Privacy Policy


Last Modified:  Nov 29th 2022



Happy Talks, LLC and its affiliates and subsidiaries (collectively, “we”, “us” or “our”) are committed to protecting your (“you” or “your”) privacy and empowering you with this privacy policy (this “Privacy Policy”). This Privacy Policy explains how we collect, use, disclose, and apply the information collected when you use or access any of our products and/or services, including our website (www.happytalks.com), applications, platforms, and integrated services (collectively, the “Services”). Our terms of service (the “Terms of Service”) are expressly incorporated herein by reference and are an integral part hereof. The Terms of Service can be found here: [www.happytalks.com/terms].


By using the Services or interacting with us, you are agreeing to this Privacy Policy. If you do not agree with the terms, do not access or use the Services. Please read the following carefully to understand how we collect, use, and maintain your personal information. In addition, it describes your choices for use, access, and correction of your information.


1.         Changes to this Notice. We may change this Privacy Policy from time to time. In the event we make changes, we will notify you by revising the “Revised and Effective as of” date at the top of this Privacy Policy. If there are significant changes to this Privacy Policy, we will attempt to notify you directly by email or provide information via our home page prior to changes becoming effective. We encourage you to review our Privacy Policy whenever you use the Services to stay informed of ways you can protect your privacy.


2.         Information We Collect and Receive. We collect information about you from various sources and methods, including through the use of the following:


            2.1       Information Provided to Us. We collect information that can identify you that you provide directly to us via our website or in connection with the use of our Services. Information provided to us includes:


2.1.1     Account and Profile Information. When you create an account, we collect basic information about you such as name, email address, phone number, payment information, physical address, and any other information you input in open text fields.


2.1.2     Your Content. Our Services are designed for you to store your files, documents, photos, comments, messages, etc. (“Your Content”), collaborate with others, and work across multiple devices and services. To do so, we store, process, and transmit Your Content as well as information related to it to perform the activities that you request.


2.1.3     Customer Support. When you contact us with an issue, you may provide us with a summary of the problem you are experiencing, and any other documentation, screenshots or information that would be helpful in resolving an issue submitted to our customer support. We also may create event logs that are useful in diagnosing performance-related issues, and capture information relating to the support or service issue. To improve customer service, subject to applicable laws, we may also record and review conversations with customer support representatives, and analyze any feedback provided to us through voluntary customer surveys. With your consent, our customer support representatives may sign-in to your account, if appropriate, to help troubleshoot and resolve your issue.


            2.2       Information We Automatically Collect. We receive and store certain types of information automatically, such as whenever you interact with the Services online. Information that we collect automatically includes:


2.2.1     Log Information. We retain information about you when you access and use the Services. This information can include the following: Internet Protocol (“IP”) address, timestamps, browser information, Internet Service Provider “ISP”, web pages visited, URL of the web page you visited before navigating to our website, and device identifiers.


2.2.2     Device information. We collect information about the device you use to access the Services, including your IP address, unique device identifiers, model of your device, your mobile carrier, time zone setting, and operating system.


2.2.3     Usage Information. We monitor user activity in connection with the Services and may collect information about the applications and features you use, websites you visit, as well as types and amount of the Services you use.


2.2.4     Metadata. When you upload Your Content, you automatically upload certain metadata that is connected to the Your Content. Metadata describes other data and provides information about Your Content that will not always be evident to the viewer. In particular, the metadata can describe how, when, and by whom the piece of Your Content was collected and how that content is formatted.


2.2.5     Crash and Error Information. If the Services crash or return an error, we may collect data to determine the cause of the error using first or third party services. The crash or error information collected may include the following: Device IP address, device name, operating system version, application configurations(s), the time and date, and other statistics.


2.3       Information We Obtain from Others. We may obtain information about you from third parties who help us provide our Services to you, from publicly available sources, and from other users of the Services. We may also obtain some information from our marketing partners in order to inform you about products, new surveys, or Services that we think you might be interested in. Finally, we may obtain information that does not identify you directly, but which is later used in a way that may later directly identify you. We may combine that general information with your information to provide related services to you.


3.         Cookies and Other Technologies. Like many other websites, our Site may use “Cookies” or “Other Technologies” (such as “pixel tags”, “web beacons”, “clear GIFs”, links in emails, JavaScript, device IDs assigned by Google or Apple, or similar technologies) to collect information and support certain features of our Site. Cookies and Other Technologies allow us and third parties to obtain information about your visits to our Site, including analyzing your visiting patterns. Although you are not required to accept Cookies when you visit our Site, you may be unable to use all of the functionality of our Site if your browser restricts our Cookies. We use this information to process your requests and to deliver online and mobile advertisements, messages and content for us and others that are specific to your interests. The information we collect from your web browser and from Cookies and Other Technologies does not identify you personally but in some cases, we may link it to personally identifiable information.


3.1       Cookies. Below, we explain the different types of Cookies that may be used on the Site.


3.1.1     Necessary Cookies. Necessary cookies are essential to enable your use of the Services, such as assisting with your account login, so we can show you the appropriate experience and features such as your account information, transaction history, and to edit your account settings. They may also provide authentication and site security.


3.1.2     Preference Cookies. Performance cookies are used to remember your settings and preferences, and to improve your experience on our Services.


3.1.3     Session Cookies. Session cookies are stored only temporarily during a browsing session and are deleted from your device when you close the browser. We use session cookies to support the functionality of the website and to understand your use of the website-that is, which pages you visit, which links you use and how long you stay on each page.


3.1.4     Analytics Cookies. Analytics cookies help collect information about your use of the website and enable us to improve the way it works. These cookies give us aggregated information that we use to monitor site performance, count page visits, spot technical errors, see how users reach the website, and measure the effectiveness of marketing (including emails).


3.1.5     Marketing Cookies. Marketing cookies are used to show users display advertisements across websites such as those on Facebook, LinkedIn, Twitter, or the general web. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party advertisers. We do not display ads for any services besides our own.


3.1.6     Unclassified Cookies. Unclassified cookies are cookies that we are in the process of classifying, together with the providers of individual cookies.


3.2       Other Technologies. In addition to Cookies, we may use other similar technologies, like pixel tags (also known as web beacons and clear GIFs), to, among other things, track the actions of Users of the Services (about usage including email recipients), measure the success of our marketing campaigns, and compile statistics of the Services and response rates.


4.         How We Use Your Information.


            4.1       Use of Your Information. We collect and use the information described above in order to provide you with the Services in a reliable and secure manner. We also collect and use your information for our legitimate business needs. To the extent we process your information for other purposes, we ask for your consent in advance or require that our partners obtain such consent. We may use the information we obtain about you to:


(i)             provide the information, products, and services you request;


(ii)            provide you, if you are a customer, with effective customer service;


(iii)           provide you with a personalized experience when you use our Services;


(iv)           contact you with special offers and other information we believe will be of interest to you (in accordance with any privacy preferences you have expressed to us);


(v)            contact you with information and notices related to your use of our Services;


(vi)           invite you to participate in surveys and provide feedback to us (in accordance with any privacy preferences you have expressed to us);


(vii)          better understand your needs and interests;


(viii)        improve our Services and develop new Services;


(ix)           improve our marketing and promotional efforts;


(x)            improve the content, functionality, and usability of the website;


(xi)           evaluate your interest in employment and contact you regarding possible employment with us;


(xii)          help you, if you are our employee, perform your job functions and to manage our workforce;


(xiii)        enforce our General Terms of Service;


(xiv)        promote security; to protect against and prevent fraud, claims and other liabilities; and to manage corporate risk exposure;


(xv)          meet our internal and external audit obligations; and


(xvi)        use for any other purpose for which we provide notice at the time of collection.


            4.2       Aggregation of De-Identified Information. We may aggregate and/or de-identify information collected through the Services and from other sources so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and we may also share such data with any third parties, including advertisers, promotional partners, business partners, sponsors, and/or others.


5.         How We Share and Disclose Information.


            5.1       We Do Not Sell Personal Information. We do not sell or otherwise disclose personal information we collect about you, except as described herein or otherwise disclosed to you at the time the data is collected. We share information to perform activities that you request.


            5.2       Service Providers and Business Partners. We share the categories of personal information listed above with service providers and business partners to help us perform business operations and for business purposes.


            5.3       Your Consent and Other Applications. We may share information for other purposes pursuant to your consent or with your further direction. You can choose to connect your account with third-party services. By doing so, you’re enabling us and those third parties to exchange information about you and data in your account so that we and those third parties can provide, improve, protect, and promote their services. Please remember that third parties’ use of your information will be governed by their own privacy policies and terms of service.


            5.4       Other Users. Our Services display information like your name, profile picture, device, email address, and usage information to other users you collaborate or choose to share with. When you register your account with an email address on a domain owned by your employer or organization, we may help collaborators and administrators find you and your team by making some of your basic information—like your name, team name, profile picture, and email address—visible to other users on the same domain.


            5.5       Organization Admins. If you are an authorized user of your employer’s subscription to the Services, your administrator may have the ability to access and control your account. Please refer to your organization’s internal policies if you have questions about this. If you aren’t a member of an organization’s account but interact with an authorized user of an organization (for example, by joining a shared folder or accessing content shared by that user), members of that organization may be able to view the name, email address, profile picture, and IP address that was associated with your account at the time of that interaction.


            5.6       Legal Reasons. We may also disclose information about you when we, in good faith, believe disclosure is appropriate to comply with the law, a court order, or a subpoena. We may also disclose information about you to prevent or investigate a possible crime, such as fraud or identity theft; to protect the security of our website; to enforce or apply our Terms of Service or other agreements; or to protect our own rights or property or the rights, property or safety of our users or others. We will attempt to notify users about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority.


            5.7       Sale, Merger, or Other Business Transfer. We also reserve the right to transfer information about you to a successor organization if we transfer the ownership or operation of one of our websites to another organization or if we merge with another organization. If such a transfer occurs, we will use reasonable efforts to direct the transferee to use personal information you have provided to us in a manner consistent with this policy. Following such a sale or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that information.


6.         Your Choices.


            6.1       General Communication Choices. We offer you the choice in receiving communications from us, generally by offering an “opt in” or an “opt out” option, depending on applicable law, when you provide contact information through one of our websites. Additionally, we include an “unsubscribe” link in our electronic newsletters or promotional emails. These options allow you to inform us on how you want to receive communications.


            6.2       Opt-Out from Targeted Advertisements. You may opt out of behaviorally targeted ads anytime by clearing your cache of your browser's cookies. Additionally, you may opt-out of interest-based advertising from some third-party partners by visiting http://preferences-mgr.truste.com/, http://www.youronlinechoices.eu, or the third-party provider’s websites. Please note that opting-out will only prevent targeted ads so you may continue to see generic (non-targeted ads) after you opt-out.


            6.3       Data from Third Parties. We may also obtain information from third parties and combine with information we collect through the Services. Any access that we may have to such information from a third-party is in accordance with the privacy policy and authorization procedures determined by the third-party. We protect data obtained from third parties according to the practices described in this Privacy Policy, plus any additional restrictions imposed by the other sources of the data.


            6.4       Do Not Track. Some browsers offer a “do not track” (“DNT”) option. Since no common industry or legal standard for DNT has been adopted by industry groups, technology companies or regulators, we do not respond to DNT signals. We will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.


7.         Data Processing and Data Transfers. By accessing or using the Services or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S. and other countries and territories, which may have different privacy laws from your country of residence. Whenever we share information of European Union (the “EU”) users outside the EU, we make sure an adequate transfer mechanism is in place.


8.         Security. We take security seriously and has implemented administrative, physical, and technological measures to protect your information from unauthorized access, loss, misuse, disclosure, alteration and destruction. If you wish to report a security concern or if you have a question around security, please submit your inquiry to us in accordance with the “Contact Us” section below. 


9.         European Residents. If you are a resident of the European Economic Area, you have certain rights regarding the personal information we maintain about you. We offer you certain choices about what personal data we collect from you, how we use that information, and how we communicate with you. If at any time you wish to exercise your rights, please reach out to us in accordance with the “Contact Us” section below:


            9.1       Information and Access. You can request to see which personal information we process from you. We can inform you on how and why we process this data unless restricted by law, or if we are unable to verify your identify.


            9.2       Submitting information. You may refrain from submitting information directly to us, although doing so may impact our ability to provide the services, and information you request and/or affect your ability to use the Services.


            9.3       Rectification. You may request to update or correct the personal information we maintain for you.


            9.4       Right to be forgotten/request deletion. You may request deletion of your personal information. We may ask you for additional information to verify your identity and will process your request subject to and in accordance with the law.


            9.5       Restriction. You may request the limitation on the processing of your personal information.


            9.6       Restricting cookies. You may elect not to have a unique cookie identification number assigned to your computer to avoid aggregation and analysis of data collected on our websites. Generally, if you do not wish to receive cookies, you may set your browser to deny cookies or to alert you when a cookie is placed on your computer.


            9.7       Objection. You may remove your consent for the processing of your personal information.


            9.8       Transferability. You may request to transfer your personal information.


10        California Residents.


            10.1      Applicability of CCPA. If you are a resident of the State of California, you have certain rights afforded to you under the California Consumer Privacy Act or the “CCPA”. When we say “Personal Information” in this Section, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information does not include information that is aggregated or information that cannot be reasonably linked to you.


            10.2      Collection of Personal Information of California Residents. We collect Personal Information and Non-Personal Information for the business and commercial purposes described in the Section above titled “How We Use Your Information”, and we share Personal Information with the categories of third parties described therein. We do not sell (as such term is defined in the CCPA) the Personal Information we collect (and will not sell it without providing a right to opt out).


            10.3      California Resident Rights: Subject to certain limitations, the CCPA provides California residents the following rights:

10.3.1   Right to Know. You have the right to request that we disclose to you the Personal Information we collect, use, or disclose, and information about our data practices;


10.3.2   Right to Request Deletion. You have the right to request that we delete your Personal Information that we have collected from you;


10.3.3   Right to Opt-Out. You have the right to request that we no longer sell your Personal Information to third parties;


10.3.4   Right to Non-Discrimination. We will not discriminate against you for exercising any of these rights.


            10.4      Requests for Information. California residents may make a request pursuant to their “right to know”, “right to request deletion”, and/or “right to opt-out” under the CCPA by contacting us in accordance with the “Contact Us” section below. In order to verify your request to know or delete information, we may require you to provide us with certain information to be used solely for the purpose of verifying your identity.


            10.5      Appointment of Agent. Under the CCPA, you may exercise these rights yourself or you may designate an authorized agent to make these requests on your behalf. We may request that your authorized agent have written permission from you to make requests on your behalf and may need to verify your authorized agent’s identity.


11.       Personal Information Retention. We will retain information required to comply with privacy requests, manage active accounts, as required by law, in order to resolve disputes, or enforce our agreements. We may also retain copies of your information for disaster recovery purposes.


12.       Links to Third Party Websites. We may place lines on the Services. When you click on a link to a third-party website from our website, your activity and use on the linked website is governed by that website’s policies, not by ours. We encourage you to visit their websites and review their privacy and user policies.


13.       Children’s Privacy. We are committed to protecting children’s privacy and to follow the laws, regulations and guidelines in regard to children’s privacy. We do not knowingly accept or solicit Personal Information from a user known to be under the age of thirteen (13). If you have concerns regarding children’s privacy, please contact us in accordance with the “Contact Us” section below.


14.       Contact Us. If you have any questions or concerns about our Privacy Policy, please contact us via email at help@happytalks.co