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Legal / Privacy

Privacy Policy

Effective date: 1 September 2026Version: 2.0Contact: jan@halogroup.ch

Sales (sales.halogroup.ch) is a sales workspace for business teams, built and operated by Halo Group. It is a business tool provided to organisations by arrangement, not a consumer product. This policy explains, precisely and without legal padding, what personal data the application processes, why, and what rights you have.

01Data controller

The controller of personal data processed in Sales is Halo Group, Switzerland. For all privacy matters, contact jan@halogroup.ch. We answer data-subject requests within 30 days.

02Whose data and what data we process

CategoryDataSource
Workspace usersName, e-mail address, hashed password or Google sign-in identifier, session and security logs (IP address in hashed form, browser identifier).Provided by the user or their Google account.
Business contactsName, business e-mail address, job title, company, phone number, notes and correspondence history relevant to a commercial relationship.Entered by the team, imported from files, or received in e-mail correspondence.
E-mail contentMessages sent and received through mailboxes that a team member has explicitly connected (Google or Microsoft).The connected mailbox, with the mailbox owner’s consent.
Technical logsOperational events needed to run and secure the service.Generated by the application.

03Google user data — API Services User Data Policy

Sign-in with Google requests only the openid, email and profile scopes. We use them solely to create and recognise your account.

Connected Gmail mailboxes use the gmail.modify, gmail.send and calendar.events scopes. Acting on the mailbox owner’s explicit consent, the application reads and sends messages of that mailbox for exactly one purpose: presenting the team’s correspondence in the shared inbox (Unibox) and sending messages written in the application. When a user explicitly requests an AI-assisted draft, the content of that thread is transmitted to the Google Gemini API solely to produce the draft; it is not used to train general-purpose AI or machine-learning models. Gmail data is never used for advertising, never sold, and never read by humans except (a) with the mailbox owner’s affirmative agreement, (b) for security or abuse investigation, or (c) where required by law.

Sales’ use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

Microsoft mailboxes are handled under the same rules through Microsoft Graph (Mail.ReadWrite, Mail.Send). You can revoke the application’s access at any time at myaccount.google.com/permissions or account.live.com/consent/Manage; revocation stops synchronisation immediately.

04Purposes and legal bases

  • Operating the workspace (accounts, sessions, shared inbox, pipeline) — performance of a contract with the user and Halo Group’s legitimate interest in running its sales operations (GDPR Art. 6(1)(b), (f); Swiss FADP).
  • Business outreach to professional contacts — legitimate interest in business-to-business communication, always with a working way to decline further contact; opt-outs are recorded on a suppression list so the person is not contacted again.
  • Security and abuse prevention (hashed IPs, rate limiting, audit trail) — legitimate interest in protecting the service and its data.

05Subprocessors and transfers

We do not sell personal data. Data is shared only with providers necessary to run the service, each bound by its own data-protection terms:

ProviderPurposeLocation
Hetzner Online GmbHServer hosting of the application and database.European Union (Germany/Finland).
Google (Gmail, Calendar, Gemini APIs)Mailbox synchronisation, calendar events, AI-assisted drafts.EU/USA — EU-U.S. Data Privacy Framework.
Microsoft (Graph API)Synchronisation of connected Microsoft mailboxes.EU/USA — EU-U.S. Data Privacy Framework.

06Security

All traffic is encrypted in transit (TLS). Mailbox credentials and API keys are stored encrypted at rest (AES-256-GCM). Access is limited to authenticated team members; every tenant’s data is isolated at the database level (row-level security keyed to the workspace), sensitive actions are recorded in an append-only audit log, and passwords are stored only as modern salted hashes.

07Retention

Data is kept for as long as the account or business relationship is active. Disconnecting a mailbox stops synchronisation immediately. Deleted records go through a recoverable trash and are then removed by scheduled retention jobs. Security logs are kept no longer than needed for their purpose.

08Your rights

You may request access to, correction, deletion or export of your personal data, restriction of processing, and you may object to processing based on legitimate interest — including business outreach, which we then stop. Write to jan@halogroup.ch. You may also lodge a complaint with your supervisory authority (in Switzerland: the FDPIC).

09Cookies and local storage

Sales uses one strictly necessary session cookie (HttpOnly, Secure, SameSite) to keep you signed in, and the browser’s local storage for interface preferences such as language. There are no advertising or analytics trackers, so there is no cookie banner — there is nothing to consent to.

10Changes

We update this policy when the application’s data processing actually changes; the current version always lives at this address with its effective date above. Material changes are communicated to workspace users inside the application.

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