Last Updated: May 19, 2025

This Privacy Policy describes how Flow Neuroscience Technology Inc. (“Flow”, “we”, “us”, or “our”) handles personal information that we collect when you use our website at https://halo.flowneuroscience.com/, purchase the Halo headset, use the Halo mobile application, or otherwise interact with our services (collectively, the “Service”). The Halo headset is a non-invasive headset designed to support wellbeing. Halo is not approved or cleared by the FDA and is not intended, marketed, or sold to treat or cure any disease or condition. Halo is intended for use by healthy adult individuals.

Please refer to our Consumer Health Data Privacy Policy for additional information about the processing of your consumer health data, and your rights under applicable state data privacy laws with respect to such data.

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.

Personal Information We Collect

Personal information you provide:

• Contact details. When you use our websites or otherwise interact with us, we may collect your first and last name, email and mailing addresses, and phone number.
• Account information. When you create an account, we collect your name, email address, password, and similar account details. 
• Payment and transactional data. When you buy the Halo headset, we collect information needed to complete your transaction (including name, payment card information, billing information, shipping information), and your purchase history. Your payment information is processed by a third-party payment processor, Stripe. Stripe will handle your payment information in accordance with their own privacy policy. We do not have access to your full payment card information. 
• Health information. If you choose to complete in-app questionnaires or assessments, we collect self-reported mood and mental wellbeing data, including your age, lifestyle and habits, medical treatments you have received, stress levels, sleep quality, and other wellness indicators.

 

• Communications that we exchange with you, including when you contact us with questions, feedback or otherwise.
• Marketing data such as your preferences for receiving our marketing communications and details about your engagement with them.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Automatic data collection. We, our service providers and our business partners may automatically log and combine information about you, your computer or mobile device, and your interaction over time with the Services, online resources and our communications, such as:

• Device data such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, general location information such as city, state, or geographic area, duration and frequency of usage of the Halo headset.

• Online activity data such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Services, navigation paths between pages or screens, information about your activity on a page or screen, access times, duration of access, and whether you have opened or otherwise engage with our communications, such as our marketing emails or clicked links or files within them.

We use the following tools for automatic data collection:

• Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, and helping us understand website user activity and patterns. For example, Google Analytics collects information about how users use our websites, which we then use to compile reports that disclose trends without identifying individual visitors, and help us improve our websites. For more information on Google Analytics, click here.
• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.

• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

Third-party sources. We may combine personal information we receive from you with information we obtain from other sources, such as:

• Social media information. We may maintain pages on social media platforms, such as Facebook, Instagram, YouTube, and X (formerly Twitter) that collect and process your personal information in accordance with their own privacy policies. When you visit or interact with our pages on those platforms, you or the platforms may provide us with information through the platform. 

• Other sources. We may obtain your personal information from other third parties, such as marketing partners, data providers, and publicly available sources.

How We Use Personal Information

We use personal information for the following purposes:

Providing our Services. We use personal information to operate, maintain, and provide you with our Services, including to enable you to create and manage your account, fulfill your purchase and process your transactions.

Communicating with you about our Services. We use personal information to respond to your requests, provide user support, and communicate with you about our Services, including by sending announcements, updates, security alerts, and support and administrative messages.

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.

Research and development. We analyze personal 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.

Marketing and advertising:

• Direct marketing. We may send you direct marketing communications as permitted by law, including by email. You may opt-out of our marketing communications as described in the “Opt-out of marketing communications” section below.
• Interest-based advertising. We engage advertising partners to display ads about our services on other online platforms and services. For these purposes, we may use cookies and similar technologies from third-party advertising partners to collect information about your interactions over time with our websites, and use that information to serve online ads to you and others that may be interested in our Services.

Compliance and protection. We may use personal information to comply with legal obligations, and to defend us against legal claims or disputes, including to:

• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements and internal policies;
• enforce the terms and conditions that govern the services;
• prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft; and
• comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.

How We Disclose Personal Information

We may disclose your personal information to certain entities and individuals as outlined below:

• Affiliates. We may disclose your personal information to Flow Neuroscience AB and Flow Neuroscience Ltd, to support operations and ensure smooth delivery of our services.

• Service providers. Companies and individuals that provide services on our behalf or help us operate the Services or our business (such as hosting, information technology, payment processing, order fulfillment and shipping, customer support, email delivery, research and analytics services).

• Professional advisors. Professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.
• Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
• Business transferees. 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, our company (including, in connection with a bankruptcy or similar proceedings).
• Other third parties, where applicable, at your direction or with your consent.

Privacy Rights and Choices

Marketing communications opt-out. You may opt out of marketing-related emails and other communications by following the opt-out or unsubscribe instructions in the communications you receive from us. You may also contact us as provided in the “How to Contact Us” section below to unsubscribe. Even if you opt out of marketing-related communications, you may continue to receive service-related and other non-marketing emails.

Account information. You may update or delete your account information by logging into your account or contacting us.

Personal information requests. We also offer you choices that affect how we handle the personal information that we control. Depending on your location and the nature of your interactions with our services, you may request the following in relation to personal information: 

• Information about how we have collected and used personal information. We have made this information available to you without having to request it by including it in this Privacy Policy.
• Access to a copy of the personal information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, readily usable format.
• Correction of personal information that is inaccurate or out of date.
• Deletion of personal information that we no longer need to provide the Services or for other lawful purposes. 
• Opt out of the sharing of your personal information or use of your information for targeted advertising, by limiting tracking as described below.
• Opt out of “profiling” in connection with decisions that produce legal or similarly significant effects. We do not engage in profiling in connection with decisions that produce legal or similarly significant effects.
• Where applicable, you may withdraw your consent to our processing of your personal information. This won’t affect anything we have used your personal information for before you withdraw your consent.
• Appeal our denial of your personal information request by contacting us as set out in the “How to Contact Us” section below.

To make a request, please email us or write to us as provided in the “How to Contact Us” section below. We may ask for specific information from you to help us confirm your identity. You are entitled to exercise the rights described above free from discrimination.

Limits on your choices. In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. 

Limit tracking. There are a number of ways to limit tracking, which we have summarized below. Please note that these tools are not associated with us and we cannot guarantee that they work as their providers advertise them:

• Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org. Use the following links to learn more about how to control cookies and online tracking through your browser:
  • Firefox; Chrome, Microsoft Edge, Safari (Mac), Safari (Mobile/iOS)

• Using privacy plug-ins or browsers. You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party cookies/trackers.

• Google Analytics. We use Google Analytics to help us better understand how people engage with our websites by collecting information and creating reports about how users use our websites. For more information on Google Analytics, click here. For more information about Google’s privacy practices, click here. You can opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.
• Advertising industry opt-out tools. You can also use these opt out options to limit use of your information for interest-based advertising by participating companies:
  • Digital Advertising Alliance for Websites: outout.aboutads.info  
  • Network Advertising Initiative: optout.networkadvertising.org 
• Platform opt-outs. Some advertising partners offer opt-out features that let you opt out of use of your information for interest-based advertising, including:
  • Google 
  • Facebook 
  • LinkedIn opt-out

 

Please be aware that if you disable or remove tracking technologies some parts of the Service may not function correctly.

Note that because these opt out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Other Sites and Services

Our Services may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third-party. We do not control websites or online services operated by third parties, and we are not responsible for their actions. This Privacy Policy does not apply to such third-party sites or services.

Security

We use reasonable organizational, technical, and administrative measures designed to protect against unauthorized access, misuse, loss, disclosure, alteration, and destruction of personal information we maintain. Unfortunately, data transmission over the internet cannot be guaranteed as completely secure. Therefore, while we strive to protect your personal information, we cannot guarantee the security of personal information.

Children’s Privacy 

Our services are not intended for use by children under 18 years of age. If we learn that we have collected personal information through the services from a child under 18 without the consent of the child’s parent or guardian as required by law, we will delete it.

Retention of Personal Information

Where required under applicable laws, we retain personal information only for as long as is necessary to fulfil the purposes for which it was collected and processed, in accordance with our retention policies, and in accordance with applicable laws and regulatory obligations or until you withdraw your consent (where applicable). 

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, the purposes for which we use personal information and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements. 

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the website or on the app. 

How to Contact Us

If you have any questions or comments about this Privacy Policy or our privacy practices, please contact us by email at support@haloneuroscience.com, or write to us at Flow Neuroscience Technology Inc., Nordic Innovation House, 470 Ramona Street, Palo Alto, CA 94301.