Privacy Policy

1. Who we are?

Halny Tech Ltd ("we","us","our") is an online consultancy service best suited to businesses operating in travel industry.

Our Privacy Policy explains how we, as a data controller, collect, store and process personal data when you browse our site halny.tech (the "Halny Tech website"), use Copilot service/application ("Copilot") or otherwise provide personal data to us. Please read this Privacy Policy carefully to understand how we will treat your data, including personal data.

This Privacy Policy should be read with our Terms of Service, which, together, apply to your use of both the Halny Tech website and Copilot service.

2. What information do we collect and receive?

Your personal data

When we say "personal data", we mean any information that relates to and identifies a living person. Personal data will be contained in the information that you provide to us or that is provided during your interactions with us or our service, or in the information that you authorise a third party to give to us on your behalf.

When it comes to your personal data, we comply in full with our obligations under the General Data Protection Regulation (GDPR) and other applicable data protection legislation. With reference to the California Consumer Privacy Act (CCPA), Halny Tech does not sell, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate personal information to another business or a third party for monetary or other valuable consideration.

Information you provide – Your personal data includes the information you provide to us or that you authorise someone else to provide when you:

• sign up for a Halny Tech account;
• elect to have a Halny Tech account provided to you;
• sign up to receive our emails or communications;
• participate in or answer questionnaires or surveys, provide feedback or enter competitions;
• provide information in your Halny Tech account profile;
• provide information during a support enquiry about you and/or your organisation;
• provide information when you complete any forms which you submit to us, e.g. contact us form; or
• provide information via an upload or data transfer.

Examples of this personal data include name, email address, contact number, as well as any correspondence sent by you when you contact us. It could also include: your bank account details and bank transaction details (if that information identifies a person); details in any invoices or receipts (if they identify a person); and/or information to identify customers in vulnerable situations so that we can offer them support or protection.

Halny Tech has no requirement to collect or process any special categories of personal data, as defined under GDPR and the Data Protection Act 2018, in order to provide the service. In addition, we do not knowingly collect or solicit any personal data from anyone under the age of 16 or knowingly allow such persons to register for Halny Tech. Halny Tech is not directed at children under the age of 16. In the event that we learn that we have collected personal data from a child under age 16 without verification of parental consent, we will delete that information as quickly as possible.

Your Financial data

In addition to your own personal data, we may also hold financial data that you enter into Halny Tech in order to make use of our services. Examples of your financial data include your organisation's bank account details, invoices, receipts and bank transactions.

It is your responsibility to safeguard your login information and control third party account access.

Information we collect - We collect information about your usage of our service and website to improve our service, understand trends and enhance and customise content. Some of this data may be "personal data", where it relates to an identifiable person. Here's the information that we collect and how we use it:

• we monitor patterns of usage, such as login dates and volumes of data, so we can understand how people are using Halny Tech. We also do this in order to keep Halny Tech secure and to develop and improve our products.
• we also monitor patterns of usage so that we can tailor any communications we may send to you or advertising that you may receive. For example, we may tailor a newsletter with information about product features that you haven't tried yet, instead of features that you use frequently. We want the content of our communications to be relevant and useful to you.
• for security reasons and to aid in our monitoring of usage patterns, we log your Internet Protocol (IP) address when you use our website. This is the individual identification number that is assigned to your computer when it’s connected to the internet.
• we monitor traffic information to our website and emails, including page visits, email clicks, purchases and referring sites. We use this information to improve our website, advertising, promotions, and to understand customer behaviour. Please see section 10 below regarding our policy on cookies.

3. What do we use your personal data for?

We collect and use your personal data for a variety of business reasons. However, we need some of the data to enter into and perform our contract with you, maintain the security of our systems and provide you with access to Halny Tech. This data includes your contact details and other information requested during the Halny Tech setup process. If you fail to provide this data, or refuse to do so, we may be unable to provide our service to you.

All the processing we carry out is underpinned by a set of processing conditions. These are the legal bases under which we have the authority to collect, use and store your personal information. The following is a summary of how these could apply to you within the Halny Tech service.

Contractual Necessity

We will process data where it is necessary to enter into a contract with you for the provision of the Halny Tech service or to perform our obligations under that contract. Please note that if you do not agree to provide us with certain requested information it may be difficult for the service to operate as intended or at all. Examples include:

• processing and reviewing applications for the Halny Tech service;
• executing your instructions;
• receiving calls or emails to our support team;
• managing and maintaining our relationships with you and for ongoing customer service;
• communicating with you about the service and products you receive from us or via the Halny Tech service; and
• handling any complaints, queries or requests which relate to the Halny Tech service.

Please note - you will retain complete discretion to terminate your account with Halny Tech where we/you consider that it does not meet your needs or expectations.

Legal Obligation

When you elect to use the Halny Tech service, we are required by law to collect and process certain personal information about you. Please be aware that, should you refuse to provide us with certain mandatory information, it may not be possible for you to access the service. Examples include:

• confirming your identity and protecting against fraud as part of a model for secure access;
• sharing information with police, law enforcement, tax authorities or other government and fraud prevention agencies where we have a legal obligation to do so, including reporting suspicious activity and complying with production and court orders;
• delivering mandatory communications to users of the service, providing service messages, publishing revised disclosures or terms and conditions;
• investigating and resolving complaints where we may need to exercise or defend our legal rights;
• conducting investigations into suspected criminal acts, breaches of conduct and corporate policies;
• processing applications for products and services available from or through Halny Tech, including making decisions about whether to agree to approve any application;
• performing assessments and analysing customer information for the purposes of managing, improving and fixing data quality; and
• providing assurance that we have effective processes to identify, manage, monitor and report on the risks Halny Tech might be exposed to (e.g. security, fraud and client confidentiality).

Legitimate Interests

We will process your personal data within Halny Tech where it is in our legitimate interests do so, and without prejudicing your interests or fundamental rights and freedoms. Examples include:

• delivering service insights and personalised recommendations to you which help to maximise your use of Halny Tech and its products and services;
• providing you with updates about the Halny Tech service and its functionality, including new features and services;
• analysing your personal data so that we can administer, support, improve and develop our business, customer service and features of the Halny Tech service; We may use third parties to assist us in performing these activities from time to time and, in those cases, we may pass on your personal and/or financial data to them. We will only share your data with third parties that we trust, and when there are assurances in place as to how they will protect the data.
• improving your experience of the Halny Tech service by:
• gathering feedback from you on your use of and interactions within our service;
• assessing your use of our service;
• tracking your interactions with our service to tailor the content; and
• recording and monitoring communications with our support.
• taking action if we need to defend our legal rights under our Terms of Service if you misuse the service or act in a way which contravenes laws, regulations or our Terms of Service;
• utilising available support functions for the management of the service. This may include technology support from relevant expert areas and third parties;
• tracking and analysing your use of our service to prepare reports on its performance;
• validating your information to check that the data we hold is accurate, consistent and current;
• performing research and trend analysis to optimise your experience of the service;
• developing and enhancing our data models to improve the accuracy of the service and your insights;
• engaging our users by:
• gathering your feedback on the service;
• reporting at an aggregate level on the user experience and service performance;
• engaging and communicating with our users on social media and via SMS/email; and
• providing you with detailed information on your account activity.
• using your personal information in an anonymised and aggregated form to create content to include in:
• infographics, industry reports and media campaigns;
• blog posts and videos on the Halny Tech service;
• emails that inform users about the success and performance of the service; and
• posts from social media accounts owned and operated by Halny Tech.

4. Who do we share your information with?

We do not share your information with any other person, entity or organization.

Especially, we do not share your information with any advertising or marketing agencies.

5. How long do we store your data for?

We only store your data for as long as is necessary for the purposes of processing that are set out in this policy.

We may retain certain data, like email communication, even after your account is cancelled.

To ensure the integrity of our systems and your data, we utilise various technologies to continually take secure, encrypted backups. All data, including deleted data, remains archived within these backups.

6. what are your rights?

• Access to your personal data: You can ask us to confirm if we are processing your personal data and you may request a copy of your personal data by contacting our team at [email protected].
• Right to change or withdraw your consent: Where you have given us consent to make use of your personal data for any of the purposes outlined in this policy, you may withdraw that consent by contacting us using the details located in section 10 of this policy. If you wish to change your contact preferences or you no longer wish to be contacted for marketing purposes, get in touch.
• Right to rectification: If you need to update out-of-date or inaccurate information we hold about you, please log on to your Halny Tech account and update your information or get in touch.
• Right to erasure: You are free to delete your data at any point by contacting us using the details located in section 10 of this policy.
• Right to data portability: In certain circumstances you may ask us to provide you with the personal data that we hold about you in a structured, commonly used, machine-readable form, or ask for us to send such personal data to another data controller.
• Right to object: In certain circumstances you may object to our processing of your personal data. If this is the case, please get in touch.
• Right to restrict processing: You can ask us to restrict the processing of personal data we hold about you in certain circumstances. If you wish to do so, please get in touch.
• Make a complaint: You may make a complaint about our data processing activities to a supervisory authority. In the UK this is the Information Commissioner's Office (ICO). Further details can be found on their website.
• Getting in touch: To make enquiries and/or to exercise any of your rights as outlined in this privacy policy please contact our team at [email protected].

7. Use of cookies

Cookies are small files saved to your device that track, save and store information about your interactions and usage of our services. The primary purpose for our use of cookies is to allow us to provide a smooth, efficient and personalised experience for our users, both on and off our website, through remembering your preferences, securely storing your password.

If you want to manage or disable cookies for the Halny Tech website or any other site, you can do so by changing your browser settings. Please bear in mind that disabling functional cookies may impair the availability and/or functionality of the Halny Tech service. We suggest consulting the “Help” section of your browser or taking a look at the About Cookies website which offers guidance for all modern browsers.

8. Security and data storage

We take security and privacy seriously. We will endeavour to take all reasonable steps to keep your personal and financial data secure once it has been transferred to our systems. We adopt appropriate, industry-standard data collection, storage and processing practices and security measures to protect against unauthorised access, alteration, disclosure or destruction.

Where we utilise third parties to help provide our services, we will always ensure that, as a minimum, the security policies and confidentiality arrangements of those third parties adhere to the same requirements that we impose and expect.

Where we have given you (or where you have chosen) a password that enables you to access certain parts of the Halny Tech website or service, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

We shall periodically check that the personal data we store for you is accurate. If you would like to update the personal data we hold about you, please log in to your Halny Tech account or contact us at [email protected] with your request.

Please note that the internet is not a secure medium and although we will do our best to protect your data, we cannot guarantee the security of any data transmitted to Halny Tech. Any such transmission is at your own risk.

9. Changes to this Privacy Policy

We may modify or update this Privacy Policy from time to time to reflect the changes in our business and practices, so you should review this page periodically. When we change the policy in a material manner we will let you know and will update the ‘last updated’ header at the top of this page.

This Privacy Policy was most recently amended in July 2024.

10. Getting in touch

If you have any queries relating to this Privacy Policy or Halny Tech's use of your personal or financial data, please contact our Privacy Officer at [email protected].