Privacy Policy

Last Updated: January 2026

Halfborg Software (“Company”, “we”, “us”, or “our”) operates the Atavra platform (the “Service”). This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use our Service.

By using Atavra, you consent to the collection and use of information in accordance with this Privacy Policy.

1. Information We Collect

1.1 Information You Provide

Account Information When you create an account, we collect:

  • Name
  • Email address
  • Password (encrypted)
  • Organization name (if creating an organization)
  • Profile information you choose to add

User Content When you use the Service, we collect content you create, including:

  • Campaign configurations and scenarios
  • Persona profiles and settings
  • Event content (simulated posts, emails, articles)
  • Responses and communications during campaign runs
  • Uploaded files (such as profile images and attachments)

Payment Information If you purchase a subscription, we collect billing information including:

  • Payment card details (processed securely by our payment processor)
  • Billing address
  • Transaction history

Communications We collect information when you:

  • Contact our support team
  • Respond to surveys or feedback requests
  • Subscribe to our newsletters or marketing communications

1.2 Information Collected Automatically

Usage Data We automatically collect information about how you interact with the Service, including:

  • Pages and features accessed
  • Actions taken within the platform
  • Time spent on the Service
  • Referring URLs and exit pages

Device and Technical Information We collect:

  • IP address
  • Browser type and version
  • Operating system
  • Device identifiers
  • Time zone and language settings

Cookies and Similar Technologies We use cookies and similar tracking technologies to collect information and improve the Service. See Section 6 for more details.

1.3 Information from Third Parties

We may receive information about you from third-party services, including:

  • Authentication providers (when you sign in)
  • Analytics services
  • Payment processors

2. How We Use Your Information

We use the information we collect to:

Provide and Operate the Service

  • Create and manage your account
  • Process transactions and send related information
  • Enable participation in campaign runs and training exercises
  • Store and deliver your content
  • Provide customer support

Improve and Develop the Service

  • Analyze usage patterns and trends
  • Identify and fix technical issues
  • Develop new features and functionality
  • Conduct research and analysis

Communicate with You

  • Send transactional emails (account verification, password resets, billing notices)
  • Send service-related announcements and updates
  • Send marketing and promotional communications (with your consent)
  • Respond to your inquiries and requests

Ensure Security and Compliance

  • Detect, prevent, and address fraud and abuse
  • Enforce our Terms of Use
  • Comply with legal obligations

3. How We Share Your Information

We do not sell your personal information. We may share your information in the following circumstances:

3.1 Within Your Organization

Information you create or share within an organization on Atavra may be visible to other members of that organization, depending on their role and permissions.

3.2 Service Providers

We share information with third-party vendors who perform services on our behalf, including:

  • Authentication services – to manage user sign-in and account security
  • Cloud hosting and storage – to store and serve your data
  • Payment processors – to process subscription payments
  • Analytics providers – to understand how the Service is used
  • Email service providers – to send transactional and marketing emails

These providers are contractually obligated to protect your information and use it only for the purposes we specify.

We may disclose your information if required to do so by law or in response to valid legal requests, such as:

  • Court orders or subpoenas
  • Government or regulatory requests
  • To protect our rights, property, or safety
  • To protect the rights, property, or safety of our users or others

3.4 Business Transfers

If we are involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change and any choices you may have.

We may share your information for other purposes with your explicit consent.

4. Data Retention

We retain your personal information for as long as necessary to:

  • Provide the Service to you
  • Comply with our legal obligations
  • Resolve disputes and enforce our agreements

Account Data: Retained while your account is active and for a reasonable period thereafter to allow for reactivation or as required by law.

Usage Data: Retained in aggregated or anonymized form for analytics purposes.

Campaign and Training Data: Retained according to your organization’s settings and our data retention policies. Organization administrators may delete campaign data at any time.

When you delete your account, we will delete or anonymize your personal information within 90 days, except where retention is required by law or for legitimate business purposes.

5. Data Security

We implement appropriate technical and organizational measures to protect your personal information, including:

  • Encryption of data in transit (TLS/SSL) and at rest
  • Secure authentication mechanisms
  • Regular security assessments and testing
  • Access controls limiting who can access personal data
  • Employee training on data protection

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee its absolute security.

6. Cookies and Tracking Technologies

6.1 What Are Cookies

Cookies are small text files stored on your device when you visit a website. We use cookies and similar technologies (such as local storage) to operate and improve the Service.

6.2 Types of Cookies We Use

Essential Cookies Required for the Service to function. These enable core features like authentication, session management, and security. You cannot opt out of essential cookies.

Analytics Cookies Help us understand how users interact with the Service. We use analytics tools to collect information about usage patterns, which helps us improve the Service.

Preference Cookies Remember your settings and preferences to provide a more personalized experience.

6.3 Managing Cookies

Most web browsers allow you to control cookies through their settings. However, disabling certain cookies may affect the functionality of the Service.

6.4 Do Not Track

Some browsers include a “Do Not Track” feature. The Service does not currently respond to Do Not Track signals.

7. Your Rights and Choices

Depending on your location, you may have the following rights regarding your personal information:

7.1 Access and Portability

You can access much of your personal information directly through your account settings. You may also request a copy of your personal data in a portable format.

7.2 Correction

You can update or correct your account information through your account settings. You may also contact us to request corrections to other personal data.

7.3 Deletion

You can delete your account at any time. You may also request deletion of specific personal data, subject to our legal obligations and legitimate interests.

7.4 Restriction and Objection

You may request that we restrict processing of your personal data or object to certain processing activities.

7.5 Marketing Communications

You can opt out of marketing emails by:

  • Clicking the “unsubscribe” link in any marketing email
  • Updating your communication preferences in account settings
  • Contacting us directly

Please note that even if you opt out of marketing emails, we may still send you transactional communications related to your account and the Service.

7.6 Exercising Your Rights

To exercise any of these rights, please contact us using the details in Section 11. We will respond to your request within a reasonable timeframe and in accordance with applicable law.

8. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. These countries may have different data protection laws.

When we transfer personal data internationally, we implement appropriate safeguards to protect your information, including:

  • Standard contractual clauses approved by relevant authorities
  • Data processing agreements with our service providers
  • Compliance with applicable cross-border transfer requirements

9. Children’s Privacy

The Service is not intended for children under the age of 18. We do not knowingly collect personal information from children under 18. If we learn that we have collected personal information from a child under 18, we will take steps to delete that information promptly.

If you believe we have collected information from a child under 18, please contact us immediately.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

11. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Halfborg Software

Email: [email protected]

We will endeavor to respond to your inquiry within a reasonable timeframe.

12. Additional Information for Specific Jurisdictions

Singapore (Personal Data Protection Act)

If you are located in Singapore, you have rights under the Personal Data Protection Act (PDPA), including the right to access and correct your personal data. To exercise these rights, contact us using the details above.

European Economic Area (GDPR)

If you are located in the EEA, you have additional rights under the General Data Protection Regulation, including the right to lodge a complaint with a supervisory authority.

California (CCPA)

If you are a California resident, you have rights under the California Consumer Privacy Act, including the right to know what personal information we collect, the right to delete, and the right to opt out of the sale of personal information. We do not sell personal information.

By using Atavra, you acknowledge that you have read and understood this Privacy Policy.

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