Privacy Policy

This Privacy Policy ("Policy") is intended to explain the processing of your personal data ("Data") obtained through the Harmony platform https://heyharmony.com/ ("Harmony"). We are committed to ensuring that Data is processed in accordance with the law, including Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC ("General Data Protection Regulation" – "GDPR").

The terms used in the Policy have the meanings assigned to them in the Harmony Terms of Service, available here.

Information on Data Processing

The Data Controller is Harmony Inc. with its registered office in the United States, Delaware, 8 The Green, Ste. R., in the City of Dover County of Kent, zip code 19901 ("We" or "Company").

You may contact our representative Agnieszka Pilarska, appointed pursuant to Article 27 of the GDPR, with respect to questions, requests and complaints regarding the processing of Data ("Requests"):

• via e-mail at: [email protected]; or
• in writing to the address: Agnieszka Pilarska, Reja 12/26, 31-216, Cracow.

In the Request, provide: (i) Data of the person to whom the Request relates, (ii) a description of the event to which the Request relates, and (iii) your expected resolution of the reported issue.

We process Data within Harmony to:

• take action upon request prior to entering into a Contract with you and its performance, including the provision of services by us – based on Article 6(1)(b) of the GDPR;
• send to you commercial information (including newsletters), via the communication channel to which you voluntarily give your marketing consent, i.e. via electronic message to the indicated e-mail address and/or telephone notifications (SMS/MMS), for the purpose of presenting commercial offers and terms and conditions – based on Article 6(1)(a) GDPR;
• to carry out our legal obligations (e.g. under accounting and tax regulations) – based on Article 6(1)(c) of the GDPR;
• pursue our legitimate interest, which is: (i) to establish, assert or defend against claims; (ii) to conduct analytical, marketing or statistical activities within Harmony in connection with the use of cookies; (iii) to carry out direct marketing – in particular, if you are a potential Harmony user – to inquire about the possibility of contacting you and sending you commercial information regarding the marketing of the services offered by the Company (i.e. promotion of the Company's services); (iv) to contact you, e.g. when you contact us via the contact form or in connection with a Request; (v) if you are a person representing the User or appointed by the User for contact purposes – to perform the contract concluded with the entity you represent – based on Article 6(1)(f) of the GDPR).

More detailed information, including the legal bases for processing Data within specific cookies, is provided in §2 below.

We may transfer the Data to entities cooperating with us, including IT system providers, payment operators, legal, accounting, debt collection, or training service providers, as well as companies providing courier and postal services, as well as all to institutions authorized under applicable law, in particular courts and tax authorities. In any case, the processing of your personal data by the aforementioned recipients will be carried out on the basis of an appropriate authorization, a data processing agreement, or under applicable regulations.

The Data will be processed within the European Economic Area (EEA) and outside the EEA, in particular in the USA. In the case of transfer of the Data outside the EEA, the Data will be transferred to countries for which the European Commission has issued a decision stating an adequate level of protection, and in the absence of such a decision, security will be ensured by appropriate safeguards, including but not limited to standard contractual clauses approved by the European Commission. You have the right to obtain a copy of the safeguards applied to personal data transferred outside the EEA by contacting the Company. We will then ensure their confidentiality and ensure that only the Data necessary for the proper performance of the Contract will be transferred and the transfer will be based on appropriate safeguards required by law.

We will not retain the Data longer than necessary to provide the services for which it was collected, i.e., until the contract expires or any related claims become time-barred. In the case of contacting us, the Data will be retained until the matters related to the contact are resolved unless otherwise required by law.

If you are a User using Harmony, we process your Data in the form of: first name, last name, company details e-mail address, Tax ID number. We have received this Data directly from you.

If you are a person representing the User or designated by them to contact us, we have received your Data (including your first name, last name, e-mail address, phone number, and job title) from the User whom you represent or on whose behalf you are acting.

Where we process the Data based on your consent, you have the right to withdraw your consent at any time. The processing of the Data until you withdraw your consent remains lawful.

You have the right to file a complaint with the supervisory authority, in Poland: President of the Personal Data Protection Office.

You have the right to request access to your Data, its rectification, erasure, or restriction of processing, as well as the right to object to the processing of your Data and the right to Data portability.

Providing your Data is voluntary; however, without it, cooperation with the Company (e.g., conclusion or performance of a contract, contacting us, or accessing information and materials about our products) will not be possible. You will not be subject to automated decision-making, including profiling, within Harmony.

Cookies

Within Harmony, we use cookies or other similar technologies, and therefore, using Harmony requires placing small text files with information on your End Device, which are used by websites that connect to your browser, as well as other data storage mechanisms – collectively referred to as cookies. During your use of Harmony, we retrieve and store information from browsers that may contain the Data.

Please be advised that we use essential cookies to provide you with services and ensure the functionality of Harmony. The legal basis for the processing of the Data in connection with the use of necessary cookies is the necessity of the processing for the performance of the contract – based on Article 6(1)(b) of the GDPR, in the case where we conclude a Contract with you – or our legitimate interest under Article 6(1)(f) of the GDPR, which is to provide the highest quality of services within Harmony.

With regard to other so-called "optional" cookies, the legal basis for the processing of the Data in connection with the use of cookies, including the adaptation of Harmony's functionality to your needs and preferences, is your consent – Article 6(1)(a) of the GDPR. By managing the cookie settings in your own browser, you can withdraw the consents you have given at any time.

The period of activity of cookies is as follows: in the case of temporary cookies – the files are automatically deleted after a certain expiration date; in the case of permanent cookies – the files are active on your browser until they are deleted, which you can do at any time.

You have the right to use the options offered by each browser to manage cookies. For more information, you can refer to the privacy/security settings of the browser you are using. Deleting cookies may affect the proper operation of Harmony and its functionalities, the correctness of Harmony's display, and the loss of your preferred web page settings within Harmony. Blocking or restricting access of cookies to your End Device may adversely affect the functionality of Harmony.

Cookies and pixel tags may also be used by third parties (e.g. Google, Facebook) to provide their own content or advertisements on websites or portals based on records from these cookies and pixel tags.

We use the following types of cookies: (i) essential – necessary for the proper functioning of Harmony, including storing your session and enabling the operation and improving the functionality of Harmony; (ii) analytical – used for conducting analysis and statistics regarding Harmony; (iii) functional – used to remember and customize Harmony according to your choices; (iv) advertising – used in advertising campaigns to tailor ads to you and remember your settings. In addition, as part of the aforementioned types of cookies, we also use external cookies, i.e. cookies placed by third parties (such as Google Analytics or Facebook's Pixel). In the case of external cookies, the rules for their processing are also described in separate documents provided by third parties.

Final provisions

The development of technology and the growth of our offering may lead to changes in the Policy, which we will inform you about through Harmony or via e-mail.

The date of last modification of the Policy: 03/29/2025