Last Updated: May 19, 2025

This Consumer Health Data Privacy Policy explains how Halo collects, uses, shares, and protects “consumer health data” as defined under applicable U.S. state laws, and the privacy rights and choices you have with respect to such data. This Consumer Health Data Privacy Policy supplements our Privacy Policy.

We can assure you Halo and our Service do not:

• Read your mind, track your thoughts, or measure your brain activity.

• Collect any data from your brain or nervous system.

• Monitor, record, or analyze brainwaves or neural data.

• Rather, the headset merely applies a preset stimulation program. It does not collect any data.

Any information you share—like how you’re feeling, your mood and progress —is actively input by you directly through questionnaires in the app

• Categories of Consumer Health Data We Collect

We collect the following categories of consumer health data:

• Individual health conditions, treatment, diseases, or diagnosis. We collect self-reported information about your mental wellbeing through in-app questionnaires. This may include data related to your mood, stress levels, energy, or sleep quality. Although we do not diagnose medical conditions, this information may reflect aspects of your mental health or perceived wellbeing and may be considered indicative of a health condition.
• Social, psychological, behavioral, and medical interventions. Through your responses and interactions with the app, we may collect information that reflects psychological or behavioral wellness strategies—such as the use of meditation, exercise, sleep routines, or mood tracking—recommended as part of your personalized wellness plan. These features are intended to support mental wellness and self-care, not to treat or cure medical conditions.

• Health-related surgeries or procedures. We do not request or require information about past or planned medical procedures or surgeries. However, if you choose to voluntarily share such details in open-text questionnaire fields or feedback, that information may be processed and stored as part of your account data.

• Bodily functions, vital signs, symptoms, or measurements of the information. You may provide information related to your physical state—such as symptoms (e.g., fatigue, restlessness), sleep quality, or daily energy levels—through your responses in the app. 
• Any inferences of the above categories of health data derived or extrapolated from non-health information. We may draw limited inferences about your wellbeing based on how you interact with the Halo app and headset—for example, session frequency or engagement. While this data is not health information on its own, it may suggest wellness needs (e.g., stress support). These inferences are used only to personalize your in-app experience and are not used or shared for advertising or promotional purposes.

• Categories of Sources of Consumer Health Data

We collect consumer health data directly from you when you use the Halo headset and app. This includes information you provide through in-app wellness questionnaires, self-assessments, and any optional feedback you choose to submit. We may also derive limited health-related inferences from your usage patterns—such as how frequently you engage with the app or specific features—to personalize your experience. 

• Purposes For Which We Collect And Use Consumer Health Data

We collect and use consumer health data as provided below:

• To process your requests or respond to your inquiries. This includes assessing whether an individual is eligible for a Headset in response to your request or inquiry.
• Personalizing your experience and wellness recommendations. We analyze your self-reported mood, mental wellbeing assessments, and usage patterns to:
  • Tailor wellness suggestions (e.g., when and how often to use the headset)
  • Provide individualized encouragement or progress tracking based on how your reported mood evolves
  • Recommend relevant in-app content (such as exercises, educational materials, or reminders) that aligns with your stated goals or areas of focus (for example, managing stress, improving sleep, or boosting energy), to support your personal wellness journey.
  • Customize app interface and notifications based on usage behavior, for example, highlighting your progress or sending reminders to help you get back on track if you haven’t used the app for a while.
• For research and development purposes, including to analyze and improve our products and services. As part of these activities, we analyze information, such as general usage patterns, feature engagement, and questionnaire response trends, to understand how users interact with the Halo headset and app. This helps us identify what features are most helpful, detect potential technical issues, and continuously improve the effectiveness, usability, and design of our Services. When we share insights outside our organization (for example, in aggregated reports or research), we do so only in anonymized or de-identified form that does not identify individual users.
• For compliance and protection, including to comply with legal obligations, defend against legal claims or disputes, protect the security and integrity of our products and services, and identify and investigate fraudulent, harmful, unauthorized, unethical, or illegal activity.
• At your direction or with your consent, if you choose to provide consumer health data to us for any other purpose, as disclosed at the time you provide such information.

• Disclosures of Consumer Health Data

We may disclose the categories of consumer health data described above to:

• Our affiliates Flow Neuroscience AB and Flow Neuroscience Ltd, to support operations and ensure smooth delivery of our services.

• Processors or service providers, who assist us in providing products and services to you, such as hosting, research, and analytics. 
• Authorities and others, such as law enforcement, government authorities, and private parties, where we believe in good faith to be necessary or appropriate to comply with the law or protect our legitimate interests.
• Business transferees, such as acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Flow (including, in connection with a bankruptcy or similar proceedings).
• Other third parties, where applicable, at your direction or with your consent.

• Your Rights

Depending on your location, you may request the following in relation to your consumer health data:

• Confirm whether we are collecting, sharing, or selling your consumer health data, and to access your consumer health data.
• Delete your consumer health data.
• Withdraw your consent from our collection or sharing of your consumer health data.

How to submit requests. Please contact us at support@haloneuroscience.com. You are entitled to exercise the rights described above free from discrimination.

 

Appeal. If your request to exercise a right under consumer health data privacy laws is denied, you may appeal that decision by emailing us at support@haloneuroscience.com. If your appeal is unsuccessful, you can raise a concern or lodge a complaint with the Washington State Attorney General at www.atg.wa.gov/file-complaint, or other regulatory authority as applicable. 

 

• Changes to This Consumer Health Data Privacy Policy

We reserve the right to modify this Consumer Health Data Privacy Policy at any time. If we make material changes to this Consumer Health Data Privacy Policy, we will notify you by updating the date of this Consumer Health Data Privacy Policy and posting it on our website or app. If required by law we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email or another appropriate manner. Any modifications to this Consumer Health Data Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of our services after the effective date of any modified Consumer Health Data Privacy Policy indicates your acceptance of the modified Consumer Health Data Privacy Policy.