The definition of personal information (used interchangeably with “personal data” for European residents) depends on the applicable law based on your physical location. Only the definition that applies to your physical location will apply to you under this Policy. For purpose of this Policy, personal information does not include data that has been irreversibly anonymized or aggregated so that it can no longer enable us, whether in combination with other information or otherwise, to identify you.
We may update this Policy at any time, without prior notice, and changes will apply to any personal information we already hold about you as well as any additional personal information collected after the Policy is updated. If we make changes, we will notify you by revising the date at the top of this Policy. If we make a change to this Policy that we believe materially affects how we process your personal information or reduce your rights, we will provide you with advanced notice via email, through push notification, or by posting a prominent notice on our Sites. Unless otherwise required by laws in your residence, your continued access or use of our Services after receiving the notice of changes, constitutes your acknowledgment that you accept the updated Policy.
In addition, we may provide you with real time disclosures or additional information about the personal information handling practices of specific parts of our Services. Such notices may supplement this Policy or provide you with additional choices about how we process your personal information.1. Personal Information We Collect
Halara collects certain personal information about you and your use of our Services. This information falls into three primary categories: (1) information you voluntarily provide to us, (2) information we collect from you automatically.Information You Voluntarily Provide to Us. We, or service providers that assist us in providing, maintaining, and operating our Services, may collect the following types of personal information from you: (1) Account Registration. We may collect information relating to the creation of an account when using our Services, such as, email address, phone number, and/or a unique individual password. If you use a third-party service (e.g., Apple, Facebook, Tiktok) to create an account, we may receive personal information that you allow such third-party service to share with us, such as your name and email address.(2) Order Placement. We may collect your personal information when you place an order on our Sites or in our App, including, for example, your first and last name, mailing address, postal code, email address, phone number, payment account or credit card information. In some regions, we may need your passport information and tax number for customer clearance.(3) Customer Support. When you engage with our supports team, we may collect records, copies of your correspondence (including email addresses), social media handles, or additional information you choose to share with us. (4) Newsletter Sign-ups. You may choose to provide us your contact details, such as your email address and phone number, if you wish to receive information about the products and services that Halara offers.(5) Fitting Recommendation. You may voluntarily provide us your height, age, weight and measurements and your preference. This information is used by us to recommend clothing sizes, and to provide fit prediction services for you.(6) Public Forum. If you post information on public areas of our Site, for example, disclosing your measurement and fitting information in a product review, that information may be collected and used by Halara, visitors to our Sites, and the public generally. We strongly recommend that you do not post any information through the Site that allows strangers to identify or locate you or that you otherwise do not want to share with the public.(7) Promotional Events. From time to time, we may ask you to complete a survey and/or offer you an opportunity to participate in promotions, programs and/or sweepstakes (collectively, “Promotions”) via the Site. If you choose to participate in a Promotion, we will collect and store the personal information you provide in connection with your participation in the Promotion, including, but not limited to, your name, email address, date of birth, and/or phone number. We may provide “just-in-time” disclosure or additional information about our information collection, use and sharing practices of specific Promotions. We use this information to administer the Promotion, such as by notifying winners and distributing prizes, and for Halara and our Promotion sponsors’ marketing purposes as permitted by applicable law. Acceptance of a prize may require you (unless prohibited by law) to allow us to post publicly some of your information via the Site, such as on a winner's page.(8) Brand Ambassador. If you apply to become our brand ambassador, we may collect your name, email address, phone number, social media handles, region and school attended in order to process your application. (9) Affiliate Program. If you apply to join one of our affiliate programs to earn commission, we may collect your full name, username, country or region, company website, company address, time zone.Information We Automatically Collect. To the extent permitted under the applicable law, we may collect certain types of information automatically, such as whenever you interact with the Sites or use the Services. We may collect the following types of information automatically from you:(10) Usage Data. When you browse our Sites, we automatically collect log data such as your web request, Internet Protocol (“IP”) address, browser type, domain names, referring and exit pages and URLs, pages viewed and the order of these page views, the date and time you access our servers, and other diagnostic data. (11) Device Information. When you use your desktop or mobile devices to access our Services, we may be able to identify your device’s unique device identifier, MAC address, operating system, and your mobile device’s advertising ID. (12) Location Information. When you use our Service, we may infer the generic physical location and geographic regions of your device from your WiFi, Bluetooth and other device settings. For example, your IP address may indicate your general geographic region. You may choose not to share your location details with us by adjusting your mobile or desktop device’s location services settings. For instructions on changing the relevant settings, please contact your service provider or device manufacturer.(13) Aggregate and Analytic Data. We may also combine the information we collect among our Services and across your devices for analytic, security and fraud prevention purposes. For example, we use algorithms that analyze your account status and payment information to detect the unsafe and unsecured payment. We may also use analytic data to assess your account security and provide you suggestion for improvement.Information We Collect From Third Parties. From time to time, we may obtain information about you from third party sources as required or permitted by law. These sources may include:2. Cookies and Other Tracking Technologies
We, and third parties on our behalf may employ various tracking technologies, such as cookies and other similar technologies (collectively, “Tracking Technologies”) to collect personal information automatically as you interact with our Site and App, to help us customize your experience and better manage content, including to:
Analyze our web and app traffic using an analytics package
Identify whether you already visited our Services
Store information about your preferences
If you want to exercise your rights regarding personal information collected via cookies and similar tracking technologies, please see the Your Rights and Choices section below.3. How We Use Your Personal Information
We maintain advisors, potential transactional partners or other third parties designed to guard and prevent misuse of your personal information. Our security measures include industry-standard physical, technical and administrative measures to prevent unauthorized access to or disclosure of your information, to maintain data accuracy, to ensure the appropriate use of information, and otherwise safeguard your personal information. We also restrict access to your personal information to our employees and third parties who need such information to provide products or Services.
Please recognize that protecting your personal information is also your responsibility. We ask you to be responsible for safeguarding your password, secret questions and answers and other authentication information you use to access our Services.If you feel that the security of your account or personal information has been compromised, please immediately contact us at the following email address Legal@halara.com. Please be aware that, despite our best efforts, no security system is impenetrable. In the event of a security breach, we will promptly notify you and the proper authorities if required by law.6. How Long We Keep Your Personal Information
We will retain your personal information only for as long as is necessary for the purposes set out in this Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.
If you send us correspondence, including emails, we retain such information electronically in the records of your account. We will also electronically retain customer service correspondence and other correspondence from Halara to you. We retain these records to measure and improve our customer service and to investigate potential fraud and violations. We may, over time, delete these records as permitted by law.
Halara will also retain Site and services usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Site, or we are legally obligated to retain this data for longer periods.
We will cease to retain your personal information or remove the means by which the information can be associated with you as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal information was collected and is no longer necessary for legal or business purposes.7. Your Rights and ChoicesDepending on the applicable law where you reside, you may exercise the right to access, correct, or delete your personal information that we have collect or has been previously provided to us. If you would like to exercise your rights under applicable law, please contact us at Legal@halara.com
In your request, please make clear what personal information you would like to have access, changed or removed from our database. We may seek to verify your identity when we receive your privacy rights request to ensure the security of your personal information.
Additional Rights for California Residents
You may have additional privacy rights if you are a California Residents, see Section 11 “Notice to California Residents” below for more information.
Additional Rights for Individuals in the European Economic Area, the United Kingdom, Switzerland and Brazil
You may have additional privacy rights if you use or access our Service from the European Economic Area, the United Kingdom, Switzerland and Brazil, see Section 12 “Notice to Individuals in the European Economic Area, the United Kingdom, Switzerland and Brazil” below for more information.8. Third-Party Websites
Our Services are not directed to, and we do not knowingly collect personal information from, children under the age of 16 (or other age as required by local law). If you are under 16, please do not attempt to fill out our forms or send any personal information about yourself to us. If you are a parent or guardian and wish to review information collected from your child, or have that information modified or deleted, you may contact us via the method identified in the Contact Us section below. If we become aware that a child under 16 has provided us with personal information, we will terminate the user’s access to our Service and take steps to delete such information from our filesystems, unless we have a legal obligation to keep it.10. International Transfers of Personal Information
Halara’s business operates on a global scale. Thus, when you access and submit personal information to Halara, your personal information may be processed, maintained, and used on computers, servers, and systems located, mostly in the United States and China, where privacy and data protection laws may be less stringent than the laws in your country of residence. For those countries or regions, measures have been taken pursuant to applicable data protection laws to protect your personal information. We rely primarily on the European Commission’s Standard Contractual Clauses to facilitate the international and onward transfer of personal information collected in the European Economic Area, the United Kingdom, Switzerland and Brazil, to extent the recipients of the European Personal Information are located in a country that the European Countries consider to not provide an adequate level of data protection. We may also rely on an adequacy decision of the relevant regulatory body confirming an adequate level of data protection in the jurisdiction of the party receiving the information, or derogations in specific situations.If you do not want your information transferred to, processed, or maintained outside of the country or jurisdiction where you are located, you should immediately stop accessing or using the Services. For further details about these transfers and the safeguards that we use to facilitate such transfers, contact us at Legal@halara.com11. Notice for California Residents
This section applies only to California residents. The purpose of this section is to inform California residents (“consumers” or “you”), at or before the time of collection of personal information, about our data collection practices and your privacy-related rights under California law, including the California Consumer Privacy Act of 2018, as amended (“CCPA”) and the California Privacy Rights Act (“CPRA”). Your “right to know” about personal information collected, used, and disclosed by Halara includes what categories of personal information we collect from you and the purpose for its collection; how we use those categories of personal information; and how we share the personal information you entrust to us. For purpose of this section, the term “personal information”, as defined under the CCPA, is used.
Categories of Personal Information Collected
The chart below described the categories of personal information we have collected in the preceding 12 months, the sources and purpose of such collection, and the parties to whom the information was shared for business purpose.
|Personal Information Category (corresponds to categories in CCPA §1798.140(o)(1))||Sources of Personal Information (see Section 1 above for more information)||Purpose of Information Collection||Disclosure of Personal Information|
|(A) Identifiers||Information you voluntarily provide to us; Information we automatically collect, as outlined in Section 1 above.||See Section 3, subsection 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, and 11.||See Section 4, subsection 1, 2, 3, 4, 5, 6, and 7.|
|(B) Personal information under California Civil Code section 1798.80||Information you voluntarily provide to us; Information we automatically collect as outlined in Section 1 above.||See Section 3, subsection 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, and 11.||See Section 4, subsection 1, 2, 3, 6, and 7.|
|(C) Protected Classifications, including gender and age.||Information you voluntarily provide to us; Information we automatically collect, as outlined in Section 1 above.||See Section 3, subsection 2 and 3.||See Section 4, subsection 1, 2, 3 and 6. To our services providers, as outlined in Section 5 above.|
|(D) Commercial information, such as records of service purchased||Information you voluntarily provide to us; Information we automatically collect, as outlined in Section 1 above.||See Section 3, subsection 1, 2, 4, 5, 6, 7, 8, 9, and 10.||See Section 4, subsection 1, 2, 3 and 6.|
|(F) Internet activity information, such as browsing history.||Information we automatically collect as outlined in Section 1 above.||See Section 3, subsection 1, 4, 5, 6, 7, 8, 9, and 10.||See Section 4, subsection 1, 2, 3, 4, and 7.|
|(G) Geolocation data||Information we automatically collect as outlined in Section 1 above.||See Section 3, subsection 1, 6, and 9.||See Section 4, subsection 3 and 7.|
|(H) Audio or similar information||Information you provide to us as outlined in Section 1 above.||See Section 3, subsection 4 and 5.||See Section 4, subsection 2 and 3.|
|(J) Inferences about preferences, characteristics, etc.||Information you provide to us, Information we automatically collect, as outlined in Section 1 above.||See Section 3, subsection 7, 8, and 9.||See Section 4, subsection 2, 3, 4, and 5.|
Your Rights Under California LawAccess to Specific Information and Data Portability Rights. Subject to certain exceptions, if you are a California resident you have the right to request a copy of the personal information that we collected about you during the 12 months before your request. Once we receive your request and verify your identity, we will disclose to you:
The categories of personal information we have collected about you;
The categories of sources for the personal information we have collected about you;
Our business or commercial purpose for the information collection;
The categories of third parties with whom we share that personal information; and
The specific pieces of personal information we collected about you.Changes to Specific Personal Information. We rely on you to update and correct your personal information. You may update or correct the personal information in your account profile through features provided on our Sites or in our Apps. If our Site or App does not permit you to update or correct certain information, you have the right to request us to correct inaccurate personal information. Please note that we may keep historical information in our backup files as permitted by applicable law.Sale of Personal Information. To the extent we sell your personal information to third parties, you have the right to request that we disclose to you:
The categories of your personal information that we sold, and
Exercising Your Rights Under California LawSubmit a Request. To exercise your rights described above as a California resident, please submit a request to us by contacting us as described in the “Contact Us” section below. Before fulfilling your request, as required by law, we may ask you to verify personal information we already have on file to confirm your identity. If we cannot verify your identity based on the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes.Use of an Authorized Agent to Submit a Request – Only you or a person you formally authorize to act on your behalf, may make a verifiable consumer request related to your personal information as a California consumer. If you use an authorized agent to submit such a request, we will require written proof that the authorized agent has been authorized to act on your behalf or a copy of the power-of-attorney document granting that right.12. Notice to Individuals in the European Economic Area, the United Kingdom, Switzerland and Brazil
This section only applies to individuals using or accessing our Service while located in the European Economic Area, the United Kingdom, Switzerland (collectively, the “European Countries”), or Brazil at the time of data collection. Pursuant to the European Union’s General Data Protection Regulation, the UK General Data Protection Regulation (collectively, the “GDPR”), and the Brazil General Personal Data Protection Act (“LGPD”), for the sake of clarity, references to personal information in this Policy concerns personal data in the sense of the GDPR.
We may ask you to identify which country you are located in when you use or access some of the Services, or we may rely on your IP address to identify which country you are located in. When we rely on your IP address, we cannot apply the terms of this section to any individual that masks or otherwise hides their location information from us so as not to appear located in European Countries or Brazil. If any terms in this section conflict with other terms contained in this Policy, the terms in this section shall apply to individuals in a European Country or Brazil.Our Relationship to You. Your personal data is collected and processed by HK DFS Limited, Incorporated in Hong Kong, which is operating the website and the sale of Halara brand products. In other words, HK DFS Limited is the Controller of the data. This means that we are responsible for processing and protecting your personal data.
Legal Bases for Processing Your Personal Data
|Section & Purpose of Processing||Legal Bases for Processing|
|Section 3(2) To Maintain Legal and Regulatory Compliance. Section 3(4) To Detect and Prevent Fraud and Security Risks. Section 4(1) As required by Law||Based on our legal obligations. Article 6(1) lit.(c) GDPR; Article 7(II) LGPD.|
|Section 3(1) To Provide Halara’s Services. Section 3(3) To Enforce Compliance with Our Terms, Agreements and Policies. Section 3(5) To Respond to Requests. Section 3(6) To Provide Services Communications. Section 4(2) Within Our Corporate Organization. Section 4(3) With Our Service Providers Section 4(5) For Co-Branded Services and Features||Based on our contract with you or to take steps at your request prior to entering a contract. Article 6(1) lit.(b) GDPR; Article 7(V) LGPD.|
|Section 3(8) To Research and Develop Our Services. Section 3(9) To Personalize Your Experience. Section 3(10) To Facilitate Corporate Acquisitions, Mergers and Transactions. Section 4(6) During Business Transaction or Other Asset Transfers||Based on our legitimate interest to operate our business and not overridden by your data protection interests or fundamental rights and freedom. Article 6(1) lit.(f) GDPR; ; Article 7(IX) LGPD.|
|Section 3(7) To Provide Marketing Communication. Section 3(11) With Your Consent. Section 4(4) With Third Party Advertisers Section 4(7) With Your Consent||Based on your consent. Article 6(1) lit.(a) GDPR; Article 7(I) LGPD.|
Right to access. You may have the right to obtain a copy of your personal data that we hold about you, as well as other supplementary information, such as the purposes of processing, the categories of personal data that we process, the entities to whom we disclose your personal data, etc..
Right to rectification. You may have the right to request us correct any of your personal data in our files.
Right to erasure. Under certain circumstances, you may have the right to request erasure of your personal data that we hold about you. To note, this right is not absolute, and we may refuse your right to erasure if there are compelling legitimate grounds for keeping your data.
Right to restriction. You have the right to request that we restrict our processing of your personal data in certain circumstance. For instance, this right is available if you contest the accuracy of the personal data or you objected to our processing.
Right to object to processing. You have the right to object to our processing of your personal data at any time and as permitted by applicable law if we process your personal data on the legal bases of: consent, or legitimate interests. However, we may continue to process your personal data if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.
Right to portability. Under circumstances, you may have the right to receive personal data we hold about you in a structured, commonly used, and machine-readable format so that you can provide that personal data to another controller.
Right to lodge a complaint. Without prejudice to any other administrative or judicial remedy, you may have the right to lodge a complaint with a supervisory authority in a specific region according to applicable law.If you believe we have infringed or violated your privacy rights, please contact us at Legal@halara.com. so that we may resolve your dispute directly.Automated Decision-Making, including Profiling. We do not make any decisions based on algorithms or other automated processing that significantly affect you.13. Contact Us