Privacy Policy

Effective Date: September 29, 2026

Halogen Ltd. ("Halogen," "we," "us," or "our") respects your privacy. This Privacy Policy describes how we collect, use, retain, and protect personal information through our website, www.halogenltd.com (the "Website"), and in connection with our vehicle sales, consignments, and related business activities.

This Privacy Policy also describes privacy rights available to California residents under the California Consumer Privacy Act, as amended ("CCPA"), to the extent the CCPA applies to Halogen.

Business Contact Information

Halogen Ltd.
71 Glenn Way, Unit 2
San Carlos, CA 94070
Email: hello@halogenltd.com

1. Information We Collect

We collect information that you voluntarily provide to us, information collected automatically when you use our Website, and information collected in connection with transactions and other business relationships.

Information You Provide to Us

Depending on how you interact with Halogen, we may collect:

  • Name and contact information, such as your email address, telephone number, and mailing address;

  • Information you provide when submitting an inquiry through our Website;

  • Information contained in communications between you and Halogen;

  • Information provided when purchasing, selling, or consigning a vehicle;

  • Information contained in purchase agreements, consignment agreements, invoices, title and registration documents, and other transaction records;

  • Vehicle-related information, including vehicle identification numbers, mileage, ownership history, service information, and other information relating to a vehicle;

  • Payment and transaction information necessary to complete a transaction; and

  • Other information you voluntarily provide to us in connection with our business.

In connection with certain transactions, we may also collect information contained in government-issued identification documents or other information necessary to verify identity, ownership, authorization, or eligibility to complete a transaction.

We collect only information that is reasonably necessary for the purposes described in this Privacy Policy or otherwise permitted or required by law.

Information Collected Automatically

When you visit our Website, certain information may be collected automatically through the Website and its underlying technology.

Our Website is hosted on Squarespace. We use Squarespace's standard website functionality and analytics tools. Depending on your browser, device, and Website interaction, these technologies may collect information such as:

  • IP address;

  • Browser and device type;

  • Operating system;

  • Pages visited;

  • Date and time of visits;

  • Referring website or page;

  • General information about how visitors interact with the Website; and

  • Other technical information necessary for Website operation and analytics.

The Website may use cookies and similar technologies for essential Website functions, security, and analytics. Cookie behavior can vary depending on the Website configuration, your browser, and Squarespace's current technology.

Halogen does not intentionally use advertising pixels, behavioral advertising trackers, or similar technologies for cross-context behavioral advertising.

2. How We Use Personal Information

We may use personal information for the following purposes:

  • Responding to questions and inquiries;

  • Communicating with customers, prospective customers, vehicle owners, and consignors;

  • Providing information about vehicles and our services;

  • Facilitating vehicle purchases and sales;

  • Managing vehicle consignments;

  • Preparing and performing contracts and other agreements;

  • Processing transactions and payments;

  • Maintaining business and transaction records;

  • Verifying identity, ownership, and authorization when reasonably necessary;

  • Complying with applicable laws, regulations, legal obligations, and governmental requests;

  • Protecting our Website, business, customers, and property from fraud, misuse, or unauthorized activity;

  • Maintaining and improving our Website; and

  • Understanding general Website usage through standard analytics.

Information submitted through the Website for an inquiry is used to respond to that inquiry and for related business communications. We do not use Website inquiry information for unrelated advertising campaigns.

3. How We Share Personal Information

Halogen does not sell personal information.

Halogen does not share personal information for cross-context behavioral advertising.

We may disclose personal information when reasonably necessary to operate our business, including:

  • To service providers that assist us in hosting, operating, maintaining, or analyzing our Website;

  • To payment processors, financial institutions, title and registration services, or other providers when necessary to complete a transaction;

  • To professional advisers such as attorneys, accountants, or other advisers where reasonably necessary;

  • To governmental agencies or law enforcement when required or permitted by law;

  • In connection with a legal claim, investigation, or dispute; or

  • In connection with a merger, acquisition, sale, reorganization, or other transfer of some or all of our business or assets.

Service providers and contractors that process personal information on our behalf are expected to use that information only for the purposes for which it was provided or as otherwise permitted by law.

4. Cookies and Analytics

Our Website uses Squarespace as its hosting and website platform.

Squarespace and the Website may use cookies and similar technologies to provide essential Website functions, maintain security, and provide standard analytics concerning Website traffic and usage.

Halogen does not use cookies for the purpose of selling personal information or providing cross-context behavioral advertising.

You may be able to control or disable certain cookies through your web browser settings. Disabling certain cookies may affect Website functionality.

Because the specific technologies used by Squarespace may change over time, the categories and purposes of individual cookies may also change.

5. Personal Information Collected in the Preceding 12 Months

During the preceding 12 months, Halogen may have collected the following categories of personal information, depending on how an individual interacted with us:

CategoryExamplesPurposeIdentifiersName, email address, telephone number, mailing addressCommunication, transactions, customer recordsCommercial informationVehicle purchase, sale, or consignment information; transaction recordsProviding services and completing transactionsInternet or other electronic network activityIP address, browsing activity, Website interactionWebsite operation, security, analyticsGeolocation informationGeneral location information that may be associated with an IP addressWebsite analytics and securityProfessional or employment-related informationInformation voluntarily provided in connection with a business transactionBusiness communications and transactionsFinancial informationPayment or transaction information necessary to complete a transactionProcessing transactionsInferencesLimited information that may be derived from Website interactions or business communicationsWebsite analytics and business operationsSensitive personal information, where applicableInformation contained in identification or transaction documents when reasonably necessaryIdentity verification, transaction processing, legal compliance

We do not collect every category listed above from every person. The categories collected depend on the nature of the individual's interaction with Halogen.

We do not use or disclose sensitive personal information for purposes that are not reasonably necessary and proportionate to providing our services, completing transactions, maintaining security, or other purposes permitted by applicable law.

6. Retention of Personal Information

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to:

  • Provide services and complete transactions;

  • Maintain appropriate business and transaction records;

  • Comply with legal, tax, accounting, licensing, and regulatory requirements;

  • Resolve disputes and enforce agreements;

  • Detect and prevent fraud or other misuse; and

  • Protect our legitimate business interests.

The appropriate retention period depends on the nature of the information and the reason it was collected. Transaction and contractual records may be retained for longer periods when required or reasonably necessary for legal, accounting, tax, regulatory, warranty, or dispute-resolution purposes.

When personal information is no longer reasonably necessary for these purposes, we may delete, destroy, or de-identify it, subject to applicable law and legitimate business requirements.

7. California Privacy Rights

The following section applies to California residents to the extent the CCPA applies to Halogen.

California law provides certain consumers with rights concerning their personal information. Depending on the circumstances and applicable legal requirements, these rights may include:

Right to Know

You may have the right to request information about:

  • The categories of personal information we have collected about you;

  • The categories of sources from which the information was collected;

  • The purposes for collecting or using the information;

  • The categories of third parties to whom personal information is disclosed; and

  • The specific pieces of personal information we have collected about you, subject to applicable exceptions.

Right to Delete

You may have the right to request deletion of personal information that we have collected from you.

This right is subject to exceptions under applicable law. For example, we may retain information when necessary to complete a transaction, provide a service, comply with a legal obligation, maintain certain business records, protect against fraud or security incidents, or for other purposes permitted by law.

Right to Correct

You may have the right to request correction of inaccurate personal information that we maintain about you.

Right to Opt Out of Sale or Sharing

You may have the right to opt out of the sale or sharing of your personal information.

Halogen does not sell personal information and does not share personal information for cross-context behavioral advertising. Accordingly, Halogen does not provide a "Do Not Sell or Share My Personal Information" mechanism for a practice that it does not conduct.

Right to Limit Use of Sensitive Personal Information

California residents may have the right to limit certain uses or disclosures of sensitive personal information.

Halogen does not use or disclose sensitive personal information beyond purposes reasonably necessary and proportionate to the purposes for which it was collected, or other purposes permitted by applicable law.

Right to Non-Discrimination

You have the right not to receive discriminatory treatment for exercising privacy rights provided by applicable California law.

We will not deny goods or services, charge different prices, or provide a different level or quality of service solely because you exercised a privacy right, except as permitted by law.

8. How to Submit a Privacy Request

To submit a request concerning your California privacy rights, contact us at:

Email: hello@halogenltd.com

Mail:
Halogen Ltd.
Attn: Privacy Request
71 Glenn Way, Unit 2
San Carlos, CA 94070

Please clearly identify the nature of your request and provide sufficient information for us to reasonably verify your identity.

We may need to request additional information to verify that the person making a request is the consumer about whom we maintain personal information. We will use information provided in connection with a privacy request for purposes of verifying and responding to the request.

Where required by applicable law, we will provide additional methods for submitting privacy requests.

We generally respond to verifiable consumer requests within the time periods required by applicable law. If additional time is permitted and reasonably necessary, we will notify you of the extension.

9. Verification of Requests

To protect personal information from unauthorized disclosure or deletion, we may need to verify your identity before completing certain requests.

The verification process may depend on the nature of the request and the sensitivity of the information involved.

We will not require you to provide information that is unnecessary to reasonably verify your identity.

If we cannot reasonably verify your identity, we may be unable to fulfill certain requests, as permitted by applicable law.

10. Authorized Agents

Where permitted by California law, you may designate an authorized agent to submit a privacy request on your behalf.

We may require appropriate documentation establishing the agent's authority to act on your behalf and may independently verify your identity as permitted or required by law.

11. Children's Privacy

Our Website and services are not directed toward children under 13 years of age.

We do not knowingly collect personal information from children under 13 through the Website. If we learn that we have collected personal information from a child under 13 without appropriate authorization, we will take reasonable steps to delete it.

12. Security

We take reasonable measures designed to protect personal information against unauthorized access, disclosure, alteration, or destruction.

No method of transmitting or storing information electronically is completely secure, and we cannot guarantee absolute security.

13. Third-Party Websites

Our Website may contain links to third-party websites, including websites where vehicles may be advertised or discussed.

Those websites operate independently of Halogen and have their own privacy practices and policies. This Privacy Policy does not apply to information collected directly by third-party websites.

We encourage you to review the privacy policies of any third-party websites you visit.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our business practices, Website technology, legal requirements, or other circumstances.

When we make material changes, we will update the effective date at the top of this Privacy Policy and take any additional steps required by applicable law.

15. Contact Us

If you have questions about this Privacy Policy or Halogen's privacy practices, please contact us:

Halogen Ltd.
71 Glenn Way, Unit 2
San Carlos, CA 94070

Email: hello@halogenltd.com