POLICIES
Privacy Policy
1- General information
This privacy statement (“Privacy Statement”) specifies how Happitech B.V. (hereinafter referred to as “Happitech”, "we", "us", "our") handles personal data of its users (''Users'', ''you'') to offer its services via the Happitech Heart Rhythm App (hereinafter referred to as ‘’App’’).
2- Who is responsible for the processing of your personal data?
Happitech is responsible for the processing of personal data as outlined in this Privacy Statement. Happitech therefore acts as data controller within the General Data Protection Regulation (“GDPR”). The App is owned and operated by Happitech B.V. Regarding the processing of personal data through the tool that Happitech offers, Happitech acts as a data processor.
Happitech is an entity incorporated under the laws of the Netherlands and registered in the Netherlands with the Dutch Chamber of Commerce under registration number 62365835.
3- Which personal data do we process?
In providing our App, we may process the following personal data of our Users:
Types of personal data
Heart rate information:
● BPM value
● Confidence of heart rate estimation
● Number of good heartbeats
● Time values
● RR Intervals (average and values, root mean square)
● Quality and confidence of the RR intervals
● Completeness of measurement
Purpose (see below)
2, 5
Device information:
● Device Type
● Device OS
● Camera Setting
● Battery Level
● Light Level
● Version of the Algorithm being used
1
Raw Data:
● Timestamp of each frame
● Red, blue and green value of each frame
● X and Y acceleration of each frame
● ISO/Exposure/Ambient light of each frame
● Logging main/statuses/warning/errors/Logging camera setting changes during of calibration
2
Contact information:
Contact information:
● User ID (optional functionality provided by Module)
● Any contact information you might share (full name, (work) e-mail address, phone number);
● E-mail communication (e.g. your message to us);
● Other inquires via our App or customer support.
1
Data collected through analytics:
● Automatically collected events:
o First app launch
o Session start
o User engagement metrics
o Screen/page views
o App updates
o OS updates
● Technical data:
o App instance ID (unique installation identifier)
● Behavioural data:
o Time spent in app
o App usage frequency
o User flow through app screens
o Session duration
● Network & platform data:
o App store source
o Campaign attribution data
● User demographics*:
o Approximate age
o Gender
o Interests
o Geographic location (city/region based on IP)
* = All of this data may be unavailable or inaccurate, especially if the user doesn't actively use Google services or uses private/privacy-focused settings.
2, 4
4- What are the purposes and legal grounds of processing?
We may only process your personal data if we have a valid legal ground to do so. The GDPR specifically states these legal grounds. In the case of Happitech these are usually: explicit consent, compliance with a legal obligation and sometimes legitimate interest.
As part of providing our App, we process personal data, including special categories of personal data such as health-related information. The legal basis for this processing is either your explicit consent, or, where applicable, compliance with a legal obligation under the Medical Device Regulation (MDR). Personal data that are used for our internal research and analysis (statistical purposes) are processed on the basis of your consent.
We processes personal data of customers with contracts primarily for the purpose of providing our App on the basis of performance of a contract or our legitimate interests to conduct a normal business.
We will only process personal data based on legitimated interest if our interests outweigh the privacy interests of the person to whom the data relates. In that case, the legitimate interests of Happitech correspond to the purposes set out below. For further information on the balancing of interests in a specific case, please contact us using the contact details at the bottom of this Privacy Statement. It may also be the case that Happitech has to process personal data to comply with an applicable legal obligation, for example to meet applicable minimum retention periods.
It may also be necessary in exceptional cases to process personal data to protect someone's vital interests. This may be the case, for example, in the unlikely event that someone falls unconscious at the Happitech office and health data must be provided to a care provider. If Happitech cannot rely on one of the aforementioned bases, consent must be obtained for the processing of personal data.
Happitech will inform you in a specific situation if providing personal data is a legal or contractual obligation or necessary condition for entering into an agreement. It will also inform you of the possible consequences of not providing the data.
Happitech processes the personal data included in subsection 3 for the following purposes and on the basis of the relating legal grounds:
Purpose
1- To enter into and for the performance of agreements, with regard to our App.
Legal ground
Necessary for performance of the agreement (article 6(1)(b) GDPR)
2- To offer, maintain, secure and improve our App.
Explicit consent (Article 9(2)(b) GDPR) jo article 6(1)(a) GPDR/ Comply with a legal obligation (Article 6(1)(c) GDPR)
3- To have and maintain contact with you, for example, through our contact form and to provide customers support.
Consent (Article 6(1)(a) GDPR)
4- To establish, exercise and defend our rights.
Legitimate interest (Article 6(1)(f) GDPR)
5- To comply with applicable laws and regulations or an injunction or request from authorized regulators or other government agencies.
Comply with a legal obligation (Article 6(1)(c) GDPR)
5- How do we obtain your personal data?
We obtain your personal data in various ways:
● Provided by you. Some personal data we receive straight from you. For example, if you fill out a contact form on the App.
● Through the use of the App. For example, we may process your IP address or data about your use of our App (log data). Sometimes we process personal data not on our own initiative, but to comply with a legal obligation incumbent on us. This is the case, for example, when we retain personal data for a longer period in order to comply with a legal retention obligation.
In principle you are under no obligation to provide any information about yourself to us. However, refusal to supply certain information could have a negative influence on, for example, your experiences on or functionality of our App. If the provision of certain personal data is a legal or contractual obligation or an essential requirement for concluding an agreement with us, we will separately provide additional information about this for as far as this is not clear in advance. In this case we will also inform you about the possible consequences if this information is not provided.
6- Under which circumstances and with whom do we share your personal data?
We could share your personal data on a need-to-know basis with the parties mentioned below. In this context, "need-to-know" means that a party only gets access to personal data if and insofar as this is required for the professional App provided by this party. We only share your personal data with third parties if:
● This is necessary for the provision of a service or the involvement of the third party. Sub-contractors, for example, will in principle only get access to the personal data that they require for their part of the service provision.
● The persons within the third party that have access to the personal data are under an obligation to treat the personal data confidentially. Where necessary this is also contractually agreed upon.
● The third party is obliged to comply with the applicable regulations for the protection of personal data, for instance because we have concluded an agreement with this party. This includes that the party is obliged to ensure appropriate technical and organizational security measures, and that any transfer of personal data to countries outside the European Economic Area (“EEA”) is adequately legitimized.
We may share your personal data with the following parties:
● Authorized persons, employed by Happitech, who are involved with the processing activity concerned. Such as, the members of the customer support team you are in contact with.
● Authorized persons, employed by service providers / sub-contractors engaged by Happitech, who are involved with the processing activity concerned.
● Authorized government institutions. Such as, courts, police, and law enforcement agencies. We may release information about our App visitors, including IP address, when legally required to do so, at the request of governmental institutions conducting an investigation or to verify or enforce compliance with the policies governing the our App and applicable laws. We may also disclose such user information whenever we believe disclosure is necessary to protect the rights, property or safety of Happitech, or any of our respective business partners, customers or others.
7- To which countries do we transfer your personal data?
We do not transfer personal data to parties located outside the EEA.
8- How do we protect your personal data?
Protecting your privacy and personal data is very important to us. Therefore, Happitech has implemented appropriate technical and organizational measures to protect and secure the personal data we process, in order to prevent violations of the confidentiality, integrity and availability of data. This includes applying privacy by design principles in the development of our App. Furthermore, users of the App are not linked to individual accounts, meaning that the personal data collected is pseudonymised and cannot be directly traced back to you.
In addition, a data breach procedure is applicable within Happitech. In the event we become aware that the security of App has been compromised or Users’ Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the User as a result of the breach or if notice is otherwise required by law. When we do, we will post a notice in the App, send you an email.
We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of personal data in our control and custody. However, no data transmission over the Internet or wireless network can be guaranteed.
9- What are your privacy rights?
In relation to the processing of your personal data by Happitech, you have the following privacy rights:
a. Right of access. This concerns the right to request access to your personal data. This enables the you to receive a copy of the data we hold about you (but not necessarily the files themselves). We will then also provide further specifics of our processing of the personal data. For example, the purposes for which we process the data, where we got it from, and with whom we share it.
b. Right to rectification. This concerns the right to request rectification of the data that we hold about you. This enables you to have any incomplete or inaccurate data corrected.
c. Right to erasure. This concerns the right to request erasure of the data. This enables you to ask us to delete or remove personal data where: (i) the data is no longer necessary, (ii) the processing activities have been objected to, (ii) the data has been unlawfully processed, (iv) the data has to be erased on the basis of a legal requirement, or (v) where the data has been collected in relation to the offering of information society App. However, we do not have to honour such request in all cases.
d. Right to object. This concerns the right to object to the processing of personal data where we are relying on legitimate interest as processing ground (see above). Insofar as the processing of the data takes place for direct marketing purposes, we will always honour an objection. For processing for other purposes, we will also cease and desist processing, unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms or that are – for example - related to the institution, exercise or substantiation of a legal claim. If such is the case, we will inform on our compelling interests and the balance of interests made.
e. Right to restriction. The right to restriction of processing means that Happitech will continue to store personal data at the request of you but may in principle not do anything further with it. In short, this right can be exercised when Happitech does not have (or no longer has) any legal grounds for the processing of the data or if this is under discussion.
f. Automated decision-making. This concerns the right not to be subject to a decision based solely on automated processing, which significantly impacts you. In this respect, please be informed that when processing your data, we do not make use of automated decision-making.
g. Right to withdraw consent. This concerns the right to withdraw consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
h. Right to complaint. This concerns the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, place of work or where an alleged infringement took place. Please be referred to the App of the European Data Protection Board (“EDPB”) for an overview of the supervisory authorities and their contact details. However, we would appreciate the chance to deal with any concerns before the supervisory authority is approached, so please contact us beforehand.
10- How to exercise your privacy rights?
You can exercise the privacy rights above free of charge, by phone or by e-mail via the contact details displayed below. If requests are manifestly unfounded or excessive, in particular because of the repetitive character, we have the right to either charge a reasonable fee or refuse to comply with the request. In addition, we may request specific information to help us confirm your identity before we further respond to a privacy request. Finally, we will provide information about the follow-up of the request without undue delay and in principle within one month of receipt of the request. Depending on the complexity of the request and on the number of requests, this period can be extended by another two months.
11- How long do we keep your personal data?
You can exercise the privacy rights above free of charge, by phone or by e-mail via the contact details displayed below. If requests are manifestly unfounded or excessive, in particular because of the repetitive character, we have the right to either charge a reasonable fee or refuse to comply with the request. In addition, we may request specific information to help us confirm your identity before we further respond to a privacy request. Finally, we will provide information about the follow-up of the request without undue delay and in principle within one month of receipt of the request. Depending on the complexity of the request and on the number of requests, this period can be extended by another two months.
11- How long do we keep your personal data?
In general, Happitech does not keep personal data for longer than is necessary in relation to the purposes for which we process the personal data. There could, however, be exceptions applicable to the general retention terms. In view hereof, shorter retention periods could apply: if an individual exercises certain privacy rights, it is possible that we retain it for a shorter period of time. Longer retention periods could also apply. In certain situations, we process personal data of individuals for a longer period of time than what is necessary for the purpose of the processing. This is for instance the case when we have to process personal data for a longer period of time:
● Retention obligation - to comply with a minimum retention period or other legal obligation to which Happitech is subject based on EU law or the law of an EU member state;
● Procedure - personal data which is necessary in relation to a legal procedure;
● Freedom of expression - when further processing of personal data is necessary in order to exercise the right to freedom of expression and information.
12- Contact information
If you have any questions regarding this Privacy Statement, or data collection by Happitech in particular, please contact us at patientsupport@happitech.com or by using the contact information below:
Happitech B.V.
Hofplein 20
3032 AC Rotterdam
The Netherlands
13- Changes to this Privacy Statement
Occasionally, we may need to update or change this Privacy Statement. In case of important changes, we will inform you in an appropriate manner and ask you to take note of the changes made. The latest version of the Privacy Statement is always available in our App.
This Privacy Statement was updated September 2025.
Collection of personal information
You can access and use the Website and Services without telling us who you are or revealing any information by which someone could identify you as a specific, identifiable individual. If, however, you wish to use some of the features offered on the Website, you may be asked to provide certain Personal Information (for example, your name and e-mail address).
We receive and store any information you knowingly provide to us when you fill any online forms on the Website. When required, this information may include the following:
• Contact information (such as email address, phone number, etc)
• Basic personal information (such as name, country of residence, etc)
Some of the information we collect is directly from you via the Website and Services. However, we may also collect Personal Information about you from other sources such as public databases and our joint marketing partners.
You can choose not to provide us with your Personal Information, but then you may not be able to take advantage of some of the features on the Website. Users who are uncertain about what information is mandatory are welcome to contact us.
Privacy of children
We do not knowingly collect any Personal Information from children under the age of 18. If you are under the age of 18, please do not submit any Personal Information through the Website and Services. If you have reason to believe that a child under the age of 18 has provided Personal Information to us through the Website and Services, please contact us to request that we delete that child’s Personal Information from our Services.
We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through the Website and Services without their permission. We also ask that all parents and legal guardians overseeing the care of children take the necessary precautions to ensure that their children are instructed to never give out Personal Information when online without their permission.
Use and processing of collected information
We act as a data controller and a data processor in terms of the GDPR when handling Personal Information, unless we have entered into a data processing agreement with you in which case you would be the data controller and we would be the data processor.
Our role may also differ depending on the specific situation involving Personal Information. We act in the capacity of a data controller when we ask you to submit your Personal Information that is necessary to ensure your access and use of the Website and Services. In such instances, we are a data controller because we determine the purposes and means of the processing of Personal Information and we comply with data controllers’ obligations set forth in the GDPR.
We act in the capacity of a data processor in situations when you submit Personal Information through the Website and Services. We do not own, control, or make decisions about the submitted Personal Information, and such Personal Information is processed only in accordance with your instructions. In such instances, the User providing Personal Information acts as a data controller in terms of the GDPR.
In order to make the Website and Services available to you, or to meet a legal obligation, we may need to collect and use certain Personal Information. If you do not provide the information that we request, we may not be able to provide you with the requested products or services. Any of the information we collect from you may be used for the following purposes:
• Improve products and services
• Send marketing and promotional communications
• Send marketing and promotional communications
• Respond to inquiries and offer support
• Request user feedback
• Improve user experience
• Deliver targeted advertising
• Run and operate the Website and Services
Processing your Personal Information depends on how you interact with the Website and Services, where you are located in the world and if one of the following applies: (i) you have given your consent for one or more specific purposes; this, however, does not apply, whenever the processing of Personal Information is subject to California Consumer Privacy Act or European data protection law; (ii) provision of information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof; (iii) processing is necessary for compliance with a legal obligation to which you are subject; (iv) processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us; (v) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.
We rely on the following legal bases as defined in the GDPR upon which we collect and process your Personal Information:
• User’s consent
Note that under some legislations we may be allowed to process information until you object to such processing by opting out, without having to rely on consent or any other of the legal bases above. In any case, we will be happy to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Disclosure of information
Depending on the requested Services or as necessary to complete any transaction or provide any Service you have requested, we may share your information with our affiliates, contracted companies, and service providers (collectively, “Service Providers”) we rely upon to assist in the operation of the Website and Services available to you and whose privacy policies are consistent with ours or who agree to abide by our policies with respect to Personal Information. We will not share any personally identifiable information with third parties and will not share any information with unaffiliated third parties.
Service Providers are not authorized to use or disclose your information except as necessary to perform services on our behalf or comply with legal requirements. Service Providers are given the information they need only in order to perform their designated functions, and we do not authorize them to use or disclose any of the provided information for their own marketing or other purposes.
Retention of information
We will retain and use your Personal Information for the period necessary to comply with our legal obligations, to enforce our agreements, resolve disputes, and unless a longer retention period is required or permitted by law up to a maximum of 60 months.
We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, Personal Information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after the expiration of the retention period.
Transfer of information
Depending on your location, data transfers may involve transferring and storing your information in a country other than your own, including USA. The transfer of your Personal Information to countries outside the European Union will be made only if you have explicitly consented to it or in the cases provided for by the GDPR and will be processed in your interest.
You are entitled to learn about the legal basis of information transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by us to safeguard your information. If any such transfer takes place, you can find out more by checking the relevant sections of this Policy or inquire with us using the information provided in the contact section.
Data protection rights under the GDPR
If you are a resident of the European Economic Area (“EEA”), you have certain data protection rights and we aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information. If you wish to be informed what Personal Information we hold about you and if you want it to be removed from our systems, please contact us. In certain circumstances, you have the following data protection rights:
(i) You have the right to withdraw consent where you have previously given your consent to the processing of your Personal Information. To the extent that the legal basis for our processing of your Personal Information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
(ii) You have the right to learn if your Personal Information is being processed by us, obtain disclosure regarding certain aspects of the processing, and obtain a copy of your Personal Information undergoing processing.
(iii) You have the right to verify the accuracy of your information and ask for it to be updated or corrected. You also have the right to request us to complete the Personal Information you believe is incomplete.
(iv) You have the right to object to the processing of your information if the processing is carried out on a legal basis other than consent. Where Personal Information is processed for the public interest, in the exercise of an official authority vested in us, or for the purposes of the legitimate interests pursued by us, you may object to such processing by providing a ground related to your particular situation to justify the objection. You must know that, however, should your Personal Information be processed for direct marketing purposes, you can object to that processing at any time without providing any justification. To learn whether we are processing Personal Information for direct marketing purposes, you may refer to the relevant sections of this Policy.
(v) You have the right, under certain circumstances, to restrict the processing of your Personal Information. These circumstances include: the accuracy of your Personal Information is contested by you and we must verify its accuracy; the processing is unlawful, but you oppose the erasure of your Personal Information and request the restriction of its use instead; we no longer need your Personal Information for the purposes of processing, but you require it to establish, exercise or defend your legal claims; you have objected to processing pending the verification of whether our legitimate grounds override your legitimate grounds. Where processing has been restricted, such Personal Information will be marked accordingly and, with the exception of storage, will be processed only with your consent or for the establishment, to exercise or defense of legal claims, for the protection of the rights of another natural, or legal person or for reasons of important public interest.
(vi) You have the right, under certain circumstances, to obtain the erasure of your Personal Information from us. These circumstances include: the Personal Information is no longer necessary in relation to the purposes for which it was collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure such as where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, to exercise or defense of legal claims.
(vii) You have the right to receive your Personal Information that you have provided to us in a structured, commonly used, and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance from us, provided that such transmission does not adversely affect the rights and freedoms of others.
(viii) You have the right to complain to a data protection authority about our collection and use of your Personal Information. If you are not satisfied with the outcome of your complaint directly with us, you have the right to lodge a complaint with your local data protection authority. For more information, please contact your local data protection authority in the EEA. This provision is applicable provided that your Personal Information is processed by automated means and that the processing is based on your consent, on a contract which you are part of, or on pre-contractual obligations thereof.
California privacy rights
Consumers residing in California are afforded certain additional rights with respect to their Personal Information under the California Consumer Privacy Act (“CCPA”). If you are a California resident, this section applies to you.
In addition to the rights as explained in this Policy, California residents who provide Personal Information as defined in the statute to obtain Services for personal, family, or household use are entitled to request and obtain from us, once a calendar year, information about the categories and specific pieces of Personal Information we have collected and disclosed.
Furthermore, California residents have the right to request deletion of their Personal Information or opt-out of the sale of their Personal Information which may include selling, disclosing, or transferring Personal Information to another business or a third party for monetary or other valuable consideration. To do so, simply contact us. We will not discriminate against you if you exercise your rights under the CCPA.
How to exercise your rights
Any requests to exercise your rights can be directed to us through the contact details provided in this document. Please note that we may ask you to verify your identity before responding to such requests. Your request must provide sufficient information that allows us to verify that you are the person you are claiming to be or that you are the authorized representative of such person. If we receive your request from an authorized representative, we may request evidence that you have provided such an authorized representative with power of attorney or that the authorized representative otherwise has valid written authority to submit requests on your behalf.
You must include sufficient details to allow us to properly understand the request and respond to it. We cannot respond to your request or provide you with Personal Information unless we first verify your identity or authority to make such a request and confirm that the Personal Information relates to you.
Cookies
Our Website and Services use “cookies” to help 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. Click here to learn more about cookies and how they work.
We may use cookies to collect, store, and track information for security and personalization, and for statistical purposes. For further information on the cookies we collect and their purpose, see our cookie policy. Please note that you have the ability to accept or decline cookies. Most web browsers automatically accept cookies by default, but you can modify your browser settings to decline cookies if you prefer.
Data analytics
Our Website and Services may use third-party analytics tools that use cookies, web beacons, or other similar information-gathering technologies to collect standard internet activity and usage information. The information gathered is used to compile statistical reports on User activity such as how often Users visit our Website and Services, what pages they visit and for how long, etc. We use the information obtained from these analytics tools to monitor the performance and improve our Website and Services. We do not use third-party analytics tools to track or to collect any personally identifiable information of our Users and we will not associate any information gathered from the statistical reports with any individual User.
Do Not Track signals
Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a website. For these purposes, tracking refers to collecting personally identifiable information from consumers who use or visit a website or online service as they move across different websites over time. How browsers communicate the Do Not Track signal is not yet uniform. As a result, the Website and Services are not yet set up to interpret or respond to Do Not Track signals communicated by your browser. Even so, as described in more detail throughout this Policy, we limit our use and collection of your Personal Information.
Advertisements
We may permit certain third-party companies to help us tailor advertising that we think may be of interest to Users and to collect and use other data about User activities on the Website. These companies may deliver ads that might place cookies and otherwise track User behavior.
Social media features
Our Website and Services may include social media features, such as the Facebook and Twitter buttons, Share This buttons, etc (collectively, “Social Media Features”). These Social Media Features may collect your IP address, what page you are visiting on our Website and Services, and may set a cookie to enable Social Media Features to function properly. Social Media Features are hosted either by their respective providers or directly on our Website and Services. Your interactions with these Social Media Features are governed by the privacy policy of their respective providers.
Email marketing
We offer electronic newsletters to which you may voluntarily subscribe at any time. We are committed to keeping your e-mail address confidential and will not disclose your email address to any third parties except as allowed in the information use and processing section or for the purposes of utilizing a third-party provider to send such emails. We will maintain the information sent via e-mail in accordance with applicable laws and regulations.
In compliance with the CAN-SPAM Act, all e-mails sent from us will clearly state who the e-mail is from and provide clear information on how to contact the sender. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting us.
Links to other resources
The Website and Services contain links to other resources that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other resources or third parties. We encourage you to be aware when you leave the Website and Services and to read the privacy statements of each and every resource that may collect Personal Information.
Information security
We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in our control and custody. However, no data transmission over the Internet or wireless network can be guaranteed.
Therefore, while we strive to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and the Website and Services cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.
Data breach
In the event we become aware that the security of the Website and Services has been compromised or Users’ Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the User as a result of the breach or if notice is otherwise required by law. When we do, we will post a notice on the Website, send you an email.
Changes and amendments
We reserve the right to modify this Policy or its terms related to the Website and Services at any time at our discretion. When we do, we will revise the updated date at the bottom of this page. We may also provide notice to you in other ways at our discretion, such as through the contact information you have provided.
An updated version of this Policy will be effective immediately upon the posting of the revised Policy unless otherwise specified. Your continued use of the Website and Services after the effective date of the revised Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Information in a manner materially different than what was stated at the time your Personal Information was collected.
Acceptance of this policy
You acknowledge that you have read this Policy and agree to all its terms and conditions. By accessing and using the Website and Services and submitting your information you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to access or use the Website and Services.
Contacting us
If you have any questions, concerns, or complaints regarding this Policy, the information we hold about you, or if you wish to exercise your rights, we encourage you to contact us using the details below:
https://www.happitech.com/contactus/
info@happitech.com
We will attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by applicable data protection laws.
This document was last updated on July 30, 2021