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Privacy Policy

HAL — Health AI-Augmented Learning

Last updated: January 2026

Overview

HAL is a clinical training application that uses artificial intelligence to help healthcare professionals practise their consultation skills, clinical reasoning, and condition management. This privacy policy explains what data we collect, how we use it, and your rights.

HAL Education ("we", "us", "our") is the data controller responsible for your personal data as described in this policy.

By using HAL, you consent to the data practices described in this policy. We collect and process data solely for the purpose of providing the app's training functionality, and will not repurpose your data for any other use without your explicit consent.

Data We Collect

Account Information

When you sign in with Apple, we receive and store locally on your device:

• Apple User Identifier — a unique, anonymous ID generated by Apple (not your real Apple ID)
• Name — only if you choose to share it during sign-in
• Email — only if you choose to share it during sign-in (Apple offers a private relay option)

This information is stored on your device only and is not sent to our servers.

Chat and Training Data

When you use HAL's clinical training features:

• Your messages (typed or spoken) are sent to our secure servers for processing by AI services that generate responses
• AI-generated responses are sent back to your device

Chat messages are not stored on our servers. They exist only in memory during your active session and on your device. When you clear a conversation or close the app, the conversation data is removed.

Voice Data

• Speech-to-text: When you use the microphone, audio is processed by Apple's on-device and cloud-based speech recognition services to convert your speech to text, subject to Apple's privacy policy.
• Text-to-speech: Text from AI responses is sent to our secure servers to generate spoken audio. The text is not stored after the audio is generated.

Subscription Information

Subscription purchases are handled entirely by Apple through the App Store. We do not collect or store any payment information. Apple manages all billing, receipts, and refunds subject to Apple's privacy policy.

Device Information

We do not collect device identifiers, analytics, location data, or usage statistics. HAL does not use Apple's Identifier for Advertisers (IDFA) and does not track you across other apps or websites as defined by Apple's App Tracking Transparency framework.

Legal Basis for Processing

We process your data on the following legal bases:

• Consent — By using HAL and its features (chat, voice input, text-to-speech), you consent to the processing of your data as described in this policy. You may withdraw consent at any time by ceasing to use the relevant feature or deleting your account.
• Legitimate interest — We process minimal data necessary to deliver the app's core training functionality, maintain service security, and ensure reliable operation.
• Contractual necessity — Processing is necessary to provide the service you have requested when using the app.

Third-Party Services

AI Service Providers

We use third-party AI services to power the chat and voice features in HAL. Your messages are transmitted to these services via our secure servers to generate responses and spoken audio. Our agreements with these providers ensure that your data is not used to train their AI models, is processed only for the purpose of generating responses, and is transmitted over encrypted connections.

Apple

Sign in with Apple, speech recognition, and subscription payments are provided by Apple. Refer to Apple's privacy policy for details.

Data Storage and Security

• Account information (Apple User ID, name, email) is stored locally on your device
• Chat conversations are held in memory only and are not persisted after the app is closed
• All communication between the app and our servers uses HTTPS encryption
• Authentication credentials are stored securely on our servers and are never included in the app
• Our servers do not log or store conversation content

International Data Transfers

To provide HAL's AI-powered features, your data may be processed by servers located outside your country of residence, including outside the European Economic Area (EEA). Where such transfers occur, we ensure appropriate safeguards are in place, including encrypted transmission and contractual obligations with our service providers to protect your data in accordance with applicable privacy laws.

Data Sharing

We do not sell, trade, or share your personal data with third parties. Data is only shared with the service providers described above (our AI service providers and Apple) as necessary to provide the app's functionality.

Data Retention

• Account data: Stored on your device until you sign out, at which point it is deleted
• Chat data: Exists in memory during your session only; not persisted
• Server-side: Our servers do not retain any user data, messages, or audio

Your Rights

You have the following rights regarding your personal data:

• Right to access — You may request a copy of the personal data we hold about you
• Right to rectification — You may request correction of inaccurate personal data
• Right to erasure — You may request deletion of your personal data ("right to be forgotten")
• Right to restrict processing — You may request that we limit how we use your data
• Right to data portability — You may request your data in a structured, machine-readable format
• Right to object — You may object to the processing of your personal data
• Right to withdraw consent — You may withdraw consent at any time, without affecting the lawfulness of processing carried out prior to withdrawal

To exercise any of these rights, please contact us at info@hal-education.com. We will respond within 30 days.

If you are in the European Economic Area, you also have the right to lodge a complaint with your local data protection supervisory authority.

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information is collected, the right to request deletion, and the right to opt out of the sale of personal information. We do not sell personal information.

Practical Controls

You can also manage your data directly within the app:

• Delete your account — You can delete your account from within the app's Settings. Because all account data is stored locally on your device and we hold no server-side account records, deleting your account permanently removes all associated personal data (Apple User ID, name, email, and conversation history) from your device. No personal data remains on our servers as we do not store any.
• Clear conversation history at any time using the Settings menu
• Control voice data by not using the microphone feature
• Control email sharing by using Apple's private relay email option during sign-in

Automated Decision-Making

HAL uses AI to generate simulated patient responses and training feedback. These AI-generated outputs are intended solely as educational tools for practising clinical skills. No automated decisions are made that produce legal effects or similarly significant effects concerning you. All AI outputs should be treated as training material and not as medical advice.

Children's Privacy

HAL is intended for healthcare professionals and students. It is not designed for or directed at children under 17. We do not knowingly collect personal data from children. If we become aware that we have inadvertently collected data from a child under 17, we will take steps to delete it promptly.

Changes to This Policy

We may update this privacy policy from time to time. Any changes will be reflected in the "Last updated" date above. Continued use of the app after changes constitutes acceptance of the updated policy.

Contact

This privacy policy applies to the HAL iOS application.

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