Introduction

HappyPoints provides Shopify Development Services to merchants who use Shopify to power their stores. This Privacy Policy describes how personal information is collected, used, and shared when you visit our sites.

HOW DO WE USE YOUR PERSONAL INFORMATION?

We use the information that we collect in a variety of ways in providing the website and operating our business, including the following:

Operations

We use the information to operate, maintain, enhance and provide the services and information that you request, to respond to comments and questions and to provide support to users of the website.

Understand and improve our services

We use the information to understand and analyze the usage trends and preferences of our Visitors to improve the website, and to develop new products, services, features, and functionality. Should this purpose require HappyPoints to process your data, then the information will only be used in anonymized or aggregated form.

Communicate with you

We may use a user’s email address or other information (i) for administrative purposes such as customer service, to address intellectual property infringement, right of privacy violations or defamation issues related to the data posted on the Service or (ii) with updates on promotions and events, relating to products and services offered by us and by third parties we work with. You have the ability to opt-out of receiving any promotional communications as described below under “Your rights and choices”

Service-related communications

We may send you service and administrative emails to ensure the service is working properly.

Promotional

Subject to your opt-out preference, we may send you emails about new product features or other news about HappyPoints or on topics we think would be relevant to you. You may opt-out of receiving these communications at any time. See the “Your Rights and Choices” section below for more information.

Legal compliance

We may use your information to comply with applicable legal or regulatory obligations, including informal requests from law enforcement or other governmental authorities.

Other

We also may use your information to manage our business or perform functions as otherwise described to you at the time of collection subject to your consent. Please read all online agreements carefully before accepting them.

MINORS AND CHILDREN’S POLICY

Protecting the privacy of young children is especially important. Our website is not directed to children under the age of 18, and we do not knowingly collect Personal Data from children under the age of 18 without obtaining parental consent. If you are under 18 years of age, then please do not use or access the website at any time or in any manner. If we learn that Personal Data has been collected on the App from persons under 18 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 18 years of age has obtained access to the App, then you may alert us at [email protected] and request that we delete that child’s Personal Data from our systems.

The website is not intended to be used by minors and is not intended to be used to post content to share publicly or with friends. To the extent that a minor has posted such content on the website, the minor has the right to have this content deleted or removed using the deletion or removal options detailed in this Privacy Policy. If you have any questions regarding this topic, please contact us as indicated in the “How to contact us” section. Please be aware that, although we offer this deletion capability, the removal of content may not ensure complete or comprehensive removal of that content or information.

HOW DO WE KEEP YOUR PERSONAL INFORMATION SECURE?

We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We maintain appropriate administrative, technical and physical safeguards to protect Personal Data against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Data in our possession. This includes, for example, firewalls, password protection and other access and authentication controls. We use SSL technology to encrypt data during transmission through public internet, and we also employ application-layer security features to further anonymize Personal Data.

However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store on the Service, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you believe your Personal Data has been compromised, please contact us as set forth in the “How to contact us” section.

If we learn of a security systems breach, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.

SHARING YOUR PERSONAL INFORMATION

We do not and will never share, disclose, sell, rent, or otherwise provide personal information to other companies for the marketing of their own products or services.

We do not use the personal information we collect from you or your customers to independently contact or market to your customers. However, HappyPoints may contact or market to your customers if we obtain their information from another source, such as from the customers themselves.

We will share information we collect about you, including personal information, in the following ways:

With third-party service providers, agents, or contractors

We use other companies, agents or contractors (“Service Providers”) to perform services on our behalf or to assist us with providing services to you.or example, we may engage Service Providers to provide services such as marketing, advertising, communications, infrastructure and IT services, to provide customer service and to analyze and enhance data (including data about users’ interactions with our service). These Service Providers may have access to your personal or other information in order to provide these functions. In addition, some of the information we request may be collected by third party providers on our behalf. We require our Service Providers to agree to take reasonable steps to keep the personal information that we provide to them securely. We do not authorize them to use or disclose your personal information except in connection with providing their services.

To comply with legal process or to protect HappyPoints and our users and members

We may share your data: if we believe that disclosure is reasonably necessary to comply with a law, regulation, legal or governmental request; to respond to a subpoena, court order, warrant, or other legal processes; to enforce applicable terms of use or this Privacy Policy, including investigation of potential violations thereof; to protect the safety, rights, or property of the public, any person, or HappyPoints; to detect, prevent, or otherwise address, security, or technical issues or illegal or suspected illegal activities (including fraud); or as evidence in litigation in which we are involved, as part of a judicial or regulatory proceeding.

Business Transfers

We may engage in a merger, acquisition, bankruptcy, dissolution, reorganization, or similar transaction or proceeding that involves the transfer of the information described in this policy. In such transactions, customer information is typically one of the business assets that is transferred or acquired by a third party. If we are acquired by or merged with another company, if we sell or transfer a business unit or assets to another company, in the unlikely event of a bankruptcy proceeding, or as part of any other similar business transfer, you acknowledge that such transfers may occur.

Aggregate or De-identified Information

We may disclose aggregate, anonymous, or de-identified information about users for marketing, advertising, research, compliance, or other purposes.

BEHAVIOURAL ADVERTISING

Interest-based advertising is the collection of data from different sources and across different platforms in order to predict an individual’s preferences or interest and to deliver to that individual, or his/her computer, smartphone or tablet, advertising based materials on his/her assumed preference or interest inferred from the collection of data pertaining to that individual or others who may have a similar profile or similar interests.

We work with a variety of third parties to attempt to understand the profiles of the individuals who are most likely to be interested in the HappyPoints products or services so that we can send them promotional emails, or serve our advertisements to them on the websites and mobile apps of other entities.

These third parties include: (a) advertising networks, which collect information about a person’s interests when that person views or interacts with one of their advertisements; (2) attribution partners, which measure the effectiveness of certain advertisements; and (3) business partners, which collect information when a person views or interacts with one of their advertisements.

In collaboration with these third parties, we collect information about our customers, prospects and other individuals over time and across different platforms when they use these platforms or interact with them. Individuals may submit information directly on our Sites or on platforms run by third parties, or by interacting with us, our advertisements, or emails they receive from us or from third parties. We may use special tools that are commonly used for this purpose, such as cookies, beacons, pixels, tags, mobile advertising IDs, flash cookies, and similar technologies. We may have access to databases of information collected by our business partners.

The information we or third parties collect enables us to learn what purchases the person made, what ads or content the person sees, on which ads or links the person clicks, and other actions that the person takes on our Sites, or in response to our emails, or when visiting or using third parties’ platforms.

We, or the third parties with which we work, use the information collected as described above to understand the various activities and behaviors of our customers, Site visitors and others. We, or these third parties, do this for many reasons, including: to recognize new or past visitors to our Sites; to present more personalized content; to provide more useful and relevant ads – for example, if we know what ads you are shown we can try not to show you the same ones repeatedly; to identify visitors across devices, sales channels, third party websites and Sites, or to display or send personalized or targeted ads and other custom content that is more focused on a person’s perceived interest in products or services similar to those that we offer.

Our interest-based ads may be served to you in emails or on third-party platforms. We may serve these ads about our products or services or send commercial communications directly ourselves or through these third parties.

Visitors may opt-out of receiving interest-based advertising by advertising networks that may be delivered to them on our platform and other websites by visiting the following websites: http://www.aboutads.info/consumers; and http://www.networkadvertising.org. These features will opt a Visitor out of many – but not all – of the interest-based advertising activities in which we or third parties engage.

DO NOT TRACK POLICY

California law requires that operators of websites and online services disclose how they respond to a Do Not Track signal. Some browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference to the website or online service that a user visits, indicating that the user does not wish to be tracked. Because there is not yet a common understanding of how to interpret Do Not Track signals, we do not currently respond to Do Not Track signals. We continue to work with the online industry to define a common understanding of how to treat Do Not Track signals.

In the meantime, you may opt-out of receiving interest-based advertising from advertising networks that may be delivered on our platform and other websites by visiting the following websites. If you want to opt-out of this online behavioral advertising, visit the following sites: https://www.aboutads.info/consumers and https://www.networkadvertising.org.

This will opt you out of many – but not all – of the interest-based advertising activities in which we or third parties engage. Choices you make may be browser and device specific. If you delete your cookies or use a different browser or a different computer or device, you may need to update your opt-out choices. Other third-party Sites provide visitors with the ability to opt-out of receiving interest-based ads on their Sites that you need to control through your settings on that Site. For example, to opt-out of Google’s use of your online behavior for advertising purposes, visit Google’s Ad Settings page.

YOUR RIGHTS AND CHOICES

If you are a European resident, 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 at [email protected] or using the contact information at the bottom of this Privacy Policy.

Additionally, if you are a European resident we note that we are processing your information in order to fulfil contracts we might have with you, or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe.

If you would like to make a request, cancel your account or request we delete or no longer use your account information to provide you Services, contact us at [email protected] or the address set forth at the end of this policy. Subject to applicable law, we will retain and use your account information only as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

Email

You may opt-out of receiving HappyPoints email marketing materials by using the unsubscribe link in these communications. You can also email [email protected] and ask to stop email communications. Please note it can take up to 7 days to process your request.

Third-party analytic services

Some of the services used provide the ability to opt-out. You may opt-out of Google Analytics’ services using opt-out features on their respective websites.

The Google Analytics service is provided by Google Inc. You can opt-out from Google Analytics service from using your information by installing the Google Analytics Opt-out Browser tool: tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: www.google.com/policies/privacy.

DATA RETENTION

To request the removal of your data please email [email protected]. All requests will be processed within 30 days from the time of the request.

Third-party links

Our website may contain links to third-party websites and applications. Subject to your opt-out preferences (see Your rights and choices), we may also use third-party advertisers, ad networks, and other advertising, marketing, and promotional companies, to serve advertisements on our websites. Any access to and use of such linked websites and applications is not governed by this Privacy Policy but instead is governed by the privacy policies of those third parties. We do not endorse these parties, their content, or any products and services they offer, and we do not endorse these parties, their content, or any products and services they offer, and we are not responsible for the information practices of such third-party websites or applications.

CHANGES AND UPDATES TO THIS POLICY

We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

Policy Effective Date 3/13/2018

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