Privacy Policy

Last updated: August 6, 2026

At Halos Inc. (“Halos,” “we,” or “us”), we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing this Site in any manner, you acknowledge that you accept the practices and policies outlined below, and you consent that we will collect, use, and disclose your information as described in this Privacy Policy.

What this Privacy Policy covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use www.haloshq.com (the “Site”). “Personal Data” means any information that identifies or relates to a particular individual, and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules, or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control, or people we don’t manage.

Halos is currently in private beta with dealerships in the United States. Our handling of data inside the Halos product, including dealership records, inspection media, and vehicle owner information, is governed by the written agreement between Halos and the dealership, not by this Privacy Policy. In those cases we act as a service provider and process that data at the dealership’s direction, and the dealership’s own privacy policy, rather than this one, applies to the individuals whose data it sends us.

Personal Data

Categories of Personal Data we collect

This Site has no accounts, no sign-in, and no payments, and it does not ask you to submit a form. Aside from the categories above, we do not collect Personal Data through the Site. The revenue estimator on this Site runs entirely in your browser; the figures you enter are never transmitted to us or stored.

How we use and disclose your Personal Data

Each of the categories of Personal Data above may also be collected, used, and disclosed to the government, including law enforcement, or to other parties in order to meet certain legal requirements and enforce legal terms, including: fulfilling our legal obligations under applicable law, regulation, court order, or other legal process, such as preventing, detecting, and investigating security incidents and potentially illegal or prohibited activity; protecting the rights, property, or safety of you, Halos, or another party; enforcing any agreements with you; and resolving disputes.

We also disclose your Personal Data to the category of service providers described below.

Service providers. These parties help us provide the Site or perform business functions on our behalf. They include:

• Hosting and content delivery providers
• Analytics providers for web traffic and Site usage
• Scheduling and calendar providers
• Security and infrastructure providers

We do not disclose your Personal Data to advertising partners or ad networks. We do not serve advertising of any kind on this Site, we do not deliver interest-based ads, and we do not use session replay technology.

Business transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy, or other transaction in which that third party assumes control of our business, in whole or in part.

Data that is not Personal Data

We may create aggregated, de-identified, or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified, or anonymized data and disclose it to third parties for our lawful business purposes, including to analyze, build, and improve the Site and to promote our business, provided that we will not disclose such data in a manner that could identify you.

Tracking tools and opt-out

The Site uses cookies (“Cookies”) to tell us how and when visitors use the Site, analyze trends, and improve it. Cookies are small pieces of data, usually text files, placed on your computer, tablet, phone, or similar device when you use that device to access the Site.

Please note that because of our use of Cookies, the Site does not support “Do Not Track” requests sent from a browser at this time.

The Cookies we use

The only Cookies set on this Site are analytical Cookies, which allow us to understand how visitors use the Site by collecting information about the number of visitors, which pages they view, and how long they spend on them. We use Google Analytics for this purpose. Google LLC (“Google”) uses Cookies in connection with its Google Analytics service, and Google’s ability to use and disclose information collected by Google Analytics about your visits to the Site is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on.

The Site sets no essential, functional, or advertising Cookies. Nothing on this Site depends on a Cookie to work. There are no accounts, no sign-in, and no saved preferences, so you can block or clear Cookies in your browser and the Site will continue to function normally.

Data security

We seek to protect your Personal Data from unauthorized access, use, and disclosure using appropriate physical, technical, organizational, and administrative security measures based on the type of Personal Data and how we are processing that data. Although we work to protect the data we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

Data retention

We retain Personal Data for as long as necessary to provide the Site or to perform the business or commercial purposes for which we collected it. When establishing a retention period for a category of data, we consider who we collected the data from, our need for it, why we collected it, and its sensitivity. In some cases we retain Personal Data for longer, where doing so is necessary to comply with our legal obligations or resolve disputes, or is otherwise permitted or required by applicable law, rule, or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

For example:

• We retain Site analytics data on a rolling basis, in line with the retention period configured with our analytics provider.
• We retain scheduling records and correspondence for as long as they remain relevant to the private beta program.

Personal Data of children

The Site is intended for business use by automotive dealership professionals. We do not knowingly collect or solicit Personal Data from children under 18 years of age; if you are a child under the age of 18, please do not use the Site or send us any Personal Data. If we learn that we have collected Personal Data from a child under 18 years of age, we will delete that information as quickly as possible.

California resident rights

Under California Civil Code Sections 1798.83–1798.84, California residents are entitled to prevent the disclosure of Personal Data to third parties for those third parties’ direct marketing purposes. Halos does not disclose Personal Data to third parties for their direct marketing purposes, so no such request is necessary.

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. The Site does not support Do Not Track requests at this time.

Nevada resident rights

Please note that we do not sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.

Changes to this Privacy Policy

As we continue to build Halos, we may need to change this Privacy Policy from time to time. We will alert you to material changes by posting the updated policy on the Site and revising the date at the top of this page. If you use the Site after changes to this Privacy Policy have been posted, that means you agree to the changes.