Halo Habits — Privacy Policy

Last Updated: August 21, 2025

1) Overview

This Privacy Policy explains how Halo Habits ("Halo Habits," "we") collects, uses, shares, and protects personal information when you use our app, website, and mobile messaging program.

2) Information we collect

• Account & contact info: name, email, phone number, password, preferences.
• App data: habit selections, check-ins, goals, progress, timestamps, app interactions.
• Messaging data: phone number, delivery status, timestamps, carrier information, and message content you send/receive through our program.
• Device & technical data: IP address, device identifiers, app version, cookies and similar technologies.
• Support & feedback: information you provide when contacting us.

3) How we use information

• Provide and improve the Services (including reminders, check-ins, and support messages).
• Personalize content and recommendations.
• Communicate about your account, features, and policy updates.
• Ensure security, prevent misuse, and comply with laws, carrier/industry policies, and platform rules.
• Create de-identified or aggregated insights to improve the Services.

4) SMS/MMS program privacy specifics

We store and process your mobile number, messaging metadata, and message content as needed to operate the program and maintain consent records.

We honor HELP/STOP requests and keep audit logs as required by law and industry rules.

Sharing for delivery. To deliver messages, we share necessary data with our messaging provider(s) (e.g., Twilio) and with wireless carriers and their service providers. Message content and metadata may be processed and disclosed for delivery, filtering, fraud prevention, and legal compliance.

No sale of numbers. Your mobile number will not be sold, rented, or shared with third parties for marketing purposes. It is only used for the delivery of Halo Habits services as described in this Policy.

Cost & frequency. Message & data rates may apply. Message frequency: up to 3 check-in messages per week.

Opt-out. Text STOP to end (recognized synonyms include STOP, STOPALL, UNSUBSCRIBE, CANCEL, END, QUIT). Text HELP for help.

5) Legal bases (EEA/UK users)

We process data as needed to perform our contract with you, with your consent (e.g., marketing texts), to comply with legal obligations, and for our legitimate interests (e.g., service improvement and security). You may withdraw consent at any time (e.g., by texting STOP).

6) Sharing of information

We share data with:

• Service providers/processors who help us run the Services (hosting, analytics, customer support, and messaging providers such as Twilio and telecom carriers).
• Legal, safety, and compliance recipients where required (e.g., to comply with law or enforce our terms).
• Business transfers (merger, acquisition, or asset sale).

We do not sell your personal information.

7) Data retention

We retain personal information for as long as necessary to provide the Services, meet legal/operational requirements (including consent and opt-out records), resolve disputes, and enforce agreements.

8) Security

We use administrative, technical, and organizational measures designed to protect personal information. No method of transmission or storage is 100% secure.

9) Your choices & rights

• Account & preferences: You can update or delete certain information in the app or by contacting us.
• Mobile messaging: Text STOP to opt out; HELP for help.
• Marketing: You can opt out of non-essential emails/SMS at any time.
• CCPA/CPRA (California): You may request access, deletion, or correction and the right to limit certain uses of sensitive data. We do not sell or share personal information for cross-context behavioral advertising.
• GDPR (EEA/UK): You may request access, deletion, correction, restriction, or portability, and object to certain processing. You also have the right to complain to your supervisory authority.

10) Children's privacy

The Services are not directed to children under 13, and we do not knowingly collect personal information from them.

11) International data transfers

We may transfer and process information in countries other than your own (including the U.S.). Where required, we use appropriate safeguards (e.g., standard contractual clauses).

12) Changes to this Policy

We may update this Policy and will post the new effective date above.

13) Contact

Privacy questions or requests: hello@halohabits.app

Postal:
Dig Wells, Inc.
2261 Market Street STE 10586
San Francisco, CA 94114