· Who we are.
· Our Website
· How to Contact Us
· Lawful Basis for Collection and use of your Personal Information
· Cookies and Other Tracking Technologies
· Your Marketing Preferences
· Your Rights
· Keeping your personal information secure
· How to Complain
· If You Need Additional Help
· Policy Amendments
Who We Are
We are Happya Ltd. Registered in England and Wales with the Company Number 13333001.
Our registered address is 14 The Glebe, Lavendon, Buckinghamshire, England, MK46 4HY.
We are registered as a Data Controller with the Information Commissioner's Office (ICO) reference ZB185144.
How to Contact Us
Write to us at our registered address: 14 The Glebe, Lavendon, Buckinghamshire, England, MK46 4HY. Please contact us if you have any questions about this privacy notice or the information, we hold about you.
Lawful Basis for Collection and use of your Personal Information
We operate our data protection and privacy policies and procedures according to the UK’s Data Protection Act 2018 and the UK general Data Protection Regulation (UK GDPR) which apply across the European Union and the United Kingdom.
We are responsible as ‘controller’ of that personal information for the purposes of those laws.
Our commitment is to ensure all personal information is protected and processed lawfully and ethically. To ensure this we adopt the following privacy principles:
1. We only request and store personal required to provide you with our products and services including those that may be of interest, or we are required to by law.
2. We only request and store special category personal information including health and financial information when you request a service where we have a legal or ethical obligation to do so.
3. We only share information for third parties as set out in this policy to enable us to fulfil our obligations and transact business.
Our legal basis for processing your personal information
When we use your personal information, we are required to have a legal basis for doing so. There are various legal bases on which we may rely, depending on what personal information we process and why.
The legal bases we may rely on include:
• Consent: where you have given us clear consent for us to process your personal information for a specific purpose
• Contract: where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract
• Legal obligation: where our use of your personal information is necessary for us to comply with the law (not including contractual obligations)
• Legitimate interests: where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information which overrides our legitimate interests)
What Information do we Collect?
We collect personal information about you when you access our website, register with us, contact us, send us feedback, purchase products or services via our website, post material to our website and social media sites and/or complete customer surveys.
We collect this personal information from you either directly, such as when you register with us, contact us, or purchase products or services via our website or indirectly, such as your browsing activity while on our website (see ‘Cookies’ below).
The personal information we collect about you depends on the particular activities carried out through our website. This information includes:
· Information such as: name, address and contact details, date of birth (where relevant).
· Details of any feedback you give us by phone, email, post or via social media.
· Information about the services we provide to you.
· Your account details, such as username, login details.
· Information about the use of our websites (including your IP address, geographical location, browser type, referral source, length of visit and number of page views).
· Special category information required to provide requested services including finance, health related information allowing us to facilitate special considerations and facilitate our equal opportunities policy, and conviction information where required for safeguarding or by law.
· Some of our services carry a duty of care requiring us to ask about health conditions that might be affected. There is no obligation for you to provide health information to us, but it may affect the service we can make available and any subsequent recourse.
We use this personal information to:
• Provide you with products and services, including passing necessary information to third parties who may form part of the product or service.
• Contact you and provide you with relevant information based on your enquiries.
• Create and manage your relationship with us, including but not limited to verifying your identity, account maintenance, payment processing, debt collection, and legal or regulatory communications.
• Communicate with you to notify any changes to our website or services that may affect you, or to improve our services.
• Communicate marketing information to you relating to products and services offered by our business.
• Customise our website and its content to your particular preferences.
This website is not intended for use by children.
Information Provided by You
We require you to provide name, address, email address and home address to enable us to provide our services to you, formalise a contract between us amongst other reasons. We will inform you at the point of collecting information from you, whether you are required to provide the information to us.
We will not keep personal information for longer than is necessary. However, the length of time information is retained will depend on the type of information and the contractual relationship we have in place with you. As standard we will retain information for up to 7 years from our last interaction with you, which includes you logging into one of our systems.
Our records are regularly reviewed to ensure we anonymise or delete information that is no longer required.
Please see “Your Rights” below to understand your right to erasure (right to be forgotten).
In addition, we may disclose information in the following circumstances:
• When we are required to do so by law.
• In connection with legal proceedings or prospective legal proceedings.
• To establish, exercise or defend our legal rights (Including providing information to others for the purposes of fraud prevention, anti-money laundering and reducing credit risk).
• For the purposes of litigation.
• To provide regulatory bodies with reports if a breach in regulation occurs (customers will also receive notification of the details being provided prior to submission if there is any identifying data included within the report).
• In the event we sell any business or assets, we may disclose personal information held by us to the prospective buyer of said business or assets.
Third party websites
Our website, our products and services, and marketing communications may contain links to third parties. We are not responsible for the privacy policies or processes of said third parties.
Transfer of your information out of the UK and EEA
We store your information in the UK and the EU. We do not directly transfer information outside of the EEA.
We use a third-party payment processor Stripe and PayPal and do not retain your payment card number. When using our third-party payment processors your personal information is governed by their own privacy notice. The payment processors we work with adhere to the standards set by the PCI Security Standards Council.
Where payments are made in instalments, we store a ‘token’ provided by the payment processer. This enables us to collect payments without storing your personal card details.
When paying by instalments if you fall behind or default on your agreed repayments your information may be passed to a credit reference agency and/or debt collection agency.
Cookies and Other Tracking Technologies
Some of the cookies we use are strictly necessary for our website to function, and we do not ask for your consent to place these on your computer.
Cookies set by parties other than us are called “third party cookies”. Third party cookies enable third party features or functionality to be provided on or through the website, such as advertising, interactive content, and analytics. The third parties that set these cookies can recognise your device when it visits our website and certain other websites.
Most web browser allow you to control cookies. You may modify your browser preferences to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject cookies, certain functions and conveniences of our website may not work properly.
For more information about cookies and how to control them within your browser please see: www.allaboutcookies.org/.
Your Marketing Preferences.
We would like to send you information about our, products and services, news, and special offers, which may be of interest to you. Where we have your consent or it is in our legitimate interests to do so, we may do this by email, telephone, text message (SMS) or through social media.
We will only ask whether you would like us to send you marketing messages when you tick the relevant boxes when you download our products or buy our services.
If you have previously agreed to being contacted in this way, you can unsubscribe at any time by contacting us at firstname.lastname@example.org or clicking unsubscribe at the bottom of one of our emails. It may take up to 30 days for this to take place.
For more information on your rights in relation to marketing, see ‘Your Rights’ below.
Under the General Data Protection Regulations, you have several important rights free of charge.
Right of access: at any time, you can ask us what information we hold about you. You can request, a copy in part or in full, of the information we hold about you. There may be limitations in terms of some special category data, including manual records, health, and credit files.
Right of rectification: you can ask us to rectify inaccurate or incomplete information.
Right of erasure: You have the right to have your personal information erased “right to be forgotten”. You can request this at any time when any of the following applies.
· Your personal information is no longer necessary for the purpose it was collected or processed.
· You withdraw your consent to processing and this is the only lawful basis applied.
· Where legitimate interest is the basis for processing and you object to the processing, and there are no overriding legitimate interest or other lawful basis to continue.
· You remove your consent for direct marketing.
· If your personal information has been unlawfully processed.
· Where your personal information must be erased to comply with legal obligations.
· If the offer of information society services such as social media has captured information relation to a child.
Circumstances may exist where we are unable to erase your information, including but not limited to complying with a legal or regulatory obligation or to establish, exercise, or defend a legal or regulatory claim. Right to restrict processing: in special circumstances you can request we limit or restrict processing of your information.
Right to data portability: if we are processing your personal information under your consent or to fulfil a contract, and it is automatically processed, you can ask us to provide a copy of the information in a structured and portable format. You can also request we transmit your information to another data controller.
Right to object: If we are processing your personal information under consent or legitimate interest, you may withdraw that consent at any time. There may be occasions when this is not practical or reasonable, however if for any reason we are unable to facilitate a consent withdrawal, we will provide an explanation along with the lawful basis under which we would continue to process your information.
You can remove consent for direct marketing at any time without exception.
Submit a request.
If you wish to make a request regarding your personal information, please use the contact us information provided in the section above. We aim to complete any request relating to your information rights within 1 month of receipt of your request or 3 months in complex situations relating to one individual.
Further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
Keeping your personal information secure
We have appropriate security measures in place and take reasonable technical and organisational precautions to prevent personal information from being accidentally lost, used, or accessed in an unauthorised way. We store all personal information provided securely. Where we use third parties to provide information storage and processing services, the provider holds an ISO certificate and are registered with the ICO.
How to complain
If you are unhappy about our use of your personal information, please contact us in the first instance and we hope we can resolve any query or concern you may raise about our use of your information. You also have the right to raise a complaint about the use of your information with the Information Commissioner’s Office (ICO). Further details can be found: www.ico.org.uk/make-a-complaint/ or telephone 0303 123 1113.
If You Need Additional Help
We may update this policy from time to time. The latest version will be available on our website www.happyacoach.com. You should check with this page to ensure you are happy with any changes. If there is a fundamental change to our policy, we will contact you to provide further information and if necessary to request your consent.
Policy dated: 6th August 2023