Halo Mobile (hereinafter “Halo Mobile”, “we”, “us” or “our”) is the Halo Mobile company acting as the data controller in connection with any personal data collected or received by Halo Mobile arising from your use of any Halo Mobile products, services, applications, websites (including any e-commerce stores) and contact centres made available to you. Halo Mobile is responsible for ensuring that the processing of personal data complies with this Policy.
Please note that other companies in the Halo Mobile are responsible for their respective personal data processing activities in connection with other Halo Mobile products and services. These Halo Mobile companies may have their own privacy policies, which are generally available from the relevant websites for those products and services. Click on the relevant section heading to expand that section:
- Personal data that we collect
- How Halo Mobile uses your personal data about you
- Sharing personal data about you
- Marketing communications
- Security of your personal data
- Cookies & Tracking
- Access to your personal data and your rights
- Contact us
1. Personal data that we collect
What personal data does Halo Mobile collect and where does this personal data come from?
Halo Mobile may collect personal data about you in several different ways which are explained below. Please take care when submitting personal data to us, particularly when completing free text fields or uploading content, documents and other materials. Some of our services are automated and we may not recognise that you have accidentally provided us with incorrect or sensitive personal data.You can always contact us to correct incorrect data (see section 8 below).
A. Personal data that you provide us
Whenever you interact with Halo Mobile, you may be asked to provide us with personal data relating to you. For example:
- Some of our applications or services require you to create an account. When creating your account(s), we may ask you to provide a range of personal data, such as your name, date of birth, location, contact details, applicable device ID(s) relating to the devices you are using to access and receive particular applications and services, interests and account and marketing preferences and your current mobile network operator
- When you purchase, register, send for repair or return one of our products via any one of our authorised channels, we may ask you to provide personal data such as your contact details, applicable device ID s) relating to your particular product(s), delivery date and place of purchase and payment information
- When you contact our customer service centres for assistance (by any means of communication including written communications or via our website(s), support forums, telephone, email, SMS or our social media channels), we may record customer service calls and keep personal data about the particular communication, where this is permitted by applicable law. The personal data collected may include your name, the product(s) you bought, the reason why you contacted us, applicable device ID(s) relating to your particular product(s) and the advice we gave you so we can track the resolution of any customer service issues and for customer service training purposes
- When you join and/or participate in one of our loyalty programmes, we may collect personal data relating to your use of the loyalty programme and the rewards you claim
- When you enter our retail or repair facilities, your image may be recorded by our security cameras
- When you visit us at a public event, such as a trade show or exhibition or participate in one of our surveys, competitions or prize draws, we may ask for personal data, such as your business card, name, contact details, interests and marketing preferences
- When you use our applications and services or other platforms, we may receive content that you choose to upload, such as product reviews, comments, photos and forum posts, or details of your interests and preferences that you choose to tell us about when, for example, selecting the services that you wish to receive. Further, use of applications with voice recognition may require us to access certain personal data on your device and also record your voice
- When you specify interests and preferences during setup of an internet-enabled product or service
B. Personal data we collect when you use our websites, products, services and applications
In order to improve and provide a better user experience, some of our websites, internet-enabled products and applications and services provide Halo Mobile with personal data about your use of them, including:
- Details of your usage patterns, content(including any advertisements) that you view and interact with including personal data on the services and applications you are using on-device to personalise services to your specific needs. For example, when you use our websites, we may collect personal data about your visit, such as your browser software, which pages you view and which items you ‘clicked’ on or added to your shopping basket
- Service, product or server logs which hold technical personal data about your use of our service, product or websites, such as your IP address, device ID(s), domain, device and application settings, errors and hardware activity. We may use your IP address to determine your location/country of origin
- Device Information such as your device ID(s), including personal data about where your device is physically located. For example, when you are using a geo-location service or application and you have given consent to your location being shared. Your device ID is also collected, when you download a software update
- With your explicit consent, personal data related to your physical behaviour, health and biometric data such as voice authentication data, fingerprint or facial characteristics or features
- Voice recognition and utterance data when using a voice command application. Such data may be sent to our technology partners
C. Personal data we collect in relation to social networks
If you use any of our social network features, pages or plug-ins, or you use our products or services that allow interaction with social networks, we may receive personal data relating to such use. For instance:
- If you log in to one of our websites, applications or services using your social network account, we may receive basic details from your social network profile. The basic details we receive may depend on your social network account privacy settings. Typically; however, they might include your social network ID, name, profile picture, gender and locale. We may also receive additional personal data from your profile if you give us permission to access it
- If you click on a ‘like’, ‘+1’, ‘tweet’ or similar button on one of our websites or services, we may record the fact that you have done so. In addition, the content that you are viewing may be posted to your social network profile or feed. We may receive personal data about further interactions with this posted content (for example, if your contacts click on a link in the posted content), which we may associate with the details that we store about you
- If you ‘like’, ‘+1’ or similar one of our pages on a social network site, we may receive personal data about your social network profile, depending on your social network account privacy settings
D. Personal data we collect from other sources
We may also collect personal data from publicly available sources and third parties, including:
- When you seek to make a purchase from us, we may carry out credit and financial checks to ensure payment is not made fraudulently and that you have a suitable credit rating
- If you purchase products or services from a HaloMobile, mobile network operator or other retailer, we may receive certain information about your purchase from that retailer, such as your IMEI code, contact information and time of purchase
2. How Halo Mobile uses your personal data
How does Halo Mobile use your personal data and what is the legal basis for processing this personal data?
Halo Mobile uses the personal data you provide or which we collect mainly for these purposes:
A. Service provision
- When we are using personal data to offer our products and services to you, the processing is based on a contract between you and Halo Mobile. We may use personal data to:
- provide you with a product or service you have requested, including any back-up and restore service
- provide you with software updates which may contain critical security and functionality patches that make your device more secure and protect the personal data on the device
- facilitate and process your searches and requests for information when you contact us about Halo Mobile and its products and services
- provide our checkout assistance service. When you use our applications and services including any online e-commerce stores, such as the Xperia™ store, details of any products that you seek to purchase and your email address may be collected as you fill in the checkout form. If you do not complete your purchase, we and/or our authorised fulfilment partner(s) may contact you using these details to offer our assistance (in case, for instance, you were experiencing technical difficulties that prevented you from completing a transaction). This is an optional service. You can choose not to receive our checkout assistance emails at any time by following the link at the bottom of each assistance email
B. Product and service development
- We work constantly to make our products and services better. We base this processing on our legitimate interests to develop our products and services, to better meet customer requirements, to ensure quality, to develop identity management, and to strengthen network and information security. We may use personal data to:
- create and manage customer database(s) of our users, including basic account information (such as your name, date of birth, address, contact details), applicable device ID(s) (relating to the devices you are using to access and receive particular applications and services), related product or service usage information and customer preference information as provided by you from time to time. As part of our on-going customer relationship management activities, we may consolidate several databases into one or otherwise link separate databases to more effectively manage your accounts
- ask for your opinions on Halo Mobile products and services and conduct product surveys
- improve and enhance existing Halo Mobile products, services and applications and develop new offerings, recommendations, advertisements and other communications and learn more about customers’ shopping preferences in general
C. Marketing and advertisement
- When we use personal data for marketing purposes, we base the processing on our legitimate interests to know our customers, keep you up-to-date about Halo Mobile's latest products and services and to personalise your customer experience. In some cases, we base marketing on your prior consent, e.g. for sending marketing messages. We may use the personal data we collect and/or any personal data about you which is shared with us for marketing purposes, e.g. from other Halo Mobile companies whose products, applications and services you also use. In particular, we may:
- provide you with product and service updates, newsletters and other communications about existing and/or new products and services by post, email, telephone, in-device messaging, text message (SMS) or other means, if you have consented or if we are otherwise permitted to do so under applicable law
- ensure that you benefit from any relevant special offer or promotion
- hold prize draws, contests and other promotional offers
- create user group profiles or segment data and to otherwise create anonymous, aggregated statistics about the use of our websites, products, services and loyalty programmes, which we may share with third parties and/or make available to the public
- use product reviews, comments or content you have uploaded and made publicly visible in our websites or services to link to, publish or publicise elsewhere, including in our own marketing. Each time you create or reply to a post or thread on a website forum from Halo Mobile, in addition to providing this forum service, we may also record the forum name and the time and date of your post or thread with your account details. We do this to better understand the ‘typical users’ of our forums and to select or tailor our marketing communications to reflect your forum activity. We do not use the actual content of your forum posts or threads for purposes of sending marketing communications
D. Fraud prevention and investigation
- Halo Mobile may use personal data to prevent fraud and to investigate violations or our policies. For example, we may use your device information such as your device ID(s) to ensure that any vouchers or discounts relating to any promotions or campaigns are not being redeemed fraudulently, and to check that a payment is not made fraudulently. In this case, we base the processing of personal data on our legitimate interest to prevent fraud and to provide benefits only to our customers. We may also use personal data to comply with applicable laws, regulations and court orders and to comply with valid legal information requests from such bodies. We may use your personal data to enforce or defend the legal rights of any Halo Mobile company or the terms and conditions of any Halo Mobile product or service. In this case, we base the processing on a legal obligation to which Halo Mobile is subject or on our legitimate interest to defend our legal rights.
E. Other purposes
- We may use your personal data for other purposes:
- for staff training and quality assurance purposes, particularly in relation to our customer relations staff at our call, email and other customer support centres. We base this processing on our legitimate interest to ensure the quality and efficiency of our customer service
- if we consider employing you if you contact us via one of Halo Mobile’s job application websites. This processing is based on your consent and we provide additional information about data processing in recruitment on our recruitment websites
3. Sharing personal data about you
How is personal data about you shared within Halo Mobile and with 3rd parties?
A. Sharing of personal data by Halo Mobile
In general, Halo Mobile does not disclose personal data about you to third parties without your consent. However, there are exceptions:
- Our service providers
We may use other Halo Mobile companies and/or third party service providers to provide certain data processing services for us (acting as our authorised data processors). Examples of authorised data processors could include billing and fulfilment partners, data analytics providers who process personal data on our behalf for the purposes outlined above. For example, we may use the services of third parties to personalise content, fulfil orders, deliver packages, send postal mail and emails, send text messages (SMS), provide marketing assistance, process credit card payments, provide fraud checking services, provide back-up services and provide customer services.
B. Sharing of personal data provided by you
A number of our applications and services allow you to upload and share messages, photos, video and other content and links with others and/or create a publicly accessible profile for your account. For example:
- The communities and forums area (where applicable) of our websites allows you to post comments (with your account name), which are visible to other users of that service
Other services allow you to share a link which if clicked on may allow the recipient to access your uploaded content
4. Marketing communications and how to change your preferences
How does Halo Mobile use your personal data to send you communications and how can you change your marketing preferences?
- Marketing communications
When you provide us with contact details, such as when you purchase a product, contact our customer support call centres or create an account for one of our services, you may be given the opportunity to opt-in to (or in certain cases where applicable law allows, opt-out of) receiving various newsletters and other communications from Halo Mobile and/or other Halo Mobile companies. These communications may include, for instance, details about the latest Halo Mobile products and services, including upgrades and special offers in which you may be interested. You can change your marketing communication preferences at any time:
a. If you would like to unsubscribe from an email sent to you, follow the ‘unsubscribe’ link and/or instructions placed (typically) at the bottom of the email. But note that:
b. If you use more than one email address to shop or contact Halo Mobile, you will need to unsubscribe separately for each email address
c. This method will only unsubscribe you for emails. You will need to separately unsubscribe for other types of marketing communications you receive
d. If you have registered with any applications and services provided by Halo Mobile and have your own account, you may log in and amend your marketing communication preferences in the account settings page or area
e. For managing other types of communication, such as push-notifications in apps, please go the app specific settings to make the changes
- Customer profiles
As described above, we may create user group profiles or segment data to better understand our customers and to otherwise create anonymous, aggregated statistics about the use of our websites, products, services and loyalty programmes. This processing is based on our legitimate interest to understand our customers better and to provide you with products and services that are better suited to your needs. We may also link or combine personal data to provide you with better personalised services, content, marketing and adverts. When we use customer profiles for direct marketing purposes, you have the right to object to this kind of personal data processing at any time you wish to do so.
- Important information and service messages
Occasionally, we may send you important information (including via text message, push notifications, email) regarding essential software updates, changes to applicable terms and conditions and/or other communications or notifications as may be required to fulfil our legal and contractual obligations to provide warranty or after sales repair services. These important product and/or service communications are not affected by your marketing communication preferences.
5. Security of your personal data
How does Halo Mobile protect your personal data and what can you do to protect yourself?
- What we do to protect your personal data
While Halo Mobile can’t guarantee that unauthorised access will never occur, rest assured that Halo Mobile takes great care in maintaining the security of your personal data to prevent unauthorised access to it, through the use of appropriate technology and internal procedures. We take a number of steps to protect your personal data from unauthorised access, use or alteration and unlawful destruction and disclosure, including where appropriate:
- Using Secure Sockets Layer (SSL) encryption when collecting or transferring sensitive personal data, such as credit card details (SSL encryption is designed to make the data unreadable by anyone but us)
- Limiting access to the personal data we collect about you (for instance, only those of our personnel who need your personal data to carry out our business activities are allowed access)
- Putting in place physical, electronic and procedural safeguards in line with industry standards
- What you should do to protect your personal data
As general best practice on the internet, it is recommended that individuals take great care with user accounts, and follow some basic rules:
- Do not use trivial passwords (such as single dictionary words)
- Do not use the same password for multiple accounts
- Do use very long passwords (at least 10 characters, but preferably much longer)
- Do use passwords which contain a combination of upper and lower case letters, numbers and special characters e.g. $%^& etc.
- Do keep passwords securely (never written down, or shared with anyone) and changed periodically
6. Cookies & Tracking
What are cookies and how are they used?
Our websites use industry-wide technologies, such as “cookies”, to collect information about the use of our websites and email communications. For instance, these technologies may tell us which visitors clicked on key elements (such as links or graphics) on a website or email and recognise your browser the next time you visit our websites. Cookies allow us to customise your experience to better match your interests and preferences, or to simply facilitate your signing in to use the services. Most browsers will allow you to erase cookies from your computer hard drive, block acceptance of cookies or receive a warning before a cookie is stored. However, if you block or erase cookies, we may not be able to restore any preferences or customisation settings you have previously specified, and our ability to personalise your online experience would be limited. Please refer to your browser instructions to learn more about these functions.
7. Access to your personal data and your rights
How can you access your personal data and what are your rights?
8. Contact us
How can you contact Halo Mobile about your personal data?
If you need further assistance or would like to make a comment, please Contact Us online.