Table of Contents
We appreciate that you trust us with your information, and we intend to honor that trust.
PERSONAL INFORMATION WE COLLECT
There are several ways we may obtain information about you, including through (A) information you provide to us directly; (B) information that we automatically collect; and (C) information we receive from third parties. Some of the information directly or indirectly identifies you as an individual. When information identifies or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household, we refer to it as “Personal Information.” This Personal Information includes the following categories:
- Identifiers/Contact Information: These include your name, postal and email address, phone number, and unique identifiers that may identify your device or browser but not you by name.
- Location Data: data about the location of the device you use to access the Services as more fully described below.
- Commercial Information: Your purchase and usage history (such as cooking time, temperature, and equipment health for your Halo Products), and goods and service preferences, including payment information or photos you share from your devices.
- Internet/Electronic Activity: Your geolocation information, IP address, web/app browsing and search history related to our Services, and information regarding your interaction(s) with the Services or HPG advertising.
- Profile Inferences: The inferences that we draw from your Personal Information and online activity to create a personalized profile so we can better identify goods and services that may be of interest.
We also work with various types of data that are de-identified or aggregated, and not reasonably capable of being associated with, or reasonably be linked, directly or indirectly, with you or your household. This data is not Personal Information.
Personal Information You Provide
HPG collects Personal Information when you choose to share it with us, such as:
Personal Information you provide when you create or use your account or other Services, or contact us. You must create a HPG account (“HPG Account”) to use certain Services, including the Halo Hub App. A HPG Account as well as certain services we may offer such as subscription to our auto-delivery services require you to provide Personal Information so we can identify you and process your purchases, enable you to customize the Services to your liking (e.g., identify your brewing preferences), and so we can link your product preferences to your HPG Account. Also, when you contact us, we may monitor and record your conversation with the HPG representative (where permitted by law).
Personal Information you provide when you make a purchase. We collect Personal Information to process your purchases from us, and to provide you with the goods or services you ordered.
Personal Information you provide for customer support. We collect your feedback and questions that you provide to us for customer support. In answering your questions, we may collect supporting data from your device.
Personal Information collected with your consent. We also may ask you for your consent to collect Personal Information in a particular interaction with you as described to you in those circumstances.
Personal Information Collected Automatically
Whenever you visit or interact with the Services, HPG, as well as third-party advertisers and/or service providers, may use a variety of technologies to collect Personal Information, such as:
Usage Information. We collect Personal Information about your activity on the Services, such as login date and time, features you use, brew preferences, and website, mobile app, and product interactivity.
Device & Device Usage Information. We collect Personal Information from and about the electronic devices that you use to access the Services, including IP address, device ID and type, device and app settings and characteristics, app crashes, advertising IDs, browser type and language, operating system, time zones, software version, domain name, identifiers associated with cookies or other technologies that may uniquely identify your device or browser, and information on your wireless and mobile network connection, like your service provider and signal strength. Our Internet connected devices, such as our smart devices, may also include a camera designed to collect an image of the area where a pod is positioned within the brewer. This may be required to enable some connected Services and may also be used for diagnostic purposes to help ensure the brewer is working properly. Through this use, we collect Device Information associated with your HPG product, but not other Personal Information.
Location Information. We may collect data about the location of the device you use to access the Services (“Location Data”) using IP address, GPS, cellular towers and information from your mobile service provider, sensors that provide HPG with information on nearby devices, Bluetooth address, Wi-Fi access points, and information made available by you or others that indicates the current or prior location of your device. How we collect Location Data depends on how you use the Services.
Third Party Analytic and Advertising Technologies. HPG also may use third parties’ analytics and tracking tools, such as Google Analytics, and others, to help us track, segment, and analyze usage of HPG Services, and to help us or those third parties serve more targeted advertising to you on the Services and across the Internet. These tools may use technology such as cookies, web beacons, pixel tags, log files, Flash cookies, or other technologies to collect and store information and may also combine such information with information that they collect from other sources. HPG also may use session replay software, which collects information about your interaction with the Services, including keystrokes, mouse movements, and form field entries, and may monitor your interactions with the Services, including for our compliance verification purposes. To learn more about your choices relating to advertising tracking, please see the “Your Choices and Opt Out” section below.
Personal Information Received from Other Third Parties
HPG collects Personal Information about you from third parties, such as social media platforms, public databases, third party smart virtual assistants, or data vendors. This may include:
Personal Information collected from data vendors. HPG may supplement your Personal Information with information that we obtain from third parties, such as public databases or data aggregators.
Personal Information collected through service providers. Our service providers also may collect and use Personal Information to assist us with our business operations. For example, our service providers may need Personal Information to help us analyze the performance of the Services, detect and prevent fraud, or to improve user experiences.
Combination of Information
We may combine the Personal Information we receive from and about you. As noted, we may also de-identify or aggregate information, so it is no longer Personal Information.
HOW WE USE YOUR PERSONAL INFORMATION
To administer your account and provide the Services to you, such as to:
- Create and manage your HPG Account
- Provide you with customer support and respond to your requests
- Complete your transactions
- Communicate with you about the Services, including order management and billing
To Ensure a Consistent Experience Across Your Devices, such as to:
- Synchronize your usage across the various devices you use to interact with us
- Personalize your experience with our Services
To Offer Promotions and Ads, such as to:
- Administer sweepstakes, contests, discounts, or other promotions
- Develop, display, and track content and advertising tailored to you on the Services and on other websites
- Provide or contact you with customized Services content and offers from HPG or on behalf of our partners and affiliates
To Improve the services and develop new ones, such as to:
- Administer focus groups and surveys
- Conduct consumer research
- Use demographic, profile and other data for analytical and demographic purposes (this processing may involve profiling – for example to create audiences based on demographic or location-based information for marketing and customization purposes)
- Develop new features and services
To Prevent, Detect, and Fight Fraud or Other Illegal or Unauthorized Activities, such as to:
- Enforce our Terms
- Address fraud or alleged unlawful activity
- Assist law enforcement
- Conduct data analysis to better understand and design countermeasures against fraud
- Protect the security and integrity of the Services and our business
To Ensure Legal Compliance, such as to:
- Comply with legal requirements
- Enforce or exercise our rights or those of third parties
- Due diligence and required disclosures for corporate acquisitions and sales
- Address problems with the Services or our business
HOW WE SHARE YOUR PERSONAL INFORMATION
Sharing of Information by You
Sharing of Personal Information by Us
- With Our Service Providers. We use service providers to help us operate and improve the Services, such as for data hosting and maintenance, analytics, customer care, marketing, payment processing, order fulfillment, and security operations.
- Legal Obligations; Safety. We may access and disclose your Personal Information to respond to subpoenas, judicial processes, or government requests and investigations, in connection with an investigation on matters related to public safety, or as permitted or otherwise required by law. We may disclose your Personal Information to protect the security of our Services, servers, network systems, and databases.
- To Enforce Legal Rights. We may also share Personal Information (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and those of our users, business partners, or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding suspected illegal activity, fraud, or other wrongdoing.
- With Your Consent or At Your Request. We also may share your information as disclosed to you at the time of collection.
COOKIES AND OTHER TRACKING TECHNOLOGIES
We may use various practices and tracking technologies to allow us and third parties to develop and deliver targeted advertising on the Services and on websites or applications of third parties, and to analyze and report on such advertising you see.
Cookies. Certain parts of the HPG Services require cookies. Although you are not required to accept cookies or mobile device identifiers, if you block or reject them, you may not have access to all features available through the Services. Opting out of targeted advertising using any of the below links does not mean that you will stop seeing digital advertisements. Rather, opting out means digital advertising will not be targeted to you based on your interests (as inferred from your online activities). The Services use the following cookies:
- Strictly necessary cookies, which are required for the operation of the Services. Without them, for example, you would not be able to register or log in for the Services that HPG offers.
- Analytical/performance cookies, which allow HPG to recognize and count the number of visitors, learn how visitors navigate the Services and improve the Services.
- Functionality cookies, which HPG uses to recognize you when you return to the Services.
- Targeting cookies, which record your visits to the Services, the pages you visited and the links you followed. Targeting cookies help HPG deliver digital advertisements that are targeted to your interests (as inferred from your online activity). HPG also shares information collected through targeting cookies with third parties that send you targeted advertisements
- Interaction cookies, which allow you to recommend HPG on Social Media.
Web Beacons. HPG also uses web beacons (also called pixel tags or clear GIFs). Some of HPG’s content and emails may contain embedded web beacons that allow a server to read certain types of information from your device, as well as allow us to count the number of people who have viewed content and to know when you opened an email message and the IP address of your device. Web beacons help HPG develop statistical information to provide better and more personalized content. To learn more about web beacons, visit www.allaboutcookies.org.
YOUR CHOICES AND OPT-OUT
Access and Updates to Your Personal Information
For halo-pg.com account holders, if you would like to correct your Account information or delete your profile information from your Account page, please visit the “Profile” tab in the “Account” section on a Site or in the App, visit the Settings screen, My Account and then choose the Profile option. HPG reserves the right to request that you provide information that will enable HPG to confirm that you have the authority to correct or delete the profile information that you want corrected or deleted. HPG may not be able to correct or delete information shared with third parties. Pursuant to applicable law, we may be entitled to refuse to act on the request. California residents may exercise their rights to access or delete Personal Information according to the instructions in the “Information for Current California Residents” section below.
HOW LONG YOUR PERSONAL INFORMATION IS RETAINED
We will retain your Personal Information consistent with applicable law and our retention policies. Such retention may include satisfying any legal, accounting, or reporting requirements. We also may aggregate or de-identify the information so that it no longer identifies you, in which case we may use this information indefinitely without further notice to you.
SECURITY OF YOUR PERSONAL INFORMATION
HPG takes precautions intended to help protect Personal Information that we collect and store. Unfortunately, no system or electronic data transmission is completely secure. Any transmission is at your own risk, and we expect that you will use appropriate security measures to protect your information.
You are responsible for maintaining the security of your HPG Account. HPG will treat access to the Services through your HPG Account as authorized by you.
The Services are not directed to or intended for use by minors. We do not direct the Services to, nor do we knowingly collect any Personal Information from, children under the age of eighteen (18) (or age of majority of the individual’s relevant jurisdiction of residence).
CHANGES & OTHER HPG PRIVACY POLICIES
INFORMATION FOR CALIFORNIA RESIDENTS
Categories of Personal Information Sold
In the last 12 months, HPG has sold the following categories of Personal Information, namely for personalized advertising purposes:
- Identifiers: sold to third party advertisers and internally with HPG’s Affiliates;
- Geolocation data: sold to third party advertisers and internally with HPG’s Affiliates;
- Internet/Electronic Activity: sold to third party advertisers and internally with HPG’s Affiliates; and
- Profile Inferences: sold to third party advertisers and internally with HPG’s Affiliates.
We do not knowingly sell Personal Information about persons under the age of 16.
Categories of Personal Information Disclosed
In the last 12 months, HPG has disclosed the following categories of Personal Information for a business purpose (such as with our service providers who are restricted from using your Personal Information outside the scope of their services for HPG):
- Identifiers: disclosed internally within HPG and with HPG’s Affiliates, as well as to service providers;
- Geolocation data: disclosed internally within HPG and HPG’s Affiliates, as well as to service providers;
- Commercial Information: disclosed internally within HPG and with HPG’s Affiliates, as well as to service providers’
- Internet/Electronic Activity: disclosed internally within HPG and with HPG’s Affiliates, as well as to service providers; and
- Profile Inferences: disclosed internally within HPG and with HPG’s Affiliates, as well as to service providers.
You have the right to access, delete, and opt-out of the sale of your Personal Information. HPG will not discriminate against you for exercising these rights but may offer financial incentives to consumers who affirmatively allow us to collect and/or sell their Personal Information.
Access Request. You may make up to two requests per year for information as to:
- The categories of Personal Information that we’ve collected and sold about you, or shared for a business purpose with our service providers.
- The sources from which we collected such information.
- The third parties with whom we’ve shared that Personal Information and to whom we’ve sold that Personal Information.
- The business or commercial purpose for collecting or selling that Personal Information.
- The specific pieces of Personal Information we’ve collected about you.
Deletion Request. You may request that we delete the Personal Information that we’ve collected from or about you. If we cannot delete all of your Personal Information, we will let you know the reason for non-deletion, such as if we need to complete a transaction for you, or for a legal reason.
HPG may take steps to verify your identity based on the information we have on file about you before responding to your Access or Deletion Request. You may need to provide your email address to be used for this purpose. We will confirm receipt of your request within 10 business days and will respond to your request within 45 calendar days unless we need additional time, in which case we will let you know.
Please click here to make an Access or Deletion request. You may also contact our customer care centers at the telephone numbers and contact pages below:
- Halo at (833) 572-1688 or click here.
Agent Request. You may authorize someone to make a privacy rights request on your behalf (an authorized agent). Authorized agents will need to demonstrate that you’ve authorized them to act on your behalf, and that they are registered with the California Secretary of State to conduct business in California or must demonstrate they have power of attorney pursuant to applicable probate law. HPG retains the right to request confirmation directly from the consumer confirming that the agent is authorized to make such a request, or to request additional information to confirm the agent’s identity. An authorized agent shall not use a consumer’s personal information, or any information collected from or about the consumer, for any purpose other than to fulfill the consumer’s requests, for verification, or for fraud prevention.
DELETE YOUR HALO ACCOUNT
If you are looking to delete your account with HALO, please contact us at firstname.lastname@example.org and we would be happy to assist you with removing your account and any additional information that was provided that did not include information for a purchase.