HALARA PRIVACY POLICY

Last updated: 9 May 2026

Welcome to Halara! We at FR DFS d/b/a Halara ("Halara," "we," "us," or "our") are committed to protecting your privacy. This Privacy Policy ("Policy") explains how we collect, use, share, and process your information, as well as the rights and choices you have associated with that information. This Policy applies when you visit our website that links to this Policy (the "Sites"); when you use our HALARA mobile application (the "App"); or otherwise interact with our products or services that we own or operate (collectively, the "Services"). This Policy does not apply to personal information we collect from Halara's employees, contractors, job applicants, owners, directors, or officers. Please see our Human Resources Privacy Policy for more details.

Please read this entire Policy to ensure you fully understand it. By accessing, visiting, or using our Services, you acknowledge the collection, use, and disclosure of your personal information in accordance with this Policy, and you agree to the attached Terms and Conditions https://thehalara.es/foot/terms-of-service (“Terms”). If you are uncomfortable with any part of this Policy or do not agree to the Terms, please immediately stop accessing or using our Services.

We may update this Policy at any time, without prior notice, and changes will apply to any personal information we already hold about you, as well as any additional personal information collected after the Policy is updated. If we make changes, we will notify you by revising the date at the top of this Policy. If we make a change to this Policy that we believe materially affects how we process your personal information or reduces your rights, we will provide you with advance notice by email, push notification, or by posting a prominent notice on our Sites. Unless otherwise required by the laws in your place of residence, your continued access to or use of our Services after receiving notice of changes constitutes your acknowledgment that you accept the updated Policy.

In addition, we may provide you with real-time disclosures or additional information about the personal information handling practices of specific parts of our Services. Such notices may supplement this Policy or give you additional choices about how we process your personal information.

1. Personal Information We Collect

Halara collects certain personal information about you and your use of our Services. The definition of personal information (used interchangeably with "personal data" for European residents) depends on the applicable law based on your physical location. Only the definition that applies to your physical location will apply to you under this Policy. For the purposes of this Policy, personal information does not include data that has been irreversibly anonymized or aggregated so that it no longer allows us, either in combination with other information or otherwise, to identify you.

This information is divided into three main categories: (1) information that you voluntarily provide to us, (2) information that we automatically collect from you.

Information You Voluntarily Provide. We, or service providers who help us provide, maintain, and operate our Services, may collect the following types of personal information from you:

(1) Account Registration. We may collect information related to creating an account when you use our Services, such as your email address, phone number, and/or a unique password. If you use a third-party service (for example, Apple, Facebook, TikTok) to create an account, we may receive personal information that you allow that third-party service to share with us, such as your name and email address.

(2) Order Processing. We may collect your personal information when you place an order on our Sites or in our App, including, for example, your first and last name, mailing address, postal code, email address, phone number, payment account information, or credit card details. In some regions, we may require your passport information and tax identification number for customs clearance.

(3) Customer Support. When you interact with our support team, we may collect records, copies of your correspondence (including email addresses), social media usernames, or other additional information you choose to share with us.

(4) Newsletter Subscription. You can choose to provide us with your contact details, such as your email address and telephone number, if you wish to receive information about the products and services offered by Halara.

(5) Size Recommendations. You can voluntarily provide us with your height, age, weight, and measurements, as well as your preferences. We use this information to recommend clothing sizes and provide fit prediction services.

(6) Public Forum. If you post information in public areas of our Site, such as disclosing your measurements and fit details in a product review, that information may be collected and used by Halara, visitors to our Sites, and the general public. We strongly recommend that you do not post information through the Site that would allow strangers to identify or locate you, or that you otherwise do not wish to share publicly.

(7) Promotional Events. From time to time, we may ask you to complete a survey and/or offer you the opportunity to participate in promotions, programs, and/or sweepstakes (collectively, "Promotions") through the Site. If you choose to participate in a Promotion, we will collect and store the personal information you provide in connection with your participation in the Promotion, including, but not limited to, your name, email address, date of birth, and/or telephone number. We may provide "at-the-moment" disclosures or additional information about our information collection, use, and sharing practices for specific Promotions. We use this information to administer the Promotion, such as notifying winners and distributing prizes, and for marketing purposes by Halara and the Promotion sponsors, as permitted by applicable law. Acceptance of a prize may require you to allow us (unless prohibited by law) to publicly display some of your information through the Site, such as on a winners page.

(8) Brand Ambassador. If you apply to become our brand ambassador, we may collect your name, email address, phone number, social media usernames, region, and school you attend to process your application.

(9) Affiliate Program. If you apply to join one of our affiliate programs to earn commissions, we may collect your full name, username, country or region, company website, company address, and time zone.

Information We Collect Automatically. To the extent permitted by applicable law, we may automatically collect certain types of information whenever you interact with the Sites or use the Services. We may automatically collect the following types of information from you: (1) Usage Data. When you browse our Sites, we automatically collect log data such as your web request, Internet Protocol ("IP") address, browser type, domain names, referring and exit pages and URLs, pages viewed and the order of those page views, the date and time you access our servers, and other diagnostic data.

(2) Device Information. When you use your desktop or mobile devices to access our Services, we may be able to identify your device's unique identifier, MAC address, operating system, and mobile device advertising ID.

(3) Location Information. When you use our Service, we can infer your device's general physical location and geographic regions from your Wi-Fi, Bluetooth, and other device settings. For example, your IP address may indicate your general geographic region. You can opt out of sharing your location details with us by adjusting your mobile or desktop device's location services settings. For instructions on how to change the relevant settings, please contact your service provider or device manufacturer.

(4) Aggregated and Analytical Data. We may also combine the information we collect across our Services and on your devices for analytical, security, and fraud prevention purposes. For example, we use algorithms that analyze your account status and payment information to detect unsafe and unsecured payments. We may also use analytical data to assess the security of your account and provide you with suggestions for improvements.

Information We Collect from Third Parties. From time to time, we may obtain information about you from third-party sources as required or permitted by law. These sources may include:

2. Cookies and Other Tracking Technologies

We, and third parties on our behalf, may use various tracking technologies, such as cookies and other similar technologies (collectively, "Tracking Technologies"), to automatically collect personal information as you interact with our Site and App, in order to help us personalize your experience and better manage content, including for:

Analyze the traffic of our website and application using an analytics package

Identify if you have already visited our Services

Store information about your preferences

To recognize when you return to our Services

Please read our Cookie Policy https://thehalara.es/foot/cookie-policy for more details on the types of tracking technologies we use.

3. How We Use Your Personal Information

We use your personal information as described in this Policy for business and marketing purposes, or as disclosed to you prior to such processing. We may process your personal information to:

(1)   To Provide Halara Services. We will use your personal information to provide you with information or perform Services you request, including managing your request as a registered user of our Site. For example, when you order products from us, we need your shipping information to deliver your order and payment information to process it. We will not be able to provide you with the Service without this information. Third parties, such as payment processing companies and courier services, may also access and/or collect your personal information when they assist us in fulfilling your order. We work diligently with these third parties to protect your information.

(2) To Maintain Legal and Regulatory Compliance. Our Services are subject to certain laws and regulations that may require us to process your personal information. For example, we process your personal information to pay our taxes, fulfill our business obligations, ensure compliance with employment and recruitment laws, or as necessary to manage risk as required by applicable law. Without processing your personal information for such purposes, we cannot perform the Services in accordance with our legal and regulatory requirements.

(3) To Enforce Compliance with Our Terms, Agreements, and Policies. When you access or use our Services, you are bound by our Terms. To ensure your compliance, we process your personal information by actively monitoring, investigating, preventing, and mitigating any alleged or actual prohibited, unlawful, or illegal activity on our Services. Subject to applicable law, we may also process your personal information to investigate, prevent, or mitigate violations of our internal terms, agreements, or policies, and to enforce our agreements with third parties and business partners.

(4)   To Detect and Prevent Fraud and Security Risks. We may process your personal information to help monitor, prevent, and detect fraud and misuse of our Service, control and verify your identity so that unauthorized users do not access your information, improve system security, and combat spam, malware, malicious activity, or other security risks that could result in financial loss.

(5)   To provide customer support or respond to you. We collect any information you provide when you contact us. Without your personal information, we cannot respond to you or guarantee your continued use and enjoyment of the Services.

(6) To Provide You with Service-Related Communications. We will send you administrative or account-related information to keep you updated about your account and the Services. These communications may include information about updates to the Privacy Policy, confirmations of your actions or transactions on the account, security updates or tips, or other relevant transaction-related information. Service-related communications are not promotional in nature. You cannot opt out of these communications; otherwise, you may miss important developments related to your account or the Services.

(7) To Provide You Marketing Communications (e.g., SMS, email). We may collect your email address, phone number, or other electronic addresses that you voluntarily provide when you choose to participate in our promotional activities or subscribe to marketing communications. You can opt out of receiving these marketing messages from us at any time by unsubscribing or following the instructions in the messages. We may also collect and use your mobile advertising identifiers for marketing campaign purposes. Please see our Cookies and Other Similar Tracking Technologies section for more information.

(8) To Research and Develop Our Services. We may process your personal information and derive analytical and statistical data to better understand how you use and interact with our Services. For example, analyzing where, on what types of devices, and how our Site is used, how many visitors we receive, and where they click on the Site can help us improve our existing Services and create new ones. See our Cookies and Other Similar Tracking Technologies section for more information.

(9)   To Personalize Your Experience. We may process your information to personalize your experience. Through personalization, we enable you to interact more easily with our Services across different platforms and devices. We also use it to remember you if you revisit our Site, so we know if you have already been provided with surveys, or (when Site content is being tested) which version of the content was shown to you. See our Cookies and Other Similar Tracking Technologies section for more information.

(10) To Facilitate Corporate Acquisitions, Mergers, and Transactions. We may process any information related to your account and your use of our Services that is necessary in the context of corporate acquisitions, mergers, or other corporate transactions.

(11) With Your Consent. For any other purpose previously disclosed to you before you provide us with your personal information, or as reasonably necessary to provide the requested services or other related services, with your permission or at your direction.

4. Share Your Personal Information

We share your personal information as necessary to fulfill the purposes described in this Policy and as permitted by applicable law. We may disclose your personal information as follows:

(1)   As Required by Law. We may access, preserve, and disclose information about you if we believe doing so is necessary or appropriate to (a) comply with law enforcement and legal process requests, such as a court order or subpoena; (b) comply with requests from auditors, examiners, or other regulators; (c) respond to your requests; or (d) protect your rights, our property or safety, or the rights or safety of others.

(2) Within Our Corporate Organization. We may share your personal information within our organization to provide you with the Services and take actions based on your request.

(3) With Our Service Providers. We may share your personal information with third-party service providers who act on our behalf to help us operate our Services. These service providers and vendors provide us with support services, such as credit card processing, order fulfillment, website hosting, email and postal delivery, analytics services, conducting surveys and research, and network maintenance. These third parties may only use your information in accordance with our written instructions and must comply with the information security protections we have established. We contractually obligate our third-party service providers to protect your personal information.

(4) With Third-Party Advertisers. In certain circumstances and subject to applicable law, we may share your personal information with third-party advertisers.

(5) For Co-Branded Services and Features. Portions of our Site or Services may be offered as part of co-branded services and features. We will share your personal information with our co-branded partners based on your voluntary use of or participation in a co-branded service or feature. Co-branded partners will be identified within the co-branded service or feature, along with the applicable co-branded partner's privacy policy. A co-branded partner's use of your personal information will be subject to the co-branded partner's privacy policy. If you wish to opt out of future use of your personal information by a co-branded partner, you must contact the co-branded partner directly.

(6) During Business Transactions or Other Transfers of Assets, we may disclose and transfer information about you to buyers, service providers, advisors, prospective transaction partners, or other third parties in connection with advising, prospective transaction partners, or other third parties in a corporate transaction in which we are acquired by or merged with another company, or we sell, liquidate, or otherwise transfer all or part of our business or assets. By interacting with us or using our Services, you understand and agree to our assignment or transfer of rights to your personal information.

(7) With your consent. We may disclose your personal information for any purpose with your consent.

5. How We Protect Your Personal Information

We maintain advisors, potential transaction partners, and other third parties to protect and prevent the misuse of your personal information. Our security measures include industry-standard physical, technical, and administrative measures to prevent unauthorized access to or disclosure of your information, maintain data accuracy, ensure the appropriate use of information, and generally protect your personal information. We also restrict access to your personal information to our employees and third parties who need that information to provide products or services.

Please acknowledge that protecting your personal information is also your responsibility. We ask that you be responsible for safeguarding your password, security questions and answers, and other authentication information you use to access our Services.

If you believe the security of your account or personal information has been compromised, please contact us immediately at the following email address: Legal@halara.com . Please note that, despite our best efforts, no security system is invulnerable. In the event of a security breach, we will promptly notify you and the appropriate authorities if required by law.

6. How Long We Keep Your Personal Information

We will retain your personal information only for as long as necessary for the purposes set out in this Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

If you send us correspondence, including emails, we store that information electronically in your account records. We also electronically store customer service correspondence and other correspondence from Halara to you. We maintain these records to measure and improve our customer service and to investigate potential fraud and violations. Over time, we may delete these records as permitted by law.

Halara will also retain Site and Services usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or improve the functionality of our Site, or we are legally required to retain this data for longer periods.

We will stop retaining your personal information or remove the means by which the information may be associated with you as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal information was collected and is no longer necessary for legal or business purposes.

7. Your Choices, Privacy Rights and Opt-Out Rights

A. Your Options

(to)   Correct or Update Your Information. If you have created a user account through the Services, you will be able to access, update, and correct the personal information you have provided in connection with your account by logging into your account through the Services.

(b)   Marketing Communications. We offer you certain choices about how we communicate with you. To update your preferences and limit the communications you receive from us, please contact us as specified in the " How to Contact Us " section at the end of this Policy. Where permitted by law, you can withdraw any consent you previously gave us, and we will apply your preferences going forward. You can also opt out of receiving marketing communications from us by clicking the unsubscribe link in our marketing content.

(c) Cookie Management. You have the right to decide whether or not to accept cookies on our Sites. If you do not wish us to use cookies on your browser, you can exercise your preference through our cookie preference manager or by modifying your web browser settings to reject some or all cookies, or to notify you and ask for permission when a website attempts to set a cookie. If you would like to learn how to modify your browser settings, please use the "Help," "Tools," or "Edit" options in your browser for more information.

menu in your browser or check the instructions provided by the following browsers: Internet Explorer , Google Chrome , Mozilla Firefox , Safari Desktop , Safari Mobile;   and Android browser. If you block or delete the technical and/or functional cookies used on our Sites, browsing the Sites may become impossible, certain services or features of the Sites may become inaccessible, or other malfunctions may occur. In this case, you may have to manually modify or enter certain information or preferences each time you visit the Sites.

(d) Analytics. We may use third-party service providers to monitor and analyze the use of our Sites, such as Google Analytics. Google Analytics is a web analytics service offered by Google LLC (“Google”) that tracks and reports website traffic. For more information about Google’s privacy practices, please visit the Google Privacy & Terms webpage: https://policies.google.com/privacy?hl=en . The Google Analytics Opt-out Browser Extension allows visitors to prevent their data from being collected and used by Google Analytics, available at: https://tools.google.com/dlpage/gaoptout .

(and)   Interest-Based Advertising Management. We and our third-party service providers may use interest-based advertising technologies when you interact with our Site or App. Please read our Cookie Policy https://thehalara.es/foot/cookie-policy for more details.

a. Website Browser. Many advertising companies that collect information for interest-based advertising are members of the Digital Advertising Alliance (DAA) or the Network Advertising Initiative (NAI), both of which maintain websites where individuals can opt out of receiving interest-based advertising from their members. To opt out of interest-based advertising on websites provided by participating companies of each of these organizations, visit the DAA's opt-out portal at http://optout.aboutads.info/ or the NAI's opt-out portal at http://optout.networkadvertising.org/?c=1 . If you reside in the European Economic Area, Switzerland, or the United Kingdom, you can opt out of receiving online behavioral advertising served by participating member organizations of the European Interactive Digital Advertising Alliance by visiting https://youronlinechoices.eu/ .

Mobile Application . When you use our mobile application, we or our third-party marketing partners may use one or more identifiers for your mobile device, including the Apple Advertising Identifier (IDFA) or the Android Advertising Identifier (AAID), to target and display ads in our application or in other applications. This means that your device identifier could be accessed by third-party advertising networks and used to: (a) help manage the number and types of ads you see; (b) track the origin of ad installations related to ads seen in other applications; and (c) identify your interests and behavior, and target advertising to you based on those interests and behavior.

Apple requires app developers to request permission before they can track your activity on apps or websites they don't own, in order to target advertising to you, measure your actions in response to advertising, or share your information with data intermediaries. If you previously granted our mobile app permission to track you, you can tell our app to stop tracking your activity. On iOS or iPadOS, go to Settings, tap our app, and then turn off Allow Tracking. You can also reset your IDFA from your mobile device's settings page, which will prevent the continued use of existing behavioral data associated with your previous IDFA.

If you have an Android device and are using Android 12 or later, you can permanently remove your advertising ID by opening Settings, going to Privacy > Ads, tapping "Remove advertising ID," and then tapping it again on the next page to confirm. This will prevent any apps on your phone from accessing it in the future. Keep in mind that if you do this, you will still see ads, but they won't be tailored to your inferred interests.

You can also access industry-provided opt-out tools, although they are not tailored to our mobile apps. For example, to opt out of data collection by participating Digital Advertising Alliance (DAA) member companies for interest-based advertising in mobile apps, download the DAA's "App Choices" mobile app for the opt-out option.

https://youradchoices.com/appchoices

B. Your Privacy Rights

Depending on the law applicable in your place of residence or where you are located, you may be able to exercise certain rights identified below with respect to your personal information. If any of the rights listed below are not provided to you under the law governing the processing of your personal information, we have absolute discretion in granting you those rights. Please refer to the “ What Rights Apply” section to determine your rights in the jurisdiction where you reside.

(a) Right to Know/Access. You may have the right to obtain a copy or a list of categories of the personal information we hold about you, as well as additional information such as the purposes of processing and the entities to which we disclose your personal information.

(b)   Right to Correction/Rectification. You may have the right to correct any personal information about you in our records and systems. You can ask us to rectify, correct, or update any personal information about you that we hold that is inaccurate.

(c) Right to Erasure/Deletion. In certain circumstances, you may have the right to request that we delete the personal information we hold about you. This right is not absolute, and we may refuse your deletion request if it is reasonably necessary to provide you with a service you have requested; to fulfill a contract between us; to maintain the functionality and ensure the security of our systems; to enable only intended internal uses of your personal information; to exercise a right granted by law; to comply with a legal obligation; or if there are compelling legitimate grounds for retaining your personal information.

(d)   Right to Portability. In certain circumstances, you may have the right to receive the personal information we hold about you in a structured, commonly used, and machine-readable format, so that you can provide that personal information to another entity.

(and)   Right to Non-Discrimination. You have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your privacy rights.

(F)   Right to Object to Automated Decision-Making. You may have the right not to be subject to a decision based solely on automated processing (where a decision is made about you using an electronic system without human intervention) that significantly affects your rights. We will not make decisions about you solely based on automated decision-making that has a significant impact on you.

(g) Right to Withhold or Withdraw Consent. We may request your consent to process certain personal information. If we do so, you have the right to withhold or withdraw your consent at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.

(h)   Right to Restriction. You may have the right to request that we restrict our processing of your personal information in certain circumstances. For example, this right is available if you contest the accuracy of the personal information or have objected to our processing.

(Yo) Right to Object to Processing. You may have the right to object to the processing of your personal information at any time, as permitted by applicable law, if we process your personal information based on your consent or legitimate interests. However, we may continue to process your personal information if necessary for the defense of legal claims or other exceptions permitted by applicable law.

(j) Right to Appeal. You may have the right to appeal if we refuse to take action regarding your request for rights. Instructions on how to appeal will be provided to you in the event of such a refusal, but in any case, those instructions will be substantially similar to those provided below for submitting requests.

To determine what rights you have, refer to the table below which references the rights described above.

Submit a Request to Exercise Your Privacy Rights

To exercise your privacy rights, please email Legal@halara.com . Please note that, to protect your privacy and security, we need to verify your identity before we can process your request to exercise any of the privacy rights you may have under applicable law. We may conduct the verification process by email or phone, and we may ask you to provide information such as your name, contact information, and any additional information relevant to your relationship with us.

8. Third-Party Websites

Our Site may contain links to third-party websites. This Privacy Policy does not apply to those third-party websites. We recommend that you read the privacy statements of any other site you visit, as we are not responsible for the privacy practices of those sites.

9. How We Handle Children's Information

Our Services are not directed to children under the age of 16 (or other age required by local law), and we do not knowingly collect personal information from children under 16. If you are under 16, please do not attempt to complete our forms or submit personal information about yourself. If you are a parent or guardian and wish to review, amend, or delete the information we have collected about your child, you may contact us using the method identified in the "Contact Us" section below. If we become aware that a child under 16 has provided us with personal information, we will terminate that user's access to our Service and take steps to delete that information from our records, unless we have a legal obligation to retain it.

10. International Transfers of Personal Information

Halara's business operates globally. Therefore, when you access and submit personal information to Halara, your personal information may be processed, maintained, and used on computers, servers, and systems located primarily in other countries , where privacy and data protection laws may be less stringent than the laws in your country of residence. For those countries or regions, measures have been taken in accordance with applicable data protection laws to protect your personal information. We primarily rely on the European Commission's Standard Contractual Clauses to facilitate the international and onward transfer of personal information collected in the European Economic Area, the United Kingdom, Switzerland, and Brazil, to the extent that the recipients of European Personal Information are located in a country that European countries deem does not provide an adequate level of data protection. We may also rely on an adequacy decision from the relevant regulatory body confirming an adequate level of data protection in the jurisdiction of the party receiving the information, or on exceptions in specific situations.

If you do not want your information transferred, processed, or maintained outside of the country or jurisdiction where you are located, you must immediately stop accessing or using the Services. For more details about these transfers and the safeguards we use to facilitate them, please contact us at Legal@halara.com.

11. Additional Notice for Persons in the European Economic Area, the United Kingdom, Switzerland and Brazil

This section applies only to individuals who use or access our Service while located in the European Economic Area, the United Kingdom, Switzerland (collectively, the "European Countries"), or Brazil at the time of data collection. In accordance with the European Union's General Data Protection Regulation, the United Kingdom's General Data Protection Regulation (collectively, the "GDPR"), and Brazil's General Law on the Protection of Personal Data ("LGPD"), for the sake of clarity, references to personal information in this Policy refer to personal data within the meaning of the GDPR.

We may ask you to identify your country when you use or access some of the Services, or we may rely on your IP address to identify your country. When we rely on your IP address, we cannot apply the terms of this section to anyone who masks or otherwise conceals their location information to avoid appearing to be located in European countries or Brazil. If any term in this section conflicts with other terms in this Policy, the terms of this section will apply to individuals in a European country or Brazil.  

Legal Basis for the Processing of Your Personal Data

Marketing. We will only contact you electronically (such as by email or SMS) if you are located in a European country, based on our legitimate interests, as permitted by applicable law or your consent. If you do not wish us to use your personal data in this way, please contact us at Legal@halara.com. You can opt out of direct marketing at any time, free of charge.

Right to lodge a complaint with your local Data Protection Authority. If you reside in European countries, you may have the right to lodge a complaint with your national data protection authority or an equivalent regulatory body. You can find details of the supervisory authorities of the Spanish Data Protection Agency (EPD) here: https://edpb.europa.eu/about-edpb/board/members_en. The supervisory authority in the United Kingdom is the Information Commissioner's Office (ICO).

12. How to Contact Us

We welcome questions, comments, and concerns about our privacy policy and privacy practices.

The Services are provided by FR DFS d/b/a Halara. If you wish to provide feedback, have any questions or concerns, or wish to exercise your rights related to your personal data, please email us at Legal@halara.com

If you are a resident of the European Union, the European Economic Area, and/or the United Kingdom and believe that we process your Personal Data within the scope of the General Data Protection Regulation (“GDPR”) in the EU/EEA and the Data Protection Act 2018 (as amended) in the UK, you may direct questions or complaints to our Data Protection Officer . Our Data Protection Officer is DataRep, and you can contact them by sending an email to halara@datarep.com or by completing an online web form at www.datarep.com/data-request