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Privacy Policy

This Privacy Policy explains our policy regarding the collection, use, disclosure and transfer of your information by The Hartman Group.

Privacy Policy and GDPR Notice

Last updated: December 14, 2018

We understand that you are aware of and care about your personal privacy interests, and we take that seriously. This Privacy Policy sets forth your privacy rights and describes the policies and practices of The Hartman Group, Inc., a Bellevue, Washington, U.S.A. Corporation regarding the collection and use of your personal data when its processing is governed by the EU General Data Protection Regulation (“GDPR”). This Privacy Policy applies to personal data collected and used in connecting to or using websites managed by The Hartman Group (each, a Website) or as a current or potential Hartman Group client or service provider. The Controller of your personal data is The Hartman Group with its principal place of business located at 3150 Richards Road, Bellevue, WA 98005, U.S.A. We recognize that information privacy is an ongoing responsibility, and so we will, from time to time, update this Privacy Policy as we undertake new personal data practices or adopt new privacy policies. Please read the entire Privacy Policy before using our Website. By using the Website, you consent to the terms of this Privacy Policy and our Terms and Conditions of Use.

1.   Information We Collect

A.  Information You Provide

We may collect information you provide directly via the We may ask you for some or all of the following types of information when you register with our Websites, access various content or features, register for content or events, submit comments and other content, order products, or directly contact us with questions or feedback:

Contact information, including:

  • Name, title, company name, e-mail address, postal address, and telephone number;
  • Payment information, such as credit card number and expiration date;
  • Communications preferences;
  • Search queries;
  • Correspondence and other information that you send to us; and
  • Additional information as otherwise described to you at the point of collection or pursuant to your consent.

The information you provide may include Personal Information.  “Personal Information” is information that identifies you personally (whether alone or in combination). Personal Information once “de-identified” is not subject to this Privacy Policy and we may treat it as non-Personal Information and use it without obligation to you except as prohibited by applicable law.

B.  Information Collected Automatically

We also may collect certain information automatically when you visit the Websites (“Usage Information”), including:

  • Your browser type and operating system;
  • Your Internet Protocol (IP) address, which is the number automatically assigned to your computer whenever you access the Internet and that can sometimes be used to derive your general geographic area;
  • Geolocation information;
  • Other unique identifiers, including mobile device identification numbers;
  • Sites you visited before and after visiting the Websites;
  • Pages you view and links you click on within the Websites;
  • Information collected through cookies, web beacons, and other technologies;
  • Information about your interactions with e-mail messages, such as the links clicked on and whether the messages were opened or forwarded; and
  • Standard server log information.

Except to the extent required by applicable law, The Hartman Group does not consider Usage Information to be Personal Information. However, Usage Information may be combined with your Personal Information. To the extent that we combine Usage Information with your Personal Information, we will treat the combined information as Personal Information under this Privacy Policy.

We may use cookies, pixel tags, Local Shared Objects (sometimes referred to as “Flash Cookies”), and other technologies to automatically collect Usage Information:

Cookies, Pixel Tags, and Local Shared Objects

Cookies are small bits of information that are stored by your computer’s web browser. You can decide if and how your computer will accept a cookie by configuring your preferences or options in your browser. However, if you choose to reject cookies, you may not be able to use certain online products, services or features on the Services.

Pixel tags are very small images or small pieces of data embedded in images, also known as “web beacons” or “clear GIFs,” that can recognize cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device.

Local Shared Objects (sometimes referred to as “Flash Cookies”) are similar to standard cookies except that they can be larger and are downloaded to a computer or mobile device by the Adobe Flash media player.  Please note that you may need to take additional steps beyond changing your browser settings to refuse or disable Local Shared Objects and similar technologies.  For example, Local Shared Objects can be controlled through the instructions on Adobe’s Setting Manager page.  If you choose to refuse, disable, or delete these technologies, some of the functionality of the Websites may no longer be available to you.

Embedded Scripts

An embedded script is programming code designed to collect information about your interactions with the Websites. It is temporarily downloaded onto your device from our web server or a third party with whom we work, is active only while you are connected to the Services, and deleted or deactivated thereafter.

Location-identifying Technologies

GPS (global positioning systems) software, geo-filtering, and other location-aware technologies locate (sometimes precisely) you for purposes such as verifying your location and delivering or restricting relevant content based on your location.

For further information on tracking technologies and your choices regarding them, please see Section 6 below.

C.  Information from Other Sources.

We may obtain information about you from other sources, including service providers and third-party services, and combine such information with information we have collected about you.  To the extent we combine such third party sourced information with Personal Information we have collected about you on the Websites, we will treat the combined information as Personal Information under this Privacy Policy. We are not responsible for the accuracy of any information provided by third parties or third-party policies or practices.

2.  Use of Information

We may use information that we collect through the Websites for a variety of purposes, including to:

  • Provide you with the products, promotions, services, newsletters, and information you request and respond to correspondence that we receive from you;
  • Customize and personalize your use of the Websites;
  • Contact you via email and otherwise about products, services, and events that we think might be of interest to you;
  • Contact you with surveys, legal notices, and other information that may be relevant to your use of the Websites;
  • Maintain or administer the Websites, perform business analyses, or for other internal purposes to improve the quality of our business, the Websites, and other products and services we offer;
  • Process employment applications and inquiries;
  • Create articles and other content;
  • Detect, investigate, and prevent activities that may violate our policies or may be fraudulent or illegal;
  • As otherwise described to you at the point of collection or pursuant to your consent.

3.  Sharing of Information

We want you to understand when and with whom we may share the information we collect. We may share information that we collect through the Websites with third parties as follows:

Service Providers. We may share your information with our agents and service providers that perform certain functions or services on our behalf, such as to host the Websites, manage databases, host a store or other e-commerce platform, perform analyses, or send communications and newsletters for us.

In Connection with Transfer of Assets. If we sell all or part of our business, or make a sale or transfer of assets, or are otherwise involved in a merger or business transfer, or in the event of bankruptcy, we may transfer your information to one or more third parties as part of that transaction.

Aggregate Information. We may disclose information to third parties that does not describe or identify individual users, such as aggregate website usage data or demographic reports.

4.  Social Networking Services

The Hartman Group has worked with certain third-party social media providers to offer you their social networking services through our Websites. For example, you can use third-party social networking services, including but not limited to LinkedIn, Facebook, Twitter, and others to share information about your experience on our Websites with your friends and followers on those social networking services.  These social networking services may be able to collect information about you, including your activity on our Websites.  These third-party social networking services also may notify your friends, both on our Websites and on the social networking services themselves, that you are a user of our Websites or about your use of our Websites, in accordance with applicable law and their own privacy policies.  If you choose to access or make use of third-party social networking services, we may receive information about you that you have made available to those social networking services, including information about your contacts on those social networking services.

5.  Links to Third Party Sites and Services

The Websites may contain links to other websites or online services that are operated and maintained by third parties and that are not under the control of or maintained by The Hartman Group.  Such links do not constitute an endorsement by The Hartman Group of those other websites, the content displayed therein, or the persons or entities associated therewith. This Privacy Policy does not apply to this third-party content. We encourage you to review the privacy policies of these third-party websites or services.

6.  Analytics and Advertising Tracking Technologies.

We may allow third parties to place and read their own cookies, web beacons, Local Shared Objects, and other technologies to collect information through the Websites.  For example, our third-party service providers may use these technologies to collect information that helps us with traffic measurement, research, and analytics.  To the extent we combine information from third party services with Personal Information we collect directly from you on the Websites, we will treat the combined information as Personal Information under this Privacy Policy. Otherwise, the information collected and stored by third parties remains subject to their policies and practices, including whether they continue to share information with us, the types of information shared, and your choices on what is visible to others on third party services.

We use Google Analytics, a web analytics service provided by Google, Inc. The cookies and other technologies used by Google may collect Personal Information, but The Hartman Group does not use Google Analytics to gather information that personally identifies you. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on.

7.  Communications Preferences

You may choose to receive promotional communications (including emails), newsletters, and similar communications from us. You may opt out of receiving certain promotional communications from us at any time in promotional emails by clicking on the opt-out or “unsubscribe” link included in the commercial e-mails you receive. Please note that your opt-out is limited to the e-mail address and will not affect subsequent subscriptions. Opt-out requests for e-mail may take up to 10 business days to be effective. Your opt-out request will not apply to messages that you request or that are not commercial in nature.

8.  Your California Privacy Rights

Pursuant to California’s “Shine The Light” law, California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of Personal Information to third parties for their own direct marketing purposes in the preceding calendar year. You may request this disclosure information at privacy@hartman-group.com and indicate in the email subject line “California Shine The Light Request” so that we can process your request. Please include your mailing address, state of residence and email address with your request.

9.  Children’s Privacy

The Services do not knowingly collect, use, or disclose personal information from children under the age of 13 without prior parental consent, except as permitted by the Children’s Online Privacy Protection Act (“COPPA”). If you are a parent or guardian and believe we have collected information in a manner not permitted by COPPA, please contact us at privacy@hartman-group.com.

10.  Data Security

We maintain reasonable security procedures to help protect against loss, misuse, unauthorized access, disclosure, alteration or destruction of the information you provide to us.  Please note that no data transmission or storage can be guaranteed to be 100% secure.  As a result, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and cannot be responsible for the theft, destruction, or inadvertent disclosure of your information.

11.  International Users

Please note that the Websites are directed towards users who reside in the United States. By using the Websites, you consent to the collection, storage, processing, and transfer of your information in and to the United States, or other countries and territories, pursuant to the laws of the United States. Some of these countries may not offer the same level of privacy protection as your own. Any such transfers will comply with safeguards as required by relevant law. If applicable, you may have a right to claim compensation for damages caused by a breach of relevant data protection laws.

If you are a resident of the European Economic Area (EEA) or Switzerland, the following information applies:

Purposes of processing and legal basis for processing

As explained above, we process personal data as defined under data protection laws in various ways depending upon your use of the Websites. We process personal data on the following legal bases: (1) with your consent; (2) as necessary to perform our agreement to provide services; and (3) as necessary for our legitimate interest in providing the Websites where those interests do not override your fundamental rights and freedom related to data privacy.

Right to lodge a complaint

Users that reside in the EEA or Switzerland have the right to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. Contact details for data protection authorities are available here.


Personal information we collect may be transferred to, and stored and processed in, the United States or any other country in which we or our affiliates or subcontractors maintain facilities. Upon the start of enforcement of the General Data Protection Regulation (GDPR), we will ensure that transfers of personal information to a third country or an international organization are subject to appropriate safeguards as described in Article 46 of the GDPR.

Individual Rights

If you are a resident of the EEA or Switzerland, you are entitled to the following rights, which may be exercised by contacting us as described below. In order to verify your identity, we may require you to provide us with personal information prior to accessing any records containing information about you.

  • The right to request data erasure. You have the right to have your data erased from our website if the data is no longer necessary for the purpose for which it was collected, you withdraw consent and no other legal basis for processing exists, or you believe your fundamental rights to data privacy and protection outweigh our legitimate interest in continuing the processing.
  • The right to restrict or object to our processing. You have the right to restrict or object to our processing if we are processing your data based on legitimate interests or the performance of a task in the public interest as an exercise of official authority (including profiling); using your data for direct marketing (including profiling); or processing your data for purposes of scientific or historical research and statistics.

12.  Privacy Policy Updates

We may modify this Privacy Policy at any time by posting revisions to the Websites or other appropriate notice. Your continued use of the Websites after any modification to the Privacy Policy will constitute your acceptance of the new terms and conditions.

13.  Contact Us

If you have any questions about this Privacy Policy, you may contact us at:

The Hartman Group
3150 Richards Road
Bellevue, WA 98005
Tel: (425) 452-0818
Email: privacy@hartman-group.com

Third Party Partners
To serve readers in the United States, EEA and other countries, The Hartman Group relies on partners to provide many features of our sites and services using data about your use of the Websites. Below is a list of these partners with links to more information their use of your data and how to exercise your rights to opt-out.

If you would like to opt-out of data processing from a specific vendor, and that vendor does not provide their own means of opt-out please specify the name of the vendor in the subject line of your email to privacy@hartman-group.com. Some data processing is so crucial to the functioning of The Hartman Group’s websites that opting out will result in your no longer being able to access our content.

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