Halo Dogs Privacy policy
Halo Dogs Privacy Policy
Version 2.0 – Last updated: 13 July 2025
1. Introduction
This Privacy Policy (“Policy”) outlines the principles, practices, and procedures followed by Halo Dogs Ltd (“Halo Dogs”, “we”, “our” or “us”) to ensure the protection, lawful handling, and responsible processing of personal data in accordance with applicable laws. These include, without limitation, the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and other relevant data protection legislation and regulatory guidelines issued by the Information Commissioner’s Office (ICO).
Halo Dogs operates a multifaceted business combining dog day care, luxury boarding, behavioural and obedience training, puppy socialisation, veterinary liaison, grooming, and a registered canine rescue and rehabilitation charity. In delivering these services, we routinely collect and process a wide array of data from dog owners, suppliers, staff, charitable donors, veterinary professionals, and other stakeholders. This Policy details our commitment to protecting this information throughout its lifecycle—from initial collection and lawful justification, to retention, sharing, security, and deletion.
Our data handling practices are designed to be transparent, fair, and proportionate to the needs of the service. We treat all personal data as a critical asset, essential to providing safe, effective, and high-quality canine care, while maintaining full respect for the rights and expectations of data subjects. Whether you’re a first-time visitor to our website, a long-standing client boarding your dog with us, a rescue applicant, or a supplier interacting with our administrative systems, we want you to understand exactly how your data is managed and protected.
In particular, this Policy aims to help you understand:
- What personal data we collect and why
- How we ensure that the processing of data is fair, lawful, and transparent
- How we safeguard and manage your data, both digitally and physically
- Who we may share your data with and under what circumstances
- What your legal rights are under UK data protection law
- How you can contact us to exercise your rights or raise concerns
We understand that your data—and the data of your dog—matters. Whether that information includes your contact details, your dog’s health conditions, emergency instructions, or payment information, we are committed to handling it with the care and responsibility it deserves.
This Policy applies to all personal data collected and processed by Halo Dogs Ltd, regardless of format (electronic, paper, photographic or verbal), and across all channels and locations. It is binding on all employees, contractors, volunteers, and third-party processors who handle data on our behalf.
We encourage you to read this Policy carefully and contact us at mypet@halodogs.co.uk if you have any questions, concerns, or requests related to your personal data.
2. Definitions
For the purpose of this Policy, the following terms are defined as follows:
- Personal Data: Any information that relates to an identified or identifiable natural person.
- Processing: Any operation or set of operations performed on personal data, whether or not by automated means. This includes collection, storage, retrieval, use, transmission, dissemination, or destruction.
- Data Subject: The individual to whom the personal data relates.
- Data Controller: The entity that determines the purposes and means of the processing of personal data—in this case, Halo Dogs Ltd.
- Data Processor: An entity that processes personal data on behalf of the Data Controller.
- UK GDPR: The retained EU law version of the General Data Protection Regulation (EU) 2016/679 as it applies in the UK.
- Special Category Data: Sensitive personal data including health, biometric, or other information requiring heightened protection.
3. Scope of This Policy
This Policy governs all processing of personal data by Halo Dogs in connection with its business operations, whether collected directly from you or indirectly via third parties acting on your behalf (such as veterinarians, referring trainers, or professional service agents).
This includes but is not limited to data collected when you:
- Visit or use our website (www.halodogs.co.uk)
- Make enquiries about our services or facilities
- Register your dog for day care, boarding, or training
- Subscribe to newsletters or marketing communications
- Donate or support our affiliated dog rescue and rehabilitation charity
- Engage with us via social media platforms or marketing campaigns
It applies to all current, past and prospective clients, and includes both in-person and digital interactions.
4. Legal Bases for Processing
Halo Dogs will only process your personal data when we have a lawful basis to do so under UK data protection laws. These include:
- Consent: You have given clear permission for us to process your data for a specific purpose, such as email marketing or consent to photograph your dog during activities.
- Contractual Necessity: The data processing is required to enter into or perform a contract—for example, to fulfil your booking for boarding, training, or day care.
- Legal Obligation: We are required to process data to comply with legal obligations, including tax recordkeeping, health & safety, and animal welfare regulations.
- Legitimate Interests: We process data to pursue our legitimate business interests in a way that is not overridden by your rights and freedoms. Examples include service improvement, fraud prevention, CCTV security, and internal analytics.
We will inform you at the point of data collection which lawful basis applies, and when consent is required, you may withdraw it at any time by contacting mypet@halodogs.co.uk.
5. Categories of Data We Collect
Halo Dogs collects a variety of personal data depending on your relationship with us. These categories include:
- Client Identity Data: Name, address, date of birth, contact telephone number, email, preferred pronouns.
- Dog Profile Data: Name, breed, age, gender, neutering status, microchip number, veterinary records, behavioural notes, vaccination history, diet, insurance details, and medical or welfare needs.
- Booking & Transaction Data: Dates of bookings, services rendered, payments, refunds, special requirements, vehicle registration (for chauffeur collection/drop-off), invoices, and billing address.
- Marketing & Communication Data: Newsletter subscription status, opt-in or opt-out preferences, participation in promotions, event attendance, photo usage consent, and customer service communications.
- Website & Technical Data: IP address, device type, browser type and version, operating system, referral source, cookies and site usage data, pages visited, time spent on site.
- Social Media Data: Publicly available content and metadata from interactions with Halo Dogs’ official profiles on platforms like Facebook, Instagram, TikTok, or LinkedIn.
- Charity Supporter Data: Donation history, gift aid status, fundraising participation, and communications preferences related to Halo Dogs Rescue & Rehabilitation Charity.
In addition, CCTV and on-site photography may capture images or video recordings of you and/or your dog during drop-off, pick-up, assessments, training sessions, or enrichment activities.
6. Automated Decision-Making and Profiling
Halo Dogs does not currently undertake automated individual decision-making, including profiling, as defined in Article 22 of the UK GDPR. All decisions concerning your dog’s welfare, behavioural assessments, and suitability for various services are made manually by qualified staff based on professional judgement, documented history, and behavioural observations.
Should automated profiling or decision-making processes be introduced in the future (e.g. automated risk flagging via digital intake forms or CRM systems), we will notify you explicitly, explain the logic involved, and outline the significance and potential consequences of such processing. Where required by law, we will obtain your explicit consent prior to implementation, and you will retain the right to request human intervention, to express your point of view, and to contest the decision.
We may use non-intrusive profiling techniques for service tailoring—for example, categorising customers by dog breed, training level, or frequency of use for targeted communications—but such profiling does not produce legal or significant effects on individuals.
7. Cookies and Web Tracking
When you visit our website (halodogs.co.uk), we may store or retrieve information on your browser, mostly in the form of cookies. Cookies are small text files that are placed on your device to help the site provide a better user experience. This information might be about you, your preferences, or your device, and is mostly used to make the site work as you expect it to. The information does not usually directly identify you, but it can give you a more personalised web experience.
We categorise our cookies as follows:
- Strictly Necessary Cookies: These cookies are essential for the operation of our website. They include, for example, cookies that enable you to log into secure areas or submit booking forms.
- Performance Cookies: These allow us to recognise and count the number of visitors and to see how visitors move around our website. This helps us to improve the way our website works, for example, by ensuring users are finding what they are looking for easily.
- Functional Cookies: These are used to recognise you when you return to our website. This enables us to personalise our content for you and remember your preferences (e.g. your choice of language or region).
- Targeting or Marketing Cookies: These cookies record your visit to our website, the pages you have visited and the links you have followed. We use this information to make our website and the advertising displayed on it more relevant to your interests.
We use third-party tools such as Google Analytics to analyse traffic to our website. Google may use cookies or other tracking technologies to collect information about your use of our website and other websites. You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on available at https://tools.google.com/dlpage/gaoptout.
You will be presented with a cookie consent banner when visiting our site for the first time. You have the right to choose which categories of cookies you allow, except for those that are strictly necessary. Your preferences can be adjusted at any time via our cookie management tool found in the website footer.
Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. Please be aware that disabling cookies may affect the functionality and performance of our website.
We may share personal data with:
- Veterinary professionals during medical emergencies
- Regulatory bodies (e.g., DEFRA, local authorities)
- Our CRM and booking software providers
- Third-party payment gateways (Stripe, PayPal)
- Law enforcement if required by law or court order
9. International Transfers
Some service providers may store data in countries outside the UK. In these cases, we ensure data is protected with:
- Standard Contractual Clauses (SCCs)
- UK adequacy decisions
- Encryption and restricted access
10. Data Retention
We retain your data for specific periods:
- Dog service records: 7 years from last service
- Billing and invoices: 7 years (HMRC compliance)
- Marketing preferences: Until unsubscribed
- CCTV footage: 30 days unless flagged for incident investigation
11. Your Data Protection Rights
You have the following rights under the UK GDPR:
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure (“right to be forgotten”)
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision making and profiling
To exercise any of these rights, email mypet@halodogs.co.uk. We aim to respond within one calendar month.
12. Making a Complaint
If you have any concerns about the way Halo Dogs processes your personal data, we encourage you to raise them with us directly so that we can investigate and resolve the issue as promptly and transparently as possible. We take all privacy-related matters seriously and aim to provide fair, timely, and satisfactory resolutions in accordance with data protection legislation.
Step 1: Contacting Us
Please send your complaint in writing to our Privacy Lead via email at mypet@halodogs.co.uk or by post to our registered address:
Halo Dogs Ltd
Holly Hill Farm, The Ridgeway, EN2 8AN
Attention: Privacy Lead
Include as much detail as possible in your correspondence, such as dates, relevant services, and the nature of the concern. We will acknowledge your complaint within five working days and aim to provide a formal response within 30 calendar days.
Step 2: Review and Investigation
If your concern requires further investigation or additional time, we will inform you of the reason and provide an updated timeline. We may request additional information to help clarify your issue and ensure that the correct internal processes are followed. Our Privacy Lead may consult with relevant team members to determine the root cause and any necessary corrective actions.
Step 3: Outcome and Resolution
Once the investigation is complete, we will provide a written response outlining the outcome and any actions taken, including steps to prevent recurrence. If you remain dissatisfied with our decision, you may request a secondary review by our Managing Director or escalate the matter to an independent authority.
Step 4: Contacting the Information Commissioner’s Office (ICO)
If you are unsatisfied with our response or believe that we are not processing your data lawfully, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK’s independent authority for upholding information rights:
Information Commissioner’s Office (ICO)
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 0303 123 1113
Website: https://ico.org.uk/make-a-complaint/
We advise contacting us first before reaching out to the ICO, but this is not mandatory. You may also seek independent legal advice or contact consumer rights organisations if you wish to escalate further.
13. Changes to This Privacy Policy
We regularly review and update this Privacy Policy to reflect changes in our services, technology infrastructure, legal obligations, or user feedback. The most recent version will always be available on our website, and the version number and date of last update are listed at the top of this document.
Updates may occur for various reasons, including:
- New services or features offered by Halo Dogs that affect the nature of personal data processing
- Changes to UK legislation or guidance from the Information Commissioner’s Office (ICO)
- Feedback from clients, legal advisors, auditors, or supervisory authorities
- Expansion of our premises, team structure, or third-party partnerships
If we make material changes that significantly impact your privacy rights—for example, changes to how we collect or share data—we will take appropriate steps to notify you in advance. These may include direct communication via email (if we hold your contact details), pop-up banners on our website, or notices within our booking system.
You are encouraged to revisit this page periodically to stay informed about how we protect your data. Continued use of our services following a policy update will be interpreted as acceptance of the changes unless otherwise stated.
For historical reference, a full version log is available under Section 26: Version History and Governance.
14. Contacting Us
Halo Dogs Ltd
Holly Hill Farm, The Ridgeway, EN2 8AN
Email: mypet@halodogs.co.uk
Phone: 020 8367 7899
Web: www.halodogs.co.uk
15. Data Protection Impact Assessments (DPIAs)
Halo Dogs carries out Data Protection Impact Assessments (DPIAs) when launching new technologies or services that may pose a high risk to the rights and freedoms of individuals. For example, we conduct DPIAs when evaluating third-party software for booking, when changing the way customer feedback is collected, or when deploying new CCTV systems. DPIAs help us identify, assess, and minimise privacy risks and ensure compliance with Article 35 of the UK GDPR.
16. Security Measures and Safeguards
We implement appropriate technical and organisational measures to secure personal data, including but not limited to:
- Encryption of sensitive digital records at rest and in transit
- Role-based access controls and multi-factor authentication for internal systems
- Regular staff training on data protection and cybersecurity
- Physical access controls for sensitive areas and CCTV monitoring
- Routine vulnerability assessments and external audits
These safeguards are reviewed annually and after any significant operational changes.
17. Children’s Data and Parental Consent
We do not knowingly collect personal data directly from children under the age of 13. Any data collected that relates to minors—such as children visiting the premises with parents or guardians—is handled with appropriate safeguards. Where data is collected from a minor (e.g., testimonials, photos), we will seek parental or guardian consent in accordance with Article 8 of the UK GDPR.
18. Direct Marketing Practices
Halo Dogs may send email marketing communications to individuals who have provided prior consent or who are existing customers under the soft opt-in exemption. These communications may include service updates, promotions, seasonal booking notices, or charity campaign appeals. You may unsubscribe at any time by clicking the “unsubscribe” link at the bottom of the email or by contacting mypet@halodogs.co.uk.
19. Links to Third-Party Sites
Our website may contain links to third-party websites such as veterinary partners, industry awards, or charity platforms. This Privacy Policy does not apply to third-party websites, and we are not responsible for the privacy practices of such sites. We recommend reviewing their privacy notices before submitting personal data.
20. Data Accuracy and Updating Mechanisms
We rely on our customers and service users to ensure their information is up to date. You can update your details by contacting our admin team or using the self-service features in our booking system. Halo Dogs will take reasonable steps to ensure that inaccurate personal data is rectified or erased without delay under Article 5(1)(d) of the UK GDPR.
21. Law Enforcement Requests
We may disclose personal data to law enforcement agencies, government authorities, or regulators if required to do so by law, legal process, or in response to valid requests under the Investigatory Powers Act 2016, Data Protection Act 2018, or other applicable UK law. We will ensure all requests are assessed for legal validity before disclosure and will log such requests where appropriate.
22. Veterinary and Welfare-Linked Sharing Protocol
In the interest of animal welfare, we may share dog-related data—including behavioural observations, medical history, and diet—with registered veterinary professionals or qualified animal behaviourists, particularly in emergency situations. Data is shared only when necessary to protect the vital interests of the dog or others and may also be used to complete insurance forms, health assessments, or treatment plans.
23. Record of Processing Activities (ROPA)
Halo Dogs maintains a full Record of Processing Activities as required under Article 30 of the UK GDPR. This document includes all categories of personal data, purposes of processing, recipients, international transfers, and security measures. The ROPA is reviewed annually and upon major changes to our services or processing practices.
24. Data Breach Procedures and Notifications
We have an internal incident response plan in place to identify, assess, and report data breaches in accordance with Articles 33 and 34 of the UK GDPR. In the event of a personal data breach likely to result in a risk to individuals’ rights and freedoms, we will notify the ICO within 72 hours and affected data subjects without undue delay.
25. Data Protection Officer Contact
While Halo Dogs is not legally required to appoint a Data Protection Officer (DPO), we have appointed a privacy lead responsible for compliance and oversight. You may contact our privacy lead with any concerns regarding this Policy at:
Email: mypet@halodogs.co.uk
Phone: 020 8367 7899
26. Version History and Governance
This Privacy Policy is reviewed annually or upon any significant change in services, legal obligations, or processing activities. Below is a summary of version changes:
- Version 1.0 – Published May 2021 – Initial version
- Version 2.0 – Updated July 2025 – Full overhaul with UK GDPR compliance and expanded scope
Any future updates will be logged here. We encourage users to review this policy regularly to stay informed about how we protect personal data.
