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Privacy Policy

Effective Date: August 19, 2026 · Last Updated: August 30, 2026

⚠️ BETA NOTICE: Halden Pro is currently in closed beta. Features, pricing, and terms described herein are subject to change prior to public launch. Beta participants receive lifetime Pro access at no charge in exchange for feedback and agree to these terms as written.

1. Introduction and Applicability

Cox Toolworks LLC ("Company," "Platform," "we," "us," or "our") operates Halden Pro as a multi-tenant business-to-business (B2B) software-as-a-service (SaaS) platform designed specifically for independent contractors, service professionals, and trade businesses (including HVAC, plumbing, electrical, landscaping, handyman, and roofing operations across the United States). This Privacy Policy explains how we collect, use, disclose, process, and protect information when independent contractor businesses ("Subscribers"), their authorized employees and users ("Authorized Users"), and their customers ("End Customers") interact with the Halden Pro web application, progressive web app (PWA), mobile applications, APIs, and associated services (collectively, the "Platform").

This Privacy Policy and all matters arising out of or relating to it shall be governed by and construed in accordance with the laws of the State of Florida. By accessing or using Halden Pro, you acknowledge that you have read and understood this Privacy Policy.

2. Categories of Personal Information We Collect

We collect various types of information depending on how users interact with the Platform:

  • Subscriber and User Account Data: Business names, owner/administrator names, corporate addresses, email addresses, phone numbers, billing details, and login credentials (stored as secure cryptographic hashes).
  • End Customer Information: Contact details, service addresses, phone numbers, email addresses, service history, invoices, estimates, and payment transaction metadata uploaded, inputted, or generated by Subscribers within the Platform.
  • Telecommunications and SMS Data: Phone numbers, message bodies, delivery timestamps, carrier routing data, and opt-in/opt-out status logs transmitted via our telecommunications infrastructure. The Platform maintains an SMS activity log ("SMSLog") recording the status of every outbound SMS attempt (delivered, blocked due to monthly limit, or failed), the destination phone number, message content, and timestamp. SMSLog records are used exclusively for billing accuracy, monthly allocation enforcement, and abuse prevention.
  • Geolocation Data: GPS coordinates, check-in data, route logs, and time-tracking data generated by mobile application users when explicitly enabled by the Subscriber.
  • Biometric and Visual Data: Job site photographs, property images, document attachments, and user-uploaded media that may incidentally capture faces, physical characteristics, or identifiers.
  • Technical, Device, and Usage Data: IP addresses, browser types, operating systems, device identifiers, system logs, error reports, and diagnostic information collected automatically via our infrastructure.
  • Lead and Social Monitoring Data: Publicly available social media posts, forum discussions, and online mentions collected via third-party monitoring services solely to identify potential business leads for Subscribers.

3. How We Collect Personal Information

We obtain information through three primary methods:

  • Information Provided Directly: Data entered manually or uploaded by Subscribers and Authorized Users during account registration, customer management, invoicing, estimate creation, and daily field operations.
  • Information Collected Automatically:Technical telemetry, error traces, server access logs, and performance metrics gathered automatically when users access or navigate the Platform.
  • Information from Third-Party Integrations:Data passed through connected third-party services, such as payment transaction status updates from our payment processor, telecommunications delivery statuses, or authentication responses from our cloud hosting environment.

4. Purposes for Processing and Using Personal Information

We process and use collected information exclusively for legitimate business and operational purposes, including:

  • Providing, maintaining, optimizing, and supporting the multi-tenant Halden Pro software architecture.
  • Processing subscription billing, managing account lifecycles, and facilitating secure payment routing.
  • Enabling core field service workflows, including scheduling, dispatching, estimating, invoicing, and customer communication tools.
  • Delivering automated text messages, reminders, and notifications via telecommunications partners at the strict direction of the Subscriber.
  • Monitoring system performance, detecting technical bugs, managing security incidents, and running error-tracking diagnostics.
  • Complying with applicable federal, state, and local legal obligations, tax requirements, and lawful binding requests.

5. Artificial Intelligence (AI) Data Processing and Model Training

Halden Pro incorporates artificial intelligence features powered by third-party large language models to assist with estimates, scheduling, document drafting, and communications.

Input and Output Handling

Data submitted to AI features ("Inputs") and the resulting generated text or data ("Outputs") are transmitted securely to third-party AI service providers solely to generate the requested response for the Subscriber.

Strict Prohibition on Foundational Training

Cox Toolworks LLC explicitly warrants that Subscriber business data and End Customer personal information (PII) are never used to train public foundational AI models. We strictly prohibit our third-party AI providers from retaining or utilizing your data for public model training.

Aggregated Platform Improvement

We reserve the right to utilize strictly anonymized, non-identifiable aggregated data derived from feature usage to optimize and improve internal Platform functionality. No individual personal data or tenant-specific information is ever exposed or identifiable in this process.

6. Geolocation, GPS Tracking, and Mobile Data

The Halden Pro mobile application and PWA include optional GPS time-tracking, location services, and field routing features.

Subscriber Responsibility

The Subscriber bears sole and absolute legal responsibility for notifying their employees, subcontractors, and field personnel, and for obtaining all legally required consents prior to enabling GPS tracking features on any device.

Platform Limitation

Cox Toolworks LLC processes geolocation data strictly as a data processor directed by the Subscriber. We bear zero liability for any employment, privacy, labor law, or civil claims brought by field personnel arising from GPS tracking enabled by the Subscriber.

7. SMS, Telecommunications, and TCPA Compliance Data

Halden Pro integrates with third-party telecommunications infrastructure to facilitate SMS invoicing, dispatch notifications, and customer updates.

Subscriber as Sender

The Subscriber is the legal originator and sender of all SMS communications sent to End Customers through the Platform. The Subscriber bears the sole burden for compliance with the Telephone Consumer Protection Act (TCPA), the Florida Telephone Solicitation Act (FTSA), the CAN-SPAM Act, and all applicable telecommunications laws, including securing initial consumer consent.

Consent and Opt-Out Logs

The Platform maintains secure logs of message delivery metadata, consent markers, and opt-out requests (including inbound "STOP," "UNSUBSCRIBE," "CANCEL," or "QUIT" replies). We retain these logs strictly for the protection of the Subscriber and to enforce mandatory communication blocklists.

SMS Activity Logging (SMSLog)

The Platform automatically records an SMSLog entry for every outbound SMS transmission attempt, capturing the destination phone number, message content, delivery status (SENT, BLOCKED_LIMIT_REACHED, or FAILED), and timestamp. SMSLog data is processed exclusively for the following purposes: (1) enforcing monthly SMS allocation limits per subscription tier; (2) auditing SMS delivery accuracy; and (3) detecting and preventing abuse of the Platform's telecommunications infrastructure. SMSLog records containing personal data (destination phone numbers and message content) are subject to the retention period described in Section 15.

8. Biometric Data, Photos, and Job Site Media

Subscribers and their field crews frequently upload job site photographs, property videos, and digital attachments to document completed work.

Incidental Capture and Compliance

Images or attachments may occasionally capture incidental facial geometry, physical features, or biometric identifiers of workers, bystanders, or End Customers.

Sole Subscriber Control

The Subscriber acts as the sole data controller for any such media. The burden of compliance with the Illinois Biometric Information Privacy Act (BIPA), the Texas Capture or Use of Biometric Identifier Act (CUBI), and all other applicable biometric or privacy statutes rests entirely with the Subscriber. Cox Toolworks LLC stores these files strictly as static assets within secure cloud storage at the direction of the Subscriber.

9. Payment Processing, Financial Data, and Stripe Integration

Subscription Fees

Payments collected directly from Subscribers for platform access are processed by Stripe, acting as our merchant of record. We do not store raw credit card numbers on our local database servers.

End Customer Transactions

Payments collected by Subscribers from their End Customers are processed through Stripe Connected Accounts. Cox Toolworks LLC is not the merchant of record for these transactions, does not hold or control funds transferred between Subscribers and End Customers, and does not retain raw financial credentials. All financial data handled via Stripe is governed by the Stripe Services Agreement.

10. Data Sharing and Third-Party Service Providers

We do not rent, lease, or trade personal information. We share data only with trusted third-party infrastructure and service providers bound by contractual obligations to protect data security.

11. Multi-Tenant Data Security and Architectural Isolation

Halden Pro is engineered as a secure multi-tenant SaaS platform.

Logical Data Isolation

We explicitly enforce multi-tenant data isolation. Tenant data is segregated logically within our PostgreSQL database architecture utilizing rigorous tenant identification keys and strict row-level security policies.

Impenetrable Tenant Boundaries

The application layer enforces strict authorization controls ensuring that Tenant A cannot access, query, view, or modify the data, estimates, customer lists, or financial records of Tenant B under any circumstances. Data encryption is maintained both in transit (via TLS/HTTPS) and at rest.

12. US State Privacy Rights Addendum

(CCPA, VCDPA, CPA, CTDPA, UCPA, TDPSA, OCPA, NJDPA, TIPA, IDPL, and all 2026 enacted laws)

Service Provider / Processor Status

Cox Toolworks LLC acts strictly as a "Service Provider" under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), and as a "Processor" under the Virginia Consumer Data Protection Act (VCDPA), the Colorado Privacy Act (CPA), the Connecticut Data Privacy Act (CTDPA), the Utah Consumer Privacy Act (UCPA), the Texas Data Privacy and Security Act (TDPSA), the Oregon Consumer Privacy Act (OCPA), the New Jersey Data Privacy Act (NJDPA), the Tennessee Information Protection Act (TIPA), the Indiana Data Privacy Law (IDPL), and all other enacted and future comprehensive US state data privacy laws.

Consumer Rights Requests

Because we process End Customer data strictly on behalf of our Subscribers, any consumer rights requests received directly by Cox Toolworks LLC will be redirected to the respective Subscriber (the data controller), who maintains primary responsibility for fulfilling consumer rights under applicable law.

13. Do Not Sell or Share and Targeted Advertising Opt-Outs

No Sale or Sharing of Personal Data

Cox Toolworks LLC explicitly does not sell, rent, release, disclose, disseminate, make available, or otherwise share End Customer personal data to any third parties for monetary or other valuable consideration.

No Cross-Context Behavioral Advertising

We do not share End Customer personal information with third parties for cross-context behavioral advertising or targeted marketing purposes.

14. Children's Privacy (COPPA Compliance)

Halden Pro is a professional B2B software platform built exclusively for commercial trade contractors and business entities. The Platform is not directed to, marketed toward, or intended for use by individuals under the age of 18. We do not knowingly collect, solicit, or maintain personal information from children under the age of 13. If we discover that a user under 13 has provided personal data, we will terminate the account and purge the data immediately in strict compliance with the Children's Online Privacy Protection Act (COPPA).

15. Data Retention, Storage, and Deletion

Domestic Storage Only

All data processed by Halden Pro is stored exclusively within secure server regions located entirely inside the United States (Railway US East, Neon AWS US East 1, and Cloudflare R2 US storage buckets). There are no international data transfers; all data remains in the United States.

Retention Timelines

  • Financial and Tax Records: Retained for seven (7) years to comply with federal IRS and standard state auditing requirements.
  • SMS/TCPA Consent Logs: Opt-in records and STOP logs retained for four (4) years from the date of the last message to align with the federal statute of limitations for TCPA claims.
  • SMS Activity Logs (SMSLog): Records of individual SMS transmission attempts, including destination phone numbers, message content, delivery status, and timestamps, are retained for two (2) years from the date of the transmission attempt, after which they are permanently purged. This retention period supports billing audits, allocation enforcement reviews, and telecommunications compliance obligations.
  • Geolocation Data: GPS location data retained on a ninety (90) day rolling window for operational and routing verification, after which it is permanently purged.
  • Operational Data: Business data, End Customer estimates, invoices, and job site photos are retained for the lifetime of the active Subscriber account.

Post-Termination Deletion

Upon complete cancellation or termination of a Subscriber's account, Cox Toolworks LLC applies a ninety (90) day grace period. Following this grace period, all tenant database records and associated Cloudflare R2 stored media are permanently and irreversibly destroyed, except where extended retention is legally required.

16. Changes to This Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time. When material changes are made, we will provide notice to registered Subscribers via email to their registered address at least thirty (30) days prior to the effective date of the update. Continued use of the Halden Pro platform following the effective date of any modification constitutes full acceptance of the revised Privacy Policy.

17. Contact Information

For any questions, concerns, or legal inquiries regarding this Privacy Policy or our data practices, please contact:

Cox Toolworks LLC
Attn: Privacy and Legal Compliance
Orlando, Florida 32807
Email: [email protected]

18. Data Breach Notification and Incident Response

Cox Toolworks LLC is committed to safeguarding Subscriber and End Customer data through continuous monitoring via tools including Sentry error monitoring. In the event that Cox Toolworks LLC confirms a data breach resulting in the unauthorized access or disclosure of End Customer personal data, we will formally notify the affected Subscriber (acting as the data controller) within seventy-two (72) hours of confirmation. Upon notification, it is the sole responsibility of the Subscriber to notify their End Customers in accordance with applicable state and federal laws.

In compliance with the Florida Information Protection Act (FIPA), Cox Toolworks LLC will provide direct notification to the Florida Department of Legal Affairs if a confirmed breach affects five hundred (500) or more individuals within the State of Florida. Immediately following the discovery of a breach, Cox Toolworks LLC will take all commercially reasonable steps to contain the incident, remediate structural vulnerabilities, and restore platform security.

19. Cookies, Local Storage, and Authentication Tokens

To ensure the security and functionality of the Halden Pro web application and Progressive Web App (PWA), the Platform utilizes strictly necessary technical tools. We use secure session cookies to maintain authenticated access. We also rely on secure, HttpOnly authentication tokens (such as NextAuth JWT) to safeguard user sessions. Additionally, browser localStorage is utilized strictly to cache user preferences and enable essential offline functionality for field operations. Cox Toolworks LLC expressly prohibits the deployment of third-party advertising cookies, marketing pixels, or cross-site tracking scripts on the Platform.

SMS Communications

All of the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties. Information will not be sold or shared with third parties for promotional or marketing purposes. We will not share your opt-in to an SMS campaign with any third party for purposes unrelated to providing you with the services of that campaign. We may share your personal data, including your SMS opt-in or consent status, with third parties that help us provide our messaging services, including but not limited to platform providers, phone companies, and any other vendors who assist us in the delivery of text messages.