Last Updated: December 28, 2022
- Submit purchase orders or engage in other transactions with us;
- Communicate with us by email, telephone, mail, facsimile, or in person at events;
- Sign up to receive email, mail, or other communications from us; or
- Otherwise provide Personal Information (as defined below) to us, whether offline or online in the context of our relationship with you.
What Information We Collect
“Personal Information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household.
We may collect the following types of Personal Information about you:
- Identifiers, such as your name, your place of business, job title, postal address, email address, telephone number, mailing or shipping address, and any personal or business contact information you voluntarily provide to HALO;
- Customer records, such as your signature;
- Protected class information, such as your gender;
- Commercial information, such as payment information (including your credit or debit card information, bank account details, and other payment processing information), information relating to your purchases or items you are interested in (including the products and services you purchase or receive from us, the items in your shopping cart on our Sites, any information we receive in connection with your order, and information related to your online customer account you register on the Sites), and credit information (such as tax status, names and contact information of owners and officers, bank references, trade references, and other information in credit applications);
- Professional information, such as your employer, occupation, salary, and professional accomplishments;
- Internet or other electronic network activity information, including information we automatically receive about the devices you use to access the Sites or use our services, your IP address, the type of Internet browser used to visit the Sites, how you interact with the Sites and our services (including the areas of the Sites you visited and the actions you performed on the Sites), and information we collect using cookies and other tracking technologies as described in the “Cookies and Web Beacons” section below;
- Geolocation data, such as the city, state, and zip code associated with your IP address;
- Audio, electronic, visual, or other sensory information, such as photographs you submit to personalize products you purchase;
- Inferences, drawn from any of the information we collect, such as products and services you might be interested in;
- Sensitive Personal Information, consisting of account log-in information; and
- Other information you choose to provide, such as when you participate in a survey, contest, promotion, request customer support, submit comments or questions regarding our products and services, or otherwise communicate with HALO.
How We Collect Your Personal Information
We collect your Personal Information from the following sources:
- You, such as when you visit the Sites, register a user account with the Sites; order our products; submit an application for credit; communicate with us online or offline; sign up to receive email, newsletters, or other communications from us; or otherwise voluntarily provide Personal Information to us. When we request your Personal Information, you do not have to provide it, but if you choose not to, we may not be able to provide you with all of our products and services.
- Tracking technologies and other automated sources, such as cookies and other tracking technologies when you visit our Sites and use our services.
- Third parties, such as your employer, friends or other references, business partners, social and other third parties with whom we interact.
- Publicly available sources, such as profiles on websites.
How We Use Your Personal Information
We may use Personal Information as outlined below:
- Provide you with products and services. We may use your Personal Information to provide you with products and services, including to process and fulfill your orders; process your payment card and other transactions; send you invoices; evaluate any credit application you submit to us and, if applicable, extend credit to you; administer and maintain your customer account, including any online customer account you register on the Sites; operate contests, sweepstakes and other promotions; and send you communications related to your orders and our products and services.
- Build and maintain our customer relationships, including through marketing. We may use your Personal Information to improve your experience with our products and services, send you marketing messages about products or services that may be of interest to you, send you informational newsletters, provide you with customer service, and showcase our products to you at events. We may also draw inferences from the Personal Information you provide to us, such as information about your preferences, characteristics, and interest in our products and services.
- Improve the Sites and our product and service offerings. We may use your Personal Information to understand who is visiting the Sites, using our services, and purchasing our products, perform market research and analysis, analyze how the Sites or our services are being used and accessed, improve the functionality of the Sites and your user experience, conduct quality assurance activities, perform internal business reviews, and develop new product offerings and services.
- Comply with our legal obligations and respond to legal proceedings. We may use your Personal Information to comply with our legal obligations, including maintaining records of our compliance with federal and state law requirements. We may also use your Personal Information to establish, exercise, or defend legal claims.
- In connection with a corporate transaction, such a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy, or other change of ownership or control (whether in whole or in part).
How We Disclose Your Personal Information
We may disclose your Personal Information as outlined below:
- Our Account Executives. We may disclose your name and contact information (such as email address) to one or more of our Account Executives if you purchase a product or submit an inquiry or request. “Account Executives” refers to our local sales representatives who represent our product lines. Many of our Account Executives work for us as independent contractors and often have their own websites. Our Account Executives may communicate with you on our behalf to assist with your request, inquiry, or transaction; send you marketing messages about our products and services; or support our customer relationship with you.
- To our business partners. We may disclose your name and contact information (such as email address) to our business partners, including our product manufacturers and vendors, so that they can provide products and services to us.
- To our suppliers and other service providers. We may disclose your Personal Information in general to our suppliers, service providers, and vendors that perform tasks on our behalf, such as order and payment processing, order fulfillment and production, order shipping and delivery, invoicing or billing activities, data processing and storage, data security, marketing activities, and operating and maintaining the Sites and our services.
- To advertisers and advertising networks. We may disclose your Site usage information to our advertisers and advertising networks. These third parties may combine information they receive from us with information they receive directly from you or from other third parties. They may use the information for their own business purposes, such as improving their own services or products.
- To public and governmental authorities. We may disclose your Personal Information in general to entities that regulate or have jurisdiction over HALO, such as regulatory authorities, law enforcement, public bodies, and judicial bodies.
To other third parties, as reasonably necessary. We may disclose your Personal Information in general:
- In relation to a merger, sale, acquisition, divesture, restructuring, reorganization, dissolution, bankruptcy, or other change of ownership or control (whether in whole or in part);
- To comply with your request.
Retention of Information
As a general matter, we will retain your Personal Information for as long as it is necessary to fulfill the purposes for which we collected it, to satisfy legal and regulatory requirements, or as required or permitted by applicable law. To determine the length of time for which we will retain Personal Information, we will consider the volume and sensitivity of the Personal Information, the risk of harm to people like you, the purposes for which we collect and use the Personal Information, and applicable legal and regulatory requirements.
In certain circumstances, we may anonymize your Personal Information so that it can longer be associated with you. We may use such anonymized information for various business purposes, including analytics and research, and may retain it indefinitely without further notice to you.
Cookies and Web Beacons
Web Beacons. Web beacons are small bits of code embedded in web pages or in emails. We may use web beacons to deliver or communicate with cookies, count users who have visited the Sites, and understand usage patterns. We also may include web beacons in emails to learn if messages have been opened, acted on, or forwarded to others. Web beacons cannot be declined when delivered via a regular web page. However, web beacons can be refused when delivered via email. If you do not wish to receive web beacons via email, you will need to disable HTML images or refuse HTML emails via your email software (e.g., by choosing to receive “text only” emails).
Web Analytics and Advertising Services Provided by Others
Do Not Track
Some web browsers incorporate a Do Not Track (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, then the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option, and DNT signals are not yet uniform. For this reason, many digital service operators, including HALO with respect to most of the Sites, do not recognize or respond to DNT signals. To learn more about DNT signals, you may wish to visit http://www.allaboutdnt.com/.
Opt Out from Emails and Other Communications
If you no longer wish to receive marketing emails or other marketing communications from HALO, you may unsubscribe at any time by clicking the “unsubscribe” link in the emails you receive from us or by contacting us using the information below in the “Contact Us” section. Please note that even if you opt out of receiving marketing communications from us, we may continue to send you non-promotional communications regarding your order, your account, other transactions with us, or notices consistent with our legal rights and obligations.
Your Online User Account
If you have registered an online account on the Sites, you may make changes to your Personal Information by logging in to your account and making changes there.
Opt Out of Cookies and Other Tracking Technologies
Regular cookies generally may be disabled or removed using tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options, so you may need change their settings separately. In addition, tools from commercial browsers may not be effective with respect to HTML5 cookies or other tracking technologies.
Please be aware that if you disable or remove these technologies, some parts of our Sites may not work, and when you revisit the Sites, your ability to limit browser-based tracking technologies is subject to your browser settings and limitations.
Opt Out of Analytics and Interest-Based Advertising
Notice to California Residents
Certain California residents have the privacy rights listed below. The rights listed below under the California Consumer Privacy Act and Shine the Light are not the same. To exercise your rights, you will need to follow the directions below.
California Privacy Rights
California residents may have certain rights concerning their Personal Information, described below.
Request to Know. You have the right to request to know (1) the specific pieces of Personal Information we have collected about you; (2) the categories of Personal Information we have collected about you; (3) the types of sources from which that Personal Information was collected; (4) the categories of your Personal Information that we sold, shared, or disclosed; (5) the categories of third parties to whom your Personal Information was sold, shared or disclosed ; and (6) the purposes for collecting, selling and sharing your Personal Information. You may exercise your right to request to know twice a year, free of charge.
Please note, in response to a request to know, we are prohibited from disclosing your Social Security number, driver’s license number or other government-issued identification number, financial account number, health insurance or medical identification number, and account password or security questions and answers.
- Request to Delete. You have the right to request that we delete the Personal Information that we have collected from or about you. We may deny your request under certain circumstances, such as if we need to comply with our legal obligations or complete a transaction for which your Personal Information was collected. If we deny your request to delete, we will let you know the reason for the denial.
- Request to Opt Out of Sale or Sharing of Your Personal Information. You have the right to opt out of the sale or sharing of your Personal Information.
- Request to Correct. You have the right to request that we correct inaccurate Personal Information that we maintain about you.
- Right to Non-Discrimination. If you choose to exercise any of these rights, we will not discriminate against you in any way. If you exercise certain rights, please understand that you may be unable to use or access certain features of the Sites or our services.
To make a request to know, request to correct, or a request to delete under the California Consumer Privacy Act, please contact us using the information in the “Contact Us” section below.
To make a request to opt out of the sale or sharing of your Personal Information, please use the “Do Not Sell or Share My Personal Information” link in the Site footer. To fully opt out of any sale or sharing of Personal Information collected through cookies and other tracking technologies, you must complete this step on each device and browser from which you visit our Sites. Please note that if you block cookies, we will not be able to complete your request to opt out of sales or sharing, and if you clear cookies, you will need to resubmit your request. You may also opt out of sales or sharing of your Personal Information using an opt-out preference signal. If you have a commonly used and recognized opt-out preference signal enabled when you visit our Sites, such as an HTTP header, we will opt you out of the sale or sharing of Personal Information collected through cookies and other tracking technologies. We process opt-out preference signals on a per-device, per-browser basis, so you will need to enable opt-out preference signals on each browser and device you use to visit our Sites to fully opt-out of the sales and sharing of your Personal Information.
We will take steps to verify your identity before processing your request to know, request to correct, or request to delete. We will not fulfill your request unless you have provided sufficient information for us to reasonably verify you are the individual about whom we collected Personal Information. We may request additional information about you so that we can verify your identity, such as your customer name, email address, and/or company name. We will only use the Personal Information you provide to verify your identity and to process your request, unless you initially provided the information for another purpose.
You may use an authorized agent to submit a request to know, request to correct, or request to delete using the information provided in the “Contact Us” section below. When we verify your agent’s request, we may require your agent to provide proof of your signed permission to submit the request. In addition, we may require you to verify your identity or confirm that you provided the agent permission to submit the request. To protect your Personal Information, we reserve the right to deny a request from an agent who does not submit proof that you have authorized the agent to act on your behalf.
Additional Information on our Processing of Personal Information of California Residents
This section provides additional information on our collect, use, and disclosure of the Personal Information of California residents.
We use and disclose sensitive personal information only for (i) performing services or providing goods reasonably expected by an average consumer; (ii) detecting security incidents; (iii) resisting malicious, deceptive, or illegal actions; (iv) ensuring the physical safety of individuals; (v) short-term, transient use, including non-personalized advertising; (vi) performing or providing internal business services; (vii) verifying or maintaining the quality or safety of a service or device; or (viii) purposes that do not infer characteristics about you.
Although we have not sold your Personal Information for money in the past 12 months, depending on your use of the Sites, we may disclose Site usage and similar information about you to advertisers and advertising networks for advertising purposes, which may be considered a “sale” or “sharing” as defined by California law. We disclose this information with our advertisers and advertising networks to allow them to better tailor their advertisements on our Sites and/or on third party websites. We do not knowingly sell the Personal Information of individuals under 16 years of age.
The table below lists the third parties to whom we have disclosed, sold or shared each category of Personal Information that we collect as described in the “What Information We Collect” section.
|Category of Personal Information||Categories of Third Parties to Whom We Disclose Personal Information for a Business Purpose||Categories of Third Parties to Whom Personal Information is Sold or Shared|
|Personal information subject to the California Customer Records Act||
|Characteristics of protected classifications under California or federal law||
|Professional or employment-related information||
|Internet or other electronic network activity||
|Audio, electronic, visual, olfactory, or other sensory information||
|Sensitive Personal Information||
If you have questions or concerns about our privacy policies and practices, please contact us using the information in the “Contact Us” section.
California “Shine the Light” Law
Certain California residents may also request information from us once per calendar year about certain Personal Information disclosed to third parties for their own direct marketing purposes, including the categories of information and the names and addresses of those businesses to which we have disclosed such information. To request this information, please contact us by using the information provided in the “Contact Us” section below.
Notice to Residents of the European Economic Area, Switzerland and the United Kingdom
HALO Branded Solutions, Inc. is the data controller responsible for the processing of your personal information. You can contact us using the information in the “Contact Us” section below.
Legal Bases for Processing Your Information
We collect and process your Personal Information for the purposes described in the “How We Use Your Personal Information” section on the following legal bases:
|Processing Purpose||Legal Basis(es)|
|Provide you with products and services||
|Build and maintain our customer relationships, including through marketing||
|Improve the Sites and product and service offerings||
|Maintain the security of the Sites and our services||
|Comply with or legal obligations and respond to legal proceedings||
|In connection with a corporate transaction||
Transfers of Personal Information Outside of the European Economic Area, Switzerland, or the United Kingdom
While processing your Personal Information, we may transfer it to an entity in a country outside of the European Economic Area, Switzerland, or United Kingdom. Regulatory authorities in those regions have determined that certain countries outside of the European Economic Area meet specific data privacy standards. If we make a transfer to an entity in a country that is not one of those countries, we will do so lawfully, such as on the basis of the Standard Contractual Clauses approved by the European Commission or the United Kingdom Information Commissioner’s Office, Binding Corporate Rules, on the basis of permissible statutory derogations, or other valid data transfer mechanisms.
Your Rights and Choices
As a resident of the European Economic Area, Switzerland, or the United Kingdom, you may have certain rights with respect to the Personal Information we maintain about you. Your rights depend on the circumstances under which we collected and process your Personal Information. Conditional on those circumstances, you may have the right to:
- Access the Personal Information we maintain about you;
- Rectify your Personal Information that is incomplete or misleading;
- Receive a copy of your Personal Information in an electronic format so that it can be transferred to third parties;
- Object to the processing of your Personal Information;
- Restrict the processing of your Personal Information;
- Erase your Personal Information; and/or
- Lodge a complaint with a supervisory authority.
If you have provided your consent for us to process your Personal Information, you have the right to withdraw it at any time. The lawfulness of any processing that occurred prior to your withdrawal will not be affected.
You may exercise these rights by contacting us using the information in the “Contact Us” section.
We use commercially reasonable measures to safeguard Personal Information that you have disclosed to us, but absolute security cannot be guaranteed. It is important for you to protect against unauthorized access to your account access information and to your computer. We urge you to keep your account log-in information in a safe place and not to divulge it to anyone. We will endeavor to notify you in the event we become aware of a breach of the security of your Personal Information stored by or for us. However, we shall not be liable for any breach of the security of your Personal Information resulting from your own acts or omissions.
We use one or more secure servers for the Site. By “secure,” we mean that the Site uses the Secure Socket Layer (SSL) protocol and that our web servers are capable of delivering 128-bit encryption. For example, when you make a purchase on the Site, your Personal Information (including payment account information) is transmitted using the SSL protocol and then encrypted (using industry-standard 128-bit SSL technology) into a secure database maintained by our payment gateway provider, which will be accessible only by those who are authorized to access the information and who are required to keep the information confidential. Please note, however, that your browser, not our web servers, ultimately determines the exact level of encryption. You may not be able to shop online if your browser does not support SSL or if you are accessing the Internet from behind a firewall that prohibits SSL transactions.
We do not knowingly collect Personal Information from individuals under the age of 18. If we discover that any registration, transaction, or other submission of personal information is made by an individual under the age of 18, we will take reasonable steps to immediately and permanently delete and remove such information, with or without notice.
Changes to this Notice
HALO Branded Solutions
Attn: HALO.COM Customer Service
1500 HALO Way
Sterling, IL 61081
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