Halo Privacy 

Last Updated on July 16, 2019

At Halo, we strive to create a financial community built on trust and provide a marketplace for Borrowers and Backers to connect. The privacy and security of your personal information are very important to us. If you have any questions at all about this Privacy Policy, please do not hesitate to check out our Frequently Asked Questions (FAQ) for more information or contact us at contact@thehaloapp.com.

 

What’s Covered

  • Applicability of our Privacy Policy

  • What Information Does Halo Collect?

  • How Does Halo Use the Information We Collect?

  • Does Halo Share Your Personal Information?

  • What are Tracking Technologies, such as Cookies and Web Beacons, and How Does Halo Use Them?

  • How Does Halo Secure Your Personal Information?

  • Your Choices Regarding Your Information

  • Links to Third-Party Websites and Services

  • How Halo Responds To Do Not Track signals

  • Children Under 13

  • Users Outside of the United States

  • Contact Us

Applicability of our Privacy Policy

This Privacy Policy (“Privacy Policy”) explains how we collect, use, share and otherwise process information relating to natural persons (“Personal Information”) through the Halo Application and Services operated by us. All capitalized terms not herein defined will have the meaning set forth in our Terms of Use. This Privacy Policy applies to any visitor to or User (including Registered Users) of our Halo Application and Services.

Halo determines the purposes and means of processing Personal Information as described in this Privacy Policy. We may also process Personal Information where your Personal Information was submitted to us by an authorized third party. If you wish to exercise any of your rights with respect to your Personal Information submitted by a third party, please contact the applicable third party directly.

We may update this Privacy Policy from time to time to reflect changes in our privacy practices. If we do, we will notify you of any changes by posting a notice in the Halo Application or by sending a notice to the primary email address specified in your account. Changes that materially affect your rights or our obligations will go into effect 30 days following such notification, at which point we will update the “Last Updated” date at the top of the page. Non-material changes or clarifications will take effect immediately. We encourage you to periodically check the Halo Application and Services and this page for updates.

You acknowledge that your use of our Halo Application and Services indicates to us that you have read this Privacy Policy and consent to the privacy practices described. Your continued use of our Halo Application and Services after we publish or send a notice about any changes to this Privacy Policy indicates that you have read and consent to the updated Privacy Policy.

What Information Does Halo Collect?

 

We collect information, including Personal Information, only where we have lawful bases to do so, such as your consent where you have given it, contract where processing is necessary for us to perform our obligations pursuant to a contract with you, and legitimate interests of our business such as operating and providing the Halo Application and Services to you.

We collect, store, and use the following categories of information, which includes Personal Information:

Information you give us: 

  • For Registered Users, your name, email address, phone number, postal address (including zip code) and any other information you share when you create an account on our Halo Application or otherwise use our Halo Application or Services.

  • Your responses to surveys that we may ask you to complete for research purposes or to help direct Halo activities or improve the Halo Application or Services.

  • Other Personal Information or details about you that you voluntarily submit, which may include your employer and employment information, profession, marital status, date of birth, income and personal financial information, checking account information, and possibly social security number.

  • Contact information for the purpose of the friend referral program.

  • Any information, including your name or email address, you share when you contact us.

 

Information we get from your use of the Halo Application or Services:

  • Details of how you use the Halo Application or Services.

  • Your internet protocol address (i.e., IP address) when using our website and, when accessing the Halo Application and Services from a mobile application, your unique mobile device ID number and non-email authentication.

  • Details of financial transactions, including your loan requests and borrowing activity, you participate in on the Halo Application and Services, including the amount, currency, and method of payment.

  • Your social networking account credentials and information shared with us via your social networking accounts.

  • Browser and device information and information collected through Tracking Technologies (defined below), such as cookies, pixel tags, and other technologies.

  • When you use the Halo Application or Services from a mobile device, that device will send us data about your location based on your phone settings. We will ask you to opt-in before we use GPS or other tools to identify your precise location.

How Does Halo Use The Information We Collect?

 

We use the information you provide to us and we collect through the Halo Application for a variety of purposes, including to improve the Halo Application and Services, refine and customize our technology and algorithms, and innovate ways to forward our mission to help everyone.

In particular, we use the information we collect to:

  • Administer the Halo Application and Services, enable you to use its features, and improve the overall user experience.

  • To accomplish or further our mission – creating a social lending marketplace that provides access to an economy of cash.

  • To verify your identity is true and accurate and to verify income to prove Borrowers have resources to repay loans to Backers and Backers have sufficient funds to provide loans to Borrowers.

  • Create and display a profile to make available and share between Borrowers and Backers, or link to a Borrower’s or Backer’s social networking account.

  • Display lending or borrowing activity for loans made or requested through the Halo Application and Services between Borrowers and Backers.

  • Communicate with you through email, text, SMS, message via social media platforms, telephone, or any other medium for which we have contact information so that we can provide you with information and updates about us, our work, and our community, and to make it easier for you to share such information about us with your social networks.

  • Send information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.

  • Respond to comments and questions and provide technical support and customer support.

  • Analyze how Users use the Halo Application and Services using analytics tools, like Google Analytics, and other tools to help us understand traffic patterns and know if there are problems with the Halo Application or Services.

  • Create targeted advertising to promote the Halo Application and Services and engage the community and our Users.  

  • Protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.

  • Link or combine User Information with other Personal Information in order to provide the Services.

  • Compare information for accuracy, update our records, and verify it with third parties.

 

Does Halo Share Your Personal Information?

 

Halo does not rent, sell, or share your Personal Information with other people or non-affiliated third parties, except with your consent or as necessary to provide any specific service you have requested or authorized, such as sharing certain information between Borrowers and Backers. We do not and will not share your Personal Information with third-party marketers for their direct marketing purposes without your consent.

To help us do our work, Halo may provide limited access to some of your Personal Information to the following third parties:

  • Payment facilitators: We work with payment facilitators to help process payment methods made through the Halo Application and Services. These certified payment facilitators will store certain information about you. Please refer to their privacy policies to learn more about how they use your Personal Information.

  • Service Providers: We work with a wide range of third-party providers, notably our database administrators, cloud computing services, advertising services, data analysts, application service providers, bulk SMS services, and other vendors. We do not authorize them to use or disclose your Personal Information except in connection with providing their services. 

 

We may also transfer your Personal Information to a third party as a result of a merger, acquisition, reorganization or similar transaction; when required by law or to respond to legal process; to protect our customers; to protect lives; to maintain the security of the Halo Application and Services; and to protect the rights or property of Halo. In such an event, and to the extent legally permitted, we will notify you and, if there are material changes in relation to the processing of your Personal Information, give you an opportunity to consent to such changes.

We will also share Personal Information with companies, organizations or individuals outside of Halo if we have a good-faith belief that access, use, preservation, or disclosure of your Personal Information is reasonably necessary to (1) detect or protect against fraud or security issues, to enforce our Terms of Use, (2) meet any enforceable government request, (3) defend against legal claims, or protect against harm our legal rights or safety, or that of our staff or Users.

What is Tracking Technologies, such as Cookies, and How Does Halo Use Them?

We, or third parties we do business with, may use certain technologies to automatically collect log files and other information about your usage of, and the devices you use to access, the Halo Application or Services (“Tracking Technologies”). For example, we may use Tracking Technologies like cookies, log files, web beacons or similar technologies to help us analyze our web and application page flow, customize our services, content and advertising, measure promotional effectiveness, and promote trust and safety.

Even if you are only browsing the Halo website, certain information (including computer and connection information, browser type and version, operating system and platform details, and the time of accessing the Halo Application or Services) is automatically collected about you. This information will be collected every time you access the Halo Application and Services and it will be used for the purposes outlined in this Privacy Policy.

You may delete and block all cookies from the Halo website, but parts of the Halo website may not work. We want to be open about our cookie use. You can reduce the information cookies collected from your browser. An easy way of doing this is to change the settings in your browser or device. If you do make changes, you should know that (a) your use of the Halo Application or Services may be adversely affected (and possibly entirely prevented), (b) your experience of our website, any web-based version of the Halo Application and other sites that use cookies to enhance or personalize your experience may be adversely affected, and (c) you may not be presented with advertising that reflects the way that you use our and other sites. You find out how to make these changes to your browser at this site: www.allaboutcookies.org/manage-cookies/. Unless you have adjusted your browser settings so that it will refuse cookies, our system will send cookies as soon as you visit the Halo website. By using the Halo website and Halo Application, you consent to the described use of Tracking Technologies, unless you change your browser or device settings.  

Web beacons may be used to track the traffic patterns of Users from one page to another in order to maximize web traffic flow. Our third-party advertising service providers may also use web beacons to recognize you when you visit or use the Halo Application or Services and to help determine how you found the Halo Application or Services. If you would like more information about this and to know your choices about not having this information used by these companies, please visit the Digital Advertising Alliance’s website, http://www.aboutads.info/, or the Network Advertising Initiative’s website, http://networkadvertising.org/consumer/opt_out.asp.

How Does Halo Secure Your Personal Information?

Halo makes use of proprietary safe shield technology and best-in-class security tools and practices to maintain a high level of security. We take reasonable steps to protect your Personal Information against unauthorized access, alteration, disclosure, misuse, or destruction, including but not limited to using bank-level security protections. We will only retain your Personal Information for as long as necessary to provide the Services to you and for the purposes we collected such Personal Information for. We also use features in the Halo Application and Services to protect our community and to keep you and your Personal Information safe, such as machine learning and automation to protect users from fraudulent accounts and scammers. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. The safety and security of your Personal Information also depends on you. If you are a Registered User, you are solely responsible for keeping your account details confidential, including any access credentials like passwords or mobile device PINs.

Your Rights Regarding Your Personal Information

You have certain rights with respect to the use of Personal Information on our Halo Application and Services:

 

Accessing, Correcting or Deleting Your Personal Information. You may access, review, update, correct or delete the Personal Information you provided by logging into your account and navigating to the setting tab on the home page in the Halo Application or by contacting us at contact@thehaloapp.com.

 

If you request to update, correct or delete your Personal Information by emailing us, for your protection, we may only share and update the Personal Information associated with the specific email address that you use to send us your request, and we may need to verify your identity before doing so. We will use commercially reasonable efforts to honor your request and will try to comply with such requests in a timely manner. We may retain an archived copy of your records as required by law or for legitimate business purposes.

 

Note: If you completely delete all of your Personal Information, your user account may become deactivated.

 

Delete or Correct Your Information. You may access, correct, amend, or delete Your Information by accessing your user account. You control all of Your Information that you upload or provide through the Halo Application and Services. Information that you delete (including Your Information containing Personal Information) may be retained in archived or backup copies in order to enable you to use certain features like in-app lending and financial histories. For instructions on how to permanently delete Your Information from your account, please contact us at contact@thehaloapp.com. Please note that the permanent deletion of Your Information through this process will impair or disable those features with respect to that information.

 

Deactivate Your Account. If you wish to deactivate your account, you may do so through your profile page. If you do, personally identifiable information associated with your account will be deleted as soon as it is reasonably practical or as required by applicable law. Please note that we may retain information that is otherwise deleted in an anonymized and aggregated form, in archived or backup copies as required pursuant to our records retention obligations or otherwise as required by law.

Download or Access Personal Information. You can ask us for a copy of your Personal Information, as well as information about its processing, and can ask for a copy of your Personal Information (including in machine-readable form) by emailing us at contact@thehaloapp.com.

 

Electronic and Promotional Communications

 

Marketing or Promotional Communications. We may use some of the information we collect for marketing purposes, including communications about new Halo features, products, events, or other opportunities. We will periodically send you free newsletters and e-mails that directly promote the use of our Halo Application or Services.

Application & Transactions Communications. Despite your indicated e-mail or electronic communication preferences, we may send you account, service or transactions related communications, including notices of any updates to our Terms of Use or Privacy Policy.

Opting Out of Electronic and Promotional Communications. If you wish to unsubscribe from the Halo email list, stop receiving promotional communications or to opt-out of the use of your information for marketing or promotional purposes, please follow the opt-out or unsubscribe instructions by clicking "Unsubscribe" (or similar opt-out language) provided in the e-mail or by contacting us directly at contact@thehaloapp.com. However, certain emails are transactional in nature and required by law and cannot be opted out of.

Links to Third-Party Websites and Services

We may provide links to other websites or online services. We have no control over these websites and online services and they are subject to their own terms of use and privacy policies. As such, we do not endorse and are not responsible for the availability of, or for any content, advertising, products, or other materials on or available from, these third party websites or online services.

By using the Halo Application or Services, you agree that we will not be liable for any damage or loss caused by your use of or reliance on any content, advertising, products, or other materials on or available from these third-party websites or online services.

How Halo Responds to Do Not Track Signals

Your browser settings may allow you to automatically transmit a Do Not Track signal to websites and other online services you visit. Halo does not alter our practices when we receive a Do Not Track signal from a visitor’s browser because we do not track our visitors to provide targeted advertising. To find out more about Do Not Track, please visit http://www.allaboutdnt.com.

Children Under 13

The Halo Application and Services are not directed to individuals who are under the age of 13 and we do not solicit nor knowingly collect Personal Information from children under the age of 13. If you believe that we have unknowingly collected any Personal Information from someone under the age of 13, please contact us immediately at contact@thehaloapp.com and the information will be deleted.

A Note to Users Outside the United States

Halo is based in the United States. The Halo Application and Services are controlled and operated by us from the United States and is not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your Personal Information may be collected, transferred to, stored and otherwise processed in any country where we have facilities or in which we engage service providers, and, by using the Halo Application and Services, you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.

Contact Us

If you have any questions about this Privacy Policy, your Personal Information, or the Halo Application or Services, you can contact contact@thehaloapp.com or by mailing us at the below address:

Halo Lending Company

350 Massachusetts Avenue, Suite 300

Indianapolis, IN 46204

Please contact us if you have any complaints or concerns with respect to your privacy. If you believe we are unable to assist you, you have the right to lodge a complaint with a supervisory authority in the relevant jurisdiction. However, we are committed to working with you to resolve any complaint or concern you may have with respect to your privacy.

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