Privacy Policy

Last updated: April 2, 2023

Our Privacy Policy explains how we manage and safeguard your personal information, including your privacy rights and the applicable legal safeguards.

We might utilise your personal information to improve and optimise your usage of our platform.

Interpretation and Definitions


The words of which the initial letter is capitalised have meanings defined under the following conditions.

The capitalised words in this document carry specific definitions that apply regardless of whether they are used in the singular or plural form.


For the purposes of this Privacy Policy:

You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Halto Major.

  • Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
  • Account means a unique account created for You to access our Service or parts of our Service.
  • Website refers to Halto Major, accessible from https://haltomajor.com/
  • Service refers to the Website.
  • Country refers to: Hong Kong
  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analysing how the Service is used.Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
  • Personal Data is any information that relates to an identified or identifiable individual.Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

During your use of Our Service, we may request that you provide us with certain personally identifiable information that could be used to contact or identify you. This information may encompass, but is not restricted to:

  • Email address
  • First name and last name
  • Phone number
  • Address, State, Province, ZIP/Postal code, City
  • Usage Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data pertains to data that is gathered automatically when you use the Service, including Your device’s Internet Protocol (IP) address, browser type and version, the Service pages you visit, the date and time of your visit, the duration of time spent on those pages, unique device identifiers, and other diagnostic information. This data is collected to enhance the Service and to examine how users interact with it.

The information we collect aids in enhancing the Service and delivering an improved user experience. It may be utilised to diagnose and troubleshoot technical issues, analyse usage patterns, monitor user activity on the site, and gather demographic data on our user base as a whole. Additionally, we may leverage this information to present personalised content and advertisements to You on the Service or on third-party websites that align with your interests and browsing history.

We may obtain data that Your browser automatically transmits whenever You visit our Service, or when You access the Service through a mobile device.

Tracking Technologies and Cookies

We employ cookies and similar tracking technologies to observe the usage of Our Service and retain specific information. Beacons, tags, and scripts are also used as tracking technologies to gather and monitor information, as well as to enhance and analyse Our Service.

You have the option to configure Your browser settings to reject all Cookies or to notify You when a Cookie is being transmitted. However, if You opt-out of Cookies, certain sections of our Service may be inaccessible to You.

Cookies may be categorized as “Persistent” or “Session” Cookies. Persistent Cookies remain on your personal computer or mobile device even when you are offline, while Session Cookies are deleted as soon as You close your web browser.

We use both session and persistent Cookies for the purposes set out below:

We use both session and persistent Cookies for the purposes set out below:
Necessary / Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are critical for furnishing You with services accessible through the Website and for allowing You to use some of its features. They aid in the verification of users and prevent the unauthorized use of user accounts. The services You requested cannot be supplied without these Cookies, and We only utilize them for the purpose of providing You with those services.

Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies determine whether users have given their consent for the use of cookies on the Website.

Functionality Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies permit Us to recall choices that You make while using the Website, such as remembering Your login credentials or language preference. The intent of these Cookies is to furnish You with a more individualised encounter and to prevent You from having to re-enter Your preferences every time You use the Website.

Tracking and Performance Cookies
Type: Persistent Cookies
Administered by: Third-Parties
Purpose: These Cookies are employed to monitor details about traffic to the Website and how users interact with it. The information obtained via these Cookies may identify You directly or indirectly as a particular visitor. This is because the information accumulated is typically associated with a pseudonymous identifier linked to the device that You employ to access the Website. We may also use these Cookies to test new advertisements, pages, features, or functionalities of the Website to gauge how our users respond to them.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Service, including to monitor the usage of our Service.
  • To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
  • To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
  • To manage Your requests: To attend and manage Your requests to Us.

We may share your personal information in the following situations:

  • With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to show advertisements to You to help support and maintain Our Service, to contact You, to advertise on third party websites to You after You visited our Service or for payment processing.
  • For Business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.
  • With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
  • With Business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
  • With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.

Retention of Your Personal Data

Halto Major will store Your Personal Data for only as long as it is essential for the objectives stated in this Privacy Policy. We will retain and utilise Your Personal Data as much as required to adhere to our legal commitments (for instance, if we are required to keep your data to comply with applicable laws), settle disputes, and enforce our legal contracts and policies.

Halto Major may also keep Usage Data for internal analysis purposes. Generally, Usage Data is kept for a shorter period of time, except when it is used to enhance the security or functionality of Our Service, or when We are required by law to keep this data for longer periods of time.

Transfer of Your Personal Data

The processing of your information, including Personal Data, may occur at Halto Major’s operating offices or other locations where the parties involved in the processing are located. This may require the transfer of information to computers situated outside your jurisdiction, including to countries that have different data protection laws than those of your state, province, or country.

By providing your information and agreeing to this Privacy Policy, you consent to such transfers. 

The Company will take reasonable measures to ensure that your data is treated securely and in compliance with this Privacy Policy. This includes implementing adequate controls to protect the security of your data and other personal information during any transfer.

Disclosure of Your Personal Data

Business Transactions

If Halto Major is involved in a merger, acquisition, or sale of all or a portion of its assets, your Personal Data may be included in the assets that are transferred. Before any transfer takes place, we will notify you and obtain your consent, if required by law, and ensure that any new entity or third party that receives your Personal Data will handle it in accordance with this Privacy Policy.

Law enforcement

Under certain circumstances, Halto Major may be obligated to disclose your Personal Data if required by law or in response to valid requests from public authorities, such as a court or government agency.

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

Security of Your Personal Data

The protection of your Personal Data is significant to us. However, it’s important to note that there’s no 100% secure method of transmitting or storing data electronically over the internet. Although we make every effort to use commercially acceptable means to secure your Personal Data, we cannot guarantee its complete security.

Detailed Information on the Processing of Your Personal Data

Service Providers are only allowed to access your Personal Data for the purpose of performing their duties on behalf of Halto Major. They are required to keep your Personal Data confidential and are not allowed to disclose or use it for any other purpose.


We may enlist the services of third-party service providers to monitor and analyze how our Service is being used.

Email Marketing

We may use your Personal Data to send you newsletters, marketing or promotional materials, and other information that may be of interest to you. If you no longer wish to receive these communications, you can opt-out by following the unsubscribe link or instructions provided in any email we send you or by contacting us directly.

We may use Email Marketing Service Providers to manage and send emails to You.


We may offer products or services for purchase through the Service. If you choose to make a purchase, we may use third-party services for payment processing, such as payment processors.

We will not store or collect your payment card details. Instead, this information will be provided directly to our third-party payment processors, who will use your personal information in accordance with their own privacy policies. These payment processors are required to comply with the standards set by the PCI Security Standards Council and adhere to the requirements of PCI-DSS, which help to ensure the secure handling of payment information.

Their Privacy Policy can be viewed at https://stripe.com/us/privacy

Children’s Privacy

Our Service is designed for use by individuals who are at least 16 years old. We do not knowingly collect personal information from anyone under 16 years of age. If you are a parent or guardian and you believe that your child has provided us with personal information, please contact us. If we become aware that we have collected personal information from a child under the age of 16 without parental consent, we take steps to remove that information from our servers.

We may impose limitations on the collection, use, and storage of information of users aged between 13 and 18. This may result in certain features or functionalities of the Service being unavailable to these users.

If we need to use consent as a legal basis for processing your information and your country requires parental consent, we may ask for your parent’s consent before collecting and using that information.

Links to Other Websites

Our Service may include links to other websites that are not operated by us. If you click on a link from a third-party website, you will be redirected to that third-party site. We highly recommend that you read and review the privacy policies of every website you visit.

We do not have any authority or responsibility over the content, privacy policies, or actions of third-party websites or services, and we are not liable for any damages or losses that may arise from Your use of such sites or services.

Changes to this Privacy Policy


We may update or change this Privacy Policy at any time, and any revisions or modifications will take effect immediately once we post the updated Privacy Policy on our website.

We will inform you about any significant changes to this Privacy Policy by prominently displaying a notice on our website or by sending an email to the email address you have provided us.

We recommend that you review this Privacy Policy regularly to stay informed about how we protect your information. If we make any changes to this Privacy Policy, we will notify you by posting a prominent notice on our website or by sending an email to the email address you provided to us. Your continued use of our website or services after any changes to this Privacy Policy indicates your acknowledgement of the updated Privacy Policy and your agreement to comply with its terms.

Contact Us

If you have any questions about this Privacy Policy, You can contact us: