| Hallan/Elsie Privacy Policy |
At Hallan, we care about your personal
information, so we
have prepared this Privacy Policy to explain how we collect, use, and
share it.
This Privacy Policy applies to Hallan websites, The ELSIE mobile apps,
and
related services (“Service”). By using the Service, you agree with
Hallan’s
collection, use, and sharing of your personal information in accordance
with
the terms of this Privacy Policy.
Please note that Hallan is constantly
testing and improving
our product features. Any features discussed in this Privacy Policy may
not be
available to all users or in all jurisdictions.
When you use ELSIE we collect the phone
number
registered to your phone, as well as summary data on how Elsie is used. We do not store or collect the numbers you
send texts to.
a. Account Registration
To register for a Hallan account, you
provide us only with
your phone number on the device you will be using Elsie on.
b. Cookies
When you access the Hallan website, we
store certain data
from your browser using cookies. A cookie is a piece of data stored on
the
user’s computer tied to data about the user. We use session ID cookies
to
confirm that users are logged in. If you do not want your data to be
collected
by cookies, there is a simple procedure in most browsers that allows
you to
deny or accept the cookie feature. However, cookies may be necessary to
provide
you with certain features available on the website (e.g., customized
information).
Hallan is based in the United States and
processes data in
the United States, which may not provide equivalent levels of data
protection
as your home jurisdiction. Hallan may transfer the data of users
outside the
United States to the United States.
Data Privacy Framework (DPF)
Hallan complies with the EU-U.S. Data
Privacy Framework
(EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S.
Data
Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department
of
Commerce. Hallan has certified to the U.S. Department of Commerce that
it
adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF
Principles) with regard to the processing of personal data received
from the
European Union in reliance on the EU-U.S. DPF and from the United
Kingdom (and
Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Hallan
has
certified to the U.S. Department of Commerce that it adheres to the
Swiss-U.S.
Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with
regard to
the processing of personal data received from Switzerland in reliance
on the
Swiss-U.S. DPF. If there is any conflict between the terms in this
privacy
policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF
Principles, the
Principles shall govern.
In compliance with the EU-U.S. DPF and
the UK Extension to
the EU-U.S. DPF and the Swiss-U.S. DPF, Hallan commits to resolve DPF
Principles-related complaints about our collection and use of your
personal
information. EU and UK and Swiss individuals with inquiries or
complaints
regarding our handling of personal data received in reliance on the
EU-U.S. DPF
and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF should
first
contact Hallan at: privacy@Hallan.com.
In compliance with the EU-U.S. DPF and
the UK Extension to
the EU-U.S. DPF and the Swiss-U.S. DPF, Hallan commits to cooperate and
comply
respectively with the advice of the panel established by the EU data
protection
authorities (DPAs) and the UK Information Commissioner’s Office (ICO)
and the
Gibraltar Regulatory Authority (GRA) and the Swiss Federal Data
Protection and
Information Commissioner (FDPIC) with regard to unresolved complaints
concerning our handling of personal data received in reliance on the
EU-U.S.
DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF.
Individuals
have the possibility, under certain conditions, to invoke binding
arbitration
for complaints regarding DPF compliance not resolved by any of the
other DPF
mechanisms.
Hallan has responsibility for the
processing of personal
information it receives under the DPF Principles and subsequently
transfers to
a third party acting as an agent on its behalf. Hallan shall remain
liable
under the DPF Principles if its agent processes such personal
information in a
manner inconsistent with the DPF Principles, unless Hallan proves that
it is
not responsible for the event giving rise to the damage.
The Federal Trade Commission has
jurisdiction over Hallan’s
compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and
the UK
Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework
(Swiss-U.S. DPF). Hallan may disclose personal information in response
to
lawful requests by US public authorities, including to meet national
security
or law enforcement requirements.
In some jurisdictions, the Service may
be subject to
supplemental privacy policies or local laws. For users in those
jurisdictions,
the applicable supplemental privacy policies and local laws will take
precedence over this Privacy Policy to the extent they conflict.
Hallan Consulting Group is the data controller of your data for the purposes of the General Data Protection Regulation (“GDPR”) and any relevant legislation. Hallan’s headquarters are located within the United States at:
Hallan
Consulting Group
PO Box 9427
Loveland, CO 80538
Privacy Policy was last revised on
September 24, 2024