Privacy Policy
Overview
Last updated: October 14, 2026.
Halo Online Technology Co., Ltd. is committed to protecting your privacy. We do not collect browsing history, traffic content or DNS queries as VPN browsing activity logs. Network privacy is distinct from account information, purchase records, advertising identifiers and connection diagnostics described in this policy.
This Privacy Policy describes how Halo Online Technology Co., Ltd. and its affiliates ("we," "our" or "us") collect, use, and share information in connection with your use of our websites, services, and applications (collectively, the "Services"). This Privacy Policy (the "Privacy Policy") applies to all of our Services, but does not apply to third-party websites, products, or services that you may access through our Services.
VPN traffic protection does not remove identifiers used by websites or accounts you sign in to. Free app access includes advertising. Advertising and diagnostic SDKs may process device identifiers, interactions and diagnostics according to the app version and your permissions. Refer to the app store privacy disclosure as well as this policy.
1. Collection of Information
We collect information about the products and services that you use and how you use them in order to provide the core features of our service, to improve our service, or to offer additional features such as value-added services and promotions. Some of the typical reasons that we collect personal data include:
1.1 Provide our product and services, including our app and related website (if any), and improve them over time;
1.2 Allow you to download and purchase products and services;
1.3 Personalize and manage our relationship with you, including introducing you to products or services that may be of interest to you or to provide customer support;
When you open the APP seeking for our VPN services, the APP assigns a unique identifier to you for the service (such unique identifier just binds up with your device identification code, but does not tie to any other personal information of users). When you use the VPN services, we will check your account information through this unique identifier to determine the level of service you have signed up for before establishing your VPN connection.
If you contact us directly, we may receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide. We may also receive a confirmation when you open an email from us.
Account Information and Privacy Tools
Basic VPN use does not require creating an account. Account tools, linked entitlements and certain privacy-tool operations require sign-in and may require a paid plan. Not requiring registration does not mean that advertising or diagnostic identifiers are absent.
If you create an account in HaloVPN Pro, we collect: (a) Email address (Email sign-in) or anonymized Apple Private Relay email (Sign in with Apple); (b) Name, if you choose to share (Sign in with Apple, Sign in with Google); (c) User ID for cross-device subscription synchronization; (d) Authentication credentials such as session tokens and password hashes (we never store plaintext passwords).
Third-party sign-in: HaloVPN Pro supports Sign in with Apple, Sign in with Google, and Email sign-in. When you use third-party sign-in, the third party (Apple, Google) shares limited account information with us according to your authorization on their consent screen. We do not have access to your third-party account beyond what is shared during sign-in.
Account deletion: HaloVPN Pro users can delete their account at any time from Settings → Account → Delete Account inside the app. Account deletion removes all stored account data within 30 days, except records we are required by law to retain (such as financial transaction records for tax compliance).
Subscription Data
When you purchase a HaloVPN Premium or HaloVPN Pro subscription, we process: (a) purchase history and subscription status from Apple App Store / Google Play, used to determine your service tier and entitlements; (b) Apple appAccountToken or Google obfuscatedAccountId — device-bound identifiers (derived from device UUID, not tied to personal identity) used to link in-app purchases to your device.
We do not have access to your payment instrument (credit card, PayPal, etc.). All payments are processed by Apple App Store or Google Play directly. We only receive purchase confirmations and entitlement status from these payment providers.
2. Use of Information
We will be able to use the information collected to 1) improve and develop our products and services; 2) communicate with users; 3) support advertising and related activities. For example:
2.1 Maintain, improve or manage our services, perform business analysis, provide advertising and related activities
2.2 Implement our Terms of Service to prevent illegal activities and abuse of services, protect the legal rights, property and security of VPN services and users and resolve related disputes;
2.3 Comply with applicable laws and assist law enforcement when we believe it is reasonable and meets applicable legal standards.
3. Data Retention
We may retain information about you and your use of the Services, including personally identifiable information, as long as you are required to provide the services and uses described in this Privacy Statement. This usually means that we will retain information for the duration of your account.
4. Security Measures
We take adequate protective measures to prevent loss of information, misuse, unauthorized access, disclosure, alteration or destruction. While we strive to protect your information and privacy, there is no guarantee that data transfer or storage is 100% secure.
5. Your Rights and Legal Basis under GDPR
Halo Online is committed to user privacy globally, and keeping personal information under users' control with minimal data collection is our existing practice. In accordance with the General Data Protection Regulation (GDPR) of the European Union (EU), we collect and process the personal data of EU users in the manner outlined in this Privacy Policy, on one of the following legal bases, depending on the circumstances:
5.1 For the purposes of fulfilling our contractual obligations to users.
5.2 For a legitimate interest associated with the operation of our business, including: (a) enhancing the quality, reliability, and effectiveness of our VPN Services and Apps; (b) communicating with customers to provide information and seek feedback related to our VPN services and Apps.
You can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent. As well, you have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the "unsubscribe" or "opt-out" link in the marketing emails we send you.
You can exercise your rights under the GDPR to access, transfer, correct, delete, or object to the processing of your personal information by contacting us at [email protected].
6. International Data Transfers
Halo Online is a global business. We may transfer personal information to countries other than the country in which the data was originally collected. These countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your personal information to other countries, we will protect that information as described in this Privacy Policy.
7. Changes to This Privacy Policy
To remain consistent with applicable privacy laws and principles, this Privacy Policy may be modified from time to time, so please review it frequently. Your continued use of our VPN services constitutes your acceptance of our Privacy Policy. Changes to this Privacy Policy will be posted on our websites. If we materially change the ways in which we use or share personal information previously collected from you through our VPN services, we will notify you through our app, email, or other communication.
8. California Privacy Rights (CCPA)
If you are a California resident, the California Consumer Privacy Act (CCPA) provides you with the following rights:
8.1 Right to Know — You may request what personal information we have collected about you over the past 12 months.
8.2 Right to Delete — You may request deletion of your personal information, subject to legal retention exceptions.
8.3 Right to Opt-Out of Sale — HaloVPN does not sell personal information to third parties. There is nothing to opt out of.
8.4 Right to Non-Discrimination — We will not discriminate against you for exercising any of your CCPA rights (e.g., we will not deny service, charge different prices, or provide a lower-quality service).
To exercise these rights, contact us at [email protected] with the subject "CCPA Request". We will respond within 45 days as required by law.
9. Children's Privacy
HaloVPN is intended for users who are at least 13 years of age (or the minimum digital consent age in your country, whichever is higher). We do not knowingly collect personal information from children under 13.
If you believe that a child under 13 has provided us with personal information, please contact us at [email protected] and we will promptly delete such information.
Website Analytics and Connection Diagnostics
Website Analytics is disabled until you accept the optional analytics category. Firebase / Google Analytics may use cookies and browser identifiers to process page visits, platform download clicks and related technical information. The website does not send passwords, OAuth authorization codes, account tokens or authenticator seeds as analytics event parameters. You can change your choice using Cookie preferences in the footer.
App connection diagnostics may include connection attempts, failure reasons, app version, network type and approximate country to help investigate availability. These diagnostics are distinct from browsing-history or traffic-content logs. Free app advertising has separate SDK processing and store privacy disclosures.
Email aliases and authenticator features process the data needed for forwarding, encrypted storage, synchronization and recovery. Access depends on the configured account, unlock method and applicable permissions. An email relay does not make all email end-to-end encrypted; do not send secret seeds or recovery codes to support.
10. Contact Information
For questions about this Privacy Policy, to exercise any of your rights described above, or to report concerns about data privacy, you may contact us at:
Email: [email protected]
Operator: Halo Online Technology Co., Ltd.
We will respond to your inquiry within a reasonable time frame (typically within 30 days for GDPR requests, 45 days for CCPA requests).