PRIVACY POLICY
Effective Date: February 25, 2025
This Privacy Policy applies to our websites, applications, services, and other offerings that link to this policy (collectively, the "Services"). It explains how HRR Technologies, Inc. (d/b/a Gale) ("Gale", "we", "our", or "us") collects, uses, stores, and protects your personal data. Please review it carefully to understand your rights and our commitments regarding your information.
As a reminder, your use of the Services is subject to our Terms of Service, which incorporates this Privacy Policys. Any terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms of Service.
This Privacy Policy does not apply to information we process on behalf of our business customers (including companies and organizations filing immigration documents) while providing the Services to them. In such cases, our use of data is governed by our agreements with those business customers. If you have concerns about personal information that we process on behalf of a business customer, please contact that business directly, as they control how your information is handled.
What this Privacy Policy Covers
To offer the Services, Gale may collect Personal Data, including from its prospects and website visitors. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use, and share your information as described in this Privacy Policy.
This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. "Personal Data" means any information that identifies or relates to a particular individual and includes information referred to as "personally identifiable information" or "personal information" under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don't own or control or people we don't manage.
Personal Data
We primarily use your information, including Personal Information, to operate Gale's business and deliver the Services you request. This may include completing immigration forms and fulfilling your product and service requests, for example by emailing you with application updates.
Categories of Personal Data We Collect
This chart details the categories of Personal Data that we collect and have collected over the past 12 months:
| Category of Personal Data | Examples of Personal Data We Collect | Categories of Third Parties with Whom We Share this Personal Data |
| Identity and Profile Information | First and last name Email address Phone number Mailing address Name of employer or company Job title Educational transcripts; diplomas Other identity verification information reasonably requested | Service Providers Parties You Authorize Your Employer Marketing Partners Government Entities |
| Sensitive Personal Information (for governmental filings) | Social Security Number Driver's License Number State ID Card Number Passport Number Racial, Ethnic or National Origin Disability Status Age Religious or philosophical beliefs Immigration status Birth Certificate Information | Service Providers Parties You Authorize Your Employer Government Entities |
| Web Analytics | Usage Statistics Performance Metrics User Behavior Website Interaction Browsing History Search History | Service Providers (e.g., Analytics Tool Providers) Advertising Partners Parties You Authorize |
| Device IP/Data | Device ID Domain server IP Address Type of device/operating system/browser used to access the Services Geolocation Data | Service Providers Parties You Authorize |
| Cookies | Cookie ID Cookie Types (e.g., Session, Persistent) | Service Providers Content Delivery Networks |
| Other Identifying Information that You Voluntarily Choose to Provide | Identifying information submitted by you in emails, messages, posts, survey responses or other content you share, post or upload to the Services | Service Providers Parties You Authorize Your Employer Government Entities |
Collection of Immigration-Specific (Sensitive) Application Information
If you order Services from Gale that involve application submission, we may receive a unique receipt number from the government associated with your application ("Application Information"). Depending on the Services you request, Application Information may include sensitive personal details such as your age, race, disability, sexual orientation, religion, national origin, or racial/ethnic origin; your Social Security number, driver's license, state identification card, or passport number; your immigration status; birth certificate information; and your employment status or employer details.
Categories of Sources of Personal Data
We collect Personal Data about you from the following categories of sources:
You
Third Parties
Our Commercial or Business Purposes for Collecting Personal Data
Providing, Customizing and Improving the Services
Advertising and Marketing the Services
Corresponding with You
Meeting Legal Requirements and Enforcing Legal Terms
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.
How We Share Your Personal Data
We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a "sale" of your Personal Data. For more information, please refer to the state-specific sections below.
Service Providers. These parties help us provide the Services or perform business functions on our behalf:
Marketing and Advertising Partners. We may share your Personal Data with marketing and advertising partners that assist us in promoting our Services, delivering targeted advertisements, and analyzing campaign effectiveness.
Analytics Partners. These parties provide analytics on web traffic or usage of the Services. They include:
Parties You Authorize, Access or Authenticate
Legal Obligations
We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under "Meeting Legal Requirements and Enforcing Legal Terms" in the "Our Commercial or Business Purposes for Collecting Personal Data" section above.
No Attorney-Client Relationship
GALE IS NOT A LAW FIRM. YOUR USE OF OUR SERVICES, AND YOUR COMMUNICATION WITH GALE, DO NOT CREATE AN ATTORNEY-CLIENT RELATIONSHIP AND YOUR COMMUNICATIONS WITH GALE ARE NOT PROTECTED BY ATTORNEY-CLIENT PRIVILEGE.
For clarity, you may receive legal advice from attorneys made available via the Services under a separate attorney agreement. In that event, your rights regarding attorney-client privilege will be detailed in that agreement. However, your use of Services will still be governed by the Terms of Service and this Privacy Policy where and as applicable.
Business Transfers
All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.
Data that is Not Personal Data
We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services (including to improve our algorithmic models) and promote our business, provided that we will not share such data in a manner that could identify you.
Tracking Tools, Advertising and Opt-Out
The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, "Cookies") to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support "Do Not Track" requests sent from a browser at this time.
We use the following types of Cookies:
Advertising Cookies. Advertising Cookies are used to deliver advertisements that are more relevant to you and your interests. They track your browsing activity across different websites to build a profile of your preferences and may be used to measure the effectiveness of advertising campaigns. These Cookies are typically placed by third-party advertising networks with our permission. If you disable Advertising Cookies, you may still see ads, but they will not be tailored to your interests.
Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns to help us improve our campaigns and the Services' content for those who engage with our advertising.
You can decide whether to accept Cookies through your internet browser's settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.
To explore what Cookie settings are available to you, look in the "preferences" or "options" section of your browser's menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.
Data Security and Retention
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.
We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services (including, without limitation, for so long as necessary to "settle" a transaction) and in accordance with applicable laws and regulations. In some cases, we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
Personal Data of Children
We do not knowingly collect or solicit Personal Data about children under 13 years of age; if you are a child under the age of 13, please do not attempt to register for or otherwise use the Services or send us any Personal Data.
State Law Privacy Rights
California Resident Rights
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties' direct marketing purposes; in order to submit such a request, please contact us at founders@getgale.app.
Nevada Resident Rights
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at founders@getgale.app with the subject line "Nevada Do Not Sell Request" and providing us with your name and the email address associated with your account.
Colorado, Connecticut, Montana, Oregon, Texas, Utah and Virginia Rights
To the extent that Gale is processing any of your Personal Data in scope of the Colorado Privacy Act, Connecticut Data Privacy Act, Montana Consumer Data Privacy Act, Oregon Consumer Privacy Act, Texas Data Privacy and Security Act, Utah Consumer Privacy Act and/or Virginia Consumer Data Protection Act, Gale will:
Ensure that each person authorized to process Personal Data is subject to a duty of confidentiality with respect to the Personal Data;
If you are employed by a Customer, at their direction, delete or return all your Personal Data as they may request at the end of the provision of the Services, unless retention of the Personal Data is required by law;
Adhere to instructions from Customers to Gale regarding treatment of your Personal Data. Customers shall ensure that their instructions to Gale adhere to all applicable laws.
Upon the reasonable request of a Customer, make available to all information in its possession necessary to demonstrate its compliance with the obligations under the foregoing laws;
Allow, and cooperate with, reasonable assessments by Customer's designated assessor; alternatively, Gale may arrange for a qualified and independent assessor to conduct an assessment of Gale's policies and technical and organizational measures in support of the obligations under the foregoing laws using an appropriate and accepted control standard or framework and assessment procedure for such assessments. Gale shall provide a report of such assessment to Customer upon request; and
Engage any subcontractor pursuant to a written contract in accordance with the foregoing laws that requires the subcontractor to meet the obligations of Gale with respect to the Personal Data; and the parties (subcontractor and Gale) shall, taking into account the context of the processing, implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk and establish a clear allocation of the responsibilities between them to implement the measures. Customer may object to such an engagement of a subcontractor.
Changes to this Privacy Policy
We're constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes by placing a notice on the Gale website, by sending you an email and/or by other means. Please note that if you've opted not to receive legal notice emails from us (or you haven't provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.
Contact Information
If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at founders@getgale.app.