Privacy Policy

1. Introduction

At Halo Eye Inc. (“Halo”, “we”, “our”, or “us”), we are committed to protecting the privacy, security, and confidentiality of the personal information we process. This Privacy Policy explains what data we collect, how we use it, how we safeguard it, and the rights available to you under applicable privacy laws.

This policy is designed to comply with:

• PIPEDA (Canada’s Personal Information Protection and Electronic Documents Act)

• GDPR (European Union General Data Protection Regulation)

• Applicable provincial and international privacy laws

By using Halo Compass or any related Halo Eye Inc. services, you acknowledge and agree to the practices described in this Privacy Policy.

2. Information We Collect

2.1 Personal Information

We may collect the following categories of personal information:

• Identity & Contact Information: name, email address, phone number, business information

• Account Information: login credentials, user permissions, preferences

• Billing Information: payment details and invoicing data (processed securely through third-party providers; Halo does not store full credit card numbers)

We collect this information when you create an account, contact us, request a demo, or use our services.

2.2 Device & Usage Information

To support platform performance, diagnostics, and security, we collect:

• IP address and approximate location

• Device type, browser version, operating system

• Log data such as feature usage, errors, and system events

• Cookies and similar technologies (see Section 10)

2.3 Operational Data

Depending on your use of Halo Compass, we may also process:

• Vehicle photographs and capture metadata

• Quality-control signals and inspection data

• Integration logs required to connect to authorized third-party systems

All operational data is processed solely to deliver and improve Halo Compass functionality.

3. How We Use Your Information

We use personal and operational data to:

• Operate and improve Halo Compass

• Authenticate identities and secure user accounts

• Facilitate integrations through our Halo Integration Agent

• Provide onboarding, training, and customer support

• Enhance AI-assisted workflows using anonymized or de-identified data

• Comply with legal and regulatory requirements

• Communicate service updates, new features, or important notices

We never sell personal information.

4. Legal Basis for Processing (GDPR)

For users in the EU or UK, we process personal data based on:

• Contractual necessity – to operate the platform

• Legitimate interests – security, service improvement, fraud prevention

• Consent – for optional analytics or marketing

• Legal obligations – regulatory and compliance requirements

5. Data Sharing & Disclosure

We only share information with:

5.1 Service Providers

Trusted partners who assist with:

• Cloud hosting and infrastructure

• Payment processing

• Analytics, monitoring, and product operations

• Authorized integrations and API connectivity

All service providers must comply with strict confidentiality and data protection standards.

5.2 Legal Requirements

We may disclose information:

• To comply with applicable laws, regulations, or legal processes

• To protect the safety, rights, or property of Halo Eye Inc., our users, or third parties

• To investigate potential violations of Halo’s Terms of Service

5.3 Business Transfers

If Halo Eye Inc. is involved in a merger, acquisition, financing, or sale of assets, your information may be transferred as part of that transaction. You will be notified of any material changes to our privacy practices.

6. International Transfers

Your data may be processed in countries outside your region, including Canada and the United States.
Where required (under GDPR), we use Standard Contractual Clauses (SCCs) or equivalent safeguards.

7. Data Security

We implement industry-leading measures to protect your data, including:

• Encryption in transit and at rest

• Role-based access control

• Secure coding practices

• Continuous monitoring and auditing

• Regular penetration tests and security reviews

While no system can guarantee complete security, we take all reasonable steps to safeguard your data.

8. Data Retention

We retain personal information only as long as necessary to:

• Deliver services

• Meet legal requirements

• Resolve disputes

• Improve system reliability and performance

When data is no longer required, we securely delete or permanently anonymize it.

9. Your Rights

Depending on your region (EU, UK, Canada), you may have the right to:

• Access your personal data

• Correct inaccurate information

• Request deletion (“Right to be Forgotten”)

• Object to or restrict processing

• Request a machine-readable copy (“data portability”)

• Withdraw consent at any time

To exercise your rights, contact us at hello@haloeye.ai.
We respond within legally mandated timelines (30 days under PIPEDA and GDPR).

10. Cookies & Tracking Technologies

Halo Compass uses cookies and similar technologies for:

• Secure authentication

• Session management

• Performance and analytics

You may adjust your cookie settings in your browser at any time.

11. Third-Party Links

Halo Compass may link to third-party sites. We are not responsible for their privacy practices. Please review their privacy policies before providing any information.

12. Children’s Privacy

Halo Compass is not intended for children under the age of 16.
We do not knowingly collect personal information from minors.

13. Updates to This Privacy Policy

We may update this policy to reflect changes in regulations, technology, or our practices.
When updates occur, we will provide notice via email or within the Halo Compass platform.

14. Contact Us

For questions, privacy requests, or concerns, contact:

Halo Eye Inc.
76 Richmond St E, Suite 350
Toronto, ON M5C 1P1
Canada

Email: hello@haloeye.ai

We are committed to protecting your personal information and building technology that respects your privacy, your rights, and your trust.