Privacy Policy - Halo Funding

Halo Funding, LLC ("Halo") is dedicated to earning and maintaining your trust. This privacy policy describes how we collect, protect, and use information about you when you engage with our services.

At all times, we reserve the right to disclose any information, including personally identifiable information, to comply with any applicable law, regulation, legal process or governmental request; to protect Halo's rights or property (including, without limitation, in the event of a transfer of control of a Halo company, affiliate, or brand, or substantially all of its assets), during an emergency when safety is at risk, or for credit fraud protection and risk reduction purposes.

Information Collection and Use

Halo collects information about you to help us serve your financial needs, to provide you with quality products and services, and to fulfill legal and regulatory requirements. We consider all information about you in our possession to be personal information, even if you cease to be a customer. Typically, we collect this information on applications and other forms you complete, through conversations you may have with our loan professionals, with other representatives, and in some cases, via our website. We may also collect information from a range of other sources in order to process and/or underwrite your loan application. These sources may include, among others, employers, attorneys, banks, title insurers, insurance companies and credit reporting agencies. This information may include your name, address, phone number, email address, social security number, and account numbers.

We do not sell or rent customer information. We share customer information with certain employees, and with companies providing services on our behalf in order to service your needs. Our policy is to require all employees and companies providing services on our behalf to keep customer information confidential. Our privacy policy applies to potential customers as well as current and former customers.

We may also collect, store or accumulate certain non-personally identifiable information concerning your use of this website, such as information regarding which of our pages are most popular. Information gathered may be used in aggregate form for internal business purposes such as generating statistics and developing marketing plans. We may share or transfer such aggregate, non-personally identifiable information with or to our affiliates.

When you fill out a form on our website, we may capture your IP address. This enables us to track and prevent fraudulent attacks against our website as a security precaution and may be used to prevent fraudulent applications. We will not use your IP address to contact you.

Special Note to Parents

This website is intended for adults. We do not knowingly collect personal information from children under the age of 13. However, if the parent or guardian of a child under 13 believes that the child has provided us with personally identifiable information, the parent or guardian of that child should contact us immediately at hello@joinhalo.com if they want this information deleted from our files, so that it is not in retrievable form. If we otherwise obtain knowledge that we have personally identifiable information about a child under 13 in retrievable form in our files, we will delete the information from our databases.

Ensuring Your Security

We have adopted policies and procedures designed to protect your personal information from unauthorized use or disclosure.

We have implemented physical, electronic, and procedural safeguards to maintain confidentiality and integrity of the personal information in our possession and to guard against unauthorized access. These include, among other things, procedures for controlling access to customer files, enforcing security programs, and information technology security measures such as the use of passwords, firewalls, and virus-detection software. We continue to access new technology as it becomes available, and to upgrade our physical and electronic security systems as appropriate.

If you encounter any potential security issues on the Halo platform and wish to responsibly disclose them, please email hello@joinhalo.com. Our policy is to permit employees to access your personal information only if they have a business purpose for using such information, such as administering, providing or developing our products or services. Our policy governs the conduct of all of our employees and third-party vendors, to safeguard personal information about the customers we serve or have served in the past.

Sharing Information With Our Service Providers

We share personal information about you, as required or permitted by law, with affiliates and third parties such as service providers who assist us in the day-to-day operations of our company in the administration, processing, servicing, and sale of your loan. These affiliates and third parties include, among others, title companies, appraisers, insurance companies, underwriting services, processing services, printing companies, software providers, marketing service providers, and purchasers of loans. Our policy is to require affiliates and third-party service providers to enter into confidentiality agreements with us, prohibiting them from using any personal information they obtain for any purpose other than those for which they were retained or as required by law. We may also disclose information about you, when necessary or required, in legal and arbitration proceedings and to government agencies.

Technology We Use

We may use cookies on this website. Any cookies will be used to monitor the performance and effectiveness of the site. "Cookies" are small pieces of information stored on computer's hard drive that communicate your use of this website to us. We do not use cookies to obtain any personally identifying information. Most web browsers automatically accept cookies, but you can change commonly-used browser settings to prevent this. Accepting a cookie does not give us access to your computer or personal information under any circumstances. If you disable cookies, you may be unable to use some features of our site.

Notification of Changes

We may revise this Privacy Policy on occasion. If we decide to change our Privacy Policy, we will post the revised policy here. As we may make changes at any time without notifying you, we suggest that you periodically consult this Privacy Policy.

Your Consent

Your continued use of this website indicates your acceptance of this Privacy Policy, and of the collection, use, disclosure, management, and storage of your personal information as described above. We may occasionally transfer or merge any personal information collected offline to our online databases or store offline information in an electronic format. We may also combine personal information we collect online with information available from other sources.

Contacting Halo

If you have any questions about this privacy policy, please contact us by mail at:

Halo Funding
Attn: Compliance Department
7800 Forsyth Blvd. Suite 300B
Saint Louis, MO 63105

Effective Date of this Policy

This policy was last revised on 6/1/2024, takes effect immediately, and will remain in effect until further revised.

California Privacy Rights Notice

This California Privacy Rights Notice supplements the information contained in Halo Funding's Privacy Policy and applies to California residents ("consumers" or "you"). If you are a California resident, then you have certain rights under the California Consumer Privacy Act ("CCPA") regarding Personal Information.

Right to Know

You have the right to know and see what data we have collected about you over the past 12 months, including:

The categories of Personal Information we have collected about you (see Categories of Information We Collect below)
The categories of sources from which the Personal Information is collected (see Categories of Sources for Personal Information below)
Our business or commercial purpose for collecting your Personal Information (see Purposes for Collection and Use of Personal Information below)
The categories of third parties with whom we have shared your Personal Information (see Sharing of Information below), and
The Personal Information we have collected specifically about you (see Exercising Your Rights below).

Right to Delete

You have the right to request that we delete the Personal Information we have collected from you (and direct our Service Providers to do the same). There are a number of exceptions, however, that include but are not limited to when the information is necessary for us to do any of the following:

Complete your transaction;
Provide services to you;
Perform a contract between us and you;
Protect your security and prosecute those responsible for breaching it;
Fix our systems in the case of a bug;
Comply with a legal obligation; or make other internal and lawful uses of the information that are compatible with the context in which you provided it.

Right to Prohibit Sales of Your Information

California law requires that we provide transparency about personal information we "sell," defined as Halo sharing personal information with third parties in exchange for valuable consideration. In the preceding twelve (12) months, Halo Funding has not sold your Personal information. We will provide notice to you prior to any change to our "No Sales" policy. In addition, you may pro-actively prohibit any such future sales of your Personal Information by us, see "Exercising Your Rights" below.

Exercising Your Rights

To exercise your specific Right to Know, or your Right to Delete, please submit a verifiable consumer request to us by email to hello@joinhalo.com or by calling us at (855) 925-5655.

To exercise your Right to Prohibit the Sales of your Personal Information (including future sales) please submit a verifiable consumer request to us by email to hello@joinhalo.com or by calling us at (855) 925-5655.

Only you, or someone legally authorized to act on your behalf, may exercise these rights related to your Personal Information. Such a request 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 specific Personal Information we have if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. We will verify your request(s) by having you provide your name, address and contact information. We will then request additional identification verification to confirm your identity and/or the identity and authority of your authorized representative.

We will not discriminate against you for exercising any of your CCPA rights described above. Unless permitted by the CCPA, we will not deny you goods or services; charge you different prices or rates for goods or services; provide you a different level or quality of goods or services; or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Categories of Information We Collect

Halo Funding collects 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 household ("Personal Information").

Specifically, we directly and/or through our website, mobile applications, or other online systems ("Systems") have collected the following categories of Personal Information from consumers within the last twelve (12) months:

Personal unique identifiers (SSN, name, driver's license, passport number)
Personal information, including contact details, financial information
Protected classification characteristics under California or federal law, such as sex or marital status
Purchase or other commercial information
Biometric information; Geo-location information, Sensory information
Internet or online information, information regarding interactions with our websites, applications, or advertisements
Employment or education-related information
Inferences drawn from personal information collected

Personal Information does not include:

Publicly available information from government records.
De-identified, anonymized or aggregated consumer information.
Information excluded from the CCPA's scope (e.g., information covered by the Fair Credit Reporting Act ("FCRA"), the Gramm-Leach-Bliley Act ("GLBA") or the California Financial Information Privacy Act ("FIPA"), and the Driver's Privacy Protection Act of 1994).

Categories of Sources for Personal Information

Halo obtains the Personal Information from the following categories of sources:

Directly from you. For example, from your communications to us and through the forms you complete and information you provide to request our financial products.
Indirectly from you. For example, when you navigate through the Systems and such information is collected automatically. Information collected automatically may include usage details, IP addresses and information collected through cookies and other tracking technologies.
From third-party sources. For example, consumer reporting agencies to process and approve your loan application, to verify identity, and to offer you financial products and services of interest to you.

Purposes for Collection and Use of Personal Information

Halo may use or disclose the Personal Information we collect for one or more of the following business purposes:

To fulfill or meet the reason you provided the information.
To provide, support, personalize, and develop our Systems and related services.
To create, maintain, customize, and secure your account information and to support everyday operations including risk, legal, and compliance requirements.
To prevent transactional fraud.
To respond to your customer support requests and/or consumer complaints.
To personalize your experience using our Systems and related services to deliver content and offerings of interest to you.
To help maintain the safety, security, and integrity of our Systems, services, databases, related technology assets, and our overall business.
For testing, research, analysis, and product development, including to develop and improve our business, our Systems and related services.
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.
To evaluate or conduct a transaction involving some or all of Halo Funding's business or assets in which such information is among the assets to be included.

Sharing Personal Information

Halo may share your personal information with the following categories of third parties:

Parties involved in the loan application, underwriting, and financing process.
Parties who service your account.
Parties that perform services on Halo's behalf.
Parties specifically authorized by you.
Halo's financing partners, investors, related agents and advisors.
Parties entitled to such information as required by law.