HarQen, Inc. Privacy Policy

Effective Date: October 1, 2011

HarQen, Inc. ("HarQen") appreciates your interest in our websites, http://www.HarQen.com, http://www.VoiceAdvantage.com, http://www.comicwonder.com and http://Symposia.HarQen.com (the "Sites"). Your privacy is important to us. Our Sites are designed to provide access to online information about HarQen and certain of our products and service lines, including Voice Advantage and Symposia. In connection with providing this information, there are times when we may ask for or collect personal information from you, either in the form of anonymous data or personally identifiable information. As part of our commitment to honoring and protecting your privacy, this Privacy Policy will explain the approach we take in protecting and using the information we gather from you through our Sites.

Changes and Updates to this Privacy Policy:

HarQen reserves the right to update and change this Privacy Policy, and the products, services, prices, and programs mentioned on the Sites at any time, at its sole discretion and without notice. We encourage you to revisit this page to stay informed of any changes. Your continued use of the Sites constitutes your agreement to the terms of this Privacy Policy and any future versions of this Privacy Policy.

Certified Compliant with EU Safe Harbor Principles:

HarQen complies with the U.S.-EU Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. We have certified that we adhere to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. For further information on HarQen's compliance with EU Safe Harbor Principles please review our EU Safe Harbor Policy http://symposia.harqen.com/policies/safeharbor. To learn more about the US-EU Safe Harbor Framework, please visit http://www.export.gov/safeharbor/.

Links and Content from Third Parties:

Our Sites and email communications may contain links to other websites that are owned and operated by third parties. The information practices of websites linked to our Sites are not covered by this Privacy Policy and, therefore, we are not responsible for the privacy policies of those websites. We encourage you to review the privacy policies of other websites to understand their privacy practices. Further, users of the Sites may from time-to-time post material on the Sites. Though we do attempt to monitor user-posted content, such user-posted material is not subject to this Privacy Policy.

Information HarQen Collects:

Cookies: When you visit the Sites, we ask your browser to store small text files containing a string of alphanumeric characters known as a cookie. HarQen uses both session cookies and persistent cookies. If you have chosen to identify yourself on a Site, we use session cookies containing encrypted information to identify you and facilitate your use of the site. Session cookies are required to access much of the content and services offered on the Sites. After you leave our Site and close your browser, a persistent cookie remains. Persistent cookies can be removed by following your help file directions in your web browser. If you refuse our cookies, some features of the Sites may not function properly.

User Provided Information: When you choose to submit personally identifiable information to HarQen on the Sites (e.g., uploading audio files, posting comments, entering contests, subscribing to mailing lists, taking advantage of promotions, responding to surveys, etc.), your information is used only for the specific purpose for which it was submitted, unless you consent otherwise or as required by law. In many cases, you choose the amount of information you supply (e.g., when sending us information through the Sites, you may choose to include only an e-mail address - not a telephone number or mailing address - for replies). There may be instances where some of the information that we ask you to provide is identified as mandatory and some as voluntary. In such cases, if you do not provide mandatory personal information with respect to a particular activity, you will not be able to engage in that activity.

Log Files: HarQen's servers automatically record certain information (e.g., web request, Internet Protocol ("IP") address, browser type, browser language, URLs, etc) that your web browser sends whenever you visit our websites.

Web Beacons: We may employ clear GIFs or Web Beacons to track anonymously how users use the Sites. We may also use Web Beacons in our emails to track which emails are opened by recipients.

How HarQen Uses Information:

HarQen and our affiliates and agents use information obtained from users of the Sites for the purposes of providing certain services available only through the Sites. HarQen uses information collected from cookies, Web beacons, and log files to enhance our users' experience by providing custom, personalized content. We also use this information to monitor the overall effectiveness of our Sites and track metrics (e.g., total number of visitors, pages viewed, etc). HarQen does not disclose or sell personally identifiable information to unaffiliated third parties unless required by law or pursuant to the user's consent.

HarQen and our affiliates and agents collect and use aggregate voice data, to enhance, and improve the speech recognition and other voice analysis components used to provide the service. Voice data means the audio files, associated transcriptions and log files provided by users of the Sites or generated in connection with the utilization of the services offered through the Sites.

When HarQen Discloses Information:

If HarQen ceases operations, personally identifiable information may be provided to a third party for bankruptcy purposes or if there is a transfer or sale of the assets or ownership of HarQen. HarQen may also disclose personally identifiable information to respond to a subpoena, court order or similar request, or to defend itself against legal claims. HarQen may also provide such personally identifiable information to investigate, prevent and take action regarding fraud or misuse, to comply with law or in response to a law enforcement agency's request, to enforce our Privacy Policy and end user agreements, and to protect the rights, property and safety of the Sites, users and others.

We provide personally identifiable information and non-personally-identifiable information to our affiliates and agents for the purpose of processing such information on our behalf. We require that these parties agree to process such information in accordance with our Privacy Policy, and we use reasonable efforts to limit their use of such information and to use security measures.

We do not share your personally identifiable information (such as name or email address) with other, third-party companies for their commercial or marketing use without your consent or except as part of a specific program or feature for which you will have the ability to opt-in or opt-out.

We may share non-personally-identifiable information (e.g., anonymous user usage data, platform types, number of clicks, etc) with third parties to determine usage patterns for certain services, advertisements, promotions, and/or functionality on the Sites.

We may release personally identifiable information and/or non-personally-identifiable information if required to do so by law, or in the good-faith belief that such action is necessary to comply with state and federal laws (e.g., U.S. copyright law) or respond to a court order, subpoena, or search warrant.

HarQen reserves the right to disclose both personally and non-personally identifiable information to enforce our Terms of Use Agreement, prevent liability, and investigate and defend itself against any third-party claims or allegations. We may also provide information to assist government enforcement agencies, protect the security or integrity of the Sites, and/or protect the rights, property, or personal safety of HarQen employees, users and others.

Data Security

To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect through the Sites. The measures include, but are not limited to, firewalls, server authentication, data encryption, user driven security settings, username and passwords. However, please be advised that we cannot guarantee and have no control over the public or third party network through which you send your personal information to our Sites.

If HarQen learns of an information security breach, we may attempt to notify you via email so that you can take appropriate steps. In addition, HarQen may post a notice on the effected Site(s). Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive a free written notice of a security breach (or to withdraw your consent from receiving electronic notice) you should notify via email at support@harqen.com.

Children's Privacy

The Sites are intended for mature audiences. HarQen does not knowingly collect personal information from children under the age of 18. Children under the age of 18 should not visit any of the Sites nor submit any personal information. Furthermore, HarQen does not knowingly use or distribute personal information regarding children under the age of 18. If HarQen obtains actual knowledge that it has collected personal information about a child under the age of 18, that information will be immediately deleted from our servers.

Contact Information

Please contact HarQen at: support@harqen.com with any questions or comments about this Privacy Statement or write to: HarQen Attn: Privacy Officer, 1830 N Hubbard St, Suite 700, Milwaukee, WI, 53212.