Privacy Policy

1. General Information:

Happymind is a mobile application with a marketing website developed by ALEGRA DIGITAL LIMITED (shall be referred to as “Happymind”, “us”, “we”, or “our” hereafter) having its registered office at 9 Hadley Road, Enfield, Middlesex, England, EN2 8JTy. For Happymind, it is very important to ensure the protection and security of your personal data from the moment you log in to the mobile application. Happymind takes all the necessary measures for this and processes your personal data in accordance with the relevant legislation when necessary. 

For the purposes of this Privacy Policy; 

• “Data subject” (natural person concerned) means the natural person, whose personal data are processed,
• “Personal data” means any information relating to an identified or identifiable natural person,
• “Processing of personal data” means any operation which is performed on personal data, wholly or partially by automated means or non-automated means which provided that form part of a data filing system, such as collection, recording, storage, protection, alteration, adaptation, disclosure, transfer, retrieval, making available for collection, categorization, preventing the use thereof.

This Privacy Policy contains information about which personal data is collecting and processing, our purpose of collecting and processing personal data, the third parties which we share your personal data with, whether we transferred your personal data outside of the country, how we store and protect your personal data and your rights about managing your personal data.

Happymind reserves the right to change this Privacy Policy at any time in order to adapt to the necessary changes in the case of changes in the legislation in force. If there are significant changes to this Privacy Policy, Happymind will notify you by sending you a notification. Nevertheless, Happymind advises all its users to visit the disclaimer page every time they log in to the mobile application.

1. Data Controller:

Happymind is the data controller of the personal data stored and processed throughout its software, mobile application or website. The company and contact information for the data controller are as follows:

Company Name: ALEGRA DIGITAL LIMITED 

Tax ID: 10590611

Address: 9 Hadley Road, Enfield, Middlesex, England, EN2 8JTy

Correspondence address: 9 Hadley Road, Enfield, Middlesex, England, EN2 8JTy

E-mail: info@happymindlabs.com

1. Processed Personal Data and Purpose of Processing:

Happymind may record, store, classify, process and transfer the personal data of its users and visitors to fulfill the legal obligations. Happymind stores and processes all data to fulfil its contractual obligations under the service agreement under the applicable legislation and limited to this.

Happymind requests some of personal data from its users at the registration stage, during the use of the application. Happymind stores and processes users’ personal information such as first name, last name, sex, identification number, date of birth, e-mail, postal address, phone number, assumed name, password, photo, location, IP information, device ID information, conditions of general and mental health;

• for compliance with relevant legislation and fulfilling contractual obligations within the scope of the service agreement as well as contacting in cases of emergency,
• for our legitimate interest in improving the service provided, to provide new services in line with customer satisfaction and needs and for marketing purposes,
• to provide our service and fulfil our contractual obligations including to direct clients

When processing the special category Personal Data such as sex and mental health conditions, we do so for the purposes of entering into a contract with you for the provision of services. When processing special category personal data, data protection laws require us to identify a special condition for that processing. The special condition we rely on is the provision of health care and can be found under Article 9 (2) (h) of the GDPR.

Your sensitive personal data such as sex and mental health conditions are collected by Happymind and shared with contracted suppliers of the platform (this includes the psychotherapist that provides counselling and a third-party call center). Your Sensitive Personal Data will not, under any circumstance, be shared with third parties apart from the service providers via our platform.

Happymind collects above-mentioned personal data directly from the users as data subject.

We like to develop our software with artificial intelligence to provide all our users with a better experience. Therefore, in addition to all of these, we use cookies to know about your behavior on our mobile application such as how much time you spent on the Happymind application and what are your interests. That ensures us to provide you a customized service according to your needs or according to your liking. You may get more information about our Cookies Policy and how you can manage them on your mobile phone or your computer.

1. Storage Principles:

Happymind will store your personal data as shown in the table below for defined purposes, and periods. Your Personal Data is deleted or destroyed at the first destruction period following the expiry of the said period. We like to state that we are storing your personal data pseudonymised and encrypted according the rules stated in GDPR and UK Data Protection Act.

1. Your personal data described below will be processed in order to fulfill the legal obligations Happymind is subject to and for the purposes of fulfilling our contractual obligations under the service agreement. We do not rely on your explicit consent when processing your personal data other than where we obtain your consent for marketing purposes. You are able to unsubscribe or withdraw your consent for marketing at any time.

Which Data	What Purposes	For How Long
Name, Surname, Telephone Number, E-mail address, Address	To compliance with relevant legislation and fulfilling contractual obligations stated in the Terms and Conditions and to contact in case of emergency	Stored until the end of the 10 (ten) years from the termination of the contractual relation
Age	To compliance age of consent auditing on the users	Stored until the end of the 10 (ten) years from the termination of the contractual relation
IP Information	For compliance with relevant legislation and fulfilling contractual obligations stated in the Terms and Conditions	Stored until the end of the 10 (ten) years from the termination of the contractual relation
Device ID Information	For compliance with relevant legislation and fulfilling contractual obligations stated in the Terms and Conditions	Stored until the end of the 10 (ten) years from the termination of the contractual relation
Case File (ID Information, address information)	For compliance with law and legal processes and measures in the context of legal action, to protect our legitimate interests in the event of uncollected product fees. Monitoring unlicensed software use in case one of the parties takes legal action in the context of a dispute	10 (ten) years following the finalization of the trial period
Case file (Subject of dispute and all related information and documents)	For compliance with law and legal processes and measures in the context of legal action, to protect our legitimate interests in the event of uncollected product fees. Monitoring unlicensed software use in case one of the parties takes legal action in the context of a dispute	10 (ten) years following the finalization of the trial period

1. Collection of Personal Data for our legitimate interest in improving our platform provided, to offer new products and services in line with customer satisfaction and needs and other commercial purposes:

Which Data	What Purposes	For How Long
E-mail address	For our legitimate interest in improving the service provided, to provide new services in line with customer satisfaction and needs and for marketing purposes	Until the termination of the contractual relation
IP Information	For our legitimate interest in improving the service provided, to provide new services in line with customer satisfaction and needs and for marketing purposes	Until the termination of the contractual relation
Device ID Information	For our legitimate interest in improving the service provided, to provide new services in line with customer satisfaction and needs and for marketing purposes	Until the termination of the contractual relation

1. Collection of special category personal data to further develop and improve AI machine learning software system to offer the best service to our users:

Which Data	What Purposes	For How Long
Sex	To provide our service and fulfil our contractual obligations including improvements to the service and for academic researches projects to further develop new services and functions.	Stored until the end of the 10 (ten) years from the termination of the contractual relation
Mental Health Conditions	To provide our service and fulfil our contractual obligations including improvements to the service and for academic researches projects to further develop new services and functions.	Stored until the end of the 10 (ten) years from the termination of the contractual relation

1.  Sharing of Personal Data:

Happymind transfers the personal data to third parties limited to the service acquired to fulfill obligations and proportional to these purposes only under the legislation and the permission received from the data subjects. Happymind shares your personal data with other relevant parties including technical support teams, technology partners and universities to serve and improve Happymind services and marketing purposes of Happymind. Also, your personal data may be shared, when necessary, in accordance with the laws and/or within the framework of the information requested by public institutions. 

However, Happymind takes all necessary precautions to ensure that there are no rights or security violations in all data transfer procedures. Happymind is not responsible for any violation or loss of rights that may occur due to the failure of the person, institution or organization to whom Happymind shares data in accordance with the applicable legislation to take the necessary measures. We like to inform you that we have strict data-sharing contracts with the third parties to make them act under the relevant legislation and ensure your data security.

We also store, process and share your;

• User-Generated Data: Such as de-identified dialog contents and form answers,
• Behavioral Data: Such as relating to your behavior and interests based on online activity,
• Aggregated Data: Information that we collect from multiple sources and individuals in an anonymous format which allows us to prepare data summaries or summary reports for our clients. Aggregated Data does not constitute Personal Data so it does not directly or indirectly reveal our users’ identity.

to understand the popularity of our features and improve our Services, including to assess the performance of our Services, to provide a personalized usage experience. In order to get all of these purposes, we share your user-generated data, aggregated data and behavioral data in an anonymously format with the Google Analytics and the universities which have a data sharing agreement for academic and clinical studies.

1. Transferring of Personal Data to Abroad:

Happymind cooperates with the program partner institutions, organizations, domestic or international third parties, and institutions that receive data storage services in the cloud system and marketing activities. Therefore, Happymind may transfer personal data through direct or indirect national or foreign subsidiaries to carry out its activities.

Happymind shares anonymously,

• your de-identified personal data related to Device ID and IP address with Google Analytics residing at [1600 Amphitheatre Parkway, Mountain View, CA 94043] who provides web analysis services, and
• your de-identified personal data with Google Cloud (Google LLC with the registered address 1600 Amphitheatre Parkway, Mountain View, California 94043, United States), AWS (Amazon Web Services, Inc. with the registered address 410 Terry Ave. N., Seattle, WA 98109-5210, United States) and Microsoft Azure (Microsoft Cooperation with the registered address Redmond, Washington, United States) who provide cloud services.

Furthermore, Happymind corporate e-mail network operates on Gmail (Google) software. In this case, all e-mail communication you perform over Happymind business e-mail address is stored in Gmail (Google) servers abroad, with encryption. Happymind will encrypt your personal data you will send attached to e-mails. 

Happymind that have an agreement on sending commercial electronic messages to its users with One Signal and HubSpot. We kindly remind you to visit these companies’ privacy policy page here.

All purchases within the application are provided through Apple and Android applications. Happymind can see all purchases but does not store data about them. Therefore, he is not responsible in any way for the problems experienced with payments.

Only you can access all the information you saved into the application. Permitted information (information except e-mail addresses) can changed only by the user him/her self. It is not possible for another member to access and change information about you unless you give permission.

1. Relations with Other Websites:

There may be links in the content of Happymind that lead users to different websites. There may be a risk causes usage of these kind of links to other websites and Happymind does not give a guarantee about their privacy policy. Happymind always advises all its users to visit the privacy policy page of other website links.

1. Plug-Ins:

Happymind may also use plug-ins from the various platforms such as Twitter, Instagram, Google, YouTube, Facebook. If you want to create an account on Happymind or visit our marketing website that contains a plug-in, your browser will create a direct link to the servers of these platforms. They may receive information about you, the fact that you have visited our website, your IP-address and whether you have interacted with their plug-in at our website. These companies will receive the information whether you are a user on their platform or not that way. These data will be stored with the above-mentioned companies in the countries where they are located, including in the USA. 

You can prevent these plug-ins from loading by using a script-blocker add-on, which you can download for your browser. We do not have any control on the collection or processing of personal data that is carried out by such platforms.

We definitely suggest you to visit Facebook, YouTube, Instagram, Twitter and Google privacy policy pages to have more information about how they process and store your data.

1. Legal Rights of Users:

Each user has the right to request to the Happymind about him/her;

1. to learn whether his/her personal data are processed or not,

1. to demand for information as to if his/her personal data have been processed,

1. to learn the purpose of the processing of his/her personal data and whether these personal data are used in compliance with the purpose,

1. to know the third parties to whom his personal data are transferred in country or abroad,

1. to request the rectification of the incomplete or inaccurate data, if any,

1. to request the erasure or destruction of his/her personal data under the conditions referred to relevant legislation,

1. to request reporting of the operations carried out pursuant to sub-paragraphs (d) and (e) to third parties to whom his/her personal data have been transferred,

1. to object to the occurrence of a result against the person himself/herself by analyzing the data processed solely through automated systems,

1. to claim compensation for the damage arising from the unlawful processing of his/her personal data,

1. to ask to correct, delete, limit or stop using his/her information,

1. to ask to move his/her information to a third party,

1. to change his/her mind about permission of holding his/her information or sending him/her marketing.

In case of you would like to exercise any of these rights or if you have any questions about our Privacy Policy, please contact us at privacy@happymindlabs.com. 

If you have any concerns, you have the right to make a complaint to a data protection supervisory authority:

• If you are in the UK, the supervisory authority is the Information Commissioner’s Office (ICO). You can visit their website at www.ico.org.uk.

• If you are in the EU, you can find your local data protection authority from the European Commission website at https://ec.europa.eu/newsroom/article29/items/612080/en. 

You can submit the above requests to the email address privacy@happymindlabs.com. Happymind will answer your request at the shortest time possible and aiming to respond in 30 (thirty) days following the receipt of relevant documents.

We kindly remind you that if you revoke your authorization for storing and processing your personal data within Happymind, you may not be able to use our application. We need to process your Personal Data to comply with law and perform our contractual obligations stated in the Terms and Conditions.

In this case, we may have to stop you from using our website or delete your Happymind account and we will notify you if this is the case at the time.