Privacy Policy

Last Updated: 08.10.2020

HALA Digital OÜ (“us”, “we”, or “our”) operates the hala.ai website (the “Service”).

This Privacy Policy explains what information HALA Digital OÜ and its related entities ("Hala", "we", "us", or “our”) collect about you, why we collect it, and how we handle the information you upload into our products and services. We make clear the choices available to you regarding our use of your personal information and describe how you can access, update and remove this information.

This policy applies across all websites that we own and operate and all services we provide, including hala.ai and hala.one (https://www.hala.ai and https://www.hala.one subdomains). For the purpose of this document, we’ll refer to them simply as our ‘services’.

By registering for or using our services you consent to the collection, transfer, processing, storage, disclosure and other uses described in this Privacy Policy.

Information you provide

Personal information

Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable.

We collect personal information when you register for an account, create or modify your profile, apply for a job, or otherwise use, access, or interact with our services. Personal information we collect for all users includes:

You may enter this information yourself, or alternatively, your name and email address may be entered by an account administrator to create an account on your behalf (usually someone from your organisation, or a trusted third party such as your accountant).

We also collect the following personal information from the owner of the Hala account:

Other information that we collect for all users includes:

Accounting information

Hala’s core activity is to provide intelligent virtual assistant services facilitating financial analysis, reporting, accounting data and all other information available in the business entities such as companies, trusts etc. To provide this functionality, Hala allows you to import into Hala’s service:

This information can be entered manually, uploaded from a spreadsheet you provide or imported directly from third party services (eg. Xero, FreshBooks, Intuit) where you have given us permission to do so. In the latter case we securely store access tokens which allow us to update the accounting information in Hala on your behalf.

Information Collection

Log Data
We may also collect information that your browser sends whenever you visit our Service (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages and other statistics.

In addition, we may use third-party services such as Google Analytics that collect, monitor and analyze this type of information in order to increase our Service’s functionality. These third-party service providers have their own privacy policies addressing how they use such information.

Usage and Data analytics

We collect usage data automatically as you interact with our services. This data is useful for us as it helps us get a better understanding of how you’re using our websites and services so that we can continue to provide the best experience possible (e.g., by personalising the content you see).

This information may include search queries, pages you visit, information on the device you are using, features you use, actions you take etc.

Occasionally we connect usage data to personal information in order to provide customer support or improve our services for individual customers. Where this occurs, it is for internal use and the combined information is used in accordance with the privacy policy.

We currently use Google Analytics as an analytics provider. To learn more about the privacy policy of Google Analytics, refer to Google's Policies and Principles. You can also use the Google Analytics Opt-out Browser Add-on to prevent analytics information from being sent to Google Analytics.

Support data

Hala uses various third party service providers to help us provide customer support to our users. In the course of obtaining support you may provide personal information or other commercially confidential information required to resolve an issue. The communication may occur by web-form, through a pop-up chat service, via email or by phone. The communication, including any file attachments, may be stored by these service providers.

The communication may also be shared with the third party service from which you imported accounting information (eg. FreshBooks, Intuit) for the purpose of troubleshooting and providing customer support.

Cookies
A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Hala uses cookies to help us identify and authenticate visitors, track usage, and store preferences. You can configure your browser to stop accepting cookies or to prompt you before accepting a cookie from websites you visit, however most aspects of the Hala Services will not function properly without the aid of cookies.

Hala and our third party partners also use other tracking technologies like ‘web beacons (also known as "tracking pixels"). These are tiny images that may be used in our websites or in emails to help us count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon.

Information we collect from other sources

We may also obtain information from third parties and combine that with information we collect within Hala. For example, we may have access to certain information from a third party authentication service (eg. Intuit) if you log into Hala through the service or otherwise provide us with access to information from the service. Any access that we may have to such information from a third party authentication service is in accordance with the authorisation procedures determined by that service, which will usually include a confirmation screen explaining to you what data will be shared. By authorising us to connect with a third party service, you typically authorise us to access and store your name, email address(es), current city, profile picture URL, and other information that the third party service makes available to us, and to use and disclose it in accordance with this Privacy Policy. You should check your privacy settings on these third party services to understand and change the information made available to us through these services.

Information Use

Principles

General

The personal information we collect is used for a variety of purposes including to:

Other uses of your information are outlined below.

Third party services

We may share your information with third party service providers who provide services to us to help with our business activities. These companies are authorised to use your personal information only as necessary to provide these services to us. These services include payment processing, customer service, sending marketing communications, research and analysis, hosting, backup, cloud computing infrastructure.

Hala takes steps to ensure that information is treated confidentially by third party service providers. If you would like more information on the services we use, please contact us using the contact information below.

Cooperation

In the event that a Data Subject or Supervisory Authority made a request relating to the processing of Personal Data under the Agreement to Hala. Hala shall not respond to such communication directly without Customer’s prior authorization, unless legally compelled to do so. If Hala is required to respond to such a request, Hala shall promptly notify Customer and provide it with a copy of the request unless legally prohibited from doing so.

If a Supervisory Authority or law enforcement agency sends Hala a demand for Customer Data (for example, through a subpoena or court order), Hala shall attempt to redirect the Supervisory Authority or law enforcement agency to request that data directly from Customer. As part of this effort, Hala may provide Customer’s basic contact information to the Supervisory Authority or law enforcement agency. If compelled to disclose Customer Data to Supervisory Authority or law enforcement agency, then Hala shall give Customer reasonable notice of the demand to allow Customer to seek a protective order or other appropriate remedy unless Hala is legally prohibited from doing so.

Return or Deletion of Data

Upon termination or expiration of the Agreement, Hala shall (at Customer’s election) delete or return to Customer all Customer Data (including copies) in its possession or control, this requirement shall not apply to the extent Hala is required by applicable law to retain some or all of the Customer Data, or to Customer Data it has archived on back-up systems, which Customer Data Hala shall securely isolate and protect from any further processing, except to the extent required by applicable law.

Customer obligation

Customer agrees to:

- Provide instructions to Hala and determine the purposes and general means of Hala’s processing of Customer Personal Data in accordance with the Terms of usage.

- Comply with its obligations as a Data Controller under Data Protection Laws in respect of its processing of Customer Data and any processing instructions it issues to Hala.

- Provide notice and obtained (or shall obtain) all consents and rights necessary under Data Protection Laws for Hala to process Customer Data and provide the Services pursuant according to the Terms of usage.

- Comply with its protection, security and other obligations with respect to Customer Personal Data prescribed by Data Protection Requirements for data controllers by: (a) establishing and maintaining a procedure for the exercise of the rights of the individuals whose Customer Personal Data are processed on behalf of Customer; (b) processing only data that has been lawfully and validly collected and ensuring that such data will be relevant and proportionate to the respective uses; and (c) ensuring compliance with the provisions of this Agreement by its personnel or by any third-party accessing or using Customer Personal Data on its behalf.

- Customer acknowledges that in connection with the performance of the Services, Hala employs the use of cookies, unique identifiers, web beacons and similar tracking technologies (“Tracking Technologies”). Customer shall maintain appropriate notice, consent, opt-in and opt-out mechanisms as are required by Data Protection Laws to enable Hala to deploy Tracking Technologies lawfully on, and collect data from, the devices of Data Subjects in accordance with and as described in the Hala Cookie Statement.

Hala obligation

Processing Requirements

Hala shall:

a. Process Customer Personal Data (i) only for the purpose of providing, supporting and improving Hala’s services, using appropriate technical and organizational security measures; and (ii) in compliance with the instructions received from Customer. Hala will promptly inform Customer if it cannot comply with the requirements under this Policy, in which case Customer may terminate the Agreement or take any other reasonable action, including suspending data processing operations;
b. The parties agree that this Policy and the Agreement set out the Customer’s complete and final instructions to Hala in relation to the processing of Customer Data and processing outside the scope of these instructions (if any) shall require prior written agreement between Customer and Hala;
c. Inform Customer promptly if, in Hala’s opinion, an instruction from Customer violates applicable Data Protection Requirements;
d. Take commercially reasonable steps to ensure that (i) persons employed by it and (ii) other persons engaged to perform on Hala’s behalf comply with the terms of the Agreement;
e. Ensure that its employees, authorized agents and any Sub-processors are required to comply with and acknowledge and respect the confidentiality of the Customer Personal Data, including after the end of their respective employment, contract or assignment;
f. Upon request, provide Customer with a summary of Hala’s privacy and security policies; and
g. Inform Customer if Hala undertakes an independent security review.

Notice to Customer

Hala will inform Customer if Hala becomes aware of:

a. Any non-compliance by Hala or its employees with this Policy relating to the protection of Customer Personal Data processed under this Policy;
b. Any legally binding request for disclosure of Customer Personal Data by a law enforcement authority, unless Hala is otherwise forbidden by law to inform Customer, for example to preserve the confidentiality of an investigation by law enforcement authorities;
c. Any notice, inquiry or investigation by a Supervisory Authority with respect to Customer Personal Data; or
d. Any complaint or request (in particular, requests for access to, rectification or blocking of Customer Personal Data) received directly from Data Subjects of Customer. Hala will not respond to any such request without Customer’s prior written authorization.

Assistance to Customer

Hala will provide reasonable assistance to Customer regarding:

a. Any requests from Customer Data Subjects in respect of access to or the rectification, erasure, restriction, portability, blocking or deletion of Customer Personal Data that Hala processes for Customer. In the event that a Data Subject sends such a request directly to Hala, Hala will promptly send such request to Customer;
b. The investigation of Security Incident and the notification to the Supervisory Authority and Customer’s Data Subjects regarding such Personal Data Breaches; and
c. Where appropriate, the preparation of data protection impact assessments and, where necessary, carrying out consultations with any Supervisory Authority.

Data Location

Our data store and data infrastructure provider is located in the United States of America and European Union (only for for the customers based in European Union). Personal information from users in other jurisdictions will be transferred to, and stored in that location. We have taken steps to satisfy ourselves that our provider will manage and secure our data in a way that is consistent with applicable regulatory requirements and international best practice.

Transfer

We may share or transfer your information (including your personal information) in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business. You will be notified via email and/or a prominent notice on the Hala website of any change in ownership or related uses or disclosures of your personal information, as well as any choices you may have regarding your personal information in those circumstances.

Privacy Policy Changes

We may update this Privacy Policy from time to time. When we make changes, the date of the most recent update will be reflected in the ‘Last Updated’ date at the top of the policy. For substantial changes, we typically provide you with additional notification (e.g. via email, or in-app notification).

Hala encourages visitors to periodically check this page for changes to this Privacy Policy.

Contact Us

If you have any questions about this Privacy Policy, to seek correction of personal information we hold, please contact us at support@hala.ai.

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