Privacy Policy

This policy explains how Lahoika OÜ (“Halo”, “we”, “us”) processes personal data when you use the Halo mobile app, visit speaktohalo.com, contact us, or use a related Halo service. It also explains the choices and rights available to you.

1. Who is responsible for your data

Controller: Lahoika OÜ, registry code 17475517

Registered office: Hane tn 4, Kristiine, Tallinn 13418, Estonia

Privacy contact: hello@speaktohalo.com

Halo is subject to the EU General Data Protection Regulation (GDPR) and applicable Estonian data-protection law.

2. Data we process

Content and information you provide

• Voice audio sent during a live session, plus the transcript created from it.
• Text conversations, journal entries, mood check-ins, feedback, and support messages.
• Names, reminders, and other details you choose to share with Halo.
• When you ask Halo to check your calendar, the event titles, times, and availability needed to answer that request.
• Onboarding and profile choices, such as language, age group, gender, reason for using Halo, and how you heard about us, where you choose to provide them.

Account, product, and payment information

• A generated user identifier and temporary account data. If you link Apple or Google sign-in, we receive the identifier and account details that provider makes available, which may include an email address.
• Subscription status, product, offer, transaction, renewal, and entitlement information from Apple, Google, and Adapty. We do not receive your full payment-card number.
• Guest Pass issue, claim, eligibility, and redemption records.

Information Halo creates

• Journal summaries, titles, mood labels, themes, patterns, insights, and memory links created from your sessions.
• Session metadata such as date, mode, duration, completion state, and feature usage.
• Streaks, counts, and other product-state information.

Technical and usage information

• Device, operating-system, language, app-version, network, IP, and server-log information.
• Push-notification tokens and notification interactions.
• App analytics events and fixed onboarding selections, such as screens viewed, features used, session counts, durations, and purchase events.
• Crash and diagnostic information sent to Sentry and platform services.
• Advertising or attribution identifiers and campaign signals only to the extent the platform and your applicable choices allow them.

Your journal may reveal sensitive facts about health, emotions, relationships, beliefs, sexuality, or other private matters. You decide what to share. Halo does not use conversation content to target advertising.

3. How voice and AI processing work

During a voice session, Halo streams audio for speech recognition. ElevenLabs Scribe is the primary speech-to-text provider; Google Speech may be used as a fallback where supported. Halo then sends the transcript and relevant conversation context to Google Gemini to create a reply. Google text-to-speech may generate the spoken response.

Halo does not store raw voice audio in its own database. We store the resulting transcript and journal data so the app can show your history and provide the features you request. Our processors may retain limited request, safety, abuse-prevention, or operational logs under their configured service terms and retention settings. We do not promise that every processor deletes all transient data the moment a session ends.

Under the paid Gemini API terms used by Halo, Google does not use submitted prompts or responses to improve its models. Limited logging may still occur for security and abuse monitoring. Other providers process data under their own agreements with us.

Halo’s AI output is generated automatically and can be incomplete or wrong. Halo does not use automated processing to make legal, employment, credit, insurance, or similarly significant decisions about you.

Calendar requests

Halo asks for full calendar access only after you ask it to find an event or a free time. The app searches the calendars available through Apple’s EventKit on your device. It may compare your search with event titles, locations, and participant display names, but it sends only a limited result to Halo: the matching event title and time, or the free slots found. It does not send calendar names, notes, URLs, participant email addresses, or provider error details.

Calendar search results are used only to answer the current request. Halo does not add the calendar question, result, or answer to your journal, memory, drafts, product analytics, or crash reports. Operational records contain only status, result count, and timing. Calendar access is optional, and declining it does not prevent you from using voice or text conversations.

4. Why we use data and our legal bases

• To provide Halo: run conversations, answer calendar requests you make, create journal entries and insights, maintain your account, remember product state, deliver Guest Passes, and provide subscription features. We rely on performance of our contract with you.
• To secure and operate the service: prevent abuse, troubleshoot failures, protect accounts, and maintain reliability. We rely on our legitimate interests and, where applicable, legal obligations.
• To improve the product: understand feature adoption and diagnose product issues using limited event and technical data. We rely on legitimate interests or consent where consent is required.
• To deliver notifications and optional measurement: send notifications, use non-essential website analytics, or access advertising identifiers where required. We rely on your consent or platform permission.
• To handle payments, rights requests, and legal duties: manage entitlements, accounting, disputes, and lawful requests. We rely on contract and legal obligations.

Where applicable law requires consent for a particular kind of processing, you can withhold or withdraw that consent. Withdrawal does not affect processing that was lawful before withdrawal. Some core processing is necessary to provide a feature you actively request; without it, that feature may not work.

5. Service providers and recipients

We use vetted providers to run Halo. They process only the data needed for their role:

• Supabase: authentication, database, storage, and server functions.
• Google Cloud: Gemini AI, speech recognition fallback, text-to-speech, Firebase/GA4 analytics, push delivery, and related infrastructure.
• ElevenLabs: primary real-time speech recognition.
• Adapty, Apple, and Google: subscriptions, entitlements, app distribution, store offers, and authentication where selected.
• Mixpanel: product analytics.
• Meta: app-campaign measurement and attribution.
• Sentry: crash and diagnostic monitoring.
• Apple Push Notification service and Firebase Cloud Messaging: notification delivery.
• Vercel: website hosting and delivery.

We do not send raw audio, conversation transcripts, or free-form journal text to Mixpanel, Firebase Analytics, Meta, or website analytics. These services may receive account identifiers, fixed profile or onboarding selections, device and app information, and event metadata such as a feature name, session count, duration, or purchase state.

We do not sell personal data and do not show third-party ads inside Halo.

6. International transfers

Halo’s primary database is hosted in the European Union. Some providers may process data in other countries. Where EU/EEA personal data is transferred outside the EEA, we use an available legal transfer mechanism, such as an adequacy decision or the European Commission’s Standard Contractual Clauses, together with appropriate safeguards where required.

7. How long we keep data

Retention depends on the data and why it is needed:

• Account, journal, transcript, mood, memory, and product-state data is generally kept while your account is active and removed from active Halo systems when you delete the account, subject to technical and legal exceptions below.
• Provider logs, analytics, attribution, and diagnostic data follow the configured retention cycles of the relevant provider and may not disappear at the same time as your Halo account.
• Security and abuse-prevention records are kept only as long as reasonably needed to investigate and protect the service.
• Transaction, tax, and accounting records may be kept for up to seven years where Estonian law requires it.
• Encrypted backups expire through the applicable provider’s backup-rotation cycle. We do not restore deleted data to active use except where required for disaster recovery.
• Aggregated or de-identified statistics that can no longer reasonably identify you may be retained.

8. Account deletion

You can delete your account in Halo under Profile → Settings → Delete Account. This removes the account and associated content from Halo’s active systems and cannot be undone. See Delete Your Account for details.

Deleting a Halo account does not cancel a subscription managed by Apple or Google. You must cancel that subscription separately in the store. Some payment, analytics, security, or diagnostic records held by providers may require separate handling or may be retained where law allows.

9. Your data-protection rights

Depending on where you live, you may have rights to access, correct, erase, or receive your data; restrict or object to processing; withdraw consent; and complain to a supervisory authority. You may also have the right not to be subject to certain automated decisions.

Send a request to hello@speaktohalo.com. We may need to verify that the request relates to your account. We aim to respond within one month. A lawful extension of up to two additional months may apply to a complex request; if so, we will tell you.

You may complain to the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) at aki.ee, or to the competent authority where you live.

10. App analytics and advertising measurement

Halo uses Mixpanel, Firebase/GA4, Meta App Events, Adapty, and Sentry for product operation, diagnostics, subscription measurement, and campaign attribution. The exact signals available depend on the device, platform rules, and your choices.

On iOS, Halo uses Apple’s App Tracking Transparency flow before accessing IDFA-quality tracking. If you decline, Halo does not use IDFA and platform-level measurement may use privacy-preserving or aggregated methods. Android and other platform identifiers are handled according to applicable platform settings and law.

Turning off a platform advertising permission does not necessarily disable essential subscription events, security logs, aggregated measurement, or product analytics that do not use that advertising identifier.

11. Website storage and analytics choices

The Halo website uses necessary first-party browser storage to remember your light or dark theme, app-banner dismissal, and analytics choice. The site offers a separate choice before loading Google Analytics. If you choose Necessary only, the site does not load Google Analytics or store campaign parameters for analytics. You can reopen Privacy choices from the footer at any time.

If you allow website analytics, Google Analytics may set or read identifiers and receive page, device, approximate-location, referral, and campaign information. Advertising personalization and Google Signals are disabled in our website configuration. We do not currently load a Meta Pixel on the website.

12. Security

We use technical and organizational safeguards such as encrypted transport, access controls, row-level database policies, secret management, and operational monitoring. No online system is completely secure, and we cannot promise absolute security.

13. Children

Halo is intended for people aged 18 or older. We do not knowingly offer the service to children. If you believe a person under 18 has provided personal data to Halo, contact us so we can investigate and take appropriate action.

14. Changes to this policy

We may update this policy when Halo, our providers, or legal requirements change. For a material change, we will provide reasonable notice in the app, on the website, or by email where available. The date above shows the latest revision.

15. Contact us