# Privacy Policy

> How Talt AI handles personal information on halqora.com and in the Halqora service, including student and family data that academies store in Halqora.

URL: https://halqora.com/privacy

Effective October 22, 2026

## Who we are

Halqora is academy management software for online academies: scheduling, a built-in classroom, billing and teacher payroll. Halqora is a product of Talt AI LLC ("Talt AI", "we", "us"), a company based in the United States. Our address is 30 N Gould St, Sheridan, WY 82801, USA.

This policy explains what personal information we handle when you visit halqora.com, ask us for a demo, or use the Halqora service, and the choices you have. It does not cover the separate privacy practices of the academies that use Halqora.

## Our role and the academy's role

**Academies are in charge of their data.** When an academy uses Halqora, it decides which students, families and teachers to add and what to record about them. For that information (we call it *Customer Data*) the academy is the controller (or "business") and Talt AI is its processor (or "service provider"). We process Customer Data only to provide the service, on the academy's instructions and under our agreement with the academy.

If you are a student, a parent or a teacher at an academy that uses Halqora, please contact your academy first about your information. We will help the academy respond, and we will pass on any request we receive directly.

**We are the controller** for information about visitors to halqora.com, people who request a demo or contact us, and the account and billing details of our customers.

## Information we collect

### On halqora.com

- **Demo requests and emails:** your name, work email, academy name, academy size, number of teachers, the tools you use today and anything you choose to tell us.
- **Technical data:** our hosting provider processes standard request data such as IP address, browser type and the pages requested, to deliver the site, prevent abuse and keep it secure. We do not use this data to build profiles of visitors.

### In the Halqora service

- **Account data:** names, email addresses, roles and sign-in details of the academy's owners, admins and teachers.
- **Customer Data the academy adds:** student and family names and contact details, time zones, schedules, class outcomes and lateness, teacher reports, class chat messages, invoices, balances and payment status, teacher pay rates and payroll, and any files (such as PDF books) the academy uploads.
- **Classroom data:** live audio, video, screen share and whiteboard content are transmitted so the class can take place. Halqora does not record class video or audio. We log when each person joins and leaves a session. An admin can observe a class, and camera and microphone are shown only where the academy has recorded consent.
- **Payment information:** families pay through the academy's own payment providers (such as PayPal, Stripe, Mercury or Wise). Halqora reads payment status and references from the accounts the academy connects so it can match payments to invoices. We never receive or store full card numbers.
- **Messages:** if the academy pairs its own WhatsApp number, Halqora sends invoice messages and payment follow-ups from that number. Email invoices and reminders are sent on the academy's behalf.
- **Customer billing data:** the contact and billing details we need to invoice an academy for its Halqora subscription. Subscription fees are invoiced and paid outside the app.

## How we use information

- To provide, maintain and secure the service, and to support academies that use it (performance of a contract; for Customer Data, on the academy's instructions).
- To answer demo requests and questions, and to send information about Halqora you asked for (our legitimate interest in responding to you, or your consent where the law requires it). You can opt out of marketing email at any time.
- To bill customers, keep business records and meet legal obligations (legal obligation and contract).
- To protect the service and its users, prevent abuse and enforce our Terms (legitimate interests).

We do not sell personal information, we do not use Customer Data for advertising, and we do not use Customer Data to train artificial intelligence models.

## Children and students

Many students taught through Halqora are under 18, and some are under 13. Halqora is a tool for academies; it is not directed to children, and children do not create accounts. Students join classes through private links issued by their academy.

The academy is responsible for having a lawful basis to use Halqora with its students, including obtaining verifiable parental consent where the US Children's Online Privacy Protection Act (COPPA), the GDPR or UK GDPR (including the age of digital consent in the student's country) or similar laws require it, and for consents to observation and camera use in class. Where an academy relies on school-authorised consent, it does so for the educational purpose of its classes only. We process children's information only to provide the service to the academy, never for advertising or profiling.

Parents can ask their academy to review, correct or delete their child's information, or contact us at [support@halqora.com](mailto:support@halqora.com) and we will work with the academy to respond. If you believe we hold a child's information outside an academy's account, contact us and we will delete it.

## Cookies and similar technologies

halqora.com does not set cookies and does not use analytics, advertising or tracking technologies. Our fonts and images are served from our own site.

The Halqora app uses strictly necessary cookies to keep academy staff signed in and secure. Students and families using private class and invoice links do not need an account. We do not use advertising cookies in the app. If this changes, we will update this policy and ask for consent where the law requires it.

## Sharing and sub-processors

We share personal information only as described here:

- **Sub-processors** that help us run Halqora, under contracts that require them to protect the information and use it only to provide their service to us. The categories are: cloud hosting, database and file storage; website hosting and network security; email delivery; and real-time audio and video infrastructure for the classroom.
- **Services the academy connects**, such as its payment providers, Google Meet if it chooses to use Meet links, and WhatsApp for the number it pairs. These are the academy's own accounts and their own terms and privacy policies apply.
- **Legal and safety reasons**, when we must respond to a valid legal request, or to protect the rights, safety and property of our users, the public or Talt AI.
- **Business transfers**, if Talt AI is involved in a merger, acquisition or sale of assets, subject to this policy.

Customers can request our current list of sub-processors and a data processing agreement by emailing [support@halqora.com](mailto:support@halqora.com).

## International transfers

Talt AI is based in the United States, and our providers may process information in the United States and other countries. Academies, students and teachers using Halqora are often in many countries. Where we transfer personal information from the European Economic Area, the United Kingdom or Switzerland, we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses and the UK addendum.

## How long we keep information

- **Customer Data** is kept for as long as the academy uses Halqora. After a subscription ends, the academy can export its data for 30 days; we then delete Customer Data from our live systems within 60 days, and from backups as they rotate out. An academy can ask us to delete data sooner.
- **Demo requests and correspondence** are kept for up to 24 months after our last contact, unless you become a customer or ask us to delete them sooner.
- **Billing and tax records** are kept for as long as the law requires.

## Security

We protect information with encryption in transit, access controls based on each user's role, and limited staff access on a need-to-know basis. No system is perfectly secure; if we become aware of a security incident affecting Customer Data, we will notify the affected academy without undue delay and help it meet its own obligations.

## Your rights

Depending on where you live, you may have the right to access, correct, delete or export your personal information, to object to or restrict certain processing, and to withdraw consent. In the European Economic Area and the United Kingdom you also have the right to complain to your data protection authority.

If your information is in an academy's Halqora account, please make your request to the academy, which controls that data. For information we control, email [support@halqora.com](mailto:support@halqora.com). We will verify the request and respond within the time the law requires (usually within 30 or 45 days). We will not discriminate against you for exercising your rights.

## Additional notice for US residents

This section applies to residents of California and other US states with consumer privacy laws. In the last 12 months we collected the categories of information described above (identifiers, commercial information, internet activity on our site, and professional information about academy staff) for the purposes described above. We do not sell or share personal information for cross-context behavioural advertising, and we do not knowingly sell or share the personal information of consumers under 16. We do not use sensitive personal information to infer characteristics about you. You or an authorised agent can exercise your rights by emailing [support@halqora.com](mailto:support@halqora.com).

## Changes to this policy

We will post any changes on this page and update the effective date. If a change is material, we will tell customers by email at least 30 days before it takes effect.

## Contact us

Questions or requests about privacy: [support@halqora.com](mailto:support@halqora.com).

Post: Talt AI LLC, 30 N Gould St, Sheridan, WY 82801, USA.
