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Privacy Policy

Effective date: October 20th, 2026

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1. Who we are and what this policy covers

Harbinger SCR is a management consulting firm based in Ontario, Canada. This Privacy Policy explains how we collect, use, disclose and protect personal information when you visit www.harbinger-scr.com (the "Website"), contact us, subscribe to our communications, or otherwise interact with us online.

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We handle personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA), Canada's Anti-Spam Legislation (CASL), and, where they apply, provincial privacy laws such as Quebec's Act respecting the protection of personal information in the private sector (as amended by Law 25).

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"Personal information" means any information about an identifiable individual, such as your name, email address or IP address. Business contact information used only to communicate with you about your employment or profession is not covered by PIPEDA, but we protect it with the same care.

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This policy does not cover personal information we process on behalf of clients during consulting engagements. That information is governed by our client agreements.

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Accountability

We have designated a Privacy Officer who is responsible for our compliance with this policy and with applicable privacy laws. Their contact details are in Section 12.

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2. Information we collect

We collect only the personal information we need for the purposes described in this policy.

Category

Examples

How we collect it

Contact details

Name, email address, phone number, company, job title

You provide it through our contact form, newsletter sign-up, event or webinar registration, or by emailing us

Inquiry content

The message you send us and any details about your project or organization

You provide it when you contact us

Communication preferences

Your subscription status and consent records

You provide it when you subscribe or unsubscribe

Technical information

IP address, browser type, device type, operating system, referring page

Collected automatically by our website platform and cookies

Usage information

Pages viewed, time on page, links clicked, approximate location (city or region)

Collected automatically through cookies and analytics tools, where you have consented

Job applications

Résumé, cover letter, work history

You provide it if you apply for a role through the Website

 

We do not knowingly collect personal information from anyone under 16. We do not ask for sensitive information, such as health or financial details, through the Website. Please do not include it in messages you send us.

We may also receive information about you from third parties, such as LinkedIn[RM2]  or event partners, when you have agreed to share it with us.

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3. Why we use your information

We use personal information to:

  1. Respond to your inquiries and requests for proposals.

  2. Provide and follow up on our change management, training, communications and AI governance services.

  3. Send newsletters, insights and event invitations, if you have consented.

  4. Register you for and run webinars and events.

  5. Review job applications.

  6. Operate, secure and improve the Website, including understanding how visitors use it.

  7. Meet our legal, regulatory and record-keeping obligations.

We will not use your information for a new purpose without first telling you and, where required, asking for your consent.

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4. Consent

We rely on your consent to collect, use and disclose personal information, except where the law permits otherwise.

  • Express consent is obtained when you submit a form, tick a box or toggle to subscribe, or accept non-essential cookies in our cookie banner.

  • Implied consent may apply where the purpose is obvious from the context, such as using your email address to reply to a message you sent us.

You can withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. See Section 10.

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5. How we share your information

We do not sell or rent your personal information. We share it only as follows:

  • Service providers who help us run our business, under contracts that require them to protect it and use it only for our purposes. These include:

    • Wix.com — our website hosting, forms and site analytics platform. Wix stores data on secure servers behind a firewall.

    • [Email marketing provider, e.g. Wix Email Marketing[RM3]  or Mailchimp]

    • Google Analytics, Bing Webmaster Tools[RM4] 

    • [CRM or scheduling tools, e.g. HubSpot, Microsoft 365[RM5] , Calendly]

  • Professional advisers, such as lawyers and accountants, where needed.

  • Legal requirements — when required by law, court order or a lawful request from a government authority.

  • Business transactions — if we are involved in a merger, acquisition or sale of assets, subject to confidentiality protections.

 

Storage and transfers outside Canada

Our Website is hosted by Wix.com, and some of our service providers store data outside Canada, including in the United States, Israel and the European Union. When your information is held in another country, it is subject to that country's laws and may be accessed by its courts, law enforcement and national security authorities. We assess these providers and use contractual safeguards to protect your information.

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6. Email and electronic communications

We send commercial electronic messages, such as newsletters and event invitations, only with your consent, as required by CASL. Every message identifies Harbinger SCR, includes our mailing address, and contains a working unsubscribe link. We process unsubscribe requests within 10 business days.

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We may still send you messages that do not require consent, such as replies to your inquiries or messages about an engagement you have with us.

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7. Cookies and tracking technologies

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The Website uses cookies and similar technologies. Essential cookies are needed for the site to work. Analytics and marketing cookies are used only if you accept them through our cookie banner, and you can change your choice at any time. Our Cookie Policy explains which cookies we use and how to manage them.

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Third-party services, such as Google Analytics or LinkedIn, may set their own cookies and have their own privacy policies.

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8. How long we keep your information

We keep personal information only as long as needed for the purposes it was collected, or as required by law.

Information

Retention period

Contact form inquiries (no engagement)

[24 months] after our last contact

Newsletter subscriber data

Until you unsubscribe, plus records of consent for [3 years]

Job applications

[12 months] after the role is filled

Analytics data

[14 months], per our analytics settings

 

When information is no longer needed, we securely delete or anonymize it. If we use information to make a decision about you, we keep it long enough for you to request access to it.

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9. How we protect your information

We use reasonable physical, organizational and technical safeguards suited to the sensitivity of the information. These include encrypted (HTTPS) connections, access controls limited to staff who need the information, multi-factor authentication on our business accounts, and confidentiality obligations for staff and service providers.

No method of transmission or storage is completely secure. If a breach of security safeguards creates a real risk of significant harm to you, we will notify you and the Office of the Privacy Commissioner of Canada as required by law, and keep a record of the breach.

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10. Your rights and choices

You have the right to:

  • Access the personal information we hold about you and learn how it has been used and to whom it has been disclosed.

  • Correct information that is inaccurate or incomplete.

  • Withdraw consent to our use of your information, including unsubscribing from emails or changing your cookie choices.

  • Request deletion of your information where we no longer need it or have no legal obligation to keep it.

  • Quebec residents also have the right to request that we stop disseminating your information, and to receive computerized information in a structured, commonly used format.

 

To make a request, contact our Privacy Officer (Section 12). We will respond within 30 days and may need to verify your identity first. We provide access at no cost or at minimal cost, and will tell you in advance if a fee applies. If we cannot fulfil a request, we will explain why, subject to legal restrictions.

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11. Changes to this policy

We may update this policy to reflect changes in our practices or the law, including the federal privacy reform currently before Parliament. The effective date at the top shows when it was last revised. If we make material changes, we will post a notice on the Website and, where appropriate, notify you directly before the change takes effect.

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12. Contact us

For questions, requests or concerns about this policy or your personal information, contact:

  • Privacy Officer: [Name or title]

  • Mail: Harbinger SCR, 2 Bloor St. W., Toronto, Ontario, M4W 1A3

  • Email: [privacy@harbinger-scr.com][RM7] 

  • Phone: (416) 500-1834

 

Complaints

If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada at 1-800-282-1376. Québec residents may also contact the Commission d'accès à l'information du Québec.

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