For residents of the EU, please note that this Policy has been updated in accordance with the requirements of EU General Data Protection Regulation (GDPR). For residents of the US, by visiting, joining, or using LocalHalo, or otherwise indicating that you agree to this Policy, you consent to and authorise our using your personal information as described in this Policy.
When you use LocalHalo there are also expectations for how you must respect and protect the privacy of other members. These are spelt out in our Member Agreement. Please read it. Violating these rules or other aspects of the LocalHalo Member Agreement may lead to a loss of account privileges, potentially including a permanent ban from LocalHalo.
1.0 Who or what is LocalHalo?
LocalHalo is the private social network for neighbourhoods; we hope that neighbours everywhere will use the LocalHalo platform to build stronger and safer neighbourhoods around the world.
We use “LocalHalo” here to refer to the LocalHalo websites and our iOS and Android apps (also referred to as our Services) that provide you with access to that platform. We also use “LocalHalo”, “we”, “us” and “our” to refer to the companies operating our Services.
2.0 Who provides the Services and controls my information?
If you live in the EU, LocalHalo is operated and provided to you by NAY PROTECT LTD, a UK company. For the purposes of EU data protection law, NAY PROTECT LTD is also your data controller.
If you change your place of residence, your information will be dealt with as specified above, according to your new residence from the date on which your place of residence changes.
Our legal bases for collecting, using, sharing and otherwise processing your information
LocalHalo relies on a number of legal bases to collect, use, share, and otherwise process the information we have about you for the purposes described in this Policy. These legal bases include:
- as is necessary to perform the Member Agreement and to provide the Services;
- where you have consented to the processing, which you may revoke at any time;
- for LocalHalo to comply with a legal obligation, a court order, or to exercise and defend legal claims;
- when necessary to protect your vital interests, or those of others;
- where you have made the information manifestly public;
- where necessary in the public interest; and
- where necessary for the purposes of LocalHalo’s or a third party’s legitimate interests, such as those of visitors, members or partners.
3.0 Our legitimate interests
We process your information in furtherance of the following legitimate interests:
- Keeping the Services safe and secure: We use your information as it is necessary to pursue our and our members’ legitimate interests in ensuring LocalHalo is secure, such as by implementing and enhancing security measures and protections, protecting against fraud, spam and abuse, and enforcing our Member Agreement.
- Providing, improving and developing the Services: We use your information to provide the Services, including any personalised services. We do so as it is necessary to pursue our legitimate interests of providing an innovative and tailored offering to our members on a sustained basis.
4.0 Information we collect
When we provide the Services, we collect or receive information in several different ways. In many cases you choose what information to provide, although some information is required in order to use LocalHalo and for us to provide the Services. We use this information for the purposes that are described further below.
Note that not all LocalHalo account types and features are available in all locations, so some of the examples below may not apply where you live.
4.1 From you, or with your permission. We collect a variety of information from you when you provide it to us directly, when we request it from you, or when you give us permission to get it from a third party source. We provide some examples of these below:
- When you register for LocalHalo, you provide your name, address, phone number, profile photo, email address, phone number and similar information.
- If you decide to invite new members to join LocalHalo, you can choose to share their residential or email address or phone number with us, or share your contacts with us, so we can send an invitation and follow-up reminders on your behalf.
- If you want to join LocalHalo but we don’t yet have service for your neighbourhood, you can choose to give us your contact information and ask us to notify you when we do.
- If you use Facebook log in to LocalHalo (or later connect your accounts for example uploading your profile photo), you authorise Facebook to share your personal information with us, including your name and email address.
- If you want to help your neighbours and LocalHalo get to know you better, you may share information about yourself in your profile — your interests, skills, or even what you love about your neighbourhood.
- If you want to connect and communicate with neighbours about specific interests, you may share information about your interests.
- If you want to communicate with your neighbours and share Content (as defined in our member agreement), you might post something on LocalHalo.
- If you want to allow us to show you where you are on your neighbourhood map, to tag your posts, photos and events by location, to verify your address (where available), you can share this in your settings.
- If you contact us with a support request or comments, you provide us with your contact information and a description of the issue so we can respond.
4.2 From your browser and device. Like nearly every other online service, we automatically collect technical information created when you visit or use LocalHalo or read a message from us. We collect information from your browser, computer, or mobile device, which provide us with technical information when you use LocalHalo as a visitor or member, including:
- Device data which tells us about the device you’re using: what type and model it is, its operating system and version, its unique identifier, crash data (if applicable), and what settings you’ve enabled. Your device and software settings affect what information your device makes available to us.
- Log data which is automatically recorded by our servers based on data sent by your app or browser. This typically includes the date and time you visited, the browser or app version you used (and its settings), the URLs you came from and go to, your IP address and protocol, and how you used LocalHalo (for example, which links you clicked on).
4.3 From third parties and public sources. We engage third parties service providers and partners to provide us with information, and we also use publicly-available sources, such as:
- Vendors provide us with map information in order to create and launch new neighbourhoods.
- Advertisers may provide us with information about their users or customers to personalise advertising or measure the performance of their advertisements.
- Public sources, such as census data, street addresses, property lot maps, and postal address change information, provide us with information which helps us understand our members and potential areas for expansion.
- Vendors may provide information about members for advertising analytics, personalisation, and measurement purposes.
5.0 How we use your information
We use the information we have to help us provide, operate, improve, understand, customise, support, and market our Services.
5.1 Establishing and developing neighbourhoods. We use information to identify and invite potential new members, and to set up new LocalHalo neighbourhoods. For example, we use the information we have to identify new members and, if you ask us to, send invitations and reminders on your behalf, send direct-mail invitations, invite your Facebook friends, or notify you when we start offering the Services to your neighbourhood.
5.2 Setting you up on LocalHalo. In order to enable us to operate and provide the Services, we use information to get you started on LocalHalo.
- For residential members, we verify that you live at the address you gave us through a combination of your address and a second factor, such as a code we provide you, the address associated with your credit card or social security number (where permitted by law), manual verification by the member who invited you or by a Lead, or geo-verification if you are offered and choose that option.
- If you sign up via Facebook or connect your accounts, we use your Facebook information to automatically create your LocalHalo account, populate your profile, and request a password, so you can log into LocalHalo in the future without connecting through Facebook.
- Once you register, your personal information is used to populate your profile.
5.3 Provide and improve the Services. We use information to operate LocalHalo and to improve our products and features:
- To highlight popular neighbourhood topics or resources on a neighbourhood’s public home page or an organisation’s public page.
- To select top posts in an area and to deliver and tailor your newsfeed.
- To help support businesses recommended by LocalHalo members.
- To understand the aggregate and anonymised trends, usage statistics, and demographic data of the members and neighbourhoods we serve.
- To respond to your support requests and comments.
- To test and evaluate potential new products and features on LocalHalo.
- To diagnose and resolve problems, analyse trends, and monitor aggregate usage and resource needs.
- For our own marketing activities, such as carrying out analysis to create statistics on and insights into the use of our Services.
5.4 Advertising. We use information to provide and improve advertisements and other commercial offerings:
- To measure whether an advertisement was interesting to members.
- To measure whether an advertisement was effective for the advertiser.
- To help personalise advertisements based on what we think will be of interest to you.
6.0 Your Choices
You have controls over what and how your information is shared and used. We delineate here, the choices you have regarding the sharing and visibility of profile information, location information; as well as your choices about communications, invitations and reminders; how and when your Content is shared; and moving, deactivating and deleting your LocalHalo account.
7.0 Your Rights
You benefit from a number of rights in relation to your information that we process. While some of these rights apply generally, certain rights apply only in certain limited cases. We describe these rights below.
In certain cases, such as for access to, rectification or deletion of your information, please be sure to read the options you have under ‘Your Choices’ section above.
7.1 Access and Porting. You can access much of your LocalHalo information by logging into your LocalHalo account. For EU member accounts, if you require additional access or if you are not currently a LocalHalo member, email us at email@example.com to request a copy of your LocalHalo information. Where legally required, we will provide your information in an easily accessible format and assist in transferring some of this information to third parties.
7.2 Rectify, Restrict, Limit, Delete. You can also rectify, restrict, limit or delete much of your LocalHalo information by logging into your LocalHalo account. If you cannot do this, or you do not have a LocalHalo account, please email us. As described above in ‘Your Choices’, you have a number of options to rectify, restrict, limit or delete your information, including your LocalHalo account.
7.3 Object. If we process your information based on our legitimate interests explained above, or in the public interest and you have an EU member account, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. Where we use your data for direct marketing, you can always object using the unsubscribe link in such communications, changing your account settings or, if you do not have an account, by emailing us.
7.5 Complain. If you have an EU member account and wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority or LocalHalo’s lead supervisory authority, the UK Information Commissioner’s Office.
8.0 Sharing information with third parties
We share information with service providers, affiliates, partners, and other third parties where it is necessary to perform the Member Agreement, to provide the Services, or for any other purposes described in the Policy.
8.1 Sharing Content with neighbours. LocalHalo is a platform for neighbours to share helpful information with each other. To that end, we make the Content you post on LocalHalo, such as posts, replies, messages, and profile information, available to other LocalHalo members based on the preferences in your settings, the preferences on the Content you provide, and as described in this Policy.
8.2 Publicly-available Content. In limited circumstances (for example to highlight popular neighbourhood resources or topics on the neighbourhood’s home page), we may make short snippets of Content available, without your name or other identifying information, to the public (meaning non-members and search engines).
8.3 Marketing and spam. We know that you do not want spam or marketing calls from third parties, so we will never sell or rent your contact information to third parties, and we won’t share it with a third party unless we have your authorisation.
8.4 Advertising. You always have a choice as to whether or how you interact with an advertisement (for example, by replying or “thanking” them or by clicking to learn more about an offer). If you reply to an advertisement or other offer, we may share your reply with the advertiser, and we may log your interaction as part of tracking the overall effectiveness of the advertisement. Our systems are not currently configured to accept browsers’ “Do Not Track” signals, as no industry-wide standard for handling them has been adopted.
8.5 Third party service providers. We may share your personal information to help us operate, provide, improve, understand, customise, support, and market our Services. These third parties are contractually required to use it only to provide their service to us, and contractually barred from using it for their own purposes. (For example, we use a company to help test and analyse the performance of our website and mobile applications.)
8.6 Business re-organisation. In instances where the business is subject to a re-organisation, such as a merger or acquisition of some or all of its assets, we may, in accordance with our legitimate interests, need to share information in the course of the transaction. In such circumstances, your information may be disclosed, where permitted by applicable law, in connection with a corporate restructuring, sale, or assignment of assets, merger, or other changes of control or financial status of LocalHalo.
8.7 Legal and safety reasons. We may retain, preserve, or share your personal information if we have a good-faith belief that it is reasonably necessary to (a) respond, based on applicable law, to a legal request (e.g., a subpoena, search warrant, court order, or other request from government or law enforcement); (b) detect, investigate, prevent, and address fraud and other illegal activity, security, or technical issues; (c) protect our rights, property, or safety; (d) enforce our Member Agreement or any other agreements we have with you; (e) prevent physical injury or other harm to any person or entity, including yourself and members of the general public. Our legal team reviews every request received from law enforcement, and we frequently seek modifications of requests that we believe are procedurally flawed or too broad.
8.8 Aggregated information. We share some aggregated information about our neighbourhoods with government agency members and other organisational members, such as statistics about neighbourhood activity and size. Because of the special role played by government agency accounts, we may provide agency accounts with limited identifying personal information (first name and last initial) for neighbourhood Leads, so that the agency can communicate directly with them.
We may also share aggregated or de-identified information with companies we do business with, including our advertisers as well as government agency members or other organisational members.
9.0 Data retention
We may retain your information in our server logs, our databases and our records for as long as necessary in light of the purposes set out in this Policy, subject to any legal obligations to further retain such information. We may retain your verification-related information for a reasonable period of time, even if you do not complete all verification steps, to assist with future verifications and to prevent abuse of our verification processes. If you decide not to verify the account and would like us to delete the verification information you provided, your can do it here or contact us.
10.0 Additional information
10.1 Account Security. LocalHalo uses technical and organisational measures intended to keep your data secure, including using https on our web pages to reduce the risk of unauthorised interception of your communications during your visits to the website. However, the internet is not a fully secure environment and we cannot guarantee that your personal information won’t be intercepted or improperly accessed. Please ensure that you keep your password and auth tokens safe and do not share it with anyone.
10.2 Other Services and Websites. In using LocalHalo, you may come across links to websites and services operated by third parties (for example, if a member shares a link to a video on YouTube or if an advertiser provides a link to a contest or sweepstakes). These third parties have their own privacy policies, which will apply to your activity if you click on the link and access their website or service. We do not accept any responsibility or liability for such external sites’ privacy and security practices.
10.3 Amendments to the Policy
From time to time we may make changes to this Policy, so please review it periodically. If we materially change our Policy, we will take steps to notify you in advance of the change, for example by emailing you or by posting a notice in your neighbourhood feed. The most up-to-date version of the Policy is available here.
11.0 Contact Us
NAY PROTECT LTD Contact Information
Our Data Protection Officer can be contacted at firstname.lastname@example.org.
Last updated: 2nd April, 2019.