Last Updated Date: October 18, 2025

Effective Date:December 5, 2025

Welcome to Halara! We d/b/a 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 any of our websites or services that link to this Policy, including www.halara.com and the former thehalara.com (now intergrated into

www.halara.com due to the brand upgrade), as well as our mobile application HALARA (the “App”) and other related services we own or operate. (collectively, the “Service(s)”).

Depending on your location, the entity responsible for the processing of your personal information is: i) For users located in the United States: If you are a registered user of our sites and apps, and you are from United States, you are contracting with US DFS Inc.; ii) For users in other locations: If you are a registered user of our sites and apps, and you are from a place outside the United States, you are contracting with FULL SCALE FULL SPEED PTE. LTD.. The data controller of your personal information is the same as your contracting entity. For contact details, please see section 12 Contact Us below. Under certain circumstances, we may provide services via backup domains operated by the same legal entity to ensure continuity. Your data will remain processed under this Privacy Policy by the same data controller and you may continue to exercise your rights.

This Policy does not apply to the personal information we collect from employees, contractors, job applicants, owners, directors or officers of Halara. Please see our HR Privacy Policy for details. Please read this entire Policy to make sure that you fully understand it. By accessing, visiting or using our Services, you acknowledge to the collection, use and disclosure of your personal information in accordance with this Policy, and you agree to the accompanying Terms and Conditions (“ Terms ”). If you are not comfortable with any part of this Policy or do not agree with the Terms, please immediately discontinue access or use of 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 reduce your rights, we will provide you with advanced notice via email, through push notification, or by posting a prominent notice on our Sites. Unless otherwise required by laws in your residence, your continued access or use of our Services after receiving the notice of changes, constitutes your acknowledgement 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 provide you with additional choices about how we process your personal information.

Table of Contents

1. Personal Information We Collect

2. Cookies and Other Tracking Technologies

3. How We Use Your Personal Information

4. Sharing Your Personal Information

5. How We Protect Your Personal Information

6. How Long We Keep Your Personal Information

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

8. Third-Party Websites

9. How We Handle Children’s Information

10. International Transfers of Personal Information

11. Additional Notice for California Residents

12. Contact Us

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 purpose of this Policy, personal information does not include data that has been irreversibly anonymized or aggregated so that it can no longer enable us, whether in combination with other information or otherwise, to identify you.

This information falls into three primary categories: (1) information you voluntarily provide to us, (2) information we collect from you automatically, (3) Information we collect from third parties.

Information You Voluntarily Provide to Us. We, or service providers that assist us in providing, maintaining, and operating our Services, may collect the following types of personal information from you:

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

(2) Order Placement. 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 or credit card information. In some regions, we may need your passport information and tax number for customer clearance.

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

(4) Newsletter Sign-ups. You may choose to provide us your contact details, such as your email address and phone number, if you wish to receive information about the products and services that Halara offers.

(5) Fitting Recommendation. You may voluntarily provide us your height, age, weight and measurements and your preference. This information is used by us to recommend clothing sizes, and to provide fit prediction services for you.

(6) Public Forum. If you post information on public areas of our Site, for example, disclosing your measurement and fitting information in a product review, that information may be collected and used by Halara, visitors to our Sites, and the public generally. We strongly recommend that you do not post any information through the Site that allows strangers to identify or locate you or that you otherwise do not want to share with the public.

(7) Promotional Events. From time to time, we may ask you to complete a survey and/or offer you an opportunity to participate in promotions, programs and/or sweepstakes (collectively, “Promotions”) via 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 phone number. We may provide “just-in-time” disclosure or additional information about our information collection, use and sharing practices of specific Promotions. We use this information to administer the Promotion, such as by notifying winners and distributing prizes, and for Halara and our Promotion sponsors’ marketing purposes as permitted by applicable law. Acceptance of a prize may require you (unless prohibited by law) to allow us to post publicly some of your information via the Site, such as on a winner's page.

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

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

Information We Automatically Collect. To the extent permitted under the applicable law, we may collect certain types of information automatically, such as whenever you interact with the Sites or use the Services. We may collect the following types of information automatically from you:

(10) 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 these page views, the date and time you access our servers, and other diagnostic data.

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

(12) Location Information. When you use our Service, we may infer the generic physical location and geographic regions of your device from your WiFi, Bluetooth and other device settings. For example, your IP address may indicate your general geographic region. You may choose not to share your location details with us by adjusting your mobile or desktop device’s location services settings. For instructions on changing the relevant settings, please contact your service provider or device manufacturer.

(13) Aggregate and Analytic Data. We may also combine the information we collect among our Services and across your devices for analytic, security and fraud prevention purposes. For example, we use algorithms that analyze your account status and payment information to detect the unsafe and unsecured payment. We may also use analytic data to assess your account security and provide you suggestion for improvement.

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. Such as certain affiliated entities within our corporate group and our vendors, including webhosting providers, analytics providers, advertising or other business partners and/or other public resources. To the extent we allow for third-party social network integrations in our apps and sites, the information we may receive from third-party services depends on your account/privacy settings with those third parties and the third parties' privacy policies. lf you access our sites or apps through third-party platforms (for example: Facebook, Google, TikTok), you are authorizing us to collect, store and use such information and content in accordance with this Policy. Any information provided to us by a third party may also be subject to such third party's privacy policy.:

2. Cookies and Other Tracking Technologies

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

Analyze our web and app traffic using an analytics package

Identify whether you already visited our Services

Store information about your preferences

To recognize when you return to our Services

Please read our Cookie Policy for more details over 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 commercial purposes, or as disclosed to you prior to such processing taking place. We may process your personal information:

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

(2) To Maintain Legal and Regulatory Compliance. Our Services are subject to certain laws and regulations which may require us to process your personal information. For example, we process your personal information to pay our taxes, to fulfill our business obligations, ensure compliance with employment and recruitment laws or as necessary to manage risk as required under 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 to our Terms. To ensure you comply with them, we process your personal information by actively monitoring, investigating, preventing and mitigating any alleged or actual prohibited, illicit or illegal activities on our Services. Subject to the applicable law, we may also process your personal information to investigate, prevent or mitigate violations of our internal terms, agreements or policies and 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 abusive use of our Service, monitor and verify your identity so that unauthorized users do not gain access to your information, enhance system security, and combat spam, malware, malicious activities or other security risks that might result in financial loss.

(5) To Provide Customer Support or Respond to You. We collect any information that you provide to us when you contact us. Without your personal information, we cannot respond to you or ensure 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. Such communications may include information about Privacy Policy updates, confirmations of your account actions or transactions, security updates or tips or other relevant transaction-related information. Service-related communications are not promotional in nature. You are not able to unsubscribe from such communications, otherwise you may miss important developments relating to your account or the Services.

(7) To Provide Marketing Communication (e.g., SMS, Email). We may collect your email address, phone number or other electronic addresses that you voluntarily provide to us when you choose to participate in our promoting activities or subscribe for marketing communications. When you no longer wish to receive these marketing messages from us, you can opt out at any time by unsubscribing or following the instructions contained within such messages. We may also collect and use your mobile advertising identifiers for the purpose of marketing campaigns. Please see our Cookies and Other Similar Tracking Technologies section for more information.

(8) To Research and Develop of Our Services. We may process your personal information and derive analytical and statistical data to better understand the way you use and interact with our Services. For instance, analyzing where, on which types of devices and how our Site is used, how many visitors we receive, and where they click on the Site may help us improve our existing Services and to build new Services. Please 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. By personalization, we enable you to interact with our Services more easily across platforms and devices. We also use it to remember you in case you re-visit our Site, so we will know if you have already been served with surveys, or (where Site content is undergoing testing) which version of the content you were served. Please 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 regarding your account and your use of our Services as is necessary in the context of corporate acquisitions, mergers or other corporate transactions.

(11) With Your Consent. For any other purpose disclosed to you prior to you providing us your personal information or which is reasonably necessary to provide the services or other related services requested, with your permission or upon your direction.

4. Sharing Your Personal Information

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

(1) As Required by Law. We may access, preserve, and disclose information about you if we believe doing so is required or appropriate to (a) comply with law enforcement requests and legal processes, 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, our, or others’ rights, property or safety.

(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 acting on our behalf to help us operate our Services. 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 performing network maintenance. These third parties can only use your information in accordance with our written instructions and must comply with the information security protections we have put in place. We contractually obligate our third-party service providers to protect your personal information.

(4) With Third Party Advertisers. In certain circumstances, and subject to the 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. The co-branded partners will be identified on the co-branded feature or service, along with an applicable co-branded partner's privacy policy. Use of your personal information by a co-branded partner will be subject to a co-branded partner's privacy policy. If you wish to opt-out of a co-branded partner's future use of your personal information, you will need to contact the co-branded partner directly.

(6) During Business Transaction or Other Asset Transfers. We may disclose and transfer information about you to buyers, service providers, advisors, potential transactional partners or other third parties in connection with the advisors, potential transactional partners or other thir

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