HALO DIAGNOSTICS
PRIVACY POLICY

Last Updated July 15, 2020

Welcome to the website (the “Site”) of HALO Dx, Inc., d.b.a HALO Diagnostics (the “Company,” “we,” “us,” or “our”). The Company provides image-based diagnostic and outpatient treatment services (collectively, including the Site, the “Services”).

This Privacy Policy explains what Personal Information (defined below) we collect, how we use and share that data, and your choices concerning our data practices.

Before using the Site or submitting any Personal Information to us, please review this Privacy Policy carefully and contact us at privacy@halodx.com if you have any questions. By using the Site, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access the Site or otherwise submit Personal Information to us.

1. PERSONAL INFORMATION WE COLLECT

When you contact us or interact with our Site we collect information that alone or in combination with other information could be used to identify you (“Personal Information”) as follows:

Personal Information You Provide:

Contacting Us; Requesting Content: We collect certain Personal Information about you if you voluntarily provide us with such information when you engage in certain activities, such as contacting us or filling in a form on our Site to learn more about our Services, asking to download content (such as brochures, studies or guides), registering for a webcast or other event. The Personal Information collected during these interactions may vary based on what you choose to share with us, but it will generally include your name, email address and phone number.

Social Media Pages: We may also collect Personal Information that you elect to provide to us when you interact with our pages on social media sites like Facebook, LinkedIn and Twitter (“Social Media Pages”), or send us a social media message, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.

Internet Activity Data:

When you visit, use, and interact with the Site, we may receive certain information about your visit, use, or interactions. For example, we may monitor the number of people who visit the Site, peak hours of visits, which page(s) are visited, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access the Site (e.g., Chrome, Firefox, Microsoft Internet Explorer, etc.), broad geographical information, and navigation patterns. In particular, the following information is created and automatically logged in our systems:

  • Log Data: Information that your browser automatically sends whenever you visit the Site. Log Data includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interacted with the Site.
  • Cookies Data: Please see the “Cookies and Other Technologies” section below to learn more about how we use cookies.
  • Device Data: Includes type of the device, e.g. mobile device, operating system, and browser you are using. Information collected may depend on the type of device you use and its settings.
  • Usage Data: We collect information about how you use our Site, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities. 

Cookies and Other Technologies:

We use cookies and other technologies to operate and administer our Site, gather usage data on our Site, and improve your experience on it. A “cookie” is a piece of information sent to your browser by a website you visit. Cookies can be stored on your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer when you open your browser and browse the Internet again (persistent cookies). For more details on cookies please visit All About Cookies.

On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:

Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site.

Advertising networks may use cookies to collect Personal Information. Most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit the Network Advertising Initiative’s online resources and follow the opt-out instructions there.

If you access the Site on your mobile device, you may not be able to control tracking technologies through the settings.

Analytics: We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the Site and enhance your experience when you use the Site. For more information on Google Analytics privacy practices, go to www.google.com/policies/privacy/partners/. For expiration of expiration of these cookies, read here.

Online Tracking and Do Not Track Signals: We and our third party service providers, including Facebook, may use cookies, pixels, or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Site and use that information to send targeted advertisements. Our Site currently does not respond to “Do Not Track” (“DNT”) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will update this Privacy Policy to describe how we do so.

2. HOW WE USE PERSONAL INFORMATION

We use Personal Information for the following purposes:

We use Personal Information that you provide to us (described above) to (i) respond to your inquiries, comments, feedback or questions, or process your request, and (ii) manage our relationship with you, which includes sending administrative information to you relating to our Site and changes to our terms, conditions, and policies, and asking you to leave a review or take a survey.

  • We use Personal Information that we collect automatically (described above) to (i) analyze how you interact with our Site and provide, maintain and improve the content and functionality of the Site and your user experience, develop our business and inform our marketing strategy (please also read the “Cookies and Other Technologies” section above to learn how we use cookies); and (ii) administer and protect our business and the Site, prevent fraud, criminal activity, or misuses of our Site, and to ensure the security of our IT systems, architecture and networks (including troubleshooting, testing, system maintenance, support and hosting of data);
  • We may contact you to tell you about information we believe will be of interest to you, such as information about products and services, features, surveys, newsletters and upcoming events. You may opt out of receiving promotional emails by following the instructions contained in each communication we send you or by contacting us as explained at the bottom of this Privacy Policy. If you unsubscribe from our marketing lists, you will no longer receive marketing communications but we will continue to contact you regarding administrative matters, and to respond to your requests.
  • We may use your Personal Information to comply with legal obligations and legal process and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or other third parties.

Aggregated Information. We may aggregate Personal Information and use the aggregated information to analyze the effectiveness of our Site, to improve and add features to our Site, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Site and share aggregated information like general user statistics with prospective business partners. We may collect aggregated information through the Site, through cookies, and through other means described in this Privacy Policy.

3. SHARING AND DISCLOSURE OF PERSONAL INFORMATION

In certain circumstances we may share the categories of Personal Information described above without further notice to you, unless required by the law, with the following categories of third parties:

  • Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Information with vendors and service providers, including providers of hosting services, cloud services, and other information technology services providers, event management services, email communication software and email newsletter services, advertising and marketing services, customer relationship management and customer support services, and web analytics services. Pursuant to our instructions, these parties will access, process, or store Personal Information in the course of performing their duties to us.
  • Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider (collectively, a “Transaction”), your Personal Information and other information may be shared in the due diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets.
  • Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Site, or the public, or (v) protect against legal liability.
  • Affiliates: We may share Personal Information with our current and future affiliates, meaning an entity that controls, is controlled by, or is under common control with the Company. Our affiliates may use the Personal Information we share in a manner consistent with this Privacy Policy.
4. DATA RETENTION

We keep Personal Information for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a business need to do so, or as required by law (e.g. for tax, legal, accounting, or other purposes), whichever is longer.

5. CHILDREN

Our Site is not directed to children who are under the age of 16. The Company does not knowingly collect Personal Information from children under the age of 16. If you have reason to believe that a child under the age of 16 has provided Personal Information to the Company through the Site please contact us and we will endeavor to delete that information from our databases.

6. LINKS TO OTHER WEBSITES

The Site may contain links to other websites not operated or controlled by the Company, including social media services (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.

7. SECURITY

You use the Site at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Site or e-mail. Please keep this in mind when disclosing any Personal Information to the Company via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Site, or third party websites.

8. INTERNATIONAL USERS

By using our Site, you understand and acknowledge that your Personal Information will be transferred from your location to our facilities and servers, and our service providers, in the United States.

9. YOUR CHOICES

In certain circumstances providing Personal Information is optional. However, if you choose not to provide Personal Information that is needed to use some features of our Site, you may be unable to use those features. You can also to ask us to update your Personal Information or if you need to change or correct your Personal Information.

10. ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS.

In accordance with the California Consumer Privacy Act (“CCPA”), this section is intended to inform California residents of (1) the Personal Information that we collect and how we disclose that information, and (2) the privacy rights California residents may have relating to their Personal Information and how those rights can be exercised.

Personal Information Collection and Disclosure

The following disclosures are intended to provide additional information about (1) the categories of Personal Information we collect, and (2) how and to whom we disclose that Personal Information. Nothing in this section limits our ability to use or disclose information as described elsewhere in this Privacy Policy.

  • Categories of Personal Information Collected: In the past 12 months, we have collected the following categories of Personal Information, as described in greater detail in the “Personal Information We Collect” section above:
    • Identification Information, such as your name, email address, phone number, mailing address.
    • Online Activity Information, such as the device used to access a Site, your internet service provider (ISP), date and time of your visit, browser language, browser type, operating system referring and exit pages and URLs, amount of time spent on particular pages, which parts of our Site you use, which links you click, search terms, traffic and related statistics, the location of the device, keywords, and/or other general browsing data or usage data.
  • Sources of Personal Information: We collect the above categories of Personal Information from you, our vendors and service providers, and as otherwise described in the “Personal Information We Collect” section above.
  • Purposes of Collection and Disclosure: We collect and disclose the above categories of Personal Information for the business and commercial purposes described in the “How We Use Personal Information” and “Sharing and Disclosure of Personal Information” sections above.
  • Categories of Personal Information Disclosed for a Business Purpose: In the past 12 months, we have disclosed for a business purpose all of the above categories of Personal Information to service providers and as described in the “Sharing and Disclosure of Personal Information” section above.
  • Categories of Personal Information Sold: We do not sell your Personal Information.

California Privacy Rights

To the extent provided for by the CCPA and subject to applicable exceptions and exclusions, California residents have the following privacy rights in relation to the Personal Information we collect:

  • The right to know what Personal Information we have collected and how we have used and disclosed that Personal Information.
  • The right to request deletion of your Personal Information.
  • The right to opt out of the sale of your Personal Information.
  • The right to be free from discrimination for the exercise of your privacy rights.

Exercising Your Rights: If you would like to exercise any or all of these rights, you may do so by contacting us at privacy@halodx.com or calling (833) 350-5050. Your authorized agent may submit requests in the same manner. Once we receive your request, we will verify your identity by sending an email to the email address you provide to us.

Verification: In order to protect your Personal Information from unauthorized access or deletion, we may require you to verify your credentials before you can submit a request to know or delete Personal Information. If you do not have an account with us, or if we suspect fraudulent or malicious activity, we may ask you to provide additional Personal Information for verification. If we cannot verify your identity, we will not provide or delete your Personal Information.

Please contact us if you have questions about your rights or our disclosures under the CCPA, or to request access to an alternative format of this Privacy Policy. 

Third Party Marketing: If you are a California resident and wish to opt out of sharing your Personal Information with third parties for their direct marketing purposes, please email The Company at privacy@halodx.com and clearly state your request, including your name, mailing address, email address, and phone number. Please see the “Your Choices” section of this Privacy Policy for additional information.

11. CHANGES TO THE PRIVACY POLICY

The Site and our business may change from time to time. As a result we may change this Privacy Policy at any time. When we do we will post an updated version on this page, unless another type of notice is required by the applicable law. By continuing to use our Site or providing us with Personal Information after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and practices described in it.

12. CONTACT US

If you have any questions about our Privacy Policy or information practices, please feel free to contact us at our designated request address: privacy@halodx.com.