Privacy Notice

Last Updated and Effective as of: September 30th, 2024

Protect Animals With Satellites LLC, d/b/a Halo, (“Halo,” “Company,” “we,” “our,” or “us”) understands that privacy is important to our users. Protecting your private information is our priority. This Privacy Policy discloses our practices regarding information collection and usage for: (a) www.halocollar.com  (the “Website”) and the Halo mobile application (“Mobile App”), (b) your purchase of any Halo products  (“Products”) and the communications and services we provide (“Services”); and (c) information you provide when applying for employment with us.  The Website and Mobile App are collectively referred to as the ”Applications”.  Products and Services are collective referred to as “Services”).

Overview:

• We collect Personally Identifiable Information (as defined below) from users of our Applications  and Services, and when you apply for employment with us when it is voluntarily provided to us, and we use it for the purposes for which it was provided (see Information We Collect Directly From You). 
• We automatically collect information from users of our Applications and Services for analytical purposes (see Information We Collect From You Automatically). 
• We will not use or share information we collect from you with anyone except as described in this Privacy Policy.

 

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we treat it. If you do not agree with our policies and practices, you should not use the Applications, the Services or apply for employment with us.  By accessing or using the Applications or Services or by applying for employment with us, you agree to this Privacy Policy. If you have questions, you can always contact us using the information in the section below titled Contact. 

Information We Collect Directly From You: 

We may collect information, including Personally Identifiable Information, when you provide such information to us directly, such as when you send us an email, or otherwise interact with us on the Applications, including creating an account (including through Single Sign-On through Facebook, Google, Apple, etc.), use the Services, including purchasing Products or signing up for a subscription for the Services, signing up to be an affiliate in our Affiliate Marketing Program, or apply for employment with us.  We may also collect your shipping address, email and phone number when you purchase a Product through one of our authorized retailers who will provide this information to us to process and fulfill your order.  Your provision of your Personally Identifiable Information to us is completely voluntary. “Personally Identifiable Information” is information that specifically identifies you.  We do not collect Personally Identifiable Information unless you submit that information to us.  Categories of Personally Identifiable Information we collect directly from you include identity data (e.g., name or other similar identifiers, including username), passwords, and contact data (e.g. address, email address, mailing address, billing address, and telephone number).  We may also collect other information that you directly provide us including marketing and communications data (e.g., your preferences in receiving marketing from us).   We may provide a means to supply data necessary to process your payment if you purchase our Products, such as your payment instrument number (such as a credit card number) and the security code associated with your payment instrument.  However, this payment data is processed and stored by one of the following payment processors:  Stripe, PayPal, Venmo and Affirm.  Your payment information is subject to their terms and conditions, including the terms of their privacy policies.  

Information We Collect Automatically:

Halo, our service providers, or our third-party partners may also automatically collect information from you when you visit our Applications and use our Services through cookies and other tracking technologies. Such information does not directly identify you as an individual and may include:

• Cookies and Similar Technology

We may store some information on your device or device hard drive in the form of a cookie or similar type of file (such as clear gifs, web beacons, tags, and similar technologies that work on mobile devices) to collect data related to usage of the Applications or our other Services. “Cookies” or mobile IDs are pieces of information that may be placed on your computer by a website or mobile application for the purpose of collecting data to facilitate and enhance your communication and interaction with that Application.  Such data may include, without limitation, the address of the applications you visited before and after you visited the Applications, the type of browser you are using, your operating system, system configuration information, internet service provider, your Internet Protocol (IP) address, what pages in the Applications you visit and what links you clicked on, the region where your device is located, and geo-IP data. We may use cookies or mobile IDs to customize your visit to the Applications and for other purposes to make your visit more convenient or to enable us to enhance our Services.

 

• Clickstream

As you use the Internet, a trail of electronic information is left at each website or mobile application you visit. This information, which is sometimes referred to as “clickstream data,” can be collected and stored by an Applications’ server. Clickstream data can tell us the type of computer and browsing software you use and the address of the website or mobile ID from which you linked to the Applications. We may collect and use clickstream data as a form of aggregate information to anonymously determine how much time visitors spend on each page of our Applications, how visitors navigate throughout the Applications and how we may tailor our Applications to better meet the needs of visitors. This information will be used to improve our Applications and Services. 

 

• Analytics

We may work with third-party service providers who use the technologies described in this section to conduct analytics to help us track and understand how visitors use our Applications and Services.

 

• Geolocation Data

When you sign up for an account and use the Halo Collar mobile app, we will request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application to provide certain location-based services: using the Halo Collar, setting up fences as part of the Services or our “Walk” service that allows you to track your walks with the Halo Collar.  We may request access or permission to use certain features from your mobile device, including your mobile device’s Bluetooth, camera, application log data, sensors, microphone or other features.  How much information we collect depends on the type of settings of the device you use to access the Services. You can opt out of allowing us to collect your mobile device information either by refusing access to the information or by disabling the location sharing setting on your device.  However, if you choose to opt out, you may not be able to use certain aspects of the Services.  The Services also collect location-based information from your Halo Collar whenever it is used.  This geolocation data is provided by using Global Navigation Satellite System (“GNSS”) in combination with other wireless communication (e.g., cellular, Bluetooth or Wi-Fi) to determine your animals’ location while using the Halo Collar and relaying such information to us.  This location information is the location of the Halo Collar device.  

Push Notifications. We may request to send you push notifications regarding your account or certain features of the Applications. If you wish to opt out from receiving these types of communications, you may turn them off in your device’s settings.

How We Use Your Information

We use Personally Identifiable Information and other information as described herein for the following purposes:

• To contact you about and provide you with our Services, including customer support, including through the “Halo Dog Park”(dogpark.halocollar.com);
• To create, maintain, customize, and secure your account with us, and to personalize your experience on the Applications and Services;
• To enable you to purchase our Products and Services and to fulfill and manage your orders and subscriptions, payments, returns, and exchanges made through the Services;
• To operate the Applications and to provide you with the Services you requested;
• To deliver marketing and promotional communications, including content and product and service offerings relevant to your interests;
• To provide you advertising for Products and Services that may be of interest to you;
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and fulfillment;
• To post testimonials regarding our Services;
• To help maintain the safety, security, and integrity of our Applications, Services, databases and other technology assets, and business;
• For internal research; for technological development and demonstration; and to improve, upgrade, or enhance our Applications and Services;
• For detecting security incidents; protecting against malicious, deceptive, fraudulent, or illegal activity; and prosecuting those responsible for that activity;
• To investigate suspected fraud, harassment, or other violations of any law, rule, or regulation, or our  policies;
• As required by law or legal process;
• To respond to your direct inquiries;
• To add you to our mailing lists and send emails to you from time to time; and
• For any additional purposes that you specifically consent to. 

 

We reserve the right to supplement your Personally Identifiable Information with information we gather from other sources which may include information we gather from online and offline sources. We also reserve the right to use and disclose information that is not Personally Identifiable Information in any manner permitted by law except as otherwise provided in this Privacy Policy. Finally, we may permit our vendors and subcontractors to access your Personally Identifiable Information, but they are only permitted to do so in connection with performing services for us. They are not authorized by us to use the information for their own benefit.

Non-Personally Identifiable Information:

As noted above, we may collect information that is not Personally Identifiable Information (“Non-Personally Identifiable Information”).  We may aggregate or de-identify Personally Identifiable Information so that the information does not personally identify you or anyone else, such as by using Personally Identifiable Information to calculate the percentage of our customers who live in a particular area.   Because Non-Personally Identifiable Information, including aggregate or de-identified information, does not personally identify you, we may collect, use and disclose Non-Personally Identifiable Information for any purpose permitted by law. In some instances, we may combine Non-Personally Identifiable Information with Personally Identifiable Information. If we combine any Non-Personally Identifiable Information with Personally Identifiable Information, the combined information will be treated by us as Personally Identifiable Information.

How We Share Your Information

 

Besides using your Personally Identifiable Information ourselves, we may send your Personally Identifiable Information and other information to other companies, affiliates, and third parties in the following instances:

• Service Providers. We may share your Personally Identifiable Information with third parties who may use your information to provide services to us such as shipping and receiving Products, website hosting, data analysis, infrastructure provisioning, information technology services, customer service, e-mail delivery services, auditing, and anti-fraud monitoring. These third parties may have access to Personally Identifiable Information that is necessary to perform their functions. 

• Legal Compliance and to Defend Our Rights. We may disclose Personally Identifiable Information and other information as we believe necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

• Business Transfers. We may share your Personally Identifiable Information and other information with third parties in connection with a corporate restructuring, acquisition, or divestiture.
• Aggregated or Non-Personally Identifiable Information. We may share aggregated information or Non-Personally Identifiable Information with unaffiliated third parties, such as business partners, manufacturers, distributors, and retailers, in a form in which the shared information will not contain nor be linked to any Personally Identifiable Information, to improve and enhance your experience using the Website and Services, and for our market research activities.

Please note that if you specifically consent to additional uses of your Personally Identifiable Information, we may use your Personally Identifiable Information in a manner consistent with that consent. 

Payment Information

We do not directly collect your payment information. Rather, that information goes directly to our payment processors, Stripe, PayPal, Venmo and Affirm.  We only retain the last 4 digits of your payment method. Your payment and other information collected by Stripe, PayPal, Venmo and Affirm shall be processed according to their privacy policies located at https://stripe.com/privacy; https://www.paypal.com/us/webapps/mpp/ua/privacy-full; https://www.affirm.com/privacy; and https://www.venmo.com/legal/us-privacy-policy/.

Security 

The security of your information is very important to us. We attempt to provide for the secure transmission of your information from your devices to our servers by utilizing encryption technology and software. However, due to the inherent open nature of the Internet, we cannot guarantee that communications between you and Halo, or information stored on the Applications, our Services, or our servers, will be free from unauthorized access by third parties such as hackers, and your use of the Applications or Services demonstrates your assumption of this risk.  We have put in place reasonable physical, electronic, and managerial procedures to safeguard the information we collect.  Only those employees who need access to your information in order to perform their duties are authorized to have access to your Personally Identifiable Information. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us at privacy@halocollar.com or Toll Free at (855) 617-7029.

Data Retention

We will retain your information for as long as your account or inquiry is active or as needed to provide you with the Applications or Services and for a reasonable time thereafter in accordance with our standard procedures or as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements. Even if we delete some or all of your information, we may continue to retain and use anonymous or aggregated data previously collected. Please note that we will not be liable for disclosures of your data due to errors or unauthorized acts of third parties.

Protection for Children

Our Applications and Services are intended for ages 18 and over. We do not knowingly collect Personally Identifiable Information from minors. When we become aware that Personally Identifiable Information (or other information that is protected under applicable law) from a child under 13 (or such other age as may be restricted under local law) has been collected, we will use all reasonable efforts to delete such information from our database. If you believe we might have any Personally Identifiable Information from or about a child under 13, please contact us at privacy@halocollar.com or Toll Free at (855) 617-7029.

Other Websites and Social Networking Services

As a convenience to you, we may provide links to third-party websites, apps, or services from within the Applications or Services. We are not responsible for the privacy practices or content of these third-party sites, and by providing a link we are not endorsing or promoting such third-party sites. When you navigate away from our Applications or Services, you do so at your own risk. We encourage you to read the policies and terms of every website, app, or service you visit.

The Applications or Services may integrate with social networking services. We do not control such services and are not liable for the manner in which they operate. While we may provide you with the ability to use such services in connection with our Applications or Services, we are doing so merely as an accommodation and, like you, are relying upon those third-party services to operate properly and fairly.

You should be aware that Personally Identifiable Information which you voluntarily include and transmit online in a publicly accessible blog, social network, or otherwise online may be viewed and used by others. We are unable to control such uses of your Personally Identifiable Information, and by using such services you assume the risk that the information provided by you may be viewed and used by third parties.

Opt-Out

To opt out of any future promotional messages from us, you should submit an unsubscribe request to us at privacy@halocollar.com.  We will process your request within a reasonable time after receipt. Please note that if you opt out in this manner, certain aspects of the Website or Services may no longer be available to you.

If you want to stop or restrict the placement of cookies or flush any cookies that may already be on your computer or device, please refer to and adjust your web browser preferences. Further information on cookies is available at www.allaboutcookies.org. By deleting our cookies or disabling future cookies, you may not be able to access certain areas or features of our Website or some of its functionality may be affected. 

Please note that, unless required by law, we do not respond to or honor “do not track” (a/k/a/ DNT) signals or similar mechanisms transmitted by web browsers.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Log into your account settings and update your user account.

• Contact us using the contact information provided.

 

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt out of interest-based advertising by advertisers on our Services visit http://www.aboutads.info/choices/

California “Shine the Light”

Under California Civil Code Section 1798.83 (“Shine the Light”), California residents have the right to request in writing from businesses with whom they have an established business relationship: (a) a list of the categories of personal information, as defined under Shine the Light, such as name, email address, and mailing address, and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes; and (b) the names and addresses of all such third parties. To request the above information, please contact us by email at privacy@halocollar.com. If you do not want your Personally Identifiable Information shared with any third party who may use such information for direct marketing purposes, then you may opt out of such disclosures by sending an email to us at privacy@halocollar.com. 

Additional EU Disclosures

IF YOU ARE SITUATED IN THE UNITED KINGDOM OR THE EUROPEAN ECONOMIC AREA, THIS SECTION APPLIES TO OUR COLLECTION, USE, AND DISCLOSURE OF YOUR PERSONAL DATA AND ADDITIONAL RIGHTS YOU HAVE UNDER APPLICABLE LAW.

Legal Basis:

We will only use your personal data, as that term is defined under the General Data Protection Regulation (“GDPR”), when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where you have consented to a certain use of your personal data.
• Where we need to comply with a legal or regulatory obligation.

To the extent permitted under applicable laws, we will also process, transfer, disclose, and preserve personal data when we have a good faith belief that doing so is necessary. 

Data controller:

Halo is the data controller of all personal data collected through our Applications and Services. To contact us, please see the section titled Contact. 

If you are situated in the UK or EU and have any complaints regarding our privacy practices, you have the right to make a complaint at any time to your local supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach your supervisory authority so please contact us in the first instance. If you have a complaint, please contact our privacy manager can be contacted here: privacy@halocollar.com.

Provision of personal data and failure to provide personal data:

Where we need to collect personal data by law or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may not be able to provide certain services to you.

Collection of personal data from third party sources:

We do not collect personal data about you through public sources. We may obtain personal data and other information about you through our third-party partners who help us provide our products and services to you. 

Withdrawing your consent:

If we are relying on your consent to process your personal data, you have the right to withdraw your consent at any time by contacting us at privacy@halocollar.com.

Data Transfer:

We may transfer personal data from the EU or UK to the USA and other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in the EU or the UK. For more information about how we transfer your data, please contact us at privacy@halocollar.com..

Use of your personal data for marketing purposes:

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:

• Promotional offers from us:  We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. You will receive marketing communications from us if you have requested information from us or used our services and, in each case, you have consented to our use of your personal data for marketing purposes.

Data Subject Rights:

If you are a situated in the EU or UK , under the GDPR, as a data subject or some jurisdictions in the US, you have the right to: 

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

To exercise these rights, please fill out this form. Please note that in order for you to assert these rights, we may need to verify your identity to confirm your right to access your personal data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. In order to verify your identity, we may need to gather more personal data from you than we currently have.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html

CANADA 

In some regions (like Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us at privacy@halocollar.com or calling us at (855) 617-7029

We will consider and act upon any request in accordance with applicable data protection laws.

 

Changes to policy: 

We reserve the right, at our discretion, to change, modify, add, or remove portions from this policy at any time, provided that any such modifications will only be applied prospectively. Your continued use of the Applications or Services following the posting of any changes to this policy means you accept such changed. The updated version will be indicated by an updated  “Revised” date and the updated version will be effective as soon as it is accessible. 

Contact: 

If you have questions or comments about this policy, please contact privacy@halocollar.com,  or call (855) 617-7029, or by mail to:

Protect Animals With Satellites, LLC
50 Tice Boulevard
Suite 340
Woodcliff Lake, NJ 07677
United States

Attention:  Legal Department

 

CCPA Privacy Notice

The California Code of Regulations defines a “resident” as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose and

(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as “non-residents.”

If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.

 What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months::

Category	Examples	Collected
A. Identifiers	Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name	YES
B. Personal information categories listed in the California Customer Records statute	Name, contact information, education, employment, employment history, and financial information	YES
C. Protected classification characteristics under California or federal law	Gender and date of birth	NO
D. Commercial information	Transaction information, purchase history, financial details, and payment information	YES
E. Biometric information	Fingerprints and voiceprints	NO
F. Internet or other similar network activity	Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements	YES
G. Geolocation data	Device location	YES
H. Audio, electronic, visual, thermal, olfactory, or similar information	Images and audio, video or call recordings created in connection with our business activities	YES
I. Professional or employment-related information	Business contact details in order to provide you our services at a business level or job title, work history, and professional qualifications if you apply for a job with us	YES
J. Education Information	Student records and directory information	YES
K. Inferences drawn from other personal information	Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics	YES

 

We may also collect other personal information outside of these categories instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels including visiting the Dog Park whether via Applications or website: dogpark.halocollar.com;

• Participation in customer surveys or contests; and

• Facilitation in the delivery of our Services and to respond to your inquiries.

2. Personal Information We Collect About California Consumers

We describe the Personal Information we have collected about consumers in the twelve (12) months preceding the effective date of this Privacy Policy in the part of our Privacy Policy titled, “Personal Information Collected” above. 

3. Disclosure, Sale, or Sharing of Personal Information.

Under the CCPA, the disclosure of Personal Information that is necessary to provide you with the Services and with some of our partners may be considered “selling” or “sharing”, even if no money is exchanged. In that respect, we may disclose email addresses and contact information to other businesses and third parties that include our joint marketing partners when we host webinars and events with them within the twelve (12) months preceding the effective date of this Privacy Notice.

We do not have actual knowledge that we sell or share the Personal Information of California residents under the age of 16.

4. Your Rights

If you are a California resident, you may have certain rights in relation to the processing of your Personal Information. These may include the following:

Right to Know and Access Personal Information.  

You have the right to request, no more than twice in a 12-month period, that we disclose to you the categories and specific pieces of Personal Information we have collected about you. Specifically, you have the right to request that we disclose the following to you:

• The categories of Personal Information we have collected about you;
• The categories of sources from which the Personal Information is collected;
• Our business or commercial purpose for collecting, selling, or sharing Personal Information;
• The categories of third parties with whom we share Personal Information;
• The specific pieces of information we have collected about you;
• The categories of Personal Information about you, if any, that we have sold or shared, and for each category identified, the categories of third parties to whom we sold or shared that particular category of Personal Information;
• The categories of Personal Information about you that we disclosed for a business purpose, and for each category identified, the categories of third parties to whom we disclosed that particular category of Personal Information.

We will deliver Personal Information that we are required by law to disclose to you in the manner required by law within forty-five (45) days after receipt of a verifiable request, unless we notify you that we require additional time to respond, in which case we will respond within such additional period of time required by law. We may deliver the Personal Information to you through your account, if you maintain an account with us, or electronically or by mail at your option. If electronically, then we will deliver the information in a portable and, to the extent technically feasible, in a readily usable format that allows you to transmit the information from one entity to another without hinderance. If we receive a Right to Know request regarding information that we process on behalf of our Client, we will also recommend that the California resident submit a Right to Know request directly with the Client and will provide contact information for that client where feasible.

Right to Deletion of Personal Information.  You have the right to request that we delete Personal Information about you that we have collected from you. If we are able to verify your identity or the identity of your authorized agent, we will respond to your request by deleting your Personal Information and, if applicable, directing any of our service providers to delete your Personal Information.

We may choose to delete Personal Information by de-identifying, aggregating, or completely erasing the information. We will specify the manner in which we delete your Personal Information. If a California resident submits a request to delete Personal Information to one of our Clients and the Client instructs us to delete the California resident’s Personal Information, we will delete the information as required by the CCPA. If we receive a Right to Deletion request regarding information that we process on behalf of our client, we will also recommend that the California resident submit a Right to Deletion request directly with the Client and will provide contact information for that Client where feasible.

In some situations and as permitted by the CCPA, we may not be able to process your request to delete if we need to maintain your information for some legally permissible purpose (e.g., to comply with our legal obligations). We will let you know if we are unable to process your request.  

Right to Correct Personal Information.  You have the right to request that we correct any inaccurate information that we maintain about you.

Right to opt Out of Sale or Sharing.  You have the right to opt-out of the “sale” or “sharing” of your Personal Information, as those terms are defined in the CCPA. To Opt-Out, click here.

Right to Limit the Use of Your Sensitive Personal Information.  You have the right to limit our use of your sensitive Personal Information to the purposes outlined in Cal. Code Regs. tit. 11, § 7027(m) of the CCPA regulations. We do not collect, use, or disclose your sensitive Personal Information for purposes other than those listed in § 7027(m).

Right to Non-Discrimination.  We may not discriminate against you because you have exercised any of the foregoing rights, including by:

• Denying you, our Services;
• Charging different prices or rates for our Services, including through the use of discounts or other benefits or imposing penalties;
• Providing you a different level or quality of our Services; or
• Suggesting that you will receive a different price or rate for our Services or a different level or quality of our Services.

However, we may charge different prices or rates or provide a different level or quality of our Services, if that difference is reasonably related to the value provided to us by your Personal Information.

5. Requests to Exercise Your Rights.  Only you or a person that you authorize to act on your behalf may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child if you believe we have received their information inadvertently. You may request to exercise the aforementioned rights by:

• Submitting a request to privacy@halocollar.com or filling out this form
• Calling us toll-free at (855) 617-7029

Please note that we may take steps to verify your identity and residency before granting you access to information or acting on your request to exercise your rights, as required or permitted by law. If you use an authorized agent, we may require proof of written authorization you have given to make the request. We may limit our response to your exercise of the above rights as permitted by law. We will confirm receipt of your request and comply with your request in the time period required under the CCPA.

If a request or series of requests are manifestly unfounded or excessive, we may charge a reasonable fee for processing the request(s) or may refuse to process the request(s).

If you have implemented an opt-out preference signal (sometimes known as a global privacy control) through your browser or device, we will treat that opt-out preference signal as a valid request of your Right to Opt-Out. Once we recognize the opt-out preference signal on our Services, we will automatically apply your Right to Opt-Out to the browser or device through which we recognize the signal. The Services respond to opt-out preference signals in a frictionless manner (i.e., you do not need to take any additional steps for your opt-out preference signal to be recognized). To learn more about opt-out preference signals, please visit https://globalprivacycontrol.org.

6. Data Sharing for Direct Marketing Purposes

California Civil Code § 1798.83 further permits California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. If you are a California resident, you may ask us to refrain from sharing your Personal Information with certain of our affiliates and other third parties for their marketing purposes. Please tell us your preference by contacting us at privacy@halocollar.com or by writing us at the address found in the “Contact Us” section.