+ SCOTT + HARPER

Last Updated 12.15.22

Privacy Policy

This Privacy Policy governs the treatment of Personal Information, as defined below, that you, as a customer and/or client of Harper + Scott, LLC, a New York limited liability company (“H+S,” “we,” or “us”) provide to H+S for the purpose of providing goods and services to you and/or your customers and/or employees. By providing Personal Information to H+S, including but not limited to names, addresses, and email addresses of you, your employees and/or your customers (collectively, “you,” “your employees,” and “your customers” are referred to as “you” or “your”), you represent and warrant that you have the authority to provide such Personal Information to H+S. H+S respects privacy rights, and is committed to safeguarding the Personal Information entrusted to us by our clients. H+S has implemented this Privacy Policy to govern the use of Personal Information that you send to us. This Privacy Policy does not govern Personal Information collected from any other source or in any other manner. This Privacy Policy is intended to provide you with information as to: (i) the type of information that is collected, (ii) how the collected information is used and with whom it is shared; (iii) how we intend to protect the information; and (iv) how you can access such information and have it
modified and/or removed.

This Privacy Policy may be changed from time to time, and we reserve the right to make changes without prior individual notice. Such changes are effective upon publication or transmission to you of the revised Privacy Policy. Please review this Privacy Policy so that you will remain abreast of H+S's current policies, including its policies concerning the gathering and use of information that may be provided to H+S by you. This Privacy Policy does not govern or apply to Personal Information collected on the H+S Websites. You are responsible for making sure you are aware of the provisions of H+S’s most current Privacy Policy. You can tell when the Privacy Policy was last modified by checking the “updated” date.
Collection and Use of Information
Personal Information

Personal Information is information that uniquely identifies you or your customers and employees, such as names, addresses, email addresses, and telephone numbers. H+S maintains your Personal Information on databases it owns and/or controls and does not share that information with third parties without your consent, other than as identified in this Privacy Policy. We do not sell your Personal Information or disclose your information to third parties for commercial purposes. The Personal Information provided to us remains your property, and no ownership rights in or to such personal Information are conveyed to H+S when you provide us with your Personal Information.

Your Consent

We collect, use and/or disclose your Personal Information to fulfill our requirements as defined by this policy. Your disclosure of your personal information to us for these purposes is considered implied
consent to use your personal information to fulfill your requests. Personal information provided to us by our Partners is considered by Us as approved consent for your information and is the responsibility of our Partners to collect your consent. We will request your consent if our policies change with the intent to use your Personal Information for any other purposes.
Use of Your Personal Information

We use your Personal Information with your consent for the purposes for which it is submitted, such as to arrange for drop shipment of goods we sell to you or to create order submission forms that may be provided to clients’ employees or customers. Your Personal Information may also be used in the following ways:

• to deliver materials, information and services to you,
• to provide you with marketing information
• for market research purposes
• to give you notice of and/or resolve any problems that may arise in connection with our services,
• to better understand the needs and interests of our customers,
• to provide information about potential client/consultant projects
• for compliance with any legal and/or regulatory obligations,
• as otherwise reasonably required to provide customer services,
• to investigate potentially unlawful activity,
• for any other purpose outlined in this Privacy Policy,
• with your consent, to communicate with you about H+S-related and/or industry-related events,
  products or services we think may be of interest to you, and as permitted by law.

Once you have initiated contact with H+S, we may use your Personal Information to respond to your inquiries or otherwise contact you in connection with our provision of services to you via telephone, direct postal mail and/or electronically regarding your relationship with H+S.
Opting in and opting out of electronic communications. You may opt out of receiving future electronic communications, such as marketing or promotional emails, from H+S at any time by (i) sending an email directly to hello@harperandscott.com (ii) writing to H+S’s corporate offices at 915 Broadway, Suite 1206, New York, NY 10010 or (iii) clicking on the “opt-out” or “unsubscribe” link in any electronic communication you receive.

Use of Your Personal Information Within H+S. H+S may share your Personal Information with our employees and other H+S personnel to assist us in providing goods and services to you. We will not share your Personal Information with unaffiliated third parties, except as stated in this Privacy Policy, without your consent.

Use of Your Personal Information by Our Service Providers. In order to provide you with the services and/or goods you have requested and/or ordered, we may hire third parties to assist us with certain functions and services, such as supply and manufacture, payment processing, data processing, computer software and website maintenance and development, transaction processing, promotional and marketing services, customer service, professional, legal or accounting services and/or business and sales analysis. H+S may share your Personal Information, without restriction with such companies that we hire to perform services for us. In such situations, H+S requires that these companies agree to maintain the confidentiality of your Personal Information and to comply with the safeguards described in this Privacy Policy. These companies have access to the Personal Information needed to perform their functions but are not permitted to share or use such information for any other purposes

If H+S changes ownership. We may also share your Personal Information as required to allow for a change in ownership of H+S and/or any of H+S’s Affiliates and/or of any business(es) to which your transactions with us relate, and the related transfer of user information to the new owner. In the event of any such change of ownership, your Personal Information will continue to be protected by the terms of this Privacy Policy unless and until you are notified of a change.

Lawful Access, Legal Action and Investigations. Your Personal Information may be disclosed to nonaffiliated third parties as either required by, or to comply with, applicable laws and regulations. We may disclose Personal Information if we believe it is necessary to investigate, prevent, or take action regarding suspected illegal activities or fraud, situations involving the physical safety of any person, violations of our Privacy Policy, or otherwise in accordance with applicable law. For example, H+S may disclose your Personal Information to comply with investigations by regulatory authorities or enforcement agencies in the United States of America or elsewhere, or to protect against or prevent actual or potential fraud. Furthermore, H+S may disclose your Personal Information if it has a reasonable good faith basis to believe that it is required to do so by law, compelled by court order or legal process, or is reasonably necessary and/or appropriate to: (i) protect the rights, property and/or safety of H+S or any other person or entity; or (ii) prevent or take action concerning any (a) illegal activity or (b) breach of the Privacy Policy.
Retention of Personal Information
Personal Information is retained to deliver our services, to otherwise fulfill identified or apparent purposes, and for record-keeping. H+S will retain your Personal information for only as long as is necessary for the uses set out in this Privacy Policy and/or to meet legal and regulatory requirements. After this period, we will securely erase Personal Information. If the Personal Information is needed for analytical, historical or other legitimate purposes, we will take appropriate measures to anonymize your Personal Information. Once anonymized, H+S undertakes not to re-identify the information.

You have the right to request details of personal Information which we hold about you. Please indicate any details to help us identify and locate your Personal Information, including company name, order number and/or delivery address.

You have the right to have your Personal Information to be modified, corrected or removed from H+S’s records and/or databases or, if technically feasible, transferred to another organization.
You also can contact us if you have any complaints about how we collect, store or use your Personal Information. If you want to contact us for or regarding any of the above reasons or purposes, please e-mail H+S at hello@harperandscott.com or write to us at Harper + Scott LLC, Attn: Operations; 915 Broadway, Suite 1206, New York, NY 10010.

Please note that we may ask for verification of your identity or that you are to act on behalf of someone else if you submit any requests or complaints in connection with your Personal Information before we take any action in response to your requests or complaints.

Protection and Security of Information

H+S is committed to maintaining the security of your Personal Information. Physical, technical, electronic and managerial procedures have been employed to safeguard the security and integrity of Personal Information provided to us by you. The Personal Information you provide is secured using industry standard security technology. H+S also restricts its own employees’ access to Personal Information, stores files that contain Personal Information in secure email or in our ERP software, all of which are accessible by individual employee user accounts that are password protected. Personal Information, such as addresses, are never scanned or archived. However, it is possible that someone may intercept or access communications, transmissions and/or Personal Information. In the event that H+S determines that there has been a security breach that results in the unauthorized disclosure of Personal Information to a third party, H+S will promptly notify clients whose Personal Information it reasonably believes has been compromised by sending an email notification with respect to the situation.

Governing Law
This Privacy Policy shall be governed by the laws of the State of New York of the United States of America, without regard to its conflict of law provisions.

Contact Us
If you have any questions concerning this Privacy Policy or our handling of your Personal Information you
may contact us at hello@harperandscott.com or by writing to us at the address provided above.