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Hal-AI Privacy Policy

Site & App Hal-AI Whats
This Privacy Notice (“Notice”) was developed in accordance with Federal Law No. 13,709/2018, also known as the “General Data Protection Law” or “LGPD,” and aims to provide information about how we process personal data on the website https://hal-ai.com (“Site”) and App.

If you have any questions and/or requests regarding the information in this Notice, please contact our customer service team through our website or by email at contato@2cw.com.br.

1. Who are we?

We are Hal-AI 2CW Cloud Technologies. (“Hal-AI Whats” or “We”), the legal entity that owns the “Hal-AI Whats” software—a technology that allows customers who purchase the product (“Clients”) to interact with their own customers (“End Users”) in a digital and automated way.

2. Who does this policy apply to?

This policy applies to the processing of data on the Hal-AI Whats Site and App and is intended for:

  • Visitors to the Site and users of the App;

  • Clients or Client representatives.

3. What about End Users?

We only process End Users’ personal data within the context of communications carried out between them and our Clients through Hal-AI Whats. In this case, we process the personal data of End Users that is collected and entered by our Clients into Hal-AI Whats in order to provide the product’s features, following the instructions given by the Clients.

In such cases, we act as a data processor, and the Client, as the data controller, is responsible for how the End User's information is used. Therefore, we recommend that End Users refer to the Client’s Privacy Notice to understand how their data is handled. It is important to note that Hal-AI is not responsible for the data privacy and protection practices of our Clients.

4. What personal data do we process?

To enable access and use of our Site and App, we may process the following personal data:

  • Identification and contact data: full name, email, and phone number

  • Payment data: card number, expiration date, and billing information

  • Browsing data: browser used, IP address, access date and time, user location, user actions on the site, connection provider, mobile device model, and operating system

5. How is personal data collected?

Personal data may be provided directly by the data subject—for example, when signing up for Hal-AI Whats or contacting us via our support channels—or collected automatically through use of the Site.

6. What are the purposes for processing personal data?

PurposePersonal Data UsedTarget AudienceLegal Basis

Enable access to the Site’s features, including through cookies and similar technologies; send various communications.Identification and contact data; Browsing dataSite visitorsLegitimate interest or consent (when applicable)

Respond to requests, support tickets, and questions submitted through contact channels; conduct research and statistical analysis for business intelligence purposes.Identification and contact data; Browsing dataSite visitors; Clients or Client representativesLegitimate interest

Enable Hal-AI Whats subscription; process payments; create access accounts; provide related services such as technical support, maintenance, and customer service.Identification and contact data; Payment dataClients or Client representativesLegitimate interest (Client representatives) or Contract execution/pre-contractual steps (Clients)

Prevent fraud and other unlawful acts; continuously improve the Site, fixing bugs and adapting to user devices.Browsing dataSite visitors; Clients or Client representativesLegitimate interest

Comply with legal obligations to retain access logs.Browsing dataSite visitors; Clients or Client representativesLegal or regulatory obligation

7. How long do we store personal data?

Personal data collected through the Site is retained for the period necessary to fulfill the purposes described in this Notice. In some cases, data may be retained longer to meet legal or regulatory requirements or to preserve the exercise of rights.

8. How do we protect personal data?

Personal data is kept secure and confidential. We adopt reasonable technical and organizational security measures to protect personal data against unauthorized access and accidental or unlawful events such as destruction, loss, alteration, disclosure, or dissemination.

These measures include technologies like logical access control, identity management, encryption, backups, antivirus/anti-spam tools, and administrative processes such as policies, procedures, and training of internal staff.

9. With whom do we share personal data?

To fulfill the purposes described in this Notice, personal data may be shared with:

  • Companies in the Hal-AI Whats economic group

  • Vendors, service providers, and business partners who help operate the Site and our business activities (e.g., technology providers, CRM platforms)

  • Competent authorities, to comply with legal or regulatory obligations or official requests

International transfer: Personal data may be transferred to entities located outside Brazil, such as cloud storage servers in other countries. These transfers will comply with applicable laws.

10. What are your rights and how to exercise them?

The LGPD grants data subjects certain rights regarding their personal data, which can be exercised subject to technical and legal limitations. These rights include:

  • Request confirmation of data processing

  • Request access to personal data

  • Request correction of incorrect, inaccurate, or outdated data

  • Request anonymization, blocking, or deletion of unnecessary or excessive data

  • Request details about data sharing

  • Request data portability under ANPD regulation

  • Revoke consent previously granted for data processing

  • Request information on possible consequences of not providing consent

  • Revoke consent and/or request deletion of data processed based on consent

  • Object to data processing if it violates the LGPD

  • Request review of automated decisions and details on the criteria used

  • File a complaint with the Brazilian Data Protection Authority (ANPD)

To exercise your rights, contact us at: contato@2cw.com.br

Note: When Hal-AI Whats acts as a processor, End Users must exercise their rights directly with the Client with whom they have a relationship, using the channels provided by the Client.

11. How do we use cookies?

To enhance your experience using our Site, we may collect cookies, which are files that allow the automatic collection of data when you visit a webpage.

Can I block/reject the use of cookies?
Yes, you can configure your browser to block cookies from our Site. However, blocking cookies may impair some functionalities. The following links provide information on managing cookies:

  • Firefox

  • Chrome

  • Safari

  • Internet Explorer

12. When was this Notice last updated?

This Notice may be updated or modified at any time.
Last updated: 04/08/2024

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