PRIVACY POLICY

Our commitment to privacy:

Happiify know that protecting the privacy and confidentiality of your personal information is important to you. This Privacy Policy governs all publications of Happiify Inc., on the collection, use and disclosure of your personal information in any form, whether written, electronic or otherwise, by Happiify Inc.. The collection, use and disclosure of your personal information is governed by the Personal Information Protection and Electronic Documents Act (the "Act"), and any applicable provincial legislation. This Privacy Policy explains what personal information may be collected from you and how it is used. It also explains how you can ask questions, make suggestions, and express concerns about our privacy practices.

Be aware that our websites, digital properties, mobile applications and mobile enabled sites (our "Sites") may contain links to other websites that are maintained by third parties who are not required to comply with this Privacy Policy and for which Happiify Inc. has no responsibility. Please review the privacy policies on any third party websites to determine their information handling practices.

This Privacy Policy is available to the public through our Sites, and in paper form from Happiify Inc.. If you have any additional concerns or questions, we encourage you to contact us and we will address your concerns to the best of our ability. Please read this Privacy Policy carefully, and check back periodically as we may update it from time to time.

What is personal information? Personal information is any information about an identifiable individual.  

Happiify Inc. is responsible for personal information in its possession and under its control. Happiify Inc. has implemented policies and practices to give effect to this Privacy Policy, including training and communicating with our employees about the importance of privacy and implementing security procedures that reasonably protect the personal information you provide to us. In addition, Torstar Corporation, Happiify Inc.'s parent company, has appointed a Chief Privacy Officer to oversee personal information-handling practices of Happiify Inc..

What is excluded from privacy protection? This Privacy Policy does not impose restrictions on: business contact information (including name, title, work contact information) collected, used or disclosed solely for the purpose of communicating with the individual in relation to their employment, business or profession; information collected, used or disclosed solely for journalistic, literary or artistic purposes; publicly available information, such as an individual's name, telephone number and address when listed in a directory or made available through directory assistance; or information that is aggregated and not associated with a specific individual, including demographic information and statistics.

Children: If you are under the age of majority in your jurisdiction of residence, be sure to obtain your parent or guardian's permission before you send any personal information to us, or anyone else. We encourage parents to get involved with their children's online usage and to be aware of the activities in which they are participating.

What personal information do we collect, and why?

We collect personal contact information (such as your name, address, email address and telephone numbers) if you: sign up for a newsletter; subscribe to a newspaper; sign up to receive electronic messages, including by email or SMS; register on an online forum or website, or to attend a paid event; download and use one of our mobile applications or register on a mobile application; purchase any product or service from Happiify Inc.; are a classified advertiser or auction participant; or provide it to us when you attend a trade or consumer show. This information is used to fulfill your request for information, products or services, to provide targeted advertising, and to respond to your inquiries. From time to time this information may be used to provide reward points or apply credit, as applicable in the circumstances.

We will retain your subscriber ID and passwords to allow you to login to our Sites and so that upon request by you we may remind you of them.

If you enter a contest or other promotion, we collect and use your personal contact information to administer the contest or promotion including contacting, announcing and promoting prizewinners, and responding to your inquiries. In addition, sometimes our contest rules provide that we may contact contest entrants with promotions and product information. Those rules will also include a way for you to indicate to us that you do not want to be contacted for this purpose. Some contests may also involve co-sponsors, who have their own privacy practices. In these cases, the contest rules and/or entry forms will indicate that your personal information is also being collected by these co-sponsors and will provide you with the ability to opt-out from receiving promotions and product information from them.

We may collect demographic information, and may use this information along with your personal contact information in order to gain a better understanding of your interests so that we may improve our products and services and develop new products and services, and to determine your eligibility for other products and services.

We maintain transactional information (such as purchase or subscription history, a list of promotions offered to you, and contests entered) in order to fulfill your request for information, products or services, to respond to your inquiries, and to provide a more personalized experience on our Sites.

We may also use demographic information, personal contact information and transactional information to contact you about changes, enhancements or other notices related to products or services you requested from us or which Happiify Inc. provides. In addition, we may use this information to provide you with more targeted offers, advertising, information and content (including offers and other information that has been supplied to us by our affiliates and selected sponsors or advertisers), including on websites you visit ("Marketing Offers"). If you do not wish to receive Marketing Offers, you may opt-out at any time by following the opt-out procedure below.

We keep notes and special instructions for classified advertisers and subscribers to help us fulfill your request and provide customer service. We may record or monitor your telephone calls with our customer service representatives for training and quality assurance purposes. We may also keep records of your interactions with our customer service team, and will use this information to fulfill your request for information, products or services, to respond to your inquiries, to improve our products and services and develop new products and services, to contact you about changes, enhancements or other notices related to products or services you requested from us or which Happiify Inc. provides, or to provide you with Marketing Offers.

We collect your credit card information if you: subscribe to a newspaper; register on a paid Site; register to attend a paid event; purchase any product from Happiify Inc. or through one of our Sites; are a classified advertiser or an auction participant. This credit card information is used for the purpose of fulfilling your order or processing refunds or applying credit, if applicable.

If you choose to opt-out of any use of your personal information in accordance with our opt-out policy, we will keep your contact information and details with respect to your opt-out on a list so that your request can be honoured, and we may retain your information to fulfill legal or regulatory obligations or for other purposes permitted by law. If you provide a complaint to any of our departments, we will collect your contact information and the nature of your complaint, for the purpose of investigating your concerns and responding to you.

If you provide freelance or other services to us, we may collect your social insurance number for tax reporting purposes and your contact information in order to pay you.

We may use your personal information for the purposes of : managing, administering, collecting or otherwise enforcing your accounts; maintaining business records for reasonable periods of time and generally managing and administering our business; and meeting all relevant Canadian and international regulatory, legal, insurance, audit, security and processing requirements.

Occasionally, we ask our customers to complete market research surveys. If you choose to participate in these surveys and provide your personal information for that purpose, your information will be aggregated as part of the survey results and shared with our advertisers, sponsors and affiliates in a manner that does not identify you. However, your information will also be used by us to gain a better understanding of your interests so that we may develop new products and services, to determine your eligibility for other products and services, and to provide you with Marketing Offers.

Other than as permitted or required by law, if we wish to collect, use or disclose your personal information for purposes that are not contemplated in this Privacy Policy, we will identify those purposes at the time of collection. You will be given a reasonable opportunity to opt-out of any such additional purposes.

Cookies and Online Behavioural Advertising

If you use any of our Sites, we may assign a cookie. A cookie is a small text file that is stored on your internet browser and that can collect and store information. We use cookies to better understand how you use our Sites, to make sure our ads and dynamic content are served correctly, to improve the performance of our websites, and to make your experience better. For example, a cookie may recall a set of preferences you have set for our Site and record items that you have registered for. Storing cookies on your web browser allows us to present you with web pages and other content that are attuned with your preferences. For example, if you are a registered user, you may see a welcome page with your name on it. These activities are invisible to you, and are generally intended to improve your internet surfing convenience. Unless you have set your preferences so that you will be alerted when a cookie is being stored on your computer, you won't know about it.

If you are concerned about cookies, please review and adjust your web browser preferences. However, please be aware that by disabling cookies, you may not be able to use all portions of our Sites, particularly pages requiring registration.

We may place advertising or other links on our Sites that originate from outside advertisers and other third parties. If you view these ads, the advertisers may assign or recognize cookies. Happiify Inc. does not control these cookies, nor is it responsible for any marketing or other use of your information by these advertisers or other third parties.

Our Sites may use Web beacon, gif or other technologies to better tailor and manage advertising on those sites. These technologies may be in use on a number of pages across web sites. When you access these pages, a notice of that visit is generated which may be processed by us or by our suppliers. These Web beacons or gifs usually work in conjunction with cookies. If you don't want your cookie information to be associated with your visits to these pages, you can set your browser to turn off cookies. If you turn off cookies, Web beacons, gifs and other technologies will still detect visits to these pages, but the notices they generate cannot be associated with other cookie information and are disregarded.

Many of our Sites use third-party advertising companies to serve ads when you visit the site. These companies may use information (such as web pages you visit and your response to ads, but not including your name, address, email address or telephone number) about your visits to this and other websites in order to provide advertisements about goods and services that may be of interest to you. Some ads appearing on our Sites are delivered to you by AdTech, which is a web advertising company. These third parties may, from time to time, use information that they collect about your visits to the Sites, such as the number of times you have viewed an ad (but not your name, address, email address or telephone number) to serve additional ads about goods and services that may be of interest to you. If you do not wish to have your information used in this way, please click on the following link:
http://www.adtechus.com/cookie_opt-out/ . The following link has useful information about how to opt out of cookies that are placed by companies who are members of the network NAI (Network Advertising Initiative): NAI Opt-Out: http://www.networkadvertising.org/choices/ For more information on online behavioural advertising or to opt-out from other third-party advertising companies, visit the Digital Advertising Alliance of Canada website at Your Ad Choices.

We may also use IP (Internet protocol) addresses to display or allow our third party advertising providers to display more targeted advertising and content.

Analytics

We use IP (internet protocol) addresses, to gather demographic and statistical information about our users, for systems administration and to diagnose problems with our servers, and to administer our Sites.

We may, from time to time, track and analyze anonymous usage and browsing patterns of visitors to our Sites to provide our advertisers with more targeted advertising opportunities and to help users see advertising that is most likely to interest them. We may use third party analytics service providers in order to gather such anonymous data on user behaviour.

We and our third party service providers may, from time to time, use cookies, web beacons and other technologies to track and analyze certain information about user behavior and interaction with our Sites (such as browser version and name, how you were directed to the relevant website, or to register with us, page views, date and time of registration or installation, push notification subscription status, push notification engagement activity, details with respect to use of mobile applications and their functionality) and with e-mails we send to you (such as open and click activity), and about your device (such as device model and type, and OS version and name). We may use third party analytics service providers in order to gather such data on user behavior, and to provide us with other data collection, reporting, ad response measurement and site analytics. This information is used to improve your experience, to help us develop new products and services, to gain a better understanding of your interests so that we may develop new products and services, to determine your eligibility for other products and services, and to provide you with Marketing Offers. These third party service providers may also collect and use certain aggregated or anonymized information, which is subject to their own privacy policies.

We may combine personal information we have collected about you or received from you with publicly available records or with other third party information sources in order to better understand our customers and enhance our ability to provide you with products, services and Marketing Offers that may be of interest to you.

User Generated Content. All information, data, text, graphics, images, messages, reviews, opinions, suggestions or other materials created by users on any Site, including but not limited to its comment forums and chat boards, is public information and may be used and disclosed by Happiify Inc. in accordance with Happiify Inc.'s Terms of Services https://happiify.me/terms.html

To whom does Happiify Inc. disclose personal information, and why?

Happiify Inc. may disclose your personal information under the following circumstances:

To provide you with Marketing Offers, Happiify Inc. may disclose your personal contact information to affiliates and selected sponsors and advertisers. If you do not wish to receive Marketing Offers, you may opt-out at any time by following the opt-out procedure below.

We may disclose or share non-personally identifiable information with partners or advertisers to help explain our business and the effectiveness of our business or for promotional purposes. For example, we may disclose aggregated demographic information which does not include any personally identifiable information.

Happiify Inc. may transfer your personal information to third party service providers, which may be located outside of Canada (including in the United States), in order to fulfill your order or perform processing and other specialized services (such as credit card or payment processing, prize fulfillment of our contests, collection of overdue accounts, management of customer service requests, product delivery, data analysis for purposes of managing and administering our business, and delivery of Marketing Offers and other communications).

Happiify Inc. may provide your name and credit card information on a confidential basis to a third party (which party may be outside of Canada) for the purpose of updating your credit card information to ensure that your ongoing subscription to Happiify Inc. products and services is not interrupted.

Your personal information may be processed and stored outside of the province in which you reside and/or outside of Canada by us, an affiliate or a third party service provider for the purposes set out in this Privacy Policy and, under the laws of these other jurisdictions, in certain circumstances foreign courts, law enforcement agencies or regulatory agencies may be entitled to access your personal information.

Happiify Inc. may disclose your personal information to our affiliates who provide internal audit, management, billing or administrative services on our behalf.

Happiify Inc. may disclose your contact information on a confidential basis to our service providers for the sole purpose of newspaper delivery verification.

Legal Purposes. Happiify Inc. may disclose your personal information to third parties if you have violated our terms of service or conditions of purchase, if we need to comply with applicable laws and lawful governmental requests, other legal and regulatory authorities, for other legal reasons (which may include lawful access by Canadian, U.S. or other foreign courts, law enforcement or governmental authorities) and as otherwise permitted or required by law.

Sale of Business

Happiify Inc. may disclose your personal information on a confidential basis to parties connected with the contemplated or actual financing, insuring, sale, assignment or other disposal of all or part of our business or assets, including for the purposes of determining whether to proceed or continue with such transaction or business relationship or fulfilling any records or other reporting requirements to such parties.

Implied consent and Marketing Offer opt-out policy. In general, when you provide us with your personal information, Happiify Inc. relies on your implied consent to our collection, use and disclosure of such information for the purposes identified or described in this Privacy Policy or, if applicable, otherwise at the time of collection. Happiify Inc. obtains your express opt-in consent to use or disclose sensitive personal information.

If you do not wish to receive Marketing Offers, you may opt-out at any time from receiving (i) Marketing Offers from Happiify Inc. or (ii) Marketing Offers from third parties by doing any of the following:

1. 1. Follow the instructions at the bottom of any email Marketing Offer you receive.
2. 2. Inform your telemarketer at the time you are called with a Marketing Offer.
3. 4. Email Happiify Inc. at [email protected] and request that your personal information not be used for Marketing Offers.

It may take 2-4 weeks to fully process your opt-out request.

We reserve the right to use and disclose your personal information without your consent where required or permitted by law, for example, if we have reasonable grounds to believe the information could be useful when investigating a contravention of a federal, provincial or foreign law, in order to protect or defend our legal interests, or to comply with applicable laws and lawful governmental requests.

Safeguards. Happiify Inc. has technical, contractual, administrative and physical security measures to protect your personal information in a manner that is reasonable and appropriate to the nature of the personal information you provide to Happiify Inc.. For example, when you provide credit card information to us, we work to help protect the security of your credit card information by using industry standard secure sockets layer (SSL) encryption technology.

Please be aware that email is not a secure medium, and any personal information you send to us by email could be intercepted. If your communication is very sensitive, you should not send it electronically unless the email is encrypted or your browser indicates that the access to our Site is secure. Credit card numbers should not be sent by email. Materials posted to online forums such as bulletin boards or comment sites are public, not secure and may be viewed by anyone. Any personal information you post may be collected and used by anyone and may result in unsolicited messages from other internet users. Happiify Inc. is not responsible for personal information you choose to post or submit in any online forum on any of its Sites.

How to access and correct your personal information. Some of our Sites provide you with the means to access, update, edit or delete certain subscriber or registration information by going to the appropriate page on the Site and changing or deleting such information as desired. Alternatively, or for other information, you may contact us and we will make the changes upon receipt of appropriate evidence.

We will give you access to the information we retain about you within a reasonable time, upon written request, satisfactory identification and proof of entitlement. In some cases, we may not provide access to personal information in our possession or control. If we deny your request, we will advise you in writing of the reason for the refusal and you may challenge our decision.

How to address concerns regarding your privacy? Happiify Inc. encourages you to contact us with any questions or concerns you have about your privacy or this Privacy Policy. If you have a question concerning Happiify Inc.'s Privacy Policy, would like a copy, or if you have any questions or concerns regarding the manner in which we or our Canadian, U.S. or other service providers treat your personal information, please contact us.

Happiify Inc. Privacy Officer can successfully deal with many issues. If you prefer, or if after contacting the Privacy Officer your concerns or questions have not been resolved to your satisfaction, you can contact us

This Privacy Policy was last updated on Oct 6, 2018