Privacy Policy

Welcome to our privacy policy. We respect your privacy and are committed to protecting your personal data. This privacy policy lets you know how we look after your personal data when you visit our website (regardless of where you visit it from) or use our services (the “website”), tells you about your privacy rights and how the law protects you.

1. Important information and who we are

Purpose of this privacy policy

This privacy policy gives you information on how we collect and process your personal data when you use the website, including any data you may provide when you use our services. This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

Tahora Limited, trading as Happl is the data controller and is responsible for the processing of your personal data (referred to as “Happl", "we", "us" or "our" in this privacy policy).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

As part of the services that we provide to our customers, we also act as a data processor in relation to employee personal data that they provide us with. To ensure that you understand how your data is used, we have also detailed that processing below. We have indicated where we act as a data controller, and where we act as a data processor.

Contact details

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

Full name of legal entity: Tahora Limited, trading as Happl

Email address: support@happl.com

Postal address: Tahora Limited, trading as Happl, 71-75 Shelton Street, London, Greater London, United Kingdom, WC2H 9JQ

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 really appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review and may update it from time to time. Please check back here regularly to see the most up to date version.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The data we process about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may be provided with, collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

·       Identity Data includes first name, last name, profile picture, date of birth, age and gender.

·       Contact Data includes billing address, delivery address, email address and telephone numbers.

·       Financial Data includes bank details and credit card information.

·      HR Data includes detailed HR information such as your salary, start date, role, position, manager, options allocation, probation end date, working pattern, employee ID, tax ID, tax code, contract type, place of work, team, department, time off usage and allowance and working location.

·       Transaction Data includes details about payments to and from you, together with other details of products and services you have purchased from us.

·       Technical Data includes internet protocol (IP)address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform,and other technology on the devices you use to access this website.  

·       Sensitive Data includes information about your racial or ethnic origin, political opinions, religious and philosophical beliefs, trade union membership, health data and sex life and/or sexual orientation.

·       Profile Data includes purchases or orders made by you, your interests, preferences and feedback.  

·       Usage Data includes information about how you use our website, products and services.

·       Marketing and Communications Data includes your preferences in receiving marketing from us and third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact, Financial, HR and Sensitive Data by filling in forms or by corresponding with us via our website. Your employer may also provide us with this data as detailed below. This includes personal data you provide when you:

• create an account on our website;

• access or purchase goods and/or services via our wesbite;  or

• give us feedback or contact us.

• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy [https://happl.com/legal/cookie-policy] for further details.

• Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:

          o Technical Data from analytics providers such as Google based outside the UK;

          o Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe;

          o Identity, Contact, Financial, HR Data and Sensitive Data from your employer, either manually or via an automatic integration with their HR, accounting or other software provider.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.
  • Where we have been appointed to process that personal data on behalf of our customers, and we do so in accordance with their specific instructions.

Generally, with the exception of Sensitive Data, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below a description of all the ways we process your personal data and have indicated whether we do so as a data processor or a data controller. Where we act as a data controller, we have identified which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Processing undertaken as a data processor on behalf of our customers, acting in accordance with their instructions

Purpose/Activity
Type of data

To register you as a new customer and/or for a Happl account

(a) Identity

(b) Contact

To help you access and use the website and our products and services, including to:

  • access employee benefits via the website;
  • engage teams via the website;
  • add employees to interest groups to allow managers to support and assign budget;
  • create bank cards via Stripe to allow employees to access benefit allowances;
  • purchase products and services and send gifts to employees for recognition and key events;
  • process accommodation requests for employees; and
  • provide a personalised and inclusive offering of benefits, allowances and groups.

(a) Identity

(b) Contact

(c) Financial

(d) HR

(e) Transaction

(f) Profile

(g) Sensitive

(h) Usage

(i) Marketing and Communications

Processing undertaken as a data controller

Purpose/Activity
Type of data

To register you as a new customer and/or for a Happl account

(a) Identity

(b) Contact

Performance of a contract with you

  • To help you access and use the following services: purchase products and services and send gifts using a personal credit card or other payment method;
  • enable you to create an account with or purchase products or services from a third party such as Headspace or gym membership providers; and
  • allow you to leave reviews relating to products, services or third parties on our website.

(a) Identity

(b) Contact

(c) Financial

(d) HR

(e) Transaction

(f) Profile

(g) Sensitive

(h) Usage

(i) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to operate our business and provide products and services to our customers)

(c) Consent, for Sensitive Data

To manage our relationship with you which may include notifying you about changes to our terms or privacy policy.

(a) Identity

(b) Contact

(c) Profile

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Sensitive

(g) Technical

(a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

(b) Consent, for Sensitive Data

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

(g) Sensitive

(a) Necessary for our legitimate interests (to develop our products/services and grow our business)

(b) Consent, for Sensitive Data

Promotional offers from us

When permitted to do so by law, we may use your Identity, Contact, Technical, Usage, HR, Sensitive and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. If we have your consent to do so, we may contact you by email with information about these products and services.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see https://happl.com/legal/cookie-policy

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

• External Third Parties:

          o Your employer, when they have asked us to do so as part of the services that we provide to them.

          o Service providers acting as data processors who provide IT and system administration services.

          o Payment and bank card processing providers, such as Stripe.

          o Professional advisers acting as data processors or data controllers including lawyers, bankers, auditors and insurers who provide professional services to us.

          o HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.

• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

When we share personal data with the third parties listed above this may involve a transfer of your personal data outside the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring appropriate legal safeguards are implemented. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

When we are acting as a data controller, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax, legal and/or accounting purposes. In some circumstances you can ask us to delete your data. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. When we are acting as data processor, your employer will notify us of our obligations regarding data deletion when our relationship with them ends.

9. Your legal rights

Under certain circumstances, you have the following tights under data protection laws in relation to your personal data:

o Request access to your personal data.

o Request erasure of your personal data

o Object to processing of your personal data

o Request restriction of processing your personal data

o Request transfer of your personal data

o Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

Last Edited:

January 24, 2023

For more information or if you have any questions please email support@joinhappl.com