Halborn Privacy Policy

Last Modified: June 1, 2022

We at Halborn are committed to protecting your privacy. This Privacy Policy applies to the information and data collected by Halborn when you interact with us on our website or through other channels (for example, by communicating with us), and when you use our products and services (collectively, the “Services”). This Privacy Policy describes how we collect, receive, use, store, share, transfer, and process your Personal Data. It also describes your choices and rights with respect to your Personal Data, including your rights of access and correction of your Personal Data. If you do not agree with this Privacy Policy, you should not use our website or Services. 

Data privacy laws sometimes differentiate between “controllers” and “processors” of Personal Data. Halborn is the controller of Personal Data as described in this Privacy Policy unless otherwise noted. This Privacy Policy does not generally apply to Halborn’s processing activities in its capacity as a processor or service provider.

We update this Privacy Policy from time to time and we encourage you to review this Privacy Policy periodically. We will post any Privacy Policy changes on this page. For the purposes of this Privacy Policy “Personal Data” shall mean any information relating to an identified or identifiable individual where such information is protected similarly as personal data or personally identifiable information under applicable legislation relating to data protection and privacy (“Data Protection Laws”).

If you have any questions about this Privacy Policy or our treatment of your Personal Data, please email privacy@halborn.com or write to us by mail at Halborn Inc., 114 NW 25th Street, Miami, Florida 33127 USA,, Attn: Privacy and Data Protection Officer.

  1. What Information We Collect About You
    1. Information You Provide to Halborn. When you interact with us via our website or use our Services, we may collect Personal Data and other information from you, as further described below.
      • When You Visit Our Websites. We collect Personal Data from you when you submit web forms or interact with our websites, for example requesting more information, subscribing to our blog, or registering for a webinar. We may ask for your email address, first and last name, and other similar business information. You are free to explore some of our website without providing any Personal Data about yourself. 
      • Performance of Our Services. We may collect Personal Data when our Services require you to sign-up for an account, or permit you to create or modify user information, set preferences, or provide any other related information to access or utilize our Services. 
      • Payment Information. We collect payment and billing information when you register for paid products or services. If you give us payment information, we use it solely as authorized by you in accordance with this Privacy Policy. You may also provide payment information, such as a credit card number or bank account numbers, when using products or services. We use secure third-party payment service providers to manage payment processing, which is collected through a secure payment process.  
      • Customer Testimonials. We post customer testimonials and comments on our websites, which may contain Personal Data. We obtain each customer’s consent via email or through other agreements between customers and Halborn prior to posting the customer’s name and testimonial.
    2. Information We Collect and Process When You Use our Services
      • Log Files. When you visit our website or when you use our Services, we automatically collect information about your computer hardware and software. This information can include your IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times and referring website addresses. 
      • Usage Data. Where our Services require an account, we collect usage data when you or your users in your account interact with the Service. We engage third-party providers to collect usage data, and we only share data with these providers in an unidentified manner. Usage data includes metrics and information regarding your use and interaction with the Service such as what product features you use the most, when an object (like a ticket) is opened and closed, and how often certain features (like workflows) are triggered in your account.  
  1. How We Use Your Information
    1. To Provide the Product and Services
      • To Market and Promote the Services. We use the information you provide to Halborn to market and promote the products and services. For example, we use the information, like your email, to send information which we think may be of interest to you. We may also reach out to you to ask about other Halborn products or services you may be interested in. 
      • To Communicate with You About the Services. We use the data you provide to Halborn when signing up for the Services to contact you about billing, other administrative matters, and security incidents. We also use your information to provide customer support, such as resolving technical issues you encounter and analyzing product outages or bugs. 
      • To Provide and Improve the Service.  We use the information you provide to Halborn to provide the product and services to you. For example, we may use the email address you provide to create your user account, and we use your payment information to process payments for use of the Service. We collect data about how our products and services are used by monitoring and tracking our product’s users. We use this data to develop and improve our products and services.  For example, we use usage data to assess trends and usage across the product to help us determine what new features or integrations our users may be interested in. We may share usage data externally but will only do so in an anonymized and/or aggregated manner to build and improve product features. 
      • To Secure and Protect our Product and Users. We use your information to investigate and help prevent security incidents, and to detect and prevent product abuse. 
      • Third Parties. We receive information from third parties. We may receive and use this information from these service providers in combination with other information we collect through other means described in this Privacy Policy for the purposes of providing you with updates, such as event promotions.
      • Social Media Features. Our website includes social media features, such as the Twitter widget, the share button, or interactive mini-programs that run on our website. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. This Privacy Policy does not apply to these features. Your interactions with these features are governed by the privacy policy and other policies of the companies providing them.
    2. Legal Basis for Processing Personal Data (EEA and UK visitors only)
      • If you are a website visitor located in the European Economic Area (“EEA”) or United Kingdom (“UK”), our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it. However, we will normally collect Personal Data from you only where we have your consent to do so or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. 
  1. How We Share Information We Collect
    1. Third Parties and Services Providers
      • We employ third parties and service providers to provide services on our behalf to our website visitors and users of the product and services. Examples include analyzing data or performing statistical analysis on your use of the Services or interactions on our websites, processing credit card payments, and hosting partners to provide the necessary hardware, software, networking, storage, and other services. These service providers are prohibited from using your Personal Data except for these purposes, and they are required to maintain the confidentiality of your information. In all cases where we share your information with such agents, we explicitly require the agent to acknowledge and adhere to our privacy and data protection policies and standards.
    2. Partners
      • We may share data with trusted Halborn partners to contact you based on your request to receive such communications or help us perform statistical analysis. We also partner with trusted third parties to provide you with co-marketing content that we think may be relevant to you. Partners are prohibited from using your Personal Data except for these purposes, and they are required to maintain the confidentiality of your data.
    3. Corporate Events
      • If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by Halborn on the website and the Services. In this event, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Data, and choices you may have regarding your Personal Data.
    4. Compelled Disclosure
      • We reserve the right to use or disclose your Personal Data if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process. 
  1. How We Transfer Data We Collect Internationally
    1. International Transfers to Third Parties
      • Some of the third parties described in this Privacy Policy, which provide services to us under contract, are based in other countries that may not have equivalent privacy and data protection laws to the country in which you reside. When we share Personal Data of individuals in the EEA, Switzerland or UK with third parties, we make use of a variety of legal mechanisms to safeguard the transfer including the European Commission-approved standard contractual clauses, as well as additional safeguards where appropriate. For transfers to or from the United Kingdom, we make use of the standard contractual clauses as adapted for the UK. For transfers to or from Canada, we make use of the standard contractual clauses. With respect to personal data received from or transferred to Canada, Halborn is subject to the regulatory enforcement powers of the Office of the Privacy Commissioner of Canada. Please contact us if you need more information about the legal mechanisms we rely on to transfer personal data outside the EEA, Switzerland, Canada, and UK.
  1. How We Store and Secure Your Information
    1. Data Storage and Security
      • We use a variety of security technologies and procedures to help protect your Personal Data from unauthorized access, use or disclosure. We secure the Personal Data you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. All Personal Data is protected using appropriate physical, technical and organizational measures.
    2. Retention of Personal Data
      • How long we keep information we collect about you depends on the type of information and how we collect and store it.  After a reasonable period of time, we will either delete or anonymize your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible. 

We retain Personal Data that you provide to us where we have an ongoing legitimate business need to do so (for example, as needed to comply with our legal obligations, resolve disputes and enforce our agreements). When we have no ongoing legitimate business need to process your Personal Data, we securely delete the information or anonymize it or, if this is not possible, securely store your Personal Data and isolate it from any further processing until deletion is possible.

  1. Cookies and Similar Technologies
    1. Cookies. Technologies such as cookies are used by Halborn and our marketing partners, affiliates, or analytics or service providers.
    2. What are cookies? A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the site again, the cookie allows that site to recognize your browser. Cookies may store user preferences and other information.  

Cookies provide a convenience feature to save you time, or tell the Web server that you have returned to a specific page. 

Cookies set by the website owner (in this case, Halborn) are called “first party cookies”. Cookies set by parties other than the website owner are called “third party cookies”.  Third party cookies enable third party features or functionality to be provided on or through the website (e.g. like advertising, interactive content and analytics). The parties that set these third party cookies can recognize your computer both when it visits the website in question and also when it visits certain other websites.

  1. Why do we use cookies? We use first party and third party cookies for several reasons. Some cookies are required for technical reasons in order for our website to operate, and we refer to these as “essential” or “strictly necessary” cookies. Other cookies also enable us to track and target the interests of our users to enhance the experience on our website.  For example, Halborn keeps track of the pages you visit within Halborn, in order to determine what portion of the website or Service is the most popular or most used. This data is used to analyze trends, administer the website, monitor how visitors navigate around the website, and to gather demographic information about our user base as a whole.
  2. What types of cookies do we use and how do we use them? The specific types of first and third party cookies served through our website include:

Essential website cookies: These cookies are strictly necessary to provide you with services available through our website. 

Performance and functionality cookies: These cookies are used to enhance the performance and functionality of our website but are non-essential to their use. 

Analytics and customization cookies: These cookies collect information that is used either in aggregate form to help us understand how our website are being used or to help us customize our website for you.

Social networking cookies: These cookies are used to enable you to share pages and content that you find interesting on our website through third party social networking and other websites. 

  1. How can I control cookies? You have the right to decide whether to accept or reject cookies. You can exercise your cookie preferences by clicking on the appropriate opt-out links provided below.

You can set or amend your web browser controls to accept or refuse cookies. If you choose to reject cookies, you may still use our website though your access to some functionality and areas of our website may be restricted. As the means by which you can refuse cookies through your web browser controls vary from browser-to-browser, you should visit your browser’s help menu for more information.

In addition, most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit http://www.aboutads.info/choices/. You may opt out by clicking here: http://optout.aboutads.info/ (or if located in the European Union, by clicking here: http://www.youronlinechoices.eu/). Please note this does not opt you out of being served advertising. You will continue to receive generic advertisements.

Essential website cookies: Because these cookies are strictly necessary to deliver the websites to you, you cannot refuse them. You can block or delete them by changing your browser settings however, as described above.

  1. How to Access & Control Your Personal Data
    1. Reviewing, Correcting and Removing Your Personal Data. You have the following data protection rights: 
      • You can request access, correction, updates or deletion of your Personal Data.
      • You can object to our processing of your Personal Data, ask us to restrict processing of your Personal Data or request portability of your Personal Data.
      • If we have collected and processed your Personal Data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
      • You have the right to complain to a data protection authority about our collection and use of your Personal Data.

To exercise any of these rights, please contact us. We will respond to your request to change, correct, or delete your data within a reasonable timeframe and notify you of the action we have taken.

  1. To Unsubscribe from Our Communications. You may unsubscribe from our marketing communications by contacting us. Customers cannot opt out of receiving transactional emails related to Services.
  1. California Privacy Rights
    1. Applicability. This section applies only to California consumers. For purposes of this section “Personal Information” has the meaning given in the California Consumer Privacy Act (“CCPA”). It describes how we collect, use, and share California consumers’ Personal Information in our role as a business, and the rights applicable to such residents. The California Consumer Privacy Act (“CCPA”) requires businesses to disclose whether they sell Personal Information. Halborn is a business, and does not sell Personal Information. We may share Personal Information with third parties if those third parties are authorized service providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such Personal Information. 

If you are unable to access this Privacy Policy due to a disability or any physical or mental impairment, please contact us and we will arrange to supply you with the information you need in an alternative format that you can access.

  1. How We Collect, Use, and Share your Personal Information. We have collected the following statutory categories of Personal Information in the past twelve (12) months:
    • Identifiers, such as name, e-mail address, mailing address, and phone number. We collect this information directly from you or from third party sources. 
    • Commercial information, such as transaction information and blockchain information. 
    • Internet or network information, such as browsing and search history. We collect this information directly from your device. 
    • Geolocation data, such as IP address. We collect this information from your device.
    • Financial information, such as payment information or financial account numbers in the process of providing you with a Service. We collect this information from you. 
    • Inferences. 
    • Other Personal Information, in instances when you interact with us online or by phone in the context of receiving help through our support channels; or in providing the Service. 

The business and commercial purposes for which we collect this information are described in Section 2 of this Privacy Policy. The categories of third parties to whom we “disclose” this information for a business purpose are described in Section 3 of this Privacy Policy.

  1. Your California Rights
    • You have certain rights regarding the Personal Information we collect or maintain about you. Please note these rights are not absolute, and there may be cases when we decline your request as permitted by law.

The right of access means that you have the right to request that we disclose what Personal Information we have collected, used and disclosed about you in the past 12 months. 

The right of deletion means that you have the right to request that we delete Personal Information collected or maintained by us, subject to certain exceptions. 

The right to non-discrimination means that you will not receive any discriminatory treatment when you exercise one of your privacy rights. 

Halborn does not sell Personal Information to third parties (pursuant to California Civil Code §§ 1798.100–1798.199, also known as the California Consumer Privacy Act of 2018).

  1. How to Exercise Your California Rights
    • You can exercise your rights yourself or you can alternatively designate an authorized agent to exercise these rights on your behalf. Please note that to protect your Personal Information, we will verify your identity by a method appropriate to the type of request you are making. We may also request that your authorized agent have written permission from you to make requests on your behalf, and we may also need to verify your authorized agent’s identity to protect your Personal Information.
    • Please use the contact details below, if you would like to: Access this policy in an alternative format; Exercise your rights; Learn more about your rights or our privacy practices; or Designate an authorized agent to make a request on your behalf.
  1. Data Protection Officer
    1. If you have any questions about this Privacy Policy or our privacy practices, or if you have a disability and need to access this notice in a different format, please contact us here or by mail at: privacy@halborn.com
  1. Other Important Privacy Information
    1. We Never Sell Personal Data. We will never sell your Personal Data to any third party. 
    2. Information About Children. The website is not intended for or targeted at children under 16, and we do not knowingly or intentionally collect Personal Data about children under 16. If you believe that we have collected Personal Data about a child under 16, please contact us here, so that we may delete the information