Privacy Policy

Version 2.0


This privacy policy applies between you, the User of this Website and Halo Mobile Ltd, the owner and provider of this Website. Halo Mobile Ltd takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website.

Please read this Privacy Policy carefully and ensure that you understand it. You will be required to read and accept this Privacy Policy when signing up for an Account. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.




1. Definitions and Interpretation In this Policy, the following terms shall have the following meanings:


1.1 In this Cookie Policy, unless the context otherwise requires, the following expressions have the following meanings:


"Account"

means an account required to access and/or use certain areas and features of Our Site;

"Cookie"

means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below

"Cookie Law"

means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

"Personal Data"

means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the Data Protection Act 1998 or after 25th May 2018 EU Regulation 2016/679 - the General Data Protection Regulation ("GDPR")

"We/Us/Our"

means Halo Mobile Ltd, a limited company registered in England and Wales under registration number 08877709 and located at Second Floor, Jordan House, Hall Court, Hall Park Way, Telford, Shropshire TF3 4NF. Our VAT Number is 179704960.




2. Information About Us


2.1 Our Site is owned and operated by Halo Mobile Ltd, a limited company registered in England and Wales and whose registered address is located at Second Floor, Jordan House, Hall Court, Hall Park Way, Telford, Shropshire TF3 4NF.


2.2 Our Data Protection Officer can be contacted by email at dataprotection@sunshinemobile.co.uk, or by post at the address above.


2.3 We are registered with the Information Commissioner's Office and our Data Protection Licence number is ZA120987.




3. What Does This Policy Cover?


3.1 This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.




4. Your Rights


4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:


  • 4.1.1 The right to be informed about Our collection and use of personal data;
  • 4.1.2 The right of access to the personal data We hold about you (see section 12);
  • 4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
  • 4.1.4 The right to be forgotten i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);
  • 4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
  • 4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
  • 4.1.7 The right to object to Us using your personal data for particular purposes; and
  • 4.1.8 Rights with respect to automated decision making and profiling.


4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK's supervisory authority, the Information Commissioner's Office.


Information Commissioner's Office
Wycliffe House,
Water Lane,
Wilmslow,
SK9 5AF


Telephone: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number.


4.3 For further information about your rights, please contact the Information Commissioner's Office or your local Citizens Advice Bureau.




5. What Data Do We Collect?


Depending upon your use of Our Site, We may collect some or all of the following personal and non-personal data (please also see section 13 on Our use of Cookies and similar technologies):


    5.1 name;

    5.2 gender;

    5.3 business/company name (if applicable);

    5.4 address;

    5.5 job title;

    5.6 contact information such as email addresses and telephone numbers;

    5.7 IP address;

    5.8 web browser type and version;

    5.9 operating system;

    5.10 last 5 digits of payment card;

    5.11 a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;




    6. How Do We Use Your Data?


    6.1 Personal Data about our customers is an important part of our business and we shall only use your Personal Data for the following purposes and shall not keep such Personal Data longer than is necessary to fulfil these purposes:


    • 6.1.1. To help us to identify you when you contact us.
    • 6.1.2. To help us to identify accounts, services and/or products which you could have from us or selected partners from time to time. We may do this by automatic means using a scoring system, which uses the Personal Data you have provided and/or any information we hold about you and Personal Data from third party agencies (including credit reference agencies).
    • 6.1.3. To help us to administer and to contact you about improved administration of any accounts, services and products we have provided before, do provide now or will or may provide in the future
    • 6.1.4. To allow us to carry out marketing analysis and customer profiling (including with transactional information), conduct research, including creating statistical and testing information.
    • 6.1.5. To help to prevent and detect fraud or loss.
    • 6.1.6. To allow us to contact you in any way (including mail, telephone, visit, text or multimedia messages) about products and services we have provided before or do provide now or may provide in the future.
    • 6.1.7. We may monitor and record communications with you (including phone conversations and emails) for quality assurance and compliance.
    • 6.1.8. We may check your details with fraud prevention agencies. If you provide false or inaccurate information and we suspect fraud, we will record this

    6.2. We will not disclose your Personal Data to any third party except in accordance with this Privacy Policy.

    6.3. We may allow other people and organisations to use Personal Data we hold about you in the following circumstances:


    • 6.3.1. If we, or substantially all of our assets, are acquired or are in the process of being acquired by a third party, in which case Personal Data held by us, about our customers, will be one of the transferred assets.
    • 6.3.2. If we have been legitimately asked to provide information for legal or regulatory purposes or as part of legal proceedings or prospective legal proceedings.
    • 6.3.3. We employ companies and individuals to perform functions on our behalf and we may disclose your Personal Data to these parties for the purposes set out in clause 2.1 or, for example, for fulfilling orders, delivering packages, sending postal mail and email, analysing data, providing search results and links (including paid listings and links), processing credit and debit card payments and providing customer service. Those parties are bound by strict contractual provisions with us and only have access to Personal Data needed to perform their functions, and may not use it for other purposes. Further, they must process the Personal Data in accordance with this Privacy Policy and as permitted by the General Data Protection Regulations. From time to time, these other people and organisations to whom we may pass your Personal Data may be outside the European Economic Area. We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy and GDPR.

    6.4. Where you give us Personal Data on behalf of someone else, you confirm that you have provided them with the information set out in this Privacy Policy and that they have not objected to such use of their Personal Data.


    6.5. In connection with any transaction which we enter into with you:

    • 6.5.1. We, and other companies in our group, may carry out credit and fraud prevention checks with one or more licensed credit reference and fraud prevention agencies. We and they may keep a record of the search. Information held about you by these agencies may be linked to records relating to other people living at the same address with whom you are financially linked. These records will also be taken into account in credit and fraud prevention checks. Information from your application and payment details of your account will be recorded with one or more of these agencies and may be shared with other organisations to help make credit and insurance decisions about you and members of your household with whom you are financially linked and for debt collection and fraud prevention. This includes those who have moved house and who have missed payments.
    • 6.5.2. If you provide false or inaccurate information to us and we suspect fraud, we will record this and may share it with other people and organisations. We, and other credit and insurance organisations, may also use technology to detect and prevent fraud.
    • 6.5.3. If you need details of those credit agencies and fraud prevention agencies from which we obtain and with which we record information about you, please write to our Data Protection Manager at PO Box 790, Hall Court, Hall Parl Way, Telford, TF7 9GA.
    • 6.2.1 Providing and managing your Account;
    • 6.2.1 Providing and managing your access to Our Site/Portal;
    • 6.2.3 Personalising and tailoring your experience on Our Site/Portal;
    • 6.2.4 Supplying Our software and services to you (please note that depending upon how your company is structured, We may require some personal data in order to enter into a contract with you);
    • 6.2.5 Personalising and tailoring Our software and services for you;
    • 6.2.6 Replying to emails from you;
    • 6.2.7 Market research;
    • 6.2.8 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;

    6.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email and/or telephone and/or post with information, news and offers on Our products and/or services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.


    6.4 Any Third parties content which may appear on Our Site from time to time may use third party Cookies, as detailed below in section 13. Please refer to section 13 for more information on controlling Cookies. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.


    6.5 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.


    6.6 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):


    • 6.6.1 Personal data will only be retained as long as we are under contract by you or your company, or considered to still be in communication with each other pending the formation of a new contract;



    7. How and Where Do We Store Your Data?


    7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.

    7.2 Your data will only be stored in the UK.

    7.3 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.

    7.4 We reveal only the last five digits of your credit card numbers when confirming an order. Of course, we transmit the entire credit card number to the appropriate credit card company during order processing.




    8. Do We Share Your Data?


    8.1 Subject to section 8.4, We will not share any of your data with any third parties for any purposes.


    8.2 We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In all of these cases however, the third parties will not have access to any of your data.


    8.3 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.


    8.4 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.




    9. What Happens If Our Business Changes Hands?


    9.1 We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.


    9.2 In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will not, however, be given the choice to have your data deleted or withheld from the new owner or controller.




    10. How Can You Control Your Data?


    10.1 In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. As we only use any personal data that you give us for the purpose of managing your account and as required by contract. We will not be using your data for marketing purposes.




    11. Your Right to Withhold Information


    11.1 You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.


    11.2 You may restrict Our use of Cookies. For more information, see section 13 and Our Cookie Policy.




    12. How Can You Access Your Data?


    You have the right to ask for a copy of any of your personal data held by Us (where such data is held. Under the GDPR, no fee is payable, and We will provide any and all information in response to your request free of charge. Please contact Us for more details at dataprotection@sunshinemobile.co.uk, or by using the contact details below in section 14.




    13. Our Use of Cookies


    13.1 Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products and services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.


    13.2 All Cookies used by and on Our Site are used in accordance with current Cookie Law.


    13.3 Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.


    13.4 Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be "strictly necessary". These Cookies are shown below in section 13.6. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser's settings as detailed below in section 13.10, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.


    13.5 The following first party Cookies may be placed on your computer or device:

    Name of Cookie Purpose & Type Expires After Strictly Necessary
    phpsessid Tracking user navigation around site 24 hours No

    13.6 Our Site uses analytics services provided by Google. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the products and services offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.


    13.7 The analytics service(s) used by Our Site use(s) Cookies to gather the required information.


    13.8 The analytics service(s) used by Our Site use(s) the following Cookies:


    Name of Cookie Purpose & Type Provider Expires After Strictly Necessary
    _ga Analytics - used to distinguish users Google 2 Years No
    _gid Analytics - used to distinguish users Google 24 hours No
    _gat Analytics - used to throttle request rate. Google 1 minute No
    AMP_TOKEN Contains a token that can be used to retrieve a Client ID from AMP Client ID service Google 30 seconds to 1 year No

    13.9 In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.


    13.10 You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.


    13.11 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.




    14. Contacting Us


    If you have any questions about Our Site or this Privacy Policy, please contact Us by email at dataprotection@sunshinemobile.co.uk, or by post at Second Floor, Jordan House, Hall Court, Hall Park Way, Telford, Shropshire TF3 4NF. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 12, above).




    15. Changes to Our Privacy Policy


    We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.