HALONOVA AI Translator Terms of Service

Version V1.3 Publication date: October 21, 2026 Effective date: October 21, 2026

These Terms apply to HALONOVA AI Translator devices, companion applications, administration consoles, cloud interfaces, and personal translation, AI Service, AI Knowledge Base, Calling Service, hotel work orders, conversation summaries, and other functions that assist hotel operations. These Terms apply both to organizational customers, such as hotels, that purchase or deploy the product and to guests, visitors, and staff who use the devices.

Important notice Real-time translation and Calling Service process both parties' voices and generate transcripts and translations. Users may choose to retain original recordings for 90 days or use a mode that does not retain recordings. Use of data for internal translation model training is optional and off by default; declining or withdrawing does not affect core translation, calling, or basic hotel services.

By clicking to agree, activating a device, using an account, or actually using the services, you confirm that you have read and accepted these Terms. Where separate consent is required by law for recording retention, model training, sensitive personal information, or cross-border provision of information, acceptance of these Terms does not replace that separate consent.

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 If any item remains incomplete, this document must not be published externally or used to obtain user consent.

1 Definitions and scope

1.1 “Services” include hardware companion functions, device software, personal translation mode, the hotel staff workbench, AI Service, AI Knowledge Base, Calling Service, hotel work orders, the administration console, cloud services, interfaces, updates, and technical support. Available functions depend on the actual product version, region, device model, plan, and organizational configuration.

1.2 “Organizational customer” means a hotel, store, medical institution, or other organization that purchases, rents, manages, or deploys the Services. “End users” include guests, visitors, staff, contractors, and other people who actually use a device or participate in a call.

1.3 “Conversation data” include original recordings, voice streams, transcripts, translations, language pairs, speaker labels, times, device and conversation identifiers, and other necessary information in real-time translation or calls.

1.4 “Hotel reports” means daily and weekly reports, service summaries, topics, counts, trends, risks, and action items produced for hotel service management. By default, reports do not display names, contact details, complete conversations, or original recordings.

1.5 “Model training” means using conversation data after sensitive information has been removed to improve HALONOVA's internal translation, speech recognition, and quality evaluation models, following the user's separate, voluntary consent. This purpose does not include voiceprint identification, voice cloning, voice imitation, or synthetic content generation.

2 Eligibility and organizational representatives

2.1 You must have the legal capacity required to enter into these Terms. Minors may use age-appropriate services only with the consent, guidance, and supervision of a parent or other guardian.

2.2 When accepting these Terms on behalf of an organizational customer, you confirm that you have the appropriate authority. If an order, purchase contract, data processing agreement, or other written document conflicts with these Terms, the document separately signed by both parties prevails to the extent that it does not diminish end users' statutory rights.

2.3 Staff, contractors, and administrators may access guest, conversation, call, report, and work order data only within the scope authorized by their organization.

3 Service functions

3.1 Personal translation mode may provide real-time two-way speech recognition, machine translation, bilingual captions, translated speech playback, microphone controls, and dual-screen display.

3.2 AI Service may receive service requests, identify intent, provide automated replies, transfer handling to staff, and create necessary service records.

3.3 AI Knowledge Base may provide staff with SOP suggestions, reference replies, and source materials based on materials configured by the organization, current translation content, and necessary context.

3.4 Calling Service may provide internet voice or video calls between devices or rooms, incoming and outgoing calls, incoming call queues, call history, bilingual captions, and call translation.

3.5 Hotel work order and operations modules may create service requests based on guest conversations or staff entries and support assignment, updates, notifications, acknowledgments, closure, conversation summaries, and hotel reports.

4 Voice processing and recording choices

4.1 Real-time translation and Calling Service require voice collection and processing during a conversation to provide speech recognition, transcription, translation, captions, and call transmission. The corresponding voice functions cannot be provided without enabling the microphone.

4.2 Before each conversation or call begins, the device must explain, in the current language, the data categories, purposes, retention periods, people who may access the data, and how to opt out. Shared devices must not carry over the previous user's choices.

4.3 Users may choose “Store this recording for 90 days.” In this mode, recordings may be used only for hotel service quality checks, report verification, complaint or dispute handling, and model training to which the user has separately consented.

4.4 Users who do not agree to retain original recordings may choose “Do not store the recording” and continue using real-time translation and calling. Audio must be deleted after real-time transcription is completed and must not be written to a persistent recording repository, training repository, or routine operations logs.

4.5 Recording retention status must remain visible throughout the conversation. Both parties to a call must receive an on-screen or audio notice; if the other party's wishes cannot be confirmed, the mode that does not retain recordings must be enabled or the call must be transferred to a human-assisted channel.

4.6 Transcripts and translations may be retained for no longer than 1 year so that the hotel can provide services, follow up work orders, handle complaints, and create reports. Organizational customers must determine and record a lawful basis for processing in each scenario.

5 Hotel reports and business records

5.1 Hotels may create daily reports, weekly reports, and service summaries from conversation and work order data to understand service topics, request volumes, handling trends, risks, and action items.

5.2 By default, reports use de-identified and aggregated information, do not display names, contact details, identity document information, payment information, or health information, and do not include complete conversations or original recordings. Reports are retained for no longer than 2 years.

5.3 Staff with appropriate permissions may access an individual transcript or translation only where genuinely necessary to handle a specific service request. The system must record the person accessing it, the time, the reason, and the action taken.

5.4 Reports assist operations and may be affected by recognition errors, mistranslations, insufficient context, or data delays. Before making important decisions or commitments concerning an individual, the hotel must have authorized staff review the information.

6 Voluntary model training

6.1 Model training is an optional purpose separate from immediate translation, calling, hotel services, and operational reports. The training option is off by default and must not be preselected, used as a basis for denying core services, or agreed to collectively by the hotel on behalf of guests.

6.2 Consent records must include the notice version, display language, time, device, user role, recording retention choice, training choice, and withdrawal status.

6.3 Before data enter the training process, names, room numbers, contact details, identity document information, payment information, health information, and other sensitive content unrelated to training must be filtered out. Data must not be used for voiceprint extraction, identity recognition, voice cloning, voice imitation, or synthetic content.

6.4 Training copies and operational copies of original recordings share the same starting point for the 90-day retention period. Copying, migration, or a change in storage location must not restart that period. Training text that can still be linked to an individual must not be retained for more than 1 year.

6.5 Users may withdraw training consent at any time. After withdrawal, we stop including new data in training and delete training copies that can still be linked to the user. Withdrawal does not affect processing lawfully completed before withdrawal.

6.6 For model parameters that have already been created and can no longer be linked to a specific individual, we cannot promise to trace or delete that individual's contribution from the model. We will reduce the risks of memorization, reproduction, or disclosure through training data registers, access controls, and model evaluations.

6.7 Data for which valid training consent was not obtained before this version took effect will not be used for model training.

7 User content and necessary authorization

7.1 Users retain the rights they lawfully hold in conversations, text, images, knowledge base materials, and other content. Using the Services does not automatically transfer those rights to us.

7.2 Users authorize us to process user content to the extent necessary to provide the selected services, maintain security, resolve faults, and perform these Terms. Authorization for model training takes effect only after the user separately consents.

7.3 Users and organizational customers must not input another person's voice, identity document information, health information, financial information, or other sensitive information that they are not entitled to process. They must not use the Services for covert recording, surveillance, or unlawful profiling.

8 Automated translation and AI-assisted results

8.1 Speech recognition, machine translation, retrieval, classification, summaries, and service intent results may contain omissions, mistranslations, incorrect matches, tone discrepancies, delays, or incomplete information.

8.2 Hotels and staff must not rely solely on automated results when providing medical, legal, financial, payment, identity verification, personal safety, emergency response, or other high-risk services.

8.3 The current Services do not provide voice cloning, voice imitation, face swapping, or deep-synthesis audio or video functions, and are not a general-purpose content generation tool open to users.

9 Organizational customer responsibilities

9.1 Organizational customers decide the purposes of their hotel services, work orders, reports, and staff management, and must determine lawful bases for processing, configure permissions, inform end users, and comply with local legal requirements.

9.2 Organizational customers must explain microphone use, transcription, translation, recording choices, and hotel reports through device screens, guest room signage, staff explanations, or other readily accessible means.

9.3 Organizational customers must provide staff with accounts and permissions appropriate to their roles, promptly disable permissions for staff who leave or change roles, and audit access to individual conversations and reports.

9.4 Organizational customers must not bypass end users to consent directly to model training, compel guests or staff to participate in training, or use refusal to participate as a reason to reduce service quality.

10 Personal information and rights

10.1 We process personal information in accordance with the Privacy Policy and applicable law. The Privacy Policy explains data categories, purposes, legal bases, roles, retention periods, recipients, storage regions, and channels for exercising rights.

10.2 Subject to applicable law, users may request access, copies, correction, deletion, restriction of processing, objection to processing, or withdrawal of consent, or complain to a competent supervisory authority. To protect others' information, we may verify the requester's identity and authority before responding.

10.3 When the deletion deadline is reached, the relevant data must be deleted or irreversibly anonymized. If retention must be extended because of legal obligations, limitation periods, security incidents, or preservation for disputes, other processing must be restricted and the reasons and new deletion date must be recorded.

10.4 When processing information concerning minors, voiceprints, identity documents, medical or health information, financial accounts, or other sensitive personal information, we and organizational customers must each fulfill the special notice, separate consent, impact assessment, and strict protection obligations required by applicable law.

11 Processing roles and the data processing agreement

11.1 For hotel service delivery, work orders, quality checks, and reports, the organizational customer generally determines the processing purposes, and HALONOVA provides processing services in accordance with the organizational customer's written instructions. Specific roles are determined by the data processing agreement and actual business decisions.

11.2 For model training voluntarily chosen by end users, HALONOVA independently determines the scope and methods of training and assumes the corresponding responsibilities for training notices, consent, withdrawal, security, and responses to rights requests.

11.3 This section does not exempt either party from responsibilities that it must bear independently under applicable law.

12 Subprocessors and cross-border processing

12.1 The Services may use cloud storage, speech recognition, machine translation, real-time communications, and security providers. The Privacy Policy and schedules to the data processing agreement must list their legal names, service purposes, data categories, and processing regions.

12.2 Subprocessors may process data only in accordance with contractual instructions and must not use conversation data for their own products, public models, or independent model training.

12.3 Data are stored in Thailand by default. If personal information needs to be provided to China or another country, we will, as required by law, disclose the overseas recipient, purpose, method, data categories, methods for exercising rights, and cross-border safeguards, and obtain separate consent where necessary.

13 Accounts and security

13.1 Users must safeguard accounts, verification codes, device administration passwords, and other credentials. If a device is lost, an account is compromised, permissions are abused, or data may have been leaked, users must immediately notify their organizational administrator or us.

13.2 We will adopt access controls, protection for data in transit and storage, logs, deletion tasks, backup management, supplier management, and security incident response measures appropriate to the risks.

14 Prohibited conduct

(1) Covertly recording audio or video, translating, monitoring, or disseminating conversation content without completing the necessary notice or authorization;

(2) Inputting, accessing, or disseminating personal information, trade secrets, unlawful content, or infringing content that you are not entitled to process;

(3) Impersonating staff, guests, rooms, or devices, or falsifying work orders, notifications, handling statuses, consent records, or call records;

(4) Bypassing authentication, permissions, recording choices, training consent, or retention period controls;

(5) Conducting unauthorized reverse engineering, security testing, crawling, or bulk data extraction of the Services;

(6) Using the Services for fraud, impersonation, harassment, discriminatory decisions, or other unlawful conduct.

15 Fees, subscriptions, and refunds

15.1 Some Services may be charged per device, account, location, feature package, usage, or subscription period. Prices, taxes, service terms, payment, renewal, and refunds are governed by the order, quotation, purchase page, or service contract.

15.2 Automatic renewal is enabled only after the user's express consent. These Terms do not exclude consumers' statutory rights to cancellation, refunds, contract termination, or other remedies.

16 Intellectual property

16.1 Intellectual property in the Services' software, interfaces, documentation, databases, trademarks, algorithms, and other materials belongs to us or our licensors. Users must not copy, modify, rent, resell, or create derivative works without authorization.

16.2 Rights in knowledge base materials uploaded by organizations and in user content remain with their original rights holders under applicable law. Automated results may be subject to restrictions arising from source materials, third-party rights, and applicable law.

17 Service changes, suspension, and termination

17.1 We may update, restrict, or suspend some Services for security, legal, product, or operational reasons. We will give reasonable advance notice of changes that materially affect users' rights.

17.2 Upon termination of the Services, data must be returned, deleted, anonymized, or subject to restricted processing in accordance with the Privacy Policy, the data processing agreement, and legal requirements.

18 Service assurances and limitations of liability

18.1 We will provide the Services with reasonable skill and care in accordance with applicable law, orders, and service contracts. We do not guarantee that automated translation, recognition, AI replies, knowledge base suggestions, or reports will be complete, accurate, or suitable for a particular purpose in all environments.

18.2 Calling Service may fail because of networks, devices, permissions, the real-time communications platform, or the other party not answering. It is not an emergency reporting, emergency medical, or other legally designated emergency communications channel.

18.3 To the extent permitted by applicable law, each party is liable only for losses directly and reasonably foreseeably caused by its breach of contract or unlawful conduct. Any cap on monetary liability applicable to organizational customers is governed by valid provisions in the order or service contract.

18.4 No exclusion or limitation of liability applies to liability that the law does not permit to be excluded or limited, including intentional misconduct, gross negligence, personal injury, fraud, infringement of personal information rights and interests, or impairment of consumers' mandatory statutory rights.

19 Complaints, security incidents, and third-party claims

19.1 Users may submit complaints or reports concerning recognition or translation errors, recordings, model training, reports, permission-based access, personal information, protection of minors, or security vulnerabilities.

19.2 If a security incident may affect personal information rights and interests, we will take remedial measures and, where required by law, notify supervisory authorities, organizational customers, or affected individuals.

19.3 If a party's intentional or negligent breach of these Terms, unlawful recording, or unauthorized processing of another person's information leads to a third-party claim, that party bears reasonable losses only as provided by applicable law and within the scope of its responsibility.

20 Updates to these Terms and dispute resolution

20.1 We may update these Terms because of legal, product, security, or business changes. If data processing purposes, methods, or categories change, we will provide renewed notice and obtain the necessary consent as required by law.

20.2 These Terms are governed by the law of the place where the operating entity actually providing the Services is registered, without excluding mandatory protections in the end user's place of residence or the place where services are provided. Any other valid agreement in an order or contract between an organizational customer and us applies as agreed.

20.3 If a dispute arises, the parties should first seek resolution through customer support, project contacts, or written notice. If negotiations fail, either party may refer the dispute to a court with jurisdiction under applicable law or resolve it under a valid arbitration agreement.

21 Contact information

If you have questions about these Terms, recording retention, model training, hotel reports, personal information, or security, contact us through the customer support entry in the device or application, the hotel administrator, or the following channels: [MUST BE COMPLETED BEFORE PUBLICATION: operating entity, address, privacy contact, email address, and telephone number].