Privacy Policy

==============

Last updated: January 10, 2022

This Privacy Policy describes Our policies and procedures on the collection,

use and disclosure of Your information when You use the Service and tells You

about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the

Service, You agree to the collection and use of information in accordance with

this Privacy Policy.

Interpretation and Definitions

==============================

Interpretation

--------------

The words of which the initial letter is capitalized have meanings defined

under the following conditions. The following definitions shall have the same

meaning regardless of whether they appear in singular or in plural.

Definitions

-----------

For the purposes of this Privacy Policy:

* Account means a unique account created for You to access our Service or

parts of our Service.

* Business , for the purpose of the CCPA (California Consumer Privacy Act),

refers to the Company as the legal entity that collects Consumers'

personal information and determines the purposes and means of the

processing of Consumers' personal information, or on behalf of which such

information is collected and that alone, or jointly with others,

determines the purposes and means of the processing of consumers' personal

information, that does business in the State of California.

* Company (referred to as either "the Company", "We", "Us" or "Our" in this

Agreement) refers to HAL Collective Inc, 651 Broad Street, Suite 206,

Middleton 19709, Delaware, USA.

For the purpose of the GDPR, the Company is the Data Controller.

* Consumer , for the purpose of the CCPA (California Consumer Privacy Act),

means a natural person who is a California resident. A resident, as

defined in the law, includes (1) every individual who is in the USA for

other than a temporary or transitory purpose, and (2) every individual who

is domiciled in the USA who is outside the USA for a temporary or

transitory purpose.

* Cookies are small files that are placed on Your computer, mobile device or

any other device by a website, containing the details of Your browsing

history on that website among its many uses.

* Country refers to: Delaware, United States

* Data Controller , for the purposes of the GDPR (General Data Protection

Regulation), refers to the Company as the legal person which alone or

jointly with others determines the purposes and means of the processing of

Personal Data.

* Device means any device that can access the Service such as a computer, a

cellphone or a digital tablet.

* Do Not Track (DNT) is a concept that has been promoted by US regulatory

authorities, in particular the U.S. Federal Trade Commission (FTC), for

the Internet industry to develop and implement a mechanism for allowing

internet users to control the tracking of their online activities across

websites.

* Facebook Fan Page is a public profile named HAL specifically created by

the Company on the Facebook social network, accessible from

<https://www.facebook.com/HALxyz/>

* Personal Data is any information that relates to an identified or

identifiable individual.

For the purposes of GDPR, Personal Data means any information relating to

You such as a name, an identification number, location data, online

identifier or to one or more factors specific to the physical,

physiological, genetic, mental, economic, cultural or social identity.

For the purposes of the CCPA, Personal Data means any information that

identifies, relates to, describes or is capable of being associated with,

or could reasonably be linked, directly or indirectly, with You.

* Sale , for the purpose of the CCPA (California Consumer Privacy Act),

means selling, renting, releasing, disclosing, disseminating, making

available, transferring, or otherwise communicating orally, in writing, or

by electronic or other means, a Consumer's personal information to another

business or a third party for monetary or other valuable consideration.

* Service refers to the Website.

* Service Provider means any natural or legal person who processes the data

on behalf of the Company. It refers to third-party companies or

individuals employed by the Company to facilitate the Service, to provide

the Service on behalf of the Company, to perform services related to the

Service or to assist the Company in analyzing how the Service is used. For

the purpose of the GDPR, Service Providers are considered Data Processors.

* Third-party Social Media Service refers to any website or any social

network website through which a User can log in or create an account to

use the Service.

* Usage Data refers to data collected automatically, either generated by the

use of the Service or from the Service infrastructure itself (for example,

the duration of a page visit).

* Website refers to HAL, accessible from <http://www.hal.xyz>

* You means the individual accessing or using the Service, or the company,

or other legal entity on behalf of which such individual is accessing or

using the Service, as applicable.

Under GDPR (General Data Protection Regulation), You can be referred to as

the Data Subject or as the User as you are the individual using the

Service.

Collecting and Using Your Personal Data

=======================================

Types of Data Collected

-----------------------

Personal Data

~~~~~~~~~~~~~

While using Our Service, We may ask You to provide Us with certain personally

identifiable information that can be used to contact or identify You.

Personally identifiable information may include, but is not limited to:

* Email address

* First name and last name

* Usage Data

Usage Data

~~~~~~~~~~

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol

address (e.g. IP address), browser type, browser version, the pages of our

Service that You visit, the time and date of Your visit, the time spent on

those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect

certain information automatically, including, but not limited to, the type of

mobile device You use, Your mobile device unique ID, the IP address of Your

mobile device, Your mobile operating system, the type of mobile Internet

browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our

Service or when You access the Service by or through a mobile device.

Information from Third-Party Social Media Services

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

The Company allows You to create an account and log in to use the Service

through the following Third-party Social Media Services:

* Google

* Facebook

* Twitter

If You decide to register through or otherwise grant us access to a Third-

Party Social Media Service, We may collect Personal data that is already

associated with Your Third-Party Social Media Service's account, such as Your

name, Your email address, Your activities or Your contact list associated with

that account.

You may also have the option of sharing additional information with the

Company through Your Third-Party Social Media Service's account. If You choose

to provide such information and Personal Data, during registration or

otherwise, You are giving the Company permission to use, share, and store it

in a manner consistent with this Privacy Policy.

Tracking Technologies and Cookies

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

We use Cookies and similar tracking technologies to track the activity on Our

Service and store certain information. Tracking technologies used are beacons,

tags, and scripts to collect and track information and to improve and analyze

Our Service. The technologies We use may include:

* Cookies or Browser Cookies. A cookie is a small file placed on Your

Device. You can instruct Your browser to refuse all Cookies or to indicate

when a Cookie is being sent. However, if You do not accept Cookies, You

may not be able to use some parts of our Service. Unless you have adjusted

Your browser setting so that it will refuse Cookies, our Service may use

Cookies.

* Flash Cookies. Certain features of our Service may use local stored

objects (or Flash Cookies) to collect and store information about Your

preferences or Your activity on our Service. Flash Cookies are not managed

by the same browser settings as those used for Browser Cookies. For more

information on how You can delete Flash Cookies, please read "Where can I

change the settings for disabling, or deleting local shared objects?"

available at <https://helpx.adobe.com/flash-player/kb/disable-local-

shared-objects-

flash.html#main_Where_can_I_change_the_settings_for_disabling__or_deleting_local_shared_objects_>

* Web Beacons. Certain sections of our Service and our emails may contain

small electronic files known as web beacons (also referred to as clear

gifs, pixel tags, and single-pixel gifs) that permit the Company, for

example, to count users who have visited those pages or opened an email

and for other related website statistics (for example, recording the

popularity of a certain section and verifying system and server

integrity).

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on

Your personal computer or mobile device when You go offline, while Session

Cookies are deleted as soon as You close Your web browser. Learn more about

cookies: [Cookies by PrivacyPolicies

Generator](https://www.privacypolicies.com/blog/privacy-policy-

template/#Use_Of_Cookies_Log_Files_And_Tracking).

We use both Session and Persistent Cookies for the purposes set out below:

* Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential to provide You with services

available through the Website and to enable You to use some of its

features. They help to authenticate users and prevent fraudulent use of

user accounts. Without these Cookies, the services that You have asked for

cannot be provided, and We only use these Cookies to provide You with

those services.

* Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies identify if users have accepted the use of cookies

on the Website.

* Functionality Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies allow us to remember choices You make when You use

the Website, such as remembering your login details or language

preference. The purpose of these Cookies is to provide You with a more

personal experience and to avoid You having to re-enter your preferences

every time You use the Website.

* Tracking and Performance Cookies

Type: Persistent Cookies

Administered by: Third-Parties

Purpose: These Cookies are used to track information about traffic to the

Website and how users use the Website. The information gathered via these

Cookies may directly or indirectly identify you as an individual visitor.

This is because the information collected is typically linked to a

pseudonymous identifier associated with the device you use to access the

Website. We may also use these Cookies to test new pages, features or new

functionality of the Website to see how our users react to them.

For more information about the cookies we use and your choices regarding

cookies, please visit our Cookies Policy or the Cookies section of our Privacy

Policy.

Use of Your Personal Data

-------------------------

The Company may use Personal Data for the following purposes:

* To provide and maintain our Service , including to monitor the usage of

our Service.

* To manage Your Account: to manage Your registration as a user of the

Service. The Personal Data You provide can give You access to different

functionalities of the Service that are available to You as a registered

user.

* For the performance of a contract: the development, compliance and

undertaking of the purchase contract for the products, items or services

You have purchased or of any other contract with Us through the Service.

* To contact You: To contact You by email, telephone calls, SMS, or other

equivalent forms of electronic communication, such as a mobile

application's push notifications regarding updates or informative

communications related to the functionalities, products or contracted

services, including the security updates, when necessary or reasonable for

their implementation.

* To provide You with news, special offers and general information about

other goods, services and events which we offer that are similar to those

that you have already purchased or enquired about unless You have opted

not to receive such information.

* To manage Your requests: To attend and manage Your requests to Us.

* To deliver targeted advertising to You : We may use Your information to

develop and display content and advertising (and work with third-party

vendors who do so) tailored to Your interests and/or location and to

measure its effectiveness.

* For business transfers: We may use Your information to evaluate or conduct

a merger, divestiture, restructuring, reorganization, dissolution, or

other sale or transfer of some or all of Our assets, whether as a going

concern or as part of bankruptcy, liquidation, or similar proceeding, in

which Personal Data held by Us about our Service users is among the assets

transferred.

* For other purposes : We may use Your information for other purposes, such

as data analysis, identifying usage trends, determining the effectiveness

of our promotional campaigns and to evaluate and improve our Service,

products, services, marketing and your experience.

We may share Your personal information in the following situations:

* With Service Providers: We may share Your personal information with

Service Providers to monitor and analyze the use of our Service, to

advertise on third party websites to You after You visited our Service,

for payment processing, to contact You.

* For business transfers: We may share or transfer Your personal information

in connection with, or during negotiations of, any merger, sale of Company

assets, financing, or acquisition of all or a portion of Our business to

another company.

* With Affiliates: We may share Your information with Our affiliates, in

which case we will require those affiliates to honor this Privacy Policy.

Affiliates include Our parent company and any other subsidiaries, joint

venture partners or other companies that We control or that are under

common control with Us.

* With business partners: We may share Your information with Our business

partners to offer You certain products, services or promotions.

* With other users: when You share personal information or otherwise

interact in the public areas with other users, such information may be

viewed by all users and may be publicly distributed outside. If You

interact with other users or register through a Third-Party Social Media

Service, Your contacts on the Third-Party Social Media Service may see

Your name, profile, pictures and description of Your activity. Similarly,

other users will be able to view descriptions of Your activity,

communicate with You and view Your profile.

* With Your consent : We may disclose Your personal information for any

other purpose with Your consent.

Retention of Your Personal Data

-------------------------------

The Company will retain Your Personal Data only for as long as is necessary

for the purposes set out in this Privacy Policy. We will retain and use Your

Personal Data to the extent necessary to comply with our legal obligations

(for example, if we are required to retain your data to comply with applicable

laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage

Data is generally retained for a shorter period of time, except when this data

is used to strengthen the security or to improve the functionality of Our

Service, or We are legally obligated to retain this data for longer time

periods.

Transfer of Your Personal Data

------------------------------

Your information, including Personal Data, is processed at the Company's

operating offices and in any other places where the parties involved in the

processing are located. It means that this information may be transferred to —

and maintained on — computers located outside of Your state, province, country

or other governmental jurisdiction where the data protection laws may differ

than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such

information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data

is treated securely and in accordance with this Privacy Policy and no transfer

of Your Personal Data will take place to an organization or a country unless

there are adequate controls in place including the security of Your data and

other personal information.

Disclosure of Your Personal Data

--------------------------------

Business Transactions

~~~~~~~~~~~~~~~~~~~~~

If the Company is involved in a merger, acquisition or asset sale, Your

Personal Data may be transferred. We will provide notice before Your Personal

Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

~~~~~~~~~~~~~~~

Under certain circumstances, the Company may be required to disclose Your

Personal Data if required to do so by law or in response to valid requests by

public authorities (e.g. a court or a government agency).

Other legal requirements

~~~~~~~~~~~~~~~~~~~~~~~~

The Company may disclose Your Personal Data in the good faith belief that such

action is necessary to:

* Comply with a legal obligation

* Protect and defend the rights or property of the Company

* Prevent or investigate possible wrongdoing in connection with the Service

* Protect the personal safety of Users of the Service or the public

* Protect against legal liability

Security of Your Personal Data

------------------------------

The security of Your Personal Data is important to Us, but remember that no

method of transmission over the Internet, or method of electronic storage is

100% secure. While We strive to use commercially acceptable means to protect

Your Personal Data, We cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

============================================================

The Service Providers We use may have access to Your Personal Data. These

third-party vendors collect, store, use, process and transfer information

about Your activity on Our Service in accordance with their Privacy Policies.

Analytics

---------

We may use third-party Service providers to monitor and analyze the use of our

Service.

* Google Analytics

Google Analytics is a web analytics service offered by Google that tracks

and reports website traffic. Google uses the data collected to track and

monitor the use of our Service. This data is shared with other Google

services. Google may use the collected data to contextualize and

personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to

Google Analytics by installing the Google Analytics opt-out browser add-

on. The add-on prevents the Google Analytics JavaScript (ga.js,

analytics.js and dc.js) from sharing information with Google Analytics

about visits activity.

For more information on the privacy practices of Google, please visit the

Google Privacy & Terms web page: <https://policies.google.com/privacy>

* Firebase

Firebase is an analytics service provided by Google Inc.

You may opt-out of certain Firebase features through your mobile device

settings, such as your device advertising settings or by following the

instructions provided by Google in their Privacy Policy:

<https://policies.google.com/privacy>

We also encourage you to review the Google's policy for safeguarding your

data: <https://support.google.com/analytics/answer/6004245>

For more information on what type of information Firebase collects, please

visit the How Google uses data when you use our partners' sites or apps

webpage: <https://policies.google.com/technologies/partner-sites>

* Mixpanel

Mixpanel is provided by Mixpanel Inc.

You can prevent Mixpanel from using your information for analytics

purposes by opting-out. To opt-out of Mixpanel service, please visit this

page: <https://mixpanel.com/optout/>

For more information on what type of information Mixpanel collects, please

visit the Terms of Use page of Mixpanel: <https://mixpanel.com/terms/>

Email Marketing

---------------

We may use Your Personal Data to contact You with newsletters, marketing or

promotional materials and other information that may be of interest to You.

You may opt-out of receiving any, or all, of these communications from Us by

following the unsubscribe link or instructions provided in any email We send

or by contacting Us.

We may use Email Marketing Service Providers to manage and send emails to You.

* Mailchimp

Mailchimp is an email marketing sending service provided by The Rocket

Science Group LLC.

For more information on the privacy practices of Mailchimp, please visit

their Privacy policy: <https://mailchimp.com/legal/privacy/>

* Sendgrid

Their Privacy Policy can be viewed at

<https://www.twilio.com/legal/privacy>

Payments

--------

We may provide paid products and/or services within the Service. In that case,

we may use third-party services for payment processing (e.g. payment

processors).

We will not store or collect Your payment card details. That information is

provided directly to Our third-party payment processors whose use of Your

personal information is governed by their Privacy Policy. These payment

processors adhere to the standards set by PCI-DSS as managed by the PCI

Security Standards Council, which is a joint effort of brands like Visa,

Mastercard, American Express and Discover. PCI-DSS requirements help ensure

the secure handling of payment information.

* Stripe

Their Privacy Policy can be viewed at <https://stripe.com/us/privacy>

Behavioral Remarketing

----------------------

The Company uses remarketing services to advertise to You after You accessed

or visited our Service. We and Our third-party vendors use cookies and non-

cookie technologies to help Us recognize Your Device and understand how You

use our Service so that We can improve our Service to reflect Your interests

and serve You advertisements that are likely to be of more interest to You.

These third-party vendors collect, store, use, process and transfer

information about Your activity on Our Service in accordance with their

Privacy Policies and to enable Us to:

* Measure and analyze traffic and browsing activity on Our Service

* Show advertisements for our products and/or services to You on third-party

websites or apps

* Measure and analyze the performance of Our advertising campaigns

Some of these third-party vendors may use non-cookie technologies that may not

be impacted by browser settings that block cookies. Your browser may not

permit You to block such technologies. You can use the following third-party

tools to decline the collection and use of information for the purpose of

serving You interest-based advertising:

* The NAI's opt-out platform: <http://www.networkadvertising.org/choices/>

* The EDAA's opt-out platform <http://www.youronlinechoices.com/>

* The DAA's opt-out platform:

[http://optout.aboutads.info/?c=2&lang=EN](http://optout.aboutads.info/?c=2&lang=EN)

You may opt-out of all personalized advertising by enabling privacy features

on Your mobile device such as Limit Ad Tracking (iOS) and Opt Out of Ads

Personalization (Android). See Your mobile device Help system for more

information.

We may share information, such as hashed email addresses (if available) or

other online identifiers collected on Our Service with these third-party

vendors. This allows Our third-party vendors to recognize and deliver You ads

across devices and browsers. To read more about the technologies used by these

third-party vendors and their cross-device capabilities please refer to the

Privacy Policy of each vendor listed below.

The third-party vendors We use are:

* Google Ads (AdWords)

Google Ads (AdWords) remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customise

the Google Display Network ads by visiting the Google Ads Settings page:

<http://www.google.com/settings/ads>

Google also recommends installing the Google Analytics Opt-out Browser

Add-on - <https://tools.google.com/dlpage/gaoptout> \- for your web

browser. Google Analytics Opt-out Browser Add-on provides visitors with

the ability to prevent their data from being collected and used by Google

Analytics.

For more information on the privacy practices of Google, please visit the

Google Privacy & Terms web page: <https://policies.google.com/privacy>

* Bing Ads Remarketing

Bing Ads remarketing service is provided by Microsoft Inc.

You can opt-out of Bing Ads interest-based ads by following their

instructions: <https://advertise.bingads.microsoft.com/en-

us/resources/policies/personalized-ads>

You can learn more about the privacy practices and policies of Microsoft

by visiting their Privacy Policy page: <https://privacy.microsoft.com/en-

us/PrivacyStatement>

* Twitter

Twitter remarketing service is provided by Twitter Inc.

You can opt-out from Twitter's interest-based ads by following their

instructions: <https://support.twitter.com/articles/20170405>

You can learn more about the privacy practices and policies of Twitter by

visiting their Privacy Policy page: <https://twitter.com/privacy>

* Facebook

Facebook remarketing service is provided by Facebook Inc.

You can learn more about interest-based advertising from Facebook by

visiting this page: <https://www.facebook.com/help/516147308587266>

To opt-out from Facebook's interest-based ads, follow these instructions

from Facebook: <https://www.facebook.com/help/568137493302217>

Facebook adheres to the Self-Regulatory Principles for Online Behavioural

Advertising established by the Digital Advertising Alliance. You can also

opt-out from Facebook and other participating companies through the

Digital Advertising Alliance in the USA

<http://www.aboutads.info/choices/>, the Digital Advertising Alliance of

Canada in Canada <http://youradchoices.ca/> or the European Interactive

Digital Advertising Alliance in Europe <http://www.youronlinechoices.eu/>,

or opt-out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit

Facebook's Data Policy: <https://www.facebook.com/privacy/explanation>

* Pinterest

Pinterest remarketing service is provided by Pinterest Inc.

You can opt-out from Pinterest's interest-based ads by enabling the "Do

Not Track" functionality of your web browser or by following Pinterest

instructions: <http://help.pinterest.com/en/articles/personalization-and-

data>

You can learn more about the privacy practices and policies of Pinterest

by visiting their Privacy Policy page:

<https://about.pinterest.com/en/privacy-policy>

Usage, Performance and Miscellaneous

------------------------------------

We may use third-party Service Providers to provide better improvement of our

Service.

* Google Places

Google Places is a service that returns information about places using

HTTP requests. It is operated by Google

Google Places service may collect information from You and from Your

Device for security purposes.

The information gathered by Google Places is held in accordance with the

Privacy Policy of Google:

<https://www.google.com/intl/en/policies/privacy/>

GDPR Privacy

============

Legal Basis for Processing Personal Data under GDPR

---------------------------------------------------

We may process Personal Data under the following conditions:

* Consent: You have given Your consent for processing Personal Data for one

or more specific purposes.

* Performance of a contract: Provision of Personal Data is necessary for the

performance of an agreement with You and/or for any pre-contractual

obligations thereof.

* Legal obligations: Processing Personal Data is necessary for compliance

with a legal obligation to which the Company is subject.

* Vital interests: Processing Personal Data is necessary in order to protect

Your vital interests or of another natural person.

* Public interests: Processing Personal Data is related to a task that is

carried out in the public interest or in the exercise of official

authority vested in the Company.

* Legitimate interests: Processing Personal Data is necessary for the

purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis

that applies to the processing, and in particular whether the provision of

Personal Data is a statutory or contractual requirement, or a requirement

necessary to enter into a contract.

Your Rights under the GDPR

--------------------------

The Company undertakes to respect the confidentiality of Your Personal Data

and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the

EU, to:

* Request access to Your Personal Data. The right to access, update or

delete the information We have on You. Whenever made possible, you can

access, update or request deletion of Your Personal Data directly within

Your account settings section. If you are unable to perform these actions

yourself, please contact Us to assist You. This also enables You to

receive a copy of the Personal Data We hold about You.

* Request correction of the Personal Data that We hold about You. You have

the right to have any incomplete or inaccurate information We hold about

You corrected.

* Object to processing of Your Personal Data. This right exists where We are

relying on a legitimate interest as the legal basis for Our processing and

there is something about Your particular situation, which makes You want

to object to our processing of Your Personal Data on this ground. You also

have the right to object where We are processing Your Personal Data for

direct marketing purposes.

* Request erasure of Your Personal Data. You have the right to ask Us to

delete or remove Personal Data when there is no good reason for Us to

continue processing it.

* Request the transfer of Your Personal Data. We will provide to You, or to

a third-party You have chosen, Your Personal Data in a structured,

commonly used, machine-readable format. Please note that this right only

applies to automated information which You initially provided consent for

Us to use or where We used the information to perform a contract with You.

* Withdraw Your consent. You have the right to withdraw Your consent on

using your Personal Data. If You withdraw Your consent, We may not be able

to provide You with access to certain specific functionalities of the

Service.

Exercising of Your GDPR Data Protection Rights

----------------------------------------------

You may exercise Your rights of access, rectification, cancellation and

opposition by contacting Us. Please note that we may ask You to verify Your

identity before responding to such requests. If You make a request, We will

try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our

collection and use of Your Personal Data. For more information, if You are in

the European Economic Area (EEA), please contact Your local data protection

authority in the EEA.

Facebook Fan Page

=================

Data Controller for the Facebook Fan Page

-----------------------------------------

The Company is the Data Controller of Your Personal Data collected while using

the Service. As operator of the Facebook Fan Page

<https://www.facebook.com/HALxyz/>, the Company and the operator of the social

network Facebook are Joint Controllers.

The Company has entered into agreements with Facebook that define the terms

for use of the Facebook Fan Page, among other things. These terms are mostly

based on the Facebook Terms of Service: <https://www.facebook.com/terms.php>

Visit the Facebook Privacy Policy <https://www.facebook.com/policy.php> for

more information about how Facebook manages Personal data or contact Facebook

online, or by mail: Facebook, Inc. ATTN, Privacy Operations, 1601 Willow Road,

Menlo Park, CA 94025, United States.

Facebook Insights

-----------------

We use the Facebook Insights function in connection with the operation of the

Facebook Fan Page and on the basis of the GDPR, in order to obtain anonymized

statistical data about Our users.

For this purpose, Facebook places a Cookie on the device of the user visiting

Our Facebook Fan Page. Each Cookie contains a unique identifier code and

remains active for a period of two years, except when it is deleted before the

end of this period.

Facebook receives, records and processes the information stored in the Cookie,

especially when the user visits the Facebook services, services that are

provided by other members of the Facebook Fan Page and services by other

companies that use Facebook services.

For more information on the privacy practices of Facebook, please visit

Facebook Privacy Policy here: <https://www.facebook.com/privacy/explanation>

CCPA Privacy

============

This privacy notice section for California residents supplements the

information contained in Our Privacy Policy and it applies solely to all

visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

--------------------------------------------

We collect information that identifies, relates to, describes, references, is

capable of being associated with, or could reasonably be linked, directly or

indirectly, with a particular Consumer or Device. The following is a list of

categories of personal information which we may collect or may have been

collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are

those defined in the CCPA. This does not mean that all examples of that

category of personal information were in fact collected by Us, but reflects

our good faith belief to the best of our knowledge that some of that

information from the applicable category may be and may have been collected.

For example, certain categories of personal information would only be

collected if You provided such personal information directly to Us.

* Category A: Identifiers.

Examples: A real name, alias, postal address, unique personal identifier,

online identifier, Internet Protocol address, email address, account name,

driver's license number, passport number, or other similar identifiers.

Collected: Yes.

* Category B: Personal information categories listed in the California

Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Examples: A name, signature, Social Security number, physical

characteristics or description, address, telephone number, passport

number, driver's license or state identification card number, insurance

policy number, education, employment, employment history, bank account

number, credit card number, debit card number, or any other financial

information, medical information, or health insurance information. Some

personal information included in this category may overlap with other

categories.

Collected: Yes.

* Category C: Protected classification characteristics under California or

federal law.

Examples: Age (40 years or older), race, color, ancestry, national origin,

citizenship, religion or creed, marital status, medical condition,

physical or mental disability, sex (including gender, gender identity,

gender expression, pregnancy or childbirth and related medical

conditions), sexual orientation, veteran or military status, genetic

information (including familial genetic information).

Collected: No.

* Category D: Commercial information.

Examples: Records and history of products or services purchased or

considered.

Collected: Yes.

* Category E: Biometric information.

Examples: Genetic, physiological, behavioral, and biological

characteristics, or activity patterns used to extract a template or other

identifier or identifying information, such as, fingerprints, faceprints,

and voiceprints, iris or retina scans, keystroke, gait, or other physical

patterns, and sleep, health, or exercise data.

Collected: No.

* Category F: Internet or other similar network activity.

Examples: Interaction with our Service or advertisement.

Collected: Yes.

* Category G: Geolocation data.

Examples: Approximate physical location.

Collected: No.

* Category H: Sensory data.

Examples: Audio, electronic, visual, thermal, olfactory, or similar

information.

Collected: No.

* Category I: Professional or employment-related information.

Examples: Current or past job history or performance evaluations.

Collected: No.

* Category J: Non-public education information (per the Family Educational

Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Examples: Education records directly related to a student maintained by an

educational institution or party acting on its behalf, such as grades,

transcripts, class lists, student schedules, student identification codes,

student financial information, or student disciplinary records.

Collected: No.

* Category K: Inferences drawn from other personal information.

Examples: Profile reflecting a person's preferences, characteristics,

psychological trends, predispositions, behavior, attitudes, intelligence,

abilities, and aptitudes.

Collected: No.

Under CCPA, personal information does not include:

* Publicly available information from government records

* Deidentified or aggregated consumer information

* Information excluded from the CCPA's scope, such as:

* Health or medical information covered by the Health Insurance

Portability and Accountability Act of 1996 (HIPAA) and the California

Confidentiality of Medical Information Act (CMIA) or clinical trial data

* Personal Information covered by certain sector-specific privacy laws,

including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley

Act (GLBA) or California Financial Information Privacy Act (FIPA), and

the Driver's Privacy Protection Act of 1994

Sources of Personal Information

-------------------------------

We obtain the categories of personal information listed above from the

following categories of sources:

* Directly from You. For example, from the forms You complete on our

Service, preferences You express or provide through our Service, or from

Your purchases on our Service.

* Indirectly from You. For example, from observing Your activity on our

Service.

* Automatically from You. For example, through cookies We or our Service

Providers set on Your Device as You navigate through our Service.

* From Service Providers. For example, third-party vendors to monitor and

analyze the use of our Service, third-party vendors to deliver targeted

advertising to You, third-party vendors for payment processing, or other

third-party vendors that We use to provide the Service to You.

Use of Personal Information for Business Purposes or Commercial Purposes

------------------------------------------------------------------------

We may use or disclose personal information We collect for "business purposes"

or "commercial purposes" (as defined under the CCPA), which may include the

following examples:

* To operate our Service and provide You with our Service.

* To provide You with support and to respond to Your inquiries, including to

investigate and address Your concerns and monitor and improve our Service.

* To fulfill or meet the reason You provided the information. For example,

if You share Your contact information to ask a question about our Service,

We will use that personal information to respond to Your inquiry. If You

provide Your personal information to purchase a product or service, We

will use that information to process Your payment and facilitate delivery.

* To respond to law enforcement requests and as required by applicable law,

court order, or governmental regulations.

* As described to You when collecting Your personal information or as

otherwise set forth in the CCPA.

* For internal administrative and auditing purposes.

* To detect security incidents and protect against malicious, deceptive,

fraudulent or illegal activity, including, when necessary, to prosecute

those responsible for such activities.

Please note that the examples provided above are illustrative and not intended

to be exhaustive. For more details on how we use this information, please

refer to the "Use of Your Personal Data" section.

If We decide to collect additional categories of personal information or use

the personal information We collected for materially different, unrelated, or

incompatible purposes We will update this Privacy Policy.

Disclosure of Personal Information for Business Purposes or Commercial

Purposes

-------------------------------------------------------------------------------

We may use or disclose and may have used or disclosed in the last twelve (12)

months the following categories of personal information for business or

commercial purposes:

* Category A: Identifiers

* Category B: Personal information categories listed in the California

Customer Records statute (Cal. Civ. Code § 1798.80(e))

* Category D: Commercial information

* Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA.

This does not mean that all examples of that category of personal information

were in fact disclosed, but reflects our good faith belief to the best of our

knowledge that some of that information from the applicable category may be

and may have been disclosed.

When We disclose personal information for a business purpose or a commercial

purpose, We enter a contract that describes the purpose and requires the

recipient to both keep that personal information confidential and not use it

for any purpose except performing the contract.

Sale of Personal Information

----------------------------

As defined in the CCPA, "sell" and "sale" mean selling, renting, releasing,

disclosing, disseminating, making available, transferring, or otherwise

communicating orally, in writing, or by electronic or other means, a

consumer's personal information by the business to a third party for valuable

consideration. This means that We may have received some kind of benefit in

return for sharing personal information, but not necessarily a monetary

benefit.

Please note that the categories listed below are those defined in the CCPA.

This does not mean that all examples of that category of personal information

were in fact sold, but reflects our good faith belief to the best of our

knowledge that some of that information from the applicable category may be

and may have been shared for value in return.

We may sell and may have sold in the last twelve (12) months the following

categories of personal information:

* Category A: Identifiers

* Category B: Personal information categories listed in the California

Customer Records statute (Cal. Civ. Code § 1798.80(e))

* Category D: Commercial information

* Category F: Internet or other similar network activity

Share of Personal Information

-----------------------------

We may share Your personal information identified in the above categories with

the following categories of third parties:

* Service Providers

* Payment processors

* Our affiliates

* Our business partners

* Third party vendors to whom You or Your agents authorize Us to disclose

Your personal information in connection with products or services We

provide to You

Sale of Personal Information of Minors Under 16 Years of Age

------------------------------------------------------------

We do not knowingly collect personal information from minors under the age of

16 through our Service, although certain third party websites that we link to

may do so. These third-party websites have their own terms of use and privacy

policies and we encourage parents and legal guardians to monitor their

children's Internet usage and instruct their children to never provide

information on other websites without their permission.

We do not sell the personal information of Consumers We actually know are less

than 16 years of age, unless We receive affirmative authorization (the "right

to opt-in") from either the Consumer who is between 13 and 16 years of age, or

the parent or guardian of a Consumer less than 13 years of age. Consumers who

opt-in to the sale of personal information may opt-out of future sales at any

time. To exercise the right to opt-out, You (or Your authorized

representative) may submit a request to Us by contacting Us.

If You have reason to believe that a child under the age of 13 (or 16) has

provided Us with personal information, please contact Us with sufficient

detail to enable Us to delete that information.

Your Rights under the CCPA

--------------------------

The CCPA provides California residents with specific rights regarding their

personal information. If You are a resident of California, You have the

following rights:

* The right to notice. You have the right to be notified which categories of

Personal Data are being collected and the purposes for which the Personal

Data is being used.

* The right to request. Under CCPA, You have the right to request that We

disclose information to You about Our collection, use, sale, disclosure

for business purposes and share of personal information. Once We receive

and confirm Your request, We will disclose to You:

* The categories of personal information We collected about You

* The categories of sources for the personal information We collected

about You

* Our business or commercial purpose for collecting or selling that

personal information

* The categories of third parties with whom We share that personal

information

* The specific pieces of personal information We collected about You

* If we sold Your personal information or disclosed Your personal

information for a business purpose, We will disclose to You:

* The categories of personal information categories sold

* The categories of personal information categories disclosed

* The right to say no to the sale of Personal Data (opt-out). You have the

right to direct Us to not sell Your personal information. To submit an

opt-out request please contact Us.

* The right to delete Personal Data. You have the right to request the

deletion of Your Personal Data, subject to certain exceptions. Once We

receive and confirm Your request, We will delete (and direct Our Service

Providers to delete) Your personal information from our records, unless an

exception applies. We may deny Your deletion request if retaining the

information is necessary for Us or Our Service Providers to:

* Complete the transaction for which We collected the personal

information, provide a good or service that You requested, take actions

reasonably anticipated within the context of our ongoing business

relationship with You, or otherwise perform our contract with You.

* Detect security incidents, protect against malicious, deceptive,

fraudulent, or illegal activity, or prosecute those responsible for such

activities.

* Debug products to identify and repair errors that impair existing

intended functionality.

* Exercise free speech, ensure the right of another consumer to exercise

their free speech rights, or exercise another right provided for by law.

* Comply with the California Electronic Communications Privacy Act (Cal.

Penal Code § 1546 et. seq.).

* Engage in public or peer-reviewed scientific, historical, or statistical

research in the public interest that adheres to all other applicable

ethics and privacy laws, when the information's deletion may likely

render impossible or seriously impair the research's achievement, if You

previously provided informed consent.

* Enable solely internal uses that are reasonably aligned with consumer

expectations based on Your relationship with Us.

* Comply with a legal obligation.

* Make other internal and lawful uses of that information that are

compatible with the context in which You provided it.

* The right not to be discriminated against. You have the right not to be

discriminated against for exercising any of Your consumer's rights,

including by:

* Denying goods or services to You

* Charging different prices or rates for goods or services, including the

use of discounts or other benefits or imposing penalties

* Providing a different level or quality of goods or services to You

* Suggesting that You will receive a different price or rate for goods or

services or a different level or quality of goods or services

Exercising Your CCPA Data Protection Rights

-------------------------------------------

In order to exercise any of Your rights under the CCPA, and if You are a

California resident, You can contact Us:

* By email: support@hal.xyz

* By visiting this page on our website: <http://www.hal.xyz>

Only You, or a person registered with the California Secretary of State that

You authorize to act on Your behalf, may make a verifiable request related to

Your personal information.

Your request to Us must:

* Provide sufficient information that allows Us to reasonably verify You are

the person about whom We collected personal information or an authorized

representative

* Describe Your request with sufficient detail that allows Us to properly

understand, evaluate, and respond to it

We cannot respond to Your request or provide You with the required information

if we cannot:

* Verify Your identity or authority to make the request

* And confirm that the personal information relates to You

We will disclose and deliver the required information free of charge within 45

days of receiving Your verifiable request. The time period to provide the

required information may be extended once by an additional 45 days when

reasonably necessary and with prior notice.

Any disclosures We provide will only cover the 12-month period preceding the

verifiable request's receipt.

For data portability requests, We will select a format to provide Your

personal information that is readily usable and should allow You to transmit

the information from one entity to another entity without hindrance.

Do Not Sell My Personal Information

-----------------------------------

You have the right to opt-out of the sale of Your personal information. Once

We receive and confirm a verifiable consumer request from You, we will stop

selling Your personal information. To exercise Your right to opt-out, please

contact Us.

The Service Providers we partner with (for example, our analytics or

advertising partners) may use technology on the Service that sells personal

information as defined by the CCPA law. If you wish to opt out of the use of

Your personal information for interest-based advertising purposes and these

potential sales as defined under CCPA law, you may do so by following the

instructions below.

Please note that any opt out is specific to the browser You use. You may need

to opt out on every browser that You use.

Website

~~~~~~~

You can opt out of receiving ads that are personalized as served by our

Service Providers by following our instructions presented on the Service:

* The NAI's opt-out platform: <http://www.networkadvertising.org/choices/>

* The EDAA's opt-out platform <http://www.youronlinechoices.com/>

* The DAA's opt-out platform:

[http://optout.aboutads.info/?c=2&lang=EN](http://optout.aboutads.info/?c=2&lang=EN)

The opt out will place a cookie on Your computer that is unique to the browser

You use to opt out. If you change browsers or delete the cookies saved by your

browser, You will need to opt out again.

Mobile Devices

~~~~~~~~~~~~~~

Your mobile device may give You the ability to opt out of the use of

information about the apps You use in order to serve You ads that are targeted

to Your interests:

* "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on

Android devices

* "Limit Ad Tracking" on iOS devices

You can also stop the collection of location information from Your mobile

device by changing the preferences on Your mobile device.

"Do Not Track" Policy as Required by California Online Privacy Protection Act

(CalOPPA)

========================================================================

Our Service does not respond to Do Not Track signals.

However, some third party websites do keep track of Your browsing activities.

If You are visiting such websites, You can set Your preferences in Your web

browser to inform websites that You do not want to be tracked. You can enable

or disable DNT by visiting the preferences or settings page of Your web

browser.

Children's Privacy

==================

Our Service does not address anyone under the age of 13. We do not knowingly

collect personally identifiable information from anyone under the age of 13.

If You are a parent or guardian and You are aware that Your child has provided

Us with Personal Data, please contact Us. If We become aware that We have

collected Personal Data from anyone under the age of 13 without verification

of parental consent, We take steps to remove that information from Our

servers.

If We need to rely on consent as a legal basis for processing Your information

and Your country requires consent from a parent, We may require Your parent's

consent before We collect and use that information.

Your California Privacy Rights (California's Shine the Light law)

=================================================================

Under California Civil Code Section 1798 (California's Shine the Light law),

California residents with an established business relationship with us can

request information once a year about sharing their Personal Data with third

parties for the third parties' direct marketing purposes.

If you'd like to request more information under the California Shine the Light

law, and if You are a California resident, You can contact Us using the

contact information provided below.

California Privacy Rights for Minor Users (California Business and Professions

Code Section 22581)

==================================================================================================

California Business and Professions Code Section 22581 allows California

residents under the age of 18 who are registered users of online sites,

services or applications to request and obtain removal of content or

information they have publicly posted.

To request removal of such data, and if You are a California resident, You can

contact Us using the contact information provided below, and include the email

address associated with Your account.

Be aware that Your request does not guarantee complete or comprehensive

removal of content or information posted online and that the law may not

permit or require removal in certain circumstances.

Links to Other Websites

=======================

Our Service may contain links to other websites that are not operated by Us.

If You click on a third party link, You will be directed to that third party's

site. We strongly advise You to review the Privacy Policy of every site You

visit.

We have no control over and assume no responsibility for the content, privacy

policies or practices of any third party sites or services.

Changes to this Privacy Policy

==============================

We may update Our Privacy Policy from time to time. We will notify You of any

changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior

to the change becoming effective and update the "Last updated" date at the top

of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes.

Changes to this Privacy Policy are effective when they are posted on this

page.

Contact Us

==========

If you have any questions about this Privacy Policy, You can contact us:

* By email: support@hal.xyz

* By visiting this page on our website: <http://www.hal.xyz>

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