This Policy describes how HaloFun processes your personal data, but it may not address all possible data processing scenarios. HaloFun may inform you of product- or service-specific data collection through supplementary policies or notices provided before collection.
This Policy describes:
1. How We Collect & Use Your Personal Data
2. Cookies & Similar Technologies
3. How We Disclose Personal Data
4. How to Access & Control Your Personal Data
5. How We Protect Your Personal Data
6. How We Process Children's Personal Data
7. Third-Party Providers and Their Services
8. International Transfers of Your Personal Data
9. Updates to This Policy
10. How to Contact Us
1.1 Definition of Personal Data
Personal data means any data that, either on its own or jointly with other data, can be used to identify a natural person. You directly provide us with such data when you use our websites, products, or services, or interact with us by, for example, creating a HaloFun account or contacting us for support. We may also obtain data by recording how you interact with our websites, products, or services. For example, we may use technologies like cookies or receive use data from software running on your device. We also collect the information you provide to us and the content of messages you send us, such as the query information you provide, or the questions or information you provide for customer service support.
1.2 How We Use Information That We Collect
Before using HaloFun’s products or services, you may need to provide personal data. In some cases you may be able to opt not to disclose your personal data to HaloFun. However, not providing HaloFun with certain data may mean that we cannot provide you with certain products or services or respond to an issue that you have raised.
We may use your personal data（including but not limited to your name, Wechat account, QQ, Skype, business address and telephone number) for the following purposes:
· Creating an account.
· Contacting you with your consent; sending you information about products and services that may interest you; inviting you to participate in HaloFun activities (including promotional activities), market surveys, or satisfaction surveys; or sending you marketing information. If you do not want to receive these types of information, you can opt out at any time.
· Sending you important notices, such as installation of and updates to operating system or application.
· Providing you with customized user experience and content.
· Qualifying and managing suppliers and business partners, and communicating or working with suppliers and business partners.
· Improving our products and services through internal audits, data analysis, and research.
· Analyzing the efficiency of our business operations and evaluating market share.
· Troubleshooting when you send us error reports.
· Synchronizing, sharing, and storing the data you upload or download and the data needed for the uploading and downloading.
· Ensuring the security of our products, services and customers or users, executing and improving our loss prevention and anti-fraud programs.
· Complying with and enforcing applicable legal requirements, industry standards and our policies.
1.3 How we use Non-PII That We Collect
HaloFun may also collect and use non-personally identifiable information (Non-PII). Non-PII is information that cannot be used to identify a particular individual. For example, HaloFun will collect statistical data, such as the numbers of visits to its website. We collect this data to understand how users use our websites, products, and services so that we can improve our services and better satisfy your needs. HaloFun may collect, use, process, transfer, or disclose non-PII for other purposes at its own discretion.
We will endeavor to isolate your personal data from non-PII and ensure that the two types of data are used separately. If personal data is combined with non-PII, it will still be treated as personal data during processing.
HaloFun will process your personal data following the requirements of applicable laws on an appropriate legal basis, including:
· Processing your personal data to fulfill the contract when responding to a transaction or service request;
· Processing your personal data with your consent;
· Processing based on the legitimate interests of HaloFun or a third party when we use your personal data to contact you, conduct marketing or market surveys, improve our products and services, execute and improve our loss prevention and anti-fraud programs, and other purposes. Legitimate interests include enabling us to more effectively manage and operate our business and provide our products and services; protecting the security of our businesses, systems, products, services, and customers; internal management; complying with internal policies and processes; and other legitimate interests described in this policy;
· Processing your personal data as necessary to comply with and fulfill legal obligations.
To ensure our website works correctly, we may at times place a small piece of data known as a cookie on your computer or mobile device. A cookie is a text file stored by a web server on a computer or mobile device. The content of a cookie can be retrieved or read only by the server that creates the cookie. The text in a cookie often consists of identifiers, site names, and some numbers and characters. Cookies are unique to the browsers or mobile applications you use, and enable websites to store data such as your preferences or items in your shopping cart.
2.2 Other Similar Technologies
In addition to cookies, we may also use other similar technologies on our websites. For example, when you receive an email from HaloFun, it may contain a click-through URL that links to a HaloFun web page. If you click the link, HaloFun will track your visit to help us learn about your preferences for products and services and improve our customer service.
HaloFun shares your personal data with other partners, as described in this Policy, when services are provided by partners authorized by HaloFun. For example, when you make an online purchase from HaloFun, we must share your personal data with the logistics provider to arrange shipment or a partner to provide services. In addition, as a global company, we may share personal data with HaloFun affiliates and subsidiaries.
To comply with applicable laws or respond to valid legal procedures, HaloFun may also disclose your personal data to law enforcement or other government agencies. If HaloFun is involved in a restructuring, merger & acquisition, or a bankruptcy or liquidation lawsuit in a given jurisdiction, your personal data may be disclosed in connection with the transaction. HaloFun may also disclose your data when appropriate, for example, to execute Terms and Conditions, when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or when it is in connection with an investigation of suspected or actual illegal activity.
It is your responsibility to ensure that all personal data submitted to HaloFun is correct. HaloFun is dedicated to maintaining the accuracy and completeness of personal data and keeping the data up-to-date.
To the extent required by applicable law, you may (i) have the right to access certain personal data we maintain about you, (ii) request that we update or correct inaccuracies in that data, (iii) object or restrict to our use of your personal data, and (iv) ask us to delete your personal data from our database. To exercise these rights, please contact us by email. Your written request may be required for security. We may decline the request if we have reasonable grounds to believe that the request is a fraudulent, unfeasible or may jeopardize the privacy of others.
If allowed by applicable laws, you have the right to withdraw your consent at any time when HaloFun processes your personal data based on your consent. However, withdrawal does not affect the legitimacy and effectiveness of how we process your personal data based on your consent before the withdrawal is made; nor does it affect any data processing based on another justification other than your consent.
If you think that the way we process your personal information does not comply with applicable data protection laws, you can contact the relevant competent data protection authority. You can obtain the information for contacting EU data protection authorities at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
The security of your personal data is important to us. We use appropriate physical, management, and technical measures to protect your personal data from unauthorized access, disclosure, use, modification, damage, or loss. For example, we use cryptographic technologies for data confidentiality, protection mechanisms to prevent attacks, and access control mechanisms to permit only authorized access to your personal data. We also provide training on security and privacy protection for employees to raise their awareness of personal data protection. HaloFun is committed to protecting your personal data; however, please note that no security measure is perfect.
We will retain your personal information for no longer than is necessary for the purposes stated in this Policy, unless otherwise extending the retention period is required or permitted by law. The data storage period may vary with scenario, product, and service. The standards HaloFun uses to determine the retention period are as follows: the time required to retain personal data to fulfill business purposes, including providing products and services; maintaining corresponding transaction and business records; controlling and improving the performance and quality of products and services; ensuring the security of systems, products, and services; handling possible user queries or complaints and locating problems; whether the user agrees to a longer retention period; and whether the laws, contracts, and other equivalencies have special requirements for data retention; etc. We will maintain your registration information as long as your account is necessary for service provision. You can choose to deregister your account. After you deregister your account, we will stop providing you with products and services through your account and delete your relevant personal data, provided that deletion is not otherwise stipulated by special legal requirements.
Our websites, products and services are primarily intended for adults. A child must not create a HaloFun account without the consent of a parent or guardian. If a child's personal data is collected with prior parental consent, we will only use or disclose the data as permitted by law, with the explicit consent of the child's parents or guardians, or when necessary for the protection of the child. If we accidentally collect a child's personal data without verified prior consent from the child's parents, we will attempt to delete the data as soon as possible.
To ensure a positive user experience, you may receive content or web links from third parties other than HaloFun and its partners ("third parties"). HaloFun does not have the right to control such third parties, but you can choose whether to use the links, view the content and/or access the products or services provided by third parties.
HaloFun cannot control the privacy practices and data protection policies of third parties that are not subject to this Policy. When you submit personal information to such a third party, please read and refer to the privacy protection policy of the third party.
As a global company, your personal data collected by HaloFun may be processed or accessed in the country/region where you use our products and services or in other countries/regions where HaloFun or its affiliates, subsidiaries, service providers or business partners have a presence. These jurisdictions may have different data protection laws. In such circumstances, HaloFun will take measures to ensure that data is processed as required by this Policy and applicable laws, which includes when transferring the data subject’s personal data from the EU to a country or region which have been acknowledged by the EU commission as having an adequate level of data protection, we may use a variety of legal mechanisms, such as signing standard contractual clauses approved by the EU Commission, obtaining the consent to the cross-border transfer of a data subject in the EU, or implementing security measures like anonymizing personal data before cross-border data transfer.
If you have any privacy complaints or issues, and want to contact HaloFun Data Protection Officer (DPO), please email to [email protected] .
Last updated: 2021-09