Privacy Policy

Last Updated: September 30, 2020

This website is operated by Happi PTE LTD. (hereinafter, “Happi”, “We”, or “Us”). This Privacy Policy (the “Privacy Policy”) governs your access to the Happi website: https://www.happirewards.com/any other and any other web services owned, controlled, or offered by Happi now or in the future (all collectively referred to as, the “Services”). The term “You” or “User” shall refer to any individual that views, uses, accesses, browses or submits any content or material to the Services.

Since we may gather certain types of information about our users, we feel you should fully understand our policy and the terms and conditions surrounding the capture and use of that information. This Privacy Policy discloses what information we gather and how we use it. The private information you provide on the Services will be used only for its intended purpose.
 

BY VISITING, SIGNING UP, USING, BROWSING, OR ACCESING THE SERVICES, YOU CONSENT TO THE DATA PRACTICES DESCRIBED IN THIS STATEMENT. IF YOU DO NOT AGREE WITH OUR PRIVACY PRACTICES, DO NOT USE THE SERVICES.

ABOUT HAPPI

The Happi app is a platform for consumer insights and interactions. As such, users receive questions regarding their status, history, intentions, opinions, preferences, and desires on a broad range of consumer, economic, political, religious and lifestyle topics. Happi collects this information on behalf of clients with the intention of selling the information to those clients. These clients may be consumer brands, market research organizations, financial services providers, political groups, employers, media and/or non-profit organizations.

This information can be used for analysis by clients or Happi and may form the basis of targeting additional questions or promotions to you. Happi does not release personally identifiable information such as names, email addresses or mobile numbers. Happi does not enable third parties to contact you directly other than through questions and promotions through the Services. If you respond to a promotion and choose to offer your personal information to any third party, the terms and conditions of your provision of that information to the third party are between you and the third party. One of the user benefits of Happi is access to promotions aligned with the opinions, preferences and desires you indicate through question responses and prize selections. You understand and confirm consent to receiving promotions, invitations, offers, and additional questions through the Services based on your responses to questions and selection of prizes on the Services.

You further confirm that if you are below 18 years of age, your parent or guardian has confirmed both awareness and consent for you to use this app. We do not collect personal information of children under the age of thirteen (13).

HOW DOES THE HAPPI WORK?

After verification of your account, you will receive profiling questions via the Services survey module. Your responses to these questions will determine which market research studies are best suited for you. When we find a study suited for you, we will ask if you want to participate via survey, push notification or by calling or emailing you. Some studies involve monitoring of your mobile activity, the advertisements to which you are exposed and/or your location. We will explain the compliance expectations, the data to be collected, and the rewards for participation so that you can decide if you wish to participate. If you opt-in to a study, the Services will then guide you through a set up process to grant the necessary permissions and access rights to the Services. We will only use the data collected from registration, surveys, and monitoring as described in this Policy. Participants are invited to the Program by advertisements on social media, job boards, and through internal Refer-a-Friend programs or other third-party companies which are each the data controller of their respective data and Participants. Taking part in the Program is entirely voluntary. For more information on how the Happi works please read our Terms and Conditions.

By signing up to the Program, and by accepting these terms, you confirm that you have read and understood the terms of this Privacy Policy. We ask you to read this Privacy Policy carefully. For the purpose of this Privacy Policy, “personal data” means any information which relates to an identifiable living individual.

This Policy does not replace the existing privacy policy of the Panels as that still applies to all Participants, whether or not they choose to participate in this Program. This Policy is supplemental to any panel-specific policies and applies only to those Participants who choose to participate in the Program.

This Policy describes our data collection and use practices for consumers who download the Application. This Policy applies only to the operation of the Services and not to any other application, website or service.

INFORMATION WE COLLECT

We may collect information, including: Personal Information and Non-Personal Information, when you interact with us and the Services, for example when you:

  • Access or use the Services;
  • Open or respond to our e-mails;
  • Contact customer service;
  • Visit any page online that displays our ads or content;
  • Make a purchase on or through the Services (if applicable);
PERSONAL INFORMATION

“Personal Information” means information about you that specifically identifies you or, when combined with other information we have, can be used to identify you. As a general rule, we do not collect Personal Information about you when you visit and/or use the Services, unless you choose to provide such information to us. Submitting Personal Information through the Services is voluntary. By doing so, you are giving us your permission to use the information for the stated purpose. 

a. LEGAL BASIS FOR COLLECTING YOUR PERSONAL INFORMATION

We collect, process and use your Personal Information for the purposes described in this Privacy Policy, based at least on one of the following legal grounds:

  • With your consent: We ask for your agreement to process your information for specific purposes and you have the right to withdraw your consent at any time.
  • When Performing this Agreement: We collect and process your Personal Information in order to provide you with the Services, following your acceptance of this Privacy Policy; to maintain and improve our Services; to develop new services and features for our Users; and to personalize the Services in order for you to get a better user experience.
  • Legitimate interests: We process your information for our legitimate interests while applying appropriate safeguards that protect your privacy. This means that we process your information for things like detecting, preventing, or otherwise addressing fraud, abuse, security, usability, functionality or technical issues with, protecting against harm to the rights, property or safety of our properties, or our users, or the public as required or permitted by law; enforcing legal claims, including investigation of potential violations of this Privacy Policy; in order to comply and/or fulfill our obligation under applicable laws, regulation, guidelines, industry standards and contractual requirements, legal process, subpoena or governmental request, as well as our Terms and our billing process.

b. INFORMATION WE COLLECT AND HOW WE COLLECT INFORMATION

Through the Services, we may collect information that can identify you when you voluntarily submit it to us. Your Personal Information may include:

  • Full Name;
  • Address;
  • Email address;
  • Phone number;
  • Demographic Data (such as age, gender, zip code)
  • Date of Birth
  • Identification (Such as a Driver’s License, to confirm your identity)
  • Other similar information

c. STORAGE OF PERSONAL INFORMATION

We will take reasonable precautions, as well as physical, technical, and organizational measures in accordance with industry standards, as described herein, to protect your Personal Information from loss, misuse, unauthorized access, disclosure, alteration, or destruction.  Computer safeguards, such as firewalls and data encryption may be used to protect your information. We authorize access to your information only for those employees or agents who require it to fulfill their job responsibilities and these individuals are required to treat this information as confidential.

However, the security of information on or transmitted via the Internet cannot be guaranteed. Unauthorized entry of use, hardware or software failures, and other factors may compromise the security of your Personal Information. All information you send to us electronically or through email is not secure. Any transmission is at your own risk as the transmission of information via the Internet is not completely secure.

NON-PERSONAL INFORMATION

We collect and temporarily store certain information about your usage of the Services. Non-Personal Information means information that alone cannot identify you, including data such as cookies, pixel tags, web beacons and device information. We collect both non-personally identifiable information and personally identifiable information from you through the Application. Examples are explained below and are related to “clickstream data”. Clickstream data is information generated by you and your device while surfing the Internet and interacting with various sites, services, apps, and device functions. In greater detail, the Application collects the following types of information. The information includes, without limitation:

  • Online Browsing: This includes the sites you visit and apps you use, including news sites/apps or social networks, and your interactions with how you use them, how much time you spend browsing the internet and the terms of any search you carry out.

  • Online Activities: This includes the search terms you enter and the results of such searches, the videos you view, the products you shop for online, information you enter into forms, the materials you download or upload, the advertisements you see, information and content on sites or apps that you visit or use and with which you interact and may include personal, financial and health information (subject to the process described below in the section entitled “Protecting Personal & Sensitive Information”).
  • Information on secure pages/apps: This includes information and content from protected or secure pages or apps that you access, such as online accounts or the content of complete and incomplete consumer transactions when you are checking out through a service’s shopping cart, even if the service makes this information unreadable to others.
  • System Information: This includes information about the device and system you are running on, including unique identifiers that may be stored in your device’s operating system such as your device’s unique identifier, IP address and phone number of the device. This also includes unique identifiers used by websites and apps and information about your access to cellular and Wi-Fi networks.
  • Mobile Device and Computer Usage Information: This includes information about your use of your mobile phone. Please note this information is collected and transmitted to Us “in the background” and does not require any further activation on your part. We call this “mobile monitoring”. This can include the following types of information:
    • Information about your internet browsing habits – how much time you spend browsing the internet on your mobile phone, tablet or computer or your mobile device, the sites you visit or apps you use, and the terms of any search you carry out.
    • Information about your usage of other apps and features on your device, including the identity of the apps and features, when you downloaded them, how often you use them and for how long. This includes things like your use of the camera(s) (although we do not collect your photos) and the media player(s) (including the titles of songs/tracks and videos)
    • Your location (see below)
    • Social media activity, including access times and duration, the posts and stories you see, the ads you see, and how you interact with all of the above.
    • Information about when you send or receive text messages, SMS or MMS. We do not intentionally collect or record the content of SMS text or MMS messages sent and received through your phone with the exception of order confirmation texts you may receive from mobile commerce sites.
    • Information about the time emails are sent and received on your mobile phone, tablet or computer or your mobile device. 
    • Information about the type of device you use, when and for how long you charge it, its battery status, whether it is switched on, off or in a stand-by or “Airplane” mode.
    • Information about which mobile network you use, which WIFI networks you connect to, and at what times.
    • Information about the volume of data downloaded to your mobile device, the times that you download that data and the method of connection you use (WIFI or mobile network). 
    • Information we can deduct from combining the above information – e.g., what apps you were using just before you searched for particular information using your device’s internet browser, or the geographic location in which you are most likely to charge your device, use mobile commerce or social media, or download an app.
  • Location Information: This includes information which reveals the geographic location of your device, which we obtain from the location services function of your phone.
  • Information you provide: In some cases, we may ask you to send video, audio or image content to us. That content may include personal information, for example in the form of an identifiable image of you. We may also invite you to participate in surveys, in which case your responses are considered information collected under, and subject to, this Privacy Policy.
INFORMATION COLLECTION TECHNOLOGIES

The technologies we use for automatic information collection may include:

  • Cookies (or mobile cookies): We may use “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you. The purpose of a cookie is to tell the web server that you have returned to a specific page. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Services.
  • Retargeting/Advertising Cookies: Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. 
  • Web Beacons: The Services and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an e-mail and for other related Services statistics.
  • Social Ad Platforms: We may also use Google Analytics, Facebook, Instagram, and Twitter’s functionality of re-marketing through their tracking cookies and pixel-based retargeting services. This means that if you provided your consent to Google, Facebook, Instagram or Twitter (the “Social Ad Platforms”) to be provided with personalized commercial offers, you may be served with ads (including advertisements of third parties) based on your access to the Services, outside of the Services and across the internet. In such event, the Social Ad Platforms, will place cookies on your web browser and use such cookies to serve you ads based on past visits to our Services.

Please visit the Social Ad Platforms Privacy policy to find out how they use such information:

  • Mobile Device Identifiers. Mobile device identifiers help Happi learn more about our users’ demographics and internet behaviors. Mobile device identifiers are data stored on mobile devices that may track mobile device and data and activities occurring on and through it, as well as the applications installed on it. Mobile device identifiers enable collection of Personal Information (such as media access control, address and location, and tracking data, including without limitation IP address, domain server, type of device(s) used to access the Services, web browser(s) used to access the Services, referring webpage or other source through which you accessed the Services, other statistics and information associated with the interaction between your browser or device and the Services).
  • Cross Device Matching. To determine if users have interacted with content across multiple devices and to match such devices, we may work with partners who analyze device activity data and/or rely on your information (including demographic, geographic and interest-based data). To supplement this analysis, we may also provide de-identified data to these partners. Based on this data, we may then display targeted advertisements across devices that we believe are associated or use this data to further analyze usage of Services across devices.
CHANGING YOUR DATA COLLECTION SETTINGS

We strive to provide you with choices regarding the Personal Information you provide to us. You may need to adjust the settings on your computer and/or device to restrict the collection of information by the Services, but this may prevent you from accessing all of the features of the Services.

  • Tracking Technologies: You may be able to set your browser or device to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the Services may then be inaccessible or not function properly.
  • Location Information: You can choose whether or not to allow the Services to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some parts or all of the Services may be inaccessible or not function properly.
  • Social Ad Platforms: If you wish to opt-out of re-targeting and tracking functionality of the Social Ad Platforms, you may do so through each platform directly. PLEASE NOTE that these tracking and targeting by Social Ad Platforms, is provided pursuant to your engagement with the Social Ad Platforms and the actual nature and scope of Personal Information collection and processing performed by such Social Ad Platforms may not be fully known to us. If you would like to learn more or make further inquiries with respect to such nature or scope, please refer to each Social Ad Platforms directly.

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You may also be able to reject mobile device identifiers by activating the appropriate setting on your mobile device. You can also delete all Cookies that are already on your computer. Although you are not required to accept Happi’s Cookies, if you block, reject, or delete them, you may have to manually adjust some preferences every time you visit a site and some of the Services and functionalities may not work.

THIRD-PARTY AUTOMATIC INFORMATION COLLECTION

When you use the Services or its contents, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:

  • Advertisers, ad networks and ad servers;
  • Analytics companies;
  • Your mobile device manufacturer;
  • Your mobile service provider; and/or
  • Your Internet provider.

These third parties may use tracking technologies to collect information about you when you use the Services. The information they collect may be associated with your Personal Information or they may collect information about your online activities over time and across different websites, mobile applications and other online sites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

HOW WE USE YOUR INFORMATION

The below describes how your data – which includes web use, app use, demographic information, survey responses and information we have obtained from third parties – contributes to the kinds of services our clients buy from Us.  Our typical process is to combine Participants data into consumer segments and to report on the aggregated (or grouped) results. Consumer segments are pools of users who have common interests or characteristics. For example, “women between the ages of 28-34 interested in travel websites”. Once aggregated, the results and consumer segments are shared with our clients and other parties as described in this Policy. The following are examples of the kinds of services we provide, and how your data is used in these services:

  • Advertising Research: Your data is combined with data from other users into a pool that is then analyzed for exposure to certain advertising. Information about the combined pool, which does not identify any particular user, is shared with clients so they can understand if and how their advertising spending impacts the consumer journey and consumer decisions. For example, by comparing the behaviors of a group of users who saw a particular online advertisement with another group of users who did not see that advertisement, we can help advertisers understand the effectiveness of their ads.  The Application may also modify or replace content or ads that you see, as part of a market research study.
  • Media Use Analysis:  Your data is combined with data from other users to form consumer segments that are shared with clients without identifying any particular user. These segments are typically analyzed on behalf of clients to understand where consumers go online and how consumers interact with digital media, which includes website content, apps and advertising that they see. For example, we help companies understand the effectiveness of their websites or apps by comparing how users are interacting with their websites or apps versus how users are interacting with their competitors’ websites or apps.
  • Social Media Content: Your data is combined with data from other users to form consumer segments that are shared with clients without identifying any particular user. These segments are typically analyzed on behalf of clients to understand the incidence rate of hate speech, misinformation, fake news or other potentially harmful or malicious content distributed on that platform and the adjacency of that content to specific advertisements.
  • User-Level Data: On occasion, we may share user-level data we collected from you with third parties (including affiliates), for purposes beyond the specific examples noted in this Policy. User-level data is information that is associated with your specific device and is not aggregated with other data. For example, we may share data with a third-party that reveals that you have viewed certain sites or used certain apps or features, but you will not be personally identified with such information. Rather, the user-level data will be associated with an identifier (such as user “X”). We prohibit the third parties with whom we share such user-level data from trying to uncover the actual identity of “X”.
  • Targeted Surveys:  We may send you invitations to participate in surveys on the basis of your online behavior collected by the Application or merely based upon your participation in the Program. For example, if you visit sites that suggest you enjoy travel, we may send you a survey regarding travel services. We may provide our clients with some or all of the responses to these surveys without directly identifying any particular user, including specific answers and quotes from individual respondents.
  • Other data usages: We also may use your information for purposes of maintaining the configuration and proper functioning of the Application, for database or Application services (such as customer support, email, or surveys), and for purposes of data quality and data cleansing

As part of the registration process prior to installation of the Application or in connection with your participation in a survey or other service, we may directly collect information such as your name, telephone number, email address, birth year, household information, income, gender, and ethnicity. This information is part of your consumer profile and used as described above. See the below chart as an example of the types of data collected and processed depending on the case-type where the data is used:

Case

Market Research

Purpose

To understand your views about certain products and services or to understand your behaviour in different situations

Data Collected/Processed

Identifier, registration information, survey responses, mobile monitoring data, images or videos you may upload.

Case

Social media safety monitoring

Purpose

Measuring the incidence rates of hate speech, misinformation or other potentially harmful or malicious content appearing your social media feeds. This information is used to help social media platforms and their advertisers protect people and brands from exposure and adjacency to such content

Data Collected/Processed

Identifier, registration information, survey responses, mobile monitoring data, images or videos you may upload.

Case

Social Media Addiction Monitoring

Purpose

Ensuring you, your parents, or other guardian are aware of the times, frequency and duration of your interaction with social media

Data Collected/Processed

Identifier, registration information, survey responses, mobile monitoring data, images or videos you may upload.

Case

Safety monitoring (Pharmacovigilance Adverse Events Reporting)

Purpose

Report Adverse Events during our studies to competent authorities

Data Collected/Processed

Identifier, contact details, email address, disease, treatment, product taken and adverse events

Case

Public Disclosure

Purpose

To share or disclosed pursuant to judicial or other government subpoenas, warrants, orders or pursuant to similar and other legal or regulatory requirements, we will provide such information to the appropriate authorities.

Data Collected/Processed

Identifier, name, contact details, email address, incentive received.

Case

Fraud Protection

Purpose

Protection of our business interests against fraudulent behaviour or behaviour not in line with our Terms and Conditions

Data Collected/Processed

IP address, browser specifications, device specifications, postal addresses, email addresses, official identification number (i.e. ME number)

Case

Survey Participation Uniqueness

Purpose

Prevention of multiple entries in surveys by the same individuals in line with our Terms and Conditions

Data Collected/Processed

IP address, browser specifications, device specifications

Case

Tracking of the Answers of Recurring Respondents

Purpose

When you participate in surveys related to the Program, we typically use a persistent ID. This means that your survey responses will always be connected to the data we hold on file about you. This helps us understanding how your opinion evolves over time and also linking data we have collected from your through different sources. Your survey responses will be considered as personal data and you will have the right to access them.

Data Collected/Processed

Persistent identifier

Case

Advertising Targeting and Media Buying Research

Purpose

We use your personal data to help our clients and vendors enrich their data by using lookalike modelling techniques.

 

Data Collected/Processed

Persistent unique identifier, contact details, email address, social login, cookie, mobile device ID, official identification number (i.e. ME number)

Case

Ad Exposure and Measurement

Purpose

We will identify what advertisements you may have been exposed to on apps and browser as well as TV and radio ad audio detected via the mic on your phone and then use your survey response or mobile monitoring data to measure how advertising effects your brand attitudes, brand recall, and purchases.

Data Collected/Processed

Identifier, registration information, survey responses, mobile monitoring data, Mobile Device ID, Mobile Advertiser ID, Facebook or other social media ID.

HOW WE DISCLOSE YOUR PERSONAL INFORMATION

The Personal Information you provide to us whether voluntarily or automatically, may be used and disclosed without limitations, in the following instances:

  • With our customers who purchase our services (who are required to protect the Personal Information);
  • With vendors who provide services for us (who are required to protect the Personal Information);
  • To report or collect on debts owed to us;
  • To a prospective buyer or buyer of Happi, or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all our assets;
  • As part of bankruptcy, liquidation or similar proceeding;
  • To comply with legal requirements for the enforcement of law, regulations, court orders, subpoena, a warrant during the course of a legal proceedings or otherwise;
  • To protect and safeguard our copyright, trademarks, legal rights, intellectual property rights or safety; or
  • In response to a subpoena, or similar legal process, including to law enforcement agencies, regulators, and courts in the United States.
HOW WE DISCLOSE YOUR NON-PERSONAL INFORMATION

We may also disclose Non-Personal Information:

  • For the same reasons, we might share Personal Information;
  • With our advertisers for their own analysis and research;
  • To facilitate targeted content and ads; or
  • With Third-Party Ad Servers to place our ads on the Services and on third-party websites or mobile applications.
HOW TO ACCESS, UPDATE, WITHDRAW CONSENT OR DELETE YOUR INFORMATION

If the laws applicable to you grant you such rights, you may ask to access, correct, or delete your Personal Information that is stored in our systems or that we otherwise control. You may also ask for our confirmation as to whether or not we process your Personal Information or ask to withdraw any consent you have previously provided to Happi in connection with our use and processing of your Personal Information. Subject to the limitations in law, you may request that we update, correct, or delete inaccurate or outdated information. You may also request that we suspend the use of any Personal Information the accuracy of which you contest while we verify the status of that data.

If you wish to exercise any of these rights or withdraw your consent, please contact us at: support@happi.sg. When handling these requests, we may ask for additional information to confirm your identity and your request. Please note, upon request to delete your Personal Information, we may retain such data in whole or in part to comply with any applicable rule or regulation and/or response or defend against legal proceedings versus us or our affiliates, or as we are otherwise permitted under such law applicable to you. While we strive to honor all reasonable requests, please be aware that we backup the data to prevent accidental or malicious destruction of your information. Information on backup servers may take some time to be completely deleted from the system. If you request that we remove you from our system and delete all your information, please note that you may still receive materials while your request is being processed.

If you request that your information be deleted, we will keep your information for a period of time in order to deter fraud. However, if you request to delete your information, your Personal Information will not be used by us or our third- party providers for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required by law, or in accordance with this Privacy Policy.

SECURITY AND DATA RETENTION

The security of your Personal Information is important to us. We seek to protect your Personal Information from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Information and how we are processing that data. We endeavor to follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and in storage. For example, the Services use industry standard Secure Sockets Layer (SSL) technology to allow for the encryption of Personal Information. We store and process your information on our servers in the United States and abroad. We maintain what we consider industry standard backup and archival systems. Although we work to protect the security of the data that we hold in our records, for example, by making good faith efforts to store Personal Information in a secure operating environment that is not open to the public, please be aware that no method of transmitting data over the Internet or storing data is completely secure. We cannot and do not guarantee the complete security of any data you share with us, and except as expressly required by law, we are not responsible for the theft, destruction, loss or inadvertent disclosure of your information or content.

If at any time during or after our relationship we believe that the security of your Personal Information may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we will endeavor to notify you as promptly as possible under the circumstances.  If we have your e-mail address, we may notify you by e-mail to the most recent e-mail address you have provided us.  If you receive a notice from us, you can print it to retain a copy of it. To receive these notices, you must check your e-mail account using your computer or mobile device and email application software. You consent to our use of e-mail as a means of such notification. If you prefer for us to use the U.S. Postal Service to notify you in this situation, please e-mail us at support@happi.sg. Please include your address when you submit your request. You can make this election any time, and it will apply to notifications we make after a reasonable time thereafter for us to process your request. You may also use this e-mail address to request a print copy, at no charge, of an electronic notice we have sent to you regarding a compromise of your Personal Information.

We retain Personal Information about you consistent with all internal policies and procedures. We may retain Personal Information to comply with our legal obligations, resolve disputes or collect fees owed, or as is otherwise permitted or required by our data retention policies and procedures.

WHERE WE STORE YOUR PERSONAL DATA

For personal data which is subject to the GDPR and transferred to a country or territory outside the European Economic Area (EEA), we shall put adequate safeguards in place to ensure the transfer is made by a lawful method for the purposes of EU data protection law and secure. For data, which is not subject to the GDPR, Happi shall strictly follow any other applicable data protection laws.

Data is collected and transmitted by the Application from your device to Happi, whose servers are hosted on Amazon Web Services in data centers located in the European Union, United States, and Singapore.

By using the Application, you freely and specifically give us your consent to export your personally identifiable information to the USA, Singapore, United Kingdom, and/or European Union countries and to store and use it in those countries as specified in this Policy. You understand that our data is subject to lawful requests by the courts or law enforcement authorities in the countries in which we operate.

We take appropriate technological and organizational measures to protect your personal data, both during transmission and once we receive it. Our security procedures are consistent with generally accepted standards used to protect personal data. All our employees are contractually obliged to follow our policies and procedures regarding confidentiality, security and privacy. Your account information and personal data are password-protected so that you and only you have access to your information. In order to keep your personal data safe, we recommend that you do not divulge your password to anyone. We will never ask you for your password in an unsolicited phone call or in an unsolicited email.

COMPLIANCE WITH APPLICABLE LAWS AND REGULATIONS

We represent and warrant that we will comply with all applicable laws, rules, regulations, directives and guidelines regarding the collection, use and disclosure of data collected from or about Users or specific devices which apply to the services utilized hereunder (collectively, the “Rules”).  The term “Rules” shall include, without limitation, (i) United States Federal Trade Commission Laws regarding the collection, use and disclosure of data from or about users and/or specific devices; (ii) the Children’s Privacy Protection Act of 1998 (COPPA); (iii) The California Consumer Privacy Act of 2018  (“CCPA”) and (iv) if applicable, the Rules of any other jurisdiction, including and European Union General Data Protection Regulation (“EU GDPR”), rules, regulations and/or directives promulgated by a pertinent Data Protection Act, and all amendments and updates to them or regulations as replaced or superseded from time to time.

CALIFORNIA ‘DO NOT SELL MY INFO’ NOTICE

Like many companies online, we work with Google, Facebook and other companies that use information collected from cookies and similar technologies to try to make the ads you see online more relevant to your interests.  This is called interest-based advertising. Our use of these services may constitute a “sale” of Personal Information as defined under the California Consumer Protection Act (CCPA).  You can opt-out of the use of your information for interest-based advertising by:

  • Browser settings.  Blocking third party cookies in your browser settings.
  • Privacy browsers/plug-ins. Using privacy browsers or ad-blocking browser plug-ins that let you block advertising trackers.
  • Platform settings. Using the opt-out settings offered by some of the advertising companies that we work with.
  • Ad industry tools. Opting out of interest-based ads from companies participating in the following industry opt-out programs:

Mobile settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes. You will need to apply these opt-out settings on each device from which you wish to opt-out.  Not all companies that serve interest-based ads participate in these opt-out programs, so even after opting-out, you may still receive some cookies and interest-based ads from other companies.  If you opt-out of interest-based advertisements, you will still see advertisements online, but they may be less relevant to you.

Our sharing of information with the data providers described above may also constitute “sales” as defined under the CCPA.  You may submit a request to opt-out of this information sharing by sending an email to support@happi.sg with “Privacy” in the subject line.

The above describes our practices currently and during the 12-month period preceding the date on which this Privacy Policy was last updated.

Your CCPA rights. As a California resident, you have the following rights as of January 1, 2020:

  • Information.  You can request the following information about how we have collected and used your Personal Information during the past 12 months:
    • The categories of Personal Information that we have collected.
    • The categories of sources from which we collected Personal Information.
    • The business or commercial purpose for collecting and/or selling Personal Information.
    • The categories of third parties with whom we share Personal Information.
    • Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information disclosed to each category of third-party recipient.
    • Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third-party recipient. 
  • Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.

  • Deletion. You can ask us to delete the Personal Information that we have collected from you.

  • Opt-out. You can opt-out of any “sale” of your Personal Information as defined in the CCPA.
  • Non-discrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA. 

You may submit a request to exercise your right to information, access or deletion by emailing support@happi.sg with “Privacy” in the subject line.  We reserve the right to confirm your California residency to process these requests and will need to confirm your identity.  Government-issued identification may be required.  You may designate an authorized agent to make a request on your behalf by providing a valid power of attorney or other proof of authority acceptable to us in our reasonable discretion, the requester’s valid government-issued identification, and the authorized agent’s valid government-issued identification.  You can submit a request to opt-out of sales of your Personal Information as described above.  We cannot process your request if you do not provide us with sufficient information to allow us to understand and respond to it.  In certain cases, we may decline your request as permitted by law.

NEVADA PRIVACY OF INFORMATION COLLECTED ON THE INTERNET COLLECTED FROM CONSUMERS ACT

Effective October 1, 2019, the NPICICA law allows persons to opt out of the sale of certain personal information (called “covered information”) to third parties.  This includes information such as your name, address, social security number, and online service activity. A data sale under the Nevada law means the exchange of “covered information “for monetary consideration by the operator to a person for the person to license or sell the covered information to additional persons. However, “Sale” does not include:

  • Disclosures to service providers;
  • Disclosures at consumer’s request;
  • Disclosures for purposes which are consistent with the reasonable expectations of a consumer considering the context;
  • Disclosure affiliates of Happi; or
  • Disclosures in the context of M&A operations and/or bankruptcy proceedings.

IF you are a resident of Nevada, and do not want any Covered Information exchanged with a third-party for monetary consideration you may opt-out by sending an email at support@happi.sg with “Nevada Resident Opt-Out” on the subject line.

CHILDREN’S PRIVACY

The Services are not directed to or intended for use by children under 13 years of age. If you are a child under the age of 18, please do not attempt to register for or otherwise use the Services or send us any Personal Information. By accessing, using and/or submitting information to or through the Services, you represent that you are not under the age of 13. As noted in the Terms and Conditions, we do not knowingly collect or solicit Personal Information from children under the age of 18. If we learn that we have received any Personal Information directly from a child under age 18 without first receiving his or her parent’s verified consent, we will use that Personal Information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Services. We will then subsequently delete that child’s Personal Information. If you believe that a child under 18 may have provided us with Personal Information, please contact us at support@happi.sg.

UPDATES TO THIS POLICY

We reserve the right to change, modify, update, add, or remove portions of this Privacy Policy at any time. Any changes or updates will be effective immediately upon posting to this page. When we do update it, for your convenience, we will make the updated policy available on this page. If you opt out of receiving communications, you may not receive certain notifications, however, they will still govern your use of the Services, and you are responsible for proactively checking for any changes. We encourage you to check this Privacy Policy frequently to stay up to date on any changes. You can determine if changes have been made by checking the effective date on the Privacy Policy.

However, if any material change is made to this Privacy Policy, we will notify you of that change via email. Continued use of the Services after the effective date of any change in this Privacy Policy will constitute acceptance of such changes and it will signify that you agree to abide by and be bound by the modified Privacy Policy.

We will always display the most up-to-date policy on this web page.

CONTACT US

If you have questions, comments, or concerns regarding this Privacy Policy, please contact us and we will respond to your request within a reasonable timeframe. Please include the following information in your request (a) Your name; (b) Your contact information, including phone number and email address; and (c) The precise nature of your request, inquiry, or complaint.

You may contact us at:

Happi PTE LTD.

By Email: support@happi.sg

By Mail: 24 Raffles Place, #10-05 Clifford Centre, Singapore 048621