PRIVACY POLICY

Halo Top International LLC, of 1658 Milwaukee Ave #100-4937, Chicago, IL USA 60647, (“Halo Top”, “us” or “we”) is concerned about online privacy issues and want you to be familiar with how we collect, use and disclose any information that individually identifies you (e.g. your name, address, phone number, e-mail address) (“personal information”). This Privacy Policy explains our online information practices and the choices you, as a visitor to any web page, web site application or platform offered through any social media website operated or provided by Halo Top related to its European operations (collectively, “Halo Top Websites” and each is a “Halo Top Website”) can make about the collection and use of your personal information. We will only collect, use and disclose your personal information in accordance with this Privacy Policy.

For the purposes of applicable data protection legislation, including the General Data Protection Legislation, Halo Top’s EU representative is Halo Top UK Ltd.

WHAT PERSONAL INFORMATION DO WE COLLECT?

We will collect personal information from you when you voluntarily provide it to us through a number of features available on or through a Halo Top Website. For example, we may ask you to provide personal information if you:

• contact our consumer service representatives with an enquiry about our products, services or Halo Top Website;

• request any information, service or other offering from us;

• ask to receive online information from us, such as e-mail newsletters or e-mail updates;

• participate in a review, survey, a consumer research panel, or similar type of activity; and

• otherwise participate in features of a Halo Top Website that ask for personal information (such as, the store locator feature).

We will also collect personal information about you from publicly available sources, such your social media account (subject to your account privacy settings).

We will only use the personal information that you provide for the purposes for which it was collected.

WHAT PURPOSES DO WE PROCESS YOUR PERSONAL INFORMATION FOR, AND ON WHAT LAWFUL BASES?

We will use the personal information you provide:

• To fulfil a contract, or take steps linked to a contract, this includes: In providing service(s) and / or products to you, or administering prize draws;

• As required by us to conduct our business and pursue our legitimate interests, in particular, we will use your personal data:

  • In responding to your questions or comments;

  • In identifying your needs and / or preferences;

  • In improving our products and / or services;

  • In fulfilling your requests; and

  • In administering and managing our business operations.

 We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details provided below.

• Where you give us consent:

  • To place cookies and use similar technologies in accordance with the cookies section below and any information provided to you when those technologies are used; and

  • To provide you with marketing information about products and services via Google, Facebook, and Instagram, which we feel may interest you.

 Whenever you give your consent to us, you may withdraw that consent at any time by contacting us using the details provided below or, where applicable, by clicking on the unsubscribe link in the marketing communication itself.

• In response to requests by government or law enforcement authorities conducting an investigation.

HOW DO WE SHARE PERSONAL INFORMATION?

Except as described below, we do not sell, transfer or otherwise disclose to third parties the personal information that we collect on Halo Top Websites. At times, we provide your personal information to third parties who provide services on our behalf (such as, website hosting, maintenance, and customer service call centre operation, marketing and PR agencies, warehouse storage, shipment fulfilment and logistics). These entities may use the information solely in conjunction with the specific services they provide for us (e.g., responding to your questions or comments or investigation of a complaint).

We reserve the right to transfer any personal information we have about you in the event that we sell or transfer all or a portion of our business or assets to a third party. Further, we reserve the right to disclose any personal information as needed if such information is requested by law enforcement agencies or if we are requested to do so by law, regulation, court order, or by a government entity. We will also disclose your personal information to third parties if we have reason to believe that disclosing such information is necessary to: (i) conduct investigations of possible breaches of law; (ii) cooperate in any legal investigation; (iii) identify, contact, or bring legal action against someone who may be violating any terms of use of any Halo Top Website; or (iv) to protect our rights, privacy, safety or property. Lastly, we will disclose your personal information for any other purpose to which you specifically consent.

LINKS TO OTHER WEBSITES

Halo Top Websites may contain links to other websites operated by third parties. Any such websites are wholly independent from our websites, and we have no control over those websites, their operators, their security, their privacy policies or their practices. Before providing any of your personal information on any such other website, you should review the policies on privacy and security for such website.

INTERACTIVE FEATURES/SOCIAL MEDIA

If you use social and/or other interactive features that may be available on a Halo Top Website (e.g. Facebook or Twitter feeds, comment sections, chat rooms, etc.), you should know that when you voluntarily disclose your personal information using social media features or in interactive areas that may be available on Halo Top Websites where personal information can be posted, the information can be collected and used by other Internet users. This may result in unsolicited messages from other posters or parties. We undertake no obligations as to the security of information you voluntarily post using social media features or in interactive areas that may be available on Halo Top Websites.

YOUR RIGHTS

You have the right to ask Halo Top for a copy of your personal data; to correct, delete or restrict processing of your personal data; and to obtain the personal data you provide in a structured, machine readable format. In addition, you can object to the processing of your personal data in some circumstances (in particular, where we do not have to process the data to meet a contractual or other legal requirement and in relation to processing based on our legitimate interests (see above)).

As noted above, where we have asked for your consent, you may withdraw that consent at any time. If you ask to withdraw your consent to Halo Top processing your data, this will not affect any processing which has already taken place at that time.

These rights may be limited, for example if fulfilling your request would unfairly reveal personal data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep.

If you would like to exercise these rights, you can contact us using the details set out below. If you have unresolved concerns you also have the right to complain to data protection authorities in the country where you live or work, or where you consider a breach of data protection law has occurred.

Where we require your personal data to comply with legal or contractual obligations, then provision of such data is mandatory: if such data is not provided, then we will not be able to manage our contractual relationship with you, or to meet obligations placed on us. In all other cases, provision of requested personal data is optional.

HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?

Where applicable, we’ll keep your personal data for as long as your company is a Halo Top customer. If it has been 4 years since we last shipped an order to your company or you last interacted with Halo Top (including, the Halo Top Websites), we will delete or anonymise your data. This is with the exception of your company payment details and transaction history which we need to keep for 10 years from this date. These periods will be extended if there is a likely or ongoing legal claim from you or your company or if we are required to keep it in connection with legal proceedings, or by law or industry guidelines.

CHILDREN’S PRIVACY

We are committed to protecting the privacy of children and we do not knowingly solicit personal information from children under the age of 18. If a child has already provided us with personal information, his or her parent or guardian may contact us to have this information deleted.

TRANSFER

Your personal information will be transferred to jurisdictions outside of the European Economic Area which may not provide adequate protection for such information, including, the United States of America where our servers are located.

 We do this on the basis of an intra-group data transfer agreement containing European Commission-approved standard contractual clauses, a copy of which can be requested by using the details provided below.

 COOKIES

Halo Top Websites uses (first party and third party) cookies (small files placed on website users’ hard drive) or similar to distinguish you from other users of the Halo Top Websites. This helps us to provide you with a high-quality experience when you browse the Halo Top Websites and also allows us to improve the Halo Top Websites.

We use the following categories of cookies on the Halo Top Websites:

1. Strictly Necessary Cookies – Up to 13 months

Some cookies are essential for the operation of the Halo Top Websites. For example, some cookies allow us to identify registered users and ensure they can access the Halo Top Websites. If a registered user opts to disable these cookies, the user may not be able to access all of the content of the Halo Top Websites.

2. Performance Cookies – Up to 13 months

Other cookies may be used to analyse how users use the Halo Top Websites and to monitor its performance. This allows us to provide a high quality experience by customising the offering and quickly identifying and fixing any issues that arise. For example, performance cookies may be used to keep track of which pages are most popular and to determine why some pages are receiving error messages.

Google Analytics is a web analysis service provided by Google, Inc. We use Google Analytics to monitor how visitors use the Halo Top Websites, to compile reports and to help us improve the Halo Top Websites. Please see Google’s privacy policy here for further information on the data Google collects and how it is processed. If you prefer to not have data reported by Google Analytics, you can install the Google Analytics Opt-Out Browser Add-On by following the instructions here. You may opt out of Google’s use of tracking technologies by visiting the Google advertising opt-out page here.

3. Functionality Cookies – Up to 13 months

Functionality cookies are used to allow us to remember users’ preferences and tailor the Halo Top Websites to provide enhanced features.

4. Targeting Cookies – Up to 13 months

Targeting cookies are used to serve users with adverts, and to collect information about users’ browsing habits and usage of the Halo Top Websites in order to make adverts more relevant to users and their interests. They are also used to limit the number of times users see an advert as well as help measure the effectiveness of an advertising campaign.

5. Social Media Cookies – Up to 13 months

These cookies allow users to share what they’ve been doing on the Halo Top Websites on social media such as Facebook and Instagram (e.g. if you use a “like” or a “share” button for a feature on our Halo Top Websites) – when this is the case, such third party providers will share information with us.