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Privacy Statement

Last updated: May 7, 2025

At Halo Investing, Inc. (“Halo,” “us” or “we”), we know your privacy is important to you, and our aim with this Privacy Statement is to help you make informed choices about your Personal Information. This Privacy Statement explains what personal information Halo and its affiliates may collect from you, how we may use it, the choices you have regarding our use of it, and whether we disclose it to anyone whenyou access our website at haloinvesting.com (the “Site”), including all content, information, and functionality available through the Site, such as the Halo Platform (collectively referred to as the
“Services”). By using our Services, including the Site, you acknowledge the terms of this Privacy Statement as they may be amended from time to time.

We treat any data that identifies you, or reasonably can be linked to you, as “Personal Information.” Data that has been de-identified or aggregated so that it cannot reasonably be linked to you is not Personal Information, and we may use that data for any purpose. Personal information also does not include publicly available information, such as information that is lawfully made available through federal, state, or local government records. We may use de identified, aggregated, or publicly available data for any purpose. We do not attempt to re-identify de-identified data unless you have given us consent to maintain and use the data in identifiable form.

How We Obtain Your Personal Information

Halo obtains Personal Information about you from you or devices you use when you interact with our Site and Services, including when you: (1) contact and communicate with us, including our sales or support teams; (2) use our Services; or (3) use our Site, including the Halo Platform. For the most part, Halo does not process Personal Information regarding consumers. Instead, Halo generally provides Services to professional financial advisors who interact directly with consumers. In limited situations, Halo collects information from consumers, such as when providing annuity products. We also collect
information from third-party analytics companies regarding browsing activity on our Site.

Personal Information We Collect

We may collect the following information when you visit our Site, use or purchase our Services, or otherwise interact with us. The Personal Information we collect includes:

  • Identifying Information – From our professional customers, we may collect identifiers such as name, mailing address, phone numbers, and email addresses. From consumers who purchase annuities, we may collect consumer name, mailing address, email address, and phone numbers, as
    well as sensitive data such social security number, date of birth, and financial account information as required by law.
  • Internet or Similar Network Activity – We may collect activity related to interaction on our Site, as well as your interaction with our advertising and other communications, which may include your IP address and browsing activity. On the Halo Platform, we utilize third-party software to track and collect information about how users interact with the platform. 
  • Commercial Information – We may collect information relating to purchases and use of our services, including purchasing or consuming histories or tendencies.
  • Employment Information – To provide our Services, we may collect employment status information.
  • Demographic Information – To provide Services, such as annuities, we may collect age, gender, citizenship and marital status.

Our Use of Personal Information

We may use your Personal Information as follows:

  • Provide Our Services: We use Personal Information to furnish our Services.
  • Communicate with You: We use Personal Information to respond to communications, contact you about your transactions, promote ourServices, provide other relevant information, and request information or feedback.
  • Advertising and Marketing: We may use Personal Information to communicate with you about services you may be interested in, or to send you information about us and our events.
  • Personalize Your Experience: We utilize Personal Information regarding your use of our Services to personalize and enhance your experiences.
  • Internal Research: We use Personal Information to conduct internal research to develop, improve or repair our Services, or technology, including for auditing and forecasting.
  • Security or Fraud Prevention: We use Personal Information to: (1) prevent, detect, protect against, or respond to security incidents, fraud or malicious or deceptive practices, or other illegal activity, (2) preserve the integrity or security of systems, and (3) investigate, prepare for, establish or defend legal claims.
  • Legal Compliance: We may use Personal Information to comply with applicable law or to comply with a lawful governmental request.

We will retain your Personal Information only for as long as necessary to fulfill the business and commercial purpose(s) for which we obtained the information or as otherwise required by law. Also, please see below regarding consumer rights that may be applicable in your jurisdiction.

We do not use or disclose sensitive personal information, as defined by the California Consumer Privacy Act (“CCPA”), for purposes that would require a consumer to exercise a right to limit under the CCPA.

Our Sharing of Personal Information

We may share Personal Information with service providers who act on our behalf, certain partners, or others operating at your direction or where legally necessary or appropriate.

  • Service Providers: We engage third parties to act as our service providers and perform certain tasks on our behalf in connection with delivering you our Services. The tasks performed by service providers include: (1) processing and storing Personal Information, including helping with onboarding as customers of our Services and using the Halo Platform; (2) assisting with marketing communications, advertising, and strategic initiatives to enhance the Services; and (3) providing technology services. We may provide service providers with all categories of Personal Information described above so they may act on our behalf. We take reasonable steps to ensure that our service providers are contractually obligated to keep Personal Information confidential and only utilize the Personal Information as permitted.
  • Third Party Product Partners: We partner with third parties to provide our Services. For example, we may share the types of Personal Information described above with our insurance carrier partners to deliver our annuity products. With authorization, we also may disclose information to other professional advisors, such as attorneys, accountants, insurance agents, broker-dealers, investment advisers, account custodians, etc.).
  • Affiliates: We may share all categories of Personal Information described above with our affiliate companies, including Halo Securities, LLC, Halo Investing Insurance Services, LLC, and Halo Investment Services, LLC.
  • Other Legal Purposes: We also may share Personal Information: (1) with your consent; (2) to respond to subpoenas, court orders, or other legal process or otherwise as required or allowed by law or the competent governmental or judicial authorities; (3) to cooperate with law enforcement, government or regulatory entities, and safety or investigation authorities; (4) when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud or other illegal activities or to establish or preserve a legal claim or defense; (5) to prevent, detect, protect against, or respond to security incidents, identity theft, fraud, harassment, malicious or deceptive activities, or other illegal activity, or preserve the integrity or security of systems; (6) to investigate, establish, exercise, prepare for, or defend legal claims; or (7) as part of a corporate restructuring, sale of assets, merger or divestiture.

We do not otherwise sell or share (as defined by the CCPA) Personal Information to non-affiliated third parties without your consent.  We also have no actual knowledge of selling or sharing the Personal Information of minors under 16 years of age to non-affiliated third parties without affirmative consent.

Use of Cookies

Like most commercial websites, we analyze how visitors use our website and portals with “cookie” technology. A cookie is a small text file that is placed on your computer when you access our website and allows us to recognize you each time you visit the website. We may use cookies and similar technologies such as pixels to: (1) enhance or personalize your website usage and experience; (2) monitor website usage; and (3) improve the website and our services. We may work with service providers or third parties that help us track, collect and analyze this information. We may combine the information we collect through cookies with other information we have collected from you or information from other sources.

If you choose, you can set your browser to reject cookies or you can manually delete individual cookies or all of the cookies on your computer by following your browser’s help file directions. However, if your browser is set to reject cookies or you manually delete cookies, you may have some trouble accessing and using some of the pages and features on our website. Please note that browser-management tools for cookies are outside of our control, and we cannot guarantee their effectiveness.

Security of Your Personal Information

We use commercially reasonable administrative, technical and physical safeguards to protect Personal Information, considering the nature of the Personal Information and the threats posed. We restrict access to all current and former clients’ information (information and records pertaining to personal background, investment objectives, financial situation, tax information/returns, investment holdings, account numbers, account balances, etc.) to those employees and affiliated/nonaffiliated entities who need to know that information in order to provide products or services to the client. However, there is security risk inherent in all internet and information technologies, and we cannot guarantee the security of your Personal Information.

Third Party Websites and Applications

Our Site may contain links to websites or applications hosted by third parties. This Privacy Statement only applies to websites and applications within Halo’s control and does not apply to any third-party sources. Any data collected through third party websites or applications is subject to the privacy practices of the third party, and you should review the privacy policies of these third parties prior to sharing any data.

Rights and Choices of Customers

We provide our customers in applicable states with certain rights regarding their Personal Information. This section describes the legal rights for California, Nebraska and Texas consumers and explains how consumers from those states can exercise those rights. We will not discriminate against you for exercising any of your rights by: (1) denying you goods or services; (2) charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (3) providing you a different level or quality of goods or services; or (4) suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Right to Know About Personal Information Collected, Used, or Disclosed

You have the right to request that we disclose certain information to you about our collection, use and disclosure of your Personal Information. Once we receive your request and verify your identity, we will disclose to you: (1) the categories of Personal Information we collected about you; (2) the categories of sources for the Personal Information; (3) our business or commercial purpose for collecting or disclosing that Personal Information; (4) the categories of third parties with whom we shared that Personal Information; and (5) the specific pieces of Personal Information we collected about you in the preceding
12 months.

Right to Delete Personal Information Collected or Maintained

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your request and verify your identity, we will permanently delete (and direct our service providers to delete) your Personal Information from our records, unless a legal exception to deletion applies.

Right to Correction of Personal Information

You have the right to request that we correct inaccurate Personal Information that we maintain about you.

Exercising Your Rights

To exercise the rights described above, please submit a verifiable consumer request to us by either:

Authorizing an Agent

In certain jurisdictions, you may designate an authorized agent to submit your consumer request on your behalf, so long as the authorized agent has your written permission to do so and you have taken steps to verify your identity directly with us.

Verifying Your Request

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.  Making a verifiable consumer request does not require you to create an account with us.  We will only use Personal Information provided in a verifiable consumer request to verify your identity or authority to make the request.

To verify your identity, we ask that you provide us with the following information when you submit your request: (1) first name, (2) last name, and (3) phone number or email. We will use the above information to verify your identity. Depending on your type of request or the information requested by you, we may require additional information to verify your identity and fulfill your request.

If we decline to take action regarding your request, certain jurisdictions may provide you with the right to appeal. Please contact us at privacy@haloinvesting.com if you would like to submit such an appeal.

Personal Information Concerning Children

We do not knowingly collect Personal Information from individuals under the age of 16. Our Site is not intended for anyone under the age of 16, and no one under the age of 16 is authorized to provide information on the Site.

Updates to the Privacy Statement

We may update this Privacy Statement periodically as we offer new products and services, and as our business, technology, and laws change. You can determine when this Privacy Statement was last revised by referring to the “Last updated” reference above. Any changes will become effective upon posting of the revised Privacy Statement. If we make material changes to the policy, we will provide notice to you of the changes as required by applicable law.

Contact Us

Halo Investing
200 W. Jackson Blvd., 18th Floor
Chicago, IL 60606
Email: privacy@haloinvesting.com

Last Updated: May 7, 2025