Harmony

    Legal

    Applicant Privacy Notice

    Last updated: September 25, 2026

    1. Introduction and Who This Notice Covers

    This Applicant Privacy Notice describes how Harmony Automation, Inc. (“Harmony,” “we,” or “us”) collects, uses, discloses, and otherwise processes Personal Information about individuals who apply to or receive public housing or other government benefits through our services, including information about the applicant’s household (“Applicants”).

    This Privacy Notice is effective as of the “Last Updated” date above. We may change this Applicant Privacy Notice from time to time. If we make changes, we will notify you by revising the “Last Updated” date. Where required by law, we will notify you of changes through the website or by other means. Please review this Applicant Privacy Notice periodically.

    Applicant Information is treated differently from other information. Because Applicant Information is collected to determine eligibility for housing and other government benefits, we limit our use and disclosure of it to what is necessary to provide, maintain, and improve those services and to comply with law. We do not sell Applicant Information, we do not use it for marketing or targeted advertising, and we do not use it to train artificial-intelligence models. We apply different standards to our use of information relating to website visitors who are not Applicants. Please review our Website Visitor Privacy Notice to learn more.

    2. Scope of This Notice

    This Notice applies to information we collect about Applicants, including in email, text, chat, and other electronic messages between you and us and through documents or applications you submit to us. It does not apply to information collected by any third party, or to information a Housing Partner (defined below) collects or holds under its own privacy policy. The information we receive from our Housing Partners is governed exclusively by our agreements with our Housing Partners.

    3. Minors

    While a minor household member may be listed on an adult Applicant’s application, we do not knowingly collect personal information directly from a minor without the consent of a parent or legal guardian. If we learn that we have collected personal information from a minor without the required consent, we will delete that information. If you believe we may hold information from or about a minor without such consent, contact us using the information in Section 14.

    4. Definitions

    Applicant Information means Personal Information (including Eligibility Information) that we collect from or about an Applicant or an Applicant’s household in connection with an application for, or receipt of, housing or other government benefits.

    Eligibility Information means information used to assess an Applicant’s eligibility for affordable housing or other government benefits, such as information about income, assets, investments, liabilities, receipt of government benefits, tax records, rent payment history, and credit, and supporting documents such as pay stubs, bank statements, tax forms, and government identification documents.

    Personal Information means information that identifies, relates to, describes, or can reasonably be linked to an identified or identifiable individual. It does not include De-Identified or Aggregated Data.

    De-Identified or Aggregated Data means information from which Personal Information has been removed or aggregated so that it can no longer reasonably be used to identify an individual, and that we maintain and use only in de-identified or aggregated form and do not attempt to re-identify.

    Housing Partner means a marketing agent, owner, leasing agent, developer, property manager, housing authority, or government agency involved in administering the housing or benefit for which an Applicant has applied.

    Verification Service means a third-party data or identity verification provider we use, at the Applicant’s direction, solely to verify Eligibility Information (for example, income, asset, tax, or identity verification providers).

    5. Information We Collect

    5.1 Information Applicants Provide

    We collect the following directly from Applicants or their authorized representatives to establish an account and process an application:

    • Contact Information: name, email address, mailing address, and phone number, and the same for household members listed on the application.
    • Eligibility Information: the information described in the Eligibility Information definition in Section 4, including supporting documents (such as pay stubs, bank statements, tax forms, and government identification) and information relating to rent payment history or credit, to the extent required to assess eligibility for the specific benefit applied for.
    • Communication Information: the content of your communications with us, including emails, texts, calls, and chats.

    5.2 Information We Collect Automatically

    As you use our website we collect limited technical information, including device and network data (hardware model, operating system, IP address, browser type) and usage data (access times, pages viewed, and links clicked).

    5.3 Information from Verification Services

    Where an Applicant directs us to do so, we obtain financial and identity-verification information from Verification Services (such as Plaid, TaxNow, and Argyle) solely to verify Eligibility Information for the application.

    6. How We Use Information

    We use Applicant Information only for the following purposes:

    • Service delivery: to provide and maintain our services, facilitate affordable-housing applications, assess eligibility for benefits, authenticate accounts, and remove duplicate applications.
    • Communication: to communicate with Applicants about their application and account, including status updates, document reminders, and responses to questions.
    • Protection and compliance: to detect and prevent fraud and security incidents, protect the rights and safety of Applicants and others, and comply with our legal obligations.
    • Research and development: to analyze and improve our services and generate De-Identified or Aggregated Data.
    • Notice or consent: for any other purpose we describe to the Applicant at the time of collection or to which the Applicant consents.

    7. Cookies and Analytics

    We use cookies to operate, secure, and understand use of the Website. You can set your browser to refuse or delete cookies, although some features may not function properly as a result. We do not sell Personal Information or use it for targeted or cross-context behavioral advertising.

    8. How We Disclose Information

    We disclose Personal Information only as follows:

    • To the Housing Partner the Applicant applied to: we disclose Applicant Information to the Housing Partner, and the applicable government agency or housing authority, for which the Applicant has submitted an application, as necessary to evaluate eligibility, conduct a lottery or waitlist, and administer the benefit. Once disclosed, the Housing Partner’s use of that information is governed by its own obligations and the confidentiality requirements.
    • To service providers and professional advisers: we disclose Personal Information to vendors, service providers, contractors, attorneys, accountants, and consultants that need this information to provide service to us (for example, web hosting, identity verification, fraud prevention, and customer support).
    • For legal and safety reasons: to comply with a court order, law, audit, or other legal process, to respond to lawful government or regulatory requests, and to protect the rights, property, and safety of Harmony, Applicants, and others.
    • In a corporate transaction: in connection with or during negotiations for a merger, financing, or sale of assets, provided the recipient is bound to protect Applicant Information consistent with this Notice and to use it only for the purposes described here.
    • With consent or at your direction: when you consent or direct us to disclose your information.

    We may disclose De-Identified or Aggregated Data for our legitimate business purposes.

    9. Program Confidentiality

    We handle Applicant Information in accordance with the confidentiality requirements of the affordable-housing and benefit programs we support, including confidentiality obligations flowed down to us through our agreements with Housing Partners (such as marketing-agent confidentiality requirements under the NYC HPD/HDC Marketing Handbook). Our personnel and service providers with access to Applicant Information are bound by confidentiality obligations consistent with this Notice.

    10. Data Minimization and Retention

    We collect only the Personal Information reasonably necessary for the purposes described in this Notice. We retain Applicant Information only for as long as necessary to provide our services, to satisfy the record-retention requirements of the applicable housing or benefit program, and to comply with our legal obligations, after which we delete or de-identify it. We retain other Personal Information for as long as reasonably necessary for the purposes described in this Notice.

    11. Data Security

    We maintain administrative, technical, and physical safeguards designed to protect Personal Information, appropriate to the volume and sensitivity of the information we process. No method of transmission or storage is completely secure, however, and we cannot guarantee absolute security. If a security incident affecting your Personal Information requires notification under applicable law, we will notify you and the appropriate regulators as required.

    12. Financial and Verification Information

    Eligibility Information obtained through Verification Services is retrieved only at the Applicant’s direction, is used solely to verify eligibility for the housing or benefit applied for, and is not used for marketing or disclosed to any third party for that party’s own purposes.

    13. SMS / Text Messaging Program

    With your consent, we will send you text messages about your housing or benefit application, such as status updates, document reminders, and answers to your questions. We do not use the mobile number you provide for marketing. Your mobile number and opt-in consent are not sold, shared, or disclosed to any third party or affiliate for that party’s own marketing or promotional purposes; we share this information only with the service providers that operate the messaging program on our behalf and as required to comply with law. You can opt out at any time by replying STOP, END, or CANCEL to the texts, and reply HELP for help. Message frequency varies, and message and data rates may apply.

    14. Contact Us

    If you have questions about this Notice or wish to exercise your rights, contact our Privacy Officer at privacy@harmonyworks.com or Harmony Automation Inc., 257 Park Ave South, Fl 15, New York, NY 10010.