1. Personal Data we collect
Definition of Personal Data
“Personal Data” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an identified or identifiable natural person or household. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, online identifier, device identifier, Internet Protocol address, residential address, work address, other location data, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person. Personal Data includes, without limitation, information that is linked or reasonably linkable to a particular consumer, individual, or household, as well as any “personal data,” “personal information,” or similar term as defined under applicable data protection laws, including the EU General Data Protection Regulation (“EU GDPR”), the UK General Data Protection Regulation (“UK GDPR”), the California Consumer Privacy Act of 2018, as amended (“CCPA”), and 201 CMR 17.00 (“Massachusetts Data Security Law” or “MDSL”). As used in this Privacy Policy, Personal Data includes “Personally Identifiable Information” as defined by NIST FIPS 201-3. Personal Data does not include information that has been de-identified, anonymized, or aggregated such that it cannot reasonably be used to identify or relate to an individual or household, provided that appropriate technical and organizational measures are implemented to prevent re-identification.
Data you provide or generate through the Services
- Account and contact data: name, email address, password (hashed), organization, role, billing contact.
- Payment data: payment-method tokens, billing address, tax IDs. Full card numbers are collected directly by our payment processor, Stripe, and are not stored on Halo systems.
- Customer Data submitted to or generated through the Services: prompts, messages, files, and other inputs you or your authorized users send to agents or to Halo Chat; configuration you supply (policies, budgets, agent metadata, app-connect bindings); credentials you supply for BYOK or third-party tools, which we encrypt at rest and use only as you direct; and telemetry, inventory, policy decisions, and other records generated through your use of Halo, including enrolled browser and device data.
- Communications: messages you send to support, sales, or via in-product chat.
Data collected automatically
- Device and connection: IP address, browser type, operating system, device identifiers, language, time zone, referring URL.
- Usage: pages viewed, features used, agent runtimes deployed, gateway decisions, classifier results, model and tool-call metadata, billing events, error logs, performance telemetry.
- Cookies and similar technologies, as described in Section 7.
Data collected by Halo Browser Security and Halo Endpoint
Halo Browser Security (our browser extension) and Halo Endpoint (our device agent) are deployed by an organization to inventory and govern AI use on enrolled browsers and devices. Depending on which collectors that organization enables, they process recognized AI application domains and activity, content submitted to those applications, inferred work/personal/unknown account classification, connected AI tool inventory, browser and device application inventory, process and application-control metadata, and installation and health data. This is Customer Data that we process as a processor on that organization’s behalf and make available to its administrators in its Halo tenant. That organization is responsible for configuring the collectors and for notifying its personnel.
Our Browser Privacy Notice and Endpoint Privacy Notice describe these product-specific categories, organizational responsibilities, and retention in more detail. The Browser Privacy Notice also describes our Chrome Web Store Limited Use commitments.
Data from third parties
- OAuth and SSO providers (e.g., Google, Microsoft, GitHub, Slack) when you sign in or connect those accounts: name, email, profile photo, and the scopes you authorize.
- Payment processor (Stripe): payment status and fraud signals.
- Enrichment vendors: firmographics for sales outreach, only where lawful.
Sensitive categories
The Services are not designed to receive special-category Personal Data (e.g., government-issued IDs, health, biometric, racial or ethnic origin, sexual orientation, precise geolocation, financial-account numbers). Do not submit such data through Inputs or agent connections unless your separate written agreement with us expressly permits it.
Absent a separate written Data Processing Agreement and the approval of the data subject, sensitive data is not intentionally accepted, stored, or processed. Upon discovery, we delete sensitive data that is not specifically authorized by the Data Processing Agreement and the data subject.
2. How we use Personal Data
We use Personal Data to:
- Provide, operate, secure, and improve the Services.
- Authenticate you and provision your account.
- Process payments, manage Halo Credits, and meter usage.
- Send service, security, and billing communications (you cannot opt out of these).
- Send marketing communications, where lawful, with an unsubscribe option in every message.
- Monitor for and investigate violations of our Terms of Use and Acceptable Use Policy, and to detect fraud and abuse.
- Develop aggregated, de-identified analytics that no longer identify any individual.
- Respond to legal process and meet legal obligations.
What we do not do:
- We do not sell Personal Data.
- We do not share Personal Data for cross-context behavioral advertising.
- We do not use Customer Data to train foundation models. Halo-managed models are operated by third-party providers (via AWS Bedrock) under contracts that prohibit training on customer prompts and outputs.
- We do not access Customer Data to read its contents except (a) at your direction (e.g., support troubleshooting), (b) for security or abuse investigation, or (c) where legally required.
3. Halo-managed models, BYOK, and third-party processing
When you use Halo-managed models (Halo Fast, Halo Balanced, Halo Powerful), the Inputs and Outputs are transmitted to the underlying provider(s) via AWS Bedrock for inference. Their processing is governed by the agreements OmniTrust holds with those providers; today, those agreements prohibit training on, and require deletion or short retention of, customer Inputs and Outputs.
When you use BYOK, your Inputs and Outputs go to the provider associated with your key (e.g., OpenAI, Anthropic, Google, Azure OpenAI). You are responsible for understanding and accepting that provider’s terms and privacy practices.
When agents you deploy connect to third-party tools, MCP servers, or APIs, the data those connections send and receive is governed by the third party’s terms.
5. International transfers
OmniTrust is headquartered in the United States and processes data primarily in the United States. If you access the Services from outside the U.S., your data will be transferred to and processed in the U.S. and other countries that may have different data-protection laws than your country.
For transfers from the EEA, UK, or Switzerland, we rely on the EU Standard Contractual Clauses (or, where applicable, the EU-U.S. Data Privacy Framework, the UK Addendum, and the Swiss SCCs). Contact legal@omnitrusthalo.com for a copy of the applicable transfer mechanism.
6. Data retention
We retain Personal Data only as long as necessary for the purposes described in this Policy or as required by law:
| Data category | Retention default |
|---|---|
| Account profile and billing | Lifetime of the account + 7 years for tax/audit |
| Customer Data (including prompts, outputs, agent traces, gateway evidence, and browser and endpoint data) | While account is active; up to 90 days after account closure for export |
| Application logs | 30 days rolling |
| Security logs and audit evidence | 1 year rolling |
| Marketing contacts | Until unsubscribe + reasonable suppression-list retention |
| Aggregated, de-identified analytics | Indefinite |
Customers on Team and Enterprise plans may negotiate alternate retention through a Data Processing Addendum.
8. Your privacy rights
Depending on where you live, you may have the right to:
- Access the Personal Data we hold about you.
- Correct inaccurate Personal Data.
- Delete Personal Data.
- Receive a portable copy of your Personal Data.
- Object to or restrict certain processing.
- Withdraw consent (where processing is based on consent).
- Lodge a complaint with your local data-protection authority.
- (For California, Virginia, Colorado, Connecticut, Utah, and other U.S. state-law jurisdictions:) opt out of the sale or sharing of Personal Data and of certain profiling. Note that we do not sell or share Personal Data for behavioral advertising.
To exercise any right, email legal@omnitrusthalo.com from the address on your account, or use the in-product privacy controls. We will verify your request and respond within the timelines required by applicable law (typically 30 to 45 days). You may designate an authorized agent to act on your behalf.
If your data is processed by us as a processor on behalf of a business customer (Professional/Team/Enterprise), please direct your request to that customer; we will assist them as required by our agreement.
9. Children
The Services are not directed to, and we do not knowingly collect Personal Data from, children under 18. If you believe a child has provided us Personal Data, contact legal@omnitrusthalo.com and we will delete it.
10. Security
We implement reasonable administrative, technical, and physical safeguards including encryption in transit (TLS 1.2+) and at rest, role-based access control, single sign-on for our employees, audit logging, and least-privilege production access. No system is perfectly secure, and we cannot guarantee absolute security. Report suspected vulnerabilities to support@omnitrusthalo.com.
11. Automated decision-making
The Services include AI agents you configure and deploy that may produce outputs and take actions automatically. You, not OmniTrust, are responsible for the decisions those agents make and for ensuring those decisions comply with applicable law (including, where relevant, providing notice of automated decision-making, allowing humans to review high-impact decisions, and avoiding prohibited uses).
OmniTrust itself does not make automated decisions about you that produce legal or similarly significant effects without human involvement.
12. Changes to this Policy
We will update this Policy from time to time. Material changes will be announced at least 30 days in advance by email or in-product notice. The “Last updated” date at the top reflects the most recent version.
13. Contact and supervisory authorities
- Privacy questions, requests, complaints: legal@omnitrusthalo.com
- Postal: OmniTrust Security LLC, Attn: Privacy
You also have the right to lodge a complaint with your local data-protection authority.