Happyr Ltd. (‘we’ or ‘us’ or ‘our’) want to explain our users (‘user’ or ‘you’) how we use the data you provide us with in our mobile app (‘App’) or on our website https://happyrhealth.com (the “Site”). Both are operated by Nicola Filzmoser and Cornelius Palm, who are also acting as Data Protection Officers (DPO) of Happyr Ltd. 

This Privacy Policy describes how your personal information is collected, used, and shared when you visit the App or Site or subscribe for the mail list, user testing on the Site.

We reserve the right to change this Privacy Policy at any point in time and for any reason. You will be updated by changes through the ‘Last updated’ date on top of this Privacy Policy. 

This Privacy Policy only applies to our App and not to any mobile store you are downloading the App from.

Types of Data We Collect

In order for the App or/and Site to function properly and fulfill all of their desired purposes we may collect and process the following information about you:

• Profile Data, such as your Email address, Username, Date of Birth, Account information of your supporter account; all of the information that you voluntarily provide us with during the registration process.

• When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.”

• Additionally, we automatically collect device information such as your operating system, mobile device ID number, model, and location. In-app user behaviour (e.g. time spent on a screen) is collected by a third party software with the sole purpose to improve the user experience you get in the app.
• We may also log basic information, such for example contact data and demographics automatically (i.e. via mail or chat history) or manually (by adding you to a user testing list, after having you agree to that). We are also asking you if you are over 16 years old, to make sure we do not collect information from minors. By asking you if you are a parent, patient or doctor, we can tailor updates that we believe are especially relevant to the selected user group. When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and manually entered personal information.

• While using the App, our servers automatically collect data from any actions taken when you create an entry in your app or edit any prior entries. For us to be able to show you a summary of your entries from the mood and symptom diary, we store the data you provide in an entry. Additionally, we store information about age, biological sex, and family history with migraine or headaches to provide you with a personalized symptom diary.  

We collect Device Information using the following technologies:

• “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. There are several different types of cookies, however, our website may use: Essential cookies; Analytical Cookies, Advertising Cookies. For more information about cookies in general and how to disable them please consult our cookie policy [insert the link to the cookie policy].
• “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
•  “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.

How and Why We Use Your Data

We use the information that we collect generally to fulfill any services on the Site, such as providing information about pediatric migraine and our related services that we deliver through, such as the mobile apps of Happyr Ltd. We use the information that we collect in the app to provide you with an overview over your prior entries. Your information allows us to provide you a personal experience when you use the app. We can create your personal profile, connect it to your supporter account, and provide you with an overview of your own data in future visits to the App. We will use the usage data to improve our App and our Site so we can provide you better information and features. 

Additionally, we use this information to communicate with you;

When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services or conduct user testing and interviews as well as share our personal (migraine) experiences if that is helpful.

We use the Device Information that we collect to improve and optimize our Site (for example, by generating analytics about how our users and visitors browse and interact with the Site, and to assess the perceived quality of our Site content as well as the success of our marketing and advertising campaigns).

We may contact you with information and offers about new products that you might find interesting using the email address you provided us with. 

The Legal Bases for Using Your Personal Information

In accordance with the GDPR, we provide the following information concerning its legal bases of article 6 for the processing of personal data:

• The consent you have affirmatively given us ;
• The legitimate interest pursued by Happyr Ltd, and more particularly:
• The commercial interest that we have in offering you specific or adapted content depending on the use you make of the Products.
• The financial interest that we have in offering you promotional offers about new products you might enjoy. 
• The business interest we have in collecting data regarding your general use of activities for the purpose of improving the App user experience.
• The commercial interest that we have in asking you to participate in surveys conducted on the Products in order to better understand your needs and expectations.
• Our business interest in complying with our legal obligations, such as keeping accurate financial records.

Sharing Your Personal Information

We attach great importance to the security of your personal data. We will not sell, share, or lease your personal information to unrelated third parties unless we are required by law to do so or have your permission. We share your Personal Information with third parties to help us use your Personal Information, as described above. 

For example, we use Google Analytics to help us understand how our customers use the Site–you can read more about how Google uses your Personal Information here:  https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics used on our Site here:  https://tools.google.com/dlpage/gaoptout.

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful requests for information we receive, or to otherwise protect our rights.

Please note that your information might be transferred outside of Europe, including Canada and the United States for clouding services.

Behavioural Advertising

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt-out of targeted advertising by:

Visiting the below websites

FACEBOOK – https://www.facebook.com/settings/?tab=ads 

GOOGLE – https://www.google.com/settings/ads/anonymous 

BING –https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads 

Additionally, you can opt-out of some of these services by visiting the Digital 

Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

Data Retention

To reduce data-related risk, we will maintain data for our records for no longer than is necessary for the purposes for which it is being processed. We may keep certain data for retrospective research purposes to enhance services for (young) people with chronic pain. 

Minors

The Site is not intended for unsupervised use for individuals under the age of 16.

Although our goal is to help young chronic pain sufferers, we believe that children should use our website (and the Internet in general) under the supervision of their parents. This is not so much because we believe that our content is not child-friendly, but because personal information (such as an email address) can be entered and we want children to be made aware of this by their parents. We do not want to compromise the privacy of children, so we want children under the age of 16 to use the website under the supervision of their parents. We do not want to obtain information from children under the age of 16 without the consent of their parents or legal guardians. 

We do not knowingly collect data from children under 16 years of age without the consent of their parents. If we have inadvertently collected (by the child entering the information him/herself) information from children under 16 years of age that you, as a carer or parent, do not agree to provide, please contact hello@happyrhealth.com.

We do not knowingly promote the app or collect data from children under the age of 16. By using our App, you confirm that you are at least 16 years old or that you are a legal guardian or parent of a person under the age of 16. As a legal guardian, you consent to the dependent use of the App by your child.

Changes

We may update this privacy policy from time to time to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

Our Data Protection Rights

Our Company would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following: 

• The right to access you – You have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below. We may charge you a small fee for this service. Additionally, if you are a European resident, we note that we are processing your information to fulfil our services and legitimate business interests listed above. 
• The right to rectification – You have the right to request that Our Company correct any information you believe is inaccurate. You also have the right to request Our Company to complete the information you believe is incomplete.
• The right to erasure – You have the right to request that Our Company erase your personal data, under certain conditions.
• The right to restrict processing – You have the right to request that Our Company restrict the processing of your personal data, under certain conditions.
• The right to object to processing – You have the right to object to Our Company’s processing of your personal data, under certain conditions.
• The right to data portability – You have the right to request that Our Company transfer the data that we have collected to another organization, or directly to you, under certain conditions.
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If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: hello@happyrhealth.com

PLEASE NOTE:

Happyr Ltd is, under no circumstances, meant to make a diagnosis or provide treatment for migraines or any other related health condition. For a proper diagnosis of your medical condition and the treatment that may stem from such a diagnosis, we suggest you consult a doctor or related health care professional.

Contact us

If you have any questions about this privacy policy or our privacy practices, please contact our (DPO) in the following ways:

Full name: Nicola Filzmoser

Email: hello@happyrhealth.com

Postal address: Kemp House 160 City Rd, London EC1V 2NX, United Kingdom

Telephone number: +4915209776641

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.