Privacy Policy

HALCYON PRIVACY POLICY


Effective as of January 16, 2025.  

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State Law Privacy Rights: See the State law privacy rights section below for important information about your rights under applicable state privacy laws.‍

This Privacy Policy describes how Halcyon Tech, Inc. and its subsidiaries ("Halcyon," "we", “us” or "our") processes personal information that we collect through our digital or online properties or services (i.e. Halcyon platform) that link to this Privacy Policy (including as applicable, our website and social media pages) as well as our marketing activities, live events and other activities described in this Privacy Policy (collectively, the “Service”)). 

This Privacy Policy references the product as the platform. “Platform” means the Halcyon Platform, including all related software, hardware, products, processes, algorithms, user interfaces, know-how, techniques, designs and other tangible or intangible technical material or information and the content therein (other than Data), as made available to Customer under this Agreement and as may be updated and modified by Halcyon from time to time, which may include Third Party Content, and the Documentation.

This Privacy Policy applies to information that we collect through the Halcyon website, the Halcyon platform, events, and any information received from third-parties that is stored in Halcyon operated systems. Our use of information that we process on behalf of our business customers may be superseded as applicable by our agreements with such customers. If you have concerns regarding your personal information that we process on behalf of a business customer, please direct your concerns to that enterprise customer. 

Our websites, products and services are designed for enterprise customers and their representatives. We do not offer products or services for use by individuals for their personal, family or household purposes. Accordingly, we treat all personal information we collect as pertaining to individuals in their capacities as representatives of the relevant enterprise and not their individual capacities.

‍NOTICE TO EUROPEAN USERS: Please see the Notice to European Users section for additional information for individuals located in the European Economic Area or United Kingdom (which we refer to as “Europe”, and “European” should be understood accordingly) below.‍


You can download a printable copy of this Privacy Policy https://www.halcyon.ai/policies/privacy-policy.
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‍Index

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Personal information we collect


‍‍Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:

  • Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, professional title and company name, and phone number.
  • Demographic data, such as your city, state, country of residence, postal code, and age.
  • Communications data based on our exchanges with you, including when you contact us through the Service, social media, or otherwise. 
  • Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
  • Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may combine personal information we receive from you with personal information falling within one of the categories identified above that we obtain from other sources, such as:

  • Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
  • Data providers, such as information services and data licensors 
  • Partners, such marketing partners and event co-sponsors. 
  • Customers.
  • Service providers that provide services on our behalf or help us operate the Service or our business.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

  • Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
  • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
  • Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails. 

For more information concerning our automatic collection of data, please see the Cookies and similar technologies section below.
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‍Cookies and similar technologies. Some of our automatic data collection is facilitated by cookies and similar technologies. For more information, see our halcyon.ai. We will also store a record of your preferences in respect of the use of these technologies in connection with the Service.

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How we use your personal information‍


‍We may use your personal information for the following purposes or as otherwise described at the time of collection:
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Service delivery and operations. We may use your personal information to:

  • provide the Service;
  • enable security features of the Service;
  • communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
  • provide support for the Service, and respond to your requests, questions and feedback.

Service personalization, which may include using your personal information to:

  • understand your needs and interests;
  • personalize your experience with the Service and our Service-related communications; and
  • remember your selections and preferences as you navigate webpages.

Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services. For more information on analytics, see our Cookie Notice. For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here. We also use Microsoft Clarity to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market the Service. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.
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Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:

  • Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.  
  • Interest-based advertising. Our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) with the Service, our communications and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the Your choices section of our Cookie Notice. 

Compliance and protection. We may use your personal information to:

  • comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
  • protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); 
  • audit our internal processes for compliance with legal and contractual requirements or our internal policies; 
  • enforce the terms and conditions that govern the Service; and 
  • prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.  

Research and development. We may use your personal information for research and development purposes. As part of these activities, we may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.  

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
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‍Cookies and similar technologies. In addition to the other uses included in this section, we may use the Cookies and similar technologies. For more information, see our Cookie Notice.
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Retention

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We retain personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, including to satisfy contractual obligations, support customer requirements, and maintain linked business operations. For users of the Halcyon platform, account data is retained for the duration of the contractual agreement. Upon license expiration, associated tenant data will be deleted within 30 days, unless retention is required for legitimate business or legal purposes.

In accordance with the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA), you have the right to request deletion of your personal data. Upon receiving a valid request to be forgotten, we will delete your data unless we are required to retain it to comply with legal obligations, resolve disputes, enforce our agreements, or fulfill other lawful business purposes.

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How we share your personal information‍‍


We may share your personal information from the website with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.  

Affiliates. Our corporate parent, subsidiaries, and affiliates.

‍Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research and website analytics). 

‍Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above. 

‍Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so. 

Partners. Third parties with whom we partner, including parties with whom we jointly offer products or services, or whose products or services may be of interest to you.
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‍Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

‍Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.

‍Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Halcyon, financing of Halcyon, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Halcyon as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

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Your choices 


In this section, we describe the rights and choices available to all users. Users who are located in certain U.S. states and Europe can find additional information about their rights below.

‍Opt-out of marketing. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.  

‍Cookies. For information about cookies employed by the Service and how to control them, see our Cookie Notice. 

You will need to apply these opt-out settings on each device and browser from which you wish to limit the use of your information for interest-based advertising purposes.  

We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above. 

‍Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

‍Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

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Other sites and services


The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

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Security 


We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information. 

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International data transfer


We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country. 

Users in Europe should read the important information provided below about transfer of personal information outside of Europe. 

This does not apply to customer data provided through the Halcyon Platform, all platform data resides in the region of origin.  

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Children  


The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

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Changes to this Privacy Policy 


We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.

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How to contact us

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State privacy rights notice


This section applies to individual residents of states only to the extent they have privacy laws applicable to us that grant their residents the rights described below (collectively the “State Privacy Laws”). Please note that many privacy laws do not apply to data that we process on behalf of our business customers.

‍This section describes how we collect, use, and share Personal Information of residents of these states and these users may have with respect to their Personal Information. Please note that not all rights listed below may be afforded to all users and that if you are not a resident of one of these states listed above, you may not be able to exercise these rights. In addition, we may not be able to process your request if you do not provide us with sufficient detail to allow us to confirm your identity or understand and respond to it.

‍For purposes of this section, the term “Personal Information” has the meaning given to “personal data”, “personal information” or other similar terms and “Sensitive Personal Information” has the meaning given to “sensitive personal information,” “sensitive data”, or other similar terms in the State Privacy Laws, except that in neither case does such term include information exempted from the scope of the State Privacy Laws. In some cases, we may provide a different privacy notice to certain categories of residents of these states, such as job applicants, in which case that notice will apply instead of this section.

‍Your privacy rights. The State Privacy Laws may provide residents with some or all of the rights listed below. However, these rights are not absolute and some State Privacy Laws do not provide these rights to their residents.  Therefore, we may decline your request in certain cases as permitted by law. We have no actual knowledge that we have sold or shared the personal information of individuals under 13 years of age in the past twelve months. We also do not use or disclose Sensitive Personal Information for purposes that relevant state residents have a right to limit under the State Privacy Laws, nor do we engage in automated decision making or profiling, as defined under the State Privacy Laws.

  • Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
    • The categories of Personal Information that we have collected.
    • The categories of sources from which we collected Personal Information.
    • The business or commercial purpose for collecting and/or selling Personal Information.
    • The categories of third parties with which we share Personal Information.
    • The categories of Personal Information that we sold or disclosed for a business purpose.
    • The categories of third parties to whom the Personal Information was sold or disclosed for a business purpose.
  • Access. You can request a copy of the Personal Information that we have collected about you. To ensure the security and privacy of your data, we are required to verify your identity before fulfilling such requests, particularly in the context of online services and online identifiers.

When submitting your request, please provide sufficient information to help us verify your identity. This may include your name and contact details, as they appear in our records, as well as information about your interactions with us, such as recent transactions or account activity, to assist in confirming your relationship with our organization.

As part of the identity verification process, we may request additional information or use reasonable measures, such as confirming account or transaction details, to securely validate your identity. We will only use the information provided for the purpose of processing your request, and we will not retain any data collected for verification longer than necessary. Once your identity has been verified and your request fulfilled, we will use reasonable efforts to delete any data used for verification will be securely deleted.

Please note that if we are unable to verify your identity using reasonable measures, we may decline your request to ensure the security of your Personal Information. Requests will only be processed for Personal Information directly associated with you as the data subject. 

  • Appeal. You can appeal our denial of any request validly submitted. 
  • Correction. You can ask us to correct inaccurate Personal Information that we have collected about you.
  • Deletion. You can ask us to delete the Personal Information that we have collected from you.
  • Opt-out of certain processing for targeted advertising purposes. You can opt-out of certain processing of personal information for targeted advertising purposes. We do not sell or share your Personal Information for monetary consideration.
  • Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the State Privacy Laws.  

Right to information, access, appeal, correct and deletion. You can request to exercise your information, access, appeal, correct and deletion rights by:

‍Exercising your right to opt-out of the “sharing” of your Personal Information.   While we do not sell personal information for money, like many companies, we use services that help deliver interest-based ads to you as described above. The State Privacy Laws may classify our use of some of these services as the “sharing” your Personal Information with the advertising partners that provide the services.  You can by submit requests to opt-out of tracking for targeted advertising purposes or other similar sharing of Personal Information here: via email to privacy@halcyon.ai.  

‍Verification of Identity; Authorized agents. We may need to verify your identity in order to process your information/know, access, appeal, correction, or deletion requests and reserve the right to confirm your residency. To verify your identity, we may require government identification, a declaration under penalty of perjury, or other information, where permitted by law.  

Under some State Privacy Laws, you many enable an authorized agent to make a request on your behalf upon.  However, we may need to verify your authorized agent’s identity and authority to act on your behalf.  We may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that your request is authorized, such as by providing your agent with written and signed permission to exercise your State Privacy Laws rights on your behalf, the information we request to verify your identity, and confirmation that you have given the authorized agent permission to submit the request. 

‍Personal information that we collect, use and disclose. We have summarized the Personal Information we collect and may disclose to third parties by reference below to both the categories defined in the “Personal information we collect” section of this Policy above and the categories of Personal Information specified in the CCPA (Cal. Civ. Code §1798.140) and describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below. 

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Personal Information (“PI”) we collect CCPA statutory category Categories of third parties to whom we “disclose” PI for a business purpose Categories of third parties to whom we “share” PI
  • Contact data
  • Identifiers (online)
  • Identifiers (other)
  • Commercial information
  • California customer records
  • Affiliates
  • Service providers
  • Advertising partners
  • Third parties designated by you
  • Professional advisors
  • Authorities and others
  • Business transferees
  • Business and marketing partners
  • Advertising partners (to facilitate online advertising)
  • Business and marketing partners
  • Demographic data
  • Identifiers (online)
  • Identifiers (other)
  • California customer records
  • AffiliatesService providers
  • Advertising partners
  • Third parties designated by you
  • Professional advisors
  • Authorities and others
  • Business transferees
  • Business and marketing partners
  • Advertising partners (to facilitate online advertising)
  • Business and marketing partners
  • Communications data
  • Identifiers (online)
  • Identifiers (other)
  • Commercial information
  • California consumer records
  • Internet or Network Information
  • Affiliates
  • Service providers
  • Advertising partners
  • Third parties designated by you
  • Professional advisors
  • Authorities and others
  • Business transferees
  • Business and marketing partners
  • Advertising partners (to facilitate online advertising)
  • Business and marketing partners
  • Marketing data
  • Identifiers (online)
  • Identifiers (other)
  • Commercial information
  • California customer records
  • Internet or Network Information
  • Affiliates
  • Professional advisors
  • Authorities and others
  • Business transferees
  • Advertising partners (to facilitate online advertising)
  • Business and marketing partners
  • Device data
  • Identifiers (other)
  • Internet or Network Information
  • Affiliates
  • Service providers
  • Advertising partners
  • Third parties designated by you
  • Professional advisors
  • Authorities and others
  • Business transferees
  • Business and marketing partners
  • Advertising partners (to facilitate online advertising)
  • Business and marketing partners
  • Online activity data
  • Identifiers (other)
  • Commercial information
  • Internet or Network Information
  • Affiliates
  • Service providers
  • Advertising partners
  • Third parties designated by you
  • Professional advisors
  • Authorities and others
  • Business transferees
  • Business and marketing partners
  • Advertising partners (to facilitate online advertising)
  • Business and marketing partners
  • Communication interaction data
  • Identifiers (online)
  • Identifiers (other)
  • Commercial information
  • California consumer records
  • Internet or Network Information
  • Affiliates
  • Service providers
  • Advertising partners
  • Third parties designated by you
  • Professional advisors
  • Authorities and others
  • Business transferees
  • Business and marketing partners
  • Advertising partners (to facilitate online advertising)
  • Business and marketing partners
  • Data derived from the above
  • Inferences
  • Affiliates
  • Service providers
  • Advertising partners
  • Authorities and others
  • Business transferees
  • Business and marketing partners
  • Advertising partners (to facilitate online advertising)
  • Business and marketing partners

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Shine the light law.  Under California’s Shine the Light law (California Civil Code Section 1798.83), California residents may ask companies with whom they have formed a business relationship primarily for personal, family or household purposes to provide the names of third parties to which they have disclosed certain personal information (as defined under the Shine the Light law) during the preceding calendar year for their own direct marketing purposes, and the categories of personal information disclosed. You may send us requests for this information to privacy@halcyon.ai. In your request, you must include the statement “Shine the Light Request," and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

‍Additional information for Nevada residents. Nevada residents have the right to opt-out of the sale of certain personal information for monetary consideration. While we do not currently engage in such sales, if you are a Nevada resident and would like to make a request to opt out of any potential future sales, please email privacy@halcyon.ai. 

‍Contact Us. If you have questions or concerns about our privacy policies or information practices, please contact us using the contact details set forth in the How to contact us section, above.

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Notice to European users


General


Where this Notice to European users applies. The information provided in this “Notice to European users” section applies where we are processing the personal information of individuals located in the United Kingdom or the European Economic Area (i.e., “Europe” as defined at the top of this Privacy Policy).

‍Personal information. References to “personal information” in this Privacy Policy should be understood to include reference to “personal data” as defined in the “GDPR” (i.e., the General Data Protection Regulation 2016/679 (“EU GDPR”) and the EU GDPR as it forms part of UK law (“UK GDPR”). This means information about individuals from which they are either directly identified or can be identified.   

‍Controller. Halcyon is the controller in respect of the processing of your personal information covered by this Privacy Policy for purposes of the GDPR. See the ‘How to contact us’ section above for our contact details.

‍Our GDPR Representatives. We have appointed the following representatives in Europe as required by the GDPR – you can also contact them directly should you wish:
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Our Representative in the EU. Our Representative in the UK.
Our EU representative appointed under the EU GDPR is Director, Product Security.
You can contact them: 		Our UK representative appointed under the UK GDPR is VP of UK.
You can contact them:



Our legal bases for processing 


In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a “legal basis” for that use. 

Our legal bases for processing your personal information described in this Privacy Policy are listed below.

  • Where we need to process your personal information to deliver our Service (“Contractual Necessity”).
  • Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your personal information for is set out in the table below.
  • Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
  • Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).  

We have set out below, in a table format, the legal bases we rely on in respect of the relevant purposes for which we use your personal information – for more information on these purposes and the data types involved, see ‘How we use your personal information’.

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Purpose Categories of personal information involved Legal basis
Service delivery and operations

Contact data

Demographic data

Communications data

Data from Third Party ServicesDevice data

Delivery and operations

Contractual Necessity

Legitimate Interests. We have a legitimate interest in ensuring the ongoing security and proper operation of our Service, our business and associated IT services, systems and networks.

Personalization

Legitimate Interests. We have a legitimate interest in providing you with a good service via the Service, which is personalized to you and that remembers your selections and preferences.

Consent, in respect of any optional processing relevant to personalization (including processing directly associated with any optional cookies used for this purpose).
Service improvement and analytics

Contact data

Demographic data

Device data

Online activity data

Communication interaction data

Legitimate Interests. We have a legitimate interest in providing you with a good service, which is personalised to you and that remembers your selections and preferences.

Consent, in respect of any optional cookies used for this purpose.
Direct marketing

Contact data

Demographic data

Communications data

Marketing data

Communication interaction data

Legitimate Interests. We have a legitimate interest in promoting our operations and goals as an organisation and sending marketing communications for that purpose.

Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given marketing communications.
Interest-based advertising

Demographic data

Device data

Online activity data

Consent, in respect of any optional processing relevant to personalization (including processing directly associated with any optional cookies used for this purpose).
Compliance and protection

Contact data

Demographic data

Compliance with Law.

Legitimate Interests. Where Compliance with Law is not applicable, we and any relevant third parties have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. We and any relevant third parties may also have a legitimate interest of ensuring the protection, maintenance, and enforcement of our and their rights, property, and/or safety.
Research and development

Any and all data types relevant in the circumstances

Legitimate Interests. We have legitimate interest, and believe it is also in your interests, that we are able to take steps to ensure that our Services and how we use Personal Information is as un-privacy intrusive as possible.
Further uses

Any and all data types relevant in the circumstances

The original legal basis relied upon, if the relevant further use is compatible with the initial purpose for which the Personal Information was collected.

Consent, if the relevant further use is not compatible with the initial purpose for which the personal information was collected.

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Additional information

No obligation to provide personal information. You do not have to provide personal information to us. However, where we need to process your personal information either to comply with applicable law or to deliver our Services to you, and you fail to provide that personal information when requested, we may not be able to provide some or all aspects of our Service to you. We will notify you if this is the case at the time.

‍No sensitive personal information. We ask that you not provide us with any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the services, or otherwise to us. If you provide us with any sensitive personal information when you use the services, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our services.

‍No Automated Decision-Making and Profiling. As part of the Service, we do not engage in automated decision-making and/or profiling, which produces legal or similarly significant effects. 
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Your rights

General. European data protection laws give you certain rights regarding your personal information. If you are located in Europe, you may ask us to take any of the following actions in relation to your personal information that we hold:

  • Access. Provide you with information about our processing of your personal information and give you access to your personal information. 
    When submitting your request, please provide sufficient information to help us verify your identity. This may include your name and contact details, as they appear in our records, as well as information about your interactions with us, such as recent transactions or account activity, to assist in confirming your relationship with our organization.
    As part of the identity verification process, we may request additional information or use reasonable measures, such as confirming account or transaction details, to securely validate your identity. We will only use the information provided for the purpose of processing your request, and we will not retain any data collected for verification longer than necessary. Once your identity has been verified and your request fulfilled, we will use reasonable efforts to delete any data used for verification will be securely deleted.
    Please note that if we are unable to verify your identity using reasonable measures, we may decline your request to ensure the security of your Personal Information. Requests will only be processed for Personal Information directly associated with you as the data subject.
  • ‍Correct. Update or correct inaccuracies in your personal information.‍
  • Delete. Delete your personal information where there is no lawful reason for us continuing to store or process it - you also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons that will be notified to you, if applicable, at the time of your request. ‍
  • Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice, in certain circumstances. Note that this right only applies to automated information for which you initially provided consent for us to use or where we used the information to perform a contract with you.‍
  • Restrict. Restrict the processing of your personal information, if: (i) you want us to establish the personal information's accuracy; (ii) our use of the personal information is unlawful but you do not want us to erase it; (iii) you need us to hold the personal information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your personal information but we need to verify whether we have overriding legitimate grounds to use.‍
  • Object. Object to our processing of your personal information where we are relying on legitimate interests as our legal basis, and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedom  – you also have the right to object where we are processing your personal information for direct marketing purposes.‍
  • Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time. This will not affect the lawfulness of any processing carried out before you withdraw your consent.  

Exercising These Rights. You may submit these requests by email to privacy@halcyon.ai or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions. Typically, you will not have to pay a fee to exercise your rights; however, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We try to respond to all legitimate requests within a month. It may take us longer than a month if your request is particularly complex or if you have made a number of requests; in this case, we will notify you and keep you updated.
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Your Right to Lodge a Complaint with your Supervisory Authority. In addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence. 

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Data Processing outside Europe 

‍We are a U.S.-based company and many of our service providers, advisers, partners or other recipients of data are also based in the U.S. This means that, if you use the Service, your personal information will necessarily be accessed and processed in the U.S. It may also be provided to recipients in other countries outside Europe.  

Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it by making sure one of the following mechanisms is implemented: 

  • Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time) or under specific adequacy frameworks approved by the European Commission or UK Government (as and where applicable) (from time to time), such as the EU-U.S. Data Privacy Framework or the UK Extension thereto.
  • Transfers to territories without an adequacy decision. 
    • We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection.  
    • However, in these cases:
      • we may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe – for example, standard-form contracts approved by relevant authorities for this purpose; or 
      • in limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your personal information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe. 

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