Last modified: February 10, 2016
Introduction and Acceptance of Terms
Information We Collect and How We Collect It
When you use the Service you provide us with three types of information: (i) information you submit via the Service; (ii) information regarding your use of the Service collected by us as you interact with the Service; and (iii) information about your use of third party mobile applications available through your mobile device. The information we gather enables us to personalize, improve, and continue to operate the Service and to provide you with the services and information you request.
We collect several types of information from and about you, including:
• information that, taken alone, identifies you and that can be used to contact you, on-line or offline ("Personally Identifiable Information"), which may include, for example, your name or email address;
• information about you that cannot be used alone to identify you ("Non-Personally Identifiable Information"), which may include, for example, demographic information including zip code, and information about your use of our Service, which may include, for example, information about your internet connection, or your computer or mobile device and software you use to access our Service, including your Internet Protocol ("IP") address or other device identifiers.
We collect and/or request information in two ways.
• Information you give us –
You must register for an account in order to access the Service. By registering for the Service, you agree that we will have access to your account information, including your email address, name, language and country and other necessary information to provide you with the Service. This information may be personal to you, and by accessing the Service, you allow us to identify you.
We may use your contact information to send you information about our Service, ask follow-up questions relating to your use of the Service or to invite you to test future versions of the Service. We may also contact you in other circumstances when we believe it is necessary.
• Information we get from your use of the Service –
Halo Device Data
When you access and use the Service, we will collect and store the data you submit to or through the Service, including information on the amount of type of Neuropriming delivered, impedance and other device performance information, and information related to athletic, cognitive, or skill assessment. When you sync your Halo Device through the Halo App, data recorded on your Halo Device about your activity is transferred from your Halo Device to our servers. This data is stored and used to provide the Service and is associated with your account. Each time a sync occurs, we log data about the transmission. Some examples of the log data are the sync time and date, device battery level, and the IP address used when syncing.
IP Address Information and Other Information Collected Automatically
We automatically receive and record certain information when you access and use the Service, which may include your IP address, cookie information, hardware model, operating system version, unique device identifiers and mobile network information. Internet traffic information, such as IP address, is usually assigned in country-based blocks, so it can be used to at least identify the country of your device, and do things such as to provide you with the correct language and locale for search queries. This information is sent as a normal part of Internet traffic. Generally, the Service automatically collects usage information, such as the number and frequency of visitors to the Service. We may use this data in aggregate form—that is, as a statistical measure—but not in a manner that would identify you personally. This type of aggregate data enables us, and third parties authorized by us, to figure out how individuals use the Service so that we can improve it accordingly.
Information Collected Using Cookies and Web Beacons.
We may also use "clear GIFs" (aka "web beacons" or "pixel tags") or similar technologies on our Service or in our communications with you to enable us to know whether you have visited a part of our Service or received a message. A clear GIF is typically a one-pixel, transparent image (although it can be a visible image as well), located on a website or in an email or other type of message, which is retrieved from a remote website on the Internet enabling the verification of an individual's viewing or receipt of a website or message. We may also log information using digital images called web beacons on our Service or in our emails. We may use web beacons to manage cookies, count visits, and to learn what marketing works and what does not. We may also use web beacons to tell if you open or act on our emails. We do not track our users across third party websites and thus do not respond to Do Not Track ("DNT") signals.
When you access our Service, you may also be asked to allow Push Messages to be sent to you outside or inside of the Service. If you do so a device token will be generated, which is associated with you until you log out. We will collect and store these device tokens on our servers.
Our Use of Your Personal Information
We may use information that we collect about you or that you provide to us, including any Personally Identifiable Information to:
• provide to you and communicate with you about the services, content, features or products you use or request;
• customize and optimize the content you receive when you use the Service, and otherwise improve your experience on the Service;
• troubleshoot the Service, to detect and protect against error, fraud or other criminal activity, and to enforce our Terms of Service;
• secure your account and prevent fraud;
• in any other way we may describe when you provide the information; and
• for any other purpose with your consent.
Our Use of Your Non-Personally Identifiable Information
Halo is committed to furthering scientific research in the fields of neuromodulation, sports science, and human performance. Consequently, Halo may share, analyze, publish or sell aggregated, de-identified data that does not identify you, with partners and the public in a variety of ways, such as by publishing scientific papers on topics related to Neuropriming, publishing reports about athletic performance, or providing guidance to consumers or partners regarding best practices. When we provide this information, we perform appropriate procedures so that the data does not identify you and we contractually prohibit recipients of the data from re-identifying it back to you.
IMPORTANT: Even if you delete the Halo App, close your account or stop using the Service, we will retain the data collected from your use of the Halo Device, including data recorded on your Halo Device about your activity. However, Halo will use such information only in a manner such that the data does not identify you.
Sharing Personally Identifiable Information with Third Parties We may share Personally Identifiable Information in response to a valid law enforcement request or legal process, to protect our rights and property or those of third parties, or as otherwise permitted or required by law.
Additionally, we may disclose your Personally Identifiable Information without your consent:
• if we believe there is a serious and imminent threat to the life, health or safety of yourself or another person;
• to investigate or report on activity which we believe on reasonable grounds to be unlawful;
• if disclosure is required or authorized by law (for example, in response to a subpoena or where a regulatory authority has the power to request the provision of certain records or information);
• if disclosure is reasonably necessary to enable an enforcement body to perform its functions, for example the prevention, detection, investigation, prosecution or punishment of criminal offenses, or the preparation for, or conduct of, proceedings before any court or tribunal, or implementation of the orders of a court or tribunal; or
• if we deem it necessary in our sole discretion to protect our legal and legitimate business interests.
Protecting Your Information
We have implemented policies and procedures, including technical measures, that are designed to help safeguard your information from unauthorized access, use or modification. However, we do not assure you that our systems are completely secure and advise you that we believe a persistent attacker with sufficient resources would be able to defeat the security measures we have in place.
Information You Can Access; Ability to Opt-Out
Examples of information you can access easily in the Service include up-to-date information regarding recent account activity; as well as Personally Identifiable Information (including name, mobile telephone number and e-mail). You may access and update such information by using the Service.
You have control over any settings related to the Push Messages, and can opt in or out of any Push Messages.
The Service is not directed to children and is not intended for any persons under 18 years of age. Moreover, we do not knowingly collect Personally Identifiable Information from subjects under 13 years of age. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, please contact us at firstname.lastname@example.org. If we become aware that a member is under the age of 13 and has provided us with Personally Identifiable Information without verifiable parental consent, we will delete such information from our file.
California residents may choose to request certain information regarding our disclosure of Personally Identifiable Information to third parties for their direct marketing purposes or choose to opt out of such disclosure. To make a request or to opt out at any time, please contact us at email@example.com or the other contact information provided below. Our policy is not to disclose Personally Identifiable Information collected online to a third party for directing marketing without your approval.