Privacy Policy

Last updated: 28 July 2026

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal Data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

heily’s Services are offered to businesses, companies and other entities, and individual professionals (our “Customers”) for professional use. We enter into customer agreements (for example, our platform agreement, pilot agreement, terms of service and data processing agreement) with our Customers. These agreements govern the delivery and use of the Services (the “Customer Agreement”). This Privacy Policy does not apply to any input or output generated on our platform, or documents uploaded to or shared with our platform. We process that data on behalf of Customers and we call it “Customer Data” and “Content”. heily’s use of Customer Data and Content received through the Services is governed by the relevant Customer Agreement, including our Data Processing Agreement. heily processes Customer Data and Content received through the Services as a Data Processor, so any queries related to this data should be directed to our Customers, who are the Data Controllers.

This Privacy Policy applies where heily is the data controller responsible for the processing of the Personal Data.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalised have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

  • Account means a unique account created for You to access our Service or parts of our Service.
  • Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
  • Application refers to heily, the software and services provided by the Company, including the application at app.heily.ai.
  • Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Manifestt Ltd, 27 Albert Embankment, London SE1 7AQ.
  • Country refers to: United Kingdom.
  • Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
  • Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
  • GDPR refers to the UK General Data Protection Regulation and, where applicable, the EU General Data Protection Regulation.
  • Personal Data is any information that relates to an identified or identifiable individual.
  • Service refers to the Application and the website at heily.ai.
  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analysing how the Service is used.
  • Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Company name and job title
  • Address, County, Postcode, City
  • Usage Data

Account Information

When You or Your employer creates an account with Us and throughout the time You or Your employer uses the Services, We collect certain information associated with Your account, including Your name, email address, information about Your profession and Your firm, sign-in details, payment information and Your transaction history with Us (collectively, “Account Information”). Account Information does not include Customer Data or Content.

Usage Data

Usage Data is collected automatically when using the Service. When You interact with the Services, metadata is generated that provides additional context about Your use of the Services, including Your email address, account identifiers, how often You visit the Service, how You interact with it, the amount of time spent, the volume and type of tasks You assign, the features interacted with and how those features performed during Your interactions (collectively, “Usage Data”).

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Information from Third-Party Social Media Services

The Company allows You to create an account and log in to use the Service through the following Third-party Social Media Services:

  • Google

If You decide to register through or otherwise grant us access to a Third-party Social Media Service, We may collect Personal Data that is already associated with Your Third-party Social Media Service’s account, such as Your name and Your email address associated with that account.

You may also have the option of sharing additional information with the Company through Your Third-party Social Media Service’s account. If You choose to provide such information and Personal Data, during registration or otherwise, You are giving the Company permission to use, share, and store it in a manner consistent with this Privacy Policy.

Information Collected while Using the Application

While using Our Application, in order to provide features of Our Application, We may collect, with Your prior permission:

  • Files, documents and messages You upload to, share with or send to the Application

We use this information to provide features of Our Service, to improve and customise Our Service. The information may be uploaded to the Company’s servers and/or a Service Provider’s server.

You can remove this information at any time through the Application or by contacting Us.

Microsoft 365 Access (OneDrive, SharePoint and Outlook)

With Your explicit consent, and only for the account You connect, Our Application may read the files in the OneDrive and SharePoint folders You share with it, file a workpaper Your reviewer has approved into the engagement folder, and read messages in the Outlook mailbox You connect. Each capability is optional, is enabled by You through Microsoft’s consent screen, and can be revoked at any time. This optional feature works as follows:

  • Voluntary Access: You may choose to grant the Application access to Your files and mailbox. This access is entirely optional and can be revoked at any time.
  • AI-Powered Analysis: When enabled, We use Large Language Model (LLM) technology to analyse the content of Your files and emails to carry out the audit work You have assigned.
  • Data Processing: Content analysed by Our LLM service is processed securely, is never used to train any model, and is deleted 30 days after You close the engagement, or earlier on request.
  • No Unauthorised Sharing: We do not share Your file or email content with third parties for any purpose other than providing the service You have authorised.
  • Control and Transparency: You can disable this feature at any time, after which We immediately cease accessing Your files and mailbox.

This feature requires explicit authorisation through Microsoft’s OAuth consent flow, and You can revoke this access at any time through Your account settings and Your Microsoft 365 administration.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Service, including to monitor the usage of our Service.
  • To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
  • To contact You: To contact You by email, telephone calls or other equivalent forms of electronic communication regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
  • To manage Your requests: To attend and manage Your requests to Us.
  • For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganisation, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
  • For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We use Account Information and Usage Data to improve and develop the Services, including to ensure the Services are functioning correctly and to discover ways to innovate new features and improve existing ones, and for general research and aggregate reporting. We do not use Customer Data or Content to develop, train or improve artificial-intelligence or machine-learning models.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. Our Service is hosted in the European Union (the Netherlands). It means that this information may be transferred to, and maintained on, computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

Our Service may give You the ability to delete certain information about You from within the Service.

You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law Enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other Legal Requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

We nevertheless apply appropriate technical and organisational measures to protect Your data. These include encryption of data in transit using industry-standard TLS/HTTPS, encryption of data at rest, and access controls that restrict access to Your data, including any data obtained through connected Microsoft 365 or Google accounts, to authorised personnel and systems on a need-to-know basis. OAuth credentials and access tokens are stored securely in encrypted form and are used only to provide the features You have enabled, and each customer’s data is logically isolated from that of other customers. We review our security practices on an ongoing basis.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

  • Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
  • Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
  • Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
  • Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
  • Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
  • Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the UK or the EU, to:

  • Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
  • Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
  • Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
  • Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
  • Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
  • Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

Children’s Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third-party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Google and Microsoft 365 Data: Limited Use

heily’s use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. We apply the same commitments to information received from Microsoft 365 through the Microsoft Graph API, and Our use of it is limited to providing the features You have enabled: reading the engagement files Your firm shares, picking up instructions and client evidence sent to the mailbox You connect, and filing an approved workpaper into the engagement folder. We access this data only to deliver these user-facing features to You.

We do not sell this Microsoft 365 data or transfer it to third parties for advertising or other unrelated purposes, and we do not use it for advertising or lending. We do not use Microsoft 365 data to develop, improve, or train generalised artificial intelligence or machine-learning models, and we do not transfer it to any third-party service that would use it to train such models. Any AI processing is performed only to deliver the requested feature for the specific user whose data it is.

To deliver these features, heily may share Your Microsoft 365 data with a limited set of service providers strictly to operate the Service, including cloud hosting and AI processing providers (such as Railway, Anthropic and Microsoft) that process the data solely to generate the requested output for You. These providers act on Our instructions under contractual terms that prohibit using Your data to train their own models or for any purpose other than providing the Service. We do not share Your Microsoft 365 data with data brokers, advertisers, or any party for advertising.

You can review or revoke heily’s access to Your Google account at any time from Your Google Account permissions page, and to Your Microsoft 365 account from Set up in the Application or from Your Microsoft 365 administration.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us: