Halo Online Technology Co., Ltd. is committed to protect your privacy. Our guiding principle toward data collection is to collect only the minimal data required to operate a world-class VPN service at scale. We want you to understand what information we collect, what we don't collect, and how we collect, use, and store information. We do not collect logs of your activity, including no logging of browsing history, traffic destination, data content, or DNS queries. We also never store connection logs, i.e., no logs of your IP address, your outgoing VPN IP address, connection timestamp, or session duration. We designed our systems not to have sensitive data about you; even when compelled, we cannot provide data that we do not possess.
We collect information about the product and services that you use and how you use them in order to properly provide the core or important features of our product and service, or to improve our product and service, or to provide additional features to our product (such as socializing functions or value-added services and promotions, etc.).Some of the typical reasons that we collect personal data include:
- Provide our product and services, including our app and related website (if any), and improve them over time;
- Allow you to download and purchase products and services;
- Personalize and manage our relationship with you, including introducing you to products or services that may be of interest to you or to provide customer support;
When you open the APP seeking for our VPN services, the APP assigns a unique identifier to you for the service (such unique identifier just binds up with your device identification code, but does not tie to any other personal information of users). When you use the VPN services, we will check your account information through this unique identifier to determine the level of service you have signed up for before establishing your VPN connection.
If you contact us directly, we may receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide. We may also receive a confirmation when you open an email from us.2. USE OF INFORMATION
We will be able to use the information collected to 1) improve and develop our products and services; 2) communicate with users; 3) support advertising and related activities. E.g:
- Maintain, improve or manage our services, perform business analysis, provide advertising and related activities
- Implement our Terms of Service to prevent illegal activities and abuse of services, protect the legal rights, property and security of VPN services and users and resolve related disputes;
- Comply with applicable laws and assist law enforcement when we believe it is reasonable and meets applicable legal standards.3. DATA RETENTION
We may retain information about you and your use of the Services, including personally identifiable information, as long as you are required to provide the services and uses described in this Privacy Statement. This usually means that we will retain information for the duration of your account.4. SECURITY MEASURES
We take adequate protective measures to prevent loss of information, misuse, unauthorized access, disclosure, alteration or destruction. While we strive to protect your information and privacy, there is no guarantee that data transfer or storage is 100% secure.5. DIRECT MARKETING
- For the purposes of fulfilling our contractual obligations to users.
- For a legitimate interest associated with the operation of our business, including: * Enhancing the quality, reliability, and effectiveness of our VPN Services, and Apps. * Communicating with customers to provide information and seek feedback related to our VPN services and Apps.
You can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent. As well, you have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the "unsubscribe" or "opt-out" link in the marketing emails we send you.
You can exercise your rights under the GDPR to access, transfer, correct, delete, or object to the processing of your personal information by contacting us at firstname.lastname@example.org. INTERNATIONAL DATA TRANSFERS
Revision date of this agreement: January 1, 2020