Privacy Policy

We at Haltia, Inc., (together with our affiliates, “Haltia”, “we”, “our” or “us”) respect your privacy and are strongly committed to keeping secure any information we obtain from you or about you. Privacy and protection of your data are the core principles of our company and it influences everything we do. This Privacy Policy describes our practices with respect to Personal Information we collect from or about you when you use our website, applications, and services (collectively, “Services”).

Our aim is to create a personal AI assistant that runs completely on your device without the need to transfer any of your information to any external services operated by us or someone else. Everything we do is done with your privacy as a first priority.

1. Data Controller

Haltia, Inc., with its registered office at 651 N Broad St, Suite 201, Middletown, Delaware 19709, United States, is the controller and is responsible for the processing of your Personal Data as described in this Privacy Policy.

2. Personal Data We Collect

Personal Information You Provide: We collect personal data and information relating to you (“Personal Information”) only if you create an account to use our Services or communicate with us as follows:

• Account Information: When you create an account with us, we will collect information associated with your account, including your email address and phone number.
• Communication Information: If you communicate with us (e.g. by email), we collect your name, contact information, and the contents of any messages you send.
• Social Media Information: We have pages on social media sites like Instagram, Facebook, Medium, Twitter, YouTube and LinkedIn. When you interact with our social media pages, we will collect Personal Information that you elect to provide to us, such as your contact details. In addition, the companies that host our social media pages may provide us with aggregate information and analytics about our social media activity.
• Personal Information We Receive Automatically From Your Use of the Services: When you visit, use, or interact with the Services, we receive the following information about your visit, use, or interactions:
• Log Data: Information that your browser or device automatically sends when you use our Services. Log data includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interact with our Services.
• Device Information: Includes name of the device, operating system, device identifiers, and browser you are using. Information collected may depend on the type of device you use and its settings.
• Analytics: We may use a variety of online analytics products that use cookies to help us analyze how users use our Services and enhance your experience when you use the Services.

We will not collect any information related to your input to our Services or the output provided by our Services.

3. Third-Party Applications

We allow you to create connections or integrations between the Services and certain third-party applications you use. To connect third-party applications, it may be necessary to have an account with each such third-party application you integrate, and the Services may require you to authenticate with each application. Our Services do not store such login credentials and such credentials are never provided to or processed by us. When you integrate third-party applications, we will forward you to sign-in directly with the third-party application provider. We are not responsible for how any third-party application collects, processes, uses, retains, or discloses your information. The way a third-party application processes information is governed by the policies of the third-party application.

Third-party applications integrated with the Services may allow you to collect, process, transmit or disclose information, content, or posts that may include other parties’ personal information. You are responsible for ensuring that you have the right to collect, process, transmit or disclose other parties’ information and that you have obtained all legally required consents to collect, process, transmit, or disclose the information you process using the Services.

The Services’ use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

4. How We Use Personal Information

We may use Personal Information for the following purposes:

• to provide, administer, maintain and/or analyze the Services;
• to communicate with you; including to send you information about our Services and events;
• to develop new programs and services;
• to prevent fraud, criminal activity, or misuses of our Services, and to protect the security of our IT systems, architecture, and networks;
• to carry out business transfers;
• and to comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.

5. Aggregated Or De-Identified Information

We may aggregate or de-identify Personal Information so that it may no longer be used to identify you and use such information to analyze the effectiveness of our Services, to improve and add features to our Services, to conduct research and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Services and share aggregated information like general user statistics with third parties, publish such aggregated information or make such aggregated information generally available. We may collect aggregated information through the Services, through cookies, and through other means described in this Privacy Policy. We will maintain and use de-identified information in anonymous or de-identified form, and we will not attempt to reidentify the information, unless required by law.

6. Disclosure Of Personal Information

In certain circumstances we may provide your Personal Information to third parties without further notice to you, unless required by the law:

• Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may provide Personal Information to vendors and service providers, including providers of hosting services, customer service vendors, cloud services, email communication software, web analytics services, and other information technology providers, among others. Pursuant to our instructions, these parties will access, process, or store Personal Information only in the course of performing their duties to us.
• Business Transfers: If we are involved in strategic transactions, reorganization, bankruptcy, receivership, or transition of service to another provider (collectively, a “Transaction”), your Personal Information and other information may be disclosed in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets.
• Legal Requirements: We may share your Personal Information, including information about your interaction with our Services, with government authorities, industry peers, or other third parties (i) if required to do so by law or in the good faith belief that such action is necessary to comply with a legal obligation, (ii) to protect and defend our rights or property, (iii) if we determine, in our sole discretion, that there is a violation of our terms, policies, or the law; (iv) to detect or prevent fraud or other illegal activity; (v) to protect the safety, security, and integrity of our products, employees, or users, or the public, or (vi) to protect against legal liability.
• Affiliates: We may disclose Personal Information to our affiliates, meaning an entity that controls, is controlled by, or is under common control with Haltia, Inc. Our affiliates may use the Personal Information we share in a manner consistent with this Privacy Policy.
• Other Users and Third Parties You Share Information With: Certain features allow you to display or share information with other users or use third-party applications that interface and communicate with the Services. For example, you may share your conversations with other users via our sharing feature or send information (including Personal Information) to third-party applications that interface and communicate with the Services. Be sure you trust any user or third party application with whom you share information.

We do not “sell” Personal Information or “share” Personal Information for cross-contextual behavioral advertising (as those terms are defined under applicable local law). We also do not process sensitive Personal Information for the purposes of inferring characteristics about an individual.

7. Retention Of Data

We will retain your Personal Information for only as long as we need in order to provide our Services to you, or for other legitimate business purposes such as resolving disputes, safety and security reasons, or complying with our legal obligations. How long we retain Personal Information will depend on a number of factors, such as:

• Our purpose for processing the data (such as whether we need to retain the data to provide our Services);
• The amount, nature, and sensitivity of the data;
• The potential risk of harm from unauthorized use or disclosure of the data;
• And any legal requirements that we are subject to.

8. Your Rights

Depending on location, users may have certain statutory rights in relation to their Personal Information. For example, you may have the right to:

• Access your Personal Information and information relating to how it is processed;
• Delete your Personal Information from our records;
• Rectify or update your Personal Information;
• Transfer your Personal Information to a third party (right to data portability);
• Withdraw your consent—where we rely on consent as the legal basis for processing at any time;
• Object to how we process your Personal Information;
• Or lodge a complaint with your local data protection authority;

You can exercise these rights by submitting your request to [email protected]. In order to protect your Personal Information from unauthorized access, change, or deletion, we may require you to verify your credentials before you can submit a request to know, correct, or delete Personal Information. If you do not have an account with us, or if we suspect fraudulent or malicious activity, we may ask you to provide additional Personal Information and proof of residency for verification. If we cannot verify your identity, we will not be able to honor your request.

9. Children

Our Service is not directed to children under the age of 13. Haltia does not knowingly collect Personal Information from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided Personal Information to Haltia through the Service, please email us a [email protected]. We will investigate any notification and if appropriate, delete the Personal Information from our systems. If you are 13 or older, but under 18, you must have permission from your parent or guardian to use our Services.

10. Security And Retention

We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Service or email. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third-party websites.

We will retain your Personal Information for only as long as we need in order to provide our Service to you, or for other legitimate business purposes such as resolving disputes, safety and security reasons, or complying with our legal obligations. How long we retain Personal Information will depend on a number of factors, such as the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, our purpose for processing the information, and any legal requirements.

11. International Users

By using our Services, you understand and acknowledge that your Personal Information will be processed and stored in our facilities and servers in the United States or elsewhere and may be disclosed to our service providers and affiliates in other jurisdictions.

Our legal bases for processing your Personal Information include:

• Performance of a contract with you when we provide and maintain our Services. When we process Personal Information solely to provide our Services to you, this information is necessary to be able to provide our Services. If you do not provide this information, we may not be able to provide our Services to you.
• Our legitimate interests in protecting our Services from abuse, fraud, or security risks, or in developing, improving, or promoting our Services, including when we train our models.
• Your consent when we ask for your consent to process your Personal Information for a specific purpose that we communicate to you. You have the right to withdraw your consent at any time.
• Compliance with our legal obligations when we use your Personal Information to comply with applicable law or when we protect our or our affiliates’, users’, or third parties’ rights, safety, and property.

11.2 Data Transfers

Where required, we will use appropriate safeguards for transferring Personal Information outside of certain countries. We will only transfer Personal Information pursuant to a legally valid transfer mechanism.

12. Changes To The Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will post an updated version on this page, unless another type of notice is required by applicable law.

13. How To Contact Us

Please contact us via email to [email protected] if you have any questions or concerns not already addressed in this Privacy Policy.