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Happify™ Privacy Policy: Last Updated January, 2020

Thank you for visiting the Happify™ website (the “Site”). The Site is an Internet property of Happify, Inc. (“Happify™,” “we” or “us”). This Happify™ Privacy Policy (“Privacy Policy”) sets out how we use, share and protect Personal Information (as hereinafter defined) and other information that we collect when you:

  1. access or use the Site;
  2. register to become a Member; and/or
  3. use the Happify™ Offerings including, without limitation, the Services and/or Promotions.

Capitalized terms not defined herein shall have the meaning set forth in the Happify™ Website Terms and Conditions (“Terms and Conditions”).

Except where noted, statements in this Privacy Policy with respect to the Site and Happify™ Offerings also apply to Happify™ mobile device applications ("Apps") for iPhone, iPad and Android devices.

If you have been given access to the Happify Offerings as a member, employee, client or customer (“Happify Health Program Client”) of a healthcare provider, health plan sponsor, or insurer or related organization or company (each a “Happify Health Program Company”), this Privacy Policy is not intended to modify any privacy policy provided by the Happify Health Program Company applicable to your personal health record.

YOU MUST AFFIRMATIVELY CONSENT TO USE OUR OFFERINGS, AND BY DOING SO, YOU CONSENT TO THIS PRIVACY POLICY AND THE USE OF YOUR PERSONAL INFORMATION AS STATED HEREIN. IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY AND THE USE OF YOUR PERSONAL DATA AS STATED HEREIN IN THEIR ENTIRETY, YOU MAY NOT ACCESS OR OTHERWISE USE THE SITE AND/OR HAPPIFY™ OFFERINGS.

We will only process your Personal Information in accordance with applicable data protection and privacy laws. For the purposes of UK and EU data protection legislation, the data controller is Happify, Inc., 51 E. 12th St., 5th Floor New York, NY 10003 (United States of America).

To review Happify™’s GDPR Commitment, click https://happify.com/public/legal/#gdrp-commitment.

You also have the right to object, the right to data portability, and the right to withdraw consent at any time. An individual who seeks access, or who seeks to correct, amend, object to or delete inaccurate data transferred to the United States under Privacy Shield or would like to exercise any other right under the European General Data Protection Regulation (the “GDPR”), should direct their query to support@happify.com. We will respond to such requests within a reasonable timeframe, and in any case within one month of receipt of the request.

Individuals have a right to lodge a complaint with the appropriate European Supervisory Authority, in particular in the EU Member State of his or her habitual residence, place of work or of an alleged infringement of the GDPR.

You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en

  1. 1. Information We Collect

    We collect three basic types of information and data: Personal Information, non-Personal Information, and aggregate data.

  2. 2. Personal Information Collected

    For the purposes of this Privacy Policy, Personal Information shall mean individually identifiable information from or about an individual. We collect Personal Information from you primarily in three (3) ways:

    1. when you register to become a Member on the Site;
    2. when you access the Site and provide information in connection with your use of the Happify™ Offerings or Happify™ Health program; or
    3. when you register to become a Member, or otherwise utilize certain aspects of the Happify™ Offerings, through and/or in connection with an account that you already have with certain third-party social media websites (“Social Media Websites”), such as Facebook® and Twitter®.

    In addition, when you access and/or use the Site and/or Happify™ Offerings, and based on our legitimate interest to improve the quality of the Happify™ Offerings, we may collect certain usage data, such as:

    1. the number of times that you visit the Site;
    2. the specific Happify™ Offerings accessed, as well as the frequency and duration of use associated with them; and
    3. other analyses and data associated with your access to, and use of, the Site and/or Happify™ Offerings (collectively, “Usage Data”).

    We also may collect information and responses you provide when participating in activities on the Site, which may include activity postings, survey responses, assessment responses and any other data you generate in using the Site and/or Happify™ Offerings (“User Responses”).

  3. 3. Site Registration

    The Personal Information that you must supply on the Site in order to obtain access to the Happify™ Offerings may include, without limitation:

    1. your full name;
    2. your e-mail address;
    3. your telephone number;
    4. your date of birth;
    5. your home address;
    6. your user name and password;
    7. a unique I.D. you receive from your healthcare company or health plan, your employee I.D. or other employer issued I.D.; and/or
    8. any and all other information requested on the applicable registration form (collectively, “Site Registration Data”).

  4. 4. Social Media Website Registration/Use

    The Personal Information that you make available to Happify™ when you register via your Facebook® account, or utilize certain Happify™ Offerings in connection with your Facebook® account, may include, without limitation, depending on the privacy settings associated with your Facebook® account:

    1. all or some of the information that comprises Site Registration Data as set forth above;
    2. your Facebook® ID;
    3. your Facebook® profile name;
    4. your Facebook® profile picture;
    5. your education history (as included in your Facebook® account);
    6. your interests (as included in your Facebook® account);
    7. the Facebook® photographs included in your Facebook® account;
    8. gender; and
    9. any and all other information made available to Happify™ by and through your Facebook® account (collectively, “Facebook® Registration Data”).

    The Personal Information that you make available to Happify™ when you register via your Twitter® account, or utilize certain Happify™ Offerings in connection with your Twitter® account, may include, without limitation, depending on the privacy settings associated with your Twitter® account:

    1. your Twitter® user ID;
    2. your Twitter® profile name;
    3. your Twitter® avatar; and
    4. any and all other information made available to Happify™ by and through your Twitter® account (collectively, “Twitter® Registration Data” and, together with the Site Registration Data and Facebook® Registration Data, the “Registration Data”).

    For purposes of this Privacy Policy, "Facebook" shall mean Facebook Inc. and "Twitter" shall mean Twitter, Inc. Facebook® is a registered trademark of Facebook Inc. Twitter® is a registered trademark of Twitter, Inc. Please be advised that Happify™ is not in any way affiliated with Facebook® or Twitter®, and the Happify™ Offerings are neither endorsed, nor sponsored, by Facebook® or Twitter®.

  5. 5. Use of Personal Information

    Based on our legitimate interest to improve the quality of the Happify™ Offerings, we may use your Usage Data, and share it with third parties:

    1. to assist us and such third parties in studying, evaluating and improving the Site and Happify™ Offerings;
    2. determine your preferences and tailor the Site and Happify™ Offerings to your needs; and
    3. so that we can promote the Site and Happify™ Offerings to third parties (using Usage Data on an aggregate and anonymous basis in that instance).

    If you are a Happify Health Program Client, we may share your Usage Data and Personal Information with your Happify Health Program Company to enable them to assess the efficacy of the Happify Offerings and Services. If your employer uses a third-party vendor to administer its program, we may provide your Usage Data to the third-party vendor, but the third-party vendor will not receive your Personal Information unless the third party-vendor has signed an agreement limiting its use of Personal Information to analytics demonstrating the effectiveness of the program. We may provide limited Usage Data on an aggregate and anonymous basis to your employer for analytical purposes. If your employer administers its own incentive program, we may provide limited data to your employer in connection with the employer’s incentive program, consisting of total points earned for completion of activities or tracks during the incentive period. We do not provide individual results, outcomes or activities associated with your account. We may also notify your employer if you win a prize in a Sweepstakes that Happify sponsors. If you hire a personal care manager, coach or therapist (a “Health Care Professional”) or elect to use a Health Care Professional under a program or service offered by a Happify Health Program Company, the Health Care Professional will be permitted to access your Usage Data and User Responses. By electing to use a Health Care Professional, you are consenting to the disclosure of this information to the Health Care Professional with whom you are working. The Health Care Professional is under a duty to maintain the confidentiality of this information and any other Personal Information you share with the Health Care Professional, and the Health Care Professional may not disclose this information to anyone else unless under a legal requirement to do so. Happify also has entered into agreements with private health care practices to which it may disclose Usage Data on an aggregate and anonymous basis.

    Other than in connection with the limited use of Usage Data and Personal Information as specified above, Happify™ will never sell, rent, exchange or barter your Personal Information to or with any third party for financial gain or marketing purposes. When you register as a Member, we use the Personal Information that you make available to personalize your experience with the Site, facilitate the delivery of the applicable Happify™ Offerings to you and for verification purposes. You also agree that, based on our legitimate interest referred to above, we may contact you at any time with updates and any other information that we may deem appropriate for you to receive in connection with your continued use of the Site and Happify™ Offerings, and to keep you informed of our other products and services. In addition, if you identify yourself to us by sending us an email or some other communication with questions or comments, we may use such information (including Personal Information) to respond to your questions or comments, and we may file your questions or comments for future reference. If you elect to participate in our coaching program, the coach will be permitted to access your user data, including happiness statistics, character strength assessment results, user posts and comments (public and private). By participating in the coaching program, you are consenting to the processing of your personal data, including special categories such as data concerning health, and to the disclosure of this information to any coach with whom you are working. The coach is under a duty to maintain the confidentiality of this information and any other Personal Information you share with the coach, and the coach may not disclose this information to anyone else unless under a legal requirement to do so.

    The Personal Information that you submit to Happify™ remains your property, but by making the Personal Information available to Happify™, you grant Happify™ the right, subject to applicable law, to use that Personal Information to bring you certain promotional offers from Happify™ and its third party partners that Happify™ believes may be of interest to you. If you wish to withdraw your consent, object to the use of Personal Information based on our legitimate interest or to stop receiving future communications from us, please see the section below entitled “Managing Your Settings.”

    We may permit our third-party agents, service providers, vendors and subcontractors (such as vendors and suppliers that provide us with technology, services, advertising and marketing assistance or content in connection with our operation and maintenance of the Site and Happify™ Offerings) to access Usage Data, but they are only permitted to do so in connection with performing services for us or to operate the Site and Happify™ Offerings. Third parties are not authorized to use your Personal Information for their own benefit. In addition, we may use, or permit third-party research partners to use, User Responses for research or data analysis purposes.

    We may also supplement the information that we collect with information from public, third-party private, or internal sources to assist us in evaluating and improving the Site and Happify™ Offerings, and to determine your preferences so that we can tailor the Site and Happify™ Offerings to your needs.

    Information that we collect about you also may be combined by us with other information available to us through third parties for research and measurement purposes, including measuring the effectiveness of content, advertising or programs. This information from other sources may include age, gender, demographic, geographic, personal interests, product purchase activity or other information. We may report aggregate information, which is not able to be identified back to an individual user of the Site, to our current or prospective advertisers and other business and research partners.

    We reserve the right to release current or past Personal Information:

    1. in the event that we believe that the Site and/or Happify™ Offerings is/are being or has/have been used in violation of the Terms and Conditions or to commit unlawful acts;
    2. if the information is subpoenaed; provided, however, that, where permitted by applicable law, we shall provide you with e-mail notice, and opportunity to challenge the subpoena, prior to disclosure of any Personal Information pursuant to a subpoena; or
    3. if Happify™ is sold, merged or acquired; provided, however, that if Happify™ is involved in a merger, acquisition or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on the Site of any change in ownership or uses of your Personal Information, as well as any choices that you may have regarding your Personal Information.

  6. 6. Interactive Services/Social Media Websites

    If you post a Comment, Activity Post or otherwise provide Personal Information by and through the Interactive Services, the Site and/or any applicable Social Media Website, you should be aware that any Personal Information that you submit using such forums can be read, collected or used by other users of these forums (depending on your privacy settings, in the case of Social Media Websites), and could be used to send you unsolicited messages or otherwise contact you without your consent or desire. We are not responsible for the Personal Information that you choose to submit in these forums. If you mistakenly post Personal Information in our public forums and would like it removed, you can send us an email to support@happify.com to request that we remove it. In some cases, we may not be able to remove such Personal Information.

    The Social Media Websites operate independently from Happify™, and we are not responsible for such Social Media Websites’ interfaces or privacy or security practices. We encourage you to review the privacy policies and settings on the Social Media Websites with which you interact to help you understand those Social Media Websites’ privacy practices. If you have questions about the security and privacy settings of any Social Media Websites that you use, please refer to their applicable privacy notices or policies.

    Further, by submitting Comments, Activity Posts and/or other material via the Interactive Services, the Site, the Services and/or Social Media Websites, you:

    1. represent and warrant that Happify™’s use of your submission does not and will not breach any agreement, violate any law, violate any Social Media Website’s terms of service or infringe upon any third party’s rights;
    2. agree that Happify™ is free to use in any manner all or part of the Comments, Activity Posts and/or other material on an unrestricted basis without the obligation to notify, identify or compensate you or anyone else; and
    3. grant Happify™ all necessary rights, including a waiver of all copyright, trademark, privacy and moral rights, to use all Comments, Activity Posts and/or other material, in whole or in part, or as a derivative work, without any duty by Happify™ to anyone whatsoever.

  7. 7. Other Information Collection and Use

    We use the information that we collect to improve the design and content of the Site and to enable us to personalize your Internet experience. We also may use this information in the aggregate to analyze Site usage, as well as to offer you products and services.