Draft for review. Not yet in effect.
Privacy Policy
What personal data BELLI AI PTE. LTD. collects when you visit belli.ai or get in touch with us, why we collect it and what you can do about it.
Last updated:
Scope
This policy covers the belli.ai website. If you use the Belli platform through your airline or ground handler, your organisation’s agreement with us governs that data. The providers behind the platform are listed on our Subprocessors page.
Who we are
BELLI AI PTE. LTD. (“Belli”, “we”, “us”) is a company incorporated in Singapore, UEN 202406286W, with its registered office at 109 North Bridge Road, #07-22, Funan, Singapore 179097. We are responsible for the personal data described in this policy.
For any question or request about it, write to info@belli.ai. Our Data Protection Officer is reachable at the same address.
What we collect and why
When you read the site
Before you answer the cookie banner or if you decline, Google Analytics and PostHog count visits without cookies and without storing anything on your device. They receive:
- the page you viewed and the page you came from;
- your browser, operating system and device type;
- your approximate location, worked out from your IP address;
- how quickly the page loaded;
- which links and buttons you click, such as the Demo button, a contact or careers email link, the Log in window, a FAQ question, a glossary search or a team profile.
Ploy, our hosting provider, also counts visits and clicks, whatever you choose in the banner. It receives the same information and keeps a random visitor ID in a cookie and in your browser’s storage so that it can tell a returning browser from a new one. If you are in the EEA, the UK or Switzerland, or Ploy cannot tell where you are, Ploy replaces your IP address with a one-way hash before storing it. Everywhere else it stores your full IP address with the visit, together with your approximate location (country, region and city) and your network provider. Ploy’s counting does not respond to Do Not Track or Global Privacy Control signals.
PostHog turns your IP address and browser details into a hash on its servers that changes every day. We can count visits, but we can’t link one day’s visit to the next or tell who you are. In this mode Google Analytics sets no cookies and doesn’t recognise you on a later visit.
If you accept cookies, Google Analytics and PostHog also set the cookies listed below. They can then recognise your browser when you come back. PostHog also records which links and buttons you click and how far down a page you scroll.
We use all of this to understand which parts of the site are useful and whether it works well. We don’t use it for advertising and we don’t sell it.
Identifying the companies that visit. If you are outside the EEA, the UK and Switzerland, Ploy sends your IP address to its identification partners, who try to match the visit to a company and, in some cases, to a person. We use this to see which airlines and businesses are interested in Belli. Visitors in the EEA, the UK and Switzerland are never identified this way.
To confirm: Visitor identification is switched on for this site (Settings → Enrichments in Ploy). Confirm: what we use the results for (only to see interest, or also to contact people), whether matches go to a person or only to a company, which of Ploy’s partners do the matching (its register lists Waterfall, Wiza and GetEmails/RB2B among others, but Ploy has not said which ones handle our site), and how long the matches are kept. Legal to check that this is allowed for visitors in Singapore and other countries without asking first.
To confirm: Ploy confirmed in writing (14 Oct): its own counting and the visitor ID cannot be switched off, delayed until consent or run without an ID on a hosted site today. A switch and consent support are on its roadmap, with no date. The cookie banner therefore cannot cover it. Decide with legal whether legitimate interest is enough for this.
Server logs. Ploy and the network that delivers the site, Cloudflare, keep standard technical logs (IP address, time, page requested) to deliver the site and protect it from abuse.
The customers globe. The map on the customers page loads its imagery and labels from MapTiler, which therefore receives your IP address and the part of the map you are looking at.
Log in. The Log in window asks which airline you work for and sends you to that airline’s Belli address. We record which airline address was chosen. We never see a password: you sign in on your airline’s own page.
When you contact us
When you email us or use a Demo or Contact link, we receive your name, email address, organisation and whatever you choose to tell us. We use it to reply. If you’re asking about Belli for your organisation, we also use it to follow up. We keep business contacts in our CRM and support conversations in Gorgias.
When you apply for a job
When you write to careers@belli.ai or fill in the associate application form, we receive your application, CV and anything else you send. We use it only to consider you for a role and share it only with the people involved in hiring. We keep it for 12 months after we’ve made a decision. If you’d like us to delete it sooner or keep it for future roles, just tell us.
Forms and posts from other sites
The associate application is a Google Form, and some pages show posts from LinkedIn. Those sites set their own cookies when their content loads, so we only load it when you click to load that one form or post. After that, the site’s own privacy policy applies to what it collects.
Cookies and what stays on your device
Cookie set before you answer the banner, by Ploy’s visit counting:
| Name | Set by | Purpose | Lasts |
|---|---|---|---|
ploy_anon_id | Ploy | A random ID that lets Ploy count a returning browser as one visitor | 365 days |
Cookies, set only after you accept:
| Name | Set by | Purpose | Lasts |
|---|---|---|---|
| _ga | Google Analytics | Recognises a returning browser | Up to 2 years |
| _ga_… | Google Analytics | Recognises a returning browser | Up to 2 years |
| ph_phc_…_posthog | PostHog | Recognises a returning browser | Up to 1 year |
| ph_phc_…_posthog_cpm | PostHog | Remembers the cookie choice | Up to 1 year |
| Google cookies | Google Forms | Set by the application form, only once it loads | See Google |
| LinkedIn cookies | Set by a LinkedIn post, only once one loads | See LinkedIn |
Changing your mind: use Cookie settings at the bottom of any page. From then on we stop setting analytics cookies. To remove cookies that were already set, clear them in your browser settings.
Stored on your device, never sent to us:
| Name | Purpose |
|---|---|
ploy_anon_id | Ploy’s copy of its visitor ID, set before you answer the banner. It stays until you clear it |
ploy_session | Ploy’s record of your current visit (a visit ends after 30 minutes without activity), set before you answer the banner |
ploy_pending_events | Visit and click events waiting to be sent again after a failed attempt, only while there are any |
belli:consent | Your answer to the cookie banner, so we don’t ask again |
__ph_opt_in_out_… | PostHog’s copy of that answer |
ph_phc_…_posthog | PostHog’s record of your browser, only after you accept |
belli:uld | Containers you saved in the ULD builder |
belli:tenant | The airline you last chose under Log in, so it’s filled in next time |
These are needed for the parts of the site you use and don’t track you. You can remove them in your browser settings at any time.
Why we’re allowed to use it
If you’re in the EU, the UK or a country with similar laws, these are the legal bases we rely on:
| What | Legal basis |
|---|---|
| Analytics cookies, and loading a form or post from another site | Your consent, which you can withdraw at any time |
| Counting visits (Google Analytics and PostHog without cookies, and Ploy), server logs and the customers globe | Our legitimate interest in running a website that works and knowing roughly how it’s used |
| Identifying the companies that visit (outside the EEA, the UK and Switzerland) | Our legitimate interest in knowing which businesses are interested in Belli |
| Replying to your messages and following up on enquiries | Our legitimate interest in answering the people who write to us |
| Job applications | Steps you’ve asked us to take before possibly entering into a contract with you |
To confirm: Legal check needed for two rows: Ploy’s counting sets its visitor ID before consent (second row), and visitor identification (third row) runs without asking.
In Singapore, we collect, use and disclose personal data under the Personal Data Protection Act 2012, with your consent or where the Act otherwise allows it.
Who we share it with
We use these providers to run the website and our correspondence. Each acts on our instructions under its own terms:
| Provider | What for | Where |
|---|---|---|
| Ploy | Hosting the site, counting visits and clicks, and identifying the companies that visit | United States |
| Google Analytics | Counting visits | United States |
| PostHog | Counting visits and how pages are used | United States |
| Cloudflare | The network the site is delivered from | Global network |
| MapTiler | Satellite imagery and place labels on the customers globe | See MapTiler |
| Google Workspace | Google’s global network | |
| Gorgias | Support conversations | United States |
| Google Forms | The associate application form, only once you load it | Google’s global network |
| Only if you load a LinkedIn post shown on our pages | See LinkedIn |
To confirm: Still missing from Ploy: the Data Processing Addendum (Ploy is confirming the version and how to sign it), and which of its subprocessors handle our visitors’ data. Its public register (trust.ploy.ai/subprocessors) lists 25 providers, almost all in the US, and Ploy says it is a general list, not specific to our site.
We may also disclose personal data:
- when the law requires it;
- to protect our rights or someone’s safety;
- to a successor if Belli’s business is merged or sold, in which case this policy continues to apply to your data.
We never sell personal data.
International transfers
Some of these providers process data outside the country you’re in, including in the United States, where Ploy’s servers are. Where the law requires it, we rely on safeguards such as the European Commission’s standard contractual clauses or the provider’s certification under the EU–US Data Privacy Framework. For transfers out of Singapore, we make sure the recipient protects the data to a standard comparable to the PDPA.
How long we keep it
| Data | Kept for |
|---|---|
| Visit and click counts in Ploy | While our Ploy account is active, and up to 30 days after it ends. The visitor ID stays in your browser until you clear it |
| Server logs | As long as Ploy and Cloudflare keep them, to be confirmed |
| Emails and enquiries | As long as the conversation or business relationship lasts, then 2 years |
| Job applications | 12 months after a decision, unless you ask otherwise |
To confirm: Ploy gives no retention period per type of data (events, logs, form submissions, backups). Its terms say data is deleted 30 days after the account ends, and Ploy says to treat 30 days as current while it revises its privacy policy (which still says 60).
Your rights
You can ask us to:
- tell you what personal data we hold about you and give you a copy;
- correct it;
- delete it;
- stop or limit using it or object to how we use it;
- give it to you or to someone else in a common format.
To confirm: Ploy cannot find or delete one visitor’s visit data by its ID: it can only delete the data of our whole account. Decide with legal how we answer a deletion request for that part, and whether this section needs to say so.
You can also withdraw any consent you’ve given at any time. For cookies, that’s Cookie settings at the bottom of every page. Withdrawing doesn’t affect what happened before.
To make a request, write to info@belli.ai. We’ll reply within 30 days. We may need to confirm who you are first.
If you’re unhappy with how we’ve handled your data, please tell us first. You can also complain to Singapore’s Personal Data Protection Commission at pdpc.gov.sg. If you’re in the EU or UK, you can complain to your local data protection authority.
Security
We protect personal data with access controls and encryption and by giving our providers only what they need. No system is perfectly secure. If a breach affects you, we’ll tell you and the authorities as the law requires. How the Belli platform is secured is on our Security page.
Children
This website is meant for businesses. We don’t knowingly collect personal data from anyone under 18. If you think a child has sent us their data, write to us and we’ll delete it.
Changes to this policy
When this policy changes, the date at the top changes with it. If a change affects how we use data you’ve already given us, we’ll ask for your consent again where the law requires it.
