Please read this Policy carefully. If You do not agree with this Policy, do not use any of the Happinetz Services.
We may modify the terms of this Policy at any time at our sole discretion and will post the modified Policy to the Site, so you should review the most up-to-date version of the Policy from time to time. Your continued use of the Happinetz Services thereafter shall constitute your acceptance of the modified Policy. We will notify you of any material modifications to the Policy. If you do not agree to the modified Policy, stop using the Happinetz Services and provide Us with written notice.
Nothing in this Policy shall be deemed to confer any third-party rights or benefits. Additional terms may apply to certain Happinetz Services, and such terms are part of Your agreement with Us if You use those Services. This Policy only applies to Sites and Services that link to this Policy. We are not liable for the practices of any third party or our customers.
This Privacy Statement describes
- The Types of Information Happinetz collects
- How Happinetz Uses Collected Information
- Remote Support For Your Happinetz Account
- How Happinetz May Share Information
- Information Security and Retention
- Your Data Privacy Choices and Rights
- Children's Privacy
- Changes to this Policy
- Contact Us
THE TYPE OF INFORMATION WE COLLECT
1. When You register for an account, or contact us, which may include:
- Contact information such as name, email address, and phone number;
- Your email account and login information;
- Subscription type;
- Payment information;
- Device types and other information processed during registration.
2.When You use our Services, including by visiting the Site, using the App, or connecting to a Network, we may collect the following information:
- Whether You are on the Happinetz Network;
- Whether You are a Registered User or Unregistered User;
- Information about You, Your purchased Happinetz Device, and any of Your device(s) associated and connected to the Network, which may include, without limitation, Navigational Information and Network Preferences (see below). Navigational information refers to information about Your device and operating system and Your interaction with the Services, including but not limited to: Your IP address, device model and version, the date and time of the visit to Our Services and how long You remained on Our Services, the referral URL (the site from which you came), the pages visited on Our Services, browser type and version, operating system, browser history, Your Device ID, and geographical location;
- Information You volunteer such as product feedback or User Content.
HOW WE USE THE INFORMATION WE COLLECT
Happinetz may use the information Happinetz collects:
- To enter into a contract, or to take steps at Your request prior to entering into a contract (such as account registration);
- To process Your orders and notify You of the status of Your order;
- To communicate with you via email, SMS, push notifications or other messaging about the Services or relevant updates. See below for your choices with these communications;
- To respond to Your inquiries and provide You with customer support services, to communicate with third parties in the handling of claims or complaints, and to maintain business administration records and prevent fraud;
- To keep records and administration on how products and services were provided, claims and complaints were handled, including the documents underlying such services, claims and complaints;
- To understand how people use the Happinetz Services, to learn more about Our Users and their preferences, to operate, maintain and improve the Happinetz Services, to develop new products and services, to send You direct marketing (which You may opt-out of at any time) or product-specific communications;
- To comply with legal obligations applicable to Happinetz, such as respond to legal process or requests for information issued by government authorities or other third parties or to protect Your, Our or third parties' rights;
- For measurement, research, and analytics;
- To inform You of important changes or additions to the Happinetz Services;
- To optimize and improve the Happinetz Services;
- To process payments and refunds, if applicable;
- To post information you volunteer when you communicate with us to post comments to our Site or App, respond to surveys, fill out an online form, participate in promotions, provide user testimonials or participate in forums, websites and related information services to share your experiences with our Services on Our App or Site.
- For any purpose where the information is aggregated or anonymized so that no individual data is directly, or indirectly, identifiable.
REMOTE SUPPORT FOR YOUR HAPPINETZ ACCOUNT
Happinetz' End User License Agreement, which can be found on our website for any Happinetz Device or Happinetz Account authorizes Happinetz or its duly authorized support representatives to access Happinetz Account information and devices on Happinetz’ network remotely. Happinetz and its duly authorized support representatives require such access in order to troubleshoot, debug, and otherwise offer support and solutions to Happinetz Services users. Remote access is enabled by the User via the Happinetz App.
Except as described elsewhere in this Policy, Happinetz does not access a given Happinetz Device or Account unless a support request has been received, and it becomes apparent to the support representative that there is a problem that can be solved via remote access. If You wish to limit the level of access to Your Happinetz Device or Account, You must state those limitations at the time of Your support request.
Happinetz or its duly authorized support representatives will only access Your Happinetz Device or Account under the conditions that You set. Whether or not You set any limitations on remote access, Happinetz will discontinue remote access upon resolution of the support request.
HOW WE SHARE INFORMATION
Happinetz can share your information in the following ways:
1. With Service Providers and Affiliates.
- With the exception of data collected through our Network (e.g., through your use of our virtual private network or mobile device management software) which is not shared with third parties, We may disclose the information we collect to service providers and affiliates who assist Us in performing our business purposes. Some service providers and contractors used on Our App and Site include, without limitation, Marketing, processing payment services, analytics services, customer support services, claim handling, billing, internal administrative services, maintenance of the Service, and providing business services to Us or to You. In cases where We may share Your Personal Data with such partners, affiliates, and service providers, we enter into appropriate confidentiality and data processing agreements with these third parties, review their security practices, and limit information sharing to the scope of what they are helping us with. Such third parties are prohibited from using Your personal information except for the stated purposes, and they are required to maintain the confidentiality of Your User Information.
- Happinetz and its affiliated entities may share information with third-party data controllers where such sharing is legally required, such as with the use of certain cookies and related tracking technologies for compliance with specific geographic laws.
2. By Law or Protected Right.
a. We may disclose information from and about You that We collect (1) if required by law; (2) if We believe that disclosure is necessary to comply with the law; (3) to enforce Our intellectual property rights; (4) to protect the rights, property or safety of Us and Our employees or agents; and (5) if necessary to defend against third-party claims. We may disclose certain information collected on the App when requested to comply with a court order, investigation, subpoena or governmental request. We will make reasonable efforts to notify You of such governmental orders and requests, either by a notification on the App or by email, except where prohibited by law or where We reasonably believe that such notification may threaten the safety of Our Users, Our business, or the public generally.
3. As part of a Business Transfer.
- a. If we go through a business transfer, such as consolidation, merger, restructuring, acquisition, or sale of part or all of Our assets. In this event, You will be notified via email and/or a prominent notice on Our App or Site, of any change in ownership, use of information from and about you, and the choices You may have regarding such information.
Happinetz does not ‘sell’, ‘license’, or otherwise share personal information from and about You except as expressly described in this Policy or with Your prior written consent.
INFORMATION SECURITY AND RETENTION
Happinetz implements appropriate administrative, technical, and physical safeguards designed to protect your personal data that we collect against unauthorized access, loss or modification. However, no information system can be 100% secure. This means that Happinetz cannot guarantee the absolute security of Your information. Moreover, Happinetz is not responsible for the security of information You transmit to Us over networks that Happinetz does not control, including the internet and wireless networks, or the data that is stored on Your Happinetz device.
We endeavour to use reasonably available state-of-the-art network and information security standards, protocols and technologies, including encryption, intrusion detection and data loss prevention, and we monitor our systems to ensure that they comply with our security policies.
We implement physical, technical and organizational safeguards to protect your personal data in our custody, both at rest and in transit, and should these measures fail to prevent a data breach, we will promptly take the necessary remedial measures, and we will provide notices as required by applicable law.
Unless You request that We delete Your personal information, Happinetz retains the information collected in an identifiable form as long as reasonably necessary and only for as long as required to fulfill the purposes and on the lawful grounds described above for which Happinetz collects the information and to comply with Our legal obligations. This means that We will keep Your personal information as long as necessary to be able to provide You with Our products and services and to be able to respond to Your requests.
Without explicitly contacting Happinetz, We are unable to judge if You have discontinued use of the hardware device. As such, Happinetz retains the information required to regain access to the device (phone number, Happinetz unique ID, and email address) until deletion of that information is requested.
Should Happinetz become aware of an unauthorized disclosure or security breach concerning any personal information (as defined in applicable law), We shall notify the affected individuals immediately and mitigate the damage of such security breach to the greatest extent possible.
Happinetz collects certain information by automated means when You interact with our Services. Like many companies, Happinetz uses “cookies” and related technologies such as pixel tags on Our Services. Our Service Providers (such as analytics providers) may also place cookies and similar technologies on the Services.
When You visit Our Site, Happinetz may view and/or store the IP address of the device You are using. Happinetz uses this information to determine the general physical location of the device and understand from what regions of the world Our Site’s visitors come from. Happinetz also may use this information to enhance the Site.
Some browsers offer a “Do Not Track” (“DNT”) signal whereby You may indicate Your preference regarding tracking and cross-site tracking. Happinetz does not currently recognize or respond to DNT signals.
YOUR DATA PRIVACY CHOICES AND RIGHTS
You may have certain rights under applicable data protection laws with respect to your personal information, which means information that relates to an identified or identifiable person. We are open about the personal information We collect and have implemented mechanisms to enable You to exercise any rights You might have under applicable laws with respect to Your personal information, such as:
- The right to request access and obtain copies of the personal information We have collected from You or shared in the past 12 months;
- The right to request We update or correct Your personal information if it changes or if You believe that any information that We have collected about You is inaccurate or out-of-date;
- The right to request We delete or erase Your personal information;
- The Right to object to or restrict Our use or processing of Your personal information;
Email marketing - unsubscribe to our email list by clicking the link at the bottom of marketing emails.
b. SMS/whatsapp marketing - you can reply with the word ‘Stop’ to any SMS/message in order to unsubscribe
c. Tailored advertising using third party cookies. In addition, you may reject or delete cookies through your browser settings.
- If We are relying on Your consent to process Your personal information You have the right to withdraw Your consent at any time. Withdrawing Your consent will not affect the lawfulness of any processing We conducted prior to Your withdrawal, nor will it affect processing of Your personal information conducted in reliance on lawful processing grounds other than consent.
If You would like to discuss or exercise Your rights, please contact Us through information provided on our website.
If You would at any time like to review or change the information in Your account or terminate Your account, You can
1. Contact Us using the contact information provided.
International Data Transfers
Happinetz may transfer your personal data to countries other than the one in which You reside. We do this to facilitate our operations, and transferees include our affiliates such as service providers, and partners. Laws in other countries may be different to those that apply where You reside. We put in place appropriate safeguards that help to ensure that such data receives an adequate level of protection. These safeguards include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between Us and our business affiliates and associates to which we choose to transfer the information that requires these companies to safeguard personal information they process. You may contact Us if You would like more information about such safeguards. We implement similar appropriate safeguards with our third-party service providers and further details can be provided upon request.
Legal Basis For Processing Personal Data
Under the GDPR, We may only process personal information where we have a sufficient legal basis.
|Happinetz Processing Activity||Legal Basis under GDPR|
|Placement of cookies on Our site||Consent|
|Collection and Processing of Your personal data to maintain and fulfill the Services||Contract|
|Processing Your personal data to improve our Services||Legitimate Interest|
|Using Your personal data to send you email communications and updates||Legitimate Interest|
|Processing Your personal data for market research||Legitimate Interest|
Although the Happinetz Services are designed to support families with children of all ages, the administration, configuration, and management of the Happinetz Services are intended for use by persons under the age of 18. Circle does not knowingly collect personal information from anyone under the age of 18 when creating or administering our Services.
Our Services are expressly designed for parents to monitor the Internet and mobile activity of their children. As a result, certain personal information related to children’s devices may be accessible by the parent-administrators of the Services, as well as Happinetz in our administration of the Services. This data includes Navigation Information, which are the websites visited or apps used, as well as the times and days allocated to such uses. In some jurisdictions, this information may be deemed ‘personal’ and subject to local laws. Happinetz does not use Navigation Information for any commercial purpose other than to provide the Services.
If You become aware that the Services or data associated with the Services is being used in a manner that may be a violation of our End User License Agreement or our Terms of Service, please let Us know by contacting Us. So Happinetz can take appropriate action. We strongly encourage the parent or guardian of any child under the age of 18 to actively guide any interactions with and/or use of the Happinetz Services.
CHANGES TO THIS POLICY
We may revise this policy from time to time. Review it occasionally so that you keep up-to-date on our most current practices. We will put the ‘Last Updated’ date at the top of each policy.