Privacy and GDPR

Updated: April 2021

We respect your privacy and are committed to protecting your personal data. This privacy notice tells you how we look after your personal data when you complete your user profile, when you visit our website or otherwise communicate with us and it tells you about your privacy rights and how the law protects you.

Contact Details

My Halo Life Limited registered office address: Kemp House, 160 City Road, London, United Kingdom, EC1V 2NX. If you need to get in touch withus for any reason in connection with your personal data, please email us at: [email protected]

Changes to our Privacy Policy

We may modify this Policy from time to time. If we make any changes to this Policy, we will change the “last updated” date above. We encourage you to check this Policy whenever you use our Site and Services to understand how your personal information is used.

My Halo’s Data Controller Responsibilities

My Halo Life Limited is the controller of your personal data. We are responsible for its security and for ensuring that we use it only for the purposes outlined in this privacy policy.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

For My Halo registered users:

Identity data includes name, email address, username and password. Usage data includes information about how you use our website. Technical data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. Marketing data includes your preferences in receiving marketing communications from us.

Where you provide us with personal data belonging to another person, we do not control that personal data and will act only as processor of that personal data in accordance with our obligations contained in our terms and conditions.

We also collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. We collect most of your data when you choose to give this to us on our website, by email or otherwise. Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies (such as Facebook and Google). You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website or application may become inaccessible or not function properly. For more information about the cookies we use, and how to disable them, please see our Cookie Policy.

Third parties or publicly available sources.

We may receive:

Technical data about you from various third parties (as governed by our Cookie Policy) and as set out below:

Analytics providers such as Google with servers based outside the UK; advertising networks such as Facebook pixel with servers based outside the UK; and search information providers Google based outside the UK.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

To provide the services to you in accordance with our website terms and conditions; or

Where it is necessary for our legitimate interests (or those of a third party) and we have made an assessment that your interests and fundamental rights do not override those interests.

Where we need to comply with a legal or regulatory obligation. Please contact us if you need details about the specific legal grounds we are relying on to process your personal data.

Where you provide us with personal data belonging to another person, we do not control that personal data and will act only as processor of that personal data in accordance with our obligations contained in our terms and conditions.

Emails – Opting out

We strive to provide you with choices regarding certain personal data uses, particularly around the emails you receive from us.

If you are a registered user, we may use your contact data to send you reminder emails as part of our service to help with the administration of your account. We automatically sign you up to this when you register with us as we think it is in our legitimate interests to offer you this complete service. You are free to opt-out from receiving these emails at any time.

If you are a registered user, you will not receive marketing communications, updates, or useful advice from us, unless you opt-in to receive this type of communication either at registration or in your account settings

We will never share your personal data with any other company for marketing purposes.

Disclosures of your personal data

We may need to share your personal data with the parties set out below:

Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Data Security

We have put in place the highest level of security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instruction, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see ‘Account Deletion’ below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your Legal Rights

You have the following rights regarding your information:

Right to be informed. You have the right to be provided with clear, transparent, and easily understandable information about how we use your information and your rights. Therefore, we are providing you with the information in this policy. Right of access. (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.

Right to rectification. 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.

Right to erasure. 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 delete your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of deletion for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Right to restrict processing. 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.

Right to data portability. 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.

Right to withdraw consent. If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful).

Right to object to processing. In addition to the above rights, you also have the right to object to certain types of processing, in certain circumstances. In particular, the right to object to the processing of your personal data based on our legitimate interest grounds (including processing for direct marketing).

For more information on your rights or to exercise any of these rights at any time, you can contact us by email at [email protected] Halo.life or by post at address: Kemp House, 160 City Road, London, United Kingdom, EC1V 2NX

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to a person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or if you have made several requests. In this case, we will notify you and keep you updated.

Account deletion

If you want to stop using your account, you may deactivate it. When you deactivate an account, you will not be able to use our Site or Services, and your information will not be capable of being viewed through our site. However, even after you deactivate your account, copies of your information, including but not limited to name and email address may be retained by us for legal and compliance reasons.

UK-GDPR Compliance

How we comply with the UK General Data Protection Regulation.

We recognise trust is the foundation of our relationship with our customers. We value the confidence you have put in us and take the responsibility of protecting your information seriously.

My Halo is UK-GDPR Compliant

From the 1st January 2021, the EU General Data Protection Regulation (EU-GDPR) legislation was succeeded by the UK-GDPR for companies established within the UK.

Details of the differences between the EU and the UK GDPR are documented in the ‘Keeling Schedules’ and can be found here:
https://www.gov.uk/government/publications/data-protection-law-eu-exit

My Halo customers can have certainty and confidence that the handling of personal data is of the GDPR’s security standards.

We have ensured the most comprehensive set of compliance offerings have been established. In particular, in accordance with UK-GDPR, My Halo has ensured that personal data is:

Processed lawfully on the basis of Legitimate Interests.

Adequate, relevant and limited to what is necessary.

Collected only for specified, explicit and legitimate purposes.

Accurate and kept up to date.

Held only for the absolute time necessary and no longer.

Processed in a manner that ensures appropriate security of the personal data.

My Halo has undertaken and executed a comprehensive evaluation and audit of all our systems and practices in connection with the personal data of our customers and have put in place the appropriate procedures and infrastructure to ensure full compliance with the requirements of the UK-GDPR.

How to Complain

If you have any concerns about our use of your personal information, you can make a complaint to us at [email protected]

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:

Information Commissioner’s Office Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

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