Privacy Policy for Halusky Inc.
Last updated: 27 Jun 2024
Introduction
Halusky Inc. ("we", "our", "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website or use our services, including serving ads on third-party websites ("publishers").
We generate contextual ads using large language models and integrate them into chatbot and LLM (Large Language Model) applications. We are committed to never use personally identifiable information (PII) to select advertisements or generate ad content. Instead, we use contextual data, such as messages in the conversation, character persona or high level session metadata (eg. time of the day, country code etc.).
This Privacy Policy is divided into multiple parts to address different user interactions with our services. Part I covers individuals who interact directly with our services, such as visiting our website or using our dashboard, where we may collect personal data and use cookies. Part II addresses individuals who see our ads on third-party websites, where we immediately discard any PI. Each part outlines the specific scope and practices related to data collection, use, and sharing for these different user groups. Finally, Part III covers general provisions applicable to all users.
Part I: Practices when users interact directly with our services
1. Scope
This part of the Privacy Policy applies to services provided on megabrain.co and its subdomains ("Services"). These services include, but are not limited to, accessing our website, using our publisher or advertiser dashboard, and other related interactions.
2. Information We Collect
Personal Data: We may collect personally identifiable information, such as your name, email address, and other contact information, when you interact with our website, dashboard, or Services.
Non-Personal Data: We may collect non-personal information, such as browser type, operating system, IP address, and browsing behavior, to better understand how users interact with our services and to improve our offerings.
Cookies and Tracking Technologies: We use cookies, web beacons, and other tracking technologies to collect information about your browsing activities. You can control cookies through your browser settings.
3. How We Use Your Information
To Provide and Improve Our Services: We use the information we collect to deliver, maintain, and improve our services and user experience.
Personalization: We may use your information to personalize your experience on our website or dashboard.
Analytics: We analyze information to understand how our services are used and to enhance their performance.
Compliance and Legal Obligations: We may use your information to comply with legal obligations, resolve disputes, and enforce our agreements.
4. How We Share Your Information
Service Providers: We may share your information with third-party service providers who perform services on our behalf, such as data analysis, email delivery, and customer support.
Advertisers: We may share non-personal information with advertisers to help them understand the performance of their ads and to improve ad targeting.
Legal Requirements: We may disclose your information if required by law or in response to legal processes.
Business Transfers: If we undergo a merger, acquisition, or asset sale, your information may be transferred as part of that transaction.
Part II: Practices when users see our ads on third-party websites
1. Scope
This part of the Privacy Policy applies to users who see our ads on third party websites (”publishers”).
2. Information We Collect
Non-Personal Data Only: We collect and immediately discard any PII when serving ads on third-party websites. We only use non-personal data such as contextual data from the conversation, character persona, or high-level session metadata (e.g., time of day, country code, user agent etc.). We also collect the ad performance metrics (views, clicks, conversions) tied to each ad identifier.
3. How We Use Your Information
To Serve Contextual Ads: We use non-personal information to generate and deliver contextual ads that are relevant to the conversation and user experience.
Analytics and Reporting: We analyze non-personal data to understand the performance of our ads and to improve their effectiveness. We share such reports with publishers and advertisers.
Model Improvement: We use the ad performance data to continuously improve models that select the right products to advertise and generate content of the ads themselves.
4. How We Share Your Information
With Publishers: We share non-personal information with third-party publishers to deliver targeted ads.
With Advertisers: We share non-personal information with advertisers to help them understand the performance of their ads and to improve ad targeting.
Legal Requirements: We may disclose non-personal information if required by law or in response to legal processes.
Business Transfers: If we undergo a merger, acquisition, or asset sale, non-personal information may be transferred as part of that transaction.
Part III: Terms applicable to all users
1. Data Transfers
We operate globally and may transfer, store, and process your information in countries outside of your own, including the United States, Sweden, and the Czech Republic. These countries may have data protection laws that are different from those of your country. We ensure that any international transfers of your personal data are subject to appropriate safeguards, such as standard contractual clauses approved by relevant regulatory authorities, to ensure the protection of your privacy and personal data.
2. Data Controllers, Processors, and Subprocessors
Data Controller: Halusky Inc. is the data controller responsible for your personal information. This means we determine the purposes and means of processing your data.
Data Processors: We engage third-party service providers as data processors to process your information on our behalf. These processors are bound by contractual obligations to safeguard your data and only process it based on our instructions.
Subprocessors: We may also use subprocessors, which are service providers engaged by our data processors. We ensure that our subprocessors comply with the same data protection obligations as our data processors.
3. Security of Your Information
Halusky Inc. takes a security-by-design approach to protecting your data. We use administrative, technical, and physical security measures to protect your personal information. We follow industry best practices, monitor our services for malicious activity and continuously implement new security protocols to keep your data secure.
4. Children’s Privacy
Our services are not intended for children under the age of 13. We do not knowingly collect personal information from children under 13. If we become aware that we have inadvertently collected personal information from a child under 13, we will delete such information from our records.
5. Your Privacy Rights
Opt-Out of Personalized Ads: You can opt out of personalized ads by adjusting your cookie settings or using industry opt-out tools.
Access and Correction: You have the right to access and correct your personal information. Contact us to exercise these rights.
Data Deletion: You can request the deletion of your personal data under certain circumstances.
Contact us if you want to exercise your privacy rights.
6. Data Retention
We retain your personal data for a period of 5 years, unless a longer retention period is required or permitted by law. After this period, we will securely delete or anonymize the personal data.
7. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on our website. You are advised to review this Privacy Policy periodically for any changes.
8. Contact Us
If you have any questions about this Privacy Policy, please contact us at:
Halusky Inc.
3550 South Dupont Highway, 19901 Dover, DE United States of America
privacy@megabrain.co