Halopro Privacy Policy

Halopro is committed to protecting your privacy and ensuring the security of your personal data. This privacy policy transparently outlines how we handle your personal information, including our practices related to collection, usage, storage, and disclosure when you use our services. By accessing or using Halopro's services, you agree to this privacy policy and its terms. This privacy policy may be updated without prior notice to users.

The terms used in this privacy policy (such as 'processing' or 'data controller') adopt the definitions in the Personal Data Protection Law (PDPL).

1.1.This agreement applies only to the products and services provided by Halopro (hereinafter referred to as 'we' or 'Halopro').

1.2.This agreement also applies to services and features that may be updated or upgraded by Halopro, including but not limited to websites, interfaces, custom programs, and derivative products or services emerging with technological developments.

1.3.This service is only available to users who have reached the legal age. Users under the legal age are not allowed to use this service or register an account. Therefore, we do not intentionally collect personal information from minors. If you are under 18 years old or have not reached the legal age in your jurisdiction, please do not use this service or provide us with any personal information.

2.1.According to applicable data protection laws, we generally act as the 'data controller' of the personal information we collect. In rare cases, we may act as a 'data processor' and process personal data solely based on the instructions of the data controller or as required by law.

2.2.This privacy policy applies to personal data of data subjects (you) processed by Halopro as the data controller in the United Arab Emirates, regardless of whether you reside or work within or outside of the UAE.

2.3.If you have any questions regarding the processing of personal data or the rights granted by the UAE Personal Data Protection Law (PDPL), please contact our team via email: service@halopro.com.

2.4.As the data controller (or in certain cases as the data processor), we undertake the following responsibilities:

2.4.1.Data Transfer. We will not transfer personal data to countries or regions outside of the UAE unless that region provides adequate protection of the rights and freedoms of data subjects.

2.4.2.If adequate protection cannot be ensured, transfers may be exempted through the following measures:

2.4.2.1.Implementing appropriate safeguards (e.g., standard contractual clauses) to ensure adequate protection.

2.4.2.2.Obtaining explicit consent from the data subject, ensuring the transfer does not violate the public interest of the UAE.

2.4.3.Data Processing Records. We may decide whether or not to retain records of data processing, unless required by law.

2.4.4.Data Breach Notification. Although we are committed to protecting your personal data, breaches may occur for various reasons:

2.4.4.1.If a data breach may jeopardize the privacy, confidentiality, or security of data subjects, the company shall immediately notify the relevant regulatory authorities upon discovering the breach.

2.4.4.2.The notification should include the following details: the nature, category, and cause of the data breach; the affected records and the number of impacted data entries; potential consequences; and the measures the company has taken to address and remedy the breach.

2.4.5.Data Retention. After the purpose of processing has been fulfilled, we will stop storing personal data unless anonymization techniques are used to make it impossible to identify the data subject.

2.4.6.Protection of Sensitive Information. We generally do not process special categories of personal data (e.g., race, political views, religious beliefs, genetic data). However, in certain cases, such as identity verification or other necessary circumstances, we may collect biometric data (e.g., facial images or fingerprints), and this processing will be based on your explicit consent, which you can withdraw at any time.

2.4.7.Controller and Processor Agreement. The processor shall process personal data based on the controller's instructions, in accordance with an agreement between the parties that specifies the scope, purpose, type, and categories of data subjects.

3.1.You acknowledge and agree that we collect your information in the following ways:

3.1.1.To complete the registration, management, and real-name verification of your Halopro account, you need to provide real, legal, and valid personal or company information, including but not limited to your name, email, social media accounts, phone number, contact address, bank account information, and business registration information.

3.1.2.To ensure secure and compliant use of our services, Halopro requires all users to complete real-name verification. You will need to provide your name, ID card, passport, driver’s license, face information, etc. Your account will only be allowed to use the services after passing these verifications. Please ensure that the information provided is legal, true, and valid.

3.1.3.Your identity will be verified through Onfido. For more information about this tool, please visit https://onfido.com/solutions/our-solutions/, and for their privacy policy, please visit https://onfido.com/privacy/.

3.1.4.In certain circumstances, you may authorize our employees or partners to upload or submit your information on your behalf.

3.1.5.Log Data. While you are using this system (website) or service, we may collect and process the following information: IP address, location information, traffic data, transaction data (e.g., deposits, payments, refunds, withdrawal addresses), device information (computer or mobile device), access frequency, duration, page interaction data, operating system, browser type, device type, unique device identifier, cookie data (including third-party cookies), optional form data, crash reports, and performance data.

3.1.6.While using Halopro's self-service features, we may collect personal information such as your name, email, contact information (including phone number and address), company name (for business accounts), industry, partial payment details (e.g., the last four digits of your credit card), account credentials (username and encrypted password), and service usage data (including login records, activity history, and preferences).

3.2.These data are essential to provide the services you request and fulfill the contractual agreements between you and Halopro, such as processing payments or subscriptions through our payment partners. The legal basis for this processing is the performance of a contract under Article 6(1)(b) of the GDPR. Personal data will only be retained for the period necessary to fulfill the initial purpose, unless a longer retention period is required by law. You can contact us anytime to modify or delete your information.

3.3.With your consent, we may securely store your payment information to expedite checkout in the future. The legal basis for storing this data is your consent, as described in Article 6(1)(a) of the GDPR. You can withdraw your consent at any time, but this will not affect processing carried out prior to the withdrawal.

To provide you with high-quality, convenient, and secure services, we use the collected information for the following purposes:

4.1 To provide services to you.

4.2.To fulfill the purposes outlined in 'Information We Collect.'

4.3.To send you product messages, Halopro updates, and other business and advertising communications, including through phone numbers, email addresses, and other contact methods such as SMS, phone calls, and emails.

4.4.To invite you to participate in surveys regarding our products and services.

4.5.To improve and optimize Halopro's online services.

4.6.To comply with legal or regulatory reporting requirements.

We will only share, transfer, disclose, or entrust the processing of your information within the legal and necessary scope, and with your explicit authorization/consent.

5.1.Sharing. We may share your personal data with trusted third-party providers, such as CRM software providers, business development services, email and email tracking providers, live chat support, customer service platforms, hosting companies, data analytics services, and payment processors. We only share necessary data with these providers, and only for tasks related to enhancing our services. If you interact directly with any of these third-party providers, please review their terms and privacy policies for details about what personal data they may collect and process independently.

5.2.Transfer. We will not transfer your personal information to any company, organization, or individual without your explicit consent. As our business continues to develop, we may undergo mergers, acquisitions, asset transfers, or similar transactions, and your information may be transferred as part of such transactions. We will notify you of the receiving party’s name and require them to comply with this privacy policy. If the receiving party changes the purposes or processing methods of personal information specified in this privacy policy, we will require the receiving party to obtain your authorization and consent again.

5.3.Disclosure of Information. We will not disclose personal information that you have not made public or that is otherwise not legally disclosed, except in the following circumstances:

5.3.1.With your prior consent, we may disclose to third parties.

5.3.2.If you are a legitimate intellectual property complainant, we may disclose to the respondent upon request to resolve potential disputes.

5.3.3.As required by law or in response to requests.

5.3.4.If you violate relevant Chinese laws, regulations, or the Halopro Service Agreement or related rules, it may be necessary to disclose your information to third parties.

5.3.5.Your personal information may need to be shared with third parties to provide you with the products and services you request.

5.3.6.In a transaction within Halopro, if any party fulfills or partially fulfills their transaction obligations and requests information disclosure, Halopro has the right to provide the necessary information, such as the contact details of the other party, to facilitate the completion of the transaction or the resolution of any disputes.

5.3.7.Other disclosures deemed appropriate by Halopro based on laws, regulations, or website policies.

5.4.Exceptions to sharing, transferring, or publicly disclosing your personal information. According to relevant laws and regulations, we may share, transfer, or disclose your information without your consent in the following situations:

5.4.1.It is necessary to provide the corresponding functions or services as described in “Section 3: Information We Collect” or for the purposes mentioned in “Section 4: How We Use the Collected Information.”

5.4.2.To fulfill our obligations or exercise our rights under the 《Halopro User Service Agreement》 or this agreement.

5.4.3.It is necessary to fulfill statutory duties or obligations, such as those directly related to national security, defense security, criminal investigations, prosecution, trials, and enforcement of judgments.

5.4.4.It is necessary to respond to public health emergencies or to protect the life, health, and property of individuals in emergency situations.

5.4.5.To carry out public interests such as news reporting and public opinion supervision, within a reasonable scope of personal information processing.

5.4.6.Personal information that users have voluntarily disclosed to the public.

5.4.7.Personal information collected from legally disclosed sources, such as legitimate news reports or government disclosures.

5.4.8.If the data subject has already made their personal data public, as per Article 4 of the Personal Data Protection Regulation, the company may process this personal data without requiring additional consent from the data subject.

6.1.Unless otherwise notified or with your consent, the company will retain your personal information only in the following necessary situations:

6.1.1.To provide the services you have ordered and ensure proper use of the system or account;

6.1.2.To comply with legal and regulatory requirements, including statutory data retention periods;

6.1.3.To support claims or defenses in court proceedings or in response to other judicial procedures;

6.1.4.Log data (see Section 3.1.5) will be retained for at least 6 months from the time of collection. After the account is terminated or suspended, this data will continue to be kept for the same period. The company has the right to extend the retention period for legitimate purposes

6.1.5.All data related to your account, including identification information (if applicable), will be kept during your entire service period as a customer, and will be retained for at least 6 months after the termination of your account.

7.1.To update or delete your personal data, please contact us at service@halopro.com.

7.2.Under the General Data Protection Regulation (GDPR), you have the following rights regarding your personal data:

7.2.1.Access. Understand what personal data we hold about you and how we process it.

7.2.2.Restriction. Request that the processing of your data be restricted if it does not comply with legal requirements or if there are other legal grounds.

7.2.3.Data Portability. Request your personal data in a structured, commonly used, and machine-readable format, or request that your data be transferred to another data controller (applies to data you provided and automatically processed based on consent).

7.2.4.Objection. Object to the processing of your data based on legitimate interests, unless there are compelling legal reasons or legal claims.

7.2.5.Withdrawal of Consent. You can withdraw your consent at any time for data processed based on consent.

If you believe your data rights have been violated, you have the right to file a complaint with your local data protection authority. We encourage you to contact us first at service@halopro.com to resolve your concerns and seek a satisfactory solution.

8.1.If you are residing in the EU, please note:

8.1.1.We are committed to ensuring your rights under the EU General Data Protection Regulation (GDPR). You can learn more about GDPR and your rights at the following link: https://gdpr.eu/.

8.1.2.Under Article 2.2 of the GDPR, non-EU organizations are subject to the GDPR under the following conditions:

8.1.2.1.The organization offers goods or services to EU residents;

8.1.2.2.The organization monitors the online behavior of EU residents;

8.1.2.3.If you are using this system/service, it falls under the scope of Article 2.2 of the GDPR.

8.1.3.Due to specific exceptions in GDPR (such as employee number limits), the scope of our obligations may be limited.

8.2.If you are a resident of California, please note:

8.2.1.We are committed to ensuring your rights under the California Consumer Privacy Act (CCPA) of 2018 (California Civil Code §§ 1798.100-1798.199) and the regulations established by the Attorney General.

8.2.2.Under the CCPA, you have the following rights:

8.2.2.1.Right to Know. Understand the categories and sources of personal information we collect;

8.2.2.2.Right to Disclosure. Know whether your personal information is being sold or shared, and the related details;

8.2.2.3.Right to Opt-Out. Opt out of the sale of your personal information;

8.2.2.4.Right to Deletion. Request the deletion of your personal information;

8.2.2.5.Right to Access. View the personal information we hold about you

8.2.3.Upon receiving a verified request, the company will provide your personal information records from the past 12 months, including:

8.2.3.1.Categories of personal information collected;

8.2.3.2.Categories of sources from which personal information is collected;

8.2.3.3.The business or commercial purpose for collecting the personal information;

8.2.3.4.Categories of third parties with whom we share information;

8.2.3.5.Specific personal information held by the company;

8.2.3.6.A copy of your personal information.

8.2.4.The company commits not to sell your personal information.

8.2.5.If you have any questions or concerns about this privacy policy or the CCPA, please contact our DPO at: service@halopro.com.

8.2.6.We will respond to your requests within the timeframe specified in this policy, but no later than 45 days after the verifiable request is made (with a possible extension of an additional 45 days if needed).

When you use our products/services, we may use cookies and similar technologies to collect some of your personal information, such as your browsing habits, login information, and more. Specific uses of cookies include:

9.1.Remembering your identity. For example, cookies help us recognize you as a registered user, saving you the step of entering your account repeatedly.

9.2.Analyzing your use of our services to understand which features you use most frequently and to provide more personalized service.

9.3.You can reject or manage cookies through your browser settings. However, please note that disabling cookies may prevent you from fully utilizing our services or achieving the best service experience, and certain functions may not be available.

9.4.This agreement also applies to information collected through Halopro cookies.