Privacy Policy for HarrisX

Last updated September 2026

This Privacy Policy (“Policy”) describes how HarrisX LLC (formerly HarrisX Telecom LLC) and certain of its corporate affiliates (listed immediately below) (together “HarrisX,” “we,” or “us”) may collect, use, and disclose your personal information, including through this and other websites (collectively, the “Site”) and its services (the “Services”) described below. These corporate affiliates are Northstar Research Partners Inc. (Northstar Canada); Northstar Research Partners LLC (Northstar US), and Northstar Research Partners (UK) Ltd (Northstar London; registered England & Wales).

Please read this Policy carefully so that you understand our information practices. If you do not agree with the terms of this Policy, please do not use the Services. This Policy may change from time to time, so please check the Policy periodically for updates.

1HarrisX Services: General Background

HarrisX provides research, analytics, and marketing services to a range of commercial and non-profit organizations. This includes research panels, quantitative and qualitative research (which draw from information we collect on our consumer-facing apps and services), mobile and device-based research, research dashboards and portals, and AI-assisted research and analysis tools. When we conduct research, we sometimes use personal information that we collect from consumers through our own consumer-facing services, such as Telephia and Billing Snapshots (each of which are further described below). We refer to consumers’ personal information, which is also referred to in some statutes as “personal data” or “personal information”; it includes information about an individual, or information that can reasonably be associated with an individual (such as their device identifier).

When we provide the above services (all of which are part of the “Services”), we may also receive information from third party data services, in order to provide or enhance the above Services, such as to provide better or more accurate research.

Some of our Services are provided to entities that have entered into an agreement with us (“Clients”) whereby we are simply providing services as a vendor. In those circumstances, HarrisX is the “data processor” or “service provider” (referred to here as “processor”) to the Client, and the Client is the “data controller” – for instance, we may collect or analyze personal information collected by or on behalf of a brand, seeking to better understand its actual or prospective customers. In those cases, HarrisX processes personal information under the instructions of the Client, or as the Client otherwise permits, as described in the applicable agreement. If you have questions about how your information is collected and processed through the Services by or on behalf of a Client, please contact the Client with whom you are affiliated or which has provided your information to us for more information; this Privacy Policy does not pertain to our Services as a processor.

2Information We Collect

We may collect personal information about you when you respond to surveys, use the Sites, automatically when you visit the Sites, and from third parties.

a.Information You Provide Directly to Us (Such as When Visiting the Site or Responding to Our Own Surveys)

We collect personal information directly from you when you use our Site or interact with us. For example, this includes when you participate in surveys we offer, fill out our Contact Us form, sign up for newsletters, send us email messages, or apply for employment or an internship opportunity on our Site.

You may provide the following types of information to us:

• Identifiers (such as name, email address, phone number, and other contact information);
• Commercial information (such as information provided to us in your communications and transaction data);
• Information about your interests and preferences;
• Professional data (such as company name);
• Employment-related data (such as in an application);
• Photo, video, or video recording when you participate in our events, industry events, and conferences. This includes “sizzle reels” we may collect, use and distribute with your consent;
• Information when you interact with us (such as contacting us);
• Other information that identifies or can be reasonably associated with you, including information you voluntarily provide;
• In addition, if you participate in one of our panels or surveys, we may collect information such as your profile, eligibility and screening information, demographic information, research participation history, communications with us, and your survey and research responses (“Responses”). Responses may on occasion contain sensitive information such as self-reported information about race, ethnicity or religion, or political opinions;
• We also may collect your responses, testimonials or opinions in the form of audio recordings, video recordings, photographs, other imagery, transcripts or other participant-provided media; and
• We may create inferences drawn from any of the above, and we may combine any of the above with other personal information we describe below (including to create inferences).

For our own corporate purposes, we may collect similar information from or about you, such as if you are an actual or prospective customer of our Services, participate in or receive marketing information from us (such as attending a webinar or receiving business-related emails), or interact with us at a trade show, conference or other event.

b.Information We Collect Automatically

We may receive and store personal information about you and your device(s) automatically when you access or use the Site, or interact with our Services, including if you fill out surveys that we are conducting. This information may include:

• Log Information. When you use the Site, our servers or a third party, such as Google Analytics automatically record certain log file information, including your Internet Protocol (“IP”) address, operating system, browser or device type and language, referring URLs, access times, pages viewed, links clicked and other information about your interactions with the Site.
• Mobile Device Information. We may collect information about the mobile device you use to access or use the Site, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
• Activity Information. We may store information about your use of the Site, such as website pages visited, date and time of your visit, transactions you initiate, and emails you receive, open, and click.
• Cookies (and cookie identifiers). We and our third-party service providers, which include ad networks and analytics companies such as Google Analytics, may use cookies, web beacons, and other tracking technologies to collect information – including the above information -- about the computers or devices (including mobile devices) you use to access the Site. Sometimes, we work with third parties who deploy these cookies on our behalf. When we use these cookies to target ads to you – for instance, to “retarget” you on other services with information about our Services, after you’ve visited our Site – we give you the opportunity to “opt out” of these ads: see Section 5(b) for information about those “opt out” methods. We also use cookies for analytics, and other purposes, as described further in Section 5(a).

c.Our “Telephia” Services

If you participate in our “Telephia” mobile research service (which is downloadable through the Google Play Store), which is described in greater detail at https://telephia.io we will collect technical and usage information from or about the participating device. This includes device identifiers and information regarding the device, operating system, network, VPN status, network and WiFi and/or device connectivity and signal strength, precise location and time spent at particular location coordinates.

d.Our Billing Snapshots Service

We collect information that you provide through our “Billing Snapshots” service, if you choose to do so. This information includes your billing statements for certain services, particularly telecommunication services. We generally use it to conduct market research and analysis (e.g., about consumer preferences and usage) for telecommunication providers, utilities, device manufacturers and other commercial entities.

e.Information We Collect From Other Third Party Sources

We may collect personal information about you from third parties, including public sources (such as public records) and commercial sources (such as panel recruitment providers, survey providers or data aggregators, who themselves may work with both publicly available and commercially provided information). We may use this information to build and improve our models and to append attributes to research data, in aggregated form, for instance, to report to a Client that its brand or product has become more popular among certain age, income or gender groupings. We may use this information for our own corporate purposes (such as to learn more about potential Clients or survey respondents) or in the course of providing our Services. In particular, we may collect:

• Contact information (which may include an email address or other unique identifier tied to personal information).
• Information about your phone number and telecommunication history, such as your carrier, activation and disconnect date, reassignment or porting history. We use this information only to produce aggregated and de-identified research and analysis; we do not report information about an individual telephone number to Clients or other third parties.
• Information about your interests or demographics, including employment information.

3Use of Information

We may use your information for any of the following purposes:

• Conducting surveys,
• Deriving insights and analysis, and creating reports from the information we collect, such as regarding market research or consumer sentiment,
• Providing and operating our services,
• Developing new products and services, including conducting analysis and creating and improving our proprietary datasets, reports, and dashboards,
• Recruiting, screening, enrolling, and managing research participants,
• Communicating with you, including through advertising, promotions and email, which may be through social media platforms,
• Analyzing how people use our Services including the Site, or respond to our marketing and communications,
• Creating reports for Clients on visitors to certain locations and general traffic patterns – for instance, based on information we collect from the Telephia app,
• Creating reports specific to the telecommunication industry – for instance, based on information we collect from the Billing Snapshots service, or databases containing information about wireless carrier and internet service subscription attitudes and decisions, phone activation, termination and other activity,
• Internal auditing and recordkeeping purposes,
• Evaluating job applications,
• Communicating with you on behalf of a Client of ours and/or in response to a survey,
• Protecting our users, Site, and services, and complying with the law,
• Detecting, investigating, and preventing improper or fraudulent use of our Services or the Site,
• Protecting our rights, and complying with the law, and
• Other uses about which we notify you.

We may aggregate and/or de-identify personal information collected through the Site or Services (or receive information in de-identified form). We may use de-identified or aggregated data for any purpose, including without limitation for research and marketing purposes, and may also disclose such data to any third parties.

4Disclosure of Personal Information

We may disclose your personal information as follows:

• To vendors and service providers who perform services on our behalf. These parties provide a variety of services to us, including without limitation billing and collections, marketing and advertising, market research, data storage, web hosting, customer and tech support, security, data enhancement, analysis and processing, auditing, accounting and legal services.
• To provide Services you have requested.
• To provide Services a Client has requested, such as to third party advertising or marketing platforms, social media platforms, or campaign analytics or measurement companies.
• To our third party partners, including panel recruitment providers and survey and research platforms.
• To HarrisX affiliates, including any subsidiaries or affiliates of Stagwell.
• If required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process; (b) protect and defend our rights or property; and/or (c) act under exigent circumstances to protect the personal safety of us, our Clients, or the public.
• In connection with, or during negotiations of, any merger, acquisition, sale of assets or any business, other change of control transaction or financing between any future parent, subsidiary, and/or affiliated company.
• In other situations, with your consent or at your direction.

We do not, however, currently “sell” personal information: for instance, in the event we provide information to a Client (such as information from a survey or recording), users may consent to and/or be paid for such information, responses or promotion. In the event we provide market research (such as regarding the telecommunication industry), such information is provided only in aggregated and de-identified form and does not identify an individual person, device or telephone number.

5Your Opt-Out Choices for Our Own Analytics and Marketing

As to our own Site or corporate practices, and separate from the Services we provide, you may exercise rights and control the marketing we send you as set out below.

Section 9 on the other hand describes how to exercise rights with respect to personal data (including data received from third parties) that we may collect and use for purposes of delivering our Services, such as the creation of reports and analysis.

a.Analytics

We may use third-party web analytics services on the Site, such as those of Google Analytics. These services use the sort of technology described in the “Information We Collect Automatically” sub-section of Section 2 above to help us analyze how users use our Site, including by noting the third-party website from which you arrive. The information collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Site. We also use Google Analytics for certain purposes related to advertising, as described in the following section. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-Out Browser Add-on.

b.Tailored Advertising

We may allow certain third parties (e.g., ad networks and ad servers) to serve targeted marketing to you on our behalf (for instance, when you are on our website) and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Site. We neither have access to, nor does this Policy govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device you use to access the Site by non-affiliated, third-party ad technologies, ad servers, ad networks or any other non-affiliated third parties. However, the parties that use these technologies may offer you a way to opt out of targeted advertising as described below.

Targeted advertising in turn often employs cookies and other device identifiers, to identify you, your browser or your device. In turn, sometimes these cookies may be associated with de-identified data linked to or derived from data you have submitted to us (e.g., your email address) that we may disclose to a service provider in hashed format.

For more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored marketing, you may visit the Digital Advertising Alliance’s (“DAA”) Consumer Opt-Out Link. That page also may provide instructions as to how to opt-out of receiving tailored advertising or (to the extent that organization maintains it) to opt out through the tools it offers. To opt out of Google Analytics for Display Advertising or customize Google Display Network ads, you can visit the Google Ads Settings page. Please note that to the extent advertising technology is integrated into the Site, you may still receive advertising content even if you opt out of tailored advertising. In that case, the advertising content will just not be tailored to your interests. We do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms. If your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different computer or change web browsers, your DAA opt-out may no longer be effective. Additional information is available on the DAA’s website, accessible by the above link.

c.Email Marketing

You may opt out of any email marketing communications you have received from us in our corporate capacity (e.g., if you are our Client) at any time by following the instructions in those communications, such as an “unsubscribe” link in emails we may send to you.

6Links

The Site may contain links or other connections to other third-party websites, platforms, products, services or applications that are independent of our Site. The information collection practices and privacy policies of these third parties may differ from ours. We provide links to you only as a convenience, and the inclusion of any link does not imply affiliation, endorsement or adoption by HarrisX of any site or any information contained therein.

7Security and Retention of Personal Information

We have implemented various administrative, technical, and physical security measures intended to protect against the loss, misuse and/or alteration of your personal information. However (like any organization), we cannot and do not guarantee that these measures will prevent every unauthorized attempt to access, use, or disclose your information since despite our efforts, no Internet and/or other electronic transmissions can be completely secure.

We generally retain personal data for so long as it may be relevant to the purposes above. In determining how long to retain information, we may consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we process the information, applicable legal requirements, and our legitimate interests.

8Children’s Privacy

Our Telephia mobile research service is available only to individuals 18 years of age or older. The Site is not directed to children, and we ask that children not submit personal information to us through the Site. If you believe that a child has provided us with personal information through the Site, please contact us as set out in the “Contact Us” section below, and we will delete that information or take other appropriate action.

9Privacy Rights You May Have With Respect to Our Services

Certain jurisdictions grant residents particular privacy rights. If you live in one of these jurisdictions, including, California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, New Hampshire, Nebraska, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia, and at various dates during 2027, Alabama, Louisiana, and Oklahoma, you may have the following rights with respect to your “personal information” or “personal data” (as such terms are defined under applicable law, and collectively referred to herein as “personal information”). A subset of these states may provide you the right to exercise your rights through an authorized agent, including California (as to which a separate “Addendum” is provided below).

Deletion and Access Rights: As to personal information we use in the course of our Services you in turn may have the right to request (without being discriminated against for asking) that we:

• Delete certain personal information we have about you.
• Provide you access to and/or a copy of certain personal information we hold about you (sometimes called the “right to know”).
• Correct or update personal information we hold about you (which we will respond to by “deleting” your information).
• Obtain a copy of certain personal information in a portable and, to the extent required by law, readily usable format.
• Restrict the processing of certain personal information.
• Exercise any other rights made available under applicable law.

If you are in the United Kingdom or the European Economic Area, you have the rights of access, rectification, erasure, restriction, portability and objection under the UK GDPR or EU GDPR, and the right to withdraw consent at any time. To exercise them, contact us at privacy@harrisx.com. You may also lodge a complaint with the UK Information Commissioner’s Office (ico.org.uk) or your national supervisory authority.

If you are in Canada, we collect, use and disclose your personal information with your consent or as otherwise permitted under the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy laws. You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. To exercise your rights of access or correction, or to withdraw consent, contact us at privacy@harrisx.com. You may also file a complaint with the Office of the Privacy Commissioner of Canada (priv.gc.ca).

To exercise the above rights, please email us at privacy@harrisx.com.

Opt-out rights: You also may have the right to opt out of the “sale” or “sharing” of your personal information, including our use of that information for targeted advertising (also called a “do not sell or share” right). Generally, if we retarget visitors of our website, we will provide a visible way to “opt out,” such as through a banner and/or link on our website.

Consumers in certain states have the right to request a list of third parties to which information was disclosed. While you may make such a request, note that we are permitted to withhold certain third parties’ names where doing otherwise would infringe upon trade secret rights. (Consumers also have a right to opt out of the processing of personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects, if applicable. We do not engage in such processing.)

Certain information may be exempt from the above requests under applicable law. For example, we need to retain certain information in order to provide our services to you. In addition, if you ask for a copy of your personal information, we will take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, verifying your name and email address. If we cannot verify you, we may be unable to respond to your requests.

Authorized Agents. You may designate an authorized agent to make requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.

Right to Appeal. In certain jurisdictions, residents have the right to appeal our decision to deny your request, if applicable. If you wish to do this, please send an email to privacy@harrisx.com with the word “Privacy Appeal” in the subject line.

Opt Out of Targeted Advertising. You may also opt out of targeted advertising, which we may occasionally engage in, such as to “retarget” with information about our services when you visit other websites (which in some states may be considered “selling” or “sharing” personal information). To opt out of targeted advertising we may play a role in facilitating, please email us at privacy@harrisx.com. We do not knowingly sell the personal information of minors under 18 years of age, or deliberately target minors with advertising.

10International Users

If you live in the European Union, United Kingdom, Canada, or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your personal information outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. Your personal data may be transferred for processing and storage by HarrisX and our affiliates and third parties. By providing your personal data you consent to any transfer and processing in accordance with this Policy. Where required, transfers from the UK or EEA are made under the UK International Data Transfer Agreement or the EU Standard Contractual Clauses.

11Legal Basis

The laws in some jurisdictions – including but not limited to the UK General Data Protection Regulation and Data Protection Act 2018, or the EU General Data Protection Regulation – require us to disclose the legal grounds we rely on to process your information as a controller. Our legal bases for processing your information as described in this Privacy Policy are as follows: (i) where you have given consent to processing for one or more purposes (such as when we obtain consent for survey responses or “sizzle reel” videos); (ii) where the processing is necessary to enter into or perform a contract you have entered into with us; (iii) where the processing is necessary for our compliance with a legal obligation; or (iv) where processing is necessary for the purposes of our legitimate business interests, unless such interests are overridden by your interests or fundamental rights and freedoms.

12Updates to this Policy

We reserve the right to change this Policy from time to time and will notify you of changes as required by law. Your continued use of the Site after such modifications will constitute your: (a) acknowledgment of the modified Policy; and (b) agreement to abide and be bound by that Policy.

13Contact Us

If you have questions or comments regarding our privacy practices or this Policy, please contact us at privacy@harrisx.com.

14Additional Detail for California Residents

CALIFORNIA PRIVACY ADDENDUM: Privacy Notice to California Residents

Last updated: September 2026

This Section 14 applies only to “personal information” about California residents, as that term is defined in the California Consumer Privacy Act (“CCPA”), and it supplements (and, in some cases, repeats) the information in the rest of our Policy above (“Privacy Notice”). Data about individuals who are not residents of California is handled differently and is not subject to the same rights described in this Privacy Notice. This Privacy Notice does not apply to data or activities that are exempt from the relevant provisions of the CCPA.

1The Personal Information We Collect

Similar to the description in our fuller Privacy Policy, the below chart provides a concise summary of the categories of information we collect, our sources of information, and the purposes for use.

2Our Purposes in Using Personal Information

More specifically, we may use your information for any of the following purposes:

• Conducting surveys,
• Deriving insights and analysis, and creating reports from the information we collect, such as regarding market research or consumer sentiment,
• Providing and operating our services,
• Developing new products and services, including conducting analysis and creating and improving our proprietary datasets, reports, and dashboards,
• Recruiting, screening, enrolling, and managing research participants,
• Communicating with you, including through advertising, promotions and email, which may be through social media platforms,
• Analyzing how people use our Services including the Site, or respond to our marketing and communications,
• Creating reports for Clients on visitors to certain locations and general traffic patterns – for instance, based on information we collect from the Telephia app,
• Creating reports specific to the telecommunication industry – for instance, based on information we collect from the Billing Snapshots service, or databases containing information about phone activation, termination and other activity,
• Internal auditing and recordkeeping purposes,
• Evaluating job applications,
• Communicating with you on behalf of a Client of ours and/or in response to a survey,
• Protecting our users, Site, and services, and complying with the law,
• Detecting, investigating, and preventing improper or fraudulent use of our Services or the Site,
• Protecting our rights, and complying with the law, and
• Other uses about which we notify you.

We may aggregate and/or de-identify personal information collected through the Site or Services (or receive information in de-identified form). We may use de-identified or aggregated data for any purpose, including without limitation for research and marketing purposes, and may also disclose such data to any third parties.

3Selling and Sharing Personal Information

We generally do not “sell” personal information (or facilitate targeted advertising) in the course of providing our Services. However, we may retarget visitors of our website with ads, if we engage in that activity (which may be “sharing” under the CCPA), in which case we will provide a visible way to “opt out” such as through a banner and/or link on our website.

4California Residents’ Privacy Rights

Deletion and Access Rights: As to personal information we use in the course of our Services you in turn may have the right to request (without being discriminated against for asking) that we:

• Delete certain personal information we have about you.
• Provide you access to and/or a copy of certain personal information we hold about you (sometimes called the “right to know”).
• Correct or update personal information we hold about you (which we will respond to by “deleting” your information).

To exercise the above rights, please email us at privacy@harrisx.com.

Opt-out Rights: As noted above, we generally do not “sell” personal information (or facilitate targeted advertising) in the course of providing our Services. However, we may retarget visitors of our website with ads, if we engage in that activity (which may be “sharing” under the CCPA), in which case we will provide a visible way to “opt out” such as through a banner and/or link on our website – also known as “opting out” of such sharing.

(Consumers also have a right to opt out of the processing of personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects, if applicable. We do not engage in such processing.)

Authorized Agents. You may designate an authorized agent to make requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.

5Security and Retention of Your Information

We have implemented administrative, technical, and physical security measures intended to protect against the loss, misuse and/or alteration of your information. However (like any organization), we cannot and do not guarantee that these measures will prevent every unauthorized attempt to access, use, or disclose your information since despite our efforts, no Internet and/or other electronic transmissions can be completely secure.

We intend to retain this information for as long as we feel it is necessary for the purposes described above, or for any longer period required by law.  Because we may collect and use the same category of personal information for different purposes and in different contexts, there is no general fixed retention period that always will apply to a particular category of personal information.