Privacy Policy

Last updated: August 21, 2020

Our Commitment to Privacy

Visitors that are residents of California should refer to our California Website Privacy Policy supplement.

Visitors that are residents of the United Kingdom, the European Union or the European Economic Area should refer to our EU Privacy Notice supplement.

Your privacy is important to Harmoni Towers LLC, a Delaware limited liability company, and its affiliates (together, “Harmoni,” “our,” “us,” “we” or “company”). To better protect your privacy, we are providing information explaining our online information practices.

This Website Privacy Policy (this “Privacy Policy”) describes how we gather and use information for visitors of this website. Please read this Privacy Policy carefully. If you do not agree with any of the terms and conditions contained herein, please do not access or otherwise use this website.

This Privacy Policy constitutes a legally binding agreement between Harmoni and you, the user of this website. By entering and using this website, you acknowledge your acceptance of, and agree to be bound by, the Privacy Policy stated herein, our Terms and Conditions and all additional terms incorporated by reference herein. If you do not agree to this Privacy Policy, please do not access or use this website or submit any personal information to Harmoni.

The Information We Collect And How We Use It

We may collect various types of information from users of this website. For example, knowing how users use our website—tracking their movement through this website—helps us improve website design and usefulness. As a result, Harmoni’s server collects general data pertaining to users, including the length of time spent on this website, the pages accessed while visiting the website and Internet Protocol (IP) addresses. Harmoni generally does not, however, collect any personally identifiable information such as names, home addresses or e-mail addresses from users of this website, unless a user submits such information to us via our “Contact” page.

To the extent that you provide us with any personally identifiable information through or in connection with this website, we may use such information for Harmoni’s business purposes, but will not disclose any personally identifiable information about you to anyone, except as permitted or required by law or regulation and to service providers. In providing personally identifiable information to Harmoni, you consent to Harmoni’s use of such personally identifiable information for the purposes described in this Privacy Policy.

Unfortunately, the transmission of information and data via the Internet is not completely secure. Although we make an effort to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through our website; any transmission of information or data by you to or through this website is at your sole risk.

Capacity

You represent to Harmoni that you have the authority to visit this website. This website is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to this website who are under the age of 18 or knowingly collect personal information from anyone under the age of 18 without parental consent. If we learn we have collected or received personal information from an individual under the age of 18, we will delete that information.

Cookies

Information regarding how you access this website (e.g., browser type, access times and Internet Protocol (IP) address) and your hardware and software may automatically be collected through the use of cookies (a small text file placed on your hard drive) or other technologies or tools. This information is used to improve website performance and for our business purposes. You may opt-in to accept cookies automatically by changing the settings on your browser. If you opt-out of certain cookies, you may not be able to access certain parts of this website. You may wish to visit www.aboutcookies.org, which contains comprehensive information about types of cookies, how they are used and how you manage your cookie preferences.

You may access any personally identifiable information we have about you by contacting our customer privacy team, at privacy@192.168.5.101.

Notification of Changes

We reserve the right to amend this Privacy Policy from time to time and for any reason, in our sole discretion, without notice, by updating this Privacy Policy. Accordingly, users are strongly encouraged to review our Privacy Policy regularly. If we decide to change our Privacy Policy, we will post those changes so our users are always aware of what information we collect, how we use it and under what circumstances, if any, we disclose it. If at any point we decide to collect personal information or use any collected information in a manner different from that stated at the time it was collected, we will notify users by posting changes on this page. We will use information only in accordance with the Privacy Policy under which the information was collected. Your continued access or use of this website following the posting of changes to this Privacy Policy means that you accept such revisions, changes and/or amendments. If you object to any of the changes to this Privacy Policy, please stop accessing this website. Please check this page frequently and review any changes to this Privacy Policy carefully so you are aware of any changes, as they are binding on you.

Miscellaneous

The provisions in our Terms and Conditions are hereby incorporated by reference.

Contact Us

If you have any questions or concerns about this Privacy Policy, please contact our customer privacy team, at privacy@192.168.5.101.

California Website Privacy Policy

Date: August 20, 2020

This California Website Privacy Policy supplements the Website Privacy Policy with respect to specific rights granted under the California Consumer Privacy Act of 2018 (as amended, the “CCPA”) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This supplement is only relevant to you if you are a resident of California as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth in this CCPA supplement is otherwise set forth in the Website Privacy Policy.

What does this Website Privacy Policy apply to?

This Website Privacy Policy applies solely to your interactions with us through our Website (as defined below). If you provide personal information to use through another means (e.g., as an employee or seeking employment or as a customer) you will receive a separate privacy notice and that notice will govern that personal information.

What information do we collect about you?

We collect limited types of personal information through our website, as well as through other electronic communications (e.g., emails), as applicable (collectively, the “Website”). The types of personal information we collect about you depends on the nature of your interaction with us. The categories of personal information we have collected from individuals on this Website over the last twelve (12) months include the following:

• Identifiers, such as name, contact details and address (including physical address, email address and Internet Protocol address);
• Other customer records, such as telephone number and personal information provided in connection with obtaining account access;
• Commercial information, such as account data;
• Professional or employment-related information;
• Education information;
• Internet or other electronic network activity information, such as information regarding your use of our Website (e.g., cookies, browsing history and/or search history), as well as information you provide to us when you correspond with us in relation to inquiries.

We do not knowingly collect or solicit personal information from anyone under the age of 18.

How do we obtain your personal information?

In connection with forming and operating our Website, we collect and maintain your nonpublic personal information from the following sources:

• Information from your communications with us in connection with this Website, including any update notices provided by you.
• Information captured on our Website, including registration information, information provided through online forms and any information captured via cookies.
• We may combine personal information that you provide to us with information that we collect from or about you from publicly available sources. This will include information collected in an online or offline context.

How do we use your personal information?

We will use your personal information for one or more of the following business purposes:

• To perform services for you.
• To improve our Website and the products and services that we offer and notify you about changes to our products and services.
• To communicate with you, including responding to requests for information submitted by you through our Website.
• To keep a record of your relationship with us.
• Ongoing operations, administrative, accounting, reporting, account maintenance and other processes.
• To audit and verify the quality and effectiveness of our services and compliance.
• To detect security incidents and to protect against malicious, deceptive, fraudulent, or illegal activity.
• To generally comply with U.S., state, local and non-U.S. laws, rules and regulations.

Who do we share your personal information with?

We do not sell any of the personal information we collect about you to third parties.

We do not disclose any nonpublic personal information about you to anyone, except as permitted or required by law or regulation and to affiliates and service providers, including but not limited to administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants, internet analytics providers, and placement agents. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.

Within the last twelve (12) months, we have shared each of the categories of personal information collected in connection with this website with affiliates and service providers as set forth above in “What information do we collect about you?”

We may also share your personal information with applicable third parties in the event of a reorganization, merger, sale, acquisition, assignment, bankruptcy proceeding, or other disposition of all or a portion of our business, assets or shares.

How do we keep your personal information secure?

We consider the protection of sensitive information to be a sound business practice, and to that end we employ appropriate organizational, physical, technical and procedural safeguards, which seek to protect your personal information in our possession or under our control to the extent possible from unauthorized access and improper use.

Your rights under the CCPA

Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.

Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection and use of personal information specific to you over the last twelve (12) months. Such information includes:

• the categories of personal information we collected about you;
• the categories of sources from which the personal information is collected;
• our business or commercial purpose for collecting such personal information;
• the categories of third parties with whom we share the personal information;
• the specific pieces of personal information we have collected about you; and
• whether we disclosed your personal information to a third party, and, if yes, the categories of personal information that each recipient obtained.

No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.

How to Exercise Your Rights: To exercise any of your rights under the CCPA, or to access this notice in an alternative format, please submit a request on your behalf using any of the methods set forth in the Contact us section below.

Contact Us

For any requests relating to the exercise of your rights under the CCPA, or questions regarding our processing of your personal information, please submit or have your authorized representative submit a request using any of the methods set forth below.

Submit a request online using the following online form: Contact Form.

Email us at the following email address: privacy@192.168.5.101.

If you would like to contact us by telephone without incurring telephone charges, please submit your request and telephone number either (1) through the above online form or (2) by email at the following address privacy@192.168.5.101, and we will call you between 9 a.m. and 6 p.m. Eastern Time.

We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request further information in order to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above.

Our goal is to respond to any verifiable consumer request within forty-five (45) days of our receipt of such request, but in certain cases, additional time might be required. Please contact the Chief Compliance Officer of Harmoni at the email address above with any questions about this California Website Privacy Policy.

EU Privacy Notice

Date: August 20, 2020

This EU Privacy Notice applies to the extent that EU Data Protection Legislation (as defined below) applies to the processing of personal data by an Authorized Entity (as defined below) or to the extent that a data subject is a resident of the United Kingdom (the “UK”), the European Union (“EU”) or the European Economic Area (“EEA”). If this EU Privacy Notice applies, the data subject has certain rights with respect to such personal data, as outlined below.

For purpose of this EU Privacy Notice, “EU Data Protection Legislation” means all applicable legislation and regulations relating to the protection of personal data in force from time to time in the EU, the EEA, or the UK, including and without limitation: the Data Protection Directive (95/46/EC), the Privacy and Electronic Communications (EC Directive) Regulations 2003, the Data Protection (Processing of Sensitive Personal Data) Order 2000, or any other legislation which implements any other current or future legal act of the European Union concerning the protection and processing of personal data (including Regulation (EU) 2016/679 (the General Data Protection Regulation) and any national implementing or successor legislation), and including any amendment or re-enactment of the foregoing. The terms “data controller”, “data processor”, “data subject”, “personal data” and “processing” in this EU Privacy Notice shall be interpreted in accordance with the applicable EU Data Protection Legislation.

Please contact us at privacy@192.168.5.101 with any queries arising out of this EU Privacy Notice.

Categories of Personal Data Collected and Lawful Bases for Processing

In connection with its commercial activities, including building and managing telecommunications towers, Harmoni Towers, LLC (“Harmoni”), its affiliates, and their respective administrators, legal and other advisors, and agents (the “Authorized Entities”) collect, record, store, adapt, and otherwise process and use personal data either relating to existing or potential customers or parties with whom the Authorized Agents may transact business, or to their respective partners, officers, directors, employees, shareholders, or affiliates or to any other data subjects from the following sources:

1. information received in telephone conversations, in voicemails, through written correspondence, via e-mail, or on subscription agreements, applications or other forms;
2. information about transactions with any Authorized Entity or others;
3. information captured on any Authorized Entity’s website, including contact or possible registration information and any information captured via “cookies”; and
4. information from available public sources.

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Any Authorized Entity may process the following categories of personal data, among others:

1. names, dates of birth and birth place;
2. contact details and professional addresses (including physical address, email address and telephone number);
3. account data and other information contained in any document provided by existing or potential customers to the Authorized Entities (whether directly or indirectly);
4. information regarding an existing or potential customer’s status under various laws and regulations;
5. information regarding an existing or potential customer’s citizenship and location of residence.

Any Authorized Entity may, in certain circumstances, combine personal data it receives from an existing or potential customer with information that it collects from, or about such existing or potential customer, as applicable. This will include information collected in an online or offline context.

One or more of the Authorized Entities are “data controllers” of personal data collected in connection with Harmoni. In simple terms, this means such Authorized Entities: (i) “control” the personal data that they or other Authorized Entities collect from existing customers, potential customers or other sources; and (ii) make certain decisions on how to use and protect such personal data.

Harmoni and the Authorized Entities have a legitimate need use such information for Harmoni’s business purposes, such as monitoring internet traffic, improve services offered, or improve the website user experience, among other things. From time to time, an Authorized Entity may need to process the personal data on other legal bases, including: with consent; to comply with a legal obligation or if it is necessary for a task carried out in the public interest.

Purpose of Processing

The applicable Authorized Entities process the personal data for the following purposes, among others:

1. ongoing communication with existing and potential customer and their respective representatives, advisors and agents;
2. ongoing administrative, accounting, reporting and other processes and communication required to operate the business of Harmoni;
3. any legal or regulatory requirement;
4. keeping existing and potential customers informed about the business of Harmoni and its affiliates generally; and
5. any other purpose that has been notified, or has been agreed, in writing.

The Authorized Entities monitor communications only in the event the law requires them to do so or, where permitted, to protect their respective businesses and the security of their respective systems.

Sharing and Transfers of Personal Data

In addition to disclosing personal data amongst themselves, any Authorized Entity may disclose personal data, where permitted by EU Data Protection Legislation, to other service providers, employees, agents, contractors, consultants, professional advisers, lenders, data processors and persons employed and/or retained by them in order to fulfil the purposes described in this EU Privacy Notice. In addition, any Authorized Entity may share personal data with regulatory bodies having competent jurisdiction over them, as well as with the tax authorities, auditors and tax advisers (where necessary or required by law).

Any Authorized Entity may transfer personal data to a Non-Equivalent Country (as defined below), in order to fulfil the purposes described in this EU Privacy Notice and in accordance with applicable law. For information on the safeguards applied to such transfers, please contact Harmoni. For the purposes of this EU Privacy Notice, “Non-Equivalent Country” shall mean a country or territory other than (i) a member state of the EEA; or (ii) a country or territory which has at the relevant time been decided by the European Commission in accordance with EU Data Protection Legislation to ensure an adequate level of protection for personal data.

Retention and Security of Personal Data

Harmoni and its affiliates consider the protection of personal data to be of high importance, and to that end, employ appropriate technical and organizational measures, including robust physical, electronic and procedural safeguards to protect personal data in their possession or under their control.

Personal data may be kept for as long as it is required for legitimate business purposes, to perform contractual obligations, or where longer, such longer period as is required by applicable legal or regulatory obligations.

Data Subject Rights

It is acknowledged that, subject to applicable EU Data Protection Legislation, the data subjects to which personal data relates, have certain rights under EU Data Protection Legislation: to obtain information about, or (where applicable) withdraw any consent given in relation to, the processing of their personal data; to access and receive a copy of their personal data; to request rectification of their personal data; to request erasure of their personal data; to exercise their right to data portability; and the right not to be subject to automated decision-making. Please note that the right to erasure is not absolute and it may not always be possible to erase personal data on request, including where the personal data must be retained to comply with a legal obligation. In addition, erasure of the personal data requested to fulfil the purposes described in this EU Privacy Notice, may result in Harmoni’s inability to provide certain services to those customers that request such erasure.

In case the data subject to whom personal data relate disagrees with the way in which their personal data is being processed under this EU Privacy Notice, the data subject has the right to object to this processing of personal data and request restriction of the processing. The data subject may also lodge a complaint with the competent data protection supervisory authority in the relevant jurisdiction.

The data subject may raise any request relating to the processing of his or her personal data with us at privacy@192.168.5.101.