AI Transparency & Use Policy

1. What Halvday uses AI for

Halvday uses artificial intelligence to help businesses research, evaluate and prepare potential sales opportunities.

Depending on the feature used, AI may assist with:

• creating, reviewing and improving an ideal customer profile;
• finding companies that may match a customer's target audience;
• researching publicly available information about companies and professional contacts;
• assessing account fit, timing signals and commercial relevance;
• identifying potentially relevant people within an organisation;
• summarising and organising public evidence;
• recommending potential next steps;
• preparing sales briefs;
• generating draft emails, connection requests, call notes and other outreach materials;
• answering user questions through the Halvday AI assistant;
• monitoring selected companies for relevant public changes and signals.

AI assists with research and preparation. It does not replace the user's commercial judgment.

2. Human control

Halvday is designed around human review and control.

Users decide:

• which ideal customer profile to activate;
• which companies should be researched;
• which accounts should be pursued, monitored, postponed or dismissed;
• whether an identified person is relevant;
• whether AI-generated information is sufficiently reliable;
• whether a generated message should be used or changed;
• whether and when any communication is sent.

Halvday does not independently enter into contracts, make purchases or create legal obligations on behalf of a user.

Unless a separate feature expressly states otherwise, Halvday does not automatically send emails, social messages or other external communications. Generated outreach is provided as a draft for review.

3. AI transparency

Halvday identifies AI-powered interactions and generated content where appropriate.

For example:

• conversational interfaces may be labelled as an AI assistant;
• AI-supported features may use an AI label or icon;
• generated messages may be identified as AI-generated drafts;
• users are informed that generated outputs should be reviewed before use.

Halvday does not present its AI agents as human employees or human representatives.

Where Halvday generates content that will be presented to another person, the Halvday customer remains responsible for determining whether an additional AI disclosure is required for that particular use.

4. Information processed by Halvday AI

Halvday may process several categories of information through AI-powered features.

4.1 Customer Data

Customer Data may include:

• account and workspace configuration;
• ideal customer profiles and targeting criteria;
• user instructions;
• company lists or records submitted by a customer;
• research requests;
• notes, decisions and feedback entered into Halvday;
• connected customer information where a customer has enabled an integration;
• information required to generate a requested output.

Halvday limits the information provided to an AI system to what is reasonably necessary for the relevant function.

4.2 Public Business Information

Halvday researches publicly accessible business information, including information found on:

• company websites;
• public professional profiles;
• public company registers;
• press releases;
• news publications;
• public job advertisements;
• public social-media posts;
• public databases and directories;
• other publicly accessible online sources.

Public accessibility does not guarantee that information is accurate, current or lawful to use for every purpose.

4.3 Generated and inferred information

Halvday may generate or infer information such as:

• account-fit assessments;
• company classifications;
• likely business priorities;
• timing or buying signals;
• possible organisational roles;
• recommended contacts;
• research summaries;
• suggested outreach angles.

Generated or inferred information represents an AI-supported assessment. It should not be treated as a verified fact unless it is supported by reliable evidence.

5. Sources and evidence

Halvday is designed to provide evidence for material research conclusions where reasonably possible.

Research results may include:

• the source from which information was obtained;
• the relevant webpage or publication;
• the date on which information was retrieved;
• an excerpt, summary or description of the supporting evidence.

Some information may be derived from multiple sources. Some sources may become unavailable, change after retrieval or contain inaccurate information.

Halvday may distinguish between:

• directly observed facts;
• third-party claims;
• AI-generated summaries;
• AI-generated inferences;
• recommendations requiring user judgment.

Users should review the underlying evidence before relying on a material conclusion.

6. AI model providers

Halvday uses third-party technology providers to operate certain AI features.

Depending on the feature, configuration and availability, these providers may include:

• OpenAI, for language-model inference, analysis, assistance and drafting;
• Anthropic, for language-model inference, research, analysis, summarisation and drafting;
• Google Cloud Vertex AI, where used to provide or route model inference, including region-controlled model access where configured.

Halvday may change models or providers to improve reliability, security, performance, regional availability or cost efficiency.

The current list of subprocessors, their purposes and relevant processing locations is maintained on Halvday's Subprocessor List. The customer-facing Data Processing Agreement is not yet published; this page will be updated with a link once it is available.

Providers independently connected or configured by a customer are governed by the customer's own agreement with that provider unless Halvday expressly states otherwise.

7. Search and research providers

Halvday may use third-party search, crawling and data-access services to locate or retrieve publicly accessible information.

These services may receive information such as:

• a public webpage URL;
• a company name;
• a public-domain search query;
• an agent-generated research instruction;
• technical information required to retrieve a public source.

Halvday's intended operating model is not to send private customer documents, credentials, private communications or complete customer datasets to public-web search or crawling providers.

Current research providers are disclosed on the Subprocessor List where they qualify as subprocessors.

8. Model training and product improvement

Halvday does not use Customer Data to train a general-purpose AI model.

Halvday selects commercial AI services under terms that restrict providers from using submitted Customer Data to train their general-purpose models, unless a customer knowingly enables a separate feature that clearly states otherwise.

Halvday may use operational information to maintain and improve its service, including:

• user feedback;
• error reports;
• performance information;
• security events;
• usage statistics;
• manually selected and appropriately protected examples.

Where personal data or Customer Data is used for product improvement, Halvday applies the Privacy Policy, contractual commitments and applicable data-protection requirements.

Aggregated or anonymised information may be used to understand product performance where individuals and customers are no longer identifiable.

9. Storage and retention

AI inputs and outputs may be temporarily processed or stored by Halvday and its approved providers where necessary to:

• deliver the requested function;
• maintain conversation or research context;
• investigate errors;
• prevent abuse;
• provide security;
• satisfy legal obligations.

Retention periods differ by data category, provider and product configuration.

Halvday does not promise that all third-party AI providers delete every input within a single universal period. Provider-specific retention terms and configured controls are assessed as part of Halvday's vendor-management process.

Halvday seeks to minimise retention and avoid sending unnecessary personal or confidential information to external models.

10. International processing

Halvday prefers European infrastructure and regional processing where it is available and suitable.

Some technology providers may nevertheless be established outside the European Economic Area or may process limited information outside it.

Where required, Halvday uses recognised data-transfer mechanisms such as:

• an adequacy decision;
• the European Commission's Standard Contractual Clauses;
• supplementary technical and organisational measures;
• another lawful transfer mechanism.

Further information is provided in the Privacy Policy, Data Processing Agreement and Subprocessor List.

11. Accuracy and limitations

AI systems are probabilistic. Their outputs may be incomplete, outdated, misleading or incorrect.

In particular, Halvday may:

• fail to locate relevant public information;
• confuse companies or people with similar names;
• misinterpret a source;
• make an unsupported inference;
• overlook contradictory evidence;
• produce wording that is inappropriate for a particular recipient;
• assign too much or too little relevance to a signal.

Halvday does not guarantee that:

• a researched company will become a customer;
• a person is the correct decision-maker;
• a signal indicates actual buying intent;
• contact details are current;
• generated outreach is legally or commercially appropriate;
• every relevant source has been found.

Users must review significant outputs before using them for commercial decisions or external communication.

12. No legally significant automated decisions

Halvday is not intended to make decisions that produce legal or similarly significant effects concerning a natural person.

Halvday should not be used as the sole basis for decisions concerning:

• employment or recruitment;
• access to education;
• creditworthiness or lending;
• insurance eligibility or pricing;
• healthcare or medical treatment;
• housing;
• public benefits;
• law enforcement;
• immigration or border control;
• legal proceedings;
• biometric identification;
• other sensitive or legally regulated decisions.

Halvday's account scoring and recommendations are designed for business-to-business sales research and prioritisation.

13. Acceptable use of AI

Customers must use Halvday lawfully and responsibly.

Halvday must not be used to:

• deceive people about the identity of a sender;
• impersonate another person without authorisation;
• generate fraudulent or materially misleading communications;
• unlawfully discriminate against individuals or groups;
• infer sensitive personal characteristics without a lawful and legitimate reason;
• manipulate vulnerable people;
• conduct unlawful surveillance;
• create or expand facial-recognition databases;
• make prohibited or high-risk decisions outside Halvday's intended sales-research purpose;
• violate privacy, intellectual-property, confidentiality or communications laws;
• circumvent website security or access restrictions;
• send unlawful spam or unsolicited communications;
• conceal the use of AI where disclosure is legally required.

Customers remain responsible for their communications and for complying with applicable marketing, privacy and electronic-communications laws.

14. Sensitive and confidential information

Users should not submit information to Halvday that is unnecessary for sales research.

In particular, users should avoid entering:

• passwords or authentication credentials;
• payment-card details;
• government identification numbers;
• medical records;
• highly sensitive personal information;
• legally privileged information;
• trade secrets that are not necessary for the requested feature;
• personal information about children;
• information obtained unlawfully.

Where a customer needs Halvday to process confidential information, the customer should ensure that the processing is covered by its agreement with Halvday and that appropriate access controls are used.

15. Personal-data rights

AI-supported research may involve personal data relating to professional contacts.

Depending on the circumstances and applicable law, individuals may have rights to:

• request access to their personal data;
• request correction of inaccurate information;
• request deletion;
• object to certain processing;
• request restriction of processing;
• receive information about the sources and purposes of processing;
• lodge a complaint with a data-protection authority.

Requests can be submitted using the contact details in Halvday's Privacy Policy.

Halvday may need sufficient information to identify the relevant record and verify the request.

16. AI governance

Halvday maintains internal measures intended to support responsible AI use, including:

• an inventory of material AI systems and providers;
• assessment of intended purpose and regulatory risk;
• rules governing which data may be sent to each provider;
• human-oversight requirements;
• provider and model review;
• security and access controls;
• source and evidence handling;
• incident and error management;
• review of significant changes to AI functionality;
• appropriate AI literacy for people operating or developing Halvday.

These measures may be proportionate to the function, data involved and level of risk.

17. Changes to this policy

AI technology and regulation develop quickly.

Halvday may update this policy when:

• new AI features are introduced;
• providers or processing arrangements change;
• legal requirements change;
• additional controls are implemented;
• material risks or limitations are identified.

The current version and its last-updated date will be published on this page.

Where a change materially affects the processing of Customer Data, Halvday will provide notice where required by contract or applicable law.

18. Contact

Questions about Halvday's use of AI, data protection or this policy can be sent to:

SUMOSMASH UG (haftungsbeschränkt)
Trading as Halvday
Berlin, Germany

Privacy and data-protection inquiries:
privacy@halvday.com

Legal inquiries:
legal@halvday.com

Further information:

• Privacy Policy: /privacy
• Terms of Service: /terms
• Subprocessors: /subprocessors (the Data Processing Agreement is not yet published)
• Trust Center: /trust
• Imprint: /imprint