Privacy Policy
Hallinan Stroud Tecnologia Ltda.
1. Who we are and what this policy covers
Hallinan Stroud Tecnologia Ltda. (“Hallinan Stroud”, “we”, “us”) makes a package that installs in a company's CRM and holds payment reminders on accounts with a live deal until the account owner answers. This policy covers this website and the service.
Registered at Avenida Paulista 1636, Conjunto 1504, Bela Vista, 01310-200 São Paulo, Brazil.
We handle personal data in two different situations, and different rules apply to each:
| Whose data | Our role | What applies | |
|---|---|---|---|
| Part A | People who visit this website, ask about the service or write to us | Controller: we decide why and how the data is used | This policy |
| Part B | People named on our customers' invoices and in their CRM: billing contacts at the companies they invoice, and their own sales and finance staff | Set out in B.1, because it depends on the data | This policy and the data processing agreement we sign with each customer |
If the data processing agreement (“DPA”) and this policy ever disagree about Part B, the DPA wins.
2. Part A: this website and our contact with you
This part covers the personal data we collect for our own purposes: running this website, answering requests, and staying in touch with people who are or might become customers.
A.1 What we collect
What you give us. When you send the form on this site, we collect what you type into it, such as your name, email address, phone number or company, and the fact that you agreed to be contacted. If you email or talk to us, we keep that correspondence and any contact details in it.
What is collected automatically. Our web server records the IP address a request came from, the browser used, the pages requested, the page you came from and the time. These logs exist to keep the site running and secure.
We don’t ask for sensitive data (the “special categories” in Article 9 GDPR) through this website, so please don’t send any through the form.
A.2 Why we use it, and what allows us to
| Why | What | Legal basis (GDPR Art. 6) |
|---|---|---|
| Answering your request and working out whether the service fits | What you sent in the form, our correspondence | Art. 6(1)(b): steps you asked for before a contract |
| Looking after customers, billing and support | Contact details, correspondence | Art. 6(1)(b): carrying out a contract |
| Keeping the site running, secure and free of abuse | Server logs | Art. 6(1)(f): our legitimate interest in running a secure service |
| Contacting you about the service | Email address, company | Art. 6(1)(f): our legitimate interest in business-to-business marketing. You can object at any time |
| Meeting tax, accounting and legal duties | Billing and contract records | Art. 6(1)(c): a legal obligation |
Where we rely on legitimate interest, we have weighed that interest against your rights, and you can ask to see the assessment.
A.3 How long we keep it
- Requests from people who don’t become customers: 12 months from our last contact, then deleted.
- Customer contact and contract records: for the length of the agreement plus five years, the period Brazilian tax law sets for tax records.
- Server logs: 30 days.
- A record that you objected or opted out: kept indefinitely, so we can keep respecting it.
A.4 Your rights
If you are in the EEA or the UK, you can ask to see your data, correct it, have it deleted, limit or object to how we use it, get a copy you can take elsewhere, and withdraw consent where we rely on it. Write to [email protected] and we will answer within one month.
You can also complain to a data protection authority. If you are in the EEA, that can be the authority where you live or work.
3. Part B: data inside the service
Part B covers the data our customers connect to the service: open invoices from their ledger, company, deal, owner and meeting records from their CRM, and the reminder emails sent from their AR mailbox. Our customer decides what is connected and why. We handle it on their instructions.
B.1 What we handle, and in what role
For everything below we act as a processor and the customer is the controller. The service reads the following and nothing wider:
- Open invoices and ledger customers. Customer name, legal name, tax ID where held, billing contact name and email address, invoice number, amount, due date and paid status, read hourly and read-only from QuickBooks, Xero, NetSuite or Sage Intacct.
- CRM companies, deals, owners and meetings. Company name, domain and address; the pipeline, stage, close date and owner of open deals; the name, work email and manager of each owner; and the date of meetings logged on a company. We do not read deal notes, call recordings, email bodies or contact records beyond the billing contact.
- Answers and releases. Who was asked about a held reminder, what they answered, the reason they picked, the date they chose, and any reason a controller typed when releasing a reminder.
- The reminders we send. The template text, the recipient address and the time of sending. The AR mailbox connection is send-only. We do not read the mailbox, and replies to a reminder never reach us.
The service writes only to its own card, its own tab and four fields on the company record. It does not edit deals, stages, amounts or forecasts, and it does not write to the ledger at all.
Billing contacts are told who is writing to them by the reminder itself, which is sent from the customer's own mailbox and domain. We are not named in it and do not contact them on our own account.
B.2 What we do with it
Matching ledger customers to CRM companies. Names, addresses, domains and tax IDs are compared by rules and then by an embedding model and a pair classifier, all running on cloud infrastructure in Dublin. A proposed match below the confidence threshold is shown to the customer's own finance user, who decides.
Checking the hold rule and asking the owner. Before each send we query the CRM for open deals and meetings on the matched company, apply the rule the customer wrote, and if it matches we show a card to the account owner and notify them, optionally through Slack with a link and no invoice detail beyond the account name.
Sending and recording. A released reminder is sent through the customer's AR mailbox. Every question, answer, escalation, release and send is written to the hold ledger, stored on cloud infrastructure in Dublin and visible to the customer's finance users and to the owner of the account concerned.
B.3 AI models: where they run and what they learn from
Where models run. Two models are used, both for matching ledger customers to CRM companies: an embedding model and a pair classifier. Both are open-weight models that we run ourselves on cloud infrastructure in Dublin, with cloud GPU capacity we control there from the fourth quarter of 2026. A third open-weight model, which proposes which CRM record a billed subsidiary belongs under, is planned for the second quarter of 2027; it will run on the same cloud GPU capacity in Dublin and its proposals will go through Match review in the same way. No customer data is sent to any third-party hosted model API, and no model provider appears on our subprocessor list. The hold rule itself is a written rule over CRM fields and involves no model.
Training. We do not train models on your invoices, your customer list, your CRM records or your reminders. The one exception is narrow. When your finance user decides a pair in Match review, we keep a row of numeric similarity features (for example how closely two names and two domains agree, and which rule fired) together with the yes or no. That row holds no names, domains, addresses or amounts. It is pooled across customers and used to retrain the pair classifier. The account hierarchy model planned for 2027 is held to the same limit: any tuning of it uses rows of this kind and nothing else. Your confirmed links themselves stay in your account only.
Where a person decides. The model proposes a match and a person decides. A pair scoring under 0.92 is never linked automatically; it waits in Match review for your finance user, and until it is decided the customer is held for finance above your balance floor. Whether a reminder is sent on a held account is decided by the account owner, their manager or your controller, never by a model and never by a timer. The service makes no automated decision that has a legal or similarly significant effect on an individual.
B.4 Where the data is kept
All data inside the service, including the hold ledger, the matching indexes and backups, is kept on cloud infrastructure in Dublin, Ireland. Models are served from the same place, on cloud GPU capacity we control in Dublin as it comes into use.
Data also remains where the customer already keeps it: in their ledger, their CRM and their mailbox, under the terms they hold with those providers.
The suppliers that handle data in the service are named on our subprocessor list, which comes with the data processing agreement and which we send to anyone who asks: write to [email protected].
B.5 How long we keep it, and what deleting can’t remove
Invoice and CRM data is refreshed on each sync and a record that disappears at the source is removed from the service within 24 hours. The hold ledger is kept for the life of the account, because its value is that it is complete.
When a customer cancels, the ledger stays exportable for 90 days and is then deleted with everything else, backups included, within a further 30 days. Deleting cannot recall a reminder already sent from the customer's mailbox, and it does not remove the four field values already written to the CRM before the package was uninstalled; uninstalling the package does.
B.6 Requests from people whose data is in the service
If you are a billing contact who received a reminder, or a member of staff named in a hold ledger, the company that uses the service is the controller of that data and the right place to send your request. If you write to us instead, we pass the request to that company within five business days and help them answer it.
For everyone
4. Moving data between countries
Hallinan Stroud Tecnologia Ltda. is a company in Brazil, outside the EEA, and handles personal data under Brazil’s LGPD (Law 13.709/2018) and, where it applies, the GDPR. Section B.4 says where the data in the service is kept. When personal data from the EEA or the UK reaches us, for example because someone there writes to us or a customer there uses the service, it is protected by the European Commission’s Standard Contractual Clauses and the technical measures described in our security documentation. You can ask us for a copy. In Brazil you can complain to the ANPD, Brazil’s data protection authority.
EU representative (Article 27 GDPR). Write to [email protected] with “EU representative” in the subject line and we will send you our representative’s details.
5. Security
We protect data in line with the risk. That includes encryption in transit and at rest, access limited to the people and systems that need it, each customer’s data kept separate from every other’s, and a log of every access to production systems.
If a personal data breach affects you, we tell you without undue delay, and at the latest within 36 hours of finding out, with the information you need to meet your own reporting duties.
6. Children
The service is sold to businesses and is not meant for children. We don’t knowingly collect personal data from anyone under 16.
7. Changes to this policy
We may update this policy. If a change matters, we email customers at least 30 days before it takes effect. The version number and date at the top of this page change every time.
8. Contact
Privacy questions and anything else: [email protected]
By post: Hallinan Stroud Tecnologia Ltda., Avenida Paulista 1636, Conjunto 1504, Bela Vista, 01310-200 São Paulo, Brazil