1. Who we are
This Privacy Policy is issued by Halogen Systems Inc. ("Halogen Systems," "we," "us," or "our"), a Nevada corporation with principal offices at 8985 Double Diamond Pkwy, B10, Reno, NV 89521, United States. We are the controller of personal information collected through our websites at halogensys.com and halogensystems.com (together, the "Sites"), our customer portals, and our products and services (collectively, the "Services").
2. Information we collect
2.1 Information you provide to us
- Contact and inquiry information — name, email address, phone number, company name, job title, and any message or content you submit through our contact forms, quote requests, or gated content downloads.
- Account information — credentials and identifying information you provide when registering for a customer portal, the Where's My Stuff order-tracking tool, the sales rep portal, or training services.
- Transaction information — billing and shipping addresses, purchase orders, RMA requests, payment references, and related correspondence. We do not collect or store full payment card numbers; payments are processed by third-party payment processors.
- Support and communications — records of your communications with us, including support tickets, emails, recorded calls (where lawful and disclosed), and messages submitted through chat or feedback tools.
- Marketing preferences — your subscription status for newsletters or product updates, and your interactions with our marketing emails (opens, clicks).
2.2 Information collected automatically
- Device and connection data — IP address, browser type and version, operating system, device type, language preferences, referring URL, and timestamps.
- Usage data — pages viewed, links clicked, time spent, navigation paths, search queries, and downloads.
- Session recording and heatmaps — through Microsoft Clarity we collect anonymized recordings of how visitors interact with our Sites (mouse movements, scrolling, clicks, page navigation). Clarity masks form inputs and personally identifying text by default. You can opt out via our cookie consent banner.
- Cookies and similar technologies — see our Cookie Policy for the full list of cookies we use and how to manage them.
2.3 Information from third parties
We may receive information about you from business partners, sales representatives, distributors, public sources (such as utility procurement records), data enrichment providers (such as ZoomInfo), and social media platforms when you interact with us through them.
2.4 Sensitive information
We do not intentionally collect sensitive personal information (such as government IDs, financial account numbers, health information, biometric data, or precise geolocation). Please do not submit such information to us through our forms or communications.
3. How we use your information
We use personal information for the following purposes:
- To respond to your inquiries, quote requests, and support tickets.
- To provide, operate, and maintain our products, portals, and Services.
- To process orders, ship products, manage RMAs, and provide order tracking.
- To send you transactional communications (order confirmations, shipping updates, service notices) and, where you have opted in or where permitted by law, marketing communications about our products, technical content, and events.
- To analyze how our Sites and Services are used, troubleshoot technical issues, and improve user experience and content quality.
- To protect the security of our Sites, prevent fraud, enforce our Terms, and comply with legal obligations.
- To conduct internal business operations, including accounting, audits, and reporting.
4. Legal bases for processing (EEA, UK, and Switzerland)
If you are located in the European Economic Area, the United Kingdom, or Switzerland, we rely on the following legal bases under the GDPR and equivalent laws:
- Consent — for non-essential cookies, session recording, and marketing emails. You may withdraw consent at any time.
- Performance of a contract — to fulfill orders, deliver products, provide portal access, and respond to support requests.
- Legitimate interests — to operate our Sites, secure our Services, communicate with business contacts, and pursue business development consistent with your reasonable expectations.
- Legal obligation — to comply with tax, accounting, export-control, and other applicable laws.
5. How we share your information
We do not sell your personal information. We share information with the following categories of recipients, only as needed:
- Service providers that process information on our behalf, including:
- HubSpot (CRM, contact forms, email marketing)
- Google LLC (Google Analytics, Google Ads, Google Workspace)
- Microsoft Corporation (Microsoft 365, Microsoft Clarity)
- Vercel Inc. (website hosting and analytics)
- Oracle NetSuite (ERP, order management)
- FedEx and UPS (shipment tracking and delivery)
- Sanity.io (content management — when activated)
- Fireflies, Canva, Notion, monday.com, Stripe, and similar business tools we use to operate
- Authorized distributors and sales representatives in your region, where necessary to respond to your inquiry or fulfill an order.
- Professional advisors — legal counsel, accountants, auditors, and insurers.
- Acquirers — if Halogen Systems is involved in a merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of that transaction, subject to standard confidentiality protections.
- Government and legal authorities — when required by law, court order, subpoena, or to protect our rights, property, or safety, or that of others.
6. International data transfers
Halogen Systems is based in the United States and many of our service providers operate in the United States and other countries. If you access our Sites or Services from outside the United States, your information will be transferred to, processed in, and stored in the United States and potentially other jurisdictions.
For transfers of personal information from the European Economic Area, the United Kingdom, or Switzerland to the United States or other countries that have not been recognized as providing an adequate level of data protection, we rely on appropriate safeguards, including the European Commission's Standard Contractual Clauses (SCCs) and the UK International Data Transfer Addendum, supplemented by additional technical and organizational measures where required.
7. How long we keep your information
We retain personal information only as long as necessary for the purposes set out in this Policy, including:
- Inquiries and leads — generally up to 36 months from your last interaction with us, after which we delete or anonymize the data unless we have an ongoing business relationship.
- Customer records — for the duration of our business relationship plus the period required by applicable tax, warranty, and accounting laws (typically 7 years).
- Marketing data — until you unsubscribe or otherwise object, plus a short suppression-list retention to honor your opt-out.
- Web analytics and session recordings — generally up to 14 months (Google Analytics) and 1 year (Microsoft Clarity).
- Legal and compliance records — for the period required by applicable law.
8. Your rights
Depending on your location, you may have the following rights with respect to your personal information:
- The right to access the personal information we hold about you.
- The right to correct inaccurate or incomplete information.
- The right to deletion (subject to legal and contractual retention requirements).
- The right to restrict or object to processing.
- The right to data portability.
- The right to withdraw consent at any time.
- The right to lodge a complaint with a supervisory authority.
To exercise these rights, contact us at info@halogensys.com. We will respond within the period required by applicable law (generally 30 days). We may need to verify your identity before fulfilling your request.
9. California residents (CCPA / CPRA)
If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA):
- Right to know — what categories and specific pieces of personal information we have collected about you, the sources, the purposes, and the categories of third parties with whom we have shared it.
- Right to delete — your personal information, subject to legal exceptions.
- Right to correct — inaccurate personal information.
- Right to opt out of "sale" or "sharing" — for cross-context behavioral advertising. We do not sell personal information for monetary consideration. We may "share" limited information with advertising partners (such as Google and LinkedIn) for advertising purposes; you may opt out via the cookie consent banner or by emailing info@halogensys.com.
- Right to limit use of sensitive personal information — we do not use sensitive personal information beyond what is permitted under the CCPA.
- Right to non-discrimination — we will not deny services, charge different prices, or provide a different quality of service because you exercised your rights.
You may submit a verifiable consumer request by emailing info@halogensys.com with the subject line "California Privacy Request." Authorized agents may submit requests with proof of authorization.
10. "Do Not Track" signals
Some browsers offer a "Do Not Track" signal. There is no industry consensus on how to respond to these signals; we do not currently change our practices in response to DNT signals. We honor Global Privacy Control (GPC) signals where required by law.
11. Children
Our Sites and Services are not directed to children under 16, and we do not knowingly collect personal information from children. If you believe we have inadvertently collected information from a child, please contact us and we will delete it.
12. Security
We use commercially reasonable technical and organizational measures designed to protect personal information against unauthorized access, disclosure, alteration, or destruction. These measures include encryption in transit (TLS), access controls, employee training, rate limiting, and ongoing security review. No system is perfectly secure, however, and we cannot guarantee absolute security.
13. Third-party links
Our Sites may contain links to third-party websites and services that we do not control. We are not responsible for the privacy practices of those third parties. Please review their privacy policies before providing them with personal information.
14. Changes to this Policy
We may update this Privacy Policy from time to time. We will post the revised Policy on this page with a new "Last updated" date. If we make material changes, we will provide additional notice (such as a banner on our Sites or an email to registered users). Your continued use of the Services after the effective date constitutes your acceptance of the revised Policy.
15. Contact and complaints
If you have questions, concerns, or complaints about this Privacy Policy or our handling of your personal information, contact our privacy team:
Halogen Systems Inc.
Attn: Privacy Team
8985 Double Diamond Pkwy, B10
Reno, NV 89521, USA
Email: info@halogensys.com
Phone: +1 (775) 832-0495
EEA/UK residents may also lodge a complaint with their local data protection supervisory authority. We are not currently required to designate an EU representative, but we will cooperate with supervisory authorities as required by law.