Effective from 5 November 2020
This Policy has been written in accordance with the Data Protection Act 2018.
Please also refer to the Terms of Service which we are also used to govern your use of this website.
What is Happity?
Happity is an online booking system and search platform which lists activities and classes for children; it’s aimed at Carers looking for activities to do with their babies and toddlers. Its goals are to support parents in their early years of parenthood as well as support Class Providers who are running and developing their businesses.
We use “Happity” here to refer to the website and our services offered as part of that website. We also use “Happity”, “we”, “us” and “our” to refer to the company operating our website and services. We use the term “Class Providers” as our main customers and “Carers” are the public audience we are providing a service to, and in general, anyone using the website and reading this Policy is “you”.
Who controls the use of my information?
Happity is operated and provided to you by Happity Limited. Happity Limited is the data controller of all personal data provided to us or that we otherwise obtain. If you book a class on Happity, then the class provider will also be a controller of your personal data.
The Information we collect
Happity may collect and use the following kinds of personal information from you:
- Contact Data: Information that you provide for the purpose of registering your business and classes on the website (such as name, email, phone, company name and description, class timetable and venue details)
- Identity Data : login details (username and password)
- Financial Data: datayou provide so that we can process payments for you including yourStripe account reference number
- Transaction Data includes details of classes you have sold through Happity
- Marketing Data includes your preferences in receiving marketing from us.
- Location Data whichis data showing where your device is located from time to time. We will only collect Location Data with your consent
- Contact Data: Information that you provide to us, including for the purpose of registering with Happity for booking classes and/or booking classes as a guest (such as name, email, address, phone, name, email, phone)
- Identity Data: Your login details (username and password)
- Children’s Data: information about your child, including child’s name, child’s age, child’s gender, any other useful information (eg allergies)
- Transaction Data includes details of classes you have booked through Happity
- Marketing Data includes your preferences in receiving marketing from us
- Location Data which is data showing where your device is located from time to time. We will only collect Location Data with your consent
- Technical Data includes data such as internet protocol (IP) address, your login data, browser type and version, cookies, 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 our website and any communications we may send to you.
- Usage Data includes information about how you use our website such as information about your visit to our website, including the full Uniform Resource Locators (URL) clickstream to and through, pages you viewed or searches you made, page response times, download errors, length of visit, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as it does not directly or indirectly identify you. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be used in accordance with this PPolicy.
Payment services are provided through Stripe so we do not obtain any bank details or credit or debit card information from our users.
Personal data you provide to us
From time to time you may provide to us personal data. This may be because:
- You access and interact with our website;
- You create an account on our website
- You purchase classes on our website;
- You offer for sale and/or sell classes on our website
- You or your employer provides services to us;
- You apply to work with us as an employee or a consultant;
- You provide feedback or reviews to us;
- You respond to a survey or questionnaire or enter a promotion or competition;
- You sign up for our newsletter;
- You otherwise contact us including with queries, comments or complaints.
We shall process all such personal data in accordance with this Policy. Certain personal data is mandatory to be provided to us in order that we can fulfil your request, for example to create an account on our website, and we shall make this clear to you at the point of collection of the personal data.
All personal data that you provide to us must be true, complete and accurate. If you provide us with inaccurate or false data, and we suspect or identify fraud, we will record this and we may also report this to the appropriate authorities.
When you contact us by email or post, we may keep a record of the correspondence and we may also record any telephone call we have with you.
Personal data we automatically collect about you
When you use our website, we may automatically collect and store information about your Technical Data and Usage Data for the purposes of research and analysis.
Some of this information is collected using cookies and similar tracking technologies. If you want to find out more about the types of cookies we use, why, and how you can control them, please see our Cookies Policy.
Personal data we receive from others
If we reasonably believe that any of the personal data you have provided to us is inaccurate, we may receive further personal data from third parties, such as credit reference agencies and the electoral register, to try to confirm your identity.
We may also receive personal data about you or your child from our third party service providers, including our payment service providers and our analytic service providers.
Given the nature of our website, if you are a Class Provider, we may receive personal data about you from a Parent/Legal Guardian that has purchased a class from you to; and if you are a Parent/Legal Guardian we may receive personal data about you from a Class Provider that has sold a class to you.
When a Parent/Legal Guardian books a class, we ask you to provide some details about the child. This information is shared with the Class Provider of the class you are booking for the purpose of ensuring that the class is within the specified age range for the class, for tracking payment and to create a class register. We or they do not communicate directly with the minor through the website. The information is provided with the consent of the Parent/Legal Guardian. Class Providers will have consented to our Terms of Service for using the booking system which outlines their responsibility in keeping this information secure.
How we use your personal information
Happity will only collect, use, share, and otherwise process the information we have about you for the purposes described in this policy where legally permitted. These legal bases include:
- For Happity to comply with a legal obligation, a court order, or to exercise and defend legal claims;
- For Happity to comply with a contractual obligation with you
- Where you have made the information manifestly public;
- Where you have given consent; and
- Where necessary for the purposes of Happity’s or a third party’s legitimate interests . When we refer to legitimate interests we mean our or a third party’s legitimate business interests in the normal running of our or their business which do not materially impact your rights, freedom or interests.
|PURPOSE/ACTIVITY||TYPE OF DATA||LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST|
|To register you and/or create your account and enable you to manage your account||Contact Identity||Performance of a contract with you|
|To enable Parents/Guardians to book a class||Contact Identity Children Financial||Performance of a contract with you|
|To manage your account including managing payments, returns and refunds, and to send invoices and statements to Class Providers||Contact Identity Financial Transaction||Performance of a contract with you|
Necessary for our legitimate interests (fraud-checking)
|To manage our relationship with you such as notifying you about changes to our Terms of Service or this Policy, remind you when you information is out of date|| Contact|
|Performance of a contract with you|
Necessary to comply with a legal obligation
Necessary for our legitimate interests
|To administer and protect our business and this website (including improving and fixing our service, analysis, testing, system maintenance, support, reporting and hosting of data)||Technical||a) Necessary for our legitimate interests (for running our business 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 and understand the effectiveness of the advertising we serve to you|| Contact Identity|
Marketing Technical Location
|Necessary for our legitimate interests (to analyse how customers use our website and manage our business accordingly)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||Technical|
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|For NHS Track & Trace||Contact Data||To comply with our legal obligations to help prevent the spread of Covid19, if requested, your contact details will be provided to NHS Track and Trace within a 21 day period of attending any class booked via Happity. If you do not wish for your contact details to be shared in this way, you must notify [email protected] and the Class Provider before your class takes place and you agree that you may not be able to attend a Class.|
|If you are a Carer, to determine how far away a class is and which ones are the most relevant to you. If you are a Class Provider, to list your Class accordingly||Location Data||Consent|
You benefit from a number of rights in relation to your information that we process. While some of these rights apply generally, certain rights apply only in certain limited cases.
Some of these rights are complex, and not all of the details have been included below. Further information can be found here
We describe these rights below.
Class Providers, you can access much of the data we hold about you by viewing your class profile pages on Happity. Carers and Class Providers who require additional information, email us at [email protected] to request a copy of the personal information we hold about you. Where legally required, we will provide your information in an easily accessible format and assist in transferring some of this information to third parties.
Rectify, Restrict, Limit, Delete.
You can also rectify, restrict, limit or delete much of the personal information we hold about you by emailing us at [email protected] and we will rectify, restrict, limit or delete your information as requested.
If we process your information based on our legitimate interests as set out in this Policy, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. Where we use your data for direct marketing, you can always object using the unsubscribe link in such communications, or by emailing us at [email protected].
Where you have previously provided your consent to us, you have the right to withdraw your consent to the processing of your information at any time. For example, you can withdraw your consent to our use of your Marketing Data by using the unsubscribe link in our email marketing communications. If you have consented to receive marketing information from a Class Provider, please contact that Class Provider to withdraw consent.
You can also revoke any consent you have provided to us for our collection of your Location Data by changing the setting on your mobile device and emailing us at [email protected].
If you withdraw your consent to the use of your information for purposes set out in this Policy, you may not have access to all (or any) of our services and we might not be able to provide you all (or any) of our services. In certain cases, we may continue to process your information after you have withdrawn consent if we have a legal basis to do so or if your withdrawal of consent was limited to certain processing activities
We reserve the right to charge an administrative fee if your request in relation to your rights is manifestly unfounded or excessive, and we may ask for identification from you before we can fully respond to your request.
If you wish to raise a concern about our use of your information (and without prejudice to any other rights you may have) please tell us. We shall review and investigate your complaint and try to get back to you within a reasonable time. You do also have the right to contact the Information Commissioner’s Office (or ICO) at www.ico.org.uk.
Sharing your Data
Given the nature of our website, if you are a Carer, we may share your Contact Data and Children’s Data with a Class Provider that you have booked a class with; and if you are a Class provider we may share your Contact Data with a Carer who has booked a class with you.
For our legitimate interests, we may share any of personal data with our service providers, sub-contractors, consultants and agents that we may appoint to perform functions on our behalf and in accordance with our instructions, including IT service providers, group companies, accountants, auditors and lawyers.
We shall provide our service providers, sub-contractors, consultants and agents only with such of your personal data as they need to provide the service for us and if we stop using their services, we shall request that they delete your personal data or make it anonymous within their systems.
If we need to use your personal data to comply with any legal obligations, demands or requirements, for example, as part of anti-money laundering processes or to protect a third party’s rights, property, or safety then in doing so, we may share your personal data with third party authorities and regulatory organisations and agencies.
If we choose to merge, sell assets, consolidate or restructure, finance, or sell of all or a portion of our business by or into another company then the new owners may use your personal data in the same way that we do as set out in this Policy.
Marketing and spam.
We know that you do not want spam or marketing calls from third parties, so we will never sell or rent your contact information to third parties, and we won’t share it with a third party except as set out in this Policy.
If you ask us to remove you from our marketing list, we shall keep a record of your name and email address to ensure that we do not send to you marketing information. If you still have an account with us, we shall continue to email you in relation to your account only.
Securing your data
Happity will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
However, you acknowledge that the internet is inherently insecure, and we cannot guarantee security of data sent over the internet. Information relating to electronic transactions entered into via this website will be protected by encryption technology.
Cross-border data transfers
Some or all of your personal data may be stored or transferred outside of the United Kingdom and/or European Economic Area (the EEA) for any reason, including for example, if our email server is located in a country outside the United Kingdom or the EEA or if any of our service providers are based outside of the United Kingdom or the EEA.
In addition, personal information that you submit for publication on the website will be published on the internet and may be available around the world. You agree to such cross-border transfers of personal information.Where we are required to transfer your data to another jurisdiction, particularly where the data is transferred out of the European Economic Area, it will only be transferred to countries that have been identified as providing adequate protection for personal data or to a third party where we have approved transfer mechanisms in place to protect your personal data – i.e., by entering into the European Commission’s Standard Contractual Clauses.
Happity commits to retain personal data only for as long as is necessary, which is a requirement of law.Where we have no legal basis for continuing to process your personal data, we shall either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
For the avoidance of doubt, we may use anonymous data, such as usage data for research or statistical purposes indefinitely without further notice to you.
Updating this Policy
Happity may update this Policy from time to time at our discretion and in particular to reflect any changes in applicable laws. If we do so, and the changes substantially affect your rights or obligations, we shall notify you if we have your email address. Otherwise, we shall post a new version of this Policy on this website. You should check this page occasionally to ensure you are familiar with any changes.
This website contains links to other websites. Happity is not responsible for the privacy policies or practices of any third party.
If you have any questions about this Policy or Happity’s treatment of your personal information, please write to: [email protected]
Happity Ltd, 85 Great Portland Street, London, England, W1W 7LT