HALONOVA AI Translator Privacy Policy
Version V1.0 Publication date: October 21, 2026 Effective date: October 21, 2026
Applies to real-time translation, Calling Service, AI Service, AI Knowledge Base, and hotel operations functions
This Policy explains how HALONOVA AI Translator collects, uses, shares, retains, and deletes personal information in personal translation, calling, hotel services, work orders, conversation summaries, and optional model training. We manage core services, hotel operations, and model training as separate processing purposes.
Your key choices You may choose to retain recordings for 90 days or use a mode that does not retain recordings. Model training is off by default; declining or withdrawing does not affect real-time translation, calling, or basic hotel services.
Information that must be completed before publication
The following information is necessary to provide effective notice of the entities processing data, rights requests, and cross-border processing. If any item remains incomplete, this document must not be published externally or used to obtain user consent.
| Item | Information to be confirmed |
|---|---|
| Operating entity | [MUST BE COMPLETED BEFORE PUBLICATION: full legal company name] |
| Registered address | [MUST BE COMPLETED BEFORE PUBLICATION: registered address] |
| Privacy contact | [MUST BE COMPLETED BEFORE PUBLICATION: responsible person or data protection contact] |
| Rights request email | [MUST BE COMPLETED BEFORE PUBLICATION: email address] |
| Storage location in Thailand | [MUST BE COMPLETED BEFORE PUBLICATION: data center region and provider] |
| Subprocessors | [MUST BE COMPLETED BEFORE PUBLICATION: list of legal names and data regions] |
1 Scope and processing entities
1.1 This Policy applies to personal information processing carried out through HALONOVA AI Translator devices, companion applications, the hotel staff workbench, the administration console, and cloud interfaces.
1.2 For hotel services, work orders, quality checks, dispute handling, and operational reports, the hotel generally determines the processing purposes, and HALONOVA provides technical services as an entrusted processor.
1.3 For model training separately chosen by users, HALONOVA independently determines the scope and methods of processing for that purpose and is responsible for notices, consent, withdrawal, security, and responses to rights requests.
2 Information we process
The table below lists the purposes, legal bases, processing roles, retention periods, recipients, storage regions, and rights channels for each data category.
| Data category | Processing details |
|---|---|
| Voice and recordings | Specific content: real-time voice streams in conversations or calls; original recordings where retention is selected. Purposes: real-time recognition, translation, captions, and calling; optional quality checks, report verification, and dispute handling. Legal basis: fulfilling user requests; a separate choice or consent for recording retention as required by applicable law. Processing roles: the hotel determines service operations, quality check, and dispute purposes, and HALONOVA processes data on instructions; HALONOVA is independently responsible for the training purpose. Retention: real-time processing or a maximum of 90 days. Recipients: authorized hotel staff, HALONOVA, and speech recognition and real-time communications providers identified by legal name. Storage region: Thailand by default; separate disclosure before cross-border processing. Rights channels: the device interface, the hotel, or [RIGHTS REQUEST EMAIL]. |
| Transcripts and translations | Specific content: source text, translated text, language pairs, speaker labels, and translation status. Purposes: completing translation, providing services, following up work orders, handling complaints, and creating reports. Legal basis: providing accommodation or hotel services, or another applicable basis confirmed by the hotel; separate consent for training. Processing roles: the hotel determines processing for service operations, and HALONOVA is the entrusted processor; HALONOVA is independently responsible for the training purpose. Retention: no longer than 1 year. Recipients: authorized hotel staff who need the data to handle services, HALONOVA, and translation providers identified by legal name. Storage region: Thailand by default; separate disclosure before cross-border processing. Rights channels: the device interface, the hotel, or [RIGHTS REQUEST EMAIL]. |
| Conversation and call metadata | Specific content: device, room, or calling endpoint identifiers, time, duration, language, connection, and status. Purposes: connecting calls, maintaining security, billing, fault diagnosis, and business records. Legal basis: providing services, lawful operations, and security obligations. Processing roles: the hotel and HALONOVA bear responsibility for the processing stages each determines. Retention: limited to periods necessary for business and required by law. Recipients: authorized hotel personnel, HALONOVA, and cloud and communications providers identified by legal name. Storage region: Thailand by default; separate disclosure before cross-border processing. Rights channels: the hotel or [RIGHTS REQUEST EMAIL]. |
| Hotel service data | Specific content: room numbers, service requests, work orders, replies, handling status, activity registrations, and handover records. Purposes: providing hotel services and the staff workbench. Legal basis: performing accommodation or hotel service contracts, or another applicable basis confirmed by the hotel. Processing roles: the hotel determines processing, and HALONOVA is the entrusted processor. Retention: according to hotel configuration and applicable law, subject to the disclosed maximum periods. Recipients: authorized hotel staff who need the data to handle services, HALONOVA, and hosting providers identified by legal name. Storage region: Thailand by default; separate disclosure before cross-border processing. Rights channels: the hotel or [RIGHTS REQUEST EMAIL]. |
| Hotel reports | Specific content: topics, counts, trends, risks, action items, and de-identified summaries. Purposes: hotel quality management, allocation of service resources, and daily and weekly reports. Legal basis: an applicable basis necessary for hotel management and service improvement; separate confirmation for displays that identify individuals. Processing roles: the hotel determines processing, and HALONOVA is the entrusted processor. Retention: reports that are de-identified by default are retained for no longer than 2 years. Recipients: authorized hotel management and HALONOVA operations personnel. Storage region: Thailand by default; separate disclosure before cross-border processing. Rights channels: the hotel or [RIGHTS REQUEST EMAIL]. |
| Accounts and permissions | Specific content: staff accounts, roles, organizations, permissions, and login records. Purposes: authentication, access control, auditing, and security. Legal basis: performing organizational customer contracts, lawful operations, and security obligations. Processing roles: the hotel manages its staff accounts, while HALONOVA provides the permissions system and processes data as agreed. Retention: the active lifetime of the account and the necessary audit period. Recipients: hotel administrators, HALONOVA security and operations personnel, and identity or hosting providers identified by legal name. Storage region: Thailand by default; separate disclosure before cross-border processing. Rights channels: the hotel administrator or [RIGHTS REQUEST EMAIL]. |
| Consent and withdrawal records | Specific content: notice version, language, time, device, user role, recording retention choice, training choice, and withdrawal status. Purposes: documenting user choices, implementing withdrawal, and auditing compliance. Legal basis: fulfilling consent management and evidentiary obligations. Processing roles: the hotel is responsible for service operations choices; HALONOVA is responsible for training choices and system evidence. Retention: the period during which consent is valid and the necessary limitation period for disputes. Recipients: hotel compliance personnel and HALONOVA compliance and security personnel. Storage region: Thailand by default; separate disclosure before cross-border processing. Rights channels: the device interface, the hotel, or [RIGHTS REQUEST EMAIL]. |
| Security and operations data | Specific content: IP addresses, versions, device status, error codes, operation logs, and security incident records. Purposes: stability, security, troubleshooting, abuse prevention, and fulfilling legal obligations. Legal basis: lawful operations, security, and statutory obligations. Processing roles: each party is responsible for the security processing it determines. Retention: according to risks and statutory periods; data collection for debugging must not become routine business retention. Recipients: HALONOVA security and operations personnel, authorized hotel administrators, and security providers identified by legal name. Storage region: Thailand by default; separate disclosure before cross-border processing. Rights channels: the hotel or [RIGHTS REQUEST EMAIL]. |
3 Processing purposes and legal bases
| Processing purpose | Primary basis | Processing roles |
|---|---|---|
| Providing real-time translation and calling | Providing services requested by the user; obtaining consent where required | HALONOVA and the hotel are responsible for the stages each determines |
| Retaining original recordings for 90 days | Separate notice on the device interface and a choice made by the user | The hotel determines quality check and dispute purposes; HALONOVA processes data on instructions |
| Retaining transcripts and translations and providing hotel services | Necessary to perform accommodation or hotel service contracts, or another basis determined by the hotel under local law | The hotel determines processing; HALONOVA is the entrusted processor |
| Creating de-identified daily and weekly reports | A basis necessary for hotel management and service improvement; separate confirmation where individuals are identified | The hotel determines processing; HALONOVA is the entrusted processor |
| Internal model training | The end user's separate, voluntary, and explicit consent | HALONOVA is independently responsible for the training purpose |
| Security and legal obligations | Fulfilling statutory obligations, protecting personal and property safety, or another applicable basis | Each party is responsible for the processing it determines |
4 Recordings and no-retention mode
4.1 When recording retention is selected, original recordings are retained for no longer than 90 days from the start of the conversation or call and may be used only by authorized personnel for quality checks, report verification, or dispute handling.
4.2 When no recording retention is selected, audio is processed temporarily only during transcription and deleted as soon as transcription is completed. It must not enter a persistent recording repository, training repository, or routine logs.
4.3 Retention of transcripts and translations is managed separately from the choice concerning original recordings. The hotel may retain transcripts and translations for no longer than 1 year within the disclosed scope, as needed to provide services and create reports.
5 Model training choices
5.1 The model training option is off by default and is not preselected. Users may decide whether to participate before each conversation begins.
5.2 Before training, names, room numbers, contact details, identity document information, payment information, health information, and other sensitive content unrelated to training will be filtered out. We do not extract voiceprints or use data for identity recognition, voice cloning, voice imitation, or synthetic content.
5.3 Subprocessors may provide technical services only under HALONOVA's written instructions and must not independently train models for themselves or third parties.
5.4 After a user withdraws consent, we stop new training uses and delete training copies that can still be linked to that user. For model parameters that have already been created and can no longer be linked to a specific individual, it is not possible to trace or delete a particular individual's contribution.
5.5 Data for which valid training consent was not obtained before this Policy took effect will not be used for model training.
6 Hotel reports and access controls
6.1 By default, hotel daily and weekly reports contain only topics, counts, trends, risks, action items, and de-identified summaries, and do not display names, contact details, complete conversations, or original recordings.
6.2 Only staff who genuinely need access to handle a specific service matter and have the appropriate role permissions may view an individual transcript or translation. Each access must record the person's identity, time, reason, and action taken.
7 Information sharing and subprocessors
We share personal information only to provide services, fulfill legal obligations, protect personal or system security, or with your separate consent. We do not sell personal information.
| Category | Provider | Purpose | Storage region | Restriction |
|---|---|---|---|---|
| Cloud storage and hosting | [LEGAL NAME MUST BE COMPLETED] | Storing transcripts, translations, recordings selected for retention, and reports | [DATA CENTER REGION IN THAILAND] | No independent training |
| Speech recognition | [LEGAL NAME MUST BE COMPLETED] | Converting real-time audio into text | [PROCESSING REGION] | No independent training |
| Machine translation | [LEGAL NAME MUST BE COMPLETED] | Translating transcripts and generating captions | [PROCESSING REGION] | No independent training |
| Real-time communications | [LEGAL NAME MUST BE COMPLETED] | Transmitting Calling Service voice, video, and control signaling | [PROCESSING REGION] | No independent training |
| Security and logs | [LEGAL NAME MUST BE COMPLETED] | Security monitoring, error diagnosis, and incident response | [PROCESSING REGION] | Logs must not be used for model training |
8 Storage locations and cross-border processing
8.1 Data are stored in Thailand by default. The actual data center region and provider will be filled in before this Policy is published.
8.2 If personal information needs to be provided to China or another country, we will explain the overseas recipient, processing purposes and methods, data categories, retention periods, rights channels, and cross-border safeguards before the transfer, and obtain separate consent where required by law.
9 Retention periods and deletion
9.1 Hotels may set shorter retention periods than those in this Policy through their contracts or administration consoles. They must not exceed the maximum periods disclosed to users unless otherwise required by mandatory law.
9.2 If extended retention is necessary for litigation, arbitration, administrative investigations, security incidents, or statutory obligations, we will freeze the relevant data, restrict other uses, and record the reasons, scope, and end date of preservation.
10 Security measures
10.1 We adopt measures including authentication, role-based permissions, encryption in transit, storage protection, access auditing, backup and recovery, deletion tasks, security testing, supplier management, and incident response.
10.2 Organizational customers must promptly disable departing staff members' accounts, restrict staff access to individual conversations and reports, and maintain the security of devices, networks, accounts, and premises.
11 Your rights
(1) To learn whether we process your personal information and to access or obtain a copy of it;
(2) To correct inaccurate or incomplete personal information;
(3) To request deletion, restriction, or cessation of processing in circumstances provided by law;
(4) To withdraw consent-based choices concerning recording retention or model training;
(5) To complain to us, the hotel, or a competent supervisory authority about abuse of permissions, data breaches, or responses to rights requests.
Please submit requests through [MUST BE COMPLETED BEFORE PUBLICATION: rights request email address and contact details]. For processing determined by a hotel, we may forward the request to the relevant hotel and assist with the response.
12 Minors and sensitive information
12.1 Minors must use the Services with a guardian's consent, guidance, and supervision. Where separate guardian consent is required, the hotel and we will provide the corresponding process.
12.2 Users should avoid stating passport numbers, bank card numbers, passwords, medical diagnoses, or other high-risk information unrelated to the service during translation conversations. Where processing is necessary, the hotel should choose a human-assisted or protected dedicated channel.
13 Automated processing and human review
13.1 Speech recognition, translation, summaries, and service intent results may be produced by automated systems. We do not use these results alone to make decisions about individuals that have significant legal or similar effects.
13.2 The hotel must arrange review by staff with appropriate permissions for important service commitments, payments, safety, medical matters, matters involving minors, and other high-risk matters.
14 Policy updates and contact information
14.1 If there are material changes to processing purposes, methods, data categories, retention periods, or recipients, we will update this Policy, provide prominent notice, and obtain renewed consent where required by law.
14.2 Operating entity, address, privacy contact, email address, and telephone number: [MUST BE COMPLETED BEFORE PUBLICATION].