[ Harkin policies ]
Harkin Privacy Policy
Last Updated: [DATE]
Harkin exists to help families preserve the stories that matter to them. We understand that those stories can be deeply personal.
This Privacy Policy explains how Harkin ("Harkin," "we," "us," or "our") collects, uses, shares, stores, and protects personal information when you visit our website, purchase or receive a Harkin experience, participate in conversations with Harkin, or otherwise use our products and services (collectively, the "Services").
By using the Services, you acknowledge the practices described in this Privacy Policy.
1. Who This Policy Applies To
A Harkin experience may involve several different people.
The Purchaser is the person who purchases a Harkin experience.
The Storyteller is the person whose conversations, memories, photographs, documents, and other materials are used to create their story.
The Purchaser and Storyteller may be the same person.
Other family members or individuals may also interact with Harkin or provide materials.
A Website Visitor is anyone who uses giveharkin.com without purchasing, including someone who tries a short sample conversation with Eleanor on our website. A Website Visitor is not a Storyteller and does not have a Harkin account.
This Privacy Policy applies to personal information we collect from or about each of these individuals through the Services.
2. Information We Collect
The information we collect depends on how you interact with Harkin.
Information You Provide to Us
We may collect information such as:
- name;
- email address;
- telephone number;
- billing and shipping information;
- gift recipient information;
- account or profile information;
- communications with Harkin;
- customer support requests;
- survey responses and feedback; and
- other information you choose to provide.
Storytelling Content
When a Storyteller participates in Harkin, we may collect and process information provided as part of their storytelling experience, including:
- transcripts of conversations;
- written responses;
- memories and personal stories;
- names and information about family members and other people;
- dates, locations, relationships, and life events;
- photographs;
- documents;
- correspondence;
- captions and annotations;
- corrections and editorial feedback; and
- other materials submitted for inclusion in or development of the Storyteller's story.
Because life stories are personal, this content may sometimes include sensitive information that a Storyteller voluntarily chooses to discuss.
Storytellers control what they choose to share during their Harkin experience and may decline to answer a question or stop a conversation at any time.
Voice Conversations and Transcripts
Harkin allows Storytellers to tell their stories through spoken conversation.
Audio from these conversations is processed to create written transcripts. Harkin does not retain audio recordings of Storyteller conversations. The resulting transcripts are retained and used as part of the Storyteller's Harkin experience.
These transcripts may contain personal and sensitive information shared by the Storyteller during their conversations.
Storytellers control what they choose to share during their Harkin experience and may decline to answer a question or stop a conversation at any time.
Payment Information
Payments may be processed through third-party payment providers such as Stripe.
Harkin may receive information about a transaction, such as the amount paid, transaction status, billing contact information, and limited payment details. We generally do not receive or store complete payment card numbers when payment information is processed directly by our payment provider.
Information Collected Automatically
When you visit our website or use our digital Services, we may automatically collect certain technical information, such as:
- IP address;
- browser and device type;
- operating system;
- pages viewed;
- referring pages;
- approximate location derived from IP address;
- dates and times of visits;
- interactions with our website; and
- cookie or similar technology identifiers.
We may use cookies and similar technologies to operate our website, understand how it is used, remember preferences, measure performance, and, where permitted, support marketing activities.
3. How We Use Personal Information
We may use personal information to:
- provide and operate the Harkin experience;
- conduct and manage Storyteller conversations;
- transcribe spoken conversations;
- organize memories and storytelling material;
- create, edit, format, and develop stories;
- prepare and produce physical books and related products;
- communicate with Purchasers and Storytellers;
- process purchases, refunds, and transfers;
- provide customer support;
- develop, train, evaluate, and improve Harkin's models and Services;
- maintain the reliability, security, and integrity of Harkin;
- detect fraud, abuse, and security threats;
- understand how our website and Services are used;
- comply with legal obligations;
- enforce our Terms of Service; and
- send marketing communications where permitted by law.
4. Voice Conversations and Transcription
Conversation is central to the Harkin experience.
When a Storyteller speaks with Harkin, audio is processed to convert the conversation into text. Harkin does not retain the audio recording after it is processed into a transcript.
Harkin retains the resulting transcript and uses it to provide the Harkin experience, including understanding the Storyteller's memories, maintaining continuity across conversations, developing their story, and preparing written material.
A Storyteller may decline to answer any question or stop a conversation at any time.
Trying Eleanor on Our Website
Our website offers a short sample conversation with Eleanor so that a visitor can hear what the experience is like before deciding whether to buy. It is brief and ends on its own after a few exchanges. No account is created and no purchase is required.
While it runs, what a visitor says is sent to Harkin's servers, converted into text, and used to generate Eleanor's reply. This uses the same categories of service provider described in Section 6, including speech-to-text and artificial intelligence providers.
Harkin does not retain the audio, and does not retain a transcript of the sample conversation. What a visitor says during the sample is not added to any Harkin story, is not associated with any account, and is not used to develop, train, evaluate, test, or improve Harkin's models, notwithstanding Section 5.
To keep the sample available and to prevent abuse, Harkin retains a small amount of technical information about it, such as the number of sample conversations started and a one-way, irreversible value derived from the visitor's IP address. Harkin does not retain the IP address itself, and this information does not include anything the visitor said.
Because a sample conversation is processed by service providers as described above, please do not share anything during it that you would not want processed in that way. It is a demonstration, not a private record, and nothing said during it is preserved.
5. Artificial Intelligence and Model Training
Artificial intelligence is an important part of how Harkin provides and improves the Harkin experience.
Harkin may use artificial intelligence and other automated technologies to assist with activities such as:
- conducting or supporting conversations;
- speech-to-text transcription;
- organizing information;
- identifying themes and relationships between stories;
- summarization;
- drafting and story development;
- editing;
- formatting;
- evaluating the quality and performance of Harkin; and
- developing, training, testing, and improving Harkin's models and Services.
Storytelling Content, including transcripts and other materials provided through the Harkin experience, may be used to develop, train, evaluate, test, and improve Harkin's artificial intelligence systems, models, and Services.
Harkin may also use third-party technology and artificial intelligence providers to help provide these functions. Information may therefore be processed by approved service providers acting on Harkin's behalf.
[BEFORE PUBLICATION: Confirm whether any third-party AI provider is permitted to use Harkin Storytelling Content to train its own general-purpose models. Harkin's own use of Storytelling Content for training and improvement is distinct from allowing an outside provider to independently train its models on that content.]
6. How We Share Personal Information
We may share personal information with service providers that help us operate Harkin, such as providers of:
- cloud hosting and data storage;
- artificial intelligence and language technology;
- speech-to-text processing;
- payment processing;
- email and communications;
- customer support;
- analytics;
- security;
- book design, printing, production, and fulfillment; and
- other technology or professional services.
These providers may access information as necessary to perform services for Harkin, subject to applicable contractual and legal requirements.
We may also disclose information:
- when you direct or authorize us to do so;
- to comply with applicable law, legal process, or valid governmental requests;
- to protect the rights, safety, security, or property of Harkin, our users, or others;
- in connection with investigating fraud, abuse, or security incidents; or
- as part of a merger, acquisition, financing, reorganization, sale of assets, or similar business transaction, subject to applicable law.
7. Public Use of Your Story
Harkin's use of Storytelling Content to operate, develop, train, evaluate, and improve its technology does not give Harkin permission to publicly identify or feature a Storyteller or their family for marketing purposes.
Harkin will not publicly publish a Storyteller's private story, photographs, transcripts, or other private Storytelling Content in advertising, social media, testimonials, promotional materials, or public examples without appropriate permission.
If we would like to feature a Harkin family or Storyteller publicly, we will request separate permission.
8. Information About Other People
Life stories naturally involve other people.
A Storyteller may discuss family members, friends, colleagues, and other individuals during their Harkin experience.
Purchasers and Storytellers should use care when providing sensitive information about other people and should only provide photographs, documents, correspondence, or other materials they have the right or appropriate permission to provide.
If you believe information about you has been included in Harkin without appropriate authorization and would like to contact us about it, please use the contact information at the end of this Policy.
9. Storyteller Privacy and Purchaser Access
A Harkin story belongs to the Storyteller. Purchasing a Harkin experience for someone else does not give the Purchaser access to that person's private conversations, transcripts, drafts, photographs, documents, or other Storytelling Content.
The Purchaser may receive limited, high-level information about the progress of the experience, such as whether the Storyteller has begun their experience or general progress toward completion.
The Purchaser will not receive access to the substance of the Storyteller's conversations or story through these progress updates.
The Storyteller controls their participation in Harkin and the information they choose to share.
The eventual sharing and delivery of a completed story or book will occur according to the Harkin experience and the Storyteller's applicable choices and permissions.
10. Data Retention
We retain personal information for as long as reasonably necessary to provide the Services, maintain appropriate business and legal records, comply with legal obligations, resolve disputes, enforce agreements, develop and improve Harkin as described in this Policy, and protect the security and integrity of our Services.
Different types of information may be retained for different periods.
Harkin does not retain the audio recordings used to generate Storyteller conversation transcripts. The resulting transcripts and other Storytelling Content may be retained as part of the Storyteller's Harkin experience and in accordance with Harkin's applicable retention practices.
Harkin does not retain the audio or the transcript of a sample conversation with Eleanor on our website, as described in Section 4. Only limited technical information about the sample is retained, and it does not include anything the visitor said.
When information is no longer required, we may delete, de-identify, or otherwise dispose of it in accordance with our policies and applicable law.
[BEFORE PUBLICATION: Establish specific retention and deletion rules for transcripts, completed stories, uploaded photographs and documents, account information, backups, model-training datasets, and finished book files.]
11. Data Security
We use reasonable administrative, technical, and organizational measures designed to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure.
However, no method of transmitting or storing information can be guaranteed to be completely secure.
If we become aware of a security incident involving personal information, we will take appropriate steps consistent with applicable law.
12. Your Privacy Choices and Rights
Depending on where you live, you may have rights regarding your personal information, which may include the right to:
- request access to personal information we hold about you;
- request correction of inaccurate information;
- request deletion of certain information;
- obtain a copy of certain information;
- object to or restrict certain processing;
- withdraw consent where processing is based on consent; and
- appeal certain decisions concerning a privacy request.
These rights may be subject to exceptions and limitations under applicable law.
To submit a privacy request, contact us using the information below.
We may need to verify your identity before completing a request.
[ATTORNEY REVIEW: Because Harkin may use Storytelling Content for model training, establish how deletion requests apply to source transcripts, training datasets, model outputs, and models that have already been trained.]
13. California Privacy Rights
California residents may have additional rights under California privacy law, depending on Harkin's activities and whether applicable statutory thresholds are met.
These rights may include rights to know about personal information collected, used, or disclosed; request deletion or correction; and receive equal service and pricing when exercising applicable privacy rights.
[ATTORNEY REVIEW: Determine which California privacy statutes and disclosure requirements apply to Harkin at launch, including requirements related to sensitive personal information and Harkin's use of personal information for artificial intelligence development and training.]
14. Cookies and Analytics
Harkin may use cookies and similar technologies necessary to operate the website and, where appropriate, to understand website usage, measure performance, and support marketing.
You may be able to control certain cookies through your browser or through privacy controls Harkin provides.
[BEFORE PUBLICATION: Update this section once Harkin's actual analytics, advertising pixels, consent-management tools, and cookie practices are finalized.]
15. Marketing Communications
If you receive marketing emails from Harkin, you may unsubscribe using the link provided in those messages.
Even if you opt out of marketing communications, we may continue sending transactional or service-related communications necessary to administer your purchase or Harkin experience.
16. Children's Privacy
Harkin's Services are not intended for independent use by children under 13.
We do not knowingly collect personal information directly from children under 13 through the Services without appropriate parental consent or another lawful basis.
Storytellers may naturally discuss their childhoods and family members, including children, as part of their life stories.
[ATTORNEY REVIEW: Confirm the intended minimum age for Storytellers and whether Harkin will permit minors to participate with parental or guardian consent.]
17. International Users
Harkin is based in the United States.
If you access Harkin from outside the United States, your information may be transferred to, stored in, or processed in the United States or other countries where Harkin's service providers operate.
Those countries may have data protection laws that differ from the laws where you live.
[BEFORE INTERNATIONAL LAUNCH: Obtain counsel regarding additional requirements for users in jurisdictions such as the European Economic Area, United Kingdom, and other regions with comprehensive privacy laws.]
18. Business Transfers
If Harkin is involved in a merger, acquisition, financing, restructuring, bankruptcy, sale of assets, or similar transaction, personal information may be transferred as part of that transaction.
Any successor's handling of personal information will remain subject to applicable law and any commitments that continue to apply under this Privacy Policy.
19. Changes to This Privacy Policy
We may update this Privacy Policy as Harkin and our Services evolve.
When we make changes, we will update the "Last Updated" date above. If changes are material, we may provide additional notice as required by applicable law.
20. Contact Us
If you have questions about this Privacy Policy, Harkin's privacy practices, or would like to exercise a privacy right, contact:
Harkin [LEGAL ENTITY NAME] [MAILING ADDRESS] [PRIVACY EMAIL]