by FULL SCALE FULL SPEED PTE.LTD. · Shopping · ★ 4.7
"We generally do not sell your personal information for profit, but like many businesses, we use cookies, pixels, and similar technology on our Sites, and we share certain personal information, such as your IP address or device identifiers, to third-party advertisers in order to improve your user experience and to optimize our marketing activities. Under the broad definition of "sell" contained in some jurisdiction's privacy laws, this could be considered a sale."
Halara admits to sharing personal information like IP addresses and device identifiers with third-party advertisers, which may constitute a sale of personal data under various state privacy laws.
"If you post information on public areas of our Site, for example, disclosing your measurement and fitting information in a product review, that information may be collected and used by Halara, visitors to our Sites, and the public generally."
Halara claims the right to collect and use any information users post publicly on their site, including personal details shared in product reviews.
"With Third Party Advertisers. In certain circumstances, and subject to the applicable law, we may share your personal information with third-party advertisers. For Co-Branded Services and Features. Portions of our Site or Services may be offered as part of co-branded services and features. We will share your personal information with our co-branded partners based on your voluntary use of or participation in a co-branded service or feature."
Halara shares personal information with third-party advertisers and co-branded partners, with vague conditions like 'in certain circumstances' providing little meaningful limitation on sharing.
"When you use our Service, we may infer the generic physical location and geographic regions of your device from your WiFi, Bluetooth and other device settings. For example, your IP address may indicate your general geographic region."
Halara collects location information not just from IP addresses but also from WiFi, Bluetooth, and other device settings, going beyond simple IP-based geolocation.
"When you use your desktop or mobile devices to access our Services, we may be able to identify your device's unique device identifier, MAC address, operating system, and your mobile device's advertising ID. We may also collect and use your mobile advertising identifiers for the purpose of marketing campaigns."
Halara collects extensive device identifiers including MAC addresses and mobile advertising IDs, which can be used for tracking and profiling beyond what is needed for a clothing shopping app.
"When you use our mobile application, we or our third-party marketing partners may use one or more of several different identifiers for your mobile device, including Apple Identifier For Advertising (IDFA) or Android Advertising ID (AAID), to target and deliver ads to you in our app or other apps. This means that your device identifier may be accessed by third-party ad networks and used to (a) help manage the number and types of ads you see; (b) track the source of installs related to ads seen in other apps; and (c) identify your interests and behavior and target advertising to you based on those interests and behavior."
Halara and its ad partners use device advertising IDs to track user behavior across multiple apps and websites, building interest-based profiles for targeted advertising.
"We may update this Policy at any time, without prior notice, and changes will apply to any personal information we already hold about you as well as any additional personal information collected after the Policy is updated. Unless otherwise required by laws in your residence, your continued access or use of our Services after receiving the notice of changes, constitutes your acknowledgement that you accept the updated Policy."
Halara reserves the right to update the privacy policy at any time without prior notice, retroactively applying changes to already-collected data, and treats continued use as acceptance.
"We will retain your personal information only for as long as is necessary for the purposes set out in this Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations, resolve disputes and enforce our legal agreements and policies. Halara will also retain Site and services 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 Site."
Halara provides no specific retention timelines and includes broad exceptions that allow indefinite retention for 'internal analysis,' security, or functionality improvement purposes.