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Haller Privacy Policy

Last updated: July 24, 2026

This Privacy Policy describes how Haller processes personal data collected through the hallerapp.com website, including the early access signup landing page.

Haller is an invite-only business networking project for managers, entrepreneurs, founders, and professionals on the move. Through the landing page, users can sign up to receive communications about the app launch and, if they choose, separate marketing communications.

1. Data controller

The Data Controller is:

  • Alberto Cinaglia
  • Email: hallerapp1@gmail.com
  • Privacy email: hallerapp1@gmail.com
  • Fiscal code / ID: CNGLRT02L03D969G

2. Personal data collected

Through the Haller landing page, we may collect the following personal data:

  • First name
  • Last name
  • Email address
  • LinkedIn page address, if voluntarily provided
  • Technical browsing information, such as IP address, online identifiers, device data, browser data, security verification data, and interactions with the site, to the extent such data is collected through analytics, tracking, or anti-abuse tools

We do not ask users to submit special categories of personal data, such as health data, political opinions, religious beliefs, or other sensitive data.

3. Purposes of processing

Personal data is processed for the following purposes:

a. Early access list signup

We use first name, last name, and email address to register the user's interest in Haller and to send communications limited to the app launch, including updates about service availability and early access.

b. Marketing communications, only with separate consent

If the user gives specific consent, we may use contact data to send promotional communications, commercial updates, or content related to Haller.

c. Site analysis and improvement

We may use analytics and tag management tools to understand how the landing page is used, measure campaign performance, and improve the user experience.

d. Security and abuse prevention

We may process technical data and use a self-hosted anti-abuse challenge to protect the site, verify that submissions are made by a real user, and prevent abuse, unauthorized access, or improper use of our services.

4. Legal basis for processing

Data processing is based on:

  • The user's consent, for early access list signup and any marketing communications
  • The Controller's legitimate interest, for security, abuse prevention, and technical operation of the site
  • Compliance with legal obligations, where applicable

Consent is optional and may be withdrawn at any time, without affecting the lawfulness of processing carried out before withdrawal.

5. Nature of data provision

Providing first name, last name, and email address is necessary to sign up for the Haller early access list.

Providing the LinkedIn page link is optional. Failure to provide it does not prevent signup for the early access list.

Consent to marketing communications is optional and separate from signup for the early access list.

6. Processing methods

Personal data is processed with IT and electronic tools, using appropriate technical and organizational measures to protect it from unauthorized access, loss, misuse, alteration, or disclosure.

Access to data is limited to authorized persons and providers that support the Controller in managing the landing page, communications, and technical tools.

7. Providers and tools used

To manage the landing page, signups, and communications, we may use third-party providers, including:

  • HubSpot, for contact and signup management
  • Google Tag Manager, for tag management
  • Google Analytics 4, for analytics and measurement
  • Meta / Facebook Pixel, for measurement and campaigns
  • Mailtrap, for email testing, sending, or technical email management

These providers may process personal data as processors or, in some cases, independent controllers, according to their respective terms and privacy notices.

8. Transfers outside the European Economic Area

Some providers may process personal data in countries outside the European Economic Area, including the United States.

Where this occurs, the Controller adopts, where necessary, appropriate safeguards required by applicable law, such as the Standard Contractual Clauses approved by the European Commission or other recognized transfer mechanisms.

9. Retention period

Data collected for early access list signup is retained until the launch of the Haller app and, after that, for a maximum period of 24 months, unless the user requests earlier deletion.

Data processed for marketing purposes is retained until consent is withdrawn or deletion is requested.

Any technical or security data may be retained for the time necessary to ensure the proper operation of the site, prevent abuse, and comply with legal obligations.

10. User rights

The user may exercise, within the limits provided by applicable law, the following rights:

  • Access to their personal data
  • Rectification of inaccurate or incomplete data
  • Deletion of data
  • Restriction of processing
  • Objection to processing
  • Data portability
  • Withdrawal of consent given
  • Complaint to the competent supervisory authority

To exercise these rights, users may write to: hallerapp1@gmail.com.

11. Email communications

Communications related to the Haller launch will be sent to users signed up for the early access list.

Marketing communications will be sent only to users who have given separate consent. Each marketing communication will include, where applicable, the option to unsubscribe or withdraw consent.

12. Cookies and tracking technologies

The landing page may use analytics, tag management, and measurement tools, including Google Tag Manager, Google Analytics 4, and Meta Pixel.

Some of these tools may use cookies, online identifiers, or similar technologies. For more information about the technologies used, their purposes, and available preferences, please refer to Haller's Cookie Policy: [COOKIE POLICY LINK].

13. Changes to this Privacy Policy

The Controller may update this Privacy Policy over time, for example to reflect legal, technical, or organizational changes.

The updated version will be published on hallerapp.com with the date of the latest update.

14. Contacts

For questions about this Privacy Policy or the processing of personal data, users may contact:

  • Alberto Cinaglia
  • Email: hallerapp1@gmail.com
  • Privacy email: hallerapp1@gmail.com