Privacy Policy

Your privacy is important to us, and so is being transparent about how we collect, use, and share information about you. This Website Privacy Policy (“Privacy Policy”) is intended to provide information about how we collect, use and transfer personally identifiable data from you through our publicly accessible websites (any of our websites such as www.happioh.com that can be accessed without a password), and on which we post a direct link to this Privacy Policy (collectively the “Site”). “Happioh,” “we,” and “us” refer to Happioh, Inc. and any of our corporate affiliates.

This Privacy Policy covers only data collected through the Site. This Privacy Policy does not cover any other data collection or processing, including, without limitation, data collection practices of webpages to which the Site links, or data that we collect offline or through webpages that do not display a direct link to this Privacy Policy, for example the Happioh applications on which we host data for registered customers. If you click on a link from the Site to open a third party site, data collected by the third party site operator will be governed by the privacy policy of that third party site operator, not this Privacy Policy.

Through your access to the Site, we receive data that you actively submit as well as data that we track. Each category is described further below.

Actively Submitted Data: When you request information, subscribe to a mailing list or for a service, respond to an online survey or otherwise actively send us data, we usually collect data such as your name, e-mail address(es), mailing address(es), telephone number(s), and certain information related to the business you represent such as number of employees and industry type. You can opt out of providing information by not entering it when asked and, if such information is required in order to allow us to respond to your inquiry, you will receive a notice advising you of this. In each such instance, you will know what data we collect through the Site, because you actively submit it.

Passively Tracked Data: When you visit the Site, we may passively track information on your computer and Internet connection, such as the IP address of your computer and/or Internet service provider, the date and time you access the Site, the Internet address of websites from which you link to our Site, the computer technology you are using and your movements and preferences on our Site. We use technology that many other websites employ, such as “cookies” or small data files stored on your computer’s hard drive, to collect such information. In some instances, we may use cookies to collect information in connection with future visits from that website, to recognize you as a previous visitor, or to track your activity on our Site. If you follow a link to the Site from a third party site or promotion, we store information about your arrival from that third party site or promotion in a session cookie. You do not need to have cookies turned on to visit our Site. You can refuse cookies by turning them off on your browser. But, if you want to access webpages that require registration, you need to accept a mandatory session cookie, which you can delete after you leave the Site.

Combinations: Unless you also actively submit personal information such as your name or address, passively tracked data does not typically allow us to identify you personally (even though it can theoretically be done, we do not have the means or an interest to find out who you are, unless you identify yourself voluntarily through an active submission of data). To the extent permitted by applicable law, we may combine passively tracked data with personal data that you actively submit.

We collect passively tracked data primarily for purposes of administering, protecting and improving our Site and our systems, to better understand the preferences of our Site visitors, to identify server problems, to compile aggregated statistics about Site usage, and to help personalize your experience on our Site. We do not deliver third party online advertisements on our sites but we may advertise our products and services on others’ websites. We also may work with service providers to deliver retargeting advertisements and other advertisements on our behalf to Site visitors.

We collect actively submitted data primarily for two purposes: First, for the purpose for which you originally sent us the data (e.g., to provide information to you or sign you up for a free trial); and second, for purposes of contacting you to further discuss your interest in our company, the services we provide, and ways we can improve them to provide information on services, promotions and events. You can opt out of receiving marketing emails as explained below.

We are not in the business of selling or renting your information to telemarketers and we do not share your personally identifiable information with others, except as follows: We may share your information within the Happioh corporate affiliates. We engage agents and service providers who process data only on our behalf and for our purposes under confidentiality agreements. We may share your information as required by law or in the interest of protecting or exercising our or others’ legal rights, e.g., without limitation, in connection with requests from law enforcement officials and in connection with court proceedings. We may share or transfer your information in connection with a prospective or actual sale, merger, transfer or other reorganization of all or parts of our business. Also, we reserve the right to fully use and disclose any information that is not in personally identifiable form (such as statistics and survey results that do not identify you individually by name).

Your personal information may be transferred to countries located outside your country or region, including to countries that may not provide a similar or adequate level of protection to that provided by your country or region. For example, if you reside in the European Economic Area (“EEA”), we may transfer your personal information to the United States or other countries outside of the EEA. By using the Site or otherwise providing personal information to us, you hereby expressly consent to the transfer of your personal information outside your country or region. Happioh, Inc. employs approved legal mechanisms to comply with privacy laws when transferring your data outside of the EU or United Kingdom. Additionally, Happioh, Inc., participates in the EU-US and Swiss-US Privacy Shield programs.

In addition to the disclosures made elsewhere in this Privacy Policy with respect to our privacy practices, our legal basis for processing personal data we collect in the EEA can vary depending on the manner in which you use our Site or otherwise engage with us. Our legal basis for processing information about you is with your consent in cases where you authorize us to engage in processing, such as an affirmative request to receive communications from us. If you provide consent, you can withdraw your consent at any time, although this will not affect the lawfulness of our processing prior to your withdrawal of consent.

In the case of processing involving passive data collection and other processing for the administration of our Site, such processing is undertaken pursuant to our legitimate interests as a data controller, including the operation of our Site. We also may process personal data where necessary for our compliance with a legal obligation to which we are subject. We also reserve the right to process personal data in the event we believe doing so is necessary to protect the rights of the data subject or another person.

More specific information about the basis for our processing may be included on specific notices or forms and, in the event of a conflict, the purposes identified on a specific form will take precedence over the purposes identified here.

If you have concerns about our processing of your personal data you can contact our privacy point of contact, using the contact information below. You also have the right to file a complaint with your country’s data protection supervisory authority.

In connection with promotions or other projects, we may ask you specifically whether you have objections against a certain kind of data use or sharing. If you opt-out under such circumstances, we will respect your decision. To opt out of receiving commercial communications from Happioh, please click on the “opt-out” link in the communication or contact us at privacy@happioh.com. Please note that our partners and other data recipients have their own data privacy policies, which may differ from ours and you would have to contact them separately with respect to opt-out requests.

As required by applicable law, including the EU-US and Swiss-US Privacy Shield Frameworks, upon request we will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. You may request this information by emailing us at privacy@happioh.com.

If personal information you have submitted through the Site is no longer accurate, current, or complete, and you wish to update it, please send an e-mail to privacy@happioh.com. Upon appropriate request we will update or amend your information, but we reserve the right to use previously obtained information to verify your identity or take other actions that we believe are appropriate.

California’s “Shine the Light” law permits California residents to annually request and obtain information free of charge about what personal information is disclosed to third-parties for third-party direct marketing purposes in the preceding calendar year. We do not distribute your personal information to third-parties for third-party direct marketing purposes, except as provided for in this Privacy Policy.

To help protect the privacy of your personal information collected through the Site, we maintain physical, technical, and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal data to those individuals who need to know that information to operate our business. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees’ privacy responsibilities.

We will keep your personal information only as long as is reasonably necessary for the purposes described in this Privacy Policy or longer as may be required by applicable law.

This Site is not directed towards children under 13 years of age nor do we knowingly collect information from children under 13. If you are under 13, please do not use the Site or submit any personal information to us. If you believe that we have unintentionally collected personal information about your child, you can contact us by mail or email as described below.

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may revise this Privacy Policy from time to time; however, any information that we collect is subject to the version of this Privacy Policy in effect at the time that information is collected. If we make any material changes to this Privacy Policy, we’ll notify you of those changes by posting them clearly on our Site or by sending you an email or other notification if we have your contact information, and we’ll indicate when such changes will become effective. When you visit the Site, you are accepting the current version of this Privacy Policy as posted on the Site at that time. We recommend that users revisit this Privacy Policy on occasion to learn of any changes.

Please feel free to contact us with any comments, questions, complaints, or suggestions you might have regarding the information practices described in this Privacy Policy. You may contact us by sending us an e-mail at privacy@happioh.com