Effective Date: March 2024
Halberd LLC (“we,” “us” or “our”) takes your privacy seriously. This Privacy policy (“Privacy policy”) explains our
data protection policy and describes the types of information we may process when you install and/or use “AI Chat
Assistant - Chatbot” software application for mobile devices (the “App”, “our App”).
When we refer to personal data (or personal information) we mean any information of any kind relating to a
natural person who can be identified, directly or indirectly, in particular by reference to such data.
It is a natural person who can be identified directly or indirectly, in particular by reference to an
identification number or to one or more factors specific to his or her physical, physiological, mental, economic,
cultural or social status.
Our Privacy policy applies to all users, and others who access the App (“Users”).
For the purposes of the GDPR, we are the data controller, unless otherwise stated.
PLEASE READ THE FOLLOWING PRIVACY POLICY, FOR INFORMATION REGARDING THE WAYS YOUR PERSONAL INFORMATION MAY
BE PROCESSED, CAREFULLY. WHEN YOU USE THE APP YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND
BY THESE TERMS.
IF YOU ARE A CALIFORNIA RESIDENT PLEASE READ THE FOLLOWING IMPORTANT NOTICE
Under the California Consumer Privacy Act of 2018 (CCPA) California residents shall have the right to
request:
PERSONAL INFORMATION
All about the categories of information, its sources and purposes of processing, please see section II.
INFORMATION WE PROCESS and III. THE PURPOSES OF PROCESSING YOUR PERSONAL DATA below.
Please mind that according to CCPA personal information does not include de-identified or aggregated
consumer information.
SHARING
How your information can be shared, please see section IV. SHARING OF YOUR INFORMATION below.
Please note that all third parties that are engaged in processing user data are service providers that use
such information on the basis of agreement and pursuant to business purpose.
OPT-OUT OPTIONS
If you don’t want us to process your personal information any more please contact us at [email protected]. In
most cases there is no way to maintain the App’s further operating without functional data therefore you will be
advised to remove the App from your device.
If you don’t want us to share device identifiers and geolocation data with service providers please check
your device settings to opt out as described below.
REQUESTS
To submit a verifiable consumer request for access, portability or deletion of personal data please contact
us at [email protected]. Please include in the text of your appeal
the wording "Your rights to maintain confidentiality
in the state of California”.
When submitting a verifiable request, you should be ready to:
We will not be able to respond to your request or provide you with personal information if we cannot: (i) verify
your identity or authority to make the request; or (ii) confirm that the personal information relates to you. We may
ask you for additional information or documents to verify your identity. We may also carry out checks, including
with third party identity verification services, to verify your identity before taking any action with your personal
information. This is regarded as a safeguard measure to prevent disclosure of your personal information under a fake
or scum request.
We ensure that personal information provided in a verifiable consumer request will be used only to verify
the requestor’s identity or authority to make the request and not for any other purpose. We will keep it for the
adequate term reasonably needed for the purpose described above and delete after the purpose is fulfilled.
We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require
more time, we will inform you of the reason and extension period in writing. Please note that we are only required
to respond to two requests per customer each year.
EQUAL RIGHTS
Nothing in the way we deal with your request shall be interpreted as discrimination, which means that we
will not set up different pricing or products, or different levels or quality of services for you, if you choose to
exercise your rights. However, in some circumstances, we may not be able to provide services if you choose to delete
your personal information from our records.
SALE OF DATA
We do not sell any of your personal data to third parties.
There are several categories of information that can be processed.
We ask for and process the following information when you use the App. This information is necessary for the adequate performance of the contract between you and us. Without such information it is impossible to provide complete functionality of the App and perform the requested services.
Information That Is Processed Automatically
On the basis of your permission we use third-party automatic data processing technologies
(advertising or analytics tools) to analyze certain information sent by your device via our App (Identity
For Advertisers). Some integrated advertising or analytics tools (check Section IV to see the list of them)
launch automated processing of your personal data, including profiling, which means any form of automated processing
of personal data used to evaluate certain personal aspects relating to you, in particular to analyze or predict
aspects concerning your personal preferences, interests, behavior, location or movements (see the list of data
described below). Processing information through automatic data processing technologies starts automatically once
you allow our App to track your activity. You can withdraw your permission at any time - please check opt-out
options in Section VIII below.
We may process some information about your device and your user behavior on the ground of our legitimate
interest. This information falls within categories of data described above in Subsection “Information That Is
Processed Automatically”, it is generally non-personal, i.e. it does not, on its own, permit direct association with
any specific individual, and we may access it only in aggregated form. We use this information for improving our App
and giving our users the best experience.
Information provided automatically to advertising or analytics tools does not generally come to our control,
therefore we cannot be responsible for processing such information. Please mind that some services are engaged in
personal data profiling and may obtain information related to your personality and/or your device by using
technologies that do not belong to our scope of responsibility. In case when your user ID is linked to your Facebook
account, Facebook may use your device information in association with categorized data that were already recorded in
its databases (eg. your age, gender or other demographic indication). We do not control, supervise or stand surety
for how the third parties process your personal data, that might be collected by their own means (not through our
App). Any information request regarding the disclosure of your personal information should be directed to such third
parties (see Section IV).
Payment Information
Our e-commerce providers (Apple and Google) are responsible for billing, processing and charging for in-app
purchases, handle your personal information and keep it absolutely safe and secure. This information is processed as
part of the performance of the contract between you and us. We cannot access or use your credit or debit card
information.
You may access the applicable “in-app” purchase rules and policies directly from the app stores.
Our mission is to constantly improve our App and provide you with new experiences. As part of this mission, we use
your information for the following purposes:
(a) To make our service available. We use functional information and information that is
processed automatically to provide you with all requested services.
(b) To improve, test and monitor the effectiveness of our App. We use information that is
processed automatically to better understand user behavior and trends, detect potential outages and technical
issues, to operate, protect, improve, and optimize our App.
(c) To provide you with interest-based (behavioral) advertising or other targeted content.
We may use information that is processed automatically for marketing purposes (to show ads that may be of interest
to you based on your preferences). We provide personalized content and information to you, which can include online
ads or other forms of marketing.
(d) To communicate with you. We use the contact information we have to communicate with
you through newsletters, i.e. to send you marketing notifications, receive your feedback about our App experience,
and let you know about our policies and terms. We also use your information to respond to you when you contact us.
(e) To prevent fraud and spam, to enforce the law. We really want our App to be free of
spam and fraudulent content so that you feel safe and free. We may use your information to prevent, detect, and
investigate fraud, security breaches, potentially prohibited or illegal activities, protect our trademarks and
enforce our Terms of Use.
If any new purposes for processing your personal data arise we will let you know we start to process
information on that other purpose by introducing the corresponding changes to this Privacy policy.
We will share your information with third parties only in the ways that are described in this Privacy policy.
Please note that while integrating external services we choose third parties that can assure they apply all
necessary technical and organizational measures to protect user personal data. However, we cannot guarantee the
security of any information transmitted from us to any such third party. We are not responsible for any accidental
loss or unauthorized access to your personal data through a fault of third parties.
We will not rent or sell your personal data to any third parties, but we may share your information from
tools like cookies, log files, and device identifiers and location data, with third-party organizations that provide
automatic data processing technologies for the App. We do not control or influence these third parties’ tracking
technologies or how they may be used.
We may also share certain information such as cookie data with third-party advertising partners. This
information allows third-party ad networks, inter alia, to deliver targeted advertisements that they believe will be
of most interest to you.
We may engage the following third-party service providers in order to provide us with necessary
infrastructure for delivery and improvement of our services:
Entity name | Services performed | Entity location | Link to Privacy Policy |
Firebase (Google LLC) | User authentication, analytics and marketing service provider | U.S.A. |
https://policies.google.com/privacy
https://firebase.google.com/support/privacy?hl=en |
OpenAI, L.L.C. | AI-generated content provider | U.S.A. | https://openai.com/privacy/
To learn more information about applicable license terms with respect to |
User Content, visit
https://openai.com/terms/ |
Entity name Firebase (Google LLC) |
Services performed User authentication, analytics and marketing service provider |
Entity location U.S.A. |
Link to Privacy Policy https://policies.google.com/privacy https://firebase.google.com/support/privacy?hl=en |
Entity name OpenAI, L.L.C. |
Services performed AI-generated content provider |
Entity location U.S.A. |
Link to Privacy Policy https://openai.com/privacy/ To learn more information about applicable license terms with respect to User Content, visit https://openai.com/terms/ |
In case you want to learn more about the services and privacy options (including opt-out) please consult the
correspondent websites and privacy policies.
Our App may contain links to third-party websites/services or you may access the App from a third-party
site. We are not responsible for the privacy practices of these third-party sites or services linked to or from our
App, including the information or content contained within them.
We may disclose your personal information if it is needed for objective reasons, due to the public interest
or in other unforeseen circumstances:
We work in the cross-border area and provide our App to our Users around the world.
We and third-party organizations that provide automatic data processing technologies for the App or our
third-party advertising partners may transfer the automatically processed information across borders and from your
country or jurisdiction to other countries or jurisdictions around the world.
If you are located in the European Union or other regions with laws governing data processing that may
differ from U.S. law, please note that we may transfer information, including personal information, to a country and
jurisdiction that does not have the same data protection laws as in your jurisdiction.
This means that your personal information can be transferred to a third country, a territory or one or more
specified sectors within that third country, or to the international organization where data protection and
confidentiality regulations may not provide the same level of protection of personal data as your country does.
We try to make sure that the recipient of any personal data provides a proper protection of the personal
data received, in accordance with the current legislation on the protection of such information. By using the App,
you agree that we may transfer your personal data to any third country, a territory or one or more specified sectors
within that third country, or to the international organization.
For the purposes of data storage, we recourse to the services of the hosting organizations. We take your
privacy seriously and, therefore, encrypt your personal data - if possible - before sending it to the hosting
organizations for the purposes of its storage. Please note that we cooperate only with those hosting organizations
that have passed our security and reliability check.
We generally retain your personal information for as long as is necessary for performing the functional service of
the App and to comply with our legal obligations. If you no longer want us to use your information that we
physically access and store, you can request that we erase your personal information and close your account.
However, some data may still be stored for a certain time period (but no longer than the storage purpose
requires) if information is necessary to comply with legal obligation (taxation, accounting, audit) or in order to
maintain safety and data backup settings, prevent fraud or other malicious acts.
Applicable data protection laws give you certain rights regarding your personal information. You have the following options in relation to your personal information that was collected:
To exercise any of the rights described above, you can contact us at [email protected].
Please bear in mind that we
ensure the above mentioned rights only with respect to the information that we physically access and store.
When your personal information is processed automatically you may object to such processing in some
circumstances. Where your personal information is processed for direct marketing purposes, you may ask to cease
processing your data for these direct marketing purposes. In order to exercise your right please contact the third
party services listed in the Section IV of this Privacy policy to learn how you can object to processing your data.
Most of them have clear instructions on their privacy pages, functional API or other options.
If you are located in the European Union, you may address our representative when you have questions on
privacy issues: [email protected]
Opt-out of marketing tracking
You can manage your activity tracking permissions. Inter alia, if you do not want third-party service
providers to use the personalized ads on the basis of your interests please follow the instructions below:
Please mind that when you opt out of certain interest based advertising, you may still continue to receive contextual
ads based on other non-personal information, such as ads related to the content of other digital products you are
using.
Opt-out of Location Data Processing
If you do not want third-party service providers to use your precise location data, or street-level location
information about you please follow the instructions below:
The security of your personal information is highly important to us. We follow generally accepted industry standards
to protect the personal information submitted to us, both during transmission and once we receive it. We take
reasonable and appropriate measures to protect personal information from loss, misuse and unauthorized access,
disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of
the personal information.
We implement appropriate technical and organizational measures, which are designed to implement
data-protection principles, such as data minimization, in an effective manner and to integrate the necessary
safeguards into the processing. We seek your personal data to be encrypted with proper and strong encryption
algorithms, including hashing where possible.
Unfortunately, no method of transmission over the Internet, or method of electronic storage, is 100%
secure. We do our best to protect your personal data, nevertheless, we cannot guarantee its absolute security. In
the event that your personal information is compromised as a breach of security, we will promptly notify you in
compliance with applicable law.
If you have any questions about the security of our App, you can contact us at [email protected].
Our App is not intended for children under the age of eighteen (18). Therefore, we do not knowingly collect or solicit any personal information from children under eighteen (18). If you have not reached the age of majority or legal age in your jurisdiction (i.e. if you are between the ages of thirteen (13) and seventeen (17) years), your use of the App is possible only with the relevant consent and under the supervision of the holder of parental responsibility for you. No one under the age of thirteen (13) may provide any personal information to the App. If we learn that we have collected personal information from a child under the age of eighteen (18) without verification of the holder of parental responsibility for a child, we will erase that information as quickly as possible. If you believe that we might have any information from or about a child under eighteen (18) and data processing is carried out without the relevant consent of the holder of parental responsibility for a child, please contact us.
This Privacy policy is updated regularly. Whenever we change this Privacy policy, we will post those changes to this Privacy policy and other places that we consider appropriate. Additional forms of notice of modifications or updates as appropriate under the circumstances may be provided to you.
If you have any questions about this Privacy policy, please feel free to contact us at [email protected].