Privacy Policy

1. What information about me is collected?

In connection with your use of the Service, we may collect information about you. Such information may include:

• Name and email address
• Conversation content you enter when you use the Service
• Coaching materials your coach uploads on your behalf, such as a discovery questionnaire, 360° report, and leadership-development plan
• Derived coaching record, including goals, experiments, reflections, AI-generated session summaries, a rolling summary, private search index (embeddings), and a set of extracted “insights/patterns”
• Any information that you choose to share through the Service

We may also collect other information that in some cases may be identifiable, such as:

• Demographic information
• Browser types
• Unique device identifiers
• Device types
• Requested URL
• Referring URL
• Browser language
• Pages you view
• Date and time of your visit
• Domain names
• Consent receipt information
• When sessions occur
• Entry mode
• Session timestamps
• Statistical data involving the use of the Service

2. Where and when is information collected (including through cookies and action tags)?

General sources. We may obtain your information in the following ways:

• We will collect information that you submit to us;
• From your Haven coach, who provides information on your behalf; and
• If you identify yourself to us by communicating with us, including by sending us an e-mail with questions or comments.

Registering to use the Service. You may be required to establish an account in order to take advantage of certain features of the Service. If so, you may be required to provide us with certain of the information described in Section 1.

Cookies and action tags. We may collect information passively using “cookies.” Cookies are small text files placed on your computer or mobile device to identify your web browser and the activities of your computer on the Service and other websites. Cookies can be used to assist you in using the Service (such as saving time by not having to reenter your name each time you use the Service) and to allow us to statistically monitor how you are using the Service to help us improve our offerings.

You do not have to accept cookies to use the Service. Although most browsers are initially set to accept cookies, you may reset your browser to notify you when you receive a cookie or to reject cookies generally. Most browsers offer instructions for doing so in the “Help” section of the toolbar. If you reject cookies, however, certain features or resources of the Service may not work properly or at all, and you may experience some loss of convenience.

Log files. We also collect information through our internet log files, which record data such as user IP addresses, browser types, domain names, and other anonymous statistical data involving the use of the Service. This information may be used to analyze trends, administer the Service, monitor its use, and gather general demographic information. We may link this information to other information about you for these and other purposes, such as personalizing your experience on the Service and evaluating the Service in general.

3. What does Haven do with the information it collects?

As examples, we may use the information collected in the following ways:

• to provide the Service to you, including the coaching-reflection experience;
• to help us understand who uses the Service;
• for internal operations such as operating and improving the Service;
• if you are a beta user of Harbor and have provided your consent, to use your conversations to improve Harbor;
• to contact you for customer service purposes;
• to facilitate the delivery of analytics;
• when we believe it is necessary or appropriate to enforce our legal rights and to comply with applicable laws, lawful requests, and legal process (including to meet national security or law enforcement requirements), such as to respond to subpoenas or requests from government authorities;
• to communicate with you, including to send a welcoming e-mail that may confirm your username;
• to send announcements and updates regarding the Service or, if applicable, your account status (you will not be able to unsubscribe from these Service announcements and updates, as they contain important information relevant to your use of the Service and are necessary for the performance of our contract with you);
• to perform statistical analysis of user behavior, to evaluate and improve the Service, and to link some of this information to other information for internal purposes or to improve your experience with the Service; and
• to anonymize your information (so that it can no longer be associated with you), in which case we may use and/or disclose such anonymous information for our lawful business purposes, using reasonable safeguards designed to minimize the risks associated with anonymizing your information.

4. When does Haven disclose information to third parties?

Harbor is specifically designed to provide you with a confidential coaching experience. Access to your information is limited to our personnel (including your Haven coach) who have a specific need to access it in connection with providing the Service to you. Your information will not be disclosed to your employer (including your employer’s human resources team) without your consent, except that we reserve the right to disclose certain of your information to your employer or other appropriate parties if we believe in good faith that disclosure is necessary or appropriate to address suspected misconduct, illegal activity, or fraud, or to comply with applicable law, legal process, or other legal or contractual obligations.

We may also disclose information we gather from or about you to the following types of third parties, and as otherwise set forth in this Privacy Policy or as specifically authorized by you.

Laws and legal rights. We may disclose your information if we believe in good faith that we are required to do so to comply with an applicable statute, regulation, rule, or law, a subpoena, a search warrant, a court or regulatory order, lawful requests by public authorities (including to meet national security or law enforcement requirements), or other valid legal process. We may also disclose information when we have reason to believe doing so is necessary to identify, contact, or bring legal action against someone who may be violating a contract with us, to detect fraud, to assist with a delinquent account, or to protect the safety and/or security of our users, the Service, or the general public.

Professional advisors. We may provide your information to professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services they render to us.

Outside contractors. We may employ independent contractors, vendors, and suppliers (“Outside Contractors”) to provide specific services and products related to the Service, such as hosting and maintaining the Service and developing applications for it. These Outside Contractors may have access to information collected through the Service, including your information, in the course of providing their products or services to us. We use reasonable efforts to ensure that Outside Contractors are capable of protecting the security of your information.

Sale of business. We reserve the right to transfer information to a third party in connection with a sale, merger, general corporate reorganization, or other transfer of all or substantially all of the assets of Haven or its Corporate Affiliates (or the portion to which the Service relates), a strategic investment by a third party in Haven, or if we discontinue our business or file (or have filed against us) a petition in bankruptcy, reorganization, or similar proceeding.

Affiliates. We may disclose information about you to our Corporate Affiliates.

5. Does this Privacy Policy apply when I click a link to other websites or services?

Our Service may provide you with access to other websites and services. We are not responsible for the privacy practices of any websites or services other than the Service. A link to a third-party website does not constitute or imply our endorsement, and we cannot guarantee the quality or accuracy of information presented on those websites. We encourage you to read the privacy policies of each such website and service. This Privacy Policy applies solely to information collected by us or on our behalf, including through the Service.

6. Is the information collected through the Service secure?

We want your information to remain secure. We strive to transmit your information from your computer or mobile device to our servers using techniques consistent with commercially reasonable standards, and to employ administrative, physical, and electronic measures designed to protect your information from unauthorized access.

There is always some risk in transmitting information over the internet, and some risk that others could find a way to thwart our security systems. While we strive to protect your information, we cannot ensure or warrant the security or privacy of any information you transmit to us, and you do so at your own risk.

7. Could my information be transferred to other countries?

Information collected on the Service may be transferred from time to time to our offices or personnel, or to third parties, located throughout the world, and the Service may be viewed and hosted anywhere in the world, including countries that may not have laws of general applicability regulating the use and transfer of such information.

8. For how long will my information be kept?

We will only retain your information for as long as necessary to fulfill the purposes for which we collected it, or as otherwise permitted by applicable law. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the information; the potential risk of harm from unauthorized use or disclosure; the purposes for which we process it and whether we can achieve those purposes through other means; and applicable legal requirements.

9. What choices do I have regarding my information?

We generally use your information as described in this Privacy Policy, as authorized by you, or as otherwise disclosed at the time we request the information. You generally must “opt in” and give us permission to use your information for any other purpose.

Under certain circumstances, and in compliance with applicable law, you may have the right to submit a request to review, verify, correct, or request erasure of your information; object to its processing; or request that we transfer a copy of it to another party. Please contact us as described in Section 11.

To protect your privacy and security, we may take reasonable steps to verify your identity before granting profile access or making corrections. You are responsible for maintaining the secrecy of your account information at all times.

It may not be technologically possible to remove every record of the information you have provided to us from our systems. Because we back up our systems to protect information from inadvertent loss, a copy of your information may exist in a non-erasable form that is difficult or impossible for us to locate. After receiving your request, we will use commercially reasonable efforts to update, correct, change, or delete your information, as appropriate, in databases we actively use and other readily searchable media, as soon as reasonably practicable.

Do Not Track. “Do Not Track” refers to an HTTP header offered by certain web browsers to request that websites refrain from tracking the user. We take no action in response to automated Do Not Track requests. If you wish to stop such tracking, please contact us using the details in Section 11.

10. How will I know if there are any changes to this Privacy Policy?

We may revise this Privacy Policy from time to time. We will not make changes that result in significant additional uses or disclosures of your information without allowing you to “opt in” to those changes. We may also make non-significant changes that generally will not significantly affect our use of your information, for which your opt-in is not required. We encourage you to check this page periodically. If any non-significant change is unacceptable to you, you must immediately contact us and, until the issue is resolved, stop using the Service.

11. Who do I contact if I have any privacy questions?

If you have any questions or comments about this Privacy Policy, please contact us:

By e-mail: info@havenhumanassets.com