Leave-in scalp spray · 50 ml · paid for once, never renewed · 30 days to return an order

Privacy Notice

Effective date: September 17, 2026

1. Who is responsible for your data

[COMPANY NAME] LIMITED, [REGISTERED OFFICE ADDRESS], Hong Kong, a company incorporated in Hong Kong SAR, is the data user / data controller (and, for California residents, the “business”) for the personal data collected through https://halogrowhq.com (the “Website”). This Privacy Notice explains what we collect, why, who we share it with and what rights you have.

[COMPANY NAME] LIMITED
[REGISTERED OFFICE ADDRESS], Hong Kong
support@halogrowhq.com · +1 (775) 476-1906

The company name and registered office address shown in square brackets are placeholders: the operating company is being registered in Hong Kong SAR and its details will be published on this page as soon as the registration is complete.

2. What we collect and why

  • Order and delivery data — name, delivery and billing address, e-mail address, telephone number, the products you ordered, the price paid and the currency. Used to conclude and fulfil your purchase, deliver the parcel, send order and shipping confirmations and handle returns and refunds. Legal basis (EU/UK): performance of a contract.
  • Payment data — card brand, the last four digits, expiry date and the result of the payment. Your full card number is entered directly with our payment service provider and is not stored by us. Used to take payment and to prevent fraud. Legal basis: performance of a contract and our legitimate interest in preventing fraud.
  • Customer-service data — the content of e-mails, calls and support requests you send us and our replies. Used to answer you and to keep a record of what was agreed. Legal basis: performance of a contract and legitimate interest.
  • Technical and usage data — IP address, approximate country, device and browser type, pages viewed, referring website, campaign parameters in the URL and the identifiers stored in cookies (see section 5). Used to run and secure the Website, measure how it is used and attribute orders to the advertising that led to them. Legal basis: legitimate interest and, where required, your consent.
  • Marketing data — your e-mail address and order history, used to send you information about the product only where you have agreed to it or where the law allows it for existing customers. You can opt out at any time via the link in every e-mail or by writing to us. Legal basis: consent or legitimate interest.

3. Who we share it with, and where

We share personal data only with service providers that need it to deliver what you ordered, and only for the purposes above:

  • our payment service providers and the payment networks (to process your payment and handle chargebacks);
  • our order-management / customer-relationship platform (where orders are recorded and support history is kept);
  • our fulfilment partner and the shipping carriers (name, address, telephone number and e-mail so the parcel can be delivered and tracked);
  • our e-mail service provider (order confirmations, shipping updates and, with your consent, marketing e-mails);
  • our customer-support and order-tracking tools;
  • analytics and advertising-measurement providers (technical and usage data, in aggregated or pseudonymised form where possible);
  • the brand owner and its supplier, to the extent needed to handle product questions, warranty issues or replacements;
  • professional advisers, and authorities where the law requires it.

These providers act on our instructions under written agreements. Your personal data may be stored and processed outside Hong Kong SAR — in particular in the United States, the European Union and other countries where our providers operate. Where EU or UK data is transferred abroad we rely on standard contractual clauses or another lawful transfer mechanism; for Hong Kong data we take reasonable steps to make sure the data is not processed in a way that would contravene the Personal Data (Privacy) Ordinance. We do not sell your personal data.

4. How long we keep it

Order, payment and invoice records: as long as required by accounting and tax law (typically 7 years after the order). Customer-service correspondence: 3 years after the last contact. Technical and usage data: up to 26 months. Marketing data: until you opt out or after 3 years of inactivity. We delete or anonymise data when it is no longer needed for the purpose it was collected for.

5. Cookies and similar technologies

The Website uses cookies and browser storage for three purposes: (a) strictly necessary — keeping your checkout working, remembering the country you are shopping from and protecting the Website against abuse; (b) measurement — understanding which pages are visited and which advertising campaign an order came from; (c) advertising — where enabled, letting advertising platforms recognise that a visit or order came from their advertisement.

You can delete or block cookies in your browser settings; the checkout will still work with strictly necessary cookies only. Where your country requires consent for measurement or advertising cookies, we ask for it before they are set.

6. Your rights

Depending on where you live you can ask us to: access the personal data we hold about you; correct it; delete it; restrict or object to its processing; receive it in a portable format; and withdraw consent you have given (without affecting processing before withdrawal).

Hong Kong — Personal Data (Privacy) Ordinance (Cap. 486, “PDPO”): you have the right to request access to your personal data and to request the correction of data that is inaccurate; we respond to such a request within 40 days and may charge a reasonable fee for access as permitted by the Ordinance. We will not use your personal data in direct marketing without your consent, and you may at any time require us to stop using your personal data in direct marketing, without charge. Complaints may be lodged with the Office of the Privacy Commissioner for Personal Data, Hong Kong.

EU / UK residents (GDPR / UK GDPR): all of the rights listed in the first paragraph apply, and you may lodge a complaint with the supervisory authority of your country of residence.

California residents (CCPA/CPRA): you have the right to know what personal information we collect, use and disclose, to request its deletion or correction, to opt out of the “sale” or “sharing” of personal information (we do not sell personal information; where advertising cookies could count as “sharing”, you can opt out through your browser or by contacting us), and not to be discriminated against for exercising your rights. Residents of other US states with privacy laws have similar rights.

To exercise any right, e-mail support@halogrowhq.com from the address used for your order, or call +1 (775) 476-1906 (we may ask you to confirm your identity). We answer within 30 days, or within the shorter period required by your local law.

7. Security, children and links

We protect personal data with encryption in transit (HTTPS), access controls and reputable service providers, but no transmission over the internet is completely secure. The Website is not directed at children under 16 and we do not knowingly collect their data. Links to other websites are subject to those websites’ own privacy notices.

8. Changes and contact

We may update this Privacy Notice; the current version is always published on this page. Effective date: September 17, 2026.

Questions or requests: support@halogrowhq.com or +1 (775) 476-1906.

[COMPANY NAME] LIMITED
[REGISTERED OFFICE ADDRESS], Hong Kong
support@halogrowhq.com · +1 (775) 476-1906