Privacy policy

1. Introduction

This Privacy Policy ("Privacy Policy") explains how Aloha Mobile Ltd, a company incorporated under the laws of the Republic of Cyprus ("AlohaJet", "we", "our" or "us"), collects, uses, discloses, stores and otherwise processes personal data in connection with your access to and use of the AlohaJet website, software, APIs, SDKs, CLI tools, MCP integrations, documentation and related products and services (collectively, the "Service").

This Privacy Policy applies whenever you access or use the Service, create or administer an Account, purchase or subscribe to a Subscription Plan, communicate with us, request support, participate in beta or early access programmes, or otherwise interact with AlohaJet.

This Privacy Policy forms part of the documentation governing your use of the Service and should be read together with our Terms of Use and, where applicable, any Data Processing Agreement entered into between AlohaJet and the relevant Customer. Additional privacy notices may apply where expressly provided for specific products, services or jurisdictions.

This Privacy Policy does not apply to personal data processed independently by third-party websites, AI Models or other Third-Party Services that may be integrated with, or accessed through, the Service. Such processing is governed by the applicable third party's own privacy policy and terms.

2. Our Role

Depending on the circumstances, AlohaJet acts as either a controller or a processor of personal data.

AlohaJet acts as a controller where it processes personal data for its own business purposes, including the provision, administration, security, support and improvement of the Service, customer relationship management, billing and compliance with legal obligations.

Where a business Customer uses the Service to process personal data contained within Customer Content and AlohaJet processes such data solely on the Customer's documented instructions, AlohaJet acts as a processor. In such circumstances, the Customer is responsible for determining the purposes and legal basis for the processing of such personal data. Where applicable, such processing is governed by a separate Data Processing Agreement.

3. Personal Data We Collect

The categories of personal data processed by AlohaJet depend on your relationship with us, how you use the Service, the functionality you enable and whether you use the Service as an individual or on behalf of a business Customer.

Account Information

When you create or administer an Account, subscribe to the Service, request support or otherwise communicate with AlohaJet, we may collect your name, email address, username, company name, job title, authentication identifiers, Account preferences and other information reasonably necessary to establish, administer, secure and support your Account. We may also process information contained in your communications with AlohaJet, including customer support requests, correspondence, feedback, survey responses and other information that you voluntarily provide.

Subscription and Billing Information

Where you purchase a Subscription Plan or otherwise enter into a commercial relationship with AlohaJet, we may process billing and commercial information necessary to administer that relationship, including billing and payment contact details, subscription information, invoices, payment status and transaction history.

Payment transactions are processed by independent third-party payment providers. AlohaJet does not store complete payment card numbers, card verification codes or other sensitive payment credentials.

Technical and Diagnostic Information

When you access or use the Service, AlohaJet may automatically collect technical and diagnostic information relating to your device, software environment and use of the Service. This may include IP address, device identifiers, operating system, application version, browser type, language settings, timestamps, network information, system logs, error logs, crash reports, browser automation telemetry, workflow execution metadata, API request metadata, feature usage information, performance metrics, latency measurements, resource utilisation information, security events and other technical information generated through the operation of the Service. Where reasonably practicable, AlohaJet uses aggregated, anonymised or de-identified information for analytics, quality assurance, security monitoring and the development, testing and improvement of the Service.

Unless you expressly enable functionality requiring transmission to AlohaJet, voluntarily provide information as part of a support request, or otherwise instruct AlohaJet to process such information on your behalf, diagnostic information will not routinely include Customer Content or Browser Data. For the avoidance of doubt, diagnostic information collected through the Service is distinct from Cookies and similar technologies used on AlohaJet's website and is not subject to your Cookie preferences except where required by applicable law.

Customer Content

Depending on how the Service is configured and used, Customer Content may include prompts, instructions, browser automation workflows, configuration settings, URLs, uploaded files, extracted information, browser automation results and other information submitted to or generated through the Service.

Where Customer Content is transmitted to or processed by systems controlled by AlohaJet, it is processed only to the extent necessary to provide and improve the Service, provide customer support, comply with applicable law, protect the rights, property or security of AlohaJet or others, enforce our legal rights or perform our obligations under the Terms of Use and any applicable Data Processing Agreement.

Where the Service is deployed exclusively within Customer Systems and Customer Content is not transmitted to AlohaJet, AlohaJet does not routinely access or process such Customer Content.

Browser Data and Local Processing

AlohaJet is designed to execute browser automation primarily within Customer-controlled environments. Unless you expressly enable optional cloud-based functionality or otherwise instruct AlohaJet to process Browser Data, browser sessions, browser state, cookies, authentication credentials, authentication tokens, browsing history, page content, extracted information and other Browser Data remain within Customer Systems and are not routinely transmitted to, stored by or processed by AlohaJet.

Where Browser Data is transmitted to AlohaJet, including as part of optional Service functionality or a support request, it will be processed only for the purposes described in this Privacy Policy, the Terms of Use and, where applicable, the Data Processing Agreement.

4. Purposes of Processing and Legal Bases

AlohaJet processes personal data only where it has a lawful basis for doing so under applicable data protection laws.

Where processing is necessary for the performance of a contract or to take steps prior to entering into a contract, AlohaJet processes personal data to create and administer Accounts, provide and operate the Service, process subscriptions and payments, provide customer and technical support, administer Subscription Plans and otherwise fulfil its contractual obligations.

Where processing is necessary to comply with a legal obligation, AlohaJet processes personal data to comply with applicable laws, regulations, court orders, lawful requests from governmental or regulatory authorities, tax and accounting obligations, export control and sanctions laws, and other legal requirements.

Where processing is necessary for the purposes of AlohaJet's legitimate interests, provided those interests are not overridden by the rights and freedoms of the relevant individual, AlohaJet may process personal data to operate, maintain, secure and improve the Service; prevent fraud, abuse and unauthorised access; investigate security incidents; develop new features; conduct analytics and quality assurance; maintain business records; enforce its legal rights; and protect the rights, property and safety of AlohaJet, its Customers, users and third parties.

Where required by applicable law, AlohaJet will obtain your consent before processing personal data for specific purposes, including sending certain marketing communications or using non-essential Cookies and similar technologies. You may withdraw your consent at any time, without affecting the lawfulness of processing carried out before its withdrawal.

Where AlohaJet processes personal data solely on behalf of a business Customer as a processor, the Customer is responsible for determining the lawful basis for such processing.

5. AI Models and Third-Party Services

The Service enables Customers to connect and interact with AI Models, websites, web applications, APIs and other Third-Party Services selected and configured by the Customer. Such Third-Party Services operate independently of AlohaJet and are governed by their own terms of use, privacy policies and data processing practices. AlohaJet does not own, operate or control such Third-Party Services and is not responsible for their processing of personal data.

Where a Customer chooses to connect the Service to a third-party AI Model or other Third-Party Service, Customer Content, prompts, instructions, Browser Data or other information submitted by or on behalf of the Customer may be transmitted directly to the selected provider in accordance with the Customer's configuration and instructions. Customers are responsible for evaluating the privacy, security and contractual terms applicable to any Third-Party Services used in conjunction with the Service and for ensuring that their use complies with applicable laws and their own internal policies.

Except as necessary to facilitate the Customer's requested interaction with a Third-Party Service, AlohaJet does not determine how such Third-Party Services use, retain, disclose or otherwise process information transmitted to them.

Where the Service is configured to operate entirely within Customer Systems, AlohaJet does not routinely transmit Customer Content or Browser Data to third-party AI Models unless expressly instructed to do so by the Customer.

AlohaJet does not use Customer Content submitted by Customers to train third-party AI Models. Unless otherwise expressly agreed with the Customer, AlohaJet also does not use Customer Content to train its own general-purpose artificial intelligence models.

6. Sharing of Personal Data

AlohaJet does not sell or rent personal data.

We may disclose personal data where reasonably necessary to provide, operate, support, secure or improve the Service, comply with applicable law, protect our rights and legitimate interests, or as otherwise described in this Privacy Policy.

Recipients may include service providers and professional advisers that support our business operations, including providers of cloud infrastructure, hosting, payment processing, identity and authentication services, customer support, communications, analytics, security, software development tools, auditing, insurance and other professional services. Where such recipients act as processors, they process personal data only on AlohaJet's documented instructions and are subject to appropriate contractual confidentiality and data protection obligations.

We may also disclose personal data where reasonably necessary to comply with applicable law or lawful requests from governmental or regulatory authorities, establish, exercise or defend legal claims, investigate or prevent fraud, abuse or security incidents, enforce our contractual rights, or protect the rights, property or safety of AlohaJet, our Customers, users or others.

If AlohaJet undergoes a merger, acquisition, financing, corporate reorganisation or the sale of all or substantially all of its business or assets, personal data may be disclosed to parties involved in the transaction, subject to appropriate confidentiality obligations and applicable data protection laws.

7. International Transfers of Personal Data

AlohaJet may process or transfer personal data outside the country in which it was originally collected, including to jurisdictions that may not provide the same level of data protection.

Where personal data is transferred internationally, AlohaJet will implement appropriate safeguards in accordance with applicable data protection laws. Depending on the circumstances, these safeguards may include transfers to jurisdictions recognised as providing an adequate level of protection, the use of the European Commission's Standard Contractual Clauses or other approved transfer mechanisms, or another lawful basis for international transfers.

Where required by applicable law, AlohaJet will take reasonable steps to ensure that recipients protect personal data in accordance with applicable data protection laws and appropriate contractual safeguards.

8. Data Retention

AlohaJet retains personal data only for as long as necessary to fulfil the purposes for which it was collected, including providing and administering the Service, complying with legal obligations, maintaining business records, resolving disputes, enforcing our legal rights and protecting the security and integrity of the Service.

Retention periods depend on the nature of the personal data, the purpose of the processing, the duration of the relevant contractual relationship and any applicable legal, regulatory, tax or accounting requirements.

When personal data is no longer required, AlohaJet will securely delete, anonymise or irreversibly de-identify it, unless continued retention is required or permitted by applicable law or is reasonably necessary to establish, exercise or defend legal claims.

Where the Service is deployed entirely within Customer Systems and personal data is not transmitted to or stored by AlohaJet, the Customer remains solely responsible for determining and implementing appropriate data retention and deletion policies.

9. Information Security

AlohaJet implements and periodically reviews appropriate administrative, technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or unauthorised access, taking into account the nature of the processing, the associated risks and applicable legal requirements.

Such measures may include, where appropriate, encryption, authentication and access controls, network security, logging and monitoring, vulnerability management, secure software development practices, security testing, incident response procedures and backup and recovery processes.

While AlohaJet maintains commercially reasonable security measures, no method of electronic transmission, storage or processing can be guaranteed to be completely secure. Accordingly, AlohaJet cannot guarantee the absolute security of personal data or that the Service will be free from security incidents.

Customers remain responsible for securing their own environments, including Customer Systems, authentication credentials, API keys, browser sessions, access permissions and network infrastructure. Where the Service is deployed within Customer Systems, the Customer is solely responsible for the security, availability and resilience of its infrastructure and for protecting Customer Content, Browser Data and any personal data processed within it. AlohaJet is responsible only for the security of the components of the Service that it owns, operates or controls.

10. Your Privacy Rights

Subject to applicable data protection laws, you may have certain rights in relation to the personal data processed by AlohaJet. Depending on the circumstances, these rights may include the right to access, correct, update, delete or restrict the processing of your personal data, to object to certain processing activities, to withdraw your consent where processing is based on consent, and to receive a copy of your personal data in a structured, commonly used and machine-readable format where required by applicable law.

To protect the privacy and security of personal data, AlohaJet may request information reasonably necessary to verify your identity before responding to a request. Where permitted by applicable law, AlohaJet may refuse or limit requests that are manifestly unfounded, excessive or repetitive.

If you believe that AlohaJet has processed your personal data in violation of applicable data protection laws, you have the right to lodge a complaint with the competent supervisory authority or seek any other remedy available under applicable law.

You may exercise your privacy rights by contacting AlohaJet using the contact details set out in this Privacy Policy. We will respond to your request within the timeframes required by applicable law.

11. Business Customers and Data Processing

Where Customers use the Service in connection with their business activities, Customer Content may contain personal data relating to the Customer's employees, contractors, clients, users or other individuals.

Except as expressly described in this Privacy Policy or otherwise agreed in writing, AlohaJet processes such personal data solely on behalf of the relevant Customer and in accordance with the Customer's documented instructions. In such circumstances, the Customer is responsible for determining the purposes and legal basis for the processing of such personal data and for ensuring compliance with applicable data protection laws.

Where required by applicable law or requested by the Customer, AlohaJet will enter into a Data Processing Agreement governing the processing of personal data on behalf of the Customer.

Nothing in this Privacy Policy shall modify the parties' respective rights and obligations under any applicable Data Processing Agreement.

12. Cookies and Similar Technologies

AlohaJet uses cookies, pixels, local storage, software development kits (SDKs), web beacons and similar technologies (collectively, "Cookies") in connection with its website and certain online services to operate, secure and improve the Service, remember user preferences, analyse website usage and, where permitted by applicable law, support our marketing activities.

This section applies only to Cookies used on AlohaJet's website and online services. It does not apply to Browser Data processed through the Service, which is governed by the other provisions of this Privacy Policy.

Cookies may be session Cookies, which expire when you close your browser, or persistent Cookies, which remain on your device until they expire or are deleted.

Types of Cookies

AlohaJet may use the following categories of Cookies:

• Strictly Necessary Cookies, which are required for the operation, security and administration of the website and online services, including user authentication, session management and fraud prevention.
• Functional Cookies, which remember your preferences and settings and improve your experience when using the website and online services.
• Analytics Cookies, which help us understand how our website and online services are used, improve functionality and identify technical issues. Where reasonably practicable, analytics information is aggregated or de-identified.
• Marketing Cookies, which may be used to measure the effectiveness of our marketing activities and deliver more relevant communications where permitted by applicable law.

Certain Cookies may be placed by third-party service providers that support the operation of our website or Service, including providers of analytics, payment processing, identity and authentication services, customer support or embedded content. Such providers process information in accordance with their own privacy policies.

Cookie Preferences

Where required by applicable law, AlohaJet will obtain your consent before placing non-essential Cookies on your device.

You may manage your Cookie preferences through our cookie preference centre, where available, or through your browser settings. Please note that disabling certain Cookies may affect the functionality or availability of parts of the website or online services.

13. Children's Privacy

The Service is not intended for individuals under the age of 18, or such higher minimum age as may be required under applicable law, and AlohaJet does not knowingly collect personal data from children. If we become aware that personal data has been collected from a child in violation of applicable law, we will take reasonable steps to delete such information. If you believe that a child has provided personal data to AlohaJet, please contact us using the details set out in this Privacy Policy.

14. Changes to this Privacy Policy

AlohaJet may amend this Privacy Policy from time to time to reflect changes in applicable law, regulatory guidance, our business operations, the functionality of the Service or our personal data processing practices. Where required by applicable law, AlohaJet will provide reasonable notice of any material changes before such changes become effective. The updated version of this Privacy Policy will be published on our website together with the revised "Last Updated" date.

15. Contact Us

If you have any questions about this Privacy Policy, wish to exercise your privacy rights or otherwise contact AlohaJet regarding our processing of personal data, please contact us at:

Aloha Mobile Ltd

Address: Spyrou Kyprianou 84, 4004, Limassol, Cyprus

Email: team@alohabrowser.com

Support enquiries relating to the Service should be submitted through the support channels identified on our website or by emailing team@alohabrowser.com