Partner Privacy Policy

This Partner Privacy Policy (the “Partner Privacy Policy”) describes how HALOFIX USA LLC (“HALOFIX USA,” “we,” “us,” or “our”) collects, uses, retains, and discloses personal information of Partners who register to refer Residents and Heroes to the HALOFIX USA platform.

This Partner Privacy Policy is separate from and supplemental to the HALOFIX USA Resident Privacy Policy and the Hero Privacy Policy.

This Partner Privacy Policy applies to:

• Partner registration and W-9 collection
• Partner-bound SMS communications (OTP, withdrawal confirmations)
• Referral attribution data (clicks, conversions, commissions)
• Partner payout via Stripe Connect
• Tax reporting information

By providing your phone number and checking the Partner SMS consent box during Partner registration, you agree to receive operational text messages from HALOFIX USA LLC related to your Partner activity. These messages may include:

• One-Time Password (OTP) — sign-in and high-value action verification codes
• Forgot OTP / OTP resend — replacement verification codes when the original expires
• Withdrawal confirmation — when a commission withdrawal is initiated to your Stripe Connect bank account
• Account security alerts — new device sign-in, password change, payout method change

We will never share your phone number with third parties or affiliates for marketing or promotional purposes. All Partner SMS opt-in data is retained solely by HALOFIX USA LLC.

Supported carriers include AT&T, T-Mobile, Verizon, Sprint, and other major US carriers.

• Legal name, business name, address, phone, email
• IRS Form W-9 (TIN, classification) for IRS tax reporting
• Stripe Connect account ID and payout bank metadata (Stripe-tokenized; we never see raw bank credentials)
• Referral attribution data: clicks, conversions, commissions earned, payout history
• Authentication metadata: IP, user-agent, session timestamps
• Marketing channels used to drive referrals (self-disclosed)

• To verify your identity and prevent fraud
• To attribute referral conversions and calculate commissions
• To process payouts via Stripe Connect
• To file the IRS tax forms HALOFIX is required to file for your payments
• To dispatch operational SMS (OTP, withdrawal confirmations) and email
• To respond to disputes or chargebacks
• To enforce the Partner Affiliate Agreement and platform policies
• To comply with applicable federal and Florida state laws

• Authentication logs: 1 year
• Partner application + onboarding records: after termination, 7 years, or until you delete your account, whichever is first (HALOFIX USA policy)
• Referral attribution + commission records: 7 years, or until you delete your account, whichever is first (HALOFIX USA policy)
• Tax records: 7 years after filing; kept even if you delete your account (HALOFIX USA policy)
• Partner SMS opt-in records: Retained for the life of the account and 4 years after it ends. When you delete your account, your name and contact details are removed and only a coded reference stays

Under applicable law (including Florida law), you have the right to:

• Access your personal information held by HALOFIX USA
• Request correction of inaccurate information
• Withdraw consent for SMS communications at any time (Reply STOP)
• Request deletion of your account and all of your personal information. When nothing is open on your account, it is deleted at once. If a payment, payout, commission or dispute is still open, nothing is deleted until it has settled; then it is deleted automatically. What remains: Proof of your consents and signatures, and our call-consent, text message, email, security and compliance logs, are kept without your name, phone number, email, address or IP address. They are linked to your request only by a coded reference. Booking and payment records are kept without anything that identifies you, for our accounting and for the earnings records of the Hero who did the work. The tax forms we are required to keep for Heroes and Partners are kept. A record that you asked for this deletion is kept.
• Receive a copy of any data we hold about you, subject to fraud-prevention redactions

To exercise these rights, contact legal@halofixusa.com.

HALOFIX USA works to follow applicable laws. In the event of a security breach affecting your Partner personal information, HALOFIX USA will notify affected Partners within 30 days of discovery.

HALOFIX USA may update this Partner Privacy Policy from time to time. Material changes will be posted to this page with a new “Last updated” date and notified via Partner email or in-platform notification at least 30 days before they take effect.