Last Updated: April 10, 2025
1. INTRODUCTION
Welcome to HaloHale (“we,” “our,” or “us”), operated by XIM., JSC. We respect your privacy and are committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website HaloHale.com, including any related services, features, or content (collectively, the “Site”).
Please read this Privacy Policy carefully. By accessing or using our Site, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with our policies and practices, please do not use our Site.
2. INFORMATION WE COLLECT
2.1 Personal Information
We may collect the following types of personal information:
- Identity Data: Name, username, or similar identifiers.
- Contact Data: Email address, physical address, telephone number.
- Technical Data: Internet protocol (IP) address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, device type.
- Usage Data: Information about how you use our Site, products, and services.
- Health-Related Preferences: Topics of health interest, wellness goals, or content preferences you voluntarily share.
2.2 Non-Personal Information
We also collect non-personal information that does not directly identify you:
- Aggregate Data: Statistical or demographic data for any purpose. This data may be derived from your personal information but is not considered personal information as it does not directly or indirectly reveal your identity.
- Anonymous Usage Analytics: General patterns of usage without identifying individuals.
3. HOW WE COLLECT INFORMATION
3.1 Information You Provide to Us
- When you register for an account
- When you subscribe to our newsletter
- When you use our interactive features or tools
- When you participate in surveys or provide feedback
- When you contact us directly
3.2 Automated Technologies or Interactions
As you navigate through our Site, we may automatically collect technical data by using the following technologies:
- Cookies: Small files stored on your device to enhance user experience. See our separate Cookie Policy section for more details.
- Log Files: Track actions occurring on the Site and collect data including IP address, browser type, referring/exit pages, and date/time stamps.
- Web Beacons: Electronic files used to record information about how you browse the Site.
- Analytics Tools: We use services like Google Analytics to understand how visitors interact with our Site.
3.3 Third Parties or Publicly Available Sources
We may receive personal information about you from various third parties and public sources:
- Analytics providers such as Google
- Advertising networks such as Google AdSense
- Search information providers
- Identity and contact data from publicly available sources
4. HOW WE USE YOUR INFORMATION
We use the information we collect for the following purposes:
4.1 Primary Purposes
- To provide, operate, and maintain our Site
- To improve, personalize, and expand our Site’s features
- To understand how users interact with our Site
- To develop new products, services, features, and functionality
- To communicate with you about updates, security alerts, and support
4.2 AI-Driven Content and Features
- To power our AI systems that process health information and deliver personalized content
- To train and improve our AI systems to better serve user needs
- To analyze patterns in health interests for content development
- To personalize health information based on your expressed interests
4.3 Marketing and Advertising
- To deliver relevant website content and advertisements
- To measure or understand the effectiveness of advertisements we serve
- To send promotional emails about new content, features, or health-related information we think you may find interesting
4.4 Legal Bases for Processing (GDPR Compliance)
For users in the European Economic Area (EEA), we process your personal information based on the following legal grounds:
- Consent: Where you have explicitly given us permission to process your personal information for a specific purpose.
- Legitimate Interest: Where processing is necessary for our legitimate interests and your fundamental rights do not override those interests.
- Contract Fulfillment: Where processing is necessary for the performance of a contract with you.
- Legal Obligation: Where processing is necessary for compliance with a legal obligation.
5. DISCLOSURE OF YOUR INFORMATION
We may disclose your personal information to the following categories of recipients:
5.1 Service Providers
We may share your information with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work.
5.2 Advertising Partners
We use Google AdSense, an advertising service provided by Google, to display advertisements on our Site. Google AdSense may use cookies, web beacons, and other technologies to collect information about your use of our Site and other websites, including your IP address, browser information, and viewed page content. This information is used to provide interest-based advertising and to evaluate the effectiveness of advertisements. For more information about how Google collects and uses your data, please visit Google’s Privacy Policy: https://policies.google.com/privacy.
5.3 Analytics Providers
We use analytics services such as Google Analytics to collect and analyze information about the use of our Site and to report on activities and trends. These services may collect information regarding your use of our Site and may also collect information regarding your use of other websites, apps, and online resources.
5.4 Business Transfers
If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction.
5.5 Legal Requirements
We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, judicial proceedings, court orders, or legal processes.
6. COOKIES AND SIMILAR TECHNOLOGIES
6.1 What Are Cookies
Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by website owners to make their websites work, provide analytics, remember your preferences, and serve relevant advertisements.
6.2 Types of Cookies We Use
- Essential Cookies: Necessary for the operation of our Site.
- Analytical/Performance Cookies: Allow us to recognize and count the number of visitors and see how visitors move around our Site.
- Functionality Cookies: Enable us to personalize content and remember your preferences.
- Targeting Cookies: Record your visit to our Site, the pages you have visited, and the links you have followed. We may use this information to make our Site and the advertising displayed more relevant to your interests.
6.3 Google AdSense and Cookies
Google AdSense uses cookies to serve ads based on a user’s prior visits to our Site or other websites. Google’s use of advertising cookies enables it and its partners to serve ads to users based on their visits to our Site and/or other sites on the Internet.
6.4 Your Choices Regarding Cookies
You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Site may become inaccessible or not function properly.
7. DATA SECURITY
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure.
8. DATA RETENTION
We will only retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information, and applicable legal requirements.
9. YOUR DATA PROTECTION RIGHTS
Depending on your location, you may have the following rights regarding your personal information:
9.1 For Residents of the European Economic Area (EEA) and United Kingdom
- Right to Access: The right to request copies of your personal information.
- Right to Rectification: The right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.
- Right to Erasure: The right to request that we erase your personal information under certain conditions.
- Right to Restrict Processing: The right to request that we restrict the processing of your personal information under certain conditions.
- Right to Data Portability: The right to request that we transfer the data we have collected to another organization, or directly to you, under certain conditions.
- Right to Object: The right to object to our processing of your personal information.
9.2 For Residents of California
Under the California Consumer Privacy Act (CCPA), California residents have the following rights:
- Right to Know: The right to request information about the personal information we collect, use, disclose, and sell.
- Right to Delete: The right to request deletion of personal information that we have collected from you.
- Right to Opt-Out: The right to opt-out of the sale of your personal information.
- Right to Non-Discrimination: The right not to be discriminated against for exercising any of your CCPA rights.
9.3 How to Exercise Your Rights
To exercise any of the rights described above, please submit a request to us by either:
- Emailing us at: help@halohale.com
We will respond to all legitimate requests within the timeframe required by applicable data protection laws.
10. CHILDREN’S PRIVACY
Our Site is not intended for children under 16 years of age. We do not knowingly collect personal information from children under 16. If you are a parent or guardian and believe your child has provided us with personal information, please contact us. If we discover we have collected personal information from a child under 16 without parental consent, we will delete that information from our servers.
11. INTERNATIONAL DATA TRANSFERS
We are based in Vietnam, and your information may be processed in countries where the data protection laws differ from those in your country. By submitting your personal information, you acknowledge this transfer, storing, or processing.
For users in the EEA, we ensure appropriate safeguards are in place to protect your personal information when transferred internationally.
12. THIRD-PARTY LINKS
Our Site may contain links to third-party websites, services, or applications that are not operated by us. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
13. CHANGES TO THIS PRIVACY POLICY
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the “Last Updated” date. You are advised to review this Privacy Policy periodically for any changes.
14. CONTACT US
If you have any questions about this Privacy Policy, please contact us at:
- Email: help@halohale.com
- Company: XIM., JSC
- Address: To 37, Cum 6, Phu Thuong, Tay Ho, HN, VN
15. CONSENT TO PROCESSING OF PERSONAL INFORMATION
By using our Site or providing personal information to us, you consent to the collection, processing, maintenance, and transfer of such information in and to Vietnam, the United States and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to those in the country where you reside and/or are a citizen.
This Privacy Policy is compliant with current privacy regulations, including GDPR, CCPA, and Google AdSense requirements. However, as regulations and our business practices evolve, we recommend reviewing and updating this policy regularly with legal counsel specialized in digital privacy law.
