Last Updated: May 31, 2019

This Privacy Policy explains how information about you is collected, used and disclosed by Halogen Networks, LLC ( “Halogen” or “we”). This Privacy Policy applies to information we collect when you use our websites, mobile apps and online services (collectively, “Services”) or when you otherwise interact with us, including when you contact us for customer support.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you an email).

For information about choices we provide in connection with our information practices, please see the “Your Choices” section below.

Collection of Information

Information You Provide to Us

We collect information you provide directly to us. For example, we collect information when you register for an account, update your profile, request customer support or otherwise communicate with us. The types of information we may collect include your first and last name, email address, phone number, profile picture, username, zip code and country, payment method information, and any other information you choose to provide.

Information We Collect Automatically When You Use the Online Services

When you use our Services, we automatically collect information about you, including:

  • Usage Information: We collect information about your use of our Services, including which content or features you interact with, purchases you make, and similar usage information.
  • Location Information: We collect the approximate location of your device based the device’s IP address. We may also collect precise location of your mobile device via our mobile app in accordance with the permission process established by your mobile device operating system.
  • Stored Information: We access information you have stored on your mobile device via our mobile app in accordance with the permission process established by your mobile device operating system. For example, with your permission, we may access contacts from your mobile device address book or photos from your mobile device photo gallery.
  • Mobile Device Information: We collect information about the mobile device you use to access our mobile apps, including hardware model, operating system version, unique device identifiers, and mobile network information.
  • Log Information: We collect server logs in connection with your use of our websites and mobile apps, which include IP address, the specific action taken through our websites and mobile apps, the date and time of the action, and web browser type and language.
  • Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information in connection with your use of our Services, including cookies, local storage and pixel tags. For more details about those technologies, including how to disable cookies, please refer to our Cookie Policy. We also use mobile device identifiers, established by your mobile device operating system, to recognize your mobile device when you use our app and to track your usage of our app.

Information We Collect From Other Sources

We also obtain information about you from other sources. For instance, if you link your Halogen account with an account you have with a social media service (such as Facebook), we will have access to certain information from that service, such as your name, profile image, and other account information, in accordance with the authorization procedures established by that service.

Use of Information

We combine the information we collect about you and use this information for various purposes, including to:

  • Provide and improve our products and services;
  • Process your transactions;
  • Send you technical notices and support and administrative messages;
  • Communicate with you about products, services, promotions, events and other news and information we think will be of interest to you;
  • Personalize our Services, including by providing content, advertisements or features we think will be of interest to you;
  • Facilitate contests and promotions and process and deliver prizes;
  • Monitor and analyze trends and usage in connection with our Services;
  • Detect and prevent fraudulent transactions and other illegal activities, comply with our legal obligations and protect the rights and property of Halogen and others; and
  • Carry out any other purpose described to you at the time the information was collected.

Sharing of Information

We share information about you as follows:

  • We share the following with other users of the platform:
    • your profile (including your name, username, profile picture, number of followers and an optional description field) is viewable by other users;
    • the creators of content that you interact with also can see your aggregate engagement with their content (including the total number of views, comments, gifts, tips, reactions and promotions);.
  • When you request to redeem Halogen coins for cash through the services offered by Hyperwallet Systems, Inc. (“Hyperwallet”), we share information about you with Hyperwallet to help you create an account with Hyperwallet and for their use as described in their privacy policy (available at: https://www.hyperwallet.com/privacy-policy/);
  • With service providers in connection with the services they perform for us or for you;
  • In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation or legal process;
  • If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of Halogen or others;
  • In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company; and
  • With your consent or at your direction.

We also share aggregated or de-identified information with third parties, which cannot reasonably be used by those third parties to identify you.


The information we collect about you may be transferred to, and accessed from within, the United States, which may not offer the same level of data protection as your home jurisdiction. We will take steps to maintain an adequate level of protection for this information in the jurisdictions in which we process it. If you are in the European Economic Area (“EEA”) or Switzerland, this information is transferred to the United States pursuant to our Privacy Shield certification. Please see the “Note to Individuals in the EEA and Switzerland” section below for more details.

Advertising and Analytics Services Provided by Others

We allow others to provide analytics services and serve advertisements on our behalf across other websites and online services. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of our websites and mobile apps and other websites and apps, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked and conversion information. This information is used by Halogen and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our websites and mobile apps and other websites and apps, and better understand your online activity. For more information about interest-based ads, or to learn how you may be able to opt out of having your web browsing information used for behavioral advertising purposes, please visit our Cookie Policy. Your mobile device may also include a feature that allows you to opt out of having certain information collected through apps used for behavioral advertising purposes. Please review the settings of your mobile device for more information.

Your Choices

Account Information

You may update the online account information you provide to us by logging into your online account.

Promotional Communications

You may opt out of receiving promotional emails from us by following the instructions in those emails. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

Contact Us

If you have any questions about this Privacy Policy, please contact us at [email protected].


If you are in the EEA or Switzerland, you have certain rights and protections under the law regarding our processing of your personal data. Please see the sections below for more details.

Legal Basis for Processing

We will only process personal data about in accordance with the following legal bases:

  • As necessary to perform our responsibilities under our contract with you. For example, by processing your order and fulfilling the products or services you purchase.
  • When we have a legitimate interest in processing your personal data. For example, to communicate with you about changes to our Services or legal documents, to prevent fraud, or to provide, protect and improve our products and services.
  • If we request your consent to a specific processing activity (such as to send marketing emails), and you provide your consent in the manner indicated.
  • In some cases, processing will be necessary for compliance with a legal obligation, such as response to legal process requests.

Data Subject Requests

You have the right to access personal data we hold about you and to ask that this data be corrected. In certain cases, you may also have the right to request that we erase data we are processing or to restrict or object to certain of our processing activities. You may also have the right to request that we provide you with the personal data you have provided us in a portable form for transmission to another controller’s service. If you would like to exercise any of these rights, you may contact us as indicated above.

Data Retention

We store the information we collect about you for as long as is necessary for the purposes for which we originally collected it. We may retain certain information for legitimate business purposes or as required by law.

EU-U.S. and Swiss-U.S. Privacy Shield Framework

We adhere to the EU-U.S. and Swiss-U.S. Privacy Shield Framework Principles issued by the U.S. Department of Commerce (the “Principles”) in connection with our processing of personal data received from the European Economic Area and Switzerland (“Covered Data”). For more information about the Principles and to view our certification, please visit the Department of Commerce’s Privacy Shield website. You may contact us about any question or complaint regarding adherence to the Principles as indicated above. If we do not resolve your complaint, you may submit your complaint free of charge to JAMS at https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim, our designated Privacy Shield independent dispute resolution provider.  Under certain conditions specified by the Principles, you may also be able to invoke binding arbitration to resolve your complaint.  We are subject to the investigatory and enforcement powers of the Federal Trade Commission.  If we share Covered Data with a third-party service provider that processes the data solely on our behalf, then we will be liable for that party’s processing of Covered Data in violation of the Principles, unless we can prove that it is not responsible for the event giving rise to the damage.

Questions or Complaints

If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see: https://edpb.europa.eu/about-edpb/board/members_en

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