Secure App Privacy Policy

1. Who we are

Halo Secure is published on Google Play by:

SPACE DATA CENTRES LTD is the data controller responsible for personal information processed through Halo Secure.

Road Angel is a trading brand used in connection with the app, GPS tracker, subscriptions and related support services.

In Phase International Ltd and other authorised Road Angel Group service providers may process relevant information on our behalf when providing customer support, installation administration, subscription support, monitoring or recovery services.

2. Scope of this policy

This policy applies to:

• The Halo Secure Android application;
• Package name com.roadangelgroup.tracking;
• Halo Secure accounts;
• Road Angel GPS trackers linked to Halo Secure;
• Halo Secure maps, alerts, journey history and sharing functions;
• Related subscription and customer-support services; and
• Updated or replacement versions of Halo Secure that link to this policy.

This policy does not apply to an unrelated third-party service that you choose to access from Halo Secure. That service will have its own privacy information.

3. What access, collection and sharing mean

For the purposes of this policy:

• Access: means the app can display, read or use information relating to your account, phone or connected Road Angel GPS tracker.
• Collection: means information is transmitted to SPACE DATA CENTRES LTD or to an authorised service provider acting on our behalf.
• Sharing: means information is made available to another organisation or to another authorised Halo Secure user.
• Tracker location: means location and journey information generated by the separate Road Angel GPS tracking device linked to your account.

4. Information Halo Secure processes

Complete payment-card information is handled by the relevant payment provider. Halo Secure does not ordinarily receive or store your full card number.

5. Where the information comes from

We receive information from:

• You, when you create or manage an account, name a device, create a geofence, invite another user or contact support;
• Your Road Angel GPS tracker, which transmits tracker identifiers, precise location, journey and device-status information;
• The Halo Secure app, which provides app, phone, diagnostic, security and push-notification information;
• Installers, retailers or vehicle partners, where they register or install a tracker on your behalf;
• Payment and subscription systems, which confirm whether an applicable service is active; and
• Authorised service providers, where they assist with hosting, mapping, notifications, customer support, monitoring or vehicle recovery.

6. How and why we use information

Halo Secure does not use precise tracker-location information for unrelated advertising or sell that information to data brokers.

7. Precise location and journey information

7.1 Where vehicle location comes from

The vehicle location displayed in Halo Secure is generated by the separate Road Angel GPS tracker linked to the account.

The tracker can continue to generate and transmit location and device-status information while the Halo Secure app is closed because the installed tracker operates independently of the phone.

7.2 How location is used

Tracker location may be used to provide:

• Live or recent vehicle position;
• Journey and route history;
• Speed, time, direction and distance information;
• Geofence entry and exit alerts;
• Movement, towing or other security alerts where supported;
• Authorised tracker sharing;
• Theft monitoring and recovery support where included in the plan;
• Customer support and fault investigation; and
• Lawful police, insurer or emergency-service assistance.

7.3 Sharing tracker location

An account holder may invite another person to view a tracker. The account holder controls which people are invited and must remove access when it is no longer appropriate.

Shared users must only use location information for an authorised and lawful purpose.

7.4 Phone location permissions

Tracker journey history is created from the installed GPS tracker rather than by continuously tracking the location of the user’s phone.

If a version of Halo Secure requests access to the phone’s location for a separate map or setup feature, the app will explain the purpose immediately before requesting the Android permission. Refusing an optional phone permission will not change the location already generated by the connected GPS tracker.

8. Who may receive information

We do not sell personal information.

Relevant information may be provided to:

• In Phase International Ltd and authorised Road Angel Group personnel providing operational or customer support;
• Cloud-hosting and secure data-storage providers;
• Mapping and location-service providers;
• Push-notification providers;
• Authentication, cybersecurity and fraud-prevention providers;
• App diagnostic and crash-reporting providers;
• Mobile-network and tracker-connectivity providers;
• Customer-support and CRM providers;
• Authorised installers, retailers and vehicle partners;
• Monitoring centres and vehicle-recovery providers where included in the customer’s service;
• Insurers or fleet operators where the customer has authorised the arrangement;
• Other Halo Secure users invited by the account holder;
• Police, courts, regulators, emergency services and other lawful authorities;
• Solicitors, accountants, auditors and professional advisers; and
• A purchaser or successor if all or part of the relevant business is sold or reorganised.

Service providers acting on our behalf may only use information for the agreed service and are subject to appropriate confidentiality, security and contractual controls.

Where you deliberately share tracker access with another Halo Secure user, that person will be able to see the information made available through the permission you grant.

9. How we protect information

We use technical and organisational security measures designed to protect Halo Secure and tracker information against accidental loss, unauthorised access, misuse, alteration or disclosure.

Measures include, where applicable:

• Encrypted transmission of personal and sensitive information;
• HTTPS/TLS protection for internet communications;
• Protected passwords and account-authentication controls;
• Role-based access permissions;
• Access logging and security monitoring;
• Network, server and infrastructure controls;
• Secure software-development and change-management processes;
• Vulnerability and incident-management procedures;
• Supplier due diligence and contractual controls;
• Staff confidentiality and data-protection training;
• Backup and recovery controls; and
• Physical security at relevant premises.

No online service can guarantee absolute security. You should use a strong, unique password, protect access to your phone and contact us immediately if you believe your Halo Secure account has been compromised.

10. International data transfers

Some hosting, mapping, notification, diagnostic or technical providers may process information outside the United Kingdom or European Economic Area.

Where required, we use a legally recognised protection such as:

• UK adequacy regulations;
• European Commission adequacy decisions;
• The UK International Data Transfer Agreement;
• The UK Addendum to the European Commission Standard Contractual Clauses;
• Standard Contractual Clauses; or
• Another lawful transfer safeguard.

You may ask us for further information about the safeguard relevant to your information.

11. How long we retain information

We keep information only for as long as reasonably necessary for the purpose for which it was collected, the applicable service plan, legal requirements, security, complaints and legal claims.

When information is no longer needed, it will be securely deleted, anonymised or restricted where immediate deletion is not technically possible.

12. Your Halo Secure controls

12.1 Tracker sharing

The account holder can control authorised users and remove another person’s access when it is no longer required.

12.2 Geofences and alerts

You can create, amend or remove geofences and manage available notifications through Halo Secure.

12.3 Notifications

You can control app notifications through Halo Secure and your phone settings. Disabling notifications may prevent movement, security, geofence or device-status alerts from reaching your phone.

12.4 Account information

You can update qualifying profile and account information through available account settings or by contacting customer support.

12.5 Marketing

Halo Secure location information is not used for third-party behavioural advertising.

Where you separately receive Road Angel marketing, you can unsubscribe using the link in the message or by contacting us.

13. How to delete your Halo Secure account and data

13.1 Information to provide

Please include:

• Your full name;
• The email address registered to Halo Secure;
• Your telephone number, if registered;
• The tracker serial number, if available; and
• Whether you want the entire Halo Secure account deleted or only specified information.

We may request reasonable information to verify your identity and prevent unauthorised deletion.

13.2 Information normally deleted

Subject to lawful retention requirements, deletion will include:

• Your Halo Secure profile and account credentials;
• Your app preferences;
• Push-notification tokens linked to your account;
• Tracker access linked only to the deleted account;
• Geofences created through your account;
• Invited-user and tracker-sharing permissions;
• Identifiable location and journey history associated with the account;
• Identifiable app-activity and diagnostic information; and
• Other personal information that is no longer required.

13.3 Information that may be retained

Limited information may be retained where necessary for:

• Tax and accounting obligations;
• Fraud prevention and account security;
• An active theft or vehicle-recovery incident;
• An insurance claim, complaint or dispute;
• A police, court or regulatory requirement;
• The establishment, exercise or defence of legal claims;
• Product safety or warranty evidence; or
• A legal obligation requiring continued retention.

Retained information will be restricted to the relevant purpose and will not be retained for normal Halo Secure use.

13.4 Processing time

We will normally complete a valid deletion request within one month after receiving the information reasonably needed to verify it.

A permitted extension may apply where a request is particularly complex or numerous. We will explain any applicable extension.

13.5 Subscriptions

Simply uninstalling Halo Secure does not delete the account or information already stored in connection with the service.

14. Your data-protection rights

Depending on the circumstances and applicable law, you may have the right to:

• Request access to personal information held about you;
• Request correction of inaccurate information;
• Request completion of incomplete information;
• Request deletion of qualifying personal information;
• Request restriction of processing;
• Object to processing based on legitimate interests;
• Object to direct marketing;
• Withdraw consent where processing relies on consent;
• Request transfer of qualifying information;
• Request information about international-transfer safeguards; and
• Complain to a data-protection authority.

These rights are subject to applicable conditions and exemptions.

To exercise a right, email privacy@roadangelgroup.com .

15. Lawful use of GPS tracking

Halo Secure and Road Angel GPS trackers must only be used for a lawful and authorised purpose.

The account holder is responsible for ensuring that:

• The tracker is installed in a vehicle or on property that the account holder is legally entitled to monitor;
• Drivers, employees, family members or other affected people receive appropriate notice where required;
• A lawful basis exists for collecting and viewing location information;
• Tracker access is only granted to people who are authorised to receive it;
• Another user’s access is removed when it is no longer required; and
• Location information is not used to harass, intimidate or unlawfully monitor another person.

We may suspend or terminate access where we reasonably believe Halo Secure is being used unlawfully, fraudulently or in a way that places another person at risk.

16. Children

Halo Secure is not directed at children under 16 and is intended to be managed by an adult account holder or an authorised business user.

We do not knowingly create accounts for children under 16 or intentionally collect their account information without an appropriate lawful basis and, where required, parental or guardian involvement.

Contact us if you believe that a child has created an account or supplied personal information without appropriate authority.

17. Changes to this policy

We may update this policy where Halo Secure, our GPS tracker services, technology, suppliers or legal obligations change.

The latest version will be published on this page with a revised update date.

Where a change materially affects how personal information is used, we may also provide an appropriate notice by email, through Halo Secure or through the customer account.

18. Contact details and complaints

Please contact us first if you have a concern about how Halo Secure uses your information.

You also have the right to complain to the UK Information Commissioner’s Office: ico.org.uk/make-a-complaint .

If you are located in the European Economic Area, you may also complain to the data-protection authority in the country where you live or work.