Privacy Statement
Last updated: April 18, 2023
At Halo Investing, Inc., 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 we collect about you, what we do with it, and how
you can control it in connection with our website or other online services (the “Site”).
Why We Collect your information
We collect personal information about you for the following reasons:
For our general administrative purposes. For example, we need your information to
administer your online account and provide customer service to you.
For our internal efforts to operate and improve our business. This could include improving
our services and the Site, or using the information for internal activities like auditing, billing, and forecasting.
For advertising and marketing purposes. This could include:
- Sending you information on promotions or surveys we offer, or information about us and our events.
- Enhancing and personalizing the content of our Site, our communications with you, and our advertising and marketing.
For security purposes, as necessary to help us protect against, identify, or investigate fraud or other criminal activity.
For other legal purposes, if we have a legal obligation, or need to pursue or defend against legal claims, for which we need to process your information.
For communication purposes, to get in touch with you in connection with any of the reasons discussed above.
What Information We Collect About You
Information you provide. When you create an account or communicate with us, we may collect
your first and last name, email, phone number, company name, title or role, state, Central Registration Depository (CRD) number, login credentials, or other information you voluntarily provide to us.
Information gathered automatically. When you log into your account, we collect information
about the actions you take while logged in. When you visit the Site, we may automatically
collect information directly or through our third-party analytics providers. We (and third parties
acting on our behalf) may collect this information directly from your browser interacting with
our Site. We may also collect it through cookies, which are typically assigned to one of four
categories, depending on their function and intended purpose:
- Essential Cookies: These cookies are necessary for our Site to operate properly and
enable you to use its features.
- Performance Cookies: These cookies collect information about how you use our Site
and are used to improve future web experiences.
- Functional Cookies: These cookies allow our Site to remember choices you make and
provide more personal features as well as services you have asked for.
- Marketing Cookies: We use cookies to help us deliver our content and advertising. You
can find more information below on advertising, including your choices with respect to
these cookies.
Your browser may give you the ability to control cookies. How you do so depends on the type of
cookie. You can be set your browser to reject cookies. To find out more about how to control
cookies from your web browser, please visit
here.
Some browsers have “do not track” features that allow you to tell a website not to track you.
These features are not all uniform. We do not currently respond to those signals. Instead, we
collect, use, and share information as described in this Privacy Statement regardless of a “do not
track” choice.
Third-Party Analytics
We use third-party providers to collect and analyze information about your use of the Site. These
providers may collect information about your online activities over time and across third-party
websites and other online services using cookies and other tracking technologies discussed above
in connection with your use of the Site. You may be able to manage how these providers collect
information by changing your browser’s cookie settings as discussed above.
How We Share Your Information
We may share your information:
- With our affiliates and other companies in which we have an economic interest or
ownership rights.
- With others working for us, which includes third parties that perform services on our
behalf such as running our Site, sending communications for us, and executing marketing
programs and promotions.
- With other third parties, such as law enforcement or other government entities: (1) if
we believe there has been a violation of our Site policies; (2) if we believe that someone
may be causing injury to our rights or property, to other users, or to anyone else; (3) to
provide information to law enforcement; or (4) as required by law.
- As part of a corporate restructure, such as a liquidation, reorganization, merger, sale of
the company, consolidation, change of control, asset or stock acquisition/disposition, or
other corporate combination. If that happens, we will use reasonable efforts to make sure
the transferee uses your information in a manner consistent with this Privacy Statement.
We do not share your personal information with any third-party vendor or website owner for
their own marketing purposes.
How You Can Control Your Information
You may review and change any personal information in your account profile and, where
applicable, personal account preferences, stored in our system if you believe it may be out of
date or incorrect. You may also contact us at the address provided in the Contact us section
below.
Protection Of Client Information
In addition to the personal information we collect from individuals for our purposes, we may
obtain nonpublic personal information (“information”) from our clients. We maintain physical,
electronic, and procedural safeguards designed to protect this information.
It is our policy to 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. We may disclose the client’s information if we are: (1)
previously authorized to disclose the information to individuals and/or entities not affiliated with
the firm, including, but not limited to the client’s other professional advisors and/or service
providers (attorney, accountant, insurance agent, broker-dealer, investment adviser, account
custodian, etc.); (2) required to do so by judicial or regulatory process; or (3) otherwise permitted
to do so in accordance with the parameters of applicable federal and/or state privacy regulations.
The disclosure of information contained in any document completed by the client for processing
and/or transmittal by us in order to facilitate the commencement/continuation/termination of a
business relationship between the client and a nonaffiliated third party service provider (broker-
dealer, investment adviser, account custodian, insurance company, etc.), including information
contained in any document completed and/or executed by the client for us (advisory agreement,
client information form, etc.), shall be deemed as having been automatically authorized by the
client with respect to the corresponding nonaffiliated third-party service provider.
We permit only authorized employees and affiliates who have confirmed in writing that they will
abide by our policy to have access to client information. Employees violating our policy will be
subject to our disciplinary process. Additionally, whenever we hire other organizations to
provide services to our clients, we will require them to sign confidentiality agreements and/or
our policy.
Changes To This Privacy Statement
This Privacy Statement is effective as of the date noted above. We may update this Privacy
Statement in the future. When we do, we will post it on the Site and include the effective date of
the update. If there are material changes to our Privacy Statement, we will post a prominent
notice on our Site and provide other notice as required by law.
Contact Us
For questions or concerns regarding this Privacy Statement or our privacy practices generally,
please contact us
here.