Halo Dream, Inc Privacy Policy

Last Updated: January 14, 2025

INTRODUCTION

Please read this privacy policy to learn how Halo Dream, Inc. (also referred to as “HALO Dream”, “we”, “us”, “our”) collects, uses, protects, or otherwise handles the personal information and data of users (also referred to as “you” and “your”) of:

• our websites, including www.halosleep.com and www.adenandanais.com
• our products and devices, including our SleepSure product; and
• our mobile applications, including our HALO mobile application (the “App”).

Our websites, products, devices, and App may be collectively referred to in this policy as our “Services.”

INFORMATION WE COLLECT

When you use our Services, we collect the following types of information.

Account Information. Some information is required to create an account on our Services, such as your name, email and mailing address, user identification, and password, and with respect to your child or children, the child’s name, date of birth, sex, gender, height, and weight. This is the only information you have to provide to create an account with us. You may also choose to provide other types of information, such as a child’s profile photo.

Payment Card Information. If you purchase HALO Dream merchandise on our websites, you may provide your payment information, including your name, credit or debit card number, card expiration date, CVV code, and billing address. Note that third-party payment processors may retain this information in accordance with their own privacy policies and terms.

Additional Collection of Information. If you contact us or participate in a survey, giveaway, promotion, or event that is sponsored or co-sponsored by HALO Dream, we collect the information you submit such as your name, contact information, and message. Additionally, when you purchase products from us, you will provide your shipping address.

Device Information. Some of our devices collect personal information. For example, SleepSure provides us with skin temperature, heart rate, and movement information whenever SleepSure is charged and placed properly on your baby's leg. When your device syncs with our applications or software, data recorded on your device is transferred from your device to our servers.

Geolocation Information. We collect geolocation data when you access our Website or App. When you use our App, we will seek your permission to collect certain geolocation data to scan for device pairing and WiFi connection although such data is not stored or transmitted.

Usage Information. When you access or use our Services, we receive certain usage or network activity information. This includes information about your interaction with the Services, for example, when you view or search content, create or log into your account, or pair your device to your account. We also collect data about the devices and computers you use to access the Services, including IP addresses, browser type and settings, language, operating system, or mobile device information (including device and application identifiers), the referring web page, pages visited, location (depending on the permissions you have granted us), and cookie information.

HOW WE USE INFORMATION

Our main purpose for collecting information from you is to provide you with our Services.

Additionally, HALO Dream may use the information we collect about you, including personal information, for the following purposes:

• To create and manage your account
• To provide you with customer support
• To communicate with you and respond to your inquiries
• To provide information you have requested
• To provide information or advertisements that may be of interest to you
• To administer, personalize, and improve our Services
• To develop new features and services
• To generate statistics and de-identified data
• To prevent, detect or fight fraud or illegal activities
• To comply with legal requirements
• For any other purpose with your consent

HOW INFORMATION IS SHARED

HALO Dream may disclose the information we collect about you, including personal information, for the following purposes:

• In the event of a merger, sale, acquisition, or other corporate transaction.
• As required by law or law enforcement.
• To our corporate affiliates.
• With your consent and in accordance with your instructions.

We do not sell the personal information we collect about you; however, certain of our advertising practices may constitute a “sale” or “sharing” as those terms are defined under California law (see further information in the CALIFORNIA RESIDENTS: YOUR RIGHTS section below).

COOKIES AND TRACKING TECHNOLOGIES

We may use cookies to enable our Website to tailor information to the visitor, to remember a user, to track visits to our Website, etc. Cookies are small pieces of information that are stored by your browser on your computer’s hard drive. While most browsers are set to accept cookies by default, you can set yours to refuse cookies or alert you before accepting them. Additionally, you can reject the placement of targeting and performance cookies by visiting our HALO Dream cookies preference center, the link to which is available in the Contact Information section at the end of this policy. You are not able to reject the placement of strictly necessary cookies as they are necessary for our Website to function.

Our Website also uses third parties to assist us in analyzing data regarding visitors to our Website. For example, we use Google Analytics to collect information about the number of visitors to a site, the webpage that referred visitors to a site, and the pages visitors view within a site. You can opt-out of Google Analytics by downloading Google’s Opt-Out Browser Add-on.

Some internet browsers have “Do Not Track” or “DNT” features which, when turned on, send a signal to the website that the individual visiting the website does not wish to be tracked. Our Website does not honor DNT signals, but you can adjust your cookies settings as described above.

DATA SECURITY

We work hard to keep your data safe. We use a combination of technical, administrative, and physical controls designed to maintain the security of your data. This includes using Transport Layer Security (“TLS ”) to encrypt many of our Services. No method of transmitting or storing data is completely secure, however.

THIRD PARTY LINKS

For practical reasons or for your information, our Website contains links to other websites, such as links to our profile pages on social media websites. HALO Dream exercises no control over such other websites and is not responsible for the content thereon. This privacy policy does not apply to third party websites, and we recommend that you review the online privacy policy of any website you visit to determine how the operator handles personal information collected through its website.

CHILDREN'S PRIVACY

This Website and our App are not intended to be used by children under 13 years of age and we do not knowingly collect personal information from children through our Website. If we learn we have collected or received personal information from a child under 13 through our Website without verification of parental consent, we will delete that information. Please note that HALO Dream does collect information from parents about their children, but such collection is not regulated by the Children’s Online Privacy Protection Act (“COPPA”) since it is not collected from a child.

CHANGES TO THIS PRIVACY

We may revise this policy from time to time. When we make changes to this policy, we will post the updated version on our Website and indicate the date the policy was last updated. We encourage you to review this policy periodically to check for any updates. Your continued use of our Website indicates your consent to the terms of this policy.

ACCESS AND CORRECTION

Accessing Data. By logging into your account on the App, you can access much of the personal information we maintain about you.

Correcting and Deleting Data. By logging into your account and using your account settings, you can change and delete your personal information. For instance, you can edit or delete the profile data you provide and delete your account if you wish. If you wish to access, correct, or delete additional personal information we maintain about you that is not available through the App or if you do not have an account with us, you may contact us by emailing us at customerservice@halosleep.com or calling us toll-free at 1-888-999-4256 to request such access or correction.

Please note that any requests to delete your information will be addressed subject to our retention and backup policies, meaning that your information may not be deleted immediately. Additionally, in some cases, we may fulfill your request by de-identifying or aggregating your information rather than deleting it.

CALIFORNIA RESIDENTS: YOUR RIGHTS

California residents (“you” and “your” for purposes of this California Residents: Your Rights section) have specific rights regarding your personal information under the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”) on January 1, 2023 (collectively referred to herein as the “CCPA”).

The CCPA and, as a result, this section of the privacy policy, apply broadly to information collected not only online, but offline as well. Please note, however, that the CCPA does not apply to certain categories of personal information and our processing of CCPA-exempt categories of information is not addressed below. Additionally, our privacy practices with respect to the personal information of employees and job applicants are not addressed below.

Categories of Personal Information Collected, Disclosed, Sold, or Shared in the Last Twelve (12) Months

You have the right to know the categories of personal information HALO Dream has collected or disclosed.

Retention of Personal Information
We will retain each category of personal information we collect for the time period required to fulfill the legitimate business purposes for which it was collected and to engage in the disclosure practices outlined in this notice, unless a different retention period is required by applicable law, or to otherwise fulfill a legal obligation or protect our legal rights.

Right to Know and Data Portability
You have the right to request that HALO Dream disclose certain information to you about our collection, use, disclosure and sale of your personal information. Once we receive and confirm your request, to the extent you have requested them, we will disclose to you:

• The categories of personal information we collected about you;
• The categories of sources from which your personal information was collected;
• Our business or commercial purpose for collecting, selling, or sharing your personal information;
• The categories of third parties to whom we disclosed, sold, or shared your personal information, if any;
• The categories of personal information we have disclosed, sold, or shared about you; and
• The specific pieces of personal information we have collected about you (also called a data portability request).

Right to Correct
You have the right to request that HALO Dream correct any inaccurate personal information we have collected and maintain about you.

Right to Delete
You have the right to request that HALO Dream delete any of the personal information we have collected and maintain about you, subject to certain exceptions. Once we receive and confirm your request, we will either delete, de-identify, or aggregate your personal information, unless a CCPA exception such as those listed at California Civil Code § 1798.105(d) applies, or not doing so is necessary for us or our service provider(s) to comply with a legal obligation.

Exercising Your Rights to Know, Correct, and Delete
To exercise your rights to know, correct, and delete under the CCPA please submit a request by emailing us at customerservice@halosleep.com or calling us toll-free at 1-888-999-4256.

Only you, or someone legally authorized to act on your behalf (i.e., your authorized agent), may make a request related to your personal information. HALO Dream may require an agent to provide verification that they are acting on your behalf when they submit a request related to your personal information.

All requests to know or delete (whether made by you or an authorized agent) must (1) provide sufficient information for us to reasonably verify you by providing two to three pieces of personal information which we will match with personal information we maintain in our records, and (2) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Right to Opt-Out of Sale or Sharing
Certain of our advertising activities may constitute a “sale” or “sharing” as those terms are defined under the CCPA. If you are age 16 or older, you have the right under the CCPA to direct us not to sell or share your personal information (known as, the right to opt-out). We only engage in the aforementioned advertising activities with respect to the personal information of adult consumers, and we never disclose the personal information we receive about our customers’ children for advertising purposes. We do not sell or share the personal information of consumers we actually know are less than 16 years old.

Exercising Your Right to Opt-Out of Sale or Sharing
To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting our HALO Dream cookies preference center, the link to which is available in the Contact Information section at the end of this policy. Alternatively, you may submit an opt-out request by emailing us at customerservice@halosleep.com or calling us toll-free at 1-888-999-4256. Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales or sharing at any time.

Additionally, HALO Dream makes reasonable efforts to honor opt-out preference signals that are set at the device- or browser-level to communicate a consumer’s choice to opt-out of the sale or sharing of personal information, provided such signals meet the requirements of the CCPA.

Sensitive Personal Information
HALO Dream does not use or disclose sensitive personal information for purposes other than those specified in section 7027(m) of the CPRA modified proposed regulations, as currently drafted.

Right to Non-Discrimination
HALO Dream will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you services;
• Charge you different prices or rates for services, including through granting discounts or other benefits, or imposing penalties;
• Provide you a different level or quality of services; or
• Suggest that you may receive a different price or rate for services or a different level or quality of services.

Notice of Financial Incentive
HALO Dream may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time. We currently provide the following financial incentive:

• We offer a one-time discount in exchange for providing your email address. By providing your email, you opt-in to this financial incentive. If, at a later time, you wish for us to no longer maintain your email address, you may ask that we delete it.

Right to Appeal
HALO Dream provides consumers the right to appeal any decisions we make regarding consumer requests to know, correct, or delete. You may appeal any decision within 30 days of receiving notice of the decision.

CONTACT INFORMATION

If you have questions about this privacy policy or HALO Dream’s privacy practices, or wish to exercise your rights described above, please contact us at:

customerservice@halosleep.com
1-888-999-4256 (9am – 5pm EST Mon – Fri)

Or you can write to us at:
Halo Dream, Inc.
Attn: Legal Department
213 West 35th Street
Suite 12W
New York, NY 10001

If a written, non-digital form is used, please note the amount of time required to receive that communication prior to complying with your information request.