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
• 1099-K (OBBBA §70432) and 1099-NEC (OBBBA §70433) tax reporting thresholds

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 1099 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 IRS 1099-K (OBBBA §70432 dual threshold: $20,000 AND 200 transactions) or 1099-NEC (OBBBA §70433, $2,000 threshold) as applicable
• 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 (NIST SP 800-92)
• Partner application + onboarding records: 7 years post-termination (IRS + FL §95.11)
• Referral attribution + commission records: 7 years (IRS audit retention)
• 1099-K and 1099-NEC tax records: 4 years post-filing (IRS §6501(a))
• Partner SMS opt-in records: Lifetime of Partner account plus 4 years for compliance audit

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 Partner account, subject to legal retention requirements (tax records, dispute records)
• Receive a copy of any data we hold about you, subject to fraud-prevention redactions

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

HALOFIX USA complies with the Florida Information Protection Act (FIPA, Fla. Stat. §501.171). In the event of a security breach affecting your Partner personal information, HALOFIX USA will notify affected Partners within 30 days of discovery, as required by FIPA.

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.