Privacy Policy
Last Updated: April 28, 2024
At Halfmore, we strive to empower families by transforming everyday tasks into opportunities for financial growth and education. Our mission is to create a world where every family can secure their children's financial future. We are a community rooted in the principles of innovation and inclusivity. Central to nurturing this community is our commitment to earning and maintaining your trust. This begins with being transparent about how we handle your information and upholding your fundamental human right to privacy, as we navigate the path of financial literacy and security together.
This privacy notice for Halfmore, Inc. and its affiliates (“we,” “us,” “our” or “Halfmore”) describes how and why we might collect, store, use and/or share (“process”) information about you and your family. It applies to everyone who: visits our websites that link to this Privacy Policy (the “Site”); uses our mobile applications, financial accounts and cards (collectively, the “App”); uses our platforms - including touch technologies, electronic services, social networking sites, interactive features, online services or any of our described online activities we own or control that link to this Privacy Policy (collectively, our “Platforms”) or otherwise uses the services we provide (collectively, the “Service”). For more information regarding the Service, please review our Terms and Conditions (the “Terms”).
Key terms: In this Privacy Policy, we refer to “you” as a visitor to our Site, user of our App/Platforms, and/or the individual, parent or guardian who is responsible for the account(s) you create using our Service (the “Custodian” as defined in our Terms). We use “your family” to refer to anyone affiliated with your account on the Service, such as any child or children you sign up for the Service. If you designate any other individual to be responsible for the Service, such as your spouse, or authorized user (as defined in the Terms), “your family” also includes that individual.
1. Types of Information We Collect and How
We collect the following categories of personal information:
Identifiers and contact details: such as name, postal addresses, email addresses, social networking website user account names, telephone numbers, or other addresses at which you are able to receive communications.
Official identification information: such as Social Security number, government issued Driver’s License, State ID Card, passport, Employer Identification Number (EIN) and/or any related information that is necessary to comply with legal obligations.
Demographic information: such as age, date of birth, gender, and pronouns.
Transaction information: such as purchases made with the Service, transaction history, trading history, and account balances.
Financial information: such as transaction information and account numbers pertaining to financial accounts you choose to link to the Service.
Location information: such as information related to your state, city, or neighborhood.
Device information: such as computer or mobile device operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information associated with IP address, such as city, state or geographic area.
Usage information: such as the pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages and screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
Communications with us and information provided: such as any customer service requests or social media interactions you or your family initiate and other information you or your family choose to provide to us through the Service, such as any images or photographs submitted or posted, or information submitted through the available chat features.
Preferences: such as marketing preferences and inferences about any Service you may be interested in.
We collect personal information from a variety of sources, including:
From you and your family: including identifiers and contact details, demographic information, financial information, location information, communications with us, and preferences.
Automatically, from your and your family’s devices: including device and usage information, some of which we collect via cookies and other technologies as described below.
Social media networks: including information you and your family provide to us and your communications with us on social media channels, such as Facebook, YouTube, TikTok, Twitter, and Instagram, and any demographic information such platforms provide to us.
Other third parties: including information we receive from:
Financial service providers, including Plaid, which allow us to verify you own the bank account you elect to use as a funding source, verify the amount requested is available to fund your Halfmore account, and complete the transfer of funds to your Halfmore account.
Payment service providers, including Astra, which allow us to process transactions, manage payment scheduling, and ensure the secure handling of your financial data.
Cookies and other similar technologies
We use the term “cookies and other similar technologies” to refer to small data files, including cookies, pixel tags, and/or other technologies provided by your browser or associated applications.
Like many digital platforms, Halfmore, our service providers, and advertising partners may collect device information, device and usage information and other personal information automatically using cookies and other similar technologies to help us enable functionality, analytics and online advertising. These technologies include:
Cookies. You can learn more about cookies and how to control them at www.allaboutcookies.org and you can set preferences for which cookies you wish to remove or reject in your browser.
Pixels. We may use pixels (also known as web beacons and clear GIFs) on our Site and in our HTML formatted emails to track the actions of users on our Site and interactions with our emails, such as when an email was opened. Pixels are embedded invisibly in image files within webpages or HTML formatted emails. Most browsers and devices allow you to configure your device to prevent images and any pixels embedded in them from loading.
SDKs. Software Development Kit (SDK) refers to third party computer code incorporated into our websites or mobile applications to enable functions and tracking similar to those enabled by the other technologies described above, including to enable third party analytics and advertising services.
Session Replay. We use services that employ software code to record users’ interactions with the Services in a manner that allows us to watch and analyze visual reconstructions of those user sessions. The replays include users’ clicks, mobile app touches, mouse movements, scrolls, and keystrokes/key touches during those sessions. These replays help us diagnose usability problems and identify areas for improvement.
Chatbot features. The Service provides users with chatbot features to get information and support. The third parties that support these features may access, monitor and record the information you submit to the chat, as well as your device data and usage data described above, to enable the chat and for the other purposes described in this Privacy Policy, including training, quality assurance and service improvement. When you use these features you are not communicating with a human.
You are free to decline optional cookies and similar technologies if permitted by your computer, browser, mobile phone, or other device, although doing so may affect your use of the Service.
Recording and monitoring
When you call us by phone for support or use the Service’s chat features, we and our third-party vendors may monitor and record the conversations for the purposes described in this Privacy Policy, including for quality assurance, training, and service improvement. We and our third-party vendors may also collect your internet and usage information associated with your use of the Service’s chat features for the same purposes. When you use our chatbot features, or interactive voice response features over the telephone, you are not communicating with a human.
2. How We Use Personal Information
We use personal information for the following purposes:
To create, fund, maintain, customize, improve, and secure the Service, or otherwise provide services you request. This includes:
Processing and analyzing account transactions and payments, and notifying you and your family about them;
Providing customer support and delivering Service update notices, answering questions and responding to requests, and otherwise communicating with you and your family;
Testing, personalizing, developing and improving the Service, including for analytics, machine learning, and to create new algorithms or other tools, so we can better cater to your interests;
Providing services or features you request
To market our products and services, including:
Direct marketing, such as sending direct marketing communications as permitted by law, including by email or text messages;
Referrals, such as facilitating, managing and confirming referrals from you, your family, and our business partners; and
Interest-based advertising, such as engaging third-party advertising companies and social media companies to display ads promoting our and other services across the web. We do not use interest-based advertising technologies within our App, including targeting interest-based ads to children under the age of 16 who are logged into our Service.
To maintain the security and integrity of the Service, our technology, assets and business, including:
Detecting, preventing, and investigating fraud, cyberattacks or other unauthorized, unethical or illegal activities;
Evaluating, monitoring and auditing the security of the Service, and troubleshooting and debugging;
Performing identity verification on our own behalf and on behalf of regulated business partners
Enforcing our Terms, including to prevent potential breaches; and
Protecting our, your or others’ rights, privacy, safety, or property (including by making and defending legal claims).
To comply with applicable laws, including responding to law enforcement requests and as required by applicable law, court order, or governmental regulations.
3. How We Share Personal Information
We do not sell personal information. We may share personal information as follows:
Within your family. Information you or your family provide may be accessible to other members of your family through the Service. For example, you and any authorized approver will be able to see the account activity of your child on the Service, and the authorized approver may be able to see certain information about you, such as your name and accounts.
Processing transactions. To process payments and other transactions on the Service, we share information with the person you or a member of your family are paying or from whom you or a member of your family are receiving a payment.
Service Providers. We engage with select service providers who provide services to support our operations such as: open banking interface providers (like Plaid); gather your data from financial institutions (like Plaid); payment processors (including merchant acquirers and automated clearinghouse (ACH) payment processors); insurance providers for mobile phone protection and purchase protection; identity verification services; cloud hosting providers (like Google Cloud ); email/SMS delivery (like Mailjet, Sinch); customer support (like Intercom); EIN creation (like IRS); functionality providers, providers of information technology, marketing, consumer research, analytics, and cybersecurity services; and other service providers pursuant to written agreement with us.
Other Parties. We share personal information when we have reason to believe that disclosing the information is necessary to prevent fraud, damage to person or property, protect and secure our business, assets, user accounts or enforce legal rights or comply with subpoena, court order, legal process or obligations, including as needed to support auditing, compliance, and corporate governance functions. We also share personal information as needed if that information is requested by law enforcement agencies or if we are required to do so by law or court order.
Your network. When you use the Service to engage with individuals outside of your family, those individuals will be able to see your name and/or username, profile photo, and any other information you choose to share.
Advertising Networks and Analytics. We may allow advertising networks to collect information on our Site for the purposes of serving ads that are more relevant. We also work with partners that assist us with ad campaign measurement and analytics on our Site and App.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Successor Entities. We may disclose or transfer your personal information to a successor entity (or its representatives) in the event of a corporate merger, divestiture, consolidation, reorganization, sale of assets or other corporate changes respecting Halfmore (including, in connection with a bankruptcy or similar proceedings), and in connection with due diligence and negotiations relating to any such transactions.
We may also share information if the information has been aggregated, de-identified, or otherwise does not identify you personally, and otherwise with your consent.
4. Your Rights and Choices
Your choices
We provide you and your family with the following choices.
Marketing Preferences. You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, replying “STOP” or “UNSUBSCRIBE” to the SMS messages that we send, or by contacting us using the details provided in the “How Can you Contact US About This Notice?” below. You will then be removed from the marketing lists. However, you may still communicate with you – for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
Update Your Information. You can edit or update personal information in your account by reviewing the account settings and profile across the family of accounts. It is your responsibility to make sure that personal information of everyone in your family is accurate. You should promptly update your and your family’s personal information if it changes or becomes inaccurate.
Change location and motion detection settings. You can change what location you share within the settings of your device. Please note that by changing these settings we may not be able to provide you with our Service.
Closing Account(s) and Deletion of Personal Information. As the primary accountholder, you can close your account and the account of any member of your family within the settings of the App. If you close an account, the account will no longer be accessible, but we may retain personal information from the account to collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations, prevent fraud, enforce the Terms, or take other actions as required or permitted by law.
Opt-Out Rights. There are a number of ways to limit online tracking on our Site, which we have summarized below:
Blocking cookies in your browser. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
Using privacy plug-ins or browsers. You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, downloading and enabling Global Privacy Control, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party cookies/trackers.
Advertising industry opt-out tools. You can also use these opt out options to limit use of your information for interest-based advertising by participating companies:
Digital Advertising Alliance for Websites: outout.aboutads.info
Network Advertising Initiative: optout.networkadvertising.org
Currently, we do not alter our data collection and use practices in response to “Do Not Track” signals. To find out more about “Do Not Track”, please visit http://www.allaboutdnt.com.
Your privacy rights
Where applicable, such as California, the following rights apply to those whose interactions with us are limited to visiting our Site, signing up for newsletters or other email alerts, or otherwise communicating with us. These rights do not apply to the personal information we collect, use, or disclose about consumers who initiate or complete the process of applying for financial products or services because such information is protected by other laws, including the Gramm-Leach-Bliley Act and the California Financial Information Privacy Act. For more information about how we handle this information and your choices, see our Consumer Privacy Disclosure.
Information. You may have the right to obtain information about how we collect, use, and share your personal information. We provide this information within this Privacy Policy.
Access, correction and deletion. You may also have the right to request access to your personal information, to correct personal information that is out of date or inaccurate, or to delete personal information that is no longer needed for a permitted purpose. Where these rights apply, you are entitled to exercise these rights free from discrimination.
Opt out of selling and sharing personal information for targeted advertising. We use cookies and other similar technologies on our Site to help us advertise our Service on other websites or services you visit. We share information we collect on our Site, such as information about the pages you visit and the actions you take on our Site, with advertising networks and analytics partners to support our interest-based advertising, which may qualify as a sale or sharing of personal information, or targeted advertising, under applicable law. You can opt-out of our use or sharing of personal information for these purposes by using our “Do Not Sell or Share My Personal Information” tool in the footer of our Site. We do not have actual knowledge that we have sold or shared the personal information of California residents under the age of 16.
The rights described above are not absolute, and, in certain cases, we may decline your request if limitations on these rights apply or as otherwise permitted by law. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
How to Submit a Request
You may exercise your rights by reaching out to support@halfmore.co.
Identity Verification. We will require you to verify your identity in accordance with applicable laws before we provide a substantive response to the request.
Authorized Agents. California residents can empower an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have a written authorization confirming that authority.
5. Data Retention
We may retain your personal data for as long as it is reasonably needed in order to maintain and expand our relationship and provide you with our Services; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of such data, the potential risk of harm from unauthorized use or disclosure of such data, the purposes for which we process it, and the applicable legal requirements.
6. Security
Our information security program is managed by dedicated information security personnel with commercially reasonable information security measures to protect personal information against loss, misuse, and unauthorized access. These measures include, but are not limited to, data encryption, cyber threat detection, and internal access controls. We regularly have our information security program assessed and validated by independent security audit experts. You and your family are responsible for maintaining the security of your usernames and passwords used to access the Service.
7. Information from Children
At Halfmore, our goal is to help parents plan and manage wealth for their children, and we take our responsibility to your children seriously.
Registration
During the registration process, we ask for your mobile phone number and date of birth, which we use to determine your age and eligibility for the Service. Children under the age of 18 must register for our Service with their parent or guardian as follows:
Children under 13. Parents or guardians must initiate the registration process on behalf of children under the age of 13. We request, via digital consent during the registration process, that you represent that you are the parent or legal guardian of any child under the age of 13 for whom you register an account and that you consent to our collection and use of the child’s personal information in accordance with this Privacy Policy. If a child under 13 initiates the registration process without a parent or guardian the registration session will end and we will inform the child that the child will need a parent or guardian to create an account. In those cases, we delete the personal information from children under 13 until a parent or guardian initiates a new registration.
For those younger than 18, a parent’s mobile phone number is required so that we can provide the parent with information about how to download the App and finish registering an account.
Parental Choices and Controls
You can update or change the personal information of a child at any time through the account settings.
At any time, you can refuse to permit us to collect further personal information of a child by closing that sub-account by calling Halfmore Customer Service at 1-650-613-8088. If you close an account, we will mark the account in our database as “Closed,” but may retain personal information from the account to deactivate the account with our service providers, allow you to reactivate the Halfmore account for some period in the future, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations, prevent fraud, enforce the Terms, or take other actions as required or permitted by law.
If you request that we delete your child’s personal information, we will delete as much information as we are legally permitted. Due to regulatory record keeping obligations, we may be required by law to retain some information associated with a closed account.
Site and Advertising
While we provide a Service for families, our Site is for promotional purposes only and is not intended for children under the age of 13. We do not knowingly collect any information from children under the age of 13 on our Site. If we learn that we have collected personal information from a child under 13 without the consent of the child’s parent or guardian as required by law, we will delete it.
8. Location of Services
We are headquartered in the United States and currently our Service is only intended for residents of the United States.
9. Changes to Privacy Policy
If we make any material changes to this Privacy Policy, we will change the Effective Date above. We encourage you to review this Privacy Policy to stay informed. If we make material changes and we need to provide additional notice, we will notify you via the email specified in your account or through the Service or Site.
10. Contact Us
If you have questions about this Privacy Policy or our information practices, please contact us by email at support@halfmore.co,.
Our mailing address is:
Halfmore, INC.
135 Seale Ave
Palo Alto, CA 94301
11. Notice at Collection
While you should read this Privacy Policy in its entirety, the following summarizes our practices currently and during the past 12 months regarding the categories of personal information that we collect and how we use them.
Collection and disclosure. The list below describes at a high level the personal information we collect by reference to the categories of personal information specified in the CCPA and the categories of third parties to whom we disclose it. The terms in the list refer to the categories of information and third parties detailed above in the sections entitled Types of Information We Collect and How We Share Personal Information. Information you voluntarily provide to us, such as in emails or free form webforms, may contain other categories of personal information (including sensitive personal information) not described below. We may also disclose personal information to the categories of third parties described above in the How We Share Personal Information section of this Privacy Policy.
| How You Use the Services | Personal Information Categories | Primary Purposes of Processing | Primary Recipients (Other than Service Providers) | Can you Limit Sharing? | How Long We Retain Personal Information |
|---|---|---|---|---|---|
| When you browse our Site |
Identifiers, including IP address and online Identifiers. Internet and other electronic network activity information, including automatically collected data, such as device and usage information, and information collected via cookies and similar technologies. Geolocation data (e.g., Geo IP). Inferences drawn from the information above. |
To create, fund, maintain, customize, improve, and secure the Service, or otherwise provide services you request | Analytics providers |
Yes
|
See “Data Retention” |
| When you browse our Site |
Identifiers, including IP address and online Identifiers. Internet and other electronic network activity information, including automatically collected data, such as device and usage information, and information collected via cookies and similar technologies. Geolocation data (e.g., Geo IP). Inferences drawn from the information above. |
To market our products and services, including for interes t-based advertising | Advertising networks |
Yes
|
Se e “Data Retention” |
| When you browse sign up for newsletters or other email alerts, or otherwise communicate with us |
Identifiers, including name, email, IP address, and online identifiers. Internet and other electronic network activity information, including automatically collected data, such as device and usage information, and information collected via cookies and similar technologies. Commercial information, including your transaction history. Geolocation data (e.g., Geo IP). Any other information you choose to provide to us in your communications. Inferences drawn from the information above. |
To create, fund, maintain, customize, improve, and secure the Service, or otherwise provide services you request | Analytics providers |
Analytics providers Yes
|
See “Data Retention” |
| When you browse sign up for newsletters or other email alerts, or otherwise communicate with us |
Identifiers, including name, email, IP address, and online identifiers. Internet and other electronic network activity information, including automatically collected data, such as device and usage information, and information collected via cookies and similar technologies. Commercial information, including your transaction history. Geolocation data (e.g., Geo IP). Any other information you choose to provide to us in your communications. Inferences drawn from the information above. |
To market our products and services, including for direct marketing | Advertising networks |
Yes
|
Se e “Data Retention” |
| When you create an account or otherwise apply for the Services |
Identifiers, including name, email, username, official identification information (e.g., SSN and driver’s license), IP address, and online Identifiers. Personal information described in Section 1798.80(e) of the California Civil Code. Protected classifications, including demographic information such as age, date of birth, gender, and pronouns. Commercial information, including transaction information and financial information. Internet and other electronic network activity information, including automatically collected data, such as device and usage information, and information collected via cookies and similar technologies. Geolocation data (e.g., Geo IP). Inferences drawn from the information above. |
To create, fund, maintain, customize, improve, and secure the Service, or otherwise provide services you request | Other members of your family | No | Se e “Data Retention” |
| When you create an account or otherwise apply for the Services |
Identifiers, including name, email, username, official identification information (e.g., SSN and driver’s license), IP address, and online Identifiers. Personal information described in Section 1798.80(e) of the California Civil Code. Protected classifications, including demographic information such as age, date of birth, gender, and pronouns. Commercial information, including transaction information and financial information. Internet and other electronic network activity information, including automatically collected data, such as device and usage information, and information collected via cookies and similar technologies. Geolocation data (e.g., Geo IP). Inferences drawn from the information above. |
To market our products and services, including for direct marketing | N/A | To opt out of direct marketing, see “Your Rights and Choices” | Se e “Data Retention” |
| When you use the App or the Platform, or otherwise use the Services |
Identifiers, including name, email, username, official identification information (e.g., SSN and driver’s license), IP address, and online Identifiers. Personal information described in Section 1798.80(e) of the California Civil Code. Protected classifications, including demographic information such as age, date of birth, gender, and pronouns. Commercial information, including transaction information and financial information. Internet and other electronic network activity information, including automatically collected data, such as device and usage information, and information collected via cookies and similar technologies. Geolocation data (e.g., Geo IP). Inferences drawn from the information above. |
To create, fund, maintain, customize, improve, and secure the Service, or otherwise provide services you request |
Processing transactions Business partners Other members of your family |
No | Se e “Data Retention” |
California Residents
California Civil Code Section 1798.83, also known as the "Shine The Light" law permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).
CCPA Privacy Notice
This section applies only to California residents. Under the California Consumer Privacy Act (CCPA), you have the rights listed below.
The California Code of Regulations defines a "resident's" as:
(1) every individual who is in the State of California for other than a temporary or transitory purpose and (2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose
All other individuals are defined as "non-residents."
If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.
Your rights with respect to your personal data
Right to request deletion of the data — Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.
Right to be informed — Request to know
Depending on the circumstances, you have a right to know:
the categories of personal information that we collect;
the purposes for which the collected personal information is used;
whether we sell or share personal information to third parties;
the categories of personal information that we sold, shared, or disclosed for a business purpose;
the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
the business or commercial purpose for collecting, selling, or sharing personal information; and
the specific pieces of personal information we collected about you.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Right to Limit Use and Disclosure of Sensitive Personal Information
If the business collects any of the following:
social security information, drivers' licenses, state ID cards, passport numbers
account login information
credit card numbers, financial account information, or credentials allowing access to such accounts
precise geolocation
racial or ethnic origin, religious or philosophical beliefs, union membership
the contents of email and text, unless the business is the intended recipient of the communication
genetic data, biometric data, and health data
data concerning sexual orientation and sex life
you have the right to direct that business to limit its use of your sensitive personal information to that use which is necessary to perform the Services.
Once a business receives your request, they are no longer allowed to use or disclose your sensitive personal information for any other purpose unless you provide consent for the use or disclosure of sensitive personal information for additional purposes.
Please note that sensitive personal information that is collected or processed without the purpose of inferring characteristics about a consumer is not covered by this right, as well as the publicly available information.
To exercise your right to limit use and disclosure of sensitive personal information, please email support@halfmore.co or visit: support@halfmore.co.
Verification process
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
Other privacy rights
You may object to the processing of your personal information.
You may request correction of your personal data if it is incorrect or no longer relevant or ask to restrict the processing of the information.
You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
You can opt out from the selling or sharing of your personal information by disabling cookies in Cookie Preference Settings and clicking on the Do Not Sell or Share My Personal Information link on our homepage.
To exercise these rights, you can contact us by visiting support@halfmore.co, by email at support@halfmore.com, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.
Colorado Residents
This section applies only to Colorado residents. Under the Colorado Privacy Act (CPA), you have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.
Right to be informed whether or not we are processing your personal data
Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")
We sell personal data to third parties or process personal data for targeted advertising. You can opt out from the selling of your personal data, targeted advertising, or profiling by disabling cookies in Cookie Preference Settings. To submit a request to exercise any of the other rights described above, please email support@halfmore.co or visit support@halfmore.co.
If we decline to take action regarding your request and you wish to appeal our decision, please email us at support@halfmore.co. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.
Connecticut Residents
This section applies only to Connecticut residents. Under the Connecticut Data Privacy Act (CTDPA), you have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.
Right to be informed whether or not we are processing your personal data
Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")
We sell personal data to third parties or process personal data for targeted advertising. You can opt out from the selling of your personal data, targeted advertising, or profiling by disabling cookies in Cookie Preference Settings. To submit a request to exercise any of the other rights described above, please email support@halfmore.co or visit support@halfmore.co.
If we decline to take action regarding your request and you wish to appeal our decision, please email us at support@halfmore.co. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.
Utah Residents
This section applies only to Utah residents. Under the Utah Consumer Privacy Act (UCPA), you have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.
Right to be informed whether or not we are processing your personal data
Right to access your personal data
Right to request deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
Right to opt out of the processing of your personal data if it is used for targeted advertising or the sale of personal data
We sell personal data to third parties or process personal data for targeted advertising. You can opt out from the selling of your personal data or targeted advertising by disabling cookies in Cookie Preference Settings. To submit a request to exercise any of the other rights described above, please email support@halfmore.co or visit support@halfmore.co.
Virginia Residents
Under the Virginia Consumer Data Protection Act (VCDPA):
"Consumer" means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.
"Personal data" means any information that is linked or reasonably linkable to an identified or identifiable natural person. "Personal data" does not include de-identified data or publicly available information.
"Sale of personal data" means the exchange of personal data for monetary consideration.
If this definition of "consumer" applies to you, we must adhere to certain rights and obligations regarding your personal data.
Your rights with respect to your personal data
Right to be informed whether or not we are processing your personal data
Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")
We sell personal data to third parties or process personal data for targeted advertising. Please see the following section to find out how you can opt out from further selling or sharing of your personal data for targeted advertising or profiling purposes.
Exercise your rights provided under the Virginia VCDPA
You can opt out from the selling of your personal data, targeted advertising, or profiling by disabling cookies in Cookie Preference Settings. You may contact us by email at support@halfmore.co or visit halfmore.co.
If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Verification process
We may request that you provide additional information reasonably necessary to verify you and your consumer's request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.
Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.
Right to appeal
If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at support@halfmore.co. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney General to seek a resolution.