PRIVACY POLICY

As used in the Privacy Policy, “Happy Numbers” refers to all websites (including www.happynumbers.com, blog.happynumbers.com and plus.happynumbers.com), applications, their features, content we offer owned or operated by Azbooka SA, aka Happy Numbers, a company organized under the laws of Switzerland, having its registered address at Parc Scientifique EPFL, PSE-C, at Fondation du Parc Scientifique sur le site de l'EPFL à Ecublens-PSE, 1015 Lausanne, Switzerland.

For users located in the United States of America (“USA”), our services will be provided and the information will be collected by Happy Numbers Inc. in the name and on behalf of Azbooka SA, our subsidiary and a company organized under the laws of the USA, having its principal place of business at 2600 El Camino Real, Suite 601 Palo Alto, CA, USA, 94306.

Please read the following to learn about our Privacy Policy and the ways in which we use your information before you proceed with use of Happy Numbers.

Date of issue of this Privacy Policy: 05.04.2017

1. The Collection of Information and How We Use It

The main reason why we collect information is to provide and improve Happy Numbers, to administer your membership and to enable users to enjoy Happy Numbers and easily navigate it.

2. What Types of Information Does Happy Numbers Collect?

We collect information when you register on our web-sites, subscribe to our newsletter, respond to a survey, fill out a form or Use our software and services.

The information collected may include but is not limited to the following: email address, last name, first name, address, zip code, country of residence, billing information, nationality, birthday, gender, chosen screen name, chosen password, language, answer to security question (together, the “Personal Information”).

If you fail to provide us with the correct email address, we will not be able to deliver our services and support to you.

3. Automatic Information

We automatically collect some information about your device when you use Happy Numbers, regardless of whether you have registered for an account or not by just browsing our servers. For example, Happy Numbers will collect your IP address, Web browser software, and referring Website. We also may collect information about your online activity at Happy Numbers. Collecting this information helps us customize your user experience and to increase functionality and user-friendliness of the Service.

4. How Do We Use Your Information?

We use other information about you for the following general purposes:
- to register your account;
- to fulfill your requests;
- to manage your account;
- understand how you are engaging with Happy Numbers and to personalize your experience;
- to improve customer service;
- to communicate with you in general;
- to respond to your questions and comments;
- to send periodic emails with a summary of activity in your account; if at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email;
- to prevent potentially prohibited or illegal activities;
- to enforce our Terms of Service;
- and as otherwise described to you at the point of collection;
- aggregated data to enhance our products through case studies;
- anonymized data to publicly highlight our offerings through, but not limited to, blog posts or interviews.

5. Use of Cookies and Web Beacons

Like many other websites, Happy Numbers use “Cookies” to collect information. Cookies are small data files, which are transferred to a computer’s hard disk in order to memorize information like registration IDs and passwords. A cookie will typically contain the name of the domain from which the cookie has originated, the "lifetime" of the cookie, and a value, usually a randomly generated unique number.

Happy Numbers further utilizes session ID cookies to enable certain features of Happy Numbers, to better understand how you interact with our web-sites and to monitor aggregate usage by Happy Numbers users and web traffic routing on our web-sites. Session ID cookies are, unlike persistent cookies, deleted from your computer when you log off from the Website and close your browser.

Please note that you can always choose not to receive a cookie file by enabling your Web browser to refuse cookies or to prompt you before accounting a cookie. To do so, you will have to access the “help” menu in your browser’s menu bar and search for the term “cookies”. Please however take note that, if you refuse cookies, you may not be able to use all portions of Happy Numbers or all functionality of the Service.

Happy Numbers may also collect certain information using Web Beacons. Web Beacons are electronic images that may be used on Happy Numbers, or in our email communications. They are used, for example, to count website visits or to tell if an email has been opened and acted upon.

If you disable cookies on your device, we will not be able to deliver our services and support to you.

6. How Do We Protect Your Information?

We want you to feel confident about using Happy Numbers. For that reason, we have implemented reasonable technical and organizational measures designed to secure your information from accidental loss and from unauthorized access, use, alteration or disclosure:

- All data is transferred only via HTTPS
- Production environment is located in a private network and fully isolated from other company systems.
- We utilize Google Cloud Platform which meets rigorous privacy and compliance standards that test for data safety, privacy, and security: https://cloud.google.com/security/compliance

However, the Internet is an open system and we cannot guarantee that unauthorized third parties will never be able to defeat those measures or use your information for improper purposes.

Keep the information confidential.

If you communicate with us by email, you should note that the secrecy of Internet e-mail is uncertain. By sending sensitive or confidential email messages or information which are not encrypted you accept the risk of such uncertainty and possible lack of confidentiality over the Internet.

Also, Happy Numbers does not encourage minors to make personal information publicly available.

In the event we become aware of an unauthorized disclosure or data breach:

- teachers will be notified by email if the teacher account or any related student accounts are affected.
- the appropriate person in the school or school district who has purchased the valid school-wide or district-wide Happy Numbers access will be notified by phone if the users from this school or school district are affected.

7. Disclosure of Information to Third Parties

We do not sell, trade, or otherwise transfer to outside parties your Personal Information, except for users located in the USA to our subsidiary: Happy Numbers Inc. This does not include trusted third parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential.

We may also send information about you to other companies or people when:
a) we have your consent to share the information; or
b) we need to share your information to provide the product or Service you have requested; or
c) we respond to subpoenas, court orders or legal process; or
d) we believe it is necessary, as determined in our sole discretion, to investigate, prevent, or take action regarding illegal activities, suspected fraud, emergency situations involving potential threats to the physical safety of any person, violations of Happy Numbers’ Terms of Service, or as otherwise required by law.

The following trusted third parties assist us in operating Happy Numbers sites and thus have access to students’ personal information:

- Google Cloud Platform (site: https://cloud.google.com/, security and compliance: https://cloud.google.com/security/compliance)

Non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

8. Business Transfer

We may sell, transfer or otherwise share some or all of our assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy. Your consent to this Privacy Policy followed by your submission of Personal Information represents your explicit agreement to that transfer.

9. Phishing

Identity theft and the practice currently known as “phishing” are of great concern to Happy Numbers. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your account ID, login password, or national identification numbers in a non-secure or unsolicited email or telephone communication.

10. Your Right to Access Information

You are entitled to see the information held about you. If you wish to do this, please contact us using information at the end of this page. We may require you to provide verification of your identity and to pay an administration fee to provide a copy of the information we hold. Please note that, in certain circumstances, we may withhold access to your information where we have the right to do so under current data protection legislation.

11. Updating Your Information

You may review, correct, update or change your Personal Information at any time by accessing your account on Happy Numbers.com. If you would like us to delete your record in our system, please contact us using information at the end of this page and we will accommodate your request, if we do not have any legal obligation to retain the record.

After the product is no longer in use by the school, we will:

- delete all students’ personally identifiable information we and our trusted third parties hold within 1 year after June 30th of the current calendar year.
- upon request, as explained in our terms of services, we will delete students’ personally identifiable information within 5 days from our website and within 60 days from our trusted third parties.

Upon request by the school, we can transfer any students’ personally identifiable information we held to the school or its designated third party. School can request such a transfer not more than once a year.

12. Links to Other Sites

If any part of Happy Numbers links to other Websites, those Websites do not operate under this Privacy Policy. If you choose to click on another third party link, you will be directed to that third party’s web site. We do not exercise control over third party websites and therefore recommend you to examine the privacy statements posted on these other Web sites to understand their procedures for collecting, using and disclosing Personal Information.

13. Our Policy towards Minors

As stated in our Terms of Service, minors are only allowed to use our Website with their legal representative’s consent. Happy Numbers strictly adheres to the Family Education Rights Protection Act of 1974 (FERPA). FERPA protects the privacy of students' data by specifying how and with whom schools can share information from these records. Happy Numbers has been granted the iKeepSafe California Student Privacy Badge, which validates our compliance with FERPA.

We agree that students’ personally identifiable information stays under the direct control of the school. We will not use personally identifiable information in student records to engage in targeted advertising. Nor will we use any information in the student record for any purpose other than those required or specifically permitted by our Privacy Policy and our Terms of Services.

If a legal representative becomes aware that his / her represented minor has provided us with Personal Information without their consent, he or she should contact us using information at the end of this page. We will delete such information from our files within 5 working days.

14. Changes to this Privacy Policy

This policy may be amended from time to time. If we amend the Privacy Policy in any way we will:

- place an updated version on this page, and/or update the Privacy Policy issue date;
- place an announcement on happynumbers.com for 2 weeks from the Privacy Policy issue date.

In case the changes to the Privacy Policy include new or additional data collection, or changes that would lessen the previously noted protections around student data privacy, we will notify in advance the appropriate person in the school or school district who has purchased the valid school-wide or district-wide Happy Numbers access.

15. Jurisdiction and Applicable Law

This policy and all matters arising out of or related to this policy shall be governed by the substantive laws and principles of Switzerland, without regards to conflicts of laws and principles thereof.

Any controversy, claim or dispute between you and Happy Numbers arising out of or relating to this policy shall be subject to the exclusive jurisdiction of the Courts of the Canton of Vaud, Switzerland.

16. Your Consent

By using Happy Numbers, you expressly consent to our Privacy policy.

17. Questions or Suggestions

If you have any questions or suggestions about this Privacy Policy or your Personal Information, please contact us using information below:

Azbooka SA
Parc Scientifique EPFL, PSE-C
1015 Lausanne
Switzerland
support@happynumbers.com
Phone: +1-800-815-1574
Fax: +1-650-618-8611


For questions or complaints about COPPA compliance, please contact iKeepSafe Safe Harbor at COPPAPrivacy@ikeepsafe.org.