HalloApp, Inc. (“we,” “our,” or “us”) builds privacy into our websites, applications, and services (collectively, our “Services”). This Privacy Notice explains how we collect, use, and share personal data about individuals in connection with our Services (collectively, “you” or “your”) that link to this Privacy Notice.
Personal Data We Collect
We collect limited personal data from or about you or your devices, as described below. When you are asked to provide us with personal data you can generally decline. If you do not provide certain data, however, you may not be able to use our Services or you may have limited features available if that data is necessary to provide you with our Services or the features you wish to use. For example, you can choose not to upload phone numbers of your contacts, but the phone number associated with your device is required to use our Services.
A. Information You Provide to Us.
Registration and Profile Information. When you sign up for an account or use our Services, we will ask you for your name/username and telephone number. You can also upload a profile photo.
Content. In addition to uploading a profile photo, you can choose to post messages, and share images and other content through our Services.
Contacts. We also request access to your device’s contacts, e.g., your phone address book, for use in the app on your device. If you agree, we upload phone numbers from your contact list to our servers. We do this to help you connect to people in your contact list. We also help you text and invite other people who are not yet using our Service. Similarly, we may collect your phone number from other people using our Service if you are in their contact lists. They can see whether you are using the Service and can invite you to connect or join.
Communications. If you contact us directly, we may receive additional personal data about you. For example, when you contact us for support, we may receive your name, email address, phone number, and the contents of your support issue along with any other information you chose to provide.
B. Personal Data We Collect When You Use our Services.
Device Data. We collect data about the device and software you use to access our Services, including IP address, and general location (such as city, state, and country) inferred from IP address, web browser type, operating system version, phone carrier and manufacturer, application installations, device identifiers, and push notification tokens. We use this data to provide and improve the Services.
Usage Data. To help us understand how you use our Services and to help us improve them, we automatically receive data about how you use our Services, like the pages or other content you view, the data you upload, how much time you spend on a page, objects such as hyperlinks you click on, and the dates and times of your visits.
How We Use the Personal Data We Collect
We use the personal data described above:
To provide, maintain, improve, and enhance our Services, including, to deliver your messages and content and to help you find and connect with people you know who use the Service or who you wish to invite to connect on our Services;
To understand and analyze how you use our Services and develop new products, services, features, and functionality;
To communicate with you, such as through push notifications and in app messaging, to provide you with updates and other information relating to our Services, such as new features you may wish to use in our Services, provide information that you request, respond to requests, comments, and questions, and otherwise provide customer support;
To generate de-identified or aggregated data for our business purposes;
To find and prevent fraud and illegal acts, and respond to trust and safety issues;
For compliance purposes, including enforcing our Terms of Service or other legal rights, as may be required by applicable laws and regulations, or as requested by any judicial process or governmental agency; and
For other purposes for which we provide specific notice at the time your personal data is collected.
How We Share Your Personal Data
We do not sell your personal data. We also design our Services so that we do not share or otherwise disclose personal data we collect from or about you in ways you would not expect. We share each of the categories of personal data described above with the following third parties for the business purposes described (or otherwise disclosed to you at the time of the collection):
Service Providers. We may share personal data we get with service providers who help us provide our Services. Service Providers may also collect or provide data on our behalf in connection with our Services.
Your Connections. Our Services are social services in which you can view and share content. Your name/username and profile information will be viewable by other users. The content you share on the Services will be viewable by other users to whom you have allowed to view such content. We also share data about you with others when certain actions happen, such as displaying your name/user name under “Seen By” if you view someone’s post and showing your phone number if you send someone a message, and as further described in our FAQs. In the “Your Choices” section of this Privacy Notice, we describe the controls that you can use, along with other relevant settings associated with your account, to limit the sharing of certain data. We are not responsible for other users’ use of your content and personal data once you decide to share. You should be careful about whether and what to share and how you wish to identify yourself on the Services.
As Required by Law and Similar Disclosures. We may access, preserve, and disclose your personal data if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, security, or safety, including enforcing our terms and policies. For the avoidance of doubt, the disclosure of your information may occur if you send any objectionable content on or through our Services.
Merger, Sale, or Other Asset Transfers. We may transfer your personal data to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction or proceeding in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our business or assets.
With Your Consent. We may also disclose your personal data with your permission or direction.
Access, Deletion, and Correction.
You can learn about different privacy choices, settings, and actions you can take, including how you can access, delete, or correct your personal data by visiting our FAQs at https://www.halloapp.com/help/. You can also request to access, delete, and correct your personal data by emailing us at email@example.com.
We provide you with settings to let you decide how you connect with others and share content. Certain information are always publicly available to others, for example, if you comment on the post of a friend, their friends can see your comments, and other information is made publicly available to others by default. To change whether certain information is publicly viewable, you can adjust the settings in your account as described at https://www.halloapp.com/help/.
Do Not Track.
We do not track your online activities over time and across third-party website and online services through our Services. We also do not let third parties do this on our Services. So, we have no need to respond to Do Not Track signals, and we do not respond to such signals.
We make reasonable and appropriate steps to protect personal data from unauthorized access, use, disclosure, alteration, and destruction by using physical and electronic safeguards designed to improve the security of the personal data. However, as no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your information.
Our Services are hosted in the United States. If you choose to use our Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal data outside of those regions to the United States for storage and processing.
Also, we may transfer your personal data from the U.S. to other countries or regions in connection with storage and processing of personal data. By providing personal data, on or to our Services, you consent to such transfer, storage, and processing. We take steps designed to ensure that the personal data we collect under this statement is processed and protected according to the provisions of this Privacy Notice and applicable law wherever the data is located.
EUROPEAN DATA PROTECTION RIGHTS
If the processing of personal data about you is subject to European Union data protection law and similar laws, you have certain rights with respect to that data:
- You can request access to, and rectification or erasure of, personal data;
- If any automated processing of personal data is based on your consent or a contract with you, you have a right to transfer or receive a copy of the personal data in a usable and portable format;
- If processing of personal data is based on your consent, you can withdraw consent at any time for future processing;
- You can to object to, or restrict, the processing of personal data under certain circumstances; and
- For residents of France, you can send us specific instructions regarding use of your data after your death.
To make such requests or contact our Data Protection Officer, please use the contact information at the bottom of this statement. You also have the right to lodge a complaint with a supervisory authority, but we encourage you to first contact us with any questions or concerns.
We rely on different lawful bases for collecting and processing personal data about you, for example, with your consent and/or as necessary to provide the services you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfil other legitimate interests.
CALIFORNIA PRIVACY RIGHTS
If you are a California resident and the processing of personal data about you is subject to the California Consumer Privacy Act (“CCPA”), you have certain rights with respect to that information as described below.
Right to Know. You have a right to request that we disclose to you the personal data we have collected about you. You also have a right to request additional information about our collection, use, disclosure, or sale of such personal data. Note that we have provided much of this information in this privacy notice and allow access to certain personal data through app settings as described in our FAQs at https://www.halloapp.com/help/. You may also make such a “request to know” by contacting us at firstname.lastname@example.org.
Right to Request Deletion. You also have a right to request that we delete personal data under certain circumstances, subject to certain exceptions. You can delete all your personal data from our servers and your device by deleting your account using app settings and you can delete certain other data as described in our FAQs at https://www.halloapp.com/help/. You may also make a request to delete by emailing us at email@example.com.
Right to Opt-Out. You have a right to opt-out from future “sales” of personal data. We do not sell or intend to sell personal data of anyone and have not done so in the past 12 months or ever. You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us. Further, to provide or delete specific pieces of personal data other than through the settings in our app we must verify your identity as required by law. We do this by having you provide information or take certain action. Finally, you have a right to receive notice of our privacy practices at or before we collect personal data, and you have a right to not be discriminated against for exercising CCPA rights.
Additionally, under California Civil Code section 1798.83, the “Shine the Light” law, California residents who have provided personal data to a business with which the individual has established a business relationship for personal, family, or household purposes (“California Customers”) may request information about whether the business has disclosed personal data to any third parties for the third parties’ direct marketing purposes. We do not disclose personal data to any third parties for their direct marketing purposes as defined by this law. California Customers may request further information about our compliance with this law by e-mailing firstname.lastname@example.org. Please note that businesses are required to respond to one request per California Customer each year and may not be required to respond to requests other than through the designated e-mail address.
California residents under the age of 18 who are registered users of online sites, services, or applications have a right to remove, or request and obtain removal of, content or information they have publicly posted. To learn how to remove content or information you have publicly posted, visit our FAQs at https://www.halloapp.com/help/. Alternatively, to request that we remove content or information, please e-mail us at email@example.com. Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
Retention of Personal Data
We retain personal data for as long as necessary to provide the services and fulfill the transactions you have requested, comply with our legal obligations, resolve disputes, enforce our agreements, and other legitimate and lawful business purposes. Because these needs are different for different data types and for different purposes, actual retention periods can vary significantly based on criteria such as user expectations or consent, the sensitivity of the data, the availability of automated controls that enable users to delete data, and our legal or contractual obligations. To learn about some of our retention practices, please visit our FAQs at https://www.halloapp.com/help/.
Update Your Information or Pose a Question
You can update your account and profile information through your profile settings. If you have questions about your privacy on our Services or this Privacy Notice, please contact us at firstname.lastname@example.org.
Changes to this Privacy Notice
When we post changes to this Privacy Notice, we will revise the “Last Updated” date at the top of the page. If we materially change the ways in which we use personal data previously collected from you through our Services, we will notify you and/or obtain consent for those changes as applicable law requires.
If you have any questions, comments, or concerns about our processing activities, please email us at email@example.com or write to us at HalloApp Inc. 855 El Camino Real Ste 13A-150 Palo Alto, CA 94301-2326