Privacy Policy

Halo ("we", "us", "our") is committed to protecting your privacy. This policy explains what personal data we collect, why we collect it, and how we use and protect it. It applies to the Halo website (myhaloapp.co.uk) and the Halo iOS application.

Data controller: Marie Jehane Juganaikloo (trading as Jehane Harding), United Kingdom.
Correspondence address: Fairway House, Links Business, Fortran Rd, St. Mellons, Cardiff, CF3 0LT, United Kingdom
Email: hello@myhaloapp.co.uk

We are the data controller for the purposes of UK GDPR, the Data Protection Act 2018, and the Data (Use and Access) Act 2025.

1. What data we collect

On our website:

• We use Cloudflare Web Analytics to understand site traffic (e.g. page views, visit counts). This is a cookieless, privacy-friendly analytics service, so it does not use tracking cookies and does not track you across other websites.

In the Halo app:

• Information you enter about your pet: name, medications, dosages, appointment details, weight and breathing rate readings, and notes
• Photos you choose to upload of your pet
• Contact information you add to your Carer's Pack, such as vet details and emergency contacts

All data entered in the app is stored on your device and backed up to your own private iCloud account, so it can follow you if you switch devices or reinstall. We do not collect personal health data about you, and we do not transmit pet health data to our own servers, we have no access to it ourselves.

2. How we use your data

• To operate the Halo app and website
• To send occasional product updates under legitimate interests (UK GDPR Article 6(1)(f)). You may opt out at any time by contacting us directly.
• To improve and develop Halo based on aggregated, anonymised usage patterns
• To comply with legal obligations

3. Legal basis for processing

Under UK GDPR Article 6, we process your data on the following bases:

• Consent (Article 6(1)(a)): when you accept optional cookies
• Legitimate interests (Article 6(1)(f)): to operate, maintain, and improve our services, where your interests and rights do not override ours
• Legal obligation (Article 6(1)(c)): where required by law, including HMRC record-keeping requirements

4. Data storage and security

Pet health data entered in the Halo app is stored on your device and synced to your own private iCloud account using Apple's on-device and iCloud storage. It is not transmitted to Halo's own servers, and Halo has no access to it. If you delete the app, locally stored data is removed; your iCloud copy is controlled by your own Apple Account and iCloud settings.

We have a documented procedure for responding to data breaches. In the event of a reportable breach, we will notify the ICO within 72 hours and affected individuals without undue delay.

5. How long we keep your data

6. Sharing your data

We do not sell your personal data. We do not share your data with third-party advertisers. We may share data with:

• Apple Inc.: the Halo app runs on Apple's iOS platform. App data is stored using Apple's on-device frameworks and, to keep your data available across your own devices, is synced through your own private iCloud account. Apple's privacy policy applies to Apple's own services. Halo has no account system, no server, and no access to your data at any point, whether on-device or in your iCloud.
• Authorities: where required to do so by law.

7. International data transfers

Where personal data is transferred outside the UK, we ensure it is protected by appropriate safeguards, including the UK International Data Transfer Agreement (UK IDTA) or Standard Contractual Clauses. Apple Inc. is based in the United States; transfers to Apple are covered by the UK extension to the EU-US Data Privacy Framework.

8. Your rights

Under UK GDPR, you have the right to:

• Access: request a copy of the personal data we hold about you (Article 15)
• Rectification: request correction of inaccurate data (Article 16)
• Erasure: request deletion of your data, subject to legal retention requirements (Article 17)
• Restriction: request that we limit how we process your data (Article 18)
• Portability: request your data in a structured, machine-readable format (Article 20)
• Object: object to processing based on legitimate interests, including direct marketing (Article 21)
• Withdraw consent: at any time where processing is based on consent (Article 7(3))
• No automated decisions: not to be subject to solely automated decision-making that significantly affects you (Article 22)

To exercise any of these rights, contact us at hello@myhaloapp.co.uk. We will respond within 30 days, free of charge.

9. Complaints

If you are unhappy with how we handle your data, you have the right to lodge a complaint with the UK Information Commissioner's Office:

10. Cookies

We use Cloudflare Web Analytics on this website, which is cookieless and does not track individuals across sites. We do not use tracking cookies. No cookie consent is required.

11. Children

Halo is not directed at children under 13. We do not knowingly collect personal data from under-13s (or under-16s within the scope of the ICO Children's Code). If you believe a child has provided us with personal data, contact us and we will delete it promptly.

12. Changes to this policy

We may update this Privacy Policy from time to time. The date at the top of this page always reflects the most recent version. Changes will not apply retroactively.

13. Contact us

For any questions about this policy:
hello@myhaloapp.co.uk
Fairway House, Links Business, Fortran Rd, St. Mellons, Cardiff, CF3 0LT, United Kingdom

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