Privacy Policy

Last Updated: Sep 05, 2024

HALO INTERACTIVE PTE. LTD., along with its subsidiaries and affiliates worldwide,
hereinafter referred to as “Utell,” “we”, “us,” or “our”) provides software and other
technologies specializing in real-time accent filter and voice related services. We are
dedicated to respecting your privacy and preferences. This Privacy Policy (“Policy”)
outlines the collection of Personal Information by Utell and its Affiliates through
www.utell.ai and other websites or applications linking to this Notice. It emphasizes our
privacy practices concerning the Personal Data we gather and handle in accordance with
relevant data privacy regulations.

Please be aware that this Policy does not encompass the handling of Personal
Information when Utell processes it on behalf of its clients. For instance, Personal
Information submitted by individuals for processing through Utell-hosted platforms to
provide services to clients is not covered by this Policy. Typically, our clients act as
Controllers for their relevant Personal Information, including any uploaded by third parties
in connection with our services, while Utell acts as a Processor under applicable Service
and/or data processing agreements (“Agreements”). Specific obligations of Controllers
and Processors can be found in these Agreements.

We encourage you to review this Policy, along with any supplementary and more detailed
information we may provide on various occasions when collecting or processing your
personal information through Utell’s website, products, or applications, as well as events
and initiatives. This will help you understand how and why we process your personal
information.

1. DEFINITIONS
2. SCOPE
3. PERSONAL INFORMATION WE COLLECT
4. HOW WE USE YOUR INFORMATION
5. HOW WE DISCLOSE YOUR INFORMATION
6. LEGAL BASIS FOR PROCESSING
7. YOUR PRIVACY CHOICES
8. YOUR PRIVACY RIGHTS.
9. CONTACT YOUR REGIONAL DATA PROTECTION AUTHORITY.
10. SECURITY OF YOUR INFORMATION
11. INTERNATIONAL DATA TRANSFERS
12. RETENTION OF PERSONAL INFORMATION
13. CHILDREN’S INFORMATION
14. OTHER PROVISIONS
15. CONTACT US

1. DEFINITIONS

Personal Data refers to information that, either on its own or when combined with other
data, allows for the direct or indirect identification of an individual (“Personal Information”
or “Personal Data”).
A Data Controller or Business (“Controller”) is an entity that determines the purposes and
methods of processing Personal Information. A Data Processor, Service Provider,
Contractor, or Third Party (“Processor”or “Third Party”) is an entity that processes
Personal Information on behalf of the Controller.

2. SCOPE

This Policy is designed to help you understand your rights under relevant laws, including
instructions on how to exercise them. It also outlines how we collect, use, process,
disclose, and store Personal Data as a Controller when you:
Interact with or use our website, including but not limited to downloading materials from
our webpages, requesting a demo, or asking us to contact you.
Interact with our software application.
Register for and/or attend our events, conferences, or webinars (individually referred to as
an “Event” or collectively as “Events”).
Provide your Personal Data for administering our services and managing our relationship
with you in any capacity, such as setting up an account or collecting Personal Data to
process invoices for accounting purposes.
Provide your Personal Data for any of our online or offline offerings.
To make this Policy easier to read, our website, software applications, and other offerings
online or offline will collectively be referred to as “Services.”
While this Policy applies globally, specific additional details may pertain to you based on
your country of residence. Such additional terms, tailored to these specific countries or
regions, are outlined in region-specific statements below.

3. PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with us, our
Services, and the requirements of applicable law. For instance, we may collect different
information about you depending on whether you are a customer of our Services
(“Customer”) who downloads our customer- facing software product (“Customer
Software”), or a contributor of vocal sound samples on our web application (“Target
Speaker”). We collect information that you provide to us, information we obtain
automatically when you use our Services, and information from other sources such as
third-party services and organizations, as described below.
A. Information You Provide to Us Directly via our Websites or Events
We may collect the following personal information that you provide to us.
Tester Account Creation
If you agree to provide audio samples for the purpose of improving the Services, you will
be assigned a Group ID, and we may collect your full name, gender, age range, and
accent.
Vocal Samples. As a Tester, you will need to provide access to a microphone to use the
web application. The application will then collect recordings of your voice speaking certain
words and phrases.
Note: although we do collect vocal samples from Testers and tie these samples tied
individual Tester profiles for our internal purposes, we only use this information to improve
our Services, and do not derive a voice print or any other information that could be used to
identify you from your vocal data.
Customer Account Creation
To create an account to use the Customer software, we may collect information about you,
such as your full name, email address, password, and the name of your business if
applicable.
Purchases.
We may collect personal information and details associated with your purchases,
including payment information. Any payments made via our Services are processed by
third-party payment processors. We do not directly collect or store any payment card
information entered through our Services, but we may receive information associated with
your payment card information (e.g., your billing details).
Your Communications with Us.
We may collect personal information, such as email address, phone number, or mailing
address when you request information about our Services, register for our newsletter,
request customer or technical support, apply for a job, or otherwise communicate with us.
Surveys
We may contact you to participate in surveys. If you decide to participate, you may be
asked to provide certain information which may include personal information.
Interactive Features
We and others who use our Services may collect personal information that you submit or
make available through our interactive features (e.g., messaging and chat features,
commenting functionalities, forums, blogs, and social media pages). Any information you
provide using the public sharing features of the Services (referred to herein as “User
Content”) will be considered “public,” unless otherwise required by applicable law, and is
not subject to the privacy protections referenced herein.
Conferences, Trade Shows, and Other Events
We may collect personal information such as audio-visual information, photographs or
images captured, video recordings (if enabled) from individuals when we attend
conferences, webinars, trade shows, and other events.
Business Development and Strategic Partnerships
We may collect personal information from individuals and third parties to assess and
pursue potential business opportunities.
Job Applications
We may post job openings and opportunities on our Services. If you reply to one of these
postings by submitting your application, CV and/or cover letter to us, we will collect and
use your information to assess your qualifications.
Feedback
We may collect queries, comments, or feedback as submitted by you, including any
correspondence you have made with us.
B. Information Collected Automatically
We may collect personal information automatically when you use our Services:
Automatic Data Collection
We may collect certain information automatically when you use our Services, such as your
Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile
carrier, mobile advertising and other unique identifiers, browser or device information,
location information (including approximate location derived from IP address), and
Internet service provider. We may also automatically collect information regarding your
use of our Services, such as pages that you visit before, during and after using our
Services, information about the links you click, the types of content you interact with, the
frequency and duration of your activities, and other information about how you use our
Services.
Data collection from the Customer Software.
Please note that by default, we do not collect voice recordings from the Customer
Software. We may however collect diagnostic or other usage information related to your
use of the Customer Software, such as to verify your purchases, ensure you are billed
correctly, or to troubleshoot errors with customer support.
Cookies, Pixel Tags/Web Beacons, and Other Technologies.
We, as well as third parties that provide content, advertising, or other functionality on our
Services, may use cookies, pixel tags, local storage, and other technologies
(“Technologies”) to automatically collect information through your use of our Services.
Cookies
Cookies are small text files placed in device browsers that store preferences and facilitate
and enhance your experience
Pixel Tags/Web Beacons.
A pixel tag (also known as a web beacon) is a piece of code embedded in our Services
that collects information about engagement on our Services. The use of a pixel tag allows
us to record, for example, that a user has visited a particular web page or clicked on a
particular advertisement. We may also include web beacons in e-mails to understand
whether messages have been opened, acted on, or forwarded.
Our uses of these Technologies fall into the following general categories:
Operationally Necessary
This includes Technologies that allow you access to our Services, applications, and tools
that are required to identify irregular website behavior, prevent fraudulent activity and
improve security or that allow you to make use of our functionality.
Performance-Related
We may use Technologies to assess the performance of our Services, including as part of
our analytic practices to help us understand how individuals use our Services (see
Analytics below).
Functionality-Related.
We may use Technologies that allow us to offer you enhanced functionality when
accessing or using our Services. This may include identifying you when you sign into our
Services or keeping track of your specified preferences, interests, or past items viewed.
See “Your Privacy Choices and Rights” below to understand your choices regarding these
Technologies.
Analytics
We may use Technologies and other third-party tools to process analytics information on
our Services. Some of our analytics partners include Google Analytics. For more
information, please visit Google Analytics’ Privacy Policy. To learn more about how to
opt-out of Google Analytics’ use of your information, please click here
Biometric Information.
While we do not currently collect any information that can be used on its own to identify
any particular speaker, we may collect this information from Target Speakers in the future.
If you consent to our collection of biometric information or if our collection of biometric
information is otherwise permitted, you agree that we may collect your voice data
C. Information Collected from Other Sources
We may obtain information about you from other sources, including through third-party
services and organizations. For example, if you access our Services through a third-party
application, such as an app store, a third-party login service, or a social networking site,
we may collect information about you from that third-party application that you have made
available via your privacy settings.

4. HOW WE USE YOUR INFORMATION

We use your information for a variety of business purposes, including to provide our
Services, for administrative purposes, and to market our products and Services, as
described below.
A. Provide Our Services
We use your information to fulfil our contract with you and provide you with our Services,
such as:
Managing your information and accounts.
Providing access to certain areas, functionalities, and features of our Services.
Providing better usability, troubleshooting and site maintenance.
Understanding which parts of the website are visited and how frequently.
Answering requests for customer or technical support.
Communicating with you about your account, activities on our Services, and policy
changes.
Processing your financial information and other payment methods for products or
Services purchased.
Facilitating communication with you, including contacting you and responding to your
queries.
Processing applications if you apply for a job we post on our Services; and
Allowing you to register for events.
B. Administrative Purposes
We use your information for various administrative purposes, such as:
Pursuing our legitimate interests such as direct marketing, research and development
(including marketing research), network and information security, and fraud prevention.
Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal
activity, and prosecuting those responsible for that activity.
Measuring interest and engagement in our Services.
Short-term, transient use, such as contextual customization of ads.
Improving, upgrading or enhancing our Services.
Developing new products and Services.
Ensuring internal quality control and safety.
Authenticating and verifying individual identities, including requests to exercise your rights
under this policy.
Auditing relating to interactions, transactions and other compliance activities.
Sharing information with third parties as needed to provide the Services.
Enforcing our agreements and policies; and
Complying with our legal obligations.
C. Marketing and Advertising our Products and Services
We may use personal information to
Tailor and provide you with content and advertisements for our Services. We may provide
you with these materials as permitted by applicable law.
Invite you for events, seminars and equivalent ceremonies organized by us and related
purposes such as running marketing or promotional campaigns, including such
promotions or publications on social media.
Publish testimonials and case studies.
Generate and maintain leads as part of our Customer Relationship Management
database
Some of the ways we market to you include email campaigns and custom audiences
advertising.
If you have any questions about our marketing practices, you may contact us at any time
as set forth in “Contact Us” below.
D. Other Purposes
We also use your information for other purposes as requested by you or as permitted by
applicable law.
Consent
We may use personal information for other purposes that are clearly disclosed to you at
the time you provide personal information or with your consent.
Automated Decision Making.
We may engage in automated decision making, such as to improve our AI algorithm using
voice samples uploaded by Target Speakers. Utell’s processing of your personal
information will not result in a decision based solely on automated processing that
significantly affects you unless such a decision is necessary as part of a contract we have
with you, we have your consent, or we are permitted by law to engage in such automated
decision making. If you have questions about our automated decision making, you may
contact us as set forth in “Contact Us” below.
De-identified and Aggregated Information
We may use personal information and other information about you to create de-identified
and/or aggregated information, such as de-identified demographic information,
information about the device from which you access our Services, or other analyses we
create
Share Content with Friends or Colleagues
Our Services may offer various tools and functionalities. For example, we may allow you
to provide information about your friends through our referral services. Our referral
services may allow you to forward or share certain content with a friend or colleague, such
as an email inviting your friend to use our Services. Please only share with us contact
information of people with whom you have a relationship (e.g., relative, friend neighbor, or
co-worker).

5. HOW WE DISCLOSE YOUR INFORMATION

We disclose your information to third parties for a variety of business purposes, including
to provide our Services, to protect us or others, or in the event of a major business
transaction such as a merger, sale, or asset transfer, as described below.
A. Disclosures to Provide our Services
The categories of third parties with whom we may share your information are described
below.
Service Providers
We may share your personal information with our third-party service providers who use
that information to help us provide our Services. This includes service providers that
provide us with IT support, hosting, payment processing, customer service, and related
services.
Business Partners.
We may share your personal information with business partners to provide you with a
product or service you have requested. We may also share your personal information to
business partners with whom we jointly offer products or services.
Affiliates
We may share your personal information with our company affiliates for our administrative
purposes, including activities such as IT management, for them to provide services to you
or support and supplement the Services we provide.
APIs/SDKs
We may use third-party Application Program Interfaces (“APIs”) and Software
Development Kits (“SDKs”) as part of the functionality of our Services. For more
information about our use of APIs and SDKs, please contact us as set forth in “Contact Us”
below.
B. Disclosures to Protect Us or Others
We may access, preserve, and disclose any information we store associated with you to
external parties if we, in good faith, believe doing so is required or appropriate to: comply
with law enforcement or national security requests and legal process, such as a court
order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our
policies or contracts; collect amounts owed to us; or assist with an investigation or
prosecution of suspected or actual illegal activity.
C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers
If we are involved in a merger, acquisition, financing due diligence, reorganization,
bankruptcy, receivership, purchase or sale of assets, or transition of service to another
provider, your information may be sold or transferred as part of such a transaction, as
permitted by law and/or contract.

6. LEGAL BASIS FOR PROCESSING

Privacy and data protection laws outline specific justifiable grounds for collecting and
processing Personal Data, commonly known as the legal basis of processing. Our primary
reliance is on the following legal bases:
We process your Personal Data when it's necessary for fulfilling a contract you're a party
to or to take pre-contractual steps at your request. For instance, when engaging with us to
receive services or managing employee data to ensure compliance with their employment
contract.
We process your Personal Information when it's necessary for legitimate interests
pursued by us or a third party, provided these interests do not override your data
protection rights. This includes understanding your website usage, generating secure
login credentials, or optimizing our processes.
We process your Personal Information with your consent, which you can revoke at any
time. For instance, when registering for events organized by us or receiving marketing
communications from us.
We may process your Personal Information to comply with legal obligations, including
applicable laws and safeguarding our legal rights, seeking remedies, and defending
against claims.

7. YOUR PRIVACY CHOICES

The privacy choices you may have about your personal information are determined by
applicable law and are described below.
Email Communications.
If you receive an unwanted email from us, you can use the unsubscribe link found at the
bottom of the email to opt out of receiving future emails. Note that you will continue to
receive transaction-related emails regarding products or Services you have requested.
We may also send you certain non-promotional communications regarding us and our
Services, and you will not be able to opt out of those communications (e.g.,
communications regarding our Services or updates to our Terms or this Privacy Policy).
California and Delaware “Do Not Track.”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers.
Privacy regulations in the United States, such as the laws of California and Delaware,
require Utell to indicate whether it honors your browser’s “Do Not Track” settings
concerning targeted advertising. Utell adheres to the standards set out in this Notice and
does not monitor or respond to Do Not Track browser requests.regarding us and our
Services, and you will not be able to opt out of those communications (e.g.,
communications regarding our Services or updates to our Terms or this Privacy Policy).

8. YOUR PRIVACY RIGHTS

In accordance with applicable law, you may have the right to:
Access Personal
Information about you, including: (i) confirming whether we are processing your personal
information; (ii) obtaining access to or a copy of your personal information in a structured,
commonly used, and machine readable format; and (iii) receiving an electronic copy of
personal information that you have provided to us, or asking us to send that information to
another company in a structured, commonly used, and machine readable format (the
“right of data portability”);
Request Correction
Request Correction of your personal information where it is inaccurate or incomplete.
(Note: In some cases, we may provide self-service tools that enable you to update your
personal information);
Request Deletion
Request Deletion of your personal information;
Request Restriction
Request Restriction of or Object to our processing of your personal information including
where the processing of your personal information is based on our legitimate interest or
for direct marketing purposes; and
Withdraw your Consent
Withdraw your Consent to our processing of your personal information
If you would like to exercise any of these rights, please contact us as set forth in “Contact
Us” below. We will process such requests in accordance with applicable laws.
Should you desire an authorized agent to make a privacy rights request on your behalf,
the agent may do so by contacting us as set forth in “Contact Us” below. We will require
written, signed permission indicating that the agent has been duly authorized to act on
your behalf. Upon receipt of the written authorization, we will review the privacy rights
request and respond accordingly. We will directly correspond with the e-mail address
provided by the authorized agent.

9. CONTACT YOUR REGIONAL DATA PROTECTION AUTHORITY.

If you're dissatisfied with our handling of your Personal Data, you may have the right, as
per the laws of your residing country, to lodge a complaint with your regional data
protection authority.

10. SECURITY OF YOUR INFORMATION

At Utell, there exists a perfect balance between Governance, Process and Technology,
the combination of which has established Utell's commitment to its customers and
stakeholders. Utell adopts reasonable and appropriate security controls, practices and
procedures including administrative, physical security, and technical controls in order to
safeguard your Personal Data. We take steps to ensure that your information is treated
securely and in accordance with this Privacy Policy. Unfortunately, no system is 100%
secure, and we cannot ensure or warrant the security of any information you provide to us.
We have taken appropriate safeguards to require that your personal information will
remain protected and require our third-party service providers and partners to have
appropriate safeguards as well. To the fullest extent permitted by applicable law, we do
not accept liability for unauthorized disclosure.
By using our Services or providing personal information to us, you agree that we may
communicate with you electronically regarding security, privacy, and administrative issues
relating to your use of our Services. If we learn of a security system’s breach, we may
attempt to notify you electronically by posting a notice on our Services, by mail or by
sending an email to you.

11. INTERNATIONAL DATA TRANSFERS

All information processed by us may be transferred, processed, and stored anywhere in
the world, including, but not limited to, the United States or other countries, which may
have data protection laws that are different from the laws where you live. We endeavor to
safeguard your information consistent with the requirements of applicable laws. Utell
operates on a global scale. As a result, the Personal Data of individuals who visit our
websites, use our services, or engage with us in any way may be transferred and
accessed worldwide, including countries where Utell, our affiliates, or processors operate.
Regardless of where it is processed, we will safeguard your Personal Data in accordance
with this policy. Utell does not willingly or proactively transfer or disclose our customers'
Personal Data to government or law enforcement authorities (“Authorities”) or grant
Authorities access to your Personal Data.

12. RETENTION OF PERSONAL INFORMATION

We retain your Personal Data for varying durations depending on the category of Personal
Data and your relationship with us. The duration is determined on a case-by-case basis,
with our aim being to keep it for the shortest period necessary to fulfill the purpose for
which it was collected. When deciding on retention periods, we consider the following
criteria:
The type of Personal Information.
Whether the Personal Information is typically subject to specific deletion schedules, such
as marketing data.
Whether the Personal Information is essential for operating or providing our services; for
instance, account information may be retained longer based on your agreement with us.
The duration required to comply with legal obligations.
Our legitimate interests or legal purposes, including network improvement, fraud
prevention, record-keeping, safety promotion, security and integrity maintenance, or
enforcing our legal rights.

13. CHILDREN’S INFORMATION

The Services are not directed to users under 18, and we do not knowingly collect personal
information from children. If you are a parent or guardian and believe your child has
uploaded personal information to our site without your consent, you may contact us as
described in “Contact Us” below. If we become aware that a child has provided us with
personal information in violation of applicable law, we will delete any personal information
we have collected, unless we have a legal obligation to keep it, and terminate the child’s
account if applicable.

14. OTHER PROVISIONS

Third-Party Websites/Applications.
The Services may contain links to other websites/applications and other
websites/applications may reference or link to our Services. These third-party services are
not controlled by us. We encourage our users to read the privacy policies of each website
and application with which they interact. We do not endorse, screen or approve, and are
not responsible for, the privacy practices or content of such other websites or applications.
Providing personal information to third-party websites or applications is at your own risk.
For your convenience, hyperlinks may be posted on the Websites that link to other
websites (“Linked Sites”). We are not responsible for, and this Notice does not apply to,
the privacy practices of any Linked Sites or of any companies that we do not own or
control. Linked Sites may collect information in addition to that which we collect on the
Websites. We do not endorse any of these Linked Sites, the services or products
described or offered on such Linked Sites, or any of the content contained on the Linked
Sites. We encourage you to seek out and read each Linked Site’s privacy notice to
understand how the Personal Information about you is used and protected.
Supervisory Authority.
If you are located in the European Economic Area, Switzerland, the United Kingdom or
Brazil, you have the right to lodge a complaint with a supervisory authority if you believe
our processing of your personal information violates applicable law.
Changes to our Privacy Policy.
We are constantly trying to improve our Websites and Services, so we may revise this
Privacy Policy from time to time in our sole discretion. If there are any material changes to
this Privacy Policy, we will notify you as required by applicable law. You understand and
agree that you will be deemed to have accepted the updated Privacy Policy if you
continue to use our Services after the new Privacy Policy takes effect. You are
responsible for periodically reviewing this Privacy Policy.

15. CONTACT US

If you have any questions about our privacy practices or this Privacy Policy, or to exercise
your rights as detailed in this Privacy Policy, please contact us at:
[email protected]