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Last Updated: January 29, 2025

INTRODUCTION

Please read this privacy policy to learn how Halo Dream, Inc. (“HALO Dream”, “we”, “us”, and “our”) collects, uses, protects, and otherwise processes the personal information we collect in the course of providing our products and services (the “Services”), which includes when you visit our Websites that post this privacy policy, including www.halosleep.com and www.adenandanais.com (the “Websites”); use our connected devices, including SleepSure and BassiNest; use our mobile applications, including our HALO mobile application (the “App”); or otherwise interact with us. By using our Services, you agree to this Privacy Policy.

 

INFORMATION WE COLLECT

“Personal information” refers to any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual. The personal information we collect about you depends on your relationship with us. For example, 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, username, 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. 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, or if you contact us for customer support, we collect the information you submit such as your name, contact information, and message. Additionally, when you purchase products from us or in some cases through a third party, we may receive information about your order including your name, email, shipping address, and billing address.

Device Usage 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. [AGG1] Our BassiNest product captures audio sounds of your baby but those sounds are not transferred from your device to our server. 

Geolocation Information. We collect geolocation data when you access our Websites 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 analyze and better understand our customers' needs, preferences, and interests and conduct analysis and research
  • To undertake quality and safety assurance measures and conduct risk and security controls and monitoring
  • To provide information. announcement 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 and internal policies or exercise or defend against legal claims
  • For any other purpose with your consent

We may also aggregate and/or anonymized personal information for statistical and other purposes permitted by law. 

 

HOW INFORMATION IS SHARED

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

  • To our service providers who process personal information on our behalf and subject to restrictions on their use of the data.
  • 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 U.S. state privacy laws (see further information in the YOUR PRIVACY RIGHTS section below).

 

COOKIES AND TRACKING TECHNOLOGIES

We may use cookies to enable our Websites to tailor information to the visitor, to remember a user, to track visits to our Websites, 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 Websites 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.

 

DATA RETENTION

We retain 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 use and disclosure practices outlined in this privacy policy, unless a different retention period is required by applicable law, or otherwise to fulfill a legal obligation or protect our legal rights. We may also maintain indefinitely personal information that has been de-identified. This information is no longer considered personal information and we commit not to attempt to reidentify such information.

 

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.

 

INTERNATIONAL USERS

HALO Dream is located in the United States. Our Website and App are intended for use by individuals in the U.S. If you are located outside the U.S. and use our Services, your personal information will be transferred to the U.S. Note that the personal information protection laws in the U.S. may be less stringent than the laws of the jurisdiction in which you reside, and might permit courts, government, law enforcement agencies, regulatory agencies, and security authorities to access your personal information without notice.

 

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.

 

YOUR PRIVACY RIGHTS

Depending on your jurisdiction of residence, you may have some or all of the privacy rights listed below with respect to the personal information we maintain about you. Please note that these rights are not absolute, may apply only in certain circumstances and, in certain cases, we may decline your request as permitted by law.

  •  Right to Confirm / Access / Know. You may have the right to request access to personal information that we hold about you, including details relating to the ways in which we collect, use, and share your information. Residents of California have the right to know the categories of personal information we have collected about them, the categories of sources from which the personal information is collected, the categories of personal information sold, shared, or disclosed, the business or commercial purpose for selling, sharing, or disclosing the personal information, and the categories of third parties to whom we have sold, shared, or disclosed their personal information. California’s “Shine the Light” law also permits users of our Websites that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes
  •  Right to Delete. You may have the right to request that we delete personal information we maintain about you.
  • Right to Correct. You may have the right to request that we correct inaccurate personal information we maintain about you
  • Right of Portability. You may have the right to receive a copy of the personal information we hold about you and to request that we transfer it to a third party.
  • Right to Withdraw Consent. You may have the right to withdraw your consent to processing of your sensitive personal information.
  •  Right to Opt-Out. You may have the right to opt-out of certain uses of your personal information such as for (i) targeted advertising, (ii) “sale” or “sharing” for cross-context behavioral advertising, or (iii) profiling or automated decision-making activities that result in a legal or similarly significant effect on you. We do not engage in the activities described in (iii), but you can opt-out of uses (i) and (ii) by adjusting your cookies settings to reject performance and targeting cookies. The link to our cookies preference center is available in the Contact Information section at the end of this policy. Additionally, if you visit our Websites with the Global Privacy Control opt-out preference signal enabled, if required by law, this signal will be treated as a request to opt-out of "sale," "sharing," or targeted advertising. Please note your request may apply only to the browser or device from which you submit the request. Learn more about the Global Privacy Control here.
  • Right to Appeal. You may have a right to appeal our decision if we decline to process your request in part or in full. You can do so by replying directly to our denial. If you are not satisfied with our response to your appeal, you may contact your state Attorney General.

Requests to exercise these rights may be made using the contact information listed at the end of this privacy policy, or as otherwise described in this section. Only you, or as permitted by law, a person that you authorize to act on your behalf, may make a request related to your personal information. For certain requests, we must verify your request before we can fulfill it. Verifying your request will require you to provide sufficient information for us to reasonably verify that you are the person about whom we collected personal information or that the requestor is authorized to act on your behalf. We will not discriminate against you for exercising your privacy rights.

 

ADDITIONAL DISCLOSURES FOR CALIFORNIA RESIDENTS

This section provides additional disclosures for residents of California, as required by the California Consumer Privacy Act, as amended (“CCPA”). Please remember that the specific information we collect from you varies based on our relationship with you.

Category Examples Collected? Source Purpose of Collection Categories of Third Parties to Whom Disclosed Categories of Third Parties to Whom Sold/Shared
A. Identifiers. A real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. Yes

Directly from you;

Indirectly from your activity on our Website

To provide our Services;

To respond to requests for information;

To provide you with information and advertisements we believe may be of interest;

To administer and improve our Website and Services

To our service providers so they may help us provide our Services To our analytics and advertising service providers and partners
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, physical characteristics or description, address, telephone number, credit card number, debit card number, or any other financial information, medical information. Yes

Directly from you;

Indirectly from your activity on our Website

To provide our Services;

To respond to requests for information;

To provide you with information and advertisements we believe may be of interest;

To administer and improve our Website and Services

To our service providers so they may help us provide our Services To our analytics and advertising service providers and partners
C. Protected classification characteristics under California or federal law. Sex Yes

Directly from you

To provide our Services To our service providers so they may help us provide our Services None
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. YES

Directly from you;

Indirectly from your activity on our Website

To provide our Services;

To respond to requests for information;

To provide you with information and advertisements we believe may be of interest;

To administer and improve our Website and Services

To our service providers so they may help us provide our Services To our analytics and advertising service providers and partners
E. Biometric information. Sleep or health data. YES 

Directly from you

To provide our Services;

To our service providers so they may help us provide our Services None
F. Internet or other similar network activities.  Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. YES Indirectly from your activity on our Website

To provide our Services;

To respond to requests for information;

To provide you with information and advertisements we believe may be of interest;

To administer and improve our Website and Services
To our service providers so they may help us provide our Services To our analytics and advertising service providers and partners
G. Geolocation data. Physical location or movements. YES Indirectly from your activity on our Website and App

To provide our Services;

To respond to requests for information;

To provide you with information and advertisements we believe may be of interest;

To administer and improve our Website and Services
To our service providers so they may help us provide our Services To our analytics and advertising service providers and partners
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. YES

We record audio of customer care phone calls;

We collect thermal data through our devices
To provide and improve our Services and customer care To our service providers so they may help us provide our Services and customer care None
I. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO N/A N/A N/A N/A
J. Inferences drawn from other personal information. Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. YES We make inferences based on your activity with us as to which products may be of interest to you

To provide you with information and advertisements we believe may be of interest

To our service providers so they may help us provide our Services None
K. Sensitive Personal Information Precise geolocation data as defined in Cal. Civ. Code § 1798.140 YES Indirectly from you as you use our Website or App

To provide our Services;

To administer and improve our Website and Services
To our service providers so they may help us provide our Services None

 

We do not sell or share the personal information of consumers under the age of 16 years old. To the extent we collect sensitive Personal information, we do not use it to infer characteristics about individuals. For information regarding your rights under the CCPA, see the section above titled “YOUR PRIVACY RIGHTS.”

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, or if you wish to no longer receive marketing emails, you may unsubscribe from them using the mechanism in the emails.

 

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.