Privacy Policy

Last updated: February 10, 2026

1. Data Controller

Sumosmash UG (haftungsbeschränkt)
Operating as: HALVDAY (halvday.com)
Seydelstr. 12
10117 Berlin, Germany
Email: hello@halvday.com

For statutory company details, see the Impressum.

2. Information We Collect

2.1 Information You Provide

  • Contact information (name, email, phone, company)
  • Project details and requirements
  • Payment and billing information
  • Communications with our team

2.2 Information Collected Automatically

  • IP address and device data
  • Browser type, operating system, and version
  • Pages visited and time spent on website
  • Referring website addresses

2.3 Cookies and Tracking

We use cookies and similar technologies for: Essential — required for site functionality and security; Analytics — Google Analytics, PostHog (only with your consent); Marketing — LinkedIn Insight Tag (only with your consent).

Our consent banner displays "Accept all" and "Reject all" buttons with equal prominence. You can change preferences anytime via the "Cookie settings" link in the footer.

3. Legal Bases for Processing

Processing occurs under GDPR Article 6 based on:

  • Contract performance — service delivery and fulfilling agreements
  • Legitimate interests — business operations, security, service improvement
  • Consent — analytics, marketing, optional activities
  • Legal obligations — tax, accounting, regulatory compliance

4. How We Use Your Information

  • Providing and managing HALVDAY services
  • Communicating about projects and support
  • Processing payments and billing
  • Sending service updates and transactional notifications
  • Improving services and developing new features
  • Complying with legal requirements and protecting rights
  • Sending marketing communications (consent required)

We assess any government or law-enforcement request for data for legality and proportionality. We do not use automated decision-making or profiling that produces legal or similarly significant effects.

5. Data Sharing and Disclosure

We do not sell your personal data. We share data only with trusted processors and as legally required:

  • Google Ireland Ltd. — Website analytics (Google Analytics)
  • PostHog Inc. — Product analytics
  • LinkedIn Ireland Unlimited Company — Marketing analytics (Insight Tag)
  • Stripe Payments Europe Ltd. — Payment processing
  • Vercel Inc. — Hosting and infrastructure

All processors are bound by GDPR-compliant contracts and safeguard your data appropriately.

6. International Data Transfers

For data processed outside EU/EEA, protection is ensured through:

  • EU Standard Contractual Clauses (SCCs)
  • EU adequacy decisions (UK, Japan)
  • EU–US Data Privacy Framework (DPF) for certified US companies

7. Data Security

Technical and organizational measures include:

  • Encryption of data in transit and at rest
  • Pseudonymisation where possible
  • Access controls and authentication mechanisms
  • Regular security reviews and employee training

8. Data Retention

  • Project data: Project duration + 3 years
  • Financial records: 10 years (required by German law)
  • Marketing data: Until consent withdrawal
  • Website analytics: Up to 26 months

We review retention periods regularly and delete or anonymize data when no longer needed.

9. Your Rights Under GDPR

  • Access — Request a copy of your data
  • Rectification — Correct inaccurate or incomplete data
  • Erasure — Request deletion ("right to be forgotten")
  • Restriction — Limit processing
  • Portability — Receive data in portable format
  • Objection — Object to processing, including direct marketing
  • Withdraw consent — Withdraw previously given consent

To exercise rights, contact: hello@halvday.com

You may lodge a complaint with your local supervisory authority.

Berlin Authority:

Berliner Beauftragte für Datenschutz und Informationsfreiheit
Alt-Moabit 59–61, 10555 Berlin
Email: mailbox@datenschutz-berlin.de

10. Children's Privacy

Our services are not directed at individuals under 16 years old. We do not knowingly collect data from children under 16.

11. Updates to This Policy

We may update this Privacy Policy from time to time. Significant changes will be notified via our website or email.

12. Contact

Sumosmash UG (haftungsbeschränkt)
Email: hello@halvday.com

v1/v2