Privacy Policy

When you use Halo of Voices, we may collect information you provide directly to us, including your name, email address, account information, profile information, and information you provide when creating or participating in a Halo.

We also collect the content you intentionally add to Halo, including:

• voice recordings and imported audio;
• recording titles, descriptions, dates, and other information associated with voice memories;
• family/member information you choose to provide;
• playlists, favorites, Vault information, invitations, and other content you create within a Halo.

When you invite someone to a Halo, information necessary to create and manage that invitation may also be stored.

We may automatically receive limited technical information necessary to operate and protect Halo, such as device or browser information, IP address, authentication information, application activity, error information, and security or diagnostic information.

We aim to collect only information reasonably necessary to provide, maintain, protect, and improve Halo. This follows the FTC's general guidance to minimize collection and retain information only when there is a legitimate need for it. Federal Trade Commission

Voice memories are at the center of Halo of Voices.

When you record a voice memory or add an existing recording, that audio is transmitted to and stored by the services Halo uses to provide the platform.

Halo does not use your voice recordings to create artificial or cloned voices.

Halo of Voices is designed to preserve and play the real recordings that you and the members of your Halo choose to add.

Voice memories may be made available to other authorized members of the same Halo according to Halo's features, permissions, and the choices made by the people using that Halo.

Content intentionally sealed in the Vault is handled according to the release choices and permissions associated with that Vault memory.

We use information collected through Halo to:

• create and maintain user accounts;
• create and operate Halos;
• store, organize, and play voice memories;
• provide the Library, Vault, Listening Room, playlists, favorites, invitations, and other Halo features;
• manage members and Keeper permissions;
• provide Halo activity and notifications;
• authenticate users and protect accounts;
• maintain the reliability, security, and performance of Halo;
• troubleshoot errors and provide support;
• prevent misuse, fraud, unauthorized access, and abuse;
• comply with applicable legal obligations; and
• administer memberships and payments when paid membership services are available.

We do not use your voice memories for unrelated advertising purposes.

Halo is designed as a private shared environment.

Information and voice memories may be visible to other authorized members of the Halo according to the features and permissions of the service.

For example, members may be able to see information about other members, hear voice memories available within the Halo, see new Halo activity, and interact with shared content.

The Keeper has additional responsibilities and permissions for managing the Halo.

You should only add or share content that you have the right and permission to place in Halo.

Halo relies on service providers to operate the platform. Those providers may process information on Halo's behalf for purposes such as:

• hosting and cloud infrastructure;
• database and file storage;
• authentication;
• secure delivery of voice memories;
• website and application hosting;
• payment processing;
• security and abuse prevention; and
• technical operations and support.

These providers receive information only as reasonably necessary to perform services for Halo, subject to their applicable agreements and privacy obligations.

When payment processing is introduced, payment information may be collected and processed by the payment provider rather than being stored directly by Halo.

We may also disclose information when reasonably necessary to comply with law, legal process, protect the rights or safety of users or others, investigate abuse, or protect Halo and its services.

Halo of Voices does not sell your voice recordings.

We also do not sell personal information for money.

If Halo's practices ever materially change, this Privacy Policy will be updated and any additional notice or consent required by applicable law will be provided. The FTC specifically cautions businesses that material changes to privacy practices can require affirmative permission rather than simply changing policy language. Federal Trade Commission

Halo of Voices is not designed around advertising.

We do not use your private voice memories to target advertisements to you.

If Halo's advertising or data-sharing practices materially change in the future, we will update this Privacy Policy and provide any notices or choices required by applicable law.

We use administrative, technical, and organizational measures designed to protect information handled through Halo.

Your voices stay private within your Halo. Voice memories are transmitted securely, stored privately, and protected by Halo's access controls so only authorized members can access them.

No internet service can guarantee absolute security, but protecting the information entrusted to Halo is an important part of how the service is designed and operated.

The FTC recommends reasonable security measures, limited access, secure storage, and appropriate disposal of information that is no longer needed. Federal Trade Commission

We retain account information, voice memories, Halo information, and related content for as long as reasonably necessary to provide the service, maintain the applicable Halo, fulfill legitimate operational purposes, comply with legal obligations, resolve disputes, and protect the service.

When information is deleted, some information may remain temporarily in backups, logs, or systems where immediate deletion is not technically practical or where retention is legally required.

We do not intend to retain personal information longer than reasonably necessary for the purposes for which it is maintained.

Depending on the features available to you, Halo provides controls for managing your account, profile, Halo membership, recordings, invitations, and other content.

You may also contact us regarding requests to access, correct, or delete personal information associated with your account.

Certain information may need to be retained when required by law, necessary to protect the security and integrity of the service, or otherwise permitted under applicable law.

Depending on where you live and whether applicable legal thresholds are met, you may have additional privacy rights concerning your personal information.

These rights may include the ability to request access to information, request correction or deletion, obtain information about how personal information is used or disclosed, and exercise other rights provided by applicable law.

California, for example, provides qualifying consumers rights that can include knowing, deleting, correcting, and opting out of certain sale or sharing practices. California Attorney General

Halo does not discriminate against users for exercising privacy rights provided by applicable law.

Instructions for submitting applicable privacy requests will be provided through Halo's designated privacy contact method.

Halo of Voices is designed for families, but an account's availability to children and the rules governing their participation must comply with applicable law.

Children's online privacy can trigger additional legal requirements, particularly for services directed to children under 13 or when an operator knowingly collects personal information from children under 13. Federal Trade Commission

Before launch, Halo's final account-age policy and parental-consent requirements will be stated here and in the Terms of Service.

This section should not be finalized until we lock Halo's minimum account age and exactly how children participate in a family Halo.

Halo of Voices is operated from the United States.

If Halo is made available to users outside the United States, their information may be processed or stored in the United States or other locations where Halo or its service providers operate.

Additional privacy rights may apply depending on the user's location.

We may update this Privacy Policy as Halo evolves or as legal requirements change.

When we make changes, we will update the Last Updated date above. If a change materially affects how we handle personal information, we will provide additional notice or obtain consent when required.

Questions about this Privacy Policy or Halo's privacy practices can be directed to:

Halo of Voices

Privacy: [privacy@haloofvoices.com — confirm/create before publication]

Website: haloofvoices.com

Business/legal name: [insert legal entity name]