. In some cases, transfers may be to countries that are not deemed to be adequate jurisdiction with respect to the level of protection. To the extent any transfers of your personal data involve such a transfer of data, Harbor implements appropriate safeguards to ensure the security of your personal data. With any transfer of any personal data that originated in the EEA to a Harbor affiliated company or a third party that is not located in the EEA or the UK, the recipient must agree to a written agreement that the European Commission approved Standard Contractual Clauses governs such transfer. Transfers from the UK are similarly governed by the UK Addendum.

7. How long do we keep your information?

Harbor only keeps your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

Harbor only keeps your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will delete such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. How do we keep your information safe?

We have implemented appropriate and reasonable technical and organizational security measures, in accordance with applicable laws, designed to protect the security of any personal information we process. We require our affiliates, subsidiaries, and third-party service providers as well to implement the same level of protections. Harbor understands the importance of confidentiality and data security and employs security measures in contemplation of the risks associated with protecting your personal data against accidental or unauthorized access, loss, alteration, or destruction. Please note that while Harbor employs these measures, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure.

9. Do we collect information from minors?

We do not knowingly solicit from or market to children under 18 years of age. By using the Services, you represent that you are at least 18. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at [email protected].

10. What are your privacy rights?

Subject to applicable laws you have the following rights:

to request access and obtain a copy of your personal information

to request correction of your personal data

to delete your personal data; and

restrict the processing of your personal information

opt out of processing your personal information for the purpose of any targeted advertising; and

opt out of the sale or sharing of your personal information.

In certain circumstances, you may also have the right to object to the processing of your personal information.

You can make such a request by contacting us by using the contact details provided in the section “How can you contact us about this notice?” below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section “How can you contact us about this notice?” below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section “How can you contact us about this notice?” below. You will then be removed from the marketing lists. However, we may still communicate with you – for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

We do not share or sell your personal data that Harbor collects to third parties for monetary consideration. However, where Harbor has received your consent, Harbor may share registration and attendee information to sponsors of events organized by Harbor for the purposes of the event and for marketing and promotional communications.

You may opt-out of that sharing by submitting a request here or by contacting us at [email protected].

Cookies and similar technologies: Most web browsers are set to accept cookies by default. If you prefer, you may choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. For further information, please see our Cookie Policy.

If you have any questions or comments about your privacy rights, you may email us at [email protected].

11. Controls for Do-Not-Track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. We do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

12. Do we make updates to this notice?

We may update the privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directing sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

13. How can you contact us about this notice?

If you have questions or comments about this notice, you may email us at [email protected] or contact us by mail at:

Harbor Global, LLC
200 N. LaSalle Street, Suite 2020
Chicago, IL 60601

UK and European users can contact our UK subsidiary:

Harbor Global UK Professional Services Limited
70 Kingsway,
London, England WC2B 6AH

14. How can you review, update, or delete the data we collect from you?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please send a request to [email protected].