If you are a resident of California, in addition to the rights set forth above, you have the right to request information from us regarding the manner in which we share certain categories of personal information with third parties for their direct marketing purposes. California law gives you the right to send us a request at a designated address to receive the following information:

•  The categories of information we disclosed to third parties for their direct marketing purposes during the preceding calendar year.
•  The names and addresses of the third parties that received that information; and if the nature of the third party’s business cannot be determined from their name, examples of the products or services marketed.

This California Consumer Act Privacy Notice (“CCPA Notice”) applies to “Consumers” as defined by the California Consumer Privacy Act (“CCPA”). For the purpose of this CCPA Notice, personal information applies to “Personal Information” as defined by the CCPA (also referred to herein as “PI”).

We collect and share the following categories of PI from the corresponding sources and for the corresponding purposes set forth in the table below.

Category of Personal Information We Collect Sources of Personal Information We Collect Purposes of Collecting Personal Information Categories of Third Parties with whom Personal Information is shared Purposes for which we may collect and use the personal information
Identifiers
(e.g. Name, Phone Number, Email Address, I.P. Address, Account Name)
Directly from you; authentication partners; Payment Vendors Delivering services requested by you; processing and managing interactions and transactions; Research and Development; quality assurance; improving Halo Capital Group’s services; security; fraud prevention; marketing; debugging Halo Capital Group affiliates; Service Professionals; Vendors which assist us in providing services and running our internal business operations (“Vendors”) Performing services on behalf of Halo Capital Group; processing and managing interactions and transactions; Research and Development; quality assurance; improving Halo Capital Group’s services; security; fraud prevention; marketing; debugging
Personal Records
(e.g. Name, Phone Number, Email Address)
Directly from you; authentication partners; Payment Vendors Delivering services requested by you; processing and managing interactions and transactions; Research and Development; quality assurance; improving Halo Capital Group’s services; security; fraud prevention; marketing; debugging Halo Capital Group affiliates; Service Professionals; Vendors Performing services on behalf of Halo Capital Group processing and managing interactions and transactions; Research and Development; quality assurance; improving Halo Capital Group’s services; security; fraud prevention; marketing; debugging
Customer Account Details / Commercial Information
(e.g. details of service requests)
Directly from you; Data Enrichment Tools; Payment Vendors Delivering services requested by you; processing and managing interactions and transactions; Research and Development; quality assurance; improving Halo Capital Group’s services; security; fraud prevention; marketing; debugging Halo Capital Group affiliates; Service Professionals; Vendors Delivering services requested by you; processing and managing interactions and transactions; Research and Development; quality assurance; improving Halo Capital Group’s services; security; fraud prevention; marketing; debugging
Internet Usage Information
(e.g. information regarding your interaction with our services)
Directly from you; analytics partners; advertising partners Delivering services requested by you; processing and managing interactions and transactions; Research and Development; quality assurance; improving Halo Capital Group’s services; security; fraud prevention; marketing; debugging measuring advertising efficacy Vendors Delivering services requested by you; processing and managing interactions and transactions; Research and Development; quality assurance; improving Halo Capital Group’s services; security; fraud prevention; marketing; debugging
Sensory Data
(e.g. recordings of customer service calls)
Directly from you Delivering services requested by you; processing and managing interactions and transactions; Research and Development; quality assurance; improving Halo Capital Group services; security; fraud prevention Vendors Delivering services requested by you; processing and managing interactions and transactions; Research and Development; quality assurance; security; fraud prevention
Inferences from PI Collected
(e.g. your preferences, likelihood of interest in certain of our services)
Data Management providers; advertising partners; internal systems Delivering services requested by you; Measuring advertising efficacy; marketing; improving Halo Capital Group’s services Vendors Performing services on behalf of Halo Capital Group; processing and managing interactions and transactions; quality assurance; improving Halo Capital Group services; security; fraud prevention; marketing; debugging

 

Please note that we may also disclose all personal information as described in the “How We Use Information” section of the Privacy Policy.

Privacy Rights

The CCPA grants individuals the following rights:

Information. You can request information about how we have collected, used and shared your Personal Information during the past 12 months.

Access. You can request a copy of the personal information that we maintain about you.

Deletion. You can ask us to delete the personal information that we collected or maintain about you.

Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. We will also respond to requests for information and access only to the extent we are able to associate with a reasonable effort the information we maintain with the identifying details you provide in your request. If we deny your request, we will communicate our decision to you. You are entitled to exercise the rights described above free from discrimination.

How to Submit a Request

To request deletion of personal information, visit the the following page:
halocapitalgroup.com/forget-me

To request access of personal information, visit the the following page:
halocapitalgroup.com/request-access

Identity verification. The CCPA requires us to verify the identity of the individual submitting a request to access or delete personal information before providing a substantive response to the request.  We will ask you to verify your identity when you submit a request.

Authorized agents. California residents can empower an “authorized agent” to submit requests on their behalf.  We will require the authorized agent to have a written authorization confirming that authority.

Notice of Collection of Personal Information. We list the categories of your information that we collect and the business and commercial purposes for our use as described in the detailed chart above.