Privacy policy

Effective Date: September 7, 2026

Thank you for visiting the Halsten website and for viewing this Online Privacy Policy (the “Privacy Policy” or “Policy”). This Policy serves to give you notice about the types of personal information we collect, how we use it, and who we share it with and why. We describe these matters in detail in the pages that follow. We encourage you to read this Privacy Policy carefully.

The effective date on the Privacy Policy above indicates the date on which this Privacy Policy was last updated. The English language version of this Privacy Policy is the controlling version regardless of any translation you may attempt.

Please note that use of our website is also governed by our Terms and Conditions of Use (“Terms of Use”), which contain a class action waiver and mandatory arbitration clause governing all privacy related complaints and disputes except those falling under the Competent Data Protection Authority (defined in Section 12). We encourage you to read the Terms of Use carefully.

1. Navigating Through This Privacy Policy

You can use the links below to navigate to areas of this Privacy Policy that apply specifically to you, or which may otherwise be of interest:

Some Important Vocabulary
When And to Whom Does This Privacy Policy Apply
How Do We Collect Your Personal Information?
What Types of Personal Information Do We Collect?
How Do We Use the Personal Information We Collect?
When/With Whom Do We Disclose or Share Personal Information?
Do Not Track and Global Privacy Control
Cookie Notice
Children’s Privacy
Your Privacy Choices; Unsubscribing
Comprehensive Privacy Laws
Changes to This Privacy Policy
Contacting Us

2. Some Important Vocabulary

This Privacy Policy is an important document that explains how we address some of our legal obligations, and your related legal rights, involving personal information. We’ll use this section to let you know about some words that have special meanings whenever you see them in this Statement. Wherever we say “Halsten,” “Company,” “we,” “us,” or “our,” we mean Zenara Commerce LLC d/b/a Halsten. We use the words “you” and “your” to mean you, the reader, and other visitors to our website who are, in all cases, over the age of 13, or otherwise have verifiable parental consent to view this page. This age requirement is discussed in more detail later in this Policy here.

When we talk about our “website,” we mean our website found at www.tryhalsten.com and its subdomains, except where a separate privacy policy is applicable to the subdomain, and such others as we may make available from time to time. An “affinity action” is when you “follow” us, “like” us, or take a similar or analogous action on our external social media presence.

Finally, when we refer to “personal information,” we mean any information, data or data element, whether in electronic or other form, that, alone or in combination with other elements, can be used to distinguish, trace, or discover your identity. Certain data privacy laws include specific elements or defined terms for what they consider to be personal information (sometimes also referred to as “personal data”). Where such data privacy laws apply, then the term “personal” includes the specific elements and defined terms required by such laws.

3. When And to Whom Does This Privacy Policy Apply?

Our website collects personal information from visitors to, and users of, our website. We may also receive personal information from users who interact with our ads and content displayed on third-party sites. This Policy applies to our processing and sharing of personal information collected by those means. If we have legal obligations to other categories of data subjects, such as our employees, supply chain or business partners, or vendors, we provide them with separate legally required notices or other terms in confidential contracts, policies, and other similar documents.

4. How Do We Collect Your Personal Information?

We collect and otherwise obtain your personal information in the following ways: (a) via our website when you choose to give it to us by voluntary submission; (b) via our website through automatic collection by technical means when you visit or use our website; and (c) when it is provided to us by external sources such as marketing companies, advertising companies, social media companies, and/or companies that provide services on our behalf who, in each case, may have previously and separately collected elements of your personal information without our involvement and then shared it with us as part of a service for which we engaged that source.

Voluntary Submission.

Here are some ways you voluntarily give us your personal information:

  • Creating Accounts – If we make an account creation feature available you will provide us your email address and other identifiers.
  • Making Purchases – You may provide information to us when it is needed to fulfill your order.
  • Signing up for Newsletters – Similar to account creation, we collect some voluntarily submitted information if you sign up to receive a newsletter or other informational or marketing material we publish.
  • Registering for Events – If we host or sponsor an event or program that you register for, you will be submitting certain identifiers. If the event requires a fee, we may also ask you to submit credit card or other financial information.
  • Sending Emails and Texts – If you choose to send us an email from our “Contact Us” link or a similar link, you will be giving us your email address and any other personal information that may be in your message or attached to it. The same is true if you send us a text message.
  • Other Methods – Any other means by which you voluntarily submit personal information to us.

Your use of our website is strictly your choice. If you prefer that we not receive the above-described voluntarily submitted personal information, please don’t submit it. This means you shouldn’t participate in the applicable activities on, or use the applicable features available from, our website. By not participating in features that require voluntary submission of personal information, you may limit your ability to take full advantage of our website, but most of the content will still be available to you and we never discriminate on the basis of how much information you provide.

Automatic Collection.

When you visit or use our website, basic information about your internet/electronic activity is automatically collected through your browser and through the systems used to operate, secure, and support our website. In addition, we use cookies and other tracking technologies, which we describe in greater detail here. Those tools and/or cookies may collect some information about your preferences for using our website or past actions, such as:

  • your IP address and rough location;
  • the type of browser and operating system you use;
  • the date and time and length of your visit;
  • the pages visited, graphics viewed, and any documents downloaded; and
  • links to other sites you accessed from our website or used to navigate to our website.

If you access our website from a phone or other mobile device, the mobile services provider may transmit to us certain information such as uniquely identifiable mobile device information. That, in turn, allows us to collect mobile phone numbers and associate them with the mobile device identification information.

External Sources.

We may work with companies who provide us with data, including personal information, so that we can tailor our services to audiences who have the most interest. We also may work with digital advertising and marketing companies to provide you with ads that meet your interests and that enhance your experience with us. These ads may be displayed on websites or device applications operated by third parties. These third parties collect information with their own cookies, pixels, and related tracking technology and then provide that information to us. We are not responsible for their data collection practices.

Further, we maintain a presence on one or more external social media platforms such as Facebook and Instagram. We may allow the community features of our online and mobile resources to connect with, or be viewable from, that external social media presence. Similarly, our website may contain connections or links to such social media platforms, or other websites or apps controlled by third parties. We are not responsible for either the content on, or the privacy practices of, social media platforms, or any third-party sites or apps to which we link. Those apps, sites, and platforms are not controlled by us and therefore have their own privacy policies and terms and conditions of use. To be clear: neither this Privacy Policy nor our Terms of Use apply to our social media presence or any third-party sites or apps to which we may link. That means even if you take an affinity action on our external social media presence, and identifiers about you are automatically collected and given to us as a result, that collection and transfer is governed by the privacy policies and other terms of the applicable social media platform and are not our responsibility.

If you have questions about how those apps, sites, and platforms collect and use personal information, you should carefully read their privacy policies and contact them using the information they provide. In addition, certain coalitions of advertisers allow consumers to opt out of receiving interest-based advertising from members of those coalitions. You can visit the Digital Advertising Alliance and Network Advertising Initiative to opt out of receiving interest-based advertising from members of these coalitions. You will need to exercise these opt-outs on each browser on each device for which you wish to opt out of interest-based advertising.

5. What Types of Personal Information Do We Collect?

The categories of personal information we have collected from visitors and users of our website in the previous 12 months, and may collect from you, are as follows:

  • General Identifiers such as a real name, alias, online identifier, Internet Protocol address, date of birth, postal address, email address, account name, or other similar identifiers.
  • Customer Record Information such as payment card numbers, username, password, security questions, preferences and settings.
  • Commercial Information such as products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies.
  • Internet Activity Data or other similar electronic network activity information, such as browsing history, chat transcripts, search history, and information regarding your interaction with our online and mobile resources or an advertisement regardless of device type used, be it a personal computer, cell phone or other mobile device.
  • Geolocation Data including geographic coordinates/physical location.
  • Audio/Visual Data such as recordings of customer service phone calls, profile or account photos, or videos or other electronic recordings.
  • Professional or Employment Related Information such as occupation, job history, and performance evaluations.
  • Education Information such as grades or transcripts.
  • Analytics and Inference Data drawn using the above-described personal information to create a profile reflecting your interests and preferences or to otherwise improve our marketing strategies.
  • Any Other Personal Information That You Voluntarily Provide to Us

Sensitive Personal Information.

We may collect account credentials as well as your debit card or credit card number, considered in combination to be “sensitive personal information” as this term is defined by applicable law, solely to authenticate account access and process transactions. We do not sell or share this information.

Deidentified Information.

We may collect deidentified data and inferences derived from the categories of personal information described in this Statement. This data does not identify you in any way. We will not reidentify, or attempt to reidentify, any deidentified information that we collect as described in this Statement.

6. How Do We Use the Personal Information We Collect?

We use the personal information we collect only in the manner and through the means allowed by applicable law. That means we determine whether we have a lawful basis or legitimate business purpose to use your personal information before doing so. Generally speaking, we collect personal data from you where we have your consent to do so, where we need the personal data to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. Specifically, we use personal information for the following business purposes:

  • Transaction Processing – processing, completing, and maintaining records of transactions.
  • Performance of Contracts – fulfilling our duties and exercising our rights under contracts we may have with you or our vendors.
  • Improving our Website – using information to operate, improve, test, and support features on our website.
  • Promotions – providing personalized promotions and special offers.
  • General Marketing – providing users with information about our brand, products, and events or programs we may participate in or sponsor.
  • Tailored Marketing – providing users with marketing tailored to their interests.
  • Improving our Products and Services – using your information to operate, improve, and support our products and services.
  • Account Servicing – facilitating and servicing your account.
  • Technical Security – monitoring our networks and detecting security incidents.
  • Customer Service – responding to customer inquiries, including requests for information, online support, and phone calls.
  • User Experience – internal research and analytics to improve user experience on our website.
  • Knowing our Customers – understanding the demographics and interests of our website visitors.
  • Debugging – debugging, identifying, and repairing errors that impair existing intended functionality of our website.
  • Detecting and Preventing Unlawful Acts – protecting against malicious or illegal activity and prosecuting those responsible.
  • Verification – verifying users, when necessary, and responding to user requests.

We Do Not Sell Personal Information.

We do not sell, and within the last 12 months have not sold, personal information to third parties.

Retaining Your Personal Information.

We store and retain your personal information in accordance with applicable law and as long as necessary to carry out the purposes described above and in accordance with our internal data retention procedures. The criteria used to determine the retention periods include:

  • how long the personal information is needed in connection with the purposes for which we use it;
  • the type of personal information collected; and
  • whether we are subject to legal, contractual, or similar retention obligations (e.g., mandatory data retention laws, government orders to preserve personal information relevant to an investigation, or personal information that must be retained for the purposes of litigation or disputes).

7. When/With Whom Do We Disclose or Share Personal Information?

We may disclose the categories of personal information described in this Privacy Policy with the following categories of third parties for the business purposes described below:

  • Corporate Affiliates – We may share personal information with our corporate affiliates who will use such information in the same way as we can under this Privacy Policy.
  • Operations Support Vendors – We may share your personal information to vendors that help us to operate and increase the efficiency of our business and our website.
  • Customer Support Vendors – We may share your personal information with vendors that provide customer support services, such as chatbot, phone, or email support.
  • Promotional or Fulfillment Vendors – In order to carry out promotions we make available to you and/or deliver our products and services, we are required to share personal information with vendors who specialize in those activities.
  • Software and Technology Vendors – Our various service providers may have access to or be provided with some of your personal information in connection with the tasks they perform on our behalf such as maintaining portions of our networks or the software applications that run on them. Some of our vendors may provide us with, or support their own services with, artificial intelligence tools.
  • Transaction Support Vendors / Payment Processors – We share personal information with those of our vendors and business partners that process payments on our behalf and send you confirmations and administrative messages.
  • Marketing and Advertising Providers – We may share your personal information to third parties, including social media networks, who support online advertising, data co-operatives, mobile advertising, data analytics, social media engagement, and other advertising networks that support our marketing efforts.
  • Analytics Providers – Third-party providers who assist us in analyzing our web traffic, some of whom are characterized as “marketing analytics companies,” such as Google Analytics.
  • Security and Fraud Prevention Providers – We also may disclose personal information to third party security and fraud prevention providers when we have reason to believe that someone is causing injury to or interference with our rights or property or harming or potentially harming other persons or property.
  • Law Enforcement or Government Agencies – We may disclose personal information to government agencies and authorities, and to other third parties when compelled to do so by such government authorities, or at our discretion, or otherwise as required or permitted by law, including responding to court orders and subpoenas.
  • Successors for Business Sale/Purchase – If we, or any of our affiliates, sell or transfer all or substantially all of our assets, equity interests, or securities, or are acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, divestiture, consolidation, or liquidation, personal information may be one of the transferred assets.

Sharing Personal Information.

In some jurisdictions, our disclosure of personal information to third-party providers for marketing and advertising could be defined as “sharing” personal information for “cross-context behavioral advertising.” We may “share” the following categories of information to third parties for these purposes: (1) general identifiers and personal information, such as unique device identifiers, email addresses, account information, IP addresses, information related to your browser and operating system, or any information that you provided through the website; and (2) user activity data, such as data generated through your activities on our website.

8. Do Not Track and Global Privacy Control

Certain browsers and plug-ins allow users to send signals such as Do Not Track (“DNT”) or Global Privacy Control (“GPC”). While we do not respond to DNT signals, we do honor GPC signals as a valid request to opt-out of the sale or sharing of your personal information where required by applicable law.

When we receive a GPC signal, we will process it in the same manner as a request to opt-out of any sale or sharing of your personal information that occurs via cookies or similar tracking technologies on our website. Please note that this opt-out mechanism applies only to the specific browser or device on which the signal is sent, and you may need to adjust your settings on each browser or device you use.

We use cookies, pixels, tags, and other tracking technologies to provide, protect, and improve our website and to collect, use, disclose, and share your information as described in this Privacy Policy. This section explains how we use cookies and the choices you have.

What is a cookie and why do we use them?

A “cookie” is a small text file that is placed onto your device when you access a website or application. Cookies help websites remember information about your visit, which can both make it easier to visit the website again and make the site more useful to you. Other tracking technologies including, without limitation, embedded scripts, web pixels, web tags, web storage, web beacons, and identifiers associated with your app or device, operate in a similar manner to cookies and are used for similar purposes. We refer to all of these technologies as “cookies.”

Who can place cookies on your device?

When you visit our website for the first time, we will ask for your permission to place non-essential cookies on your device. Depending on your choices, both Halsten and our trusted third parties may place cookies on your device. Cookies placed by Halsten are considered “first-party cookies,” whereas cookies placed by our partners or on their behalf are considered “third-party cookies.”

How long do cookies stay on your device?

Cookies can be either temporary or non-temporary as follows:

  • Session cookies are temporary and allow websites to track a user’s actions during their browser session. Session cookies are removed from your device after you leave the website you are currently visiting.
  • Persistent cookies are non-temporary and remember a user’s actions and preferences on a website, or across different websites, over time. Persistent cookies remain on a user’s device until they expire at a pre-determined time (e.g., 30 days after being downloaded), or until the user deletes them, such as by clearing browser cookies or site data.

What types of cookies do we use?

The following types of cookies are used on our website:

  • Non-Advertising/Non-Marketing cookies, also known as strictly necessary cookies, including essential cookies, preference cookies, and performance/statistics cookies. These cookies are essential for security and network management and to allow you to browse our website and use its features, as well as remember choices you have made on our website in the past. Typically, these are a mix of first-party and third-party session cookies. They do not involve sharing information with third parties for any type of marketing, advertising, or commercialization purposes.
  • Advertising/Marketing/Analytics cookies, often referred to as non-essential cookies. These cookies are almost always third-party cookies and typically involve sharing certain elements of your data with those third parties for advertising, marketing, or analytics. For example, we use third-party “web analytics” services such as those offered by Google Analytics. For more information on how Google specifically uses this data, go to www.google.com/policies/privacy/partners.

How can I manage or opt-out of cookies?

When you first visit our website, we will provide you the opportunity to opt-out of advertising/marketing/analytics cookies. We are not able to opt you out of strictly necessary/essential cookies because, as described above, they are necessary for the technical functioning of our website. If you accepted our use of non-essential cookies on your first visit and later change your mind, you can navigate away from our website, clear your browser’s cookies and/or site data, and then revisit our site clicking “Reject” in the banner that will be re-presented. You also can learn more about how to opt-out of Google Analytics via their site by going to https://tools.google.com/dlpage/gaoptout.

10. Children’s Privacy

U.S. federal law imposes special restrictions and obligations on commercial website operators who direct their sites toward, and collect and use information from, children under the age of 13. We take those age-related requirements very seriously and, consistent with them, do not intend for our website to be used by children under the age of 18, and certainly not by anyone under the age of 13. If we become aware that anyone under the age of 13 has submitted personal information to us via our website, we will delete that information and not use it for any purpose whatsoever.

11. Your Privacy Choices; Unsubscribing

By signing up to any of our promotional lists, you are giving your express permission to us and our agents or vendors the right to contact you with targeted advertising materials by email, text message (“SMS”), telephone or cellphone, including the use of automated, predictive, programmable, or similar automatic dialers or dialing software, or any other means of communication we may utilize to provide promotional offers. Your consent is not a condition of purchase. To the extent applicable, you expressly acknowledge that you are solely responsible for all charges billed by your mobile service provider. We may share your data, including your SMS opt-in or consent status, with third parties that help us provide our messaging services, including but not limited to platform providers, phone companies, and any other vendors who assist us in the delivery of promotional messages.

If you no longer wish to receive promotional communications by email, please follow the unsubscribe link located at the end of an email message. If you no longer wish to receive promotional text messages, reply STOP, END, CANCEL, UNSUBSCRIBE, or QUIT to any mobile message from us. When we receive your request, we will take reasonable steps to remove you from our distribution lists, but it may take time to do so. You may still receive materials for a period of time after you unsubscribe. Unsubscribing or changing affinity actions or other submissions or requests made on our external social media presence, will likely require that you do so directly on that applicable social media platform as we do not control their procedures.

12. Comprehensive Privacy Laws

Privacy and data protection laws vary around the world and among individual states in the U.S. Our obligations arising under the majority of the world’s privacy laws, including U.S. federal and most state laws, are satisfied by individual risk assessments that we conduct to ensure we act reasonably and responsibly when processing your personal information.

In some jurisdictions privacy laws grant you certain specific rights regarding your personal information. We refer to these types of privacy laws as “Comprehensive Privacy Laws.” Examples of Comprehensive Privacy Laws include the respective versions of the General Data Protection Regulation adopted in the European Economic Area and the United Kingdom (collectively, “GDPR”) and California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act (collectively, “CCPA”).

Whether and how a particular Comprehensive Privacy Law applies to us involves a complex assessment of factors such as the degree to which we direct our business at the residents of a particular jurisdiction and the volumes of personal information we collect from that jurisdiction. At this time, we believe that the nature, scope, and locations of our business activities make us subject to certain U.S. state Comprehensive Privacy Laws, including the CCPA. For purposes of this section, the words “you” and “your” mean only those data subjects protected by the Comprehensive Data Privacy Laws we currently, or may later, determine apply to us (“Applicable Comprehensive Privacy Laws”).

Your Rights under Applicable Comprehensive Privacy Laws.

You have the following rights under Applicable Comprehensive Privacy Laws. It’s important to us that you know that if you exercise these rights, we will not discriminate against you by treating you differently from other data subjects who use our website but do not exercise their rights.

Right to Know. You have the right to request that we disclose the personal information that we have collected about you and identify the purposes for which such information was used, whether and to whom it was shared, and what sources it was obtained from.

Right to Delete. You have the right to request that we delete any personal information that we maintain about you, subject to certain exceptions.

Right to Correct. You have the right to correct any personal information that we store about you.

Right to Opt-Out of Selling or Sharing. While we do not engage in selling personal information you may opt out of the sharing of your personal information by emailing us at info@tryhalsten.com

Right to Opt-Out of Profiling or Automated Decision Making. To the extent applicable, you have the right to not be subject to profiling or automated decision making in furtherance of decisions that produce legal or similarly significant effects.

Right to Data Portability. You have the right to request that we provide you with a copy of your personal information on file with us.

Right Not to Receive Discriminatory Treatment. Exercising your privacy rights under this Privacy Policy will not result in any discrimination by us. We will treat you the same as any other user.

Right to Complain. You have the right to complain to the data protection authority identified in applicable Comprehensive Data Protection Law as having competent authority (the “Competent Data Protection Authority”).

Right to Appeal. If you make a request to exercise any of the applicable personal information access rights as detailed herein and we are unable to comply with your request, you may request to appeal our decision. To appeal any data privacy request decision, please contact us by emailing us at info@tryhalsten.com with the subject line “Data Access Request Appeal.” If after you complete the appeal process with us, you are still not satisfied with our response, you may contact your Competent Data Protection Authority as detailed below.

How to Exercise Your Rights under Applicable Comprehensive Privacy Laws.

In order for you or an agent you may designate to exercise any of the above rights, please contact us at info@tryhalsten.com. We will confirm our receipt in the time frames prescribed by Applicable Comprehensive Privacy Laws.

We may, however, be prevented from acting on your request because Applicable Comprehensive Privacy Laws only allow us to act if we can verify your identity and/or your agent’s authority to make the request. You will also need to follow our instructions in this regard, which may include asking you to fill out a request form. The identity verification steps we use may vary depending on the sensitivity of the information and whether you have an account with us.

If we are unable to verify your identity, we may deny your requests to know or delete. In addition, Applicable Comprehensive Privacy Laws place limits on how often you can exercise your right to know. We will advise you if you exceed these limits and explain to you what they are.

13. Changes To This Privacy Policy

We reserve the right to change or update this Privacy Policy from time to time. Please check our website periodically for such changes since all information collected is subject to the Privacy Policy in place at the time of collection. We will indicate the effective/amendment date at the beginning of this Privacy Policy.

14. Contacting Us

If you have questions about this Privacy Policy or our privacy practices, please contact us at info@tryhalsten.com.