Effective-September 7th, 2018
Thank you for using Hallow!
- The ways we collect and store your personal data and why we do so,
- How we use and disclose your personal data, and
- The choices you have about your personal data.
2. Collection and Use of Information
Our primary goals in collecting information are to provide and improve our Services, to administer your use of the Services (including your Account, if you are an Account holder), and to enable you to enjoy and easily navigate our Services.
The types of Personal Information we may collect (directly from you or from third party sources) and our privacy practices depend on the nature of the relationship you have with Hallow and the requirements of applicable law. Some of the ways that we may collect Personal Information include:
- You as the user providing Personal Information directly to us through interacting with the Services, participating in surveys, during events such as sweepstakes, and requesting Services, or information.
- As you navigate the Services, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below.
Hallow collects Personal Information regarding its current, prospective, and former clients, customers, users, visitors, guests, and employees (collectively “Individuals”). We endeavor to collect only that information which is relevant for the purposes of Processing.
Below are the ways we collect Personal Information and how we use it.
3. Information You Provide Us
You agree that Hallow is free to use the content of any communications submitted by you via the Services, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or Services. We will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a Service will be published or otherwise used with your name on it; or (c) we are required to do so by law.
When you use the Services or engage in certain activities, such as registering for an Account, responding to surveys, requesting Services or information, or contacting us directly, we may ask you to provide some or all of the following types of information:
3a. Communications with Us
We may collect the following Personal Information when you choose to (i) request information about our Services, (ii) register for Hallow’s newsletter or a program that we may offer from time to time, (iii) request to receive customer or technical support, or (iv) otherwise communicate with us via:
- email address;
- phone number; or
- mailing address
From time to time, we may contact you to participate in online surveys. If you decide to participate, you may be asked to provide certain information which may include Personal Information. We may use such information to improve our products, Sites and/ or Services and in any manner consistent with the policies provided herein.
3c. Posting on the Site
Hallow may offer publicly accessible fun pages, blogs, private messages, or community forums. You should be aware that, when you disclose information about yourself on Hallow’s app, website pages, blogs, private messages, and community forums, the Site will collect the information you provide in such submissions, including any Personal Information. If you choose to submit content to any public area of the Site, such content will be considered “public” and will not be subject to the privacy protections set forth herein.
3d. Sweepstakes or Contests
Periodically, we may run sweepstakes and contests. We ask those who enter in the sweepstakes or contests to provide contact information (e.g., an e-mail address). If you participate in a sweepstakes or contest, your contact information may be used to reach you about the sweepstakes or contest, and for other promotional, marketing and business purposes. All sweepstakes/contests entry forms will provide a way for participants to opt-out of any communications that are not related to awarding prizes.
3e. Automatic Data Collection
We may collect certain information automatically through our Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, Advertiser ID, Game Center ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geolocation information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences.
4. Information from Other Sources
We may receive information about you from other sources, including through third party services and organizations to supplement information provided by you. For example, if you create an Account using your login credentials from one of your SNS Accounts, We will be able to access and collect your name and other Personal Information that your privacy settings on the SNS Account permit us to access. If you create an Account through the Services or one of your SNS Accounts, we may also collect your gender, date of birth and other information that is not considered Personal Information because it cannot be used by itself to identify you.
4a. Tracking Technologies (Cookies, Web Beacons, etc.)
We may collect information using web beacons. Web beacons are electronic images that may be used in our Services or emails. We use web beacons to deliver cookies, track the number of visits to our website and apps, understand usage and campaign effectiveness, and determine whether an email has been opened and acted upon.
We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit http://www.google.com/policies/privacy/partners/ You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to tools.google.com/dlpage/gaoptout.
We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our sites or on third party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement. If you would like to opt-out of the Technologies we employ on our sites, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.
4b. Location Information
In some cases, we may collect and store information about where you are located, such as by converting your IP address into a rough geolocation or by accessing your mobile device’s GPS coordinates or coarse location if you enable location services on your device. We may use location information to improve and personalize our Services for you. If you do not want us to collect location information, you may disable that feature on your mobile device.
4c. Social Media Platforms
Hallow’s Services may include publicly accessible blogs, community forums, or private messaging features. The Site and our other Services may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our Site or other Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.
4d. Third-Party Payment Processing
We may sell subscriptions or merchandise through our Services. When you make purchases through the Services, we process your payments through a third party application, including the Apple App Store, Google Play App Store, Amazon App Store (together with any similar applications, “App Stores”), Social Networking Sites (“SNS”) such as Facebook, and other third-party payment processors, including Stripe. The third party application may collect certain financial information from you to process a payment on behalf of Hallow, including your name, email address, address and other billing information.
5. How We Use Your Information
We acquire, hold, use, and process Personal Information about Individuals for a variety of business purposes, including:
5a. To Provide Products, Services, or Information Requested
We may use information about you to fulfill requests for products, Services, or information, including information about potential or future Services, and to:
- Generally manage Individual information and Accounts
- Respond to questions, comments, and other requests
- Provide access to certain areas, functionalities, and features of Hallow’s Services
- Contact you to answer requests for customer support or technical support
- Allow you to register for events
5b. Administrative Purposes
We may use Personal Information about you for administrative purposes to accomplish the following:
- Measure interest in Hallow’s Services
- Develop new products and Services
- Ensure internal quality control
- Verify Individual identity
- Communicate about Individual Accounts and activities on our Services and systems, and, in Hallow’s discretion, changes to any Hallow policy
- Send email to the email address you provide to us to verify your Account and for informational and operational purposes, such as Account management, customer service, or system maintenance
- Process payment for products or services purchased
- Process applications and transactions
- Prevent potentially prohibited or illegal activities
- Enforce our Terms
5c. Marketing Hallow Products and Services
We may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. We may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:
- Tailoring content, advertisements, and offers
- Notifying you about offers, products, and services that may be of interest to you
- Providing Services to you and our sponsors
- For other purposes disclosed at the time that Individuals provide Personal Information, or
- Otherwise with your consent
5d. Research and Development
We may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. From time to time, Hallow may perform research (online and offline) via surveys. We may engage third party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous Individual and aggregate data for research and analysis purposes.
5e. Direct Mail, Email and Outbound Telemarketing
5f. Services via Mobile Devices
5g. Anonymous and Aggregated Information Use
We may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access Hallow’s Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and we may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Hallow and with third parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
5h. Sharing Content with Friends or Colleagues
Hallow’s Services may offer various tools and functionalities. Our services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by us or any other third parties for any other purpose.
5i. Other Uses
We may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
6. Information That We Share With Third Parties
We will not share any Personal Information that we have collected from or regarding you except as described below:
6a. Information Shared with Our Services Providers
We may engage third party service providers to work with us to administer and provide the Services. These third-party services providers have access to your Personal Information only for the purpose of performing services on our behalf. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Site. Hallow has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
We may also share your Personal Information with our marketing service providers to help us better market our products and services to you. Our marketing service providers may use your Personal Information only for the purpose of helping us better market our products and services to you and are prohibited from transferring your Personal Information to others. If you don’t want Hallow to use your information for these purposes, you can opt out by contacting us email@example.com.
6b. Information Shared with Business Partners
We may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested. We may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with Hallow. We require our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which Hallow provided them.
6c. Information Shared with Other Systems, Such As HealthKit or Google Fit
- Hallow does not use or disclose to third parties user data or other information gained through the use of the HealthKit framework or Google Fit for advertising, other use- based data mining purposes or similar services, other than for purposes of improving health or for purposes of health or medical research.
- In the case of information gained through HealthKit or Google Fit such sharing will only be for purposes of enabling the third party to provide health and/or fitness services or for medical research.
- We do not sell any of your information, including information gained through HealthKit or Google Fit, to advertising platforms, data brokers or information resellers.
- We do not use any of the information obtained through HealthKit or Google Fit for any purpose other than providing health and/or fitness services in connection with the Services.
6d. Information Shared with Other Third Parties
We may share aggregated information and non-identifying information with third parties for industry research and analysis, demographic profiling and other similar purposes.
6e. Information Disclosed in Connection with Business Transactions
Information that we collect from our users, including Personal Information, is considered to be a business asset. As a result, if we go out of business or enter bankruptcy or if we are acquired as a result of a transaction such as a merger, acquisition or asset sale, some or all of our assets, including your Personal Information, may be disclosed or transferred to a third-party acquirer in connection with the transaction.
6f. Information Disclosed for Our Protection and the Protection of Others
We cooperate with government and law enforcement officials and/or private parties to enforce and comply with the law. We may access, preserve, and disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims or legal process and comply with law enforcement or national security requests (including subpoenas, warrants or court orders); (ii) to protect your, our, or other’s property, rights and safety and the rights, property and safety of a third party or the public in general; (iii) to prevent or stop any activity we consider illegal, unethical or legally actionable activity; (iv) to respond to your requests; (v) to collect amounts owed to us; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
7. Rights of Access, Rectification, Erasure, and Restriction
Although Hallow makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which we are unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If we determine that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, we will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
7a. Your Choices & Opt-Out
You have the right to opt out of certain uses and disclosures of your Personal Information. Where you have consented to Hallow’s processing of your Personal Information, you may withdraw that consent at any time and opt-out to further processing by contacting us at firstname.lastname@example.org. Even if you opt-out, we may still collect and use non-Personal Information regarding your activities on our Sites and/ or information from the advertisements on third party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.
We maintain “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law.
7b. Mobile Devices
We may occasionally send you push notifications through our mobile applications with updates and other notices that may be of interest to you. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. We may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.
7c. Modifying Your Information
You can access and modify the Personal Information associated with your Account through your Account settings or by contacting us email@example.com. If you want us to delete your Personal Information and your Account, please contact us firstname.lastname@example.org with your request. We will take steps to delete your information as soon we can, but some information may remain in archived/backup copies for our records or as otherwise required by law.
7d. Do Not Track Signals
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Our Services do not have the capability to respond to “Do Not Track” signals received from various web browsers.
7e. Withdrawal of Consent for Processing Activities
To the extent that you have provided appropriate consent under applicable laws to certain processing activities, such as use of trackers for the purpose of retargeting activities, such consent can be withdrawn at any time by emailing email@example.com.
8. Data Retention
8a. Data Security and Storage
All information you provide to us is stored on our secure servers located in the US. Any payment transactions will be encrypted using SSL technology; all payment information is stored with our payment processor and is never stored on Hallow’s servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Products, you are responsible for keeping this password confidential. We ask you not to share a password with anyone, and suggest that your change your password frequently.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to the Products; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
9. Links to Other Sites
The Products may, from time to time, contain links to and from the Products of our partner networks, advertisers and affiliates. If you follow a link to any of these external websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these websites or their policies. Please check these policies before you submit any personal information to these external websites.
10. International Transfer
11. Our Policy Towards Children
You must be 18 years of age, or the age of majority in your province, territory or country, to sign up as a registered user of the Products. Individuals under the age of 18, or the applicable age of majority, may utilize the Products only with the involvement and consent of a parent or legal guardian, under such person’s account and otherwise subject to these Terms. If we learn that we have collected Personal Information of a child under 18 we will take steps to delete such information from our files as soon as possible.
12. Contact Us