Privacy Policy - LECOM Harborcenter

Harborcenter Development, LLC PRIVACY POLICY

Harborcenter Development, LLC, together with its affiliates (hereinafter referred to as “HCD,” “us,” “we,” “our,” or “Company”), has created the following Privacy Policy for when you visit our website at www.rinksatharborcenter.com, mobile and other applications, and any other online services where this Privacy Policy is posted (collectively, our “Services”). This Privacy Policy describes, among other things, the types of information we collect from users when you use our Services, how we use it, and how you can access your information.

This Privacy Policy is integrated into our Terms & Conditions of Use (“Terms & Conditions”).

INFORMATION WE COLLECT ABOUT YOU

We may collect the following types of information about you which are described in more detail below: (A) information you provide to us, (B) information we may automatically collect, and (C) information we may receive from third parties. All of the information listed in (A)-(C) above, are detailed below, and hereinafter referred to as “Information.”

Information You Provide to Us:

In using our Services, you may provide us with Information, including, without limitation:

Contact information such as name, email address, postal address and telephone number(s);
Demographic information such as birth date or gender;
Account information and log in credentials, including unique identifiers such as username and password;
Payment and transaction information including credit or bank card information;
Preferences for communications, shopping, products;
Communications and opinions in chat rooms, message boards, forums, surveys, polls, and online forms;
Access to your geo-location (including through our mobile app) or to other data held on social media platforms and other software (for example, access to your contacts, calendar or photos);
Photos and/or videos;
Information about your guests or family for events; and
Additional information as otherwise described to you at the point of collection or pursuant to your consent.

Information We May Automatically Collect About You:

Our Services may automatically collect certain Information about you. We use this Information to help us design our Services to better suit our users’ needs. This Information may include:

IP address, which is the number associated with the service through which you access the Internet, like your ISP (Internet service provider), or your company;
Date and time of your visit or use of our Services;
Domain server from which you are using our Services;
Type of computer, web browsers, search engine used, operating system, or platform you use;
Data identifying the web pages you visited prior to and after visiting our website or use of our Services;
Your movement and activity within the website, which is aggregated with other information;
Geo-location information through the use of any of our mobile applications;
Mobile device information, including the type of device you use, operating system version, and the device identifier (or “UDID”); and
Mobile application identification and behavior, use, and aggregated usage, performance data, and where the application was downloaded from.

Cookies & Technologies Used to Collect Information About You

We collect the above Information directly and through the use of third parties. We collect this Information by using certain technologies, such as cookies, web beacons, and other technologies. Third-party service providers, advertisers, and/or partners may also view, edit, or set their own cookies or place web beacons. The use of these technologies by such third parties is subject to their own privacy policies and is not covered by this Privacy Policy, except as required by law.

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. Most web browsers automatically accept cookies. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our website.
Flash Cookies. We may use local shared objects, also known as Flash cookies, to store your preferences such as volume control or display content based upon what you view on our site to personalize your visit. Third parties, with whom we partner to provide certain features or to display advertising based upon your browsing activity, use Flash cookies to collect and store information. Flash cookies are different from browser cookies because of the amount of, type of, and how data is stored. Cookie management tools provided by your browser will not remove Flash cookies.
Web Beacons. Website pages may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity). We also use these technical methods to analyze the traffic patterns, such as the frequency with which our users visit various parts of the Services. These technical methods may involve the transmission of Information either directly to us or to a third party authorized by us to collect Information on our behalf. Our Services use retargeting pixels from Google, Facebook and other ad networks. We also use web beacons in HTML emails that we send to determine whether the recipients have opened those emails and/or clicked on links in those emails.
Analytics. Analytics are tools we use, such as Google Analytics, to help provide us with information about traffic to our website and use of our Services, which Google may share with other services and websites who use the collected data to contextualize and personalize the ads of its own advertising network.
Mobile Application Technologies. If you access our website and Services through a mobile device, we may automatically collect information about your device, your phone number, and your physical location.
Third-Party Advertising Technologies. We may also allow third parties to place advertisements on our Services. By interacting with such third party advertisements or clicking on them, these third parties may collect information about your visits to this and other websites, your IP address, your internet service provider, the browser you use to visit our Services, and in some instances it may collect information available from your social media accounts and profiles, such as your name, address, email address, telephone number, contacts and activities. These third parties do this using their own cookies and other technologies. Information collected may be used, among other things, to deliver advertising targeted to your interests and to better understand the usage and visitation of our website and the other sites tracked by these third parties. The information we collect is covered by this Privacy Policy, and the information the third parties or social media platforms collect is subject to the third-party website or platform’s privacy practices. We encourage you to be aware when you leave our Services to read the privacy policies of other sites that may collect your information to learn about their use of cookies and other technology. As stated in Section V of this Privacy Policy, this Privacy Policy does not apply to, and we are not responsible for, cookies or other technologies in third-party advertisements or websites.
Behavioral Targeting/Re-Targeting/Intelligent Advertising. We partner with a third-party ad network to either display advertising on our Services or to manage our advertising on other sites. Our ad network partner uses cookies and Web beacons to collect information about your activities on this and other websites and social media platforms to provide you targeted advertising based upon your interests, available information and online activities.

Information We May Receive from Third Parties

We may collect additional Information about you from third-party websites, social media platforms, such as, but not limited, to Facebook, Twitter, Instagram, SnapChat (“Social Media Platforms”), and/or sources providing publicly-available information (e.g., from the U.S. postal service) to help us provide services to you, help prevent fraud, and for marketing and advertising purposes.

Information we may access about you, with your consent, may include, but is not limited to, your basic Social Media Platform information, your location data, your list of contacts, friends or followers and certain information about your activities on the Social Media Platform. Please keep in mind that when you provide Information to us on a third-party website or platform (for example, via our applications), the Information you provide may be separately collected by the third-party website or the Social Media Platform.

The Information we collect is covered by this Privacy Policy, and the Information the third-party website or Social Media Platform collects is subject to the third-party website or platform’s privacy practices. We encourage you to be aware when you leave our sites or applications and to read the privacy policies of other sites that may collect your Information.

HOW WE USE YOUR INFORMATION

Use and Purpose of Processing Your Information

We use and process your Information for things that may include, but are not limited to, the following:

Provide you with the Services, and related products, promotions, newsletters, contests, sweepstakes, games, and information you request;
To respond to your inquiries and provide you with requested information and other communications, including by email or text messages, and including alerts, notification of promotions, contests, and events;
For general or targeted marketing and advertising purposes, including sending you promotional material or special offers on our behalf or on behalf of our marketing partners and/or their respective affiliates and subsidiaries and other third parties, provided that you have not already opted-out of receiving such communications;
To fulfill contracts we have with you;
To manage, improve and foster relationships with third-party service providers, including vendors, suppliers, and parents, affiliates, subsidiaries, and business partners;
Maintain, improve, customize, or administer the Services, perform business analyses, or other internal purposes to improve the quality of our business, the Services, resolve technical problems, or improve security or develop other products and services;
Comply with our Terms & Conditions;
Analytics for business purposes and business intelligence;
Comply with any applicable laws and regulations and respond to lawful requests; and/or
For any other purposes disclosed to you at the time we collect your Information and/or pursuant to your consent.

Sharing Your Information

We may disclose anonymized aggregated information about our users, that does not identify any individual, without any restriction.

We may share your Information as set forth in the Privacy Policy and in the following circumstances:

Third-Party Service Providers. We may share your Information with third-party service providers that perform certain functions or services on our behalf (such as to host the Services, fulfill orders, provide products and services, manage databases, perform analyses, process credit card payments, provide customer service, or send communications for us). These third-party service providers are authorized to use your Information only as necessary to provide these services to us. In some instances, we may aggregate Information we collect so third parties do not have access to your particular Information to identify you individually.
Disclosure of Information for Legal and Administrative Reasons. We may disclose your Information without notice: (i) when required by law or to comply with a court order, subpoena, search warrant, or other legal process; (ii) to cooperate or undertake an internal or external investigation or audit; (iii) to comply with legal, regulatory or administrative requirements of governmental authorities (including, without limitation, requests from the governmental agency authorities to view your Information); (iv) to protect and defend the rights, property or safety of us, our subsidiaries and affiliates and any of their officers, directors, employees, attorneys, agents, contractors and partners, and the website Service users; (v) to enforce or apply our Terms & Conditions; and (vi) to verify the identity of the user of our Services.
Business Transfers. Your Information may be transferred, sold or otherwise conveyed (“Conveyed”) to a third party where we: (i) merge with or are acquired by another business entity; (ii) sell all or substantially all of our assets; (iii) are adjudicated bankrupt; or (iv) are liquidated or otherwise reorganize. You agree to any and all such Conveyances of your Information.
Information Shared with our Subsidiaries and Affiliates. We may share your Information with our subsidiaries and affiliates. If you do not want us to share your Information with our subsidiaries and affiliates, please email us at privacy@harborcenter.com.
Information Shared with Third-Party Advertisers. In using, clicking on, or responding to third-party advertisements on the Services, third-party advertisers may compile information about you, your browser’s or device’s visits and usage patterns on the Services, and to measure the effectiveness of their ads and to personalize the advertising content or to determine targeted demographics for advertisements. Please note that an advertiser may ask us to show an ad to a certain audience of users (e.g., based on demographics or other interests). In that situation, we will determine the target audience and will serve the advertising to that audience and only provide anonymous aggregated data to the advertiser. If you respond to such an ad, the advertiser or ad server may conclude that you fit the description of the audience they are trying to reach. This Privacy Policy does not apply to, and we cannot control the activities of, third-party advertisers. Please consult the respective privacy policies of such advertisers or contact them for more information about how they use your Information.
Products or Services Offered in Partnership with Third Party(s): Certain products and/or services available on the Services are provided to you in partnership with third party(s) and may require you to disclose Information in order to register for and access such products and/or services. Such products and/or services shall identify the third-party partners at the point of registration. If you elect to register for such products and/or services, your Information will be transferred to such third party(s) and will be subject to the privacy policy and practices of such third party(s). We are not responsible for the privacy practices and policies of such third party(s) and, therefore, you should review the privacy practices and policies of such third party(s) prior to providing your Information in connection with such products and/or services.
Online Communications (Chatrooms, Forums, Contests, Message Boards). If you correspond with us by email, questionnaires, surveys, social media, or other digital online platform, we may retain such correspondence and the Information contained in it and use it to respond to your inquiry. Our Services may include chat rooms, forums, and message boards that are available to you and other users. You are not required to provide any Information when using these areas, but you may choose to do so. If you post personal Information online, you agree you have no expectation of privacy concerning that Information, that it will be publicly available and that you may receive unsolicited messages from other parties. We cannot ensure the security of any Information you choose to make public in a chat room, forum, or message board. Also, we cannot ensure that parties who have access to such publicly available Information will respect your privacy. Please exercise caution when deciding to disclose Information in these areas. To request removal of your personal Information from our blog or community forum, contact us at privacy@harborcenter.com. In some cases, we may not be able to remove your Information, in which case we will let you know if we are unable to do so and why.
With Your Consent. We may share Information consistent with this Privacy Policy with your consent.

Except as provided in this Privacy Policy, or as otherwise required by applicable law, we will not sell, trade, or disclose your Information we have collected without your consent.

LINKS TO OTHER WEBSITES

Our Services may contain links to other websites or services that are not owned or controlled by us, including links to Social Media Platforms such as Facebook, Instagram, Twitter and SnapChat, or may redirect you off our website away from our Services to other websites for information, other services, or to receive special offers, contests, games, sweepstakes, or for transactions or purchases.

For example, if you “click” on a banner advertisement, the “click” may take you off our Services and onto a different website. This includes links from advertisers, sponsors and marketing partners that may use our website’s logo as part of a co-branding agreement. These other websites may send their own cookies to you, independently collect data or solicit personal Information and may or may not have their own published privacy policies. If you visit a website that is linked to our Services, you should consult that website’s privacy policy before providing any Information.

This Privacy Policy only applies to Information collected by our Services. We are not responsible for the privacy and security practices of those other websites or Social Media Platforms or the Information they may collect (which may include IP address). You should contact such third parties directly to determine their respective privacy policies. Links to any other websites or content do not constitute or imply an endorsement or recommendation by us of the linked website, Social Media Platform, and/or content.

INFORMATION SECURITY

We use commercially reasonable measures to provide our Services. However, you should assume that no data transmitted over the Internet or stored or maintained by us or our third-party service providers can be 100% secure. Therefore, although we believe the measures implemented by us reduce the likelihood of security problems to a level appropriate to the type of data involved, we do not promise or guarantee, and you should not expect, that your Information or private communications will always remain private or secure. We do not guarantee that your Information will not be misused by third parties. We are not responsible for the circumvention of any privacy settings or security features. You agree that we will not have any liability for misuse, access, acquisition, deletion, or disclosure of your Information.

If you believe that your Information has been accessed or acquired by an unauthorized person, you shall promptly contact us so that necessary measures can quickly be taken.

DATA RETENTION

We will retain your Information for as long as needed to provide you Services, or as permitted or required by law. If you wish to cancel your account or request that we no longer use your Information to provide you Services, please contact us at privacy@harborcenter.com. We will retain and use your Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. In accordance with our routine record keeping, we may delete certain records that contain Information you have submitted to us. We are under no obligation to store such Information indefinitely and disclaim any liability arising out of, or related to, the destruction of such Information.

HOW WE WILL CONTACT YOU

You agree that we, our affiliates, and/or third-party service providers with whom we collaborate and contract, may communicate with you regarding our Services via electronic messages, including email, text message, or mobile push notification to, for example, send you information relating to our products and Services that we think may be of interest to you, communicate with you about contests, sweepstakes, offers, promotions, rewards, upcoming events, and other news about products and services provided by or through us through permissible targeted advertisements offered by us, our parent companies, our subsidiaries, our affiliates, and other business partners. See Your Choices, below, for how you can update the way we contact you.

YOUR CHOICES

Email. By using our Services, you agree that we may contact you by email as set forth herein. If you do not want to receive marketing and promotional emails from us, you may click on the “unsubscribe” link in the email to unsubscribe and opt-out of future marketing email communications or contact us.
Mobile Push Notifications. By using our Services, you agree that we may contact you by calling or sending messages to your phone. You can use the settings on your mobile device to enable or turn off mobile push notifications from us or contact us.
Text Messages. By using our Services, you agree to be reached by text message. If you no longer want to receive text messages from us, reply STOP (or as otherwise instructed) in the text message or contact us.
Cookie Choices. To exercise choices regarding cookies set through our Services, as well as other types of online tracking and internet advertising, see our Cookies Policy for more details or contact us.
Location Choices. You can change the privacy settings of your device at any time to turn off the sharing of location information with our Services. If you choose to turn off location services, this could affect certain features or services of our Services. If you have specific questions about the privacy settings of your device, we suggest you contact the manufacturer of your device or your mobile service provider for help.
Opting Out of Direct Marketing. To exercise choices regarding the marketing information you receive, you may also review the following links:
1. You may opt-out of tracking and receiving tailored advertisements on your mobile device by some mobile advertising companies and other similar entities by downloading the App Choices app at www.aboutads.info/appchoices.
2. You may opt-out of receiving permissible targeted advertisements by using the NAI Opt-out tool available at http://optout.networkadvertising.org/?c=1 or visiting About Ads at http://optout.aboutads.info.
3. You can opt-out of having your activity on our Services made available to Google Analytics by installing the Google Analytics opt-out add-on for your web browser by visiting: https://tools.google.com/dlpage/gaoptout for your web browser.
Notice to Certain Residents. In addition to the above methods of exercising choice, to the extent required by applicable law or as otherwise noted in the Notices to Certain Residents, Section IX below, we may provide you with additional choices regarding the processing of your Information, which you may exercise by contacting us as detailed in the “How to Contact Us” section below. We will try to comply with your request as soon as reasonably practicable as required by applicable law.

ACCESSING, CORRECTING, OR DELETING YOUR INFORMATION

Upon request as set forth below and subject to certain exceptions and limitations and applicable laws, we will inform you of the existence, use and disclosure of your Information and will provide you access to that Information. To the extent other state laws provide users with additional data subject rights, those rights may be honored by the company following proper authentication and verification.

We encourage you to review, update, and correct Information that we maintain about you, and you may request that we delete Information about you that is inaccurate, incomplete, or irrelevant. We may not accommodate a request to change Information if we believe the change would violate applicable law in our control.

To access, correct, or delete your Information, contact us at:

Email: privacy@harborcenter.com

Call: +1 716-855-4767

Write us: 100 Washington St.

Buffalo, NY 14203.

NOTICE TO CERTAIN RESIDENTS

Persons in the European Union or European Economic Area
1. Your Rights

To the extent any European data protection laws apply, and we hold any of your “personal data” as defined in such laws (which may include some or all of your Information as defined in this Privacy Policy), and we hold such personal data in our capacity as a data controller as defined under those laws, you may request that we:

Restrict the way that we process and share your personal data;
Transfer your personal data to a third party;
Revoke your consent for processing of your personal data;
Provide you with access to your personal data;
Remove your personal data if no longer necessary for the purposes collected;
Update your personal data so it is correct and not out of date; and/or
Object to our processing of your personal data.

If you wish to object to the use and processing of your personal data or withdraw consent to this Privacy Policy, you can contact us in the following ways:

Email of Chief Privacy Officer at: privacy@harborcenter.com

Mail: 100 Washington St., Buffalo, NY 14203

Call us toll free at: +1 716-855-4767

The requests above will be considered and responded to in the time-period stated by applicable law. Note, certain Information may be exempt from such requests. We may require additional information from you to confirm your identity in responding to such requests. You have the right to lodge a complaint with the supervisory authorities applicable to you and your situation, although we invite you to contact us with any concern as we would be happy to try and resolve it directly. Please contact us at: privacy@harborcenter.com, write us at 100 Washington St., Buffalo, NY 14203, or call us at +1 716-855-4767.

Lawful Basis for Processing Your Information

As described throughout this Privacy Policy, we believe the foregoing handling of your Information, which may include your personal data, furthers our legitimate interests in commercial activities that are not overridden by the interest or fundamental rights and freedoms of the individuals at issue. Depending on what personal data we collect from you and how we collect it, we rely on various grounds for processing your personal data, including the following reasons:

To administer our contractual relationship, including setting up any services you may request;
Because it is in our legitimate interest to effectively and efficiently operate our business and provide you with the services offered through the Services and other useful content and for other marketing, design, and advertising purposes;
To process employee data, prevent against fraud, provide technology security, and other necessary Company operational matters;
In order to fulfill any legal obligations, we may have to collect this Information from you; and/or
Because you have provided your consent for us to do so.

Consent to Transfer

Our Services are operated in the United States. Please be aware that Information, including personal data, that we collect will be transferred to, stored, and processed in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen. We collect and transfer to the U.S. only Information, including personal data: with your consent; to perform a contract with you; or to fulfill a compelling legitimate interest of HCD in a manner that does not outweigh your rights and freedoms. We endeavor to apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with us and the practices described in this Privacy Policy. We also enter into data processing agreements and model clauses with vendors whenever feasible and appropriate.

California Residents

To the extent any California data privacy law applies, we will provide California residents with certain information upon request (“Data Subject Request”). This Privacy Policy outlines how California residents can receive the information and what you can receive.

If you would like to submit a Data Subject Request, please email us at privacy@harborcenter.com. You can also call us, toll-free, at +1 716-855-4767. If you choose to submit a Data Subject Request, you must provide us with enough information to identify you and enough specificity on the requested data. We will only use the information we receive for verification. We will not be able to disclose information if it cannot verify that the person making the Data Subject Request is the person about whom we collected Information, or someone authorized to act on such person’s behalf.

If you are a California resident, you may submit a Data Subject Request to receive information about our data collection practices as it relates to your data. You may request information on the categories of personal information (as defined by California law) we have collected about you; the categories of data collection sources; any business or commercial purpose for collecting or selling personal information; the categories of third parties with whom we share personal information, if any; and the specific pieces of personal information we have collected about you. If you would like to also receive information about our data disclosure for business purposes, then please include that in the Data Subject Request. We will clarify whether the Information was collected and disclosed or simply collected and kept internally.

Please note that the categories of personal information and sources will not exceed what is contained in this Privacy Policy. Additionally, we are not required to retain any information about you if it is only used for a one-time transaction and would not be maintained in the ordinary course of business. We are also not required to reidentify personal information if it is not stored in that manner already, nor is it required to provide the personal information to you more than twice in a twelve-month period.

You may request that we delete your personal information. Your deletion request should be submitted through a Data Subject Request. Subject to certain exceptions set out below we will, on receipt of a verifiable Data Subject Request, delete your personal information from our records and direct any service providers to do the same.

Please note that we may not delete your personal information if it is necessary to:

complete the transaction for which the personal information was collected;
provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
detect security incidents, protect against malicious, deceptive activity, and take all necessary and appropriate steps to mitigate current and future risk;
debug and repair internal information technology as necessary;
undertake internal research for technological development and demonstration;
exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
comply with the California Electronic Communications Privacy Act;
engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the Information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
comply with an existing legal obligation; or
otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the Information.

We may not, and will not, treat you differently because of your Data Subject Request activity. As a result of your Data Subject Request activity, we may not and will not deny goods or services to you, charge different rates for goods or services, provide a different level quality of goods or services, or suggest any of the preceding will occur. However, we can and may charge you a different rate, or provide a different level of quality, if the difference is reasonably related to the value provided by your personal information.

In addition, if you are a California resident under the age of 18 and are a registered user, you may request us to remove content or information posted on our websites or stored on our servers by (a) submitting a request in writing to privacy@harborcenter.com and (b) clearly identifying the content or information you wish to have removed and providing sufficient information to allow us to locate the content or Information to be removed. However, please note that we are not required to erase or otherwise eliminate content or Information if (i) other state or federal laws require us or a third party to maintain the content or Information; (ii) the content or Information was posted, stored, or republished by another user; (iii) the content or Information is anonymized so that the minor cannot be individually identified; (iv) the minor does not follow the instructions posted in this Policy on how to request removal of such content or Information; and (v) the minor has received compensation or other consideration for providing the content. Further, nothing in this provision shall be construed to limit the authority of a law enforcement agency to obtain such content or Information.

CHILDREN’S INFORMATION

Our Services are intended for general audiences. We do not knowingly collect, use, or disclose Information from children under the age of thirteen (13) or as otherwise defined by local law without prior parental consent, except as permitted by the Children’s Online Privacy Protection Act (hereinafter “COPPA”) or other applicable law.

Some of our Services, such as online contests, sweepstakes, and promotions we may run from time to time, may seek information necessary for a child to participate, including the child’s name, date of birth and parent’s email address and contact information to communicate with the parent (as required by applicable law). For these services, children will be required to provide proof of consent from their parent or legal guardian in order to participate. Children are not permitted to provide Information to us through any of our Services or to share their Information with us absent the consent of their parent or legal guardian. We will not use parent emails provided for parental consent purposes to market to the parent, unless the parent has expressly opted-in to email marketing or has separately participated in an activity that allows for such email contact.

If, at any time, a parent or legal guardian becomes aware that their child has provided us with Information without their consent or wishes to withdraw their consent to our use or maintenance of Information collected from their child, the parent or guardian should contact us at privacy@harborcenter.com and we will promptly remove such Information from our database(s). Please note that we may request proof of identity and relationship to the child before doing so.

If you have any comments or questions on policies related to children’s data or about our commitment to protecting your and your children’s privacy, please contact us at privacy@harborcenter.com or by mail at the address below.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to change, modify or amend this Privacy Policy at any time to reflect changes in our products and service offerings, accommodate new technologies, regulatory requirements or other purposes. If we modify our Privacy Policy, we will update the “Effective Date” and such changes will be effective upon posting. It is your obligation to check our current Privacy Policy for any changes.

HOW TO CONTACT US

If you have any questions about this Privacy Policy or the Information we have collected about you, please contact us at the following:

Email: privacy@harborcenter.com

Call us: +1 716-855-4767

Write us: 100 Washington St.

Buffalo, NY 14203.

Last Updated: December 15, 2019