Privacy Policy
Effective date: May 1, 2024
This Privacy Policy describes how Halomark Inc. (“Halomark”) collects, uses and discloses information, and what choices you have with respect to the information.
Scope of this Privacy Policy
This Privacy Policy applies to Halomark’s products and services, including applicable mobile and desktop applications (collectively, the “Services”), Halomark.com and other Halomark domains, subdomains and websites (collectively, the “Websites”) and other interactions (for example, customer service inquiries, user conferences, email exchanges, phone calls, etc.) you may have with Halomark. If you do not agree with the terms of this Privacy Policy, do not access or use the Services, Websites, or any other aspect of Halomark’s business.
This Privacy Policy does not apply to any third-party applications or software that integrate with the Services through the Halomark platform (“Third-Party Services”), or any other third-party products, services or businesses. In addition, a separate agreement governs delivery, access, and use of the Services (the “MSA”), including the processing of any data submitted through the Services (“Service Data”). The organization (e.g., your employer or another entity or person) that agreed to the MSA (“Customer”) controls its instance of the Services and any associated Service Data (the “Customer Instance”).
Information Halomark Collects and Receives
Halomark may collect, generate, and receive Service Data and other information and data (“Other Information”; Service Data and Other Information collectively “Information”) in a variety of ways:
Service data. Customers and individuals granted access to a Customer Instance by a Customer (“Authorized Users”) may submit Service Data to Halomark when using the Services.
Usage information.
Account information. To create or update a Halomark account, you or a Customer (e.g., your employer) supply Halomark with a name, email address, phone number, password, domain and/or similar account details. In addition, Customers that purchase a paid version of the Services provide Halomark (or its payment processors) with billing details such as credit card information, banking information and/or a billing address.
Usage information.
Services metadata. When an Authorized User interacts with the Services, metadata is generated that provides additional context about the way Authorized Users interact with the Services. For example, Halomark logs what Third Party Services are connected with the Services (if any)
Log data. As with most technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include the Internet Protocol (IP) address and other identifying information, the address of the web page visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data.
Device information. Halomark collects information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether Halomark collects some or all of this information often depends on the type of device used and its settings.
Location information. Halomark receives information from you, your Customer and other third parties that may help Halomark approximate your location. Halomark may, for example, use a business address submitted by your employer, or an IP address received from your browser or device to determine approximate location. Halomark may also collect location information from devices in accordance with the consent process provided by your device.
Cookie information. Halomark uses cookies and similar technologies in our Websites and Services to help us collect Other Information. The Websites and Services may also include cookies and similar tracking technologies of third parties, which may collect Other Information about you via the Websites and Services and across other websites and online services.
Third-Party Services. A Customer can connect Third-Party Services to its Customer Instance. Typically, Third-Party Services are software services that integrate with Halomark Services, and a Customer can permit its Authorized Users to enable and disable these integrations for its Customer Instance. Halomark may also develop and offer Halomark applications that connect the Services with a Third-Party Service. Once enabled, the provider of a Third-Party Service may share certain information with Halomark. For example, if a single sign-on service is connected with Halomark, Halomark may receive the username and email address of Authorized Users, along with additional information that the application has elected to make available to Halomark to facilitate the integration. Authorized Users should check the privacy settings and notices in these Third-Party Services to understand what data may be disclosed to Halomark. When a Third-Party Service is enabled, Halomark is authorized to connect and access Other Information made available to Halomark in accordance with any permission(s) granted by Customer (including, by its Authorized User(s)). Halomark does not, however, receive or store passwords for any of these Third-Party Services when connecting them to the Services.
Contact information. An Authorized User is required to provide some contact information (e.g., an email address) when establishing an account on the Services.
Third-party data. Halomark may receive data about organizations, industries, lists of companies that are customers, Website visitors, marketing campaigns and other matters related to our business from affiliates and subsidiaries, our partners, or others that Halomark engages with to make Halomark’s own information better or more useful. This data may be combined with Other Information Halomark collects and might include aggregate-level data, such as which IP addresses correspond to zip codes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.
Additional information provided to Halomark. Halomark receives Other Information when submitted to our Services, Websites or in other ways, such as if you participate in a focus group, contest, activity or event, apply for a job, enroll in an educational program hosted by Halomark or a vendor, request support, interact with our social media accounts or otherwise communicate with Halomark.
How Halomark Uses Information
Service Data will be used by Halomark in accordance with the applicable MSA, Customer’s use of Services functionality, and as required by applicable law. Halomark is a processor of Service Data and Customer is the controller.
In addition, Halomark uses Information in furtherance of our legitimate interests in operating our Services, Websites, and business. More specifically, Halomark uses Information:
To provide, update, maintain and protect our Services, Websites, and business. This includes use of Service Data and Other Information to support delivery of the Services under an MSA, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities, or at an Authorized User’s request.
As required by applicable law, legal process, or regulation.
To communicate with you by responding to your requests, comments, and questions. If you contact us, Halomark may use Information to respond.
To develop and provide additional features. Halomark tries to make the Services as useful as possible for Customers and Authorized Users, and Halomark may use aggregated and anonymized Services Data and Other Information to develop new Services or improve existing Services.
To send emails and other communications. Halomark may send you service, technical and other administrative emails, messages, and other types of communications. Halomark may also contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them. In addition, Halomark sometimes sends emails about new product features, promotional communications, or other news about Halomark. These are marketing messages so you can control whether you receive them. If you have additional questions about a message you have received from Halomark please reach out through the contact mechanisms described below.
For billing, account management, and other administrative matters. Halomark may need to contact you for invoicing, account management, and similar reasons and Halomark uses account data to administer accounts and keep track of billing and payments.
To investigate and help prevent security issues and abuse.
If Information is aggregated or de-identified so that it is no longer reasonably associated with an identified or identifiable natural person, Halomark may use it for any business purpose. To the extent Information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Privacy Policy as “Personal Data.”
Data Retention
Halomark will retain Service Data in accordance with the applicable MSA, Customer’s use of Services functionality, and as required by applicable law.
Halomark may retain Other Information for as long as necessary for the purposes described in this Privacy Policy. This may include keeping Other Information for the period of time needed for Halomark to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes, and enforce our agreements.
We may retain customer data and credentials up to 365 days following account termination unless deletion is requested earlier.
We may retain applicant data for up to three (3) years unless deletion is requested earlier.
We may retain website visitor and log information for up to three (3) years.
If Information is aggregated or de-identified so that it is no longer reasonably associated with an identified or identifiable natural person, Halomark may use it for any business purpose. To the extent Information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Privacy Policy as “Personal Data.”
How Halomark Shares and Discloses Information
This section describes how Halomark may share and disclose Information.
Displaying and operating the Services. Because of the nature and functionality of the Services, Information will be displayed as part of the Services to Authorized Users in a Customer Instance. For example, information about which of Customer’s employees may have two-factor authentication enabled may be displayed as part of the Services.
Third-party service providers and partners. Halomark may engage third parties as service providers or business partners to process Information and support our business. These third parties may, for example, provide virtual computing and storage services. To the extent necessary and applicable, these third-party service providers and partners will be bound by appropriate and commercially reasonable confidentiality obligations. Additional information about the subprocessors Halomark uses to support delivery of our Services is set forth in our list of Halomark Subprocessors.
Third-Party Services. Customer may enable or permit Authorized Users to enable Third- Party Services. Halomark requires each Third-Party Service to disclose all permissions for information access in the Services, but Halomark does not guarantee that they do so. When enabled and as requested by Customer, Halomark may share Information with Third-Party Services. Third-Party Services are not owned or controlled by Halomark and third parties that have been granted access to Information may have their own policies and practices for its collection, use, and sharing. Please check the permissions, privacy settings, and notices for these Third-Party Services or contact the service provider for any questions
Corporate affiliates. Halomark may share Information with its corporate affiliates, parents, and/or subsidiaries.
During a change to Halomark’s business. If Halomark engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of Halomark’s assets or stock, financing, public offering of securities, acquisition of all or a portion of Halomark’s business, a similar transaction or proceeding, or steps in contemplation of such activities, some or all Information may be shared or transferred, subject to appropriate and commercially reasonable confidentiality arrangements.
Aggregated or de-identified data. Halomark may disclose or use aggregated or de-identified Information for any purpose. For example, Halomark may share aggregated or de-identified Information with prospects or partners for business or research purposes.
To Comply with Laws. If a law enforcement or government agency sends Halomark a demand for Information about a Customer, Halomark shall attempt to redirect the agency to request that data directly from the Customer. As part of this effort, Halomark may provide the Customer’s basic contact information to the law enforcement or government agency. If compelled to disclose Information to a law enforcement or government agency, then Halomark will give the Customer reasonable notice of the demand and cooperation to allow the Customer to seek a protective order or other appropriate remedy unless Halomark is legally prohibited from doing so. Halomark will not voluntarily disclose Information related to a Customer to any law enforcement or government agency, unless required by public authorities, including to meet national security or law enforcement requirements.
To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property, or safety of Halomark or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
With consent. Halomark may share Information with third parties when Halomark has consent to do so.
How Halomark Shares and Discloses Information
Security is critical to Halomark’s mission, and Halomark takes security of data seriously. Halomark uses industry-standard technical and organizational measures to protect Information from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the Information Halomark collects, processes, and stores, and the current state of technology. Given the nature of communications and information processing technology, Halomark cannot guarantee that Information in our care will be absolutely safe from intrusion by others during transmission through the Internet or while stored on our systems or otherwise. When you click a link to a third-party site, you will be leaving our site and Halomark doesn’t control or endorse what is on third-party sites.
Age Limitations
To the extent prohibited by applicable law, Halomark does not allow use of our Services and Websites by anyone younger than 16 years old. If Halomark learns that anyone younger than 16 years old has unlawfully provided Personal Data, Halomark will take steps to delete such information.
Changes to This Privacy Policy
Halomark may change this Privacy Policy from time to time. Laws, regulations, and industry standards evolve, which may make those changes necessary, or Halomark may make changes to our services or business. Halomark will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If Halomark makes changes that materially alter your privacy rights, Halomark will aim to provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy or any updates thereto, you should cease interacting with the Services. Contact the applicable Customer if you wish to request the removal of Personal Data under their control.
International Data Transfers
Halomark may transfer your Personal Data to countries other than the one in which you live - generally, from locations outside the United States to the United States. Halomark offers European Union Model Clauses (“Model Clauses”) also known as Standard Contractual Clauses, to meet the adequacy and security requirements for our Customers that operate in the EEA, Switzerland, and the UK and for other international transfers of Customer Data as relevant. A copy of our standard data processing addendum, incorporating Model Clauses, is available to applicable Customers upon request.
Identifying the Data Controller and Processor
Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, Customer is the controller of Service Data. In general, Halomark is the processor of Service Data and the controller of Other Information.
Your Rights
Individuals located in certain US States such as California, Virginia, and countries, including those in the European Economic Area and the United Kingdom, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information (in a portable form or otherwise), as well as to seek to update, delete or correct this Information. Where possible and as outlined in this Privacy Policy, you can request to limit your use and disclosure of this Information. You can exercise your privacy rights by sending a request to via email at: privacy@halomark.com or in writing to:
Halomark Inc.
Attn: Data Privacy Officer
2261 Market Street
Suite 10626
San Francisco, CA 94114
To the extent that Halomark’s processing of your Personal Data is subject to the General Data Protection Regulation or applicable laws covering the processing of Personal Data such as the UK Data Protection Act and the Brazilian General Data Protection Act (Lei Geral de Proteção de Dados), Halomark relies on its legitimate interests, described above, to process your data. Halomark may also process Other Information that constitutes your Personal Data for direct marketing purposes, and you have a right to object to Halomark’s use of your Personal Data for this purpose at any time.
Your California Privacy Rights
This section provides additional details about the personal information Halomark collects about California consumers and the rights afforded to them under the California Consumer Privacy Act, as amended by the California Privacy Rights Act or “CCPA.”
For more details about the personal information Halomark has collected over the last 12 months, including the categories of sources, please see the Information Halomark Collects and Receives section above. Halomark collects this information for the business and commercial purposes described in the How Halomark Uses Information section above. Halomark shares this information with the categories of third parties described in the How Halomark Shares and Disclose Information section above.
Subject to certain limitations, the CCPA also provides California consumers the right to request to know more details about the categories or specific pieces of personal information Halomark collects (including how Halomark uses and disclose this information), to delete their personal information, to correct errors in their personal information, and to not be discriminated against for exercising these rights. Please also note that Halomark does not collect sensitive personal information as defined under the CCPA.
We have incorporated Cookies from certain third parties into our Website. These Cookies allow those third parties to receive information about your activity on our Services that is associated with your browser or device. Those third parties may use that data to serve you relevant ads on our Website or on other websites you visit. Under the CCPA, sharing your data through third party Cookies for online advertising may be considered a “sale” or “share” of information, to which you have the right to opt out. You can opt out of these activities by following the instructions in this section.
We may “sell” or share your Personal Data to the following categories of third parties:
Ad Networks
Analytics providers
Marketing providers
Over the past 12 months, we may have “sold” the following categories of your Personal Data to categories of third parties listed above:
Usage Information
Cookie Information
We have “sold” or shared the foregoing categories of Personal Data for the following business or commercial purposes:
Improving the Services, including testing, research, internal analytics and product development.
Showing you advertisements, including interest-based or online behavioral advertising.
You have the right to opt-out of the “sale” or sharing of your Personal Data. You can opt-out by using the following methods:
Accessing your Cookie consent settings
Implementing the Global Privacy Control or similar control that is legally recognized by a government agency or industry standard and that complies with the CCPA. The signal issued by the control must be initiated by your browser and applies to the specific device and browser you use at the time you cast the signal. Please note this does not include Do Not Track signals.
Once you have submitted an opt-out request, we will not ask you to reauthorize the sale of your Personal Data for at least 12 months.
To our knowledge, we do not sell the Personal Data of minors under 16 years of age.
California consumers may make all other requests to access, correct, or delete pursuant to their rights under the CCPA by contacting us at privacy@halomark.com, or by mailing us at:
Halomark Inc.
Attn: Data Privacy Officer
2261 Market Street
Suite 10626
San Francisco, CA 94114
Halomark will verify your request using the information associated with your account, including your email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.
Your Virginia Privacy Rights
Subject to certain limitations, the Virginia Consumer Data Protection Act (“VCDPA”) provides Virginia consumers the right to request to access personal information we collect about you, to correct inaccuracies in your personal data, to request a portable copy of your personal information, and to delete your personal information. You also have the right opt-out from the processing of your Personal Data for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects to you, which Halomark does not do. You also have the right to opt out of targeted advertising and selling (as such terms are defined under the VCDPA), however, Halomark does not participate in selling of your personal information. You can opt-out of targeted advertising by using the following methods:
Accessing your Cookie consent settings
Implementing the Global Privacy Control or similar control that is legally recognized by a government agency or industry standard and that complies with the VCDPA. The signal issued by the control must be initiated by your browser and applies to the specific device and browser you use at the time you cast the signal. Please note this does not include Do Not Track signals.
If we refuse to take action on a request within a reasonable period of time after receiving your request in accordance with this section, you may file an appeal with us. In such appeal, you must (1) provide sufficient information to allow us to verify that you are the person about whom the original request pertains and to identify the original request, and (2) provide a description of the basis of your appeal. Please note that your appeal will be subject to your rights and obligations afforded to you under the VCDPA. We will typically respond to your appeal within 60 days of receiving your request. If we deny your appeal, you have the right to contact the Virginia Attorney General using the methods described at https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint.
Halomark will honor the exercise rights or appeals of decisions of Virginia residents requested via email at privacy@halomark.com or in writing to:
Halomark Inc.
Attn: Data Privacy Officer
2261 Market Street
Suite 10626
San Francisco, CA 94114
Data Protection Authority
Subject to applicable law, you also have the right to (i) restrict Halomark’s use of Information that constitutes your Personal Data and (ii) lodge a complaint with your local data protection authority or the Irish Data Protection Commissioner, which is Halomark’s lead supervisory authority in the European Union. If you are a resident of the European Economic Area or the United Kingdom and believe we maintain your Personal Data within the scope of the General Data Protection Regulation (GDPR) or applicable laws relating to personal data in the United Kingdom, you may direct questions or complaints to privacy@halomark.com or in writing to:
Halomark Inc.
Attn: Data Privacy Officer
2261 Market Street
Suite 10626
San Francisco, CA 94114
Contacting Halomark
Please also feel free to contact Halomark if you have any questions about this Privacy Policy or Halomark’s practices, or if you are seeking to exercise any of your statutory rights. Halomark will respond within a timeframe that is compliant with all applicable regulations.
You may contact us at privacy@halomark.com or in writing at our mailing address below:
Halomark Inc.
Attn: Data Privacy Officer
2261 Market Street
Suite 10626
San Francisco, CA 94114