Privacy Policy

1. Scope, Applicability, and Acceptance

1.1 This Privacy Policy (as amended from time to time in accordance with Section 15, this "Policy") is issued by HaloTherapyPRO Limited Liability Company, a limited liability company organized and existing under the laws of the State of Arizona (together with its successors, assigns, and affiliates, "HaloTherapyPRO," the "Company," "we," "us," or "our"), and sets forth the terms upon which the Company collects, uses, discloses, retains, and safeguards Personal Information (as defined in Section 2) in connection with the website located at halotherapypro.com, together with all subdomains, associated pages, features, content, and checkout functionality thereof (collectively, the "Site"), and any purchase of products or services effected through the Site (together with the Site, the "Services").

1.2 By accessing, browsing, or otherwise using the Services, you ("you," "your," or "User") acknowledge that you have read, understood, and agree to be bound by the terms of this Policy. If you do not agree with any provision of this Policy, you must discontinue all access to and use of the Services.

1.3 This Policy is incorporated by reference into, and forms an integral part of, the Terms & Conditions published on the Site at halotherapypro.com/terms (the "Terms"). Capitalized terms used but not defined herein shall have the meanings ascribed to them in the Terms. In the event of any conflict between this Policy and the Terms with respect to the processing of Personal Information, this Policy shall govern.

2. Definitions and Interpretation

2.1 For purposes of this Policy, the following terms shall have the meanings set forth below:

• "Personal Information" means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular natural person or household.
• "Processing" (and its correlatives, "Process" and "Processed") means any operation or set of operations performed upon Personal Information, whether or not by automated means, including collection, recording, organization, storage, adaptation, retrieval, use, disclosure, combination, restriction, erasure, or destruction.
• "Service Provider" means any natural or legal person that Processes Personal Information on behalf of the Company pursuant to a written agreement.
• "Tracking Technologies" means cookies, pixels, tags, web beacons, browser local storage, scripts, software development kits, and any similar or successor technologies.
• "Third-Party Partner" means each provider of analytics or advertising services identified in Section 6.1.

2.2 In this Policy, unless the context otherwise requires: (a) headings are for convenience only and shall not affect interpretation; (b) the words "include," "includes," and "including" shall be deemed to be followed by the words "without limitation"; (c) the singular includes the plural and vice versa; and (d) references to Sections are to sections of this Policy.

3. Categories of Personal Information Collected

3.1 Information Furnished by You. In connection with the placement of an order, the Company collects your name, email address, shipping and billing addresses, telephone number, and the particulars of the transaction. Where you submit an inquiry by means of the Site's contact form or by electronic mail, the Company collects your name, email address, and the contents of such communication. Where you request order status information, the Company Processes the order number and email address furnished by you for such purpose.

3.2 Payment Information. All payment transactions are processed by Stripe, Inc. ("Stripe"), an independent payment processor. Complete payment card numbers are submitted by you directly to Stripe and are neither received nor stored by the Company. The Company receives only limited payment-related data, which may include the last four digits of the payment card, the payment status, and associated invoice records. Stripe's Processing of payment information is governed by Stripe's own privacy policy.

3.3 Information Collected Automatically. When you access the Site, the Company and its Third-Party Partners automatically collect, by means of Tracking Technologies, certain technical and usage information, including Internet Protocol (IP) address, browser type and version, device characteristics, pages viewed, referring uniform resource locators (URLs), and interactions with the Site.

3.4 Attribution Information. The Company records the source through which you arrived at the Site, including the advertisement, campaign, search engine, or referring website, together with the date of such visit and the landing page, by means of browser local storage retained for a period not exceeding ninety (90) days, and associates such information with any resulting order for purposes of advertising measurement and attribution as set forth in Section 4(e).

4. Purposes of Processing

The Company Processes Personal Information for the following purposes, each of which the Company considers to be reasonably necessary for the operation of its business: (a) the processing, fulfillment, and shipment of orders; (b) the transmission of order confirmations, shipping notifications, and other transactional communications; (c) responding to inquiries and providing customer support and warranty service; (d) the operation, maintenance, analysis, and improvement of the Site; (e) the measurement, analysis, attribution, and optimization of advertising performance; (f) the detection, investigation, and prevention of fraud, abuse, and security incidents; (g) the transmission of marketing and promotional communications in accordance with Section 5; and (h) compliance with applicable legal, regulatory, tax, and accounting obligations, and the establishment, exercise, or defense of legal claims.

5. Electronic Communications

5.1 Transactional Communications. The Company sends transactional communications relating to orders, shipments, warranty matters, account access, and customer support inquiries, which are integral to the Services and are not subject to the opt-out described in Section 5.5.

5.2 Marketing Communications. The Company may send marketing and promotional communications by email, including product announcements, educational content, special offers, and discount codes, to any email address provided to the Company, whether in connection with a purchase, account registration, checkout (whether or not completed), warranty claim, contact form submission, or other inquiry. Marketing communications are transmitted on the Company's behalf by its email delivery service provider, Resend, which Processes email addresses and associated names solely for that purpose.

5.3 Checkout Reminders. Where you have provided your email address during checkout but have not completed your purchase, the Company may send one or more reminders regarding the items remaining in your shopping cart.

5.4 Engagement Measurement. Marketing communications may contain embedded pixels and tracked links that enable the Company to determine whether a message was delivered, opened, or clicked, and links to the Site may contain campaign parameters that permit the Company to attribute resulting purchases to a particular communication. Such information is used for the purposes set forth in Section 4(e) and to maintain accurate delivery and suppression records.

5.5 Opt-Out. Every marketing communication contains an unsubscribe link. You may opt out of marketing communications and checkout reminders at any time by following that link or by contacting the Company in accordance with Section 17, and the Company will honor such requests within ten (10) business days. Addresses that opt out, permanently reject delivery, or report a communication as unwanted are excluded from further marketing communications. Opting out does not affect transactional communications.

6. Tracking Technologies and Third-Party Partners

6.1 The Company utilizes the services of the following Third-Party Partners, each of which may collect information by means of Tracking Technologies and Process such information in accordance with its own privacy policy, for which the Company bears no responsibility:

• Google Analytics (Google LLC), for the analysis of Site traffic and usage. Further information: How Google uses data from partner sites (https://policies.google.com/technologies/partner-sites)
• Microsoft Clarity (Microsoft Corporation), for the analysis of User interaction with Site pages, including clicks and scrolling behavior. Further information: Microsoft Privacy Statement (https://privacy.microsoft.com/privacystatement)
• Meta Pixel (Meta Platforms, Inc.), for the measurement of advertising effectiveness on Facebook and Instagram and the delivery of relevant advertising. Further information: Meta Privacy Policy (https://www.facebook.com/privacy/policy)
• Google Ads (Google LLC), for the delivery and measurement of advertising. Further information: Google Privacy Policy (https://policies.google.com/privacy)
• ChatGPT Ads (OpenAI, L.L.C.), for the measurement of advertising effectiveness within ChatGPT. Further information: OpenAI Privacy Policy (https://openai.com/policies/privacy-policy)

6.2 User Controls. You may restrict or disable Tracking Technologies by means of your browser settings. You may opt out of Google Analytics at Google Analytics opt-out (https://tools.google.com/dlpage/gaoptout), manage Google advertising personalization at Google Ad Settings (https://adssettings.google.com), and manage Meta advertising preferences by means of your Facebook or Instagram account settings. The disabling of Tracking Technologies may impair the functionality of certain features of the Site.

6.3 Do Not Track Signals. Certain browsers transmit "Do Not Track" signals. In the absence of a uniform industry standard governing the recognition of such signals, the Site does not currently respond to them.

7. Disclosure of Personal Information

7.1 No Sale. The Company does not sell Personal Information in exchange for monetary consideration.

7.2 Service Providers. The Company discloses Personal Information to Service Providers solely to the extent reasonably necessary for the performance of services on the Company's behalf, including payment processing (Stripe), website hosting, electronic mail delivery, shipping and logistics carriers, and the Third-Party Partners identified in Section 6.1.

7.3 Legal Process and Protection of Rights. The Company may disclose Personal Information where it believes in good faith that such disclosure is required by applicable law, regulation, subpoena, court order, or other legal process, or is necessary to establish, exercise, or defend legal claims, to enforce the Terms, or to protect the rights, property, or safety of the Company, its customers, or others.

7.4 Corporate Transactions. In the event of any actual or proposed merger, acquisition, financing, reorganization, bankruptcy, receivership, or sale or transfer of all or any portion of the Company's business or assets, Personal Information may be disclosed or transferred to the counterparty or successor entity, which shall be bound by the terms of this Policy with respect to such Personal Information.

8. Data Retention

The Company retains Personal Information only for such period as is reasonably necessary to fulfill the purposes set forth in Section 4. Without limiting the foregoing: (a) order and transaction records are retained for such period as is necessary to fulfill orders, provide customer and warranty support, and satisfy applicable tax, accounting, and legal requirements; (b) correspondence submitted by means of the contact form is retained for such period as is reasonably necessary to respond thereto and to maintain a record thereof; and (c) information collected by Third-Party Partners is retained in accordance with the respective Third-Party Partner's retention settings and policies.

9. Your Rights and Requests

9.1 Subject to applicable law, you may request access to, correction of, or deletion of Personal Information maintained by the Company by submitting a written request to support@halotherapypro.com.

9.2 The Company may require verification of your identity, and of the authority of any agent acting on your behalf, prior to fulfilling any such request, and may decline any request that is manifestly unfounded, excessive, or inconsistent with the Company's legal obligations.

9.3 Residents of certain jurisdictions may be entitled to additional rights under the laws thereof, and the Company will honor such requests to the extent required by applicable law. The Company will not discriminate against any individual for the exercise of any right afforded under applicable law.

10. Data Security

The Company maintains commercially reasonable administrative, technical, and physical safeguards designed to protect Personal Information against unauthorized access, use, alteration, and disclosure, including encrypted (HTTPS) transmission and the use of a payment processor compliant with the Payment Card Industry Data Security Standard (PCI DSS). Notwithstanding the foregoing, no method of transmission over the Internet or method of electronic storage is entirely secure, and the Company does not warrant or guarantee the absolute security of any Personal Information.

11. International Users

The Company is located in, and the Site is operated from, the United States of America. If you access the Services from outside the United States, you acknowledge that your Personal Information will be transferred to, stored in, and Processed in the United States and in any other jurisdiction in which the Company's Service Providers maintain facilities, the data protection laws of which may differ from those of your jurisdiction of residence.

12. Children's Privacy

The Services are not directed to individuals under the age of thirteen (13), and the Company does not knowingly collect Personal Information from such individuals. Should the Company become aware that it has collected Personal Information from an individual under the age of thirteen (13), it will take commercially reasonable steps to delete such information.

13. Third-Party Websites

The Site may contain links to websites, products, or services operated by third parties. The Company does not control and is not responsible for the privacy practices or content of any such third party, and the inclusion of any link does not imply endorsement thereof. You are encouraged to review the privacy policy of each third-party website that you visit.

14. Limitation of Liability

To the maximum extent permitted by applicable law, in no event shall the Company, or its members, managers, officers, employees, or agents, be liable for any indirect, incidental, special, consequential, exemplary, or punitive damages arising out of or relating to this Policy or the Processing of Personal Information hereunder, including any unauthorized access to Personal Information resulting from causes beyond the Company's reasonable control. Nothing in this Policy shall exclude or limit any liability that cannot be excluded or limited under applicable law.

15. Amendments

The Company reserves the right, in its sole discretion, to amend, modify, or supplement this Policy at any time. Any such amendment shall become effective upon its posting to the Site, as evidenced by the revised "Last updated" date set forth above. Your continued access to or use of the Services following the posting of any amendment shall constitute your acceptance of the Policy as so amended.

16. Governing Law; Severability; General

16.1 Governing Law and Venue. This Policy, and any dispute or claim arising out of or relating hereto, shall be governed by and construed in accordance with the laws of the State of Arizona, without regard to its conflict-of-laws principles. Subject to any contrary provision of the Terms, any action arising out of or relating to this Policy shall be brought exclusively in the state or federal courts located in the State of Arizona, and you hereby consent to the personal jurisdiction of such courts.

16.2 Severability. If any provision of this Policy is held by a court of competent jurisdiction to be invalid, illegal, or unenforceable, such provision shall be enforced to the maximum extent permissible, and the remaining provisions shall continue in full force and effect.

16.3 No Third-Party Beneficiaries. Except as expressly provided herein, this Policy is not intended to, and shall not, confer any rights or remedies upon any person other than you and the Company.

16.4 No Waiver. No failure or delay by the Company in exercising any right under this Policy shall operate as a waiver thereof.

17. Contact Information

Inquiries, requests, and notices regarding this Policy or the Company's privacy practices shall be directed to: HaloTherapyPRO Limited Liability Company, Attention: Privacy, support@halotherapypro.com