INTRODUCTION

Horrigan Resources, Ltd. (“we,” “us” or “Company”) is strongly committed to respecting and protecting your privacy. Please carefully read the following Privacy Policy (“Policy”). In order to ensure your privacy, information the Company collects from its clients and visitors to its Website located at   www.horriganresources.com, including in particular information collected in connection with the Company’s comport365™ product, and, as applicable, Websites hosted by the Company for our clients, (collectively, the “Site”) is used only in the manner and for the purposes described in this Policy.

The purpose of this Policy is to explain the type of information that the Company collects, what we do with that information, and with whom the Company shares this information. Anyone who provides personally identifiable information (“Personal Information”) or any other information to the Company consents to the collection, use and disclosure of such information under the terms of this Policy.
This Policy applies to both our clients to whom we provide services (“Clients”) and to those individuals who browse and use our Site (“Visitors”).

The following articles make up our Privacy Policy. We hope that reading them gives you a clear idea of how we manage information we receive.
 

THE SERVICES WE PROVIDE

Horrigan Resources is committed to assisting Clients efficiently manage compliance requirements, tasking and communication. The Company collects information from our Clients as part of this service, including the use of comport365™. The Company is committed to protecting the privacy and confidentiality of our Clients and Clients’ Employees.

Clients enter into written contracts with the Company whereby, among other services, the Company provides a venue for the compliance team and line of business professionals to monitor and communicate about compliance matters. This compliance venue is populated by information submitted by our Clients and is available to our Clients through a password protected secure portal on the Company’s Site.

The information that is provided to the Company on behalf of its Clients only is used by the Company to provide products and services to its Clients, including compliance support through comport365™, and for no other purpose. Unless mandated by law or valid court order or as otherwise discussed in “Sharing Personal Information with Others” this information is only shared with our Clients. Information provided by Visitors to the Site is used to respond to specific inquiries and also to circulate a Company newsletter.
 

THE INFORMATION COLLECTED BY US

The Company may collect any Personal Information that is provided to us by our Clients or Visitors to our Website. This includes, without limitation, name, phone number, mailing address, e-mail address, or any other Personal Information that is provided to us in connection with the Site or the use of our Services.
 

COOKIES

When our Clients use our Web-based services which include access to a Client’s secure portal on the Company's Site, our servers use session cookies to help identify each Client and make using the service more efficient. Our session cookies do not collect any Personal Information and are removed when the session is concluded. We do not use any cookies when Visitors browse the Site.
 

SHARING PERSONAL INFORMATION WITH OTHERS

Horrigan Resources does not disclose, sell, share, trade or give away any Client or Visitor information to third parties, except under one or more of the following circumstances:
Consent: If a Client or Visitor has consented to the disclosure of information, the Company may share such information with others.

Protection of Horrigan Resources and Others: Horrigan Resources may disclose Information about Clients or Visitors to others: (i) if we have a good faith belief that we are required or permitted to do so by law or legal process; (ii) in connection with legal or administrative proceedings; (iii) to protect the rights, reputation, property or safety of the Company or others; (iv) to defend or enforce the Company’s rights or our Clients’ obligations; or (v) if the disclosure is required by mandatory professional standards.

Business Transfers: In the event that the Company decides to sell all or part of its stock or assets or merge its Company, it reserves the right to include Client or Visitor Information among the assets transferred to the acquiring or surviving company. It is the Company’s practice to seek appropriate protection for Personal Information in these types of transactions.
Aggregate Anonymous Information: The Company may provide to others anonymous information in the aggregate for purposes of marketing, promotion or similar activities. None of this aggregated information will identify anyone personally.

YOUR CHOICES WITH RESPECT TO PERSONAL INFORMATION

Visitors
The Site gives Visitors the opportunity to stop receiving communications from the Company if previously requested. The Site also gives Visitors options for changing and modifying information previously provided. To remove or change information in our database, or to not receive future communications from the Company, e-mail info@horriganresources.com with your request.

Children
Horrigan Resources does not sell products or services for purchase by children under the age of eighteen (“Minors”). The Company does not knowingly solicit or collect Personal Information from Minors, and we will not knowingly link to any third party Website that solicits or collects Personal Information from Minors. If you believe that a Minor has disclosed Personal Information to us or that we have linked to such a third party Website, please contact us at info@horriganresources.com so that the information and/or link can be removed.

SECURITY AND PROTECTION OF DATA COLLECTED BY US

The Company’s Site and the Websites maintained for our Clients have security measures in place to protect the loss, misuse and alteration of the information under our control. The Company has implemented various physical, electronic, and managerial measures, including education and training of our personnel, to provide Client Information with reasonable protection from accidental loss or destruction, improper use, alteration, or disclosure. The Company has invested and deployed a wide variety of technology and security features to ensure the privacy of Client Information that is collected by the Company through its services and via the Site. In addition, the Company has implemented strict operational guidelines to safeguard privacy of data we collect at every level of our organization.
The Company will continue to revise policies and implement additional security features as new technologies become available. Unfortunately, no system is perfect; therefore, the Company makes no representations or warranties with regard to the sufficiency of these security measures. The Company shall not be responsible for any actual or consequential damages (or any other damages or liability of any kind whatsoever) that result from a lapse in compliance with this Policy because of a security breach or technical malfunction.


ACCESS TO YOUR INFORMATION

If you wish to obtain a copy of particular information you provided to the Company, or if you become aware the information is incorrect and you would like us to correct or delete it, contact us at info@horriganresources.com.  Before the Company is able to provide you with any information or correct any inaccuracies, however, we may ask you to verify your identity and to provide other details to help us to respond to your request. The Company affirms that it will correct, amend or delete any erroneous data if instructed to do so by you, subject to the EU Safe Harbor principles of proportionality and reasonableness. We always will endeavor to respond within an appropriate timeframe to any request under this section.

ENFORCEMENT OF THIS PRIVACY POLICY

The Company will cooperate with the Department of Commerce to resolve any complaints and disputes arising in connection with this Policy. All Company employees will be required to be familiar with and adhere to this Policy. The Company will investigate any reported complaints of violations of this Policy and will take prompt remedial action where violations are found. In order to inquire or complain about the Company's privacy policies or anything related to the privacy of Personal Information handled by us, contact us at the following e-mail address: info@horriganresources.com.
 

AMENDMENT TO THIS PRIVACY POLICY

From time to time, the Company may update, modify or change its privacy policy. When this occurs, its new privacy policy will be posted on the Site. You should check the Site periodically to review the most recent Privacy Policy.

Amended and Effective: This Policy took effect on March 1, 2008.