Halo, a trading name of Volta Technologies Limited respects your privacy and is committed to protecting your personal data.
This policy contains the following sections.
This website is not intended for children and we do not knowingly collect data relating to children. If we collect data relating to children whilst providing services, we will notify you and seek parental consent where appropriate.
By post: Volta Technologies Limited, 17 Carlton House Terrace, London, England, SW1Y 5AS.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
In addition, we collect any information that you volunteer to us via e.g. the ‘Your Message’ field of our website contact form or via our live chat facility.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
We use different methods to collect data from and about you including through:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
The Glossary below provides further information about the types of lawful bases that we will rely on to process your personal data.
Generally, we do not rely on consent as a lawful basis for processing your personal data although we will get your consent before sending marketing communications to you. You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the lawful bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. If it is not obvious from the circumstances of your interaction with us, please contact us if you need details about the specific lawful basis we are relying on to process your personal data where more than one basis has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To manage your enquiry and register you as a new customer||(a) Identity
|Performance of a contract with you (including negotiation to enter a contract with you).|
|If you become a customer, the initial details of your first enquiry will be used to manage your account, keep you updated. Your initial contact details may potentially be used to help recover any future money owing to us if we form a contract.||(a) Identity
(c) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include:
(b) Asking you to leave a review in future
(c) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant website content to you and measure or understand the effectiveness of the information we serve to you||(a) Identity
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity
(f) Marketing and Communications
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
We strive to provide you with choices regarding certain personal data uses particularly around marketing.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You may receive marketing communications from us if you have requested information from us or purchased goods from us.
We will not share your data with third parties for marketing purposes without your express consent.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us or by following the opt-out links on any marketing message sent to you.
Where you opt-out of receiving marketing messages, we will still hold your personal data for other purposes, for example to deliver our services.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the lawful basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may share your personal data with the parties set out below for the purposes set out in the table above.
We require all third-parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
We keep basic information about our customers and website visitors for no longer than necessary. Please feel free to contact us for details of specific retention details. Please be informed that in some cases, our insurers require us to retain some data for seven years to allow for a six-year legal limitation period and additional time to allow for notification and processing of any insurance claim. This also helps us meet our tax record-keeping obligations.
In some circumstances, you can ask us to delete your data. Please contact us if you wish to make such a request.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights include to:
If you wish to exercise any of the rights set out above, please contact us.
You will not normally have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
If you are exercising your rights, we may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We aim to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Personal Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
External Third Parties include:
Internal Third Parties include any other affiliated companies.
You have the right to:
Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You also have a right to make a complaint to the Information Commissioner’s Office in the UK via the website www.ico.gov.uk or by post to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. We request that you allow us an opportunity to resolve any complaint you might have in the first instance.
Volta Technology Limited
For the purposes of the applicable UK Data Protection Legislation (which includes the EU General Data Protection Regulation, known as the “GDPR”, and the UK Data Protection Act 2018), we are the controller of your Data (that is, the person responsible for deciding how to hold and use your Data), and you are the data subject.
You must be 18 years or older to download and use the full App and use the HALO™ Service. In some cases an adult may set up and manage an account on behalf of a child.
The App enables us to provide you with access to the HALO™ Service, the world's most effective screening solution for infectious diseases, including COVID-19 (“HALO™ Service”). General information about the HALO™ Service can be found on our website at www.haloverify.com (“Site”). Further details of how to access, download and register with the App, and how the Service will be delivered, will be confirmed to you by the company or other entity for which we provide the HALO™ Service and by whom you employed or engaged (“Service Participant”).
The HALO™ Service involves us providing you with a testing kit, analysing the sample that you provide once you return it to our testing facility, and providing you with the results of the testing (“Results”) once your sample has been analysed.
Further details of how the HALO™ Service works will be given to you, either by us or by the Service Participant, when you register with the App.
Please note that nothing in the App, the Site or the HALO™ Service constitutes the offer or provision of medical advice or treatment.
When you register with the App, we ask you to provide details of:
In some cases, we also ask you to provide further means of identification such as:
The lawful basis on which we collect this information is that it is necessary to enable us to provide the Service, and also to comply with our legal obligations.
We will ask you to confirm that all information about yourself that you give us is true, complete and accurate. If any of your Data changes while you are using the Service, you may edit your earlier responses in the “my account” section of the App, or inform us at email@example.com
We will also store information that your Device provides to us in connection with your use of the App, such as your type of Device, browser type, and its unique identifiers, operating system, unique reference IDs, network information and requested and referring URLs. The lawful basis on which we collect this information is that it is necessary to enable us to maintain the App and to provide the Service, and also necessary for our legitimate interest in maintaining and improving the functionality of the App.
We will use the Data primarily to provide you with the App functionality and the HALO™ Service, on the lawful basis that it is necessary for the provision of the HALO™ Service.
We may also use the Data to:
We will do so on the basis that it is necessary for our legitimate interests in providing the App and the HALO™ Service, and maintaining and improving their functionality.
Your Data will be kept anonymous when the sample that you provide is sent to our testing facility.
When you register for the HALO™ Service, you will be given the option to:
If you later wish to change the option you have chosen, you can do so at any time by using the "my account" section of the App or by contacting us at firstname.lastname@example.org
We will only share the Results with the Service Participant on the legal basis that you have consented to our doing so.
We may also disclose your Data:
Please note that we are required by UK law to notify all Results, whether positive or negative, together with the related personal identifying details, to Public Health England (you can obtain further information at https://www.gov.uk/government/organisations/public-health-england).
Except as set out above, we will never sell, distribute or disclose any of your Data (except anonymised aggregate information) with any third party without your express consent.
We store all Data with third party service providers who provide adequate guarantees of technological and other means of protection.
Our service providers may be based in countries outside the European Economic Area whose laws provide for a different standard of protection for your personal data than that provided under UK law. In these cases, we will ensure that they have provided adequate means of protection in accordance with the applicable Data Protection Legislation, such as by means of the European Union’s standard contractual clauses for transfers of personal data outside the European Economic Area.
We keep basic information about our customers and website visitors for no longer than necessary. Please feel free to contact us for details of specific retention details. Please be informed that in some cases, our insurers require us to retain some data for seven years to allow for a six-year legal limitation period and additional time to allow for notification and processing of any insurance claim. This also helps us meet our tax record-keeping obligations. In some cases, we need to retain data for up to eight years, in accordance with the Records Management Code of Practice for Health and Social Care 2016, but will dispose of your data sooner if it is appropriate to do so. If you live in Wales, Scotland or Northern Ireland, different country-specific provisions apply on retention of records (see the links on the UK Government notice at https://www.gov.uk/government/publications/coronavirus-covid-19-testing-privacy-information/testing-for-coronavirus-privacy-information-quick-read).
At the end of the periods indicated above, it may not be possible in certain cases to physically delete the data (for instance, where it is stored on a secure external server), in which case we will take appropriate steps to ensure that it is not available for re-use or disclosure to third parties.
As a data subject you have certain rights including:
If you have any questions or requests regarding our use of your Data, please contact us by email to: email@example.com or by post to:
Volta Technologies Limited, 17 Carlton House Terrace, London SW1Y 5AS, England.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We use the following cookies:
You can find more information about the individual cookies we use and the purposes for which we use them below:
Cookie Name: _ga
Purpose: This is a small cookie that expires after around two years. It contains a randomly generated number and is used for analytical and performance purposes and may be linked with targeting. This lasts around two years.
Cookie Name: _ga_gtag_UA_163****87_1
Purpose: This is a small cookie that typically expires after around one minute. The numbers after UA link to our account ID with our analytics provider and the number 1 at the end links to this being the first profile we have on their platform. It links interactions on our website. It is used for analytical and performance purposes and may be used for targeting. This expires within around a day.
Cookie Name: _gid
Purpose: This is a small cookie that expires after around one day and it is used to identify unique users. It is used for analytical and performance purposes and may be used for targeting. This lasts around one day.
We use a simple implementation of the Google Analytics tool which has the effect of reducing our cookie use.
You can manage your cookies with Google here: https://policies.google.com/technologies/managing
Cookie Name: intercom-id[ref]
Purpose: This cookie identifies our website as opposed to other websites operated by different clients of the ‘intercom’ chat provider. This lasts between six months and one year before it expires.
Cookie Name: intercom-session-id[ref]
Purpose: This cookie identifies your own session with our chat window so that when you return, you can come back to the same chat. This lasts around one week.
The above two cookies are described at: https://www.intercom.com/legal/cookie-policy#what-type-of-cookies-do-we-use-and-what-are-they-used-for
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies.
All cookies on our website will expire after two years.
The Site is provided by Volta Technologies Limited, registered in England and Wales, no. 12612284 (“we”, “us” or “our”). Our registered address is at 17 Carlton House Terrace, London SW1Y 5AS, England.
Further details about us and the Services are described on the Site at About Us
The Site and the Services are intended for business customers and not for individual consumers.
its contents, and to add to, withdraw, or otherwise modify the Services from time to time without giving notice to you.
The Site provides general information about us and the Services. If you wish to purchase any of the Services, additional terms and conditions will apply.
Nothing in the Site constitutes medical advice, or an offer of any services.
If you choose to access the Site from outside the United Kingdom, you do so on your own initiative and are responsible for compliance with local laws.
All copyright, database right, trade mark or other intellectual property rights (“IPRs”) in any part of the Site or its content (including text, data, graphics and any other material) are owned by or licensed to us. All rights not expressly granted are reserved to us.
No IPRs contained or used in the Site (or any part of it) are intended to, and they shall not be deemed to, transfer to any person who accesses and/or uses the Site or the Services.
We reserve the right to suspend the Site at any time for operational, regulatory, legal or other reasons.
We cannot guarantee that the Site will be available at all times without interruption.
Although we make reasonable attempts to ensure that the server that makes the Site available is bug and virus free, we cannot provide any guarantee in this respect.
The Site is provided as it currently is, and we do not guarantee that the Site will meet your expectations or requirements. If your computer or other device does not support relevant technology, including encryption, you may not be able to access the Site and/or use some or all of the Services.
The Site is accessed via the World Wide Web, which is independent of us. Your use of the World Wide Web is solely at your own risk and subject to all applicable national and international laws and regulations. We do not represent that the Site is appropriate or available for use in any jurisdiction other than the United Kingdom.
The content on the Site has been compiled from a variety of sources, and is subject to change without notice. We have taken reasonable care in compiling and presenting the content of the Site to ensure that the information supplied on the Site is accurate. However, we cannot guarantee that all information will be free from errors, omissions or inaccuracies.
We will not under any circumstances have any liability to you or any other person, whether arising out of or in connection with your use of the Site, or your inability to use the Site, or for any other reason, for:
We exclude all implied conditions, warranties, representations or other terms that may apply to the Site or any content on it.
All notices from us to you will be displayed on the Site from time to time or emailed to the email address you have provided.
If you require further information about the Site and/or the Services, please contact us either by telephone or by email at the email address given in the Contact Us page on the Site.