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Privacy policy

v1.0 · Effective 1 January 2027 · Draft — pending solicitor review
Short version: the app itself sends no data anywhere. Your calculations and records stay on your device or in your own iCloud. We only see personal data when you email us support, sign up for the waitlist, or generate an expense receipt (which stays on your device). Full details below.

01Introduction

This policy explains what personal data Halo HSE (the "App") and the Halo Safety website process, why, and how you can exercise your rights under the EU General Data Protection Regulation (GDPR).

Publisher: MB The Special Something, Perkūnkiemio g. 13-91, LT-12114 Vilnius, Lithuania. Company registration: 304485059. VAT: LT100012830516.

02Data controller

MB The Special Something is the data controller for any personal data processed in connection with the App and this website. For data-protection matters, contact hello@halosafety.io.

03What data we collect

  • Data collected by the App: none. The App contains no third-party analytics SDKs, no advertising SDKs, and no tracking technologies. It does not send usage data to us.
  • Data collected by Apple: Apple's App Store may collect installation and usage data as described in Apple's Privacy Policy. From our perspective this is aggregated and anonymous — we receive only summary statistics (downloads, crash rates, sandbox purchases) through App Store Connect.
  • iCloud sync: if you enable iCloud sync in the App, your calculation data (calculators, records, saved surveys, expense-receipt buyer profile) is stored in your private iCloud container. MB The Special Something has no access to your iCloud data. iCloud is operated by Apple under their own terms.
  • Personal data on expense receipts: if you generate an expense receipt inside the App, you may enter your name, email, employer name, employer address, VAT number, and purchase order reference. This data is stored locally on your device and in your private iCloud only. It is not transmitted to us.
  • Support email: if you contact hello@halosafety.io, we process your email address and the content of your message so we can respond and improve the App. Retained for up to 24 months, then deleted.
  • Waitlist signup (website): if you submit your email address on the halosafety.io waitlist form, it is stored by our email service provider (ESP — provider to be named here once selected: Mailchimp, Buttondown, or ConvertKit) and used only to send product-update notifications. You may unsubscribe at any time via the unsubscribe link in every email.

04Legal basis for processing (GDPR Article 6)

  • Support communications: legitimate interest (Article 6(1)(f)) — responding to a user inquiry you initiated.
  • Waitlist emails: consent (Article 6(1)(a)) — you submit your email voluntarily. Consent can be withdrawn at any time by unsubscribing.
  • Contract performance: Article 6(1)(b) — where applicable to fulfilling the license agreement covered by our Terms of Use.

05Data sharing

We do not sell user data. We do not share user data with third parties for marketing purposes.

We share personal data only with:

  • Apple, as the platform for App Store distribution and iCloud storage (governed by Apple's own privacy terms);
  • Our email service provider, only for waitlist emails (provider name to be added here once selected);
  • Legal authorities where required by law (for example, in response to a valid court order).

06Data retention

  • Support emails: up to 24 months, then deleted.
  • Waitlist emails: until you unsubscribe.
  • Data stored on your device or in your iCloud: controlled entirely by you. Delete the App or clear your iCloud data to remove it.

07Your rights under GDPR

Under GDPR you have the right to:

  • Access your data (Article 15)
  • Rectify inaccurate data (Article 16)
  • Erase your data (Article 17, "right to be forgotten")
  • Restrict processing (Article 18)
  • Data portability (Article 20)
  • Object to processing (Article 21)
  • Withdraw consent (Article 7(3))
  • Lodge a complaint with a supervisory authority

For Lithuania, the supervisory authority is the State Data Protection Inspectorate (Valstybinė duomenų apsaugos inspekcija — VDAI), L. Sapiegos g. 17, 10312 Vilnius, ada@ada.lt, vdai.lrv.lt.

To exercise any of these rights, email hello@halosafety.io. We respond within 30 days.

08International data transfers

We do not transfer personal data outside the European Economic Area (EEA), except:

  • Apple's App Store services may involve processing in the United States. Apple provides its own GDPR compliance mechanisms (Standard Contractual Clauses).
  • The email service provider for the waitlist may process data in the US or the EU. The specific provider and its transfer mechanism (Standard Contractual Clauses or Adequacy Decision) will be listed here once the provider is selected.

09Cookies (halosafety.io)

The Halo Safety website uses only strictly necessary cookies for basic site functionality. It sets no advertising, analytics, or third-party tracking cookies.

Because no non-essential cookies are set, a cookie-consent banner is not required under the ePrivacy Directive as transposed into Lithuanian law.

10Children

Halo HSE is intended for professional use by adults. We do not knowingly collect data from children under 16. Apple's parental controls apply to App Store downloads. If you believe a child has provided us with data, contact hello@halosafety.io and we will delete it.

11Changes to this policy

We may update this policy. The effective date at the top will reflect the most recent version. Material changes will be notified via the App or via email if you have provided one.

12Contact

Data-protection questions and requests: hello@halosafety.io.

MB The Special Something
Perkūnkiemio g. 13-91
LT-12114 Vilnius, Lithuania
Company reg: 304485059 · VAT: LT100012830516