Legal

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Happify™ Privacy Policy: Last Updated July, 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 here.

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 a