Halwa Data Protection Notice
Enforced beginning: Jul 18 2026
For any inquiries or assistance, feel free to reach out to our dedicated support team. We welcome your questions. Reach us via email at support@clubhalwago.click.
1. Key Definitions and Scope
This document constitutes the Halwa Data Protection Notice (“Notice”) issued by Halwa (“Halwa”, “we”, “our”, or “us”) which forms part of and is governed by the Halwa Terms of Use. Kindly review the following to understand how we manage and protect your personal information. By accessing or using our website (“Site”), or utilizing our Halwa mobile application (“App”) or any related services (collectively referenced in this Notice as the “Service”), you consent to the terms herein. If you do not agree, please refrain from using the Service.
We may collect information from you as described below when visiting the Site or App. Account registration and usage will result in the collection of certain data to enable Service delivery. The specific information gathered depends on your interactions with our App and Services.
2. Legal Basis for Data Processing
We process your data based on one or more of the following legal grounds:
· Necessity to fulfill our contractual obligations (Terms of Use with you)
· Legitimate interests pursued by us or third parties, such as fraud prevention, network security, or internal administrative purposes, unless outweighed by your rights
· Your explicit consent for specified purposes, such as Service delivery
· Compliance with legal obligations or regulatory requirements
· Public interest or protection of vital interests
3. Types of Information Collected
When installing the Service, registering an account, or using our Site or App, we may collect personally identifiable information to deliver our Services. Below are the categories:
3.1. Account Registration Details
Registration involves providing certain mandatory and optional information:
Mandatory Data: Gender, name or alias, date of birth, mobile number or email address to facilitate connections and friend features.
Optional Data: Photos, videos, self-descriptions, and interests (e.g., profile page interests). Registering via Facebook, Apple, or Google may grant access to additional profile data (e.g., name, email, profile picture, birthday) if consented. We store this data to enhance cross-device synchronization and Service functionality.
3.2. Location Information
We may collect ‘Location Data’ derived from GPS coordinates, Wi-Fi, or IP address to secure account setup, maintain Service integrity, and ensure accurate connections. Your precise location assists in delivering relevant connections and personalized experiences. We may store past locations to improve Service personalization.
3.3. Log Data
“Log Data” includes your IP address, browser type, operating system, device IDs, visited pages, location, mobile carrier, and search terms. We collect this when you interact with our Site, authenticate via third parties, or use our Services, including link interactions. Metadata such as communication dates and durations may also be recorded to enhance connection suggestions and improve Service performance.
Log Data is retained for no longer than 30 days.
3.4. Data from Third Parties and Affiliates
We may receive information from partners evaluating content safety, corporate affiliates, or linked services. Payment details (e.g., card numbers, billing addresses) may also be collected for transaction processing. Third-party integrations can be revoked via app settings.
3.5. Inferred Identity and Cross-Device Association
We link your account with browsers or devices for authentication, security, and personalization. Associating accounts with shared email components or social logins (e.g., Facebook) helps maintain age-appropriate usage and Service standards.
3.6. Device and Activity Data
We collect device details (model, identifiers, IP address) and usage statistics (e.g., match durations, messaging, music choices). Access to camera, microphone, and media files is required for video/audio features and compliance (e.g., age verification). User content such as photos, videos, and messages are stored on our servers.
Error reports (without personally identifiable data) help improve App stability.
3.7. Site Interaction Data
Online tracking technologies (cookies, pixel tags) may collect data on your Site visits, browsing history, location, and device details. These enhance security, enable account access, and support analytics and marketing efforts. Disabling cookies may limit certain features.
3.8. Age Verification
The Service is not intended for users under 18. We collect age-related data to prevent underage access and may delete inadvertently collected data from minors. Users under 18 must not use the Service.
4. Your User Profile
You can modify your profile at any time via the App or Safety Centre. This includes sharing your name, interests, bio, languages, and birthday with connected users. Profile visibility depends on your settings and proximity to other users. Blocking users prevents their access to your profile. Facebook-linked accounts may auto-populate profile data (name, picture, birthdate).
5. Purposes for Processing Your Information
We process your data to provide, maintain, and improve the Service while ensuring safety and compliance:
5.1. Service Delivery: Connecting users, enabling video/audio calls, messaging, and sharing media or music.
5.2. Account Administration: Updating account details, delivering notices, and facilitating networking based on interests or location.
5.3. Safety and Security: Detecting harmful conduct, verifying accounts, and ensuring compliance with policies and legal obligations.
5.4. Business Operations: Generating analytics, improving Services, managing payments, and responding to inquiries.
5.5. Cross-Service Integration: Connecting data across Halwa Group apps for a unified experience.
6. Information Sharing with Third Parties
We share information with affiliates, vendors, and service providers supporting our operations, such as analytics, customer service, security, and payment processing. Examples include:
· Publicly visible profile data (e.g., name, gender, region, photos)
· Content shared with other users
· Halwa Group entities for Service integration
· Third-party service providers (e.g., IT, payment processors, marketing firms)
· Regulatory authorities, law enforcement, and courts
· Professional advisors and potential business transferees
7. User Content and Public Sharing
Any content you voluntarily share (e.g., photos, messages) becomes publicly accessible and may be redistributed. Even after deletion, cached or archived copies may persist. Halwa is not liable for misuse of shared content by others.
8. Direct Marketing Communications
With your consent, we may send marketing updates, offers, or event notifications via email or notifications. You can opt out at any time. We analyze preferences and transaction history to tailor content.
9. Data Access and Deletion Rights
You control shared information via App settings or device removal. Requesting account deletion results in data removal subject to legal requirements. Note that deletion may impact Service access.
10. Outbound Links
Third-party sites accessed via our Service are governed by their own privacy policies. We are not responsible for their data practices.
11. Security Measures
Halwa prioritizes data security using password protection, access logs, and system monitoring. All personally identifiable data is restricted to authorized personnel and service providers. Data may be processed internationally; transfers comply with applicable laws. We pseudonymize or aggregate data for analytics, fraud detection, and trend analysis.
12. Data Retention Policy
Personal data is retained only as necessary to fulfill the purposes outlined herein. Upon no longer being required, data is either anonymized or securely deleted.
13. Your Data Protection Rights
You have the following rights:
· Access: Request confirmation of data processing and obtain copies.
· Withdraw Consent: Revoke consent for data processing at any time.
· Rectification: Correct inaccurate data (e.g., age or gender).
· Erasure: Request deletion of your data under certain conditions (subject to legal exceptions).
· Restriction: Limit processing of your data in specific scenarios.
· Objection: Object to processing based on your particular circumstances.
· Complaint: File a grievance with our Data Protection Officer if rights are infringed.
14. Exercising Your Rights
Update or delete personal information via the App or by contacting our Customer Service Manager at: support@clubhalwago.click
15. Cookie Policy
Cookies and similar technologies (e.g., web beacons, pixel tags) are used to verify users, remember preferences, deliver relevant content, optimize performance, and track advertising effectiveness. You can modify browser settings to disable cookies, but this may impact Service functionality.
16. Policy Updates and Notifications
We reserve the right to update this Notice periodically. Changes will be posted on our Site or App, or as legally required. Continued use after updates constitutes acceptance. Review the Notice regularly to stay informed.
17. Contact Information
For questions about this Notice, contact us at support@clubhalwago.click