privacy policy
Last updated: Feb 2026
Introduction Welcome to halo Platform (hereinafter referred to as "halo" or "Platform").
We attach great importance to privacy and protect the personal information and privacy of all our users in accordance with the applicable privacy laws worldwide. To provide you with more accurate and personalized services as well as a more secure Internet environment, we have defined our principles for the collection, use, provision, storage and protection of your personal information in accordance with applicable data protection laws, regulations and technical specifications, and further elaborated your rights related to your personal information. This policy is closely related to your use of our Platform or Services. When you download, install, start, browse, register, log in or use our Platform or Services (hereinafter collectively referred to as "using our platform or services"), we will process and protect your personal information in accordance with this policy. We try our best to explain to you the technical terms covered by this policy in a clear and concise manner so that you can understand them. We have used bold font to distinguish the terms in this policy that are (possibly) Please carefully read and fully understand this policy before using, or continuing to use our Products and Services, and make appropriate choices in accordance with the guidelines set out in this policy when necessary. If you do not agree with the content of this policy, it may cause our products or services to fail to function properly, or fail to achieve the intended effect of our services. You should immediately stop accessing/using our products and services. YOU KNOW AND CONFIRM THAT IF YOU CHECK "AGREE" TO THIS PRIVACY POLICY AND USE halo, YOU AGREE THAT WE WILL PROCESS YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY.
Please be aware that this policy only applies to the information collected by us to provide services to you through the Platform, and does not apply to any products, services, websites, or content that are offered by third parties or have their own privacy policy.
About Us
This policy sets out the basis for our processing of any personal information collected from you or provided to us by you. If you have any other questions about how we use your personal information, please contact us at service@halo-voice.com.
To improve the readability and user-friendly interaction of the privacy policy, we present it through the table of contents.
1. How do we collect your personal information
2. How do we use your personal information
3. How do we share, transfer and publicly disclose your personal information
4. How do we store and protect your personal information
5. How do you manage your personal information
U. Jul ID
9. Age restrictions and parental/guardian controls
10. How do we update this privacy policy
11. How to contact us
12. Miscellaneous
1. How do we collect your personal information We will follow the principles of what is rightful, legal and necessary to collect and use the personal information that you voluntarily provide to us, obtained by us from third party and automatically collected during you use of our Platform and Services. If we want to process your personal information for other purposes not specified in this policy, or use the information we have collected for other purposes based on a particular purpose, we will notify you in a reasonable manner and seek your consent (when required by applicable data protection laws) again before using it. Information you voluntarily provide to us
• Account information. When you register the account, we will collect your mobile phone number, mobile phone operator information, or your third-party account (such as Facebook, Apple, Twitter), depending on the method you choose for registration.
• Profile information. We will collect your profile information, including your profile photo, username, gender, date of birth, country, tags and bio.
• Activity and survey related information. When you choose to participate in activities and/or surveys organized by us or our affiliates or third parties on the platform, you may be required to provide your name, gender, mailing address, contact information and bank account information. If you refuse to provide them, it may affect your participation in related activities and/or surveys, but it will not affect your use of other functions.
• Room Information. When you create a chatroom, we may collect the name, announcements, public/private status and icon of the chatroom.
• Message Information. When you send message via halo, we will collect information you provide, including the content of the message, such as when it was sent, received and the recipient(s) of the message.
When you make a comment under a post, we will also collect the content of the comment and when it was made.
• Follow information. We will collect the users and topics you follow.
• Feedback information and proof of your identity. When you use halo feedback or customer service, we will collect your communication with us (including photos if you choose to send to illustrate errors). In certain circumstances, we may require you to provide relevant personal information to prove your identity.
Information obtained from third party Third party account information. When you register or log in with third party account, we will collect username and profile photo from the third parties (including Facebook, Apple, X ). Information automatically collected during your use of our Platform and Services
We also automatically collect and store your data below:
During you use of our Platform and Services, we will automatically collect data from you, i.e. your device id, userid, operating system version, device model, device type, carrier name, network type, client version number, language setting, IP address, SIMS country, registration time, login time and records about your use of the services, such as the date and timestamp of the operation.
We may collect information regarding your use of the Platform, including but not limited to how you engage with the Platform, how you interact with content or post, videos you watched, how you interact with chatrooms (including rooms you joined in, durations of your stays in rooms), how your interact with Virtua Items.
When you use our halo voice chat service with others, we do not retain such voice chat data on our servers and it only passes through our servers so that it can be distributed to your intended recipients.
When you have voice chat or send text messages in the chatroom, we do not retain such voice chat data and text chat data on our servers, and it only passes through our servers so that it can be distributed to other halo users in the chatroom. When you send images in the chatroom, we may collect the images you send and store the images for 3 days.
When you make any transaction through Google Play or iOS App Store and other third parties (if available), we will collect information to facilitate your transaction and maintain transaction records (including Open ID and user information fees, currency, purchased products, purchase history, IP address, transaction details as well as device details, such as operating system version, mobile phone model or device type, and Internet connection);
When you post, share, upload or otherwise make publicly available any information, such as your publicly-visible account profile, posts and comments ("Your Content"), we'll collect such information to allow Your Content to be shared with other users and develop new and improve existing services and app experience.
When you use halo feedback or customer service function to deal with the problem such as program errors, we will collect some information, including OpenlD, device ID, battery power, WiFi intensity, available space in device, network type, operating system version, browser type, platform, operator, country/area code, coupon details, email address.
We may access content, including text, images, and video, found in your device's clipboard, with your permission. For example, if you choose to initiate content sharing with a third-party platform, or choose to paste content from the clipboard into the Platform, we access this information stored in your clipboard in order to fulfill your request.
To ensure the safe operation of the software and services, we will collect your device model, device name, device ID (including IMEI, IMSI, and Android ID), browser type and Settings, language Settings, operating system version, app version, network device hardware address, login IP address, network access method, network quality data, mobile network information (including operator name), and product version number. To protect your account from malicious use by other users, please understand that we will dynamically detect whether there is abnormal login in your account. Every time you switch or restart the app, we may read the information of your device ID again, and we will control the read frequency within a reasonable range.
When you use our Platform and Services, our security and anticheating security functions will (i) analyze user device status to identify uaLa al lu yuul IL. may turn off located-based services via setting on your mobile device if you choose not to share your location. If you refuse to provide such information, you will not be able to use the location-based services, but it will not affect your use of other functionalities of halo.
When you feedback any problem or inquire something about our Platform and Services, for the security of your account and system, we may require you to provide relevant personal information to match the personal information you previously provided, so as to verify your user identity. After successful verification, we may collect the information when you communicate with us (account information, order information, and picture/video/text information and relevant information provided by you to prove relevant facts), your contact information, and records when you communicate with us, including the online communicate records and mobile phone recording, so as to solve the problem for you as soon as possible and improve our products and/or services. At the same time, we may contact you by phone, text message, system message and other relevant means to solve your problems arising in the process of using our Platform and Services.
To ensure that you can maintain instant messaging with the background server when using the services of halo and that you can receive personalized content push in a timely manner, we will i) obtain and invoke your boot broadcast permission to start the mobile client software of halo or its affiliates; ii) use a third-party push messaging service to generate an ID for you to identify the uniqueness of your device.
For the purpose of training and improving our technology, such as our machine learning models and algorithms, we may use the information we collect in our internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes and to solicit your feedback. To protect your data to the maximum extent, we use less information that might be connected to you, in some cases we de-identify or aggregate information. We might also anonymize it so that it no longer identifies you.
Summary of device permission invocation. During the process of providing services to you at halo, we may invoke some of your device permissions.
2. How do we use your personal formation We use your personal information to operate, provide, develop, and improve the Platform and Services, based on your consent, for performance of the contract between you and us or third parties, for complying with our legal obligations, or for pursuing our or third-party legitimate interest (if applicable), for the following purposes:
• To provide our Platform and Service, including enabling you to communicate with other users on our Platform.
• To enforce our Terms of Use, Community Guidelines and other policies that apply to you.
• To enable you to participate in the Virtual Items interactions.
• To understand how you use the Platform, including across your devices.
• To infer additional information about you, such as your age range, gender, and interests.
• To ensure the safe operation of our Platform and Services, and protect our Platform and Services from attack.
• To communicate with you, provide customer support and give our feedback on you.
• To conduct survey, analytics, research on our Platform and Services.
• To improve and develop the Platform and Services.
• To prevent and respond to abuse, fraud, illegal activities and other potentially harmful content.
• To ensure content is presented in the most effective manner for you and your device.
• To identify security risks and cheating.
• To train and improve our technology, such as our machine learning models and algorithms.
• To comply with our legal obligations, or as necessary to perform tasks in the public interest, or to protect the vital interests of our users and other people.
In accordance with relevant laws and regulations, we may collect and use some necessary personal information without your authorized consent under the following circumstances:
• Information directly related to public security, public health and major public interests;
• Information directly related to criminal investigation, prosecution, trial and execution of judgment and related matters;
• Information that are hard to get your consent for the purpose of protecting your or other life, property and relevant major legal rights and interests;
• Your personal information that are disclosed by you to the public;
• Your personal information collected from legally and publicly disclosed information: from lawful news reports, government information disclosure and related channels;
• Information necessary under the online agreement or contract you have signed with the Platform;
• Information necessary to maintain the safe and stable operation of our products and/or services: such information are used to detect and dispose of faults in the products or services and to deal with related problems;
• Other circumstances as provided for by laws and regulations.
3. How do we share, transfer and publicly disclose your personal information Sharing with service providers We entrust other companies, agents or contractors ("Service Providers") to perform services on our behalf or to assist us with the provision of services to you. For example, we engage Service Providers to provide marketing, advertising, communications, security, infrastructure and IT services, to customize, personalize and optimize our service, to provide customer service, to analyze and enhance information (including information about users' interactions with our service), and to process and administer consumer surveys. Cloud service providers: To provide services for global users, we choose cloud service providers with high-quality privacy protection and data security protection capabilities, including storage service providers, technical service providers (including content moderation service, Real-Time Communication service, mail and/or message
regulatory requirements of the local government, we may share the content information posted by you on the platform with the third-party content audit service providers entrusted by us. Customer support provider: To provide customer support and manage our communities, we may engage in customer support provider. Cooperative third-party SDK providers: When you use the functions provided by a third party in halo, we may access the Software Development Kit (SDK) provided by a third party to realize the relevant functions. We will restrict the SDK service providers through cooperation agreement. However, third-party SDK providers may collect your Personal Information. The aforementioned service providers' collection and processing of information and other activities are subject to their own privacy terms, and do not apply to this policy. To ensure the maximum security of your information, we recommend that you review the privacy policy of any third-party SDK service before using it. To protect your legitimate rights and interests, if you find that there is a risk in this SDK or other similar apps, we suggest that you immediately stop the relevant operations and contact us in time. Please refer to Description for collecting and using information through third-party SDKs for details. Sharing with third parties You understand and be informed that, in order to provide you with more complete and high-quality products and services, we will authorize our business partners to provide you with some services. In such cases, we may share some of your personal information with our partners, so as to provide you with better customer service and user experience. Please note that we will only share your personal information for legal, legitimate, necessary, specific and explicit purposes and will only share your personal information as is necessary to provide our services. We will conduct security assessment and processing on the output form, flow and use of information data, so as to ensure data security. At the same time, we will carry out strict supervision and management to our partners. Once we find that they are handling your personal information in violation of the rules
advertising. You grant us the right to share the indirect user profiles formed by us using your relevant information collection with partners who entrust us to carry out promotion and marketing, so as to help them make marketing or decision-making suggestions, improve the effective touch rate of advertising, and further understand user needs. We promise that we will not share any personal information that can identify you without your consent. Our affiliates. We will only share these information with our affiliates or third parties with your consent or otherwise permitted by applicable laws, so as to ensure that you receive consistent services in experience during the activities. Your friends. If you make friends with certain users on our Platform, they will view the rooms you have created and/or joined in. Other third parties. You may share your personal information or other information with third parties (including non-specific objects) based on the Platform by yourself. However, we shall not be liable for the disclosure, use and other related situations of information caused by your sharing behavior.
Transfer
Transfer is the transfer of control over your personal information to another company, organization or person. We will not transfer your personal information to any other company, organization or person unless we obtain your explicit consent. However, the following circumstances are excluded:
• We have obtained your consent in advance;
• It is proposed by yourself;
• If there is a merger, acquisition or bankruptcy liquidation of us, it may involve the transfer of your personal information. In this case, we will inform you of the relevant situation and require the new company, organization and person holding your personal information to continue to be subject to this policy. Otherwise we will require it to obtain your explicit consent again (when required by laws and regulations).
• Other circumstances as provided for by laws and regulations.
Public disclosure
• We will show necessary information (appropriate desensitization) when we announce the prize winner and penalty notice;
• Your profile information (including your username, profile photo, bio, age, levels, country, the numbers of visitors, the number of following users, the number of followers, badges, the number of rooms you have join, your preferred language, zodiac sign, tags, days you have joined
halo and gifts you received will be publicly disclosed.
• When you create a chatroom or join a chatroom, your profile (including username, profile photo, in-room status) and behaviors (including the messages you send in the chatroom and your voice chats when you engage in voice chatting) in the chatroom will be publicly disclosed. However, if the chatroom is set to private by using Room Lock, these information will only be disclosed to halo's users who join the chatroom or to users of our affiliates' products and services.
• Your in-room status and your related rooms will public disclosed, however, you may choose to share only to your friends on our
Platform, or only to your friends and followers on our Platform.
• When you publish public posts or make comments, we will publicly disclose your content (including but not limited to texts, images, videos) of posts and comments, your username, profile photo and the datetime when you publish posts or make comments. You may choose to public private posts which are only visible to your friends on our Platform, or only visible to your own self.
• When you click "Like" for a post/comment or send Virtual Gifts for a post, the actions (your "Like" and the Virtual Gift you send) will be public disclosed.
• We have obtained your explicit consent.
For Legal Reasons
We will share your information with law enforcement agencies, public authorities or other organisations if legally required to do so, or if such use is reasonably necessary to:
• comply with legal obligation, process or request;
• enforce our Terms of Service and other agreements, policies, and standards, including investigation of any potential violation thereof; information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
4. How do we store and protect your personal information
Storage and cross-border transfer
Your personal information will be processed on servers that may not be in your place of residence. Our support, development and other teams around the world have access to your information from outside of your place of residence. No matter where our servers are located, we will take appropriate measures to protect your rights and interests in accordance with this privacy policy.
Our servers used for platform services are located in: Frankfurt,
Germany; Dublin, Ireland.
If your personal information is transmitted to different countries, we will inform you of the purpose and recipient (when required by the data protection laws and regulations of your country) of your personal information via system message or email, and we will obtain your authorized consent (when required by the data protection laws and regulations of your country). We will strictly comply with the data protection laws and regulations of your country and ensure that the data recipients have adequate data protection capabilities to protect your personal information. You may refer to the appropriate safeguards used by us in the context of cross-border transfer by contacting us as described in "How to contact us" in the Policy.
Storage time
We will store your personal information for the necessary and reasonable storage period required for the purposes specified in this policy and required by laws and regulations. After the expiration of the aforementioned period, we will delete or anonymize your personal information, except where retention is necessary for complying with our legal obligations or as otherwise required by laws and regulations. (The so-called "anonymization" refers to the process in which the subject of personal information cannot be identified and the processed information cannot be recovered through the technical processing of beyond the storage period required by laws and regulations. However, we may retain your personal information even after you have deleted your personal information, you have closed your account with us or we have ceased providing Services to you, if retention of your personal information is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, prevent fraud, cheating or abuse, or enforce this policy or any other agreement we may have with other users.
If we cease operation, we will stop collecting your personal information in a timely manner, notify you of our cessation of operation in the form of one-by-one service or announcement, and delete or anonymize your personal information held by us.
Protection
To ensure the security of your personal information, we will endeavor to take various security measures in accordance with industry standards to protect your personal information, so as to minimize the risk of your personal information being damaged, embezzled, revealed, accessed without authorization, disclosed and changed. We will actively establish data classification and grading systems, data security management standards and data security development standards to manage and regulate the storage and use of your personal information and ensure that no personal information unrelated to our services are collected.
Please keep your account and password information properly. We will use commercially reasonable efforts to ensure that your information is not lost, abused or altered by backing up to other servers, encrypting user passwords and other security measures. Despite the aforementioned security measures, please note that there is no "100% security measure" on the information network.
In order to prevent security incidents (including personal information leakage), we have formulated a proper early warning mechanism and emergency response plan in accordance with laws and regulations. If a security incident does occur, we will inform you of the relevant situation in a timely manner by email, letter, call, push notification and other relevant methods, when required by laws and regulations. When it is
report the handling of personal information security incidents in accordance with the requirements of regulatory authorities, and closely cooperate with the government and regulatory authorities.
5. How do you manage your personal information This Section only applies to users located in relevant jurisdictions, unless otherwise specified. If you are a user located in any country/district listed in the Adaptation Area List, then the terms set out under the name of your jurisdiction in Adaptation Area List apply to you in addition to the terms set out in this Policy. We take very seriously and do our best to protect your rights related to your personal information. You may ask us to stop using part or all of your data and withdraw your consent. You may have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). Please note that in order to protect your information, we may need to verify your identity before responding to any request to exercise your rights.
Access & Correction
You have the right to request access to your personal information we hold about you, how we use it, and who we share it with. We may not be able to provide you with certain personal information if providing it to you would interfere with another person's rights (e.g. where providing the personal information we hold about you would reveal information about another person).
You also have the right to correct that information if it is inaccurate or incomplete.
You can access and correct your personal information by logging into your account at any time.
If you want us to correct your personal information that you are unable to correct using your account, please contact us as described in
Section "How to contact us".
Withdrawal of Consent
If certain of our processing is based on your consent, you may withdraw your consent by contacting us as described in Section "How
Lu yuul changing or withdrawing permissions.
If you choose to withdraw your consent, we will no longer collect such related information, but please note that this will render some or all of the functions unavailable. At the same time, your decision to change or withdraw your consent will not affect the processing of your personal information that we previously conducted based on your consent.
Not to be subject to processing of automatic decision-making of information system
In some service functions, we may make decisions based solely on non-manual automatic decision-making mechanisms such as information system and algorithm. If these decisions significantly affect your legitimate rights and interests, you have the right to ask us for an explanation and object automated decision making, or not to be subject to automated decision-making, and we will also provide appropriate remedies to contact us for management.
Erasure
You can initiate account deletion through our official website
(https://accountdelete.treezb.com/) or In-App Settings - Delete
Account. Please note that when you choose to delete in our official website,you shall log in to verify your account. If you forget your User ID or PIN Code, you may log in to halo APP to find then, or use our feedback function to solve the problem. Currently, not all account types are supported for deletion via the website. If you are unable to delete your account through the website, please log in to the app or contact our customer support at service@halo-voice.com.
After your account is deleted, your Personal Information will be removed from halo, except the Personal Information that must be retained by us as clearly stipulated by laws (such as the information related to your transactions in halo, and the data that should be retained as clearly stipulated by the government or laws).
Please refer to the Account Deletion Guidelines for details.
Obtain copy of information/Data portability
For security and identification reasons, you may not be able to directly access, correct or delete some information through the interactive interface of halo. If it is necessary for you to access, modify or request to delete such information according to laws, please send your questions to our designated email according to the contact information provided in Section "How to contact us" of this policy. We will review the problems involved as soon as possible and reply to you in time after verifying your identity.
Object
Certain jurisdictions may confer your right to object to certain of our personal information processing. You may exercise your right to object by contacting us as described in "How to contact us" in this policy. Lodge a complaint with a supervisory authority
You have the right to file a complaint with the supervisory authority in charge of data protection.
We attach great importance to the protection of users' privacy. If you have any comments or suggestions about us, you can send them to us. We are very happy to communicate with you and address your concerns.
6. Special instructions for the use of third-party products and/or services
halo may include third-party products and/or services or information and/or services linked to third parties. Your use of such third-party services (including any personal information provided by you to such third party) is subject to the third party's terms of service and privacy policy (but not this policy), and you need to read the terms carefully and decide whether to accept them at your sole discretion. Please protect your personal information properly and provide them to others only when necessary. This policy only applies to the information collected, stored, used, shared and disclosed by us, but does not apply to the services provided by any third party or the rules governing the use of information by any third party. The third party shall be solely responsible for the behavior of using your information. your relevant mobile device so that you can log in or use the services or functions of halo that rely on cookies. halo uses cookies to provide you with more thoughtful personalized services, including promotion services. You have the right to choose to accept or refuse to accept cookies. You can refuse to accept cookies by changing your browser settings or by setting it on your mobile device. However, if you choose to refuse to accept cookies, you may not be able to use the services or functions of halo that rely on cookies. This policy applies to the information obtained through cookies set in halo.
8. Special terms for jurisdictions We do our best to comply with data protection laws and regulations worldwide to protect users' personal data. At the same time, we are constantly updating our data protection work to ensure compliance with legislative requirements in various jurisdictions. Please give us feedback if there is any need for improvement or adaptation regarding our data protection you find in your daily use. Some jurisdictions have their own particular requirements. If you are a user located in the specific jurisdiction set out below, the relevant terms under the name of your jurisdiction apply to you in addition to the terms set out in our Privacy Policy. We continue to improve and update the laws of business promotion area adaptation, please refer to our Adaptation Area List.
9. Information relating to children We do not knowingly collect or maintain personal information from persons under 18 years-of-age. If we learn that Personal Information of persons under 18 has been collected on or through the Halo Services, we will take appropriate steps to delete this information. If you believe that we have inappropriately collected Personal Information from a Young User, please contact us at service@halo-voice.com.
10. How do we update this policy We reserve the right to update or amend this policy from time to time. These updates and amendments will form part of this policy and have the same effect as this policy. Without your explicit consent (when required by applicable data protection laws), we will not diminish your rights under this policy as currently in effect. In case of any update of this policy, we will update the revised version here along with the "last updated" date, and notify you or other means, as appropriate, so that you can be informed of any changes made to this policy in a timely manner.
11. How users can request data deletion
(1) If you want to request deletion of the data we have collected, please briefly fill in the reason for deletion and send it to our official email . We will process your request immediately and send the result to your email. Official email：service@halo-voice.com.
(2) Halo official statement: The user's personal data will be deleted upon request.
E-mail: service@halo-voice.com
Notice: When writing or emailing, please accurately describe your demands.
12. Miscellaneous If you have a dispute with us over privacy protection, you may find a way to resolve the dispute as described in "Applicable Law and Dispute Resolution" the Terms of Service.
Introduction Welcome to halo Platform (hereinafter referred to as "halo" or "Platform").
We attach great importance to privacy and protect the personal information and privacy of all our users in accordance with the applicable privacy laws worldwide. To provide you with more accurate and personalized services as well as a more secure Internet environment, we have defined our principles for the collection, use, provision, storage and protection of your personal information in accordance with applicable data protection laws, regulations and technical specifications, and further elaborated your rights related to your personal information. This policy is closely related to your use of our Platform or Services. When you download, install, start, browse, register, log in or use our Platform or Services (hereinafter collectively referred to as "using our platform or services"), we will process and protect your personal information in accordance with this policy. We try our best to explain to you the technical terms covered by this policy in a clear and concise manner so that you can understand them. We have used bold font to distinguish the terms in this policy that are (possibly) Please carefully read and fully understand this policy before using, or continuing to use our Products and Services, and make appropriate choices in accordance with the guidelines set out in this policy when necessary. If you do not agree with the content of this policy, it may cause our products or services to fail to function properly, or fail to achieve the intended effect of our services. You should immediately stop accessing/using our products and services. YOU KNOW AND CONFIRM THAT IF YOU CHECK "AGREE" TO THIS PRIVACY POLICY AND USE halo, YOU AGREE THAT WE WILL PROCESS YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY.
Please be aware that this policy only applies to the information collected by us to provide services to you through the Platform, and does not apply to any products, services, websites, or content that are offered by third parties or have their own privacy policy.
About Us
This policy sets out the basis for our processing of any personal information collected from you or provided to us by you. If you have any other questions about how we use your personal information, please contact us at service@halo-voice.com.
To improve the readability and user-friendly interaction of the privacy policy, we present it through the table of contents.
1. How do we collect your personal information
2. How do we use your personal information
3. How do we share, transfer and publicly disclose your personal information
4. How do we store and protect your personal information
5. How do you manage your personal information
U. Jul ID
9. Age restrictions and parental/guardian controls
10. How do we update this privacy policy
11. How to contact us
12. Miscellaneous
1. How do we collect your personal information We will follow the principles of what is rightful, legal and necessary to collect and use the personal information that you voluntarily provide to us, obtained by us from third party and automatically collected during you use of our Platform and Services. If we want to process your personal information for other purposes not specified in this policy, or use the information we have collected for other purposes based on a particular purpose, we will notify you in a reasonable manner and seek your consent (when required by applicable data protection laws) again before using it. Information you voluntarily provide to us
• Account information. When you register the account, we will collect your mobile phone number, mobile phone operator information, or your third-party account (such as Facebook, Apple, Twitter), depending on the method you choose for registration.
• Profile information. We will collect your profile information, including your profile photo, username, gender, date of birth, country, tags and bio.
• Activity and survey related information. When you choose to participate in activities and/or surveys organized by us or our affiliates or third parties on the platform, you may be required to provide your name, gender, mailing address, contact information and bank account information. If you refuse to provide them, it may affect your participation in related activities and/or surveys, but it will not affect your use of other functions.
• Room Information. When you create a chatroom, we may collect the name, announcements, public/private status and icon of the chatroom.
• Message Information. When you send message via halo, we will collect information you provide, including the content of the message, such as when it was sent, received and the recipient(s) of the message.
When you make a comment under a post, we will also collect the content of the comment and when it was made.
• Follow information. We will collect the users and topics you follow.
• Feedback information and proof of your identity. When you use halo feedback or customer service, we will collect your communication with us (including photos if you choose to send to illustrate errors). In certain circumstances, we may require you to provide relevant personal information to prove your identity.
Information obtained from third party Third party account information. When you register or log in with third party account, we will collect username and profile photo from the third parties (including Facebook, Apple, X ). Information automatically collected during your use of our Platform and Services
We also automatically collect and store your data below:
During you use of our Platform and Services, we will automatically collect data from you, i.e. your device id, userid, operating system version, device model, device type, carrier name, network type, client version number, language setting, IP address, SIMS country, registration time, login time and records about your use of the services, such as the date and timestamp of the operation.
We may collect information regarding your use of the Platform, including but not limited to how you engage with the Platform, how you interact with content or post, videos you watched, how you interact with chatrooms (including rooms you joined in, durations of your stays in rooms), how your interact with Virtua Items.
When you use our halo voice chat service with others, we do not retain such voice chat data on our servers and it only passes through our servers so that it can be distributed to your intended recipients.
When you have voice chat or send text messages in the chatroom, we do not retain such voice chat data and text chat data on our servers, and it only passes through our servers so that it can be distributed to other halo users in the chatroom. When you send images in the chatroom, we may collect the images you send and store the images for 3 days.
When you make any transaction through Google Play or iOS App Store and other third parties (if available), we will collect information to facilitate your transaction and maintain transaction records (including Open ID and user information fees, currency, purchased products, purchase history, IP address, transaction details as well as device details, such as operating system version, mobile phone model or device type, and Internet connection);
When you post, share, upload or otherwise make publicly available any information, such as your publicly-visible account profile, posts and comments ("Your Content"), we'll collect such information to allow Your Content to be shared with other users and develop new and improve existing services and app experience.
When you use halo feedback or customer service function to deal with the problem such as program errors, we will collect some information, including OpenlD, device ID, battery power, WiFi intensity, available space in device, network type, operating system version, browser type, platform, operator, country/area code, coupon details, email address.
We may access content, including text, images, and video, found in your device's clipboard, with your permission. For example, if you choose to initiate content sharing with a third-party platform, or choose to paste content from the clipboard into the Platform, we access this information stored in your clipboard in order to fulfill your request.
To ensure the safe operation of the software and services, we will collect your device model, device name, device ID (including IMEI, IMSI, and Android ID), browser type and Settings, language Settings, operating system version, app version, network device hardware address, login IP address, network access method, network quality data, mobile network information (including operator name), and product version number. To protect your account from malicious use by other users, please understand that we will dynamically detect whether there is abnormal login in your account. Every time you switch or restart the app, we may read the information of your device ID again, and we will control the read frequency within a reasonable range.
When you use our Platform and Services, our security and anticheating security functions will (i) analyze user device status to identify uaLa al lu yuul IL. may turn off located-based services via setting on your mobile device if you choose not to share your location. If you refuse to provide such information, you will not be able to use the location-based services, but it will not affect your use of other functionalities of halo.
When you feedback any problem or inquire something about our Platform and Services, for the security of your account and system, we may require you to provide relevant personal information to match the personal information you previously provided, so as to verify your user identity. After successful verification, we may collect the information when you communicate with us (account information, order information, and picture/video/text information and relevant information provided by you to prove relevant facts), your contact information, and records when you communicate with us, including the online communicate records and mobile phone recording, so as to solve the problem for you as soon as possible and improve our products and/or services. At the same time, we may contact you by phone, text message, system message and other relevant means to solve your problems arising in the process of using our Platform and Services.
To ensure that you can maintain instant messaging with the background server when using the services of halo and that you can receive personalized content push in a timely manner, we will i) obtain and invoke your boot broadcast permission to start the mobile client software of halo or its affiliates; ii) use a third-party push messaging service to generate an ID for you to identify the uniqueness of your device.
For the purpose of training and improving our technology, such as our machine learning models and algorithms, we may use the information we collect in our internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes and to solicit your feedback. To protect your data to the maximum extent, we use less information that might be connected to you, in some cases we de-identify or aggregate information. We might also anonymize it so that it no longer identifies you.
Summary of device permission invocation. During the process of providing services to you at halo, we may invoke some of your device permissions.
2. How do we use your personal formation We use your personal information to operate, provide, develop, and improve the Platform and Services, based on your consent, for performance of the contract between you and us or third parties, for complying with our legal obligations, or for pursuing our or third-party legitimate interest (if applicable), for the following purposes:
• To provide our Platform and Service, including enabling you to communicate with other users on our Platform.
• To enforce our Terms of Use, Community Guidelines and other policies that apply to you.
• To enable you to participate in the Virtual Items interactions.
• To understand how you use the Platform, including across your devices.
• To infer additional information about you, such as your age range, gender, and interests.
• To ensure the safe operation of our Platform and Services, and protect our Platform and Services from attack.
• To communicate with you, provide customer support and give our feedback on you.
• To conduct survey, analytics, research on our Platform and Services.
• To improve and develop the Platform and Services.
• To prevent and respond to abuse, fraud, illegal activities and other potentially harmful content.
• To ensure content is presented in the most effective manner for you and your device.
• To identify security risks and cheating.
• To train and improve our technology, such as our machine learning models and algorithms.
• To comply with our legal obligations, or as necessary to perform tasks in the public interest, or to protect the vital interests of our users and other people.
In accordance with relevant laws and regulations, we may collect and use some necessary personal information without your authorized consent under the following circumstances:
• Information directly related to public security, public health and major public interests;
• Information directly related to criminal investigation, prosecution, trial and execution of judgment and related matters;
• Information that are hard to get your consent for the purpose of protecting your or other life, property and relevant major legal rights and interests;
• Your personal information that are disclosed by you to the public;
• Your personal information collected from legally and publicly disclosed information: from lawful news reports, government information disclosure and related channels;
• Information necessary under the online agreement or contract you have signed with the Platform;
• Information necessary to maintain the safe and stable operation of our products and/or services: such information are used to detect and dispose of faults in the products or services and to deal with related problems;
• Other circumstances as provided for by laws and regulations.
3. How do we share, transfer and publicly disclose your personal information Sharing with service providers We entrust other companies, agents or contractors ("Service Providers") to perform services on our behalf or to assist us with the provision of services to you. For example, we engage Service Providers to provide marketing, advertising, communications, security, infrastructure and IT services, to customize, personalize and optimize our service, to provide customer service, to analyze and enhance information (including information about users' interactions with our service), and to process and administer consumer surveys. Cloud service providers: To provide services for global users, we choose cloud service providers with high-quality privacy protection and data security protection capabilities, including storage service providers, technical service providers (including content moderation service, Real-Time Communication service, mail and/or message
regulatory requirements of the local government, we may share the content information posted by you on the platform with the third-party content audit service providers entrusted by us. Customer support provider: To provide customer support and manage our communities, we may engage in customer support provider. Cooperative third-party SDK providers: When you use the functions provided by a third party in halo, we may access the Software Development Kit (SDK) provided by a third party to realize the relevant functions. We will restrict the SDK service providers through cooperation agreement. However, third-party SDK providers may collect your Personal Information. The aforementioned service providers' collection and processing of information and other activities are subject to their own privacy terms, and do not apply to this policy. To ensure the maximum security of your information, we recommend that you review the privacy policy of any third-party SDK service before using it. To protect your legitimate rights and interests, if you find that there is a risk in this SDK or other similar apps, we suggest that you immediately stop the relevant operations and contact us in time. Please refer to Description for collecting and using information through third-party SDKs for details. Sharing with third parties You understand and be informed that, in order to provide you with more complete and high-quality products and services, we will authorize our business partners to provide you with some services. In such cases, we may share some of your personal information with our partners, so as to provide you with better customer service and user experience. Please note that we will only share your personal information for legal, legitimate, necessary, specific and explicit purposes and will only share your personal information as is necessary to provide our services. We will conduct security assessment and processing on the output form, flow and use of information data, so as to ensure data security. At the same time, we will carry out strict supervision and management to our partners. Once we find that they are handling your personal information in violation of the rules
advertising. You grant us the right to share the indirect user profiles formed by us using your relevant information collection with partners who entrust us to carry out promotion and marketing, so as to help them make marketing or decision-making suggestions, improve the effective touch rate of advertising, and further understand user needs. We promise that we will not share any personal information that can identify you without your consent. Our affiliates. We will only share these information with our affiliates or third parties with your consent or otherwise permitted by applicable laws, so as to ensure that you receive consistent services in experience during the activities. Your friends. If you make friends with certain users on our Platform, they will view the rooms you have created and/or joined in. Other third parties. You may share your personal information or other information with third parties (including non-specific objects) based on the Platform by yourself. However, we shall not be liable for the disclosure, use and other related situations of information caused by your sharing behavior.
Transfer
Transfer is the transfer of control over your personal information to another company, organization or person. We will not transfer your personal information to any other company, organization or person unless we obtain your explicit consent. However, the following circumstances are excluded:
• We have obtained your consent in advance;
• It is proposed by yourself;
• If there is a merger, acquisition or bankruptcy liquidation of us, it may involve the transfer of your personal information. In this case, we will inform you of the relevant situation and require the new company, organization and person holding your personal information to continue to be subject to this policy. Otherwise we will require it to obtain your explicit consent again (when required by laws and regulations).
• Other circumstances as provided for by laws and regulations.
Public disclosure
• We will show necessary information (appropriate desensitization) when we announce the prize winner and penalty notice;
• Your profile information (including your username, profile photo, bio, age, levels, country, the numbers of visitors, the number of following users, the number of followers, badges, the number of rooms you have join, your preferred language, zodiac sign, tags, days you have joined
halo and gifts you received will be publicly disclosed.
• When you create a chatroom or join a chatroom, your profile (including username, profile photo, in-room status) and behaviors (including the messages you send in the chatroom and your voice chats when you engage in voice chatting) in the chatroom will be publicly disclosed. However, if the chatroom is set to private by using Room Lock, these information will only be disclosed to halo's users who join the chatroom or to users of our affiliates' products and services.
• Your in-room status and your related rooms will public disclosed, however, you may choose to share only to your friends on our
Platform, or only to your friends and followers on our Platform.
• When you publish public posts or make comments, we will publicly disclose your content (including but not limited to texts, images, videos) of posts and comments, your username, profile photo and the datetime when you publish posts or make comments. You may choose to public private posts which are only visible to your friends on our Platform, or only visible to your own self.
• When you click "Like" for a post/comment or send Virtual Gifts for a post, the actions (your "Like" and the Virtual Gift you send) will be public disclosed.
• We have obtained your explicit consent.
For Legal Reasons
We will share your information with law enforcement agencies, public authorities or other organisations if legally required to do so, or if such use is reasonably necessary to:
• comply with legal obligation, process or request;
• enforce our Terms of Service and other agreements, policies, and standards, including investigation of any potential violation thereof; information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
4. How do we store and protect your personal information
Storage and cross-border transfer
Your personal information will be processed on servers that may not be in your place of residence. Our support, development and other teams around the world have access to your information from outside of your place of residence. No matter where our servers are located, we will take appropriate measures to protect your rights and interests in accordance with this privacy policy.
Our servers used for platform services are located in: Frankfurt,
Germany; Dublin, Ireland.
If your personal information is transmitted to different countries, we will inform you of the purpose and recipient (when required by the data protection laws and regulations of your country) of your personal information via system message or email, and we will obtain your authorized consent (when required by the data protection laws and regulations of your country). We will strictly comply with the data protection laws and regulations of your country and ensure that the data recipients have adequate data protection capabilities to protect your personal information. You may refer to the appropriate safeguards used by us in the context of cross-border transfer by contacting us as described in "How to contact us" in the Policy.
Storage time
We will store your personal information for the necessary and reasonable storage period required for the purposes specified in this policy and required by laws and regulations. After the expiration of the aforementioned period, we will delete or anonymize your personal information, except where retention is necessary for complying with our legal obligations or as otherwise required by laws and regulations. (The so-called "anonymization" refers to the process in which the subject of personal information cannot be identified and the processed information cannot be recovered through the technical processing of beyond the storage period required by laws and regulations. However, we may retain your personal information even after you have deleted your personal information, you have closed your account with us or we have ceased providing Services to you, if retention of your personal information is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, prevent fraud, cheating or abuse, or enforce this policy or any other agreement we may have with other users.
If we cease operation, we will stop collecting your personal information in a timely manner, notify you of our cessation of operation in the form of one-by-one service or announcement, and delete or anonymize your personal information held by us.
Protection
To ensure the security of your personal information, we will endeavor to take various security measures in accordance with industry standards to protect your personal information, so as to minimize the risk of your personal information being damaged, embezzled, revealed, accessed without authorization, disclosed and changed. We will actively establish data classification and grading systems, data security management standards and data security development standards to manage and regulate the storage and use of your personal information and ensure that no personal information unrelated to our services are collected.
Please keep your account and password information properly. We will use commercially reasonable efforts to ensure that your information is not lost, abused or altered by backing up to other servers, encrypting user passwords and other security measures. Despite the aforementioned security measures, please note that there is no "100% security measure" on the information network.
In order to prevent security incidents (including personal information leakage), we have formulated a proper early warning mechanism and emergency response plan in accordance with laws and regulations. If a security incident does occur, we will inform you of the relevant situation in a timely manner by email, letter, call, push notification and other relevant methods, when required by laws and regulations. When it is
report the handling of personal information security incidents in accordance with the requirements of regulatory authorities, and closely cooperate with the government and regulatory authorities.
5. How do you manage your personal information This Section only applies to users located in relevant jurisdictions, unless otherwise specified. If you are a user located in any country/district listed in the Adaptation Area List, then the terms set out under the name of your jurisdiction in Adaptation Area List apply to you in addition to the terms set out in this Policy. We take very seriously and do our best to protect your rights related to your personal information. You may ask us to stop using part or all of your data and withdraw your consent. You may have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). Please note that in order to protect your information, we may need to verify your identity before responding to any request to exercise your rights.
Access & Correction
You have the right to request access to your personal information we hold about you, how we use it, and who we share it with. We may not be able to provide you with certain personal information if providing it to you would interfere with another person's rights (e.g. where providing the personal information we hold about you would reveal information about another person).
You also have the right to correct that information if it is inaccurate or incomplete.
You can access and correct your personal information by logging into your account at any time.
If you want us to correct your personal information that you are unable to correct using your account, please contact us as described in
Section "How to contact us".
Withdrawal of Consent
If certain of our processing is based on your consent, you may withdraw your consent by contacting us as described in Section "How
Lu yuul changing or withdrawing permissions.
If you choose to withdraw your consent, we will no longer collect such related information, but please note that this will render some or all of the functions unavailable. At the same time, your decision to change or withdraw your consent will not affect the processing of your personal information that we previously conducted based on your consent.
Not to be subject to processing of automatic decision-making of information system
In some service functions, we may make decisions based solely on non-manual automatic decision-making mechanisms such as information system and algorithm. If these decisions significantly affect your legitimate rights and interests, you have the right to ask us for an explanation and object automated decision making, or not to be subject to automated decision-making, and we will also provide appropriate remedies to contact us for management.
Erasure
You can initiate account deletion through our official website
(https://accountdelete.treezb.com/) or In-App Settings - Delete
Account. Please note that when you choose to delete in our official website,you shall log in to verify your account. If you forget your User ID or PIN Code, you may log in to halo APP to find then, or use our feedback function to solve the problem. Currently, not all account types are supported for deletion via the website. If you are unable to delete your account through the website, please log in to the app or contact our customer support at service@halo-voice.com.
After your account is deleted, your Personal Information will be removed from halo, except the Personal Information that must be retained by us as clearly stipulated by laws (such as the information related to your transactions in halo, and the data that should be retained as clearly stipulated by the government or laws).
Please refer to the Account Deletion Guidelines for details.
Obtain copy of information/Data portability
For security and identification reasons, you may not be able to directly access, correct or delete some information through the interactive interface of halo. If it is necessary for you to access, modify or request to delete such information according to laws, please send your questions to our designated email according to the contact information provided in Section "How to contact us" of this policy. We will review the problems involved as soon as possible and reply to you in time after verifying your identity.
Object
Certain jurisdictions may confer your right to object to certain of our personal information processing. You may exercise your right to object by contacting us as described in "How to contact us" in this policy. Lodge a complaint with a supervisory authority
You have the right to file a complaint with the supervisory authority in charge of data protection.
We attach great importance to the protection of users' privacy. If you have any comments or suggestions about us, you can send them to us. We are very happy to communicate with you and address your concerns.
6. Special instructions for the use of third-party products and/or services
halo may include third-party products and/or services or information and/or services linked to third parties. Your use of such third-party services (including any personal information provided by you to such third party) is subject to the third party's terms of service and privacy policy (but not this policy), and you need to read the terms carefully and decide whether to accept them at your sole discretion. Please protect your personal information properly and provide them to others only when necessary. This policy only applies to the information collected, stored, used, shared and disclosed by us, but does not apply to the services provided by any third party or the rules governing the use of information by any third party. The third party shall be solely responsible for the behavior of using your information. your relevant mobile device so that you can log in or use the services or functions of halo that rely on cookies. halo uses cookies to provide you with more thoughtful personalized services, including promotion services. You have the right to choose to accept or refuse to accept cookies. You can refuse to accept cookies by changing your browser settings or by setting it on your mobile device. However, if you choose to refuse to accept cookies, you may not be able to use the services or functions of halo that rely on cookies. This policy applies to the information obtained through cookies set in halo.
8. Special terms for jurisdictions We do our best to comply with data protection laws and regulations worldwide to protect users' personal data. At the same time, we are constantly updating our data protection work to ensure compliance with legislative requirements in various jurisdictions. Please give us feedback if there is any need for improvement or adaptation regarding our data protection you find in your daily use. Some jurisdictions have their own particular requirements. If you are a user located in the specific jurisdiction set out below, the relevant terms under the name of your jurisdiction apply to you in addition to the terms set out in our Privacy Policy. We continue to improve and update the laws of business promotion area adaptation, please refer to our Adaptation Area List.
9. Information relating to children We do not knowingly collect or maintain personal information from persons under 18 years-of-age. If we learn that Personal Information of persons under 18 has been collected on or through the Halo Services, we will take appropriate steps to delete this information. If you believe that we have inappropriately collected Personal Information from a Young User, please contact us at service@halo-voice.com.
10. How do we update this policy We reserve the right to update or amend this policy from time to time. These updates and amendments will form part of this policy and have the same effect as this policy. Without your explicit consent (when required by applicable data protection laws), we will not diminish your rights under this policy as currently in effect. In case of any update of this policy, we will update the revised version here along with the "last updated" date, and notify you or other means, as appropriate, so that you can be informed of any changes made to this policy in a timely manner.
11. How users can request data deletion
(1) If you want to request deletion of the data we have collected, please briefly fill in the reason for deletion and send it to our official email . We will process your request immediately and send the result to your email. Official email：service@halo-voice.com.
(2) Halo official statement: The user's personal data will be deleted upon request.
E-mail: service@halo-voice.com
Notice: When writing or emailing, please accurately describe your demands.
12. Miscellaneous If you have a dispute with us over privacy protection, you may find a way to resolve the dispute as described in "Applicable Law and Dispute Resolution" the Terms of Service.