HARLO SurveySuite

Privacy Policy

 

Effective Date: March 16, 2026

HARLO Industries LLC  |  www.harlo.industries

 

Your privacy matters to us. This Privacy Policy explains what information HARLO Industries LLC collects when you use HARLO SurveySuite, how we use it, who we share it with, and what rights you have with respect to your personal data. We've written this document to be straightforward and readable — not buried in legalese.

By using HARLO SurveySuite, you agree to the collection and use of your information as described in this policy. If you do not agree, please do not use the application.

1. Who We Are

HARLO Industries LLC is the developer and operator of HARLO SurveySuite. We are a veteran-owned Service-Disabled Veteran-Owned Small Business (SDVOSB) registered in California. For the purposes of this Privacy Policy, HARLO Industries LLC is the "data controller" — meaning we determine how and why your personal data is processed.

Our principal place of business is located at 2108 N St, Sacramento, CA 95816. You can reach our privacy team at privacy@harlo.industries.

2. Information We Collect

We collect information in three ways: information you give us directly, information we collect automatically when you use the app, and information we receive from third parties.

 

2.1  Information You Provide Directly

Category of Data

Examples

How We Use It

Account information

Name, email address, password (hashed), account type (Student / Technician / Professional)

Creating and managing your account; communicating with you

Subscription and payment

Plan selection, billing period; payment data processed by Stripe or app store

Processing your subscription; fraud prevention

Profile information

Professional role, organization, state of licensure (optional)

Personalizing your experience; relevant content delivery

Support communications

Messages and attachments you send to our support team

Resolving your support requests; improving the Service

User feedback

Bug reports, feature suggestions, survey responses

Improving the application and content

Calculation inputs

Coordinate data, traverse data, and other values you enter into calculation tools

Performing calculations; displaying results; (see Section 2.3 re: storage)

 

2.2  Information Collected Automatically

Category of Data

Examples

How We Use It

Usage data

Features accessed, screens viewed, session duration, button interactions

Understanding how users engage with the app; improving UX

Device information

Device type, operating system version, app version, unique device identifiers

Technical support; ensuring compatibility; security

Performance data

Crash reports, error logs, performance metrics

Identifying and fixing technical issues

IP address and network

Internet Protocol address, connection type

Security monitoring; approximate geographic region for compliance

App store data

Installation source, update history

Measuring distribution and platform performance

 

2.3  Calculation Data — A Specific Note

When you use the COGO calculators, traverse tools, and other computation features, the coordinates, angles, distances, and other values you enter are processed locally on your device to produce results. We may collect anonymized, aggregated usage statistics about which calculation tools are used most frequently, but we do not systematically collect, store, or transmit the specific field data or project coordinates you enter into calculation tools, except where you explicitly choose to save a project within the application.

If you use the Projects feature to save work, that saved project data is stored in our secure cloud infrastructure and associated with your account. You can delete saved projects at any time from within the application.

 

2.4  AI COGO Assistant Interactions

When you interact with the AI COGO Assistant, your input prompts and the generated responses are transmitted to our AI service provider (Anthropic) for processing. These interactions may be used to improve the AI model in accordance with Anthropic's data use policies. We do not store the content of your AI COGO Assistant conversations beyond the active session unless you explicitly save them. We encourage you not to enter sensitive personally identifiable information or confidential project data into the AI assistant.

 

2.5  Information from Third Parties

We may receive information about you from the following third-party sources:

         Apple App Store / Google Play Store: subscription status, purchase history, and device identifiers necessary to validate your subscription;

         Stripe: payment confirmation, subscription status, and fraud signals (we do not receive or store your full payment card number);

         Analytics providers: aggregated usage statistics to help us understand application performance.

3. How We Use Your Information

We use the information we collect for the following purposes, each grounded in a legitimate basis for processing:

 

Purpose

What We Use

Legal Basis

Providing and maintaining the Service

Account data, subscription data, usage data

Contract performance

Processing payments and managing subscriptions

Email, subscription data, Stripe payment signals

Contract performance

Personalizing your experience

Profile information, usage patterns, plan type

Legitimate interest / Consent

Communicating with you about the Service

Email address, in-app messaging

Contract performance / Legitimate interest

Sending product updates and announcements

Email address

Consent (opt-out available)

Improving the application and content

Usage data, feedback, performance data

Legitimate interest

Ensuring security and preventing fraud

Account data, IP address, device identifiers

Legitimate interest / Legal obligation

Complying with legal obligations

Any applicable data as required

Legal obligation

Enforcing our Terms of Service

Account data, usage data

Legitimate interest / Contract performance

4. How We Share Your Information

We do not sell your personal information. We do not share your data with advertisers. We share your information only in the limited circumstances described below.

 

4.1  Service Providers

We share information with trusted third-party companies who help us operate the Service. These providers are contractually required to use your information only to perform services on our behalf and may not use it for their own purposes. Our current service providers include:

         Stripe: payment processing and subscription management;

         Anthropic: AI language model inference for the AI COGO Assistant;

         Apple / Google: app distribution, in-app purchase processing, and crash reporting;

         Cloud hosting providers: secure data storage and server infrastructure;

         Analytics providers: usage analytics to improve application performance.

 

4.2  Business Transfers

If HARLO Industries LLC is involved in a merger, acquisition, asset sale, or bankruptcy proceeding, your information may be transferred as part of that transaction. We will notify you by email or by a prominent notice within the application before your personal data is transferred and becomes subject to a materially different privacy policy.

4.3  Legal Requirements

We may disclose your information if we believe in good faith that such disclosure is necessary to: comply with a legal obligation, court order, or valid governmental request; protect the rights, property, or safety of HARLO, our users, or the public; investigate potential violations of our Terms of Service; or respond to an emergency involving risk of harm.

4.4  With Your Consent

We will share your information in any other circumstances only with your explicit consent.

4.5  Aggregated and De-Identified Data

We may share aggregated or de-identified information — information that cannot reasonably be used to identify any individual — for research, analytics, marketing, or other purposes. This information is not subject to the restrictions in this Privacy Policy.

5. Data Retention

We retain your personal information for as long as your account remains active or as needed to provide the Service. We also retain information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Specifically:

         Account information is retained for the duration of your account and for up to 3 years following account closure to meet legal and compliance obligations;

         Subscription and payment records are retained for 7 years to comply with financial recordkeeping requirements;

         Support communications are retained for 2 years following resolution of the relevant inquiry;

         Usage and analytics data is retained for up to 2 years in identifiable form, and may be retained indefinitely in anonymized or aggregated form;

         Saved project data is retained until you delete it or close your account.

 

You may request deletion of your account and associated data at any time by contacting us at privacy@harlo.industries. We will process deletion requests within 30 days, subject to our legal retention obligations.

6. Data Security

We take the security of your personal information seriously. We implement and maintain reasonable technical and organizational safeguards designed to protect your data against unauthorized access, disclosure, alteration, and destruction. These measures include:

         Encryption of data in transit using industry-standard TLS protocols;

         Encryption of sensitive data at rest within our infrastructure;

         Access controls limiting employee access to personal data on a need-to-know basis;

         Regular security reviews of our application and infrastructure;

         Third-party service providers contractually required to maintain equivalent security standards.

 

No method of data transmission or storage is 100% secure. While we strive to protect your personal information using commercially reasonable means, we cannot guarantee absolute security. If you have reason to believe that your account has been compromised, please contact us immediately at privacy@harlo.industries.

In the event of a data breach that affects your rights and freedoms, we will notify you in accordance with applicable law, including the California Consumer Privacy Act where applicable.

7. Your Privacy Rights

Depending on where you live, you may have certain rights regarding your personal information. We respect these rights regardless of your location.

 

7.1  Rights for California Residents (CCPA / CPRA)

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

         Right to Know: You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you, the sources from which we collected it, the business or commercial purposes for collecting it, and the categories of third parties with whom we share it.

         Right to Delete: You have the right to request that we delete personal information we have collected from you, subject to certain exceptions.

         Right to Correct: You have the right to request that we correct inaccurate personal information we maintain about you.

         Right to Opt Out of Sale: We do not sell personal information. This right is therefore not applicable, but we will never sell your data.

         Right to Limit Use of Sensitive Personal Information: You have the right to limit our use of sensitive personal information to what is necessary to provide the Service.

         Right to Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights. Exercising your rights will not affect the quality or price of services we provide to you.

 

To exercise any of these rights, submit a verifiable consumer request to privacy@harlo.industries. We will respond within 45 days of receipt. We may need to verify your identity before processing your request.

7.2  Rights for All Users

Regardless of where you live, we extend the following rights to all HARLO SurveySuite users:

         Access: You can request a copy of the personal information we hold about you.

         Correction: You can update most account information directly within the application. For information you cannot update yourself, contact us.

         Deletion: You can request deletion of your account and personal data as described in Section 5.

         Data Portability: You can request an export of your account data and saved projects in a machine-readable format.

         Withdrawal of Consent: Where we process your data based on consent (such as marketing emails), you can withdraw that consent at any time without affecting the lawfulness of prior processing.

         Objection: You can object to processing based on legitimate interests. We will honor your objection unless we have compelling grounds that override your interests.

 

To exercise any of these rights, contact us at privacy@harlo.industries. We will respond within 30 days. We will not charge you for making a rights request, though we may charge a reasonable administrative fee for manifestly unfounded or excessive requests.

8. Children's Privacy

HARLO SurveySuite is not directed to children under the age of 13. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and you believe your child under the age of 13 has provided personal information to us without your consent, please contact us at privacy@harlo.industries and we will promptly delete that information.

Users between the ages of 13 and 18 should review these terms with a parent or guardian. We do not knowingly use data from users under 18 for any commercial profiling or targeted advertising purposes.

9. Third-Party Services and Links

HARLO SurveySuite integrates with or links to third-party services whose privacy practices are outside our control. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing any information:

 

Service

Purpose

Privacy Policy

Apple App Store

App distribution, in-app purchases, crash reporting

apple.com/legal/privacy

Google Play

App distribution, in-app purchases

policies.google.com/privacy

Stripe

Payment processing

stripe.com/privacy

Anthropic

AI COGO Assistant inference

anthropic.com/privacy

 

We do not display advertisements in HARLO SurveySuite and do not share your data with advertising networks.

10. International Users

HARLO SurveySuite is operated from the United States. If you are accessing the Service from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your country of residence.

By using the Service, you consent to the transfer of your information to the United States. We will take appropriate steps to ensure that any transfer of personal data complies with applicable laws and that your information receives adequate protection.

11. Push Notifications

HARLO SurveySuite may request permission to send push notifications to your device. We use push notifications to send:

         Study reminders and exam preparation alerts;

         Account and subscription notifications (such as renewal reminders or payment issues);

         Important application updates or service notices.

 

You can manage push notification permissions at any time through your device's Settings application. Disabling push notifications will not affect your ability to use the core features of the application.

12. Cookies and Tracking Technologies

The HARLO SurveySuite mobile application does not use browser cookies. However, we and our service providers may use similar technologies such as device identifiers, mobile analytics SDKs, and local storage within the application for authentication, performance monitoring, and usage analytics.

These technologies are necessary to operate the Service and cannot be disabled without impairing application functionality. Aggregate analytics data may be used to improve the application. We do not use these technologies for cross-app behavioral advertising or to build personal profiles for commercial sale.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will:

         Update the "Effective Date" at the top of this document;

         Send an email notification to the address associated with your account for significant changes;

         Display a prominent notice within the application.

 

We encourage you to review this Privacy Policy periodically. Your continued use of HARLO SurveySuite after an updated Privacy Policy takes effect constitutes your acceptance of the changes. If you do not agree to the updated policy, please stop using the Service and contact us to request account deletion.

14. Data Protection Officer and Contact

We have designated a point of contact for all privacy-related inquiries. If you have questions about this Privacy Policy, wish to exercise your rights, or have concerns about how we handle your personal data, please contact us through any of the following:

 

Privacy inquiries

privacy@harlo.industries

General support

support@harlo.industries

Mailing address

HARLO Industries LLC

2108 N St, Sacramento, CA 95816

Website

www.harlo.industries

Response time

We will respond to privacy inquiries within 30 days. California residents exercising CCPA rights will receive a response within 45 days.

 

We take your privacy seriously. If you ever feel we are not living up to this policy, we want to hear about it — please reach out directly to privacy@harlo.industries.

 

© 2026 HARLO Industries LLC. All rights reserved.