Privacy Statement

Old Harbor Native Corporation Privacy Statement

Last Updated: April 2, 2026

This Privacy Statement (the “Statement”) explains how Old Harbor Native Corporation (“OHNC,” “we,” or “us”) collects, stores, uses, and discloses personal information, including when you: (1) use our shareholders services, (2) visit our website or in person, (3) communicate with us, including on social media platforms, (4) apply for a land license, or (5) apply for a job with us. This Statement addresses specific disclosure requirements from various privacy laws and also serves as our ‘notice at collection.’

PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND OUR DATA HANDLING PRACTICES AND HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS. IF YOU HAVE ANY QUESTIONS ABOUT THIS STATEMENT OR OUR PRIVACY PRACTICES, OR IF YOU WISH TO OPT-OUT OF THE SALE OR SHARING OF YOUR INFORMATION OR EXERCISE ANY OTHER PRIVACY RIGHT, PLEASE CONTACT US BY EMAIL AT info@oldharbor.org OR BY COMPLETING THIS FORM.

1. Personal Information We Collect and Process

OHNC collects information about shareholders, business contacts, job candidates, website visitors, members of our community, and other individuals. We do this in a number of ways. We collect information directly from you, such as when you fill out our contact us form, apply for a land license, subscribe to our mailing list, register for and attend our events, send us an email or social media message inquiring about our business opportunities, or submit a job application.

We collect information automatically from you using Cookies and Similar Technology when you visit our websites or engage with certain emails we send. OHNC may also collect information about you from others, such as our employees and shareholders, public sources, data brokers, and people in our network. We may make inferences about you, such as the types of business opportunities that may interest you. This information includes:

• Identifiers such as your name and contact information, including real name, account name, social media handle, IP address, unique online id, cookie identifier, email address, social security number, driver’s license number, or other similar identifiers.
• Demographic information, such as your market area (e.g., Seattle Metropolitan Area) or information about your gender or veteran status.
• Professional and employment-related information, such as your current employer and job title.
• Education information, such as information about your academic qualifications.
• Commercial information, including information about your prior purchases from us, property records, or information we glean about your commercial activity from public sources.
• Content, such as reviews you publish about our businesses, surveys you complete, or content you share with us on social media platforms.
• Financial account information, such as the banking information you provide or the credit card information you share when applying for a land use license.
• Your preferences, interests, and affiliations, such as your contact preferences, meal preferences when you sign up for our events, your professional affiliations.
• Communications, such as when you send us email or engage with us on social media platforms.
• Audio, electronic, visual, or similar information, including voicemail and meeting recordings, security and dash cam footage, and photographs taken at our events.
• Device information, such as information we automatically collect about ‎your operating system, browser, device, or connection when you use ‎our website or Wi-Fi. ‎
• Digital interactions, such as the data we gather about your activities on our website using Cookies and Similar Technology. Such information may include:

• Date and time of your visit to our websites and duration of your visit,
• Your traffic patterns and clickstreams,
• The content you viewed on our website, and
• The website from which you linked to our website.

To learn more about information automatically collected, please see Cookies and Similar Technology section below.

OHNC may process de-identified personal information. Data in this state cannot be used to infer information about, or otherwise be linked to, a particular individual. In those instances, and unless allowed under applicable law, we will maintain such information in a de-identified state and will not use it to later re-identify the individual.

Some of the information we collect, depending on our interactions, may qualify as “sensitive” under certain applicable privacy laws, such as payment card and direct deposit information, sensitive categories of demographic data, criminal background information, and government-issued identifiers. We collect this information as needed to meet our legal obligations, provide our services, enforce our rights, or facilitate the transactions you request.

2. How We Use Your Personal Information

We use your information for a variety of purposes, including to market our businesses, assist shareholders, and operate our facilities. For example, we use your information, to:

In carrying out these purposes, we combine information we collect from different contexts and/or sources to provide you a more seamless and personalized experience, to make informed business decisions, and for other legitimate business purposes.

As described above, depending on our interactions, some of the information we collect may qualify as “sensitive” under certain applicable privacy laws, such as payment card information and certain demographic information. We only collect such sensitive information as necessary to meet our legal obligations, process land use applications, conduct business, or for other legitimate purposes.

3. When We Share Your Personal Information

We share your information with others in a variety of circumstances. We share with your consent, at your direction, or to complete any transaction or request you have authorized. We also share your information in the as outlined in the chart below.

4. Your Rights and Control of Your Personal Information

Privacy laws provide individuals with specific rights regarding their personal information. ‎Depending on where you live, you may have some or all of the following ‎rights and choices regarding your information.

• The right to be informed or to know. You may have the right to be informed of how we process your information. For example, you may have the right to be informed of or to know:
  • The categories of personal information we collect and process about you.
  • The categories of sources for the personal information we collect and process about you.
  • The purposes for collecting or processing that personal information.
  • The categories of personal information shared or disclosed to third parties, the categories of those third parties, as well as the purposes of such sharing or disclosure.
  • If we sell or share your personal information. In some jurisdictions, our use of Google Analytics may be a sale or share of your information.
• The right to access. You may have the right to access or view the personal information we process about you.
• The right of data portability. You may have the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another service.
• The right to correct. You may have the right to request that OHNC correct any of your personal information.
• The right to delete. You may have the right to request that OHNC delete any of your personal information that we collect from you or process, subject to certain exceptions. Once we receive and confirm your request, we will delete (and notify any relevant third parties to delete) your personal information, unless an exception applies.
• The right to not be subject to automated decision making. We do not engage in automated decision making which results in any decision making of serious consequence.
• The right to opt-out. You may have the right to limit our use of your personal information or to opt-out of certain processing of personal information. For example, in some jurisdictions, you may have the right to limit our use of your sensitive personal information and to opt-out of targeted advertising.
• Right to not be discriminated against for exercising your rights. If you exercise your rights, we will not discriminate against you.

You can exercise your rights, as well as make choices regarding OHNC’s collection and processing of your information through various methods and tools. For example, you can:

• Contact us. If you’d like to exercise your rights, or if you have any questions about our privacy practices, please contact us using this form or call us toll free at 877-582-6100.
• Update your account. If you have a myOHNC account, you may log in to update your contact information, view and print your financial history, view information about the shares you own, RSVP for current events, and more.
• Use operating system or browser privacy controls. Most operating systems and browsers provide privacy settings. For example, many browsers allow you to control your interactions with cookies, which will impact the information processed by cookies on our websites. Please refer to your operating system or browser documentation for information on how to access these settings. Your settings may impact your experience with our websites and the functionality available to you.
• Unsubscribe. With each marketing communication, you will be given the opportunity to opt-out of receiving ‎future marketing notices. You may also opt-out of receiving future marketing notices by ‎contacting us using this form or call us toll free at 877-582-6100. If you request that we not contact you for ‎marketing purposes (either by using the unsubscribe mechanism or by sending us an email), we ‎reserve the right to contact you for non-marketing purposes.
• Other Tracking Protections. You may use industry ad choice tools to control how certain third-party advertisers use the information that they collect about you on our online services and third-party sites and apps. You can obtain more information at aboutads.info/choices (Digital Advertising Alliance). You may also download the DAA AppChoices tool in order to help control interest-based advertising on apps on your mobile device. 

You, or someone legally authorized to act on your behalf, may make a request to exercise your rights related to your personal information. We may ask that you:‎

• Provide sufficient information that allows us to reasonably verify you or your authorized representative’s authority to act on your behalf. Where possible, we will attempt to verify your identity by only using we have previously collected from you, such as an e-mail address. DO NOT SEND US SENSITIVE PERSONAL INFORMATION, such as a social security number or picture of photo ID, in your initial request to exercise any rights.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and/or confirm the personal information relates to you. We will deliver our written response by mail or electronically, at your option.

The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

5. Cookies and Similar Technology

Our websites and other services use cookies and similar technology to automatically collect personal information about your use and interactions. Cookies are small files placed on your device to store information, often consisting of a unique personal identifier, for a variety of purposes.

We use cookies to assist you with website navigation, authenticate you, secure our websites, analyze the use and performance of our websites, and measure our audience. We may also use cookies in conjunction with our marketing efforts. We may also hire others, such as a vendor providing analytics services, to place cookies on our digital properties to gather information on our behalf.

We may permit third parties to automatically collect personal information on our websites using cookies and similar technology. We use the information collected through these third parties as described herein. The third parties may use your information for their purposes as well. For example, these cookies may allow them to collect or receive information over time about your online activities from and across different sites and services. You can opt out of certain types of data processing by the third party by visiting the links provided below.

We use Google Analytics to get information about website traffic. Go here to learn how Google processes your data collected using cookies, here to opt-out of Google Analytics, and here for the Google Privacy Checkup.

Please see Your Rights and Control of Your Personal Information for information on controlling cookies and similar Technology.

6. Children’s and Teens’ Data

Our websites are not directed to children or teens. We only collect or use personal information from minors to provide shareholder services. If you are a parent or guardian of an OHNC shareholder and have questions about our use of a minor’s data, contact by ‎contacting us using this form or call us toll free at 877-582-6100. If we learn that we've collected the personal data of a child in violation of applicable law, we will take reasonable steps to delete the personal data.

7. Securing your Information 

We use reasonable and appropriate security measures to protect the confidentiality, integrity, and security of the personal information we process. ‎Unfortunately, no electronic network or methods of transmitting data over the Internet can be ‎guaranteed to be 100% secure. As a result, we cannot ‎guarantee the confidentiality, integrity, and security of the personal information we process.‎

8. Retention and Storage

We consider the following factors when determining how long we retain and store your information:

• Our legal and contractual obligations,
• Our professional and ethical responsibilities,
• The purpose for which your information was collected or processed,
• Your requests to delete the information,
• Retention periods in applicable laws and regulation, and
• Our legitimate business purposes. We may retain your data to the extent it is necessary to prevent fraudulent activity, to protect ourselves against liability, and to allow us to enforce our contractual or other rights and to pursue available remedies and limit any damages we might sustain.

OHNC stores personal information in the United States and other jurisdictions where do business.

9. Links to Third-Party Websites, Products, and Services

This Statement applies only to the information OHNC collects and processes. Our websites or our digital communications could contain links to other websites and services that are not owned or controlled by us. We are not responsible for and have not reviewed the privacy practices of such sites or services, or the owners or operators of such sites or services. We shall not be responsible or liable in any way as a result of your use of any other sites or services.

10. Updates

We may revise this Statement at any time to enhance transparency. We may also update the Statement, as necessary or as useful, in response to (a) changes in applicable laws, regulations, or standards, (b) changes to our processing of personal information, or (c) changes to our business operations. For example, we may modify the Statement if a new applicable law requires additional notices or if we intend to collect new categories of personal information. We will post any revised Privacy Statement here and provide a “Last Updated” date at the top of this Statement. In some cases, we might provide you with additional notice (such as by adding a statement to the homepage our website). We encourage you to review this Statement regularly to stay informed about our processing of personal information, your rights, and your choices.

11. Contact Us

If you have any questions about this Statement or the use of your information, please contact using this form, call us toll free at 877-582-6100, or send us mail to an address below:

Anchorage Office
2702 Denali Street, Suite 100
Anchorage, Alaska 99503

Old Harbor Office
P.O. Box 71
Old Harbor, Alaska 99643

Kodiak Office
194 Alimaq Drive, Suite 219
Kodiak, Alaska 99615