Privacy Policy

HALO Branded Solutions, Inc. and our affiliates and subsidiaries (“HALO,” “we,” “us,” or “our”) are committed to protecting your privacy. This Privacy Policy describes how we collect, use, disclose and otherwise process the information we collect about you when you:

• Visit our main website (www.halo.com), its subdomains, and all other websites that HALO owns or controls and link to this Privacy Policy (collectively, the “Sites”);
• Submit purchase orders or engage in other transactions with us;
• Communicate with us by email, telephone, mail, facsimile, or in person at events;
• Sign up to receive email, mail, or other communications from us; or
• Otherwise provide Personal Information (as defined below) to us, whether offline or online in the context of our relationship with you.

Please read this Privacy Policy carefully before using the Sites or submitting your information to us. If you are our vendor, supplier, contractor, employee, or job applicant, including a prospective or current Account Executive, this Privacy Policy does not apply to information we collect about you in the context of those relationships with us, and to the extent required by law, our privacy practices are set out in our agreement with you, personnel notices, or job postings, as applicable. In certain situations, we may receive your Personal Information from our corporate customers to provide services to them. Our corporate customers are responsible for their own privacy practices and are not subject to this Privacy Policy. To understand how our corporate customers collect, use, and disclose your Personal Information, we recommend that you review their privacy policies.

What Information We Collect

“Personal Information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household.

We may collect the following types of Personal Information about you:

• Identifiers, such as your name, your place of business, job title, postal address, email address, telephone number, mailing or shipping address, and any personal or business contact information you voluntarily provide to HALO;
• Customer records, such as your signature;
• Protected class information, such as your gender;
• Commercial information, such as payment information (including your credit or debit card information, bank account details, and other payment processing information), information relating to your purchases or items you are interested in, and credit information;
• Professional information, such as your employer, occupation, salary, and professional accomplishments;
• Internet or other electronic network activity information, including information we automatically receive about the devices you use to access the Sites, your IP address, browser type, and how you interact with the Sites;
• Geolocation data, such as the city, state, and zip code associated with your IP address;
• Audio, electronic, visual, or other sensory information, such as photographs you submit to personalize products you purchase;
• Inferences, drawn from any of the information we collect, such as products and services you might be interested in;
• Sensitive Personal Information, consisting of account log-in information; and
• Other information you choose to provide, such as when you participate in a survey, contest, promotion, request customer support, or otherwise communicate with HALO.

How We Collect Your Personal Information

We collect your Personal Information from the following sources:

• You, such as when you visit the Sites, register a user account, order our products, submit a credit application, communicate with us online or offline, or sign up to receive communications from us. When we request your Personal Information, you do not have to provide it, but if you choose not to, we may not be able to provide you with all of our products and services.
• Tracking technologies and other automated sources, such as cookies and other tracking technologies when you visit our Sites and use our services.
• Third parties, such as your employer, friends or other references, business partners, social and other third parties with whom we interact.
• Publicly available sources, such as profiles on websites.

How We Use Your Personal Information

We may use Personal Information as outlined below:

• Provide you with products and services. We may use your Personal Information to process and fulfill your orders; process your payment card and other transactions; send you invoices; evaluate credit applications; administer your customer account; operate contests and promotions; and send you communications related to your orders and our products and services.
• Build and maintain our customer relationships, including through marketing. We may use your Personal Information to improve your experience, send you marketing messages, provide customer service, and showcase our products. We may also draw inferences from the Personal Information you provide to us.
• Improve the Sites and our product and service offerings. We may use your Personal Information to understand who is visiting the Sites, perform market research and analysis, improve the functionality of the Sites, conduct quality assurance, perform internal business reviews, and develop new offerings.
• Maintain the security of the Sites and our services. We may use your Personal Information to maintain security and integrity, detect security incidents, protect against fraudulent and illegal activity, and enforce our terms of use.
• Comply with our legal obligations and respond to legal proceedings. We may use your Personal Information to comply with legal obligations and to establish, exercise, or defend legal claims.
• In connection with a corporate transaction, such as a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy, or other change of ownership or control.

How We Disclose Your Personal Information

We may disclose your Personal Information as outlined below:

• Our Account Executives. We may disclose your name and contact information to one or more of our Account Executives if you purchase a product or submit an inquiry. Account Executives are our local sales representatives who represent our product lines, many of whom work as independent contractors.
• To our business partners. We may disclose your name and contact information to our business partners, including our product manufacturers and vendors, so that they can provide products and services to us.
• To our suppliers and other service providers. We may disclose your Personal Information to suppliers, service providers, and vendors that perform tasks on our behalf, such as order processing, fulfillment, shipping, billing, data storage, marketing, and operating the Sites.
• To advertisers and advertising networks. We may disclose your Site usage information to our advertisers and advertising networks for their own business purposes.
• To public and governmental authorities. We may disclose your Personal Information to regulatory authorities, law enforcement, public bodies, and judicial bodies.
• To other third parties, as reasonably necessary. We may disclose your Personal Information:
  • In relation to a merger, sale, acquisition, restructuring, or other change of ownership or control;
  • To comply with applicable laws, legal processes, or regulatory requests; protect the rights, privacy, property, interests or safety of HALO or others; pursue available remedies; enforce our terms of use; or respond to an emergency; and
  • To comply with your request.

Retention of Information

As a general matter, we will retain your Personal Information for as long as it is necessary to fulfill the purposes for which we collected it, to satisfy legal and regulatory requirements, or as required or permitted by applicable law. To determine the length of time for which we will retain Personal Information, we will consider the volume and sensitivity of the Personal Information, the risk of harm to people like you, the purposes for which we collect and use the Personal Information, and applicable legal and regulatory requirements.

In certain circumstances, we may anonymize your Personal Information so that it can no longer be associated with you. We may use such anonymized information for various business purposes, including analytics and research, and may retain it indefinitely without further notice to you.

Cookies and Web Beacons

Cookies

We may send cookies, which are small pieces of data, to your web browser to facilitate your use of the Sites. Cookies help us deliver content specific to your interests and permit our servers to recall information from your prior visits. We may use information collected from cookies in conjunction with other information we have collected from you. We do not use cookies to access information on your computer or device. You can choose whether to accept cookies by adjusting the settings of your browser. You may also choose to reject certain cookies by clicking the “Do Not Sell or Share My Personal Information” or “Manage Privacy Preferences” link in the Site footer where applicable.

Web Beacons

Web beacons are small bits of code embedded in web pages or in emails. We may use web beacons to deliver or communicate with cookies, count users who have visited the Sites, and understand usage patterns. We also may include web beacons in emails to learn if messages have been opened, acted on, or forwarded. Web beacons cannot be declined when delivered via a regular web page. However, they can be refused when delivered via email by disabling HTML images or refusing HTML emails via your email software.

Web Analytics and Advertising Services Provided by Others

We may use web analytics providers to understand how visitors engage with our Sites and services. For example, we use Google Analytics, which employs cookies to analyze how visitors use and interact with the Sites. For more information, please review the Google Analytics Terms of Service, the Google Privacy Policy, and Google Analytics Support.

We may also engage third parties to serve advertisements on the Sites and/or on third-party services. Some of these ads may be tailored to your interests based on your browsing of the Sites and elsewhere on the Internet (“interest-based advertising” or “online behavioral advertising”). These providers may use cookies, web beacons, and other tracking technologies to collect information about your use of the Sites and other websites.

Consent to Share Personal Information When Using Live Chat Function

By using the Live Chat feature, you consent to our collection and analysis of all personal information provided. We utilize a vendor called Intercom (“Chat Vendor”) to process, analyze, and store the contents of the chat on our behalf. The Chat Vendor does not “sell” personal information as defined by the CCPA, but to review how the Chat Vendor may “share” and disclose personal information please review their privacy policy. By using the Live Chat Feature, you direct the Company to disclose any personal information you provide with the Chat Vendor and you consent to their privacy practices.

Do Not Track

Some web browsers incorporate a Do Not Track (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. Not all browsers offer a DNT option, and DNT signals are not yet uniform. For this reason, many digital service operators, including HALO with respect to most of the Sites, do not recognize or respond to DNT signals. To learn more about DNT signals, you may wish to visit www.allaboutdnt.com.

Your Choices

Opt Out from Emails and Other Communications

If you no longer wish to receive marketing emails or other marketing communications from HALO, you may unsubscribe at any time by clicking the “unsubscribe” link in the emails you receive from us or by contacting us using the information below in the “Contact Us” section. Please note that even if you opt out of marketing communications, we may continue to send you non-promotional communications regarding your order, your account, or other transactions.

Your Online User Account

If you have registered an online account on the Sites, you may make changes to your Personal Information by logging in to your account and making changes there.

Opt Out of Cookies and Other Tracking Technologies

Regular cookies generally may be disabled or removed using tools available as part of most commercial browsers. Please be aware that if you disable or remove these technologies, some parts of our Sites may not work properly.

Opt Out of Analytics and Interest-Based Advertising

For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit the Digital Advertising Alliance or the Network Advertising Initiative. You may also exercise choices regarding Google Analytics by visiting their opt-out page.

Third Parties

The Sites and other materials may contain references and/or links to third-party websites and services. We are not responsible for any third party’s data collection or privacy practices, and we have no control over what information third parties track or collect. Any access to and use of such linked websites is governed by the respective privacy policies of those third-party websites. We encourage you to review the privacy policies posted on those third-party websites for further information.

Notice to California Residents

Certain California residents have the privacy rights listed below. The rights listed below under the California Consumer Privacy Act and Shine the Light are not the same. To exercise your rights, you will need to follow the directions below.

California Privacy Rights

California residents may have certain rights concerning their Personal Information, described below.

• Request to Know. You have the right to request to know (1) the specific pieces of Personal Information we have collected about you; (2) the categories of Personal Information we have collected; (3) the types of sources from which that Personal Information was collected; (4) the categories of your Personal Information that we sold, shared, or disclosed; (5) the categories of third parties to whom your Personal Information was sold, shared or disclosed; and (6) the purposes for collecting, selling and sharing your Personal Information. You may exercise your right to request to know twice a year, free of charge.

  Please note, in response to a request to know, we are prohibited from disclosing your Social Security number, driver’s license number or other government-issued identification number, financial account number, health insurance or medical identification number, and account password or security questions and answers.

• Request to Delete. You have the right to request that we delete the Personal Information that we have collected from or about you. We may deny your request under certain circumstances, such as if we need to comply with our legal obligations or complete a transaction for which your Personal Information was collected.
• Request to Opt Out of Sale or Sharing of Your Personal Information. You have the right to opt out of the sale or sharing of your Personal Information.
• Request to Correct. You have the right to request that we correct inaccurate Personal Information that we maintain about you.
• Right to Non-Discrimination. If you choose to exercise any of these rights, we will not discriminate against you in any way.

To make a request to know, request to correct, or a request to delete under the California Consumer Privacy Act, please contact us using the information in the “Contact Us” section below.

To make a request to opt out of the sale or sharing of your Personal Information, please use the “Do Not Sell or Share My Personal Information” link in the Site footer. We process opt-out preference signals on a per-device, per-browser basis.

Additional Information on our Processing of Personal Information of California Residents

Generally, in the past 12 months, we collected the categories of Personal Information detailed in the “What Information We Collect” section from the sources described in the “How We Collect Your Personal Information” section of this Privacy Policy.

We use and disclose sensitive personal information only for (i) performing services or providing goods reasonably expected by an average consumer; (ii) detecting security incidents; (iii) resisting malicious, deceptive, or illegal actions; (iv) ensuring the physical safety of individuals; (v) short-term, transient use; (vi) performing or providing internal business services; (vii) verifying or maintaining quality or safety; or (viii) purposes that do not infer characteristics about you.

Although we have not sold your Personal Information for money in the past 12 months, we may disclose Site usage and similar information to advertisers for advertising purposes, which may be considered a “sale” or “sharing” as defined by California law. We do not knowingly sell the Personal Information of individuals under 16 years of age.

If you have questions or concerns about our privacy policies and practices, please contact us using the information in the “Contact Us” section.

California “Shine the Light” Law

Certain California residents may also request information from us once per calendar year about certain Personal Information disclosed to third parties for their own direct marketing purposes, including the categories of information and the names and addresses of those businesses to which we have disclosed such information. To request this information, please contact us using the information provided in the “Contact Us” section below.

Notice to Residents of the European Economic Area, Switzerland and the United Kingdom

HALO Branded Solutions, Inc. is the data controller responsible for the processing of your personal information. You can contact us using the information in the “Contact Us” section below.

Legal Bases for Processing Your Information

We collect and process your Personal Information for the purposes described in the “How We Use Your Personal Information” section on the following legal bases:

Transfers of Personal Information Outside of the EEA, Switzerland, or the United Kingdom

While processing your Personal Information, we may transfer it to an entity in a country outside of the European Economic Area, Switzerland, or United Kingdom. If we make a transfer to an entity in a country that does not meet specific data privacy standards, we will do so lawfully, such as on the basis of the Standard Contractual Clauses approved by the European Commission or the United Kingdom Information Commissioner’s Office, Binding Corporate Rules, on the basis of permissible statutory derogations, or other valid data transfer mechanisms.

Your Rights and Choices

As a resident of the European Economic Area, Switzerland, or the United Kingdom, you may have certain rights with respect to the Personal Information we maintain about you. Conditional on the circumstances under which we collected and process your Personal Information, you may have the right to:

• Access the Personal Information we maintain about you;
• Rectify your Personal Information that is incomplete or misleading;
• Receive a copy of your Personal Information in an electronic format so that it can be transferred to third parties;
• Object to the processing of your Personal Information;
• Restrict the processing of your Personal Information;
• Erase your Personal Information; and/or
• Lodge a complaint with a supervisory authority.

If you have provided your consent for us to process your Personal Information, you have the right to withdraw it at any time. The lawfulness of any processing that occurred prior to your withdrawal will not be affected. You may exercise these rights by contacting us using the information in the “Contact Us” section.

Security

We use commercially reasonable measures to safeguard Personal Information that you have disclosed to us, but absolute security cannot be guaranteed. It is important for you to protect against unauthorized access to your account access information and to your computer. We urge you to keep your account log-in information in a safe place and not to divulge it to anyone. We will endeavor to notify you in the event we become aware of a breach of the security of your Personal Information. However, we shall not be liable for any breach of the security of your Personal Information resulting from your own acts or omissions.

We use one or more secure servers for the Site. By “secure,” we mean that the Site uses the Secure Socket Layer (SSL) protocol and that our web servers are capable of delivering 128-bit encryption. When you make a purchase on the Site, your Personal Information (including payment account information) is transmitted using the SSL protocol and then encrypted into a secure database maintained by our payment gateway provider.

Children’s Privacy

We do not knowingly collect Personal Information from individuals under the age of 18. If we discover that any registration, transaction, or other submission of personal information is made by an individual under the age of 18, we will take reasonable steps to immediately and permanently delete and remove such information, with or without notice.

International Users

If you are visiting the Sites from outside the United States, please be aware that the information we collect may be transferred to, processed, and stored on our servers in the United States in accordance with this Privacy Policy and applicable law. The data protection laws and regulations applicable to your Personal Information that is transferred to the United States may be different from the laws in your country of residence.

Changes to this Notice

We reserve the right to amend this Privacy Policy at any time. We will inform you of any material changes to this Privacy Policy by posting a notice on the Sites. If you are on our email list or if you have an account on the Sites, we may also notify you of such material changes via email or the account. If you object to any modification, your sole recourse is to notify us that you do not agree and to stop using the Sites and providing us with your Personal Information.

Contact Us

If you have any questions about this Privacy Policy or wish to exercise any rights with respect to your Personal Information, you may contact us at: