Last updated January 2019
HaloSOS is committed to protecting and respecting your privacy.
This Privacy Statement applies to any information provided or collected through this HaloSOS Limited website and/or any HaloSOS Limited application, including the HaloSOS Limited mobile and tablet applications or any application on social media or other website, (collectively called the Digital Media) which are provided by HaloSOS Limited, a company registered in Ireland with company incorporation number 611437 and registered office address of 52 Aughrim Street, Dublin 7, D07 R7W7, Ireland.
This Privacy Statement of HaloSOS is in relation to data collected and processed by HaloSOS on its own behalf acting as a Data Controller in the provision of its Services such as this marketing website. This does not apply to Personal Data in our software where the Customer is the Data Controller which is covered by our individual service agreements and contracts with our customers.
This Privacy Statement, together with our Cookies Policy, sets out the basis on which we, as a Data Controller, gather, use, process and disclose any personal data we collect from you, or that you provide to us by using Digital Media. We are committed to protecting the privacy and personal data of our users. We will use your personal data only for the purposes and in the manner set forth below which describes the steps we take to ensure our processing of your personal data is in compliance with the General Data Protection Regulation ((EU) 2016/679) (GDPR) and any implementing legislation (Data Protection Legislation).
Please read carefully the following information to understand our use of your personal data.
The Types of Personal Data We May Collect About You
When you visit or use the Digital Media in any way, we may collect and process different types of information about you.
Information You Provide to Us
In order to obtain access to information, services or products provided by us via the Digital Media you may be required to provide personal data such as your name, postal address, country, language, date of birth, email address and telephone number.
We may also collect and process demographic information such as preferences and interests, which we may obtain from third parties such as Google or social media that you use.
You can choose not to provide this information; however, you might not be able to gain access to our information, services or products.
If you contact us for any reason, we may keep a record of the information you provide through email, phone, or through the functions of the Digital Media.
We may also collect and process details of any transactions or usage you carry out through the Digital Media and the fulfillment of orders.
Unless subscribing to a service, the provision of your personal data is not a statutory or contractual requirement and you may refuse to disclose same.
Information We Collect Through Technology
We may obtain information about your general internet usage by using tracking technologies such as cookies. A “cookie” is a small piece of data that may be stored on your computer or mobile device. Cookies help us to remember details of your visits to the Digital Media including, but not limited to, technical information (e.g. traffic data, location data, your IP address, the type of browser you use, browser plug-in types and versions, operating system and platform) or other information about your visit (e.g. websites you access from the Digital Media, other resources that you access on the Digital Media, page interaction information, information which you have viewed and the length of visits to certain pages). For further information on cookies and their use on the Digital Media please see our Cookies Policy.
If you make use of any HaloSOS social media features, either on the Digital Media or through a social media provider, we may access your personal data via that social media provider in accordance with their policies.
When using a social media feature and if you have chosen to include it in your social media account, we may access personal data such as your name, profile picture, gender, birthday, email address, address and any other information you have chosen to make available.
Depending on the privacy settings of you and your friends, we may access information that you provide to a social media provider regarding your location data to provide you with relevant content. We may also access information from social media providers about your use of the Digital Media that we run on their website.
Links to Other Websites
We may, from time to time, provide links to third-party websites. In addition, third parties’ websites may also provide links to the Digital Media. Should you choose to visit these third party websites, you should review their privacy statements to ensure you understand and are comfortable with their practices concerning your personal data.
We do not accept, and we disclaim, any responsibility for the privacy statements and data protection practices of any third party website. These links are provided to you for convenience purposes only, and you access them at your own risk.
Uses Made of Your Personal Data
Generally, all information collected is used for the purpose for which you submitted the information to us or as otherwise identified at the point of collection or in this Privacy Statement.
We may use your personal data for our legitimate business interests for the following purposes:
To provide you with general information on the Digital Media and to provide you with additional information about our products and services.
To respond to your requests for information, feedback and other communication or correspondence you may submit to us.
To measure your interest in and improve our products, services, and Digital Media.
To ensure that content on the Digital Media is presented in the most effective manner for you and for your computer or mobile device.
To provide you with information, products or services that you request from us.
To carry out our obligations arising from any contracts entered into between you and us.
To allow you to participate in interactive features of the Digital Media when you choose to do so.
To notify you about changes to the Digital Media, services, products or policies.
To notify you about special offers and products or services that may be of interest to you where you have consented to be contacted for such purposes.
We may use your personal data to comply with any legal obligations. In addition to the purpose for which you submitted your personal data, you may also be given the option to have your personal data used for an activity or service different from the primary activity or service that you are requesting. If you choose to consent to receive these additional services, we will use your personal data to provide them to you. You have the right to withdraw your consent at any time. Please contact us if you wish to do so.
Where we Store your Personal Data
The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA), for the purposes described above. Those countries may not provide an adequate level of protection in relation to processing your data. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers who act on our behalf. Such staff may be engaged in, among other things, the processing of your request for information and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing of your data. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Statement and the Data Protection Legislation.
We will store your personal data only for as long as necessary for the purposes of providing access to our Digital Media and related services to you; as required by law, and for the exercise or defense of any legal claims.
Safeguarding our Personal Data
It is extremely important to us that your personal data is kept securely and confidentially. However, as no data transmission over the internet can be guaranteed as 100% secure, we cannot ensure or warrant the security of any information that you transmit to us and you transfer the personal data at your own risk.
We endeavor to use appropriate technical and organizational measures in order to protect against unauthorized or unlawful processing of your personal data, including unauthorized destruction, alteration or disclosure or access.
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Disclosure of your Personal Data
We may disclose your personal data to third parties. Where a service provider provides a service or function on our behalf, including credit card processing, business analytics, customer service, marketing, distribution of surveys, and fraud prevention.
We may also authorize third-party service providers to collect information on our behalf, including as necessary to operate features of the Digital Media or to facilitate the delivery of online advertising tailored to your interests.
When you access certain HaloSOS social media features through the Digital Media, you are sharing information with the social media provider and the information you share will be governed by their privacy statements (including that we may access such information via the social media provider). You may be able to modify your privacy settings for these social media providers.
If HaloSOS or substantially all of its assets are acquired by a third party, in which case your personal data held by us may be included in the transferred assets. Similarly, personal data may be transferred as part of a corporate reorganization, insolvency proceeding, or another similar event, if permitted by and done in accordance with the applicable law.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or court order, or in order to enforce, establish, exercise or defend legal rights, the rights, property, or safety of you, us, our group, or employees.
Your Consent and Rights
By visiting our website, using our service, or completing a contact form, you consent to the collection and use of your information and other activities as outlined in this Statement.
You have a right to know what personal data we hold about you and to request a copy of the personal data held by us about you by contacting us.
You can also contact us to:
Request to correct your personal data if it is inaccurate, incomplete or out of date or request the deletion of your personal data.
Have the option not to share any of your personal data with us or to object to the processing of your data or data portability at any time.
Opt out to receiving newsletters, announcements, or other communications and/or services from the Digital Media, by clicking unsubscribe. Alternatively do not opt-in for those communications or services at the time of registration. If you have opted-in and, at a later time, or amend any of your preferences by contacting us.
Along with every email communication sent to you, we provide you the opportunity to discontinue receiving future communications. To do this follow the unsubscribe process or directions provided in the email. We will respond to your request in writing, or orally if requested, as soon as practicable and in any event not more than one month after receipt of your request. We may request proof of identification to verify your request. All requests should be addressed to firstname.lastname@example.org.
It is your responsibility to ensure that any information you have provided to us is accurate and up-to-date. If any of the information that you have provided to us changes, please send us an email entitled ‘CHANGE OF DETAILS’ to email@example.com.
You have the right to lodge a complaint with the Data Protection Commissioner if you are unhappy with how we are processing your personal data.
Changes to this Privacy Statement
We reserve the right to change this Privacy Statement from time to time at our sole discretion. If we make any changes, we will post those changes here and update the “Last Updated” date at the bottom of this Privacy Statement. Where you have previously consented to our use of your personal data, your continued use of the Digital Media after we make changes are deemed to be acceptance of those changes, so please check this Privacy Statement periodically for updates.
Questions, comments, requests, and complaints regarding this Privacy Statement and the information we hold are welcome; please contact us at firstname.lastname@example.org
Subcontractors and Partners Data Processing
Depending on the information processed on your behalf by HaloSOS, we may need to share data with partners or subcontractors in order to deliver your service.
Amazon Web Services (AWS)
The HaloSOS software as a service product is delivered using AWS Database services, storage servers, and application servers. Services are delivered from data centers specified in your service agreement. Find their privacy notice here:
Used for accounting, invoicing, billing, quotes, and financial reporting. HaloSOS stores subscription details, billing history, tax information, and customer contact details for the purpose of delivering invoices and payment reminders. Find their security assurance here: https://www.xero.com/ie/about/security/