Privacy Policy

The Halo Foundation Pty Ltd as trustee for the Halo Global Australia Managed Fund (HALO) ABN 19 233 977 612, is registered with the Australian Charities and Not-for-profits Commission (ACNC) and is governed under the laws of NSW Australia.

Halo is committed to protecting our patient information privacy and responsibly handling personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

Halo (“Us, We”) provides a platform through its mobile app (the Halo App) and connects its community of users to be able to request help and provide help to each other. (Collectively referred to as the “Services”),

This Privacy Policy (the “Policy”) describes and governs how we collect, use, share and protect information collected in the context of our Services. Before you use or submit any information through or in connection with the Services, please review this Policy. By using any part of the Halo App, you consent to the collection, use, and disclosure of your information as outlined in this Policy.

The data controller is The Halo Foundation Pty Ltd as trustee for the Halo Global Australia Managed Fund, which is based in Australia. All data shall be collected and stored in Australia.

INFORMATION WE COLLECT FROM OUR USERS

As further described below, when you use or otherwise access the Services, we collect information in various ways, including when you provide information directly to us.

1. Information That You Provide Directly to Us:

1. 1. 1. 1. Registration information:
            When you register for our Services or open an account, we collect your Full name, and email address, your mobile phone number (for purposes of multi-factor authentication and to provide you with important messages) and any other information you choose to provide us (such as a profile picture).

            We don’t collect any of your financial information or any other personal information you provide us.  Halo Foundation Pty Ltd as trustee for the Halo Global Australia Managed Fund, uses a third party payment processors Braintree (PayPal) who manages all donations using the Payment Card Industry Data Security Standard (PCI DSS) set of security standards designed to ensure that ALL companies that accept, process, store or transmit credit card information maintain a secure environment.

         2. Creation of a profile:

            When you create a profile on the Halo App, we collect the information you choose to provide us in relation to your profile, and we display it through our Platform. You might, in creating a profile, provide us with information relating to third parties, and in doing so, you disclose personal information of that third party.  By providing this information, you consent to our collection, storage and use of your data and warrant that you have permission to provide us with this data.  We reserve the right to identify you as the person who has made the referral in any messages that are sent out.

         3. Public Communications:
            You can post comments, leave feedback, send thank-you notes or otherwise communicate with other users through our Platform. Any content, including such comments, feedback, and notes that you choose to post through our Platform, are available to the public by default.
         4. Sensitive Health Information:
            If you choose to provide us with sensitive medical information as part of a funding campaign, you acknowledge that this will be available to other users within our community to view. You authorise Us to store, share and use this information in accordance with our business practices.
         5. Data from Other Services:
            Halo may use other third-party services to improve the quality of our own customer database so that we might improve our Services to you.  If you would like to opt-out of these efforts, please contact us via the Halo App.
         6. Data Deletion: 
            To delete your Halo account and remove all user data, the Halo user will need to first navigate to their “Profile”. Simply click on the “Profile” button on the bottom navigation panel, tap the “Settings” icon and select “Account Details”. Once you have completed these steps, click on “DELETE ACCOUNT” button. This action will remove all the user’s information from the Halo database.
         
         

2. Information That is Passively or Automatically Collected:

1. 1. 1. 1. 1. Device & Usage Information:
               When you interact with Us, we automatically receive and store certain information from devices you use to access the Services. This information is collected passively using various technologies and includes the type of mobile device you use, your operating system, and location data through an IP address. We use to store this information in the following way:
            2. Cookies and Other Electronic Technologies:
                When you interact with the Services, we try to make that experience simple and meaningful. We may use cookies or other electronic technologies (such as web beacons or pixel tags) for various purposes.

OUR USE OF INFORMATION COLLECTED

Halo uses the information collected from the Services in a manner that is consistent with this Policy. We use the information that you provide (or otherwise permit the Services to access) for the following purposes:

1. 1. 1. 1. 1. Communicating With You
                We use the information we collect to contact you for administrative purposes.
            2. Mobile Services: If you access the Services through a mobile device and if you have chosen to provide us with your mobile number or other electronic means to your mobile device, you agree that we can communicate with you regarding your Halo account by SMS, MMS, text message.  Further, when setting up your Halo account, if you click “Send code” by “Text Message,” you agree to receive automated text messages related to your account from or on behalf of Halo at the phone number provided.  You can reply STOP to such text messages to cancel.  Message frequency will vary.
            3. Providing the Services
                We use the information we collect to operate, maintain, and provide our Services, such as enabling access to the Platform, customer support or to complete transactions.
            4. Security and Fraud Prevention
                We use the information we collect to secure our Services and to verify identity, prevent fraud.
            5. Analytics, Research and Product Development
                We use the information we collect to analyse data usage trends and preferences in order to improve the accuracy, effectiveness, security, usability or popularity of our Services.  We further use data in connection with our research on our customer demographics, interests and behaviour.
            6. Legal
                We use the information we collect to defend our legal rights, comply with state, local, federal or international laws, and enforce our Terms of Service and this Policy.

OUR DISCLOSURE OF INFORMATION COLLECTED THROUGH THE SERVICES

There are certain circumstances in which we share information collected through the Services with certain third parties without further notice to you, as set forth below.

1. 1. 1. 1. Agents, Consultants, Vendors and Third Related Parties:
             Halo contracts with other companies to perform certain business-related functions on Our behalf. We provide access to or share your information with these companies so they can perform services for us.
         2. Legal Requirements:
             We can access, disclose, transfer and preserve your information when we have a good faith belief that doing so is necessary to (i) comply with the law including with subpoenas, search warrants, court orders, and other legal process; and respond to inquiries or requests from government, regulatory, law enforcement, public authorities, or content protection organisations; (ii) protect and defend the legal rights, privacy, safety or property of Halo, its affiliates, subsidiaries, employees, agents, contractors, or its users; (iii) permit us to pursue available remedies, commence, participate in, or defend litigation, or limit the damages we may sustain; or (iv) enforce this Policy or any applicable Terms of Service.
         3. Your Consent
             We may share your information in the event that you consent to the sharing of your information.
         4. Aggregated Data
             We aggregate, anonymize and/or de-identify information collected actively or passively about you so that the information no longer relates to you individually.  We then use that data for various lawful purposes, including but not limited to our research on our customer demographics, interests and behaviour. We also share this information with our affiliates, agents, business partners, research facilities or other third parties (e.g., Google Analytics).
         5. Cookies and Other Electronic Technologies
             Information is shared as stated in the Section entitled “Cookies and Other Electronic Technologies.”
         6. Other Users of Our Services
             We provide your information to other users of our Services if you choose to make your information publicly available in a publicly accessible area of the Services, such as in your fundraiser or in the comments.

CHILDREN

Our Services are not designed for use by individuals under the age of 13. If you are under the age of 13, please do not use the Halo App and/or submit any information through the Services.

SECURITY

Halo has implemented technical and organisational security measures to protect the information provided via the Services from loss, misuse, unauthorised access, disclosure, alteration, or destruction. 

RETENTION OF YOUR INFORMATION

We retain your information for as long as we deem necessary for the purpose for which that information was collected and for our legitimate business operations; provided, however, that your information is only retained to the extent permitted or required by applicable laws. When we no longer need to retain your information, we will take reasonable steps to remove it from our systems and records and/or take steps to anonymize it so that you can no longer be identified from it in accordance with our internal document retention policies.

YOUR RIGHTS

You can access and correct certain information about you by visiting the “Account Settings” portion of the Halo App. You can control whether certain information you post is publicly available to others by adjusting the settings in your account. You can also request in writing copies of personal information about you held by us. If that information is inaccurate, please let us know and we will endeavour to make the necessary amendments, erase, or block the relevant information as you request.

CHANGES TO PRIVACY POLICY

We reserve the ability to update or modify this Policy at any time and from time to time. We will notify you of any updates or changes we make to this Policy. If you disagree with our revisions to the Policy, you can deactivate your account or discontinue the use of the Halo App.

CONTACTING Halo

You can contact us at

help@halocharity.com