Privacy Policy

Halo Consulting knows that your privacy is important to you and takes user privacy very seriously. We are committed to protecting your personal data in accordance with this Privacy Policy.

Privacy Policy

Last updated on 28 March 2023

This Privacy Policy applies to the website “Site” provided by Halo Consulting (“Halo”, “We”, “Us”), a company headquartered in Johannesburg, Gauteng, South Africa, who act as data controllers[1] with respect to the personal data you share with Halo under this Policy.

The Sites include www.haloconsulting.co.za and additional websites or mobile applications produced and managed by Halo.

Halo knows that your privacy is important to you and takes user privacy very seriously. We are committed to protecting your personal data[2] (i.e. any information you provide to us from which you can be identified) in accordance with this Privacy Policy.

Halo reserves the right, at its sole discretion, to alter and update this Privacy Policy from time to time. We therefore invite you to review the current version of the Privacy Policy each time you return to our Sites.

Some terms are defined throughout this Policy. Please refer to the definitions at the bottom of this Policy.

Information we collect and how we use it

Halo might collect personal data from you such as your name, contact details, occupation, company or university affiliation, industry, region/country, relationship to Halo, reason for contacting Halo, topics you are interested in and any other information you choose to share. By browsing our Sites or sending us information, you explicitly consent to Halo processing your personal data in accordance with this Privacy Policy. Halo might use your personal data to fulfil your request, send you marketing communications or process your job application.

Halo collects personal data from you when you request information from Halo and/or supply, information through the Sites, such as when you fill out a query form or consulting contact request, opt in to receive emails from Halo, agree to participate in surveys, or apply for a role at Halo.

Personal data we collect might include your name, e-mail address, title, occupation, company or university affiliation, industry, region/country, relationship to Halo, reason for contacting Halo, topics you are interested in, any other background information provided with an application and any other information contained in messages you send us.

We might also collect information about how you use our Sites in accordance with our Cookie Policy. 

By browsing our Sites and submitting this information to us, you explicitly agree to Halo using your personal data for the purposes and in the manner described in this Privacy Policy. Please do not send us any information you do not wish Halo to use.

Halo will use your personal data to fulfil your request, provide you with the information you requested and/or send you marketing communications. If you have applied for a job at Halo, your data will be processed for the purposes of evaluating and processing your application and candidacy for the position to which you have applied. We may also use your information to analyze and improve our recruiting and onboarding processes as well as to communicate with you about Halo events and to send you publications that we think may be of interest to you. More detail can be found in the Job Applicants section.

Halo may collect personal data and may disclose such information to third party service providers in aggregate for marketing and promotional purposes. However, in these situations, we do not disclose to these entities any information that could be used to personally identify you.

You do not have to provide us with any personal data.  However, if you do not, we may be unable to handle your request or to provide you with the services you are requesting.

Halo will keep your personal data for as long as needed to handle your request or for as long as we have a relationship with you. If you have applied for a role with Halo, Halo will keep your personal data associated with your application for a period of up to five years.

Please note that Halo is not responsible for any information you may disclose publicly in any chat rooms, message boards, or similar web pages, including those hosted on or linked to our Sites. You should keep in mind that, whenever you publicly disclose information about yourself online (for example, via message boards or chat rooms), such information could be collected and used by people whom you do not know. In addition, certain message boards and similar user forums may display IP addresses along with the message poster’s name and message. Halo bears no responsibility for any action or policies of any third parties who collect any information users may disclose on the message boards, chat areas or other user forums, if any, on the Sites.

 

Use of Cookies on the Sites

We may use cookies or other technology (“cookies”) to obtain certain types of information when you browse our Sites. You can find information about what data is collected and how it is used in our Cookie Policy.

Who we share your data with

We may share your personal data with third parties that might be located in a different country than your country of residence. Halo will not share or sell your data to any third party for their own use.

We may share your personal data with others, such as:

  • Carefully selected third party service providers, such as marketing service providers (if you have subscribed to our marketing communications), IT systems providers, recruitment service providers, background check providers, data cleansing providers or event organizers, so they can provide services to Halo;
  • our advisors; and
  • law enforcement authorities or other government bodies when we are required to do so.

 

Third parties, other than law enforcement authorities or government bodies, will only handle your personal data on behalf of Halo for the purposes described in this Policy. Halo will not sell or otherwise share your personal data with such third parties for their own use.

The third parties we share your information with may be located in other countries, including countries that do not offer the same protection to your personal data as the country in which you reside. Where that is the case, Halo ensures that your personal data is protected by using appropriate legal mechanisms. If you reside in the European Union, such mechanisms include using contracts or wording approved by the European Commission (called “Standard Contractual Clauses”)[3].

 

Links to Other Websites

Our Sites may contain links to third party websites that are governed by their own terms and privacy policies. Halo does not bear any liability and responsibility for the content or your use of these websites.

The Sites may contain links to third party websites, including social network sites. Such websites are governed by their own terms of use and privacy policies, which you should review before browsing or submitting information to them. Halo is not responsible for the privacy practices of such websites. In addition, a link to a third party website does not mean that Halo endorses or accepts any responsibility for the content or the use of such website. Halo shall not bear any liability and responsibility for such content or for your use of these websites.

Security of your data

Halo has implemented appropriate technical and organizational security measures in order to protect your personal data from loss, misuse, alteration, or destruction.

Halo has implemented appropriate technical and organizational security measures in order to protect your personal data from loss, misuse, alteration, or destruction. Such measures include anonymizing [4] or pseudonymizing[5] data where possible. Authorized Halo personnel and third parties mentioned above will only have access to your personal data to the extent they need it to do their job or provide their services. Despite these precautions, however, Halo cannot guarantee that unauthorized persons will not obtain access to your information.

Your Rights

Depending on where you reside you might have the right to request access to, rectification or erasure of your personal data and to object to or ask for the restriction of the processing of your personal data. You might also have the right to withdraw your consent and request that we stop processing or delete your personal data.

To exercise your rights, please submit to info@haloconsulting.com with the subject line “Data rights”.

Depending on where you reside, you may be entitled to certain rights regarding the personal data Halo holds about you. For instance, you may have the right to request access to your information, obtain a copy of it as well as information about how we use it. You have the right to request that we correct incorrect, inaccurate or out-of-date information about you. You may also have the right to request that we stop processing your information and/or withdraw your consent to such processing and to ask us to delete your information.

In the event that Halo holds personal data about you and you no longer wish for this data to be processed as described in this Policy, or if you wish to access, rectify, cancel or oppose such processing, please submit your request using our data subject request process detailed in the section above.

If you receive marketing communications from Halo, you can opt out of receiving future emails from Halo or unsubscribe from participating in our programs through the by clicking “unsubscribe” which is accessible in every marketing email you receive from Halo. You can also submit an opt-out request by using our data subject request process detailed in the section above.

If you think we are handling your information unlawfully, we encourage you to get in touch with us using our data subject request process detailed in the section above. You may also have the right to lodge a complaint with your national supervisory authority.

Please note that we will take reasonable steps to check your identity before handling your request.

Job Applicants

If you apply for a job at Halo, you will be asked to submit information to Halo such as your name, contact details, information about your education and work history and any other background information that might be relevant for your application or that you choose to share with Halo. If you do not provide this information to us, we might not be able to process your application.

Halo will use this information to assess your application and candidacy for the position to which you have applied. Without limiting the generality of the foregoing, this may include: (i) evaluating your skills and experience in relation to the qualification required for the job to which you have applied; and (ii) tracking feedback and interactions we have with you throughout the recruiting process. We may also use your information when analyzing our internal recruiting processes to determine (i) which recruit sources to focus on; (ii) how to improve integration and training programs for new hires with different educational backgrounds and work experience; and (iii) how to enhance our interview model to improve hiring quality. The information you provide may also be used to communicate with you about Halo events and to send you publications that we think may be of interest to you.

We might share your personal data with third parties such as recruitment service providers, background check providers and IT system providers. These third parties might be located in a different country than your country of residence. In particular, if you apply for a role, your data will be stored in a third party database hosted in the EU.

We will keep your application data for up to five years. If you no longer wish for Halo to process your data or if you wish to exercise your rights, use our data subject request process detailed in the section above.

Children 

Our Sites and services are not directed at children 18 years of age or younger. Halo, therefore, will not intentionally collect information about anyone under the age of 18, and requests that no such information be submitted to us.

 

Contact Us

If you have any questions about this Privacy Policy or how Halo handles your personal data, please use our data subject request process detailed in the section above.

You can also contact Halo’s Data Protection Officer:

Email:  info@haloconsulting.co.za

 

Country Specific Information – South Africa

Data Retention and the POPIA Act:

The POPIA act of 2013 Section 14 stipulates that:

“records of personal information must not be retained any longer than is necessary for achieving the purpose for which the information was collected or subsequently processed”

Unless:

  1. Retention of the record is required or authorised by law.
  2. The responsible party reasonably requires the record for lawful purposes related to its functions or activities.
  3. Retention of the record is required by a contract between the parties thereto or
  4. The data subject or a competent person where the data subject is a child has consented to the retention of the record.

To comply with the above requirements Halo will ensure that:

  1. Data related to any subject required to identify any financial or contractual agreements will be maintained for a period the length of the contract plus at least 5 years from the last interaction with a client. This data will then be archived and only be accessed if required due to a legal request, or to comply with a government regulation or policy.
  2. Certain data outside of purely financial or transactional related data will also be required by the business to be maintained for lawful purposes related to the organisations functions or activities, these are listed in Appendix A

 Access to Personal Information:

As per the POPIA act of 2013, a data owner may request access to information held by the organisation.

Any requests related to data that is regulated under the guidance of the POPIA act will be handled following the processes as they are defined in Appendix A.

The data requestor may be charged a fee of R500.00 for their data to be removed. As per The POPIA act of 2013 Section 23

Data removal and the POPIA act:

As stipulated by the act, a data subject may ask for their data to be removed from the responsible party’s possession. Halo will act on this request and remove all data that does not impact the running of the business or conflict with requirements of other laws or regulations. All items that will be removed from the organisation’s records will be communicated to the data subject, and any items that cannot be removed due to the above requirements will be tagged as “Requested to be removed” as per The POPIA act of 2013 Section 24 – 2D.