Privacy Policy

Effective as of June 21, 2017. For a prior version of our Privacy Policy, click here

HappyFox Inc. (the "Company") is committed to ensuring the privacy of individuals who visit happyfox.com, happyfox.net and happyfoxchat.com (the “Visitors”). Individually and collectively, the sites happyfox.com, happyfox.net and happyfoxchat.com are referred to as (a “Site” or the “Sites”). Individuals who register to use the Services as defined below (“Customers”); individuals who register to attend the Company’s corporate events or provide information to Company at trade shows or similar events (“Attendees”); and individuals who apply for a job with Company (“Applicants”) may be referred to individually and collectively as ("you"). This Privacy Policy describes Company’s Privacy Policy in effect for the use of the Sites and the related applications and services offered by Company (collectively, the “Services”). This Privacy Policy also covers the privacy practices of the Sites that link to this Privacy Policy, including how the Company collects, uses, shares and secures the personal information you provide.

Company respects the privacy rights of Visitors, Customers, Attendees, and Applicants. This Privacy Policy details how Company handles the information received from Visitors, Customers, Attendees, and Applicants. By using Company’s Sites or Services, or allowing someone to use the Sites or Services on your behalf, you are consenting to Company’s collection, use, disclosure, transfer and storage in accordance with this Privacy Policy of any information including personal information received by Company as a result of such use.

Company’s Services comply with the EU–U.S. Privacy Shield Framework set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union (EU) to the United States. You can view a description of how Company complies with the Privacy Shield Principles in Company’s Privacy Shield Notice. Company has certified to the Department of Commerce that the Services described in Company’s Privacy Shield Notice adhere to the Privacy Shield Principles. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program and to view Company’s record of certification, please visit the U.S. Department of Commerce’s Privacy Shield website https://www.privacyshield.gov/.

If you have questions or complaints regarding Company’s Privacy Policy or associated practices, please contact Company at privacy@happyfox.com. If you have an unresolved privacy or data use concern that Company have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

The Sites may contain links to third party websites, which have implemented their own privacy practices and privacy policies. Company encourages you to review the privacy policies of any applicable third party websites in order to understand their privacy practices in effect.

1. CONFIDENTIALITY AND SECURITY OF PERSONAL INFORMATION

Company maintains reasonable security measures to protect personal information from loss, destruction, misuse, unauthorized access or disclosure. These technologies help ensure that personal information submitted to the Sites and other data submitted to the Sites is safe, secure, and only available to you and to those to whom you have provided authorized access. While Company follows generally accepted standards to protect information submitted, including the use of secure socket layer (“SSL”) technology, no method of storage or transmission is 100% secure. Additional information about the Company’s privacy and security practices is available here.

2. INFORMATION COLLECTED BY COMPANY

  1. Personal Information:
    1. Customer Personal Information: Company collects information from Customers that personally identifies them. In particular, Company collects the following personal information from Customers during the account registration process: (A) name; (B) address; (C) telephone number; (D) fax number; (E) e- mail address; (F) company name; (G) User ID, as selected by Customer; (H) Site password as selected by Customer; (I) and credit card information; and (J) if applicable, the number of employees within the organization that will be using the Services. If Customer communicates with Company by email or completes online forms or surveys, information provided by Customer in such communications may also be collected as personal information. Company may also ask for and collect personal information such as an email address and a name or alias from any individual that Customer authorizes to log into and utilize the Services in connection with Customer’s account. Occasionally, Company connects personal information to information gathered in Company’s log files as set forth below. In such a case, Company would treat the combined information in accordance with this Privacy Policy.
    2. Visitor Personal Information: When a Visitor submits a user inquiry through the “contact us” form on the Sites, Company collects such personal information as (A) name; (B) email address; and (C) telephone number.

      If you sign-up for a free trial account, you are not required to enter your credit card information unless and until you decide to continue with a paid subscription to Company’s Services. A third-party intermediary is used to manage credit card processing. This intermediary is not permitted to store, retain, or use your billing information for any purpose except for credit card processing on our behalf.

    3. Attendee Personal Information: When Attendee registers for or attends a sponsored event, Company collects personal information such as (A) name; (B) address; (C) telephone number; and (D) email address. Company may also collect this information from other events in which Company participates.
    4. Applicant Personal Information: Company collects personal information from Applicants such as (A) name; (B) address; (C) telephone number; (D) email address and (E) Resume or Curriculum Vitae.
  2. Other Information Collected (the “Data”):
    1. Traffic Information: When you visit any of the Sites, Company automatically tracks and collects information that does not personally identify you, including: (A) Internet protocol (“IP”) addresses and domain server address; (B) date and time of the visit to the site; (C) the type of internet browser and operating system you used to access the Site, (D) the web pages that accessed at the Site; (E) locale and language preferences; (F) identification numbers associated with the devices, (G) mobile carrier, and (H) system configuration information (collectively “Traffic Information”).
    2. Usage Data: Company also collects “Usage Data” about groups or categories of services, features or users, which do not contain personally identifying information. Usage Data helps Company understand trends in usage of the Service so that Company can better consider new features or otherwise tailor the Service.
    3. Organization Data: Company may ask you to provide additional information, such as company annual revenues, number of employees, or industry.
    4. Site Navigational Information: Company uses commonly-used information gathering tools, such as cookies and Web beacons, to collect information as you navigate the Sites about your use of the Sites and Services (“Site Navigational Information”). As described more fully below, Company and its partners use these cookies or similar technologies to analyze trends, administer websites including the Sites and Services, track users’ movements around the Sites and Services, serve targeted advertisements and gather demographic information about the user base as a whole.
      1. Cookies: Company uses cookies to make your interactions with the Sites easy and meaningful. When you visit one of the Sites, Company’s servers send a cookie to your computer. Standing alone, cookies do not personally identify you; they merely recognize your web browser. Unless you choose to identify yourself to Company, such as by responding to a promotional offer, opening an account, or filling out a Web form (such as a “Contact Us” or a “Demo Request” Web form), or by becoming an Applicant, you remain anonymous to Company. Company uses cookies that are session- based and persistent-based. Session cookies exist only during one session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you close your browser or turn off your computer. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our Sites or Services. The following sets out how Company uses different categories of cookies and your options for managing cookies’ settings:
        1. Required Cookies: These cookies enable you to navigate the Sites and use their features, such as accessing secure areas of the Sites and using Services. If you have chosen to identify yourself to Company, Company may place on your browser cookies containing an encrypted, unique identifier. The cookies allow Company to uniquely identify you when you are logged into the Sites and Services and to process your online transactions and requests. The required cookies are essential to operate the Sites and Services and therefore you cannot “opt out” of these cookies.
        2. Performance Cookies: These cookies collect information about how visitors use the Sites and Services, including the pages most often visited and if visitors receive error messages from certain pages. The cookies are only used to improve the function and performance of the Sites and Services. Company periodically engages third parties to track and analyze usage and volume statistical information from individuals who visit the Sites and Services, and to track the performance of Company’s advertisements. Company and Company’s third-party partners may also utilize HTML5 local storage or Flash cookies for these purposes. Flash cookies and HTML local storage are different from browser cookies because of the amount of, type of, and how data is stored. For information on how to opt out of performance cookies using your browser settings click here. For information on how to manage privacy and storage settings for Flash cookies click here. Various browsers may offer their own management tools for removing HTML5 local storage.
        3. Functionality Cookies: Functionality cookies allow the Sites and Services to remember information you have entered or choices you make (such as your username, language, or your region) and provide enhanced, more personal features. These cookies also enable you to optimize your use of the Sites and Services after logging in. Company uses local shared objects, also known as Flash cookies and HTML5 local storage, to store your preferences or display content based upon what you view on the Sites and Services to personalize your visit. For information on how to opt out of functionality cookies using your browser settings click here. Note that opting out may impact the functionality you receive when using the Sites and Services. For information on how to manage privacy and storage settings for Flash cookies click here.
        4. Targeting or Advertising Cookies: Company sometimes uses cookies delivered by third parties to show you ads for the products and services that Company thinks may interest you on any devices you may use and to track the performance of Company’s advertisements. For example, in these cases, cookies remember information such as which browsers have visited the Sites. The information provided to third parties does not include personal information, but this information may be associated by Company with personal information.
      2. Web Beacons: Company uses Web beacons alone or in conjunction with cookies to compile information about Customers and Visitors’ usage of the Sites and Services and interaction with emails from Company. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular website or Service tied to the Web beacon, and a description of a website or Service tied to the Web beacon. For example, Company may place Web beacons in marketing emails that notify Company when you click on a link in the email that directs you to one of the Sites. Company also uses Web beacons to operate and improve the Sites, Services and email communications.
      3. Log Files, IP Addresses, URLs and Other Data: As is true of most websites, Company gathers certain information automatically to analyze trends in the aggregate and administer their Sites and Services. This information may include your Internet Protocol (IP) address (or the proxy server you use to access the World Wide Web), device and application identification numbers, your location, your browser type, your Internet service provider and/or mobile carrier, the pages and files you viewed, your searches, your operating system and system configuration information, and date/time stamps associated with your usage. Due to Internet communications standards, when you visit or use the Sites and Services, Company automatically receives the URL of the website from which you came and the website to which you go when you leave Company’s Sites. This information is used to analyze overall trends, to help Company improve the Sites and Services, to track and aggregate non-personal information, and to provide the Sites and Services. For example, Company uses IP addresses to monitor the regions from which customers and visitors navigate the Sites. Company also collects IP addresses from customers when they log into the Services as part of the “IP Restriction” security feature as well as to maintain audit logs.
      4. Do Not Track Signals: Currently, various browsers — including Internet Explorer, Firefox, and Safari — offer a “do not track” or “DNT” option that relies on a technology known as a DNT header, which sends a signal to Web sites’ visited by the user about the user's browser DNT preference setting. Company does not currently recognize browsers' DNT signals with respect to the Sites, in part, because no common industry standard for DNT has been adopted by industry groups, technology companies or regulators, including no consistent standard of interpreting user intent. Company takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.
    5. Mobile Application Data: Company may obtain information collected through applications (“Mobile Applications”) that Customers or their authorized individuals (“Users”) download to and run on their mobile devices (“Device(s)”). Mobile Applications provided by Company may obtain information from, or access data stored on, Users’ Devices to provide services related to the relevant Mobile Application. For example, a Mobile Application may: access a camera on a User’s Device to enable the User to upload photographs to the Services. Information obtained to provide Mobile Application services may include information obtained in preparation for anticipated updates to those services. Mobile Applications may transmit information to and from Devices to provide the Mobile Application services. This also includes User’s Device identification information in order to send push notifications as part of the Services.

      Mobile Applications may provide Company with information related to Users’ use of the Mobile Application services, information regarding Users’ computer systems, and information regarding Users’ interaction with Mobile Applications, which Company may use to provide and improve the Mobile Application services. For example, all actions taken in a Mobile Application may be logged, along with associated information (such as the time of day when each action was taken). Company may also share anonymous data about these actions with third party providers of analytics services. In addition, if a User downloads a Company Mobile Application after clicking on a third-party mobile advertisement for the Mobile Application or for Company, the third-party advertiser may provide Company with certain information, such as the User’s Device identification information, which Company may use to track the performance of its advertising campaigns.

      Customers may configure Company Mobile Application services, and the information accessed or obtained by the Mobile Application on a User’s Device may be affected by the Customer’s configuration. In addition, if a Customer purchases more than one Service from Company and its affiliates, a Mobile Application may be designed to interoperate with those Services; for instance, to provide a User with access to information from any or all of those Services or to provide information from a User’s Device to any or all of those Services. Information accessed or obtained by the Mobile Application on a User’s Device may be accessible to the Customer and its organization, depending on the intended functionality of the Mobile Application. Company may provide updated versions of its Mobile Applications. If your Device’s settings permit, those updates will be downloaded and installed automatically on the Device. By installing a Company Mobile Application on your Device, you consent to the downloading and updating of that Mobile Application.

      In addition to Mobile Applications offered by Company, Company may offer platforms for the creation of third-party Mobile Applications, including but not limited to the HelpStack.io mobile SDK. Third parties may obtain information from, or access data stored on, Users’ Devices to provide services associated with any third-party Mobile Applications that Users download, install, use, or otherwise interact with over a Company platform. Company’s Mobile Applications may also contain links or integrations to other Mobile Applications provided by third parties. Third parties’ use of information collected through third-party Mobile Applications is governed by the privacy policies of such third parties. Company encourages you to review the privacy policies of third-party providers of Mobile Applications to understand their information practices.

      Notices and contractual terms related to a particular Mobile Application may be found in the end user license agreement or relevant terms of service for that application. Company encourages you to review the end user license agreement or relevant terms of service related to any Mobile Applications you download, install, use, or otherwise interact with to understand that Mobile Application’s privacy practices.

  3. Customer Data: Customers may electronically submit personal information or data to the Services for hosting and processing purposes (“Customer Data”). For clarity, an "Authorized User(s)" is any individual authorized by a Customer to register a staff / an agent account identified through a unique login as a staff / an agent and/or an administrator; an "End User(s)" is any individual who seeks to interact with a Customer or an Authorized User through the Services. For purposes of the EU Directive on Data Protection (the "Directive"), Company is the data processor and not the data controller. In particular, Customers who control their Customer Data and send the Customer Data to Company's Sites or Services for processing are the "data controllers" of that data and are responsible for complying with the Directive and relevant data protection legislation in the relevant European Economic Area ("EEA") member state before sending personal information to Company for processing. Company collects information under the direction of its Customers (the data controller), and has no direct relationship with the individuals whose personal information it processes. Company stores and processes Customer Data in the United States and EEA and potentially in other countries through third parties that Company uses to operate and manage the Sites and Services. When you access or use the Sites or Services, or otherwise provide information to us, you are consenting on behalf of yourself, Authorized Users, and End Users (and representing that you have the authority to provide such consent) to the processing and transfer of information in and to the United States and other countries which have different privacy laws from the applicable country of residence. Company will take all steps reasonably necessary to ensure that Customer Data is treated securely and in accordance with this Privacy Policy. Company will not review, share, distribute, or reference any such Customer Data except as provided in Company’s standard terms of service (HappyFox helpdesk - https://www.happyfox.com/terms-services/ and HappyFox Chat - https://happyfoxchat.com/terms-services). Company does not own, control, or direct the use of the Customer Data stored or processed through the Services. Company may access Customer Data only for the purpose of providing the Services or preventing or addressing service or technical problems or as may be required by law. Only you or your Authorized Users or your End Users, as applicable, are entitled to access, retrieve and direct the use of such personal information or Customer Data.
  4. Personal Information and Data from Third Party Services: Company may also obtain other information, including personal information, from third parties and may combine that information with personal information and Data that Company collects through its Sites and Services. For example, Company may have access to certain information from a third party social media or authentication service if you log into the Services through such a service or otherwise provide Company with access to information from the service. Any access that Company may have to such information from a third party social media or authentication service is in accordance with the authorization procedures determined by that service. By authorizing Company to connect with a third party service, you authorize Company to access and store your name, email address(es), current city, profile picture URL, and other personal information that the third party service makes available to us, and to use and disclose it in accordance with this Policy. You should check your privacy settings on these third party services to understand and change the information sent to Company through these services.

3. INFORMATION COLLECTED BY THIRD PARTIES

Certain third parties may collect personal information and Data made available through the Sites:

  1. Advertisers: Company contracts with third-party advertising networks that collect IP addresses and other information from Web beacons on the Sites and Services, from emails, and on third- party web sites. Ad networks follow your online activities over time and across different sites or other online services by collecting Site Navigational Information through automated means, including through the use of cookies. These technologies may recognize you across the different devices you use, such as a desktop or laptop computer, smartphone or tablet. Third parties use this information to provide advertisements about products and services tailored to your interests. You may see these advertisements on other websites or mobile applications on any of your devices. This process also helps Company manage and track the effectiveness of Company marketing efforts. Third parties, with whom Company partners to provide certain features on the Sites or to display advertising based upon your web browsing activity, use Flash cookies to collect and store information. Flash cookies are different from browser cookies because of the amount of, type of, and how data is stored.

    For more information about these and other advertising networks and your ability to opt out of collection, please visit the opt-out pages of the Network Advertising Initiative, here and the Digital Advertising Alliance, here. For information on how to manage privacy and storage settings for Flash cookies click here. Various browsers may offer their own management tools for removing HTML5 local storage.

  2. Social Media: The Sites may use social media functionality that collects your IP address and the page you are visiting on the Sites and may set a cookie to enable the feature to function properly. You may also be given the option by such social media functionality to post information about your activities on the Sites to a profile page that is provided by a third party social media network in order to share with others within your network. Any social media functionality will be hosted by a third party or, alternatively, hosted directly on the Site. Your interactions with any social media functionality will governed by the privacy policy of the applicable social media company providing the social media functionality. Company has no control over the personal information or Data that you choose to post to social media, and cannot ensure that third parties do not collect the personal information or Data that you post.

4. HOW COMPANY USES THE PERSONAL INFORMATION AND DATA COLLECTED

  1. Provide Access and Use: Company may use personal information and Data to enable you to access and use the Sites and Services. This includes providing any customer support that you may request; providing responses to your comments, questions and requests; sending you technical notices, updates, security alerts, and support; and sending you administrative notices.
  2. Operate the Services: Company may use personal information and Data to operate the Services.
  3. Process and Complete Transactions: Company uses personal information and Data to (i) bill, identify, authenticate, process and complete transactions, (ii) send you related information, including purchase confirmations and invoices; (iii) send transactional messages, including responses to your comments, questions, and requests; (iv) provide customer service and support; (v) send you technical notices, updates, security alerts, and (vi) provide support and administrative messages.
  4. Promote the Services: Company uses personal information and Data to send promotional communications, such as providing you with information about products and services, features, surveys, newsletters, offers, promotions, contents, and events, and other news and information about Company and Company’s partners.
  5. Personalize the Sites and Services: Company uses personal information and Data to personalize the Sites and Services.
  6. Provide Service-Related Communications: Company uses personal information to provide service related communications, such as information and updates on scheduled site maintenance. You cannot opt out of these communications, which are not promotional in nature. If you choose to subscribe to our newsletter(s), Company will use your name and email address to send you such newsletter(s). Company may use such personal information to contact you for future marketing or advertisement purposes. Unsubscribe instructions will accompany every such email and you will be at liberty to unsubscribe from the same.
  7. Improve Content and Functionality of Sites and Services: Company use and stores personal information about your use of the Sites, such as the date and time of your visit, to help improve the content and functionality of the Sites and Services.
  8. Provide Security and Prevent Fraud: Company may use personal information to prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities, unauthorized access to the Services, fraudulent transactions, illegal activities, and enforce Company’s terms of service (HappyFox helpdesk - https://www.happyfox.com/terms-services/ and HappyFox Chat -https://happyfoxchat.com/terms-services).
  9. Provide Customer Service: Company may use personal information and Data to send you a welcome email to verify your username and password. Furthermore, Company will use the same to respond to queries, to provide the services and/or technical assistance as requested.
  10. Plan and Host Events: Company may use personal information and Data about Attendees of Company’s events to plan and host events, host online forums and social networks in which the Attendees may participate, and to populate online profiles for Attendees on our Sites.
  11. Deliver Contests and Sweepstakes: Company may use personal information and Data to process and deliver contests, sweepstakes entries, and rewards.
  12. Other Purposes for Which Company Obtain Consent: Company may use personal information and Data for other purposes for which Company obtains your advance consent.

5. WHO COMPANY SHARES PERSONAL INFORMATION AND DATA WITH

  1. Third Party Service Providers: Company may share personal information and Data with its contracted third-party service providers to provide hosting, maintenance of websites, application development, backup services, storage, payment processing, analytics, technical support, and other services that the Company uses to operate the Sites and Services and maintain a high quality user experience. These service providers are authorized to use personal information and Data only as necessary to provide the requested services to Company. Without limiting the foregoing, Company may also share personal information and Data about Visitors, Customers, Attendees and Applicants with service providers to ensure the quality of information provided, and with third–party social networking and media websites, such as Facebook, for marketing and advertising on those websites. Unless specifically stated in this Privacy Policy, Company does not share, sell, rent, or trade any information with third parties for their promotional purposes.
  2. Business Partners: Company may partner with other companies to jointly offer products or services, such as Company’s integration partners. If you purchase or specifically express interest in a jointly–offered product or service from or through Company, Company may share personal information or Data about you collected in connection with your purchase or expression of interest with Company’s partner(s). Company does not control its business partners’ use of the personal information or Data, and their use of the information will be in accordance with their own privacy policies. If you do not wish for your information to be shared in this manner, you may opt not to purchase or specifically express interest in a jointly offered product or service.

    Company does not share personal information or Data about Attendees with business partners unless: (i) you specifically opt in to such sharing via an event registration form; or (ii) you attend a Company event and allow us or any Company business partners to scan your attendee badge. If you do not wish for your information to be shared in this manner, you may choose not to opt in via event registration forms and elect not to have your badge scanned at Company events. If you choose to share your information with business partners in the manner described above, your information will be subject to the business partners’ respective privacy policies.

    Company partners with third parties to display advertising on the Sites and to manage advertising on other sites. Company’s third party partners may use technologies such as cookies to gather information about your activities on the Sites and other sites in order to suggest advertisements based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving your interest-based ads, you may be able to opt-out by clicking here (or if located in the European Union click here). Please note this does not opt you out of being served ads and you will continue to receive generic ads.

  3. Law Enforcement: In certain situations, Company may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Company may disclose personal information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. Company may also share such information if Company believes it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our terms of service, or as otherwise required by law.
  4. Public Forums and Blogs: The Sites offer publicly-accessible blogs or community forums. If you participate in such blogs, forums and/or add feedback/comments inside the Services, you should be aware that any information you provide in these areas may be read, collected, and used by other members in these forums and other third parties. Company has no control over the personal information or Data that you choose to submit in these forums or blogs, and cannot ensure that third parties do not collect the personal information or Data that you post. To request removal of your personal information or Data from Company’s blog or community forum, please contact Company at privacy@happyfox.com.

6. INTERNATIONAL TRANSFER OF PERSONAL INFORMATION AND DATA COLLECTED

Company primarily stores personal information and Data in the United States. To facilitate Company’s global operations, Company may transfer and access such personal information and Data from around the world, including from other countries in which Company has operations. This Privacy Policy shall apply even if Company transfers personal information or Data to other countries.

7. RETENTION; CORRECTING AND UPDATING PERSONAL INFORMATION

Company may retain personal information as is consistent with the original purpose of collection. For instance, Company may retain your personal information during the time in which you have an account to use our Sites or Services and for a reasonable number of years thereafter. Company also may retain personal information as necessary for Company to pursue its legitimate business interests, conduct audits, comply with Company’s legal obligations, resolve disputes and enforce Company’s agreements.

You may request to review, correct, delete or otherwise modify any of the personal information that you have previously provided to us through the Sites and Services. If you have registered for an account with Company, you may generally update your user settings, profile, organization’s settings or event registration by logging into the applicable Site or Service with your username and password and editing your settings or profile. To update your billing information, discontinue your account, and/or request return or deletion of your personal information or Data associated with your account, please contact your account representative or the customer service team for the applicable Service. For other requests to access, correct, modify or delete your personal information Data, please review the “Contacting Us” section below. Requests to access, change, or delete your information will be addressed within a reasonable timeframe. If you are an employee of a Customer, you may also wish to contact your organization’s account administrator for assistance in correcting or updating your information.

Company has no direct relationship with the individuals whose personal information it processes. Company acknowledges that you have the right to access your personal information. If personal information pertaining to you as an individual has been submitted to Company by a Customer (the data controller) and you wish to exercise any rights you may have to access, correct, amend, or delete such data, please inquire with our Customer directly because Company personnel have limited ability to access personal information and Data Customers submit to our Services. If you wish to make your request directly to Company, please provide the name of the Customer who submitted your personal information or Data to our Services. Company will refer your request to the Customer, and will support them as needed in responding to your request within a reasonable timeframe.

8. TESTIMONIALS

From time to time, Company may post testimonials on the Sites that may contain personal information. Company shall obtain your consent to post your name along with your testimonial. If you wish to update or delete your testimonial, you can contact Company at privacy@happyfox.com.

9. REFERRALS

If you choose to use Company’s referral service to tell a friend about Company’s products and services, Company will ask you for your friend’s name and email address. Company will automatically send your friend an email inviting him or her to visit the Sites and will store this information for the purpose of sending this initial email, tracking the success of our referral program and other marketing activities. Your referral may contact Company at privacy@happyfox.com to request that Company remove his/her information from our database.

10. CHILDRENS PERSONAL INFORMATION

Company does not knowingly collect any personal information from children under the age of 13. If you are under the age of 13, please do not submit any personal information through our Sites or Services. Company encourages 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 Sites or Services without their permission. If you have reason to believe that a child under the age of 13 has provided personal information to Company through the Sites or Services, please contact us at privacy@happyfox.com, and Company will use commercially reasonable efforts to delete that information.

11. BUSINESS TRANSACTIONS

Company may assign or transfer this Privacy Policy, as well as Company’s account and related information and any personal information and Data, to any person or entity that acquires all or substantially all of Company’s business, stock or assets, or with whom Company merges.

12. PRIVACY SHIELD FRAMEWORK

Company abides by and has certified adherence to the principles of the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. Company has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view Company certification, please visit https://www.privacyshield.gov/. If you have an unresolved privacy or data use concern that Company have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

For residual Privacy Shield disputes that cannot be resolved by the methods above, you may be able to invoke a binding arbitration process under certain conditions. To find out more about the Privacy Shield’s binding arbitration scheme, please see: https://www.privacyshield.gov/article?id=ANNEX-I-introduction. The Federal Trade Commission has investigation and enforcement authority over Company’s compliance with the Privacy Shield.

Company is responsible for the processing of personal information it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Company complies with the Privacy Shield Principles for all onward transfers of personal information from the European Union, including the onward transfer liability provisions. If Company has received your personal information under the Privacy Shield Framework then Company adheres to the Privacy Shield Principles as long as it retains such personal information. Company has defined procedures for making public any relevant Privacy Shield related sections of any compliance or assessment report submitted to the U.S. Federal Trade Commission, to the extent consistent with confidentiality requirements. You can view a description of how Company complies with the Privacy Shield Principles in our Privacy Shield Notice.

13. CHANGES TO THIS PRIVACY POLICY

Company reserves the right to change this Privacy Policy. Company will provide notification of the material changes to this Privacy Policy through the Sites at least thirty (30) days prior to the change taking effect. Please note that the use of information Company gathers is subject to the Privacy Policy then in effect at the time of use. By continuing to access or use the Services after those changes become effective, you agree to be bound by the revised Privacy Policy.

14. CONTACT WITH YOU

Company may use your name and email address to send you a newsletter or to contact you for future marketing or advertising purposes. Unsubscribe instructions will accompany every communication. You may at any time choose to unsubscribe (or “opt out”) any of our mailings either by following the instructions or by contacting us at privacy@happyfox.com.

15. CONTACTING COMPANY

If you have any questions or comments about this Privacy Policy or any other matter regarding the Sites or Services, please send them by email to privacy@happyfox.com, or by mail to:

HappyFox, Inc.
24 Executive Park, Suite 230,
Irvine, CA 92614, USA.

16. EFFECTIVE DATE

This Privacy Policy was last updated on June 21, 2017.