Privacy policy

Privacy policy

Updated: 01/08/2024

 

The purpose of this Privacy Policy is to inform you about how HAPPN uses your personal data. We recommend you should read it carefully. However, please find an overview of the data collected and the reasons for its collection at the following link: https://www.happn.com/en/privacy-basics/ 

 

1. Definitions

 

Application: The HAPPN application, available on the Apple App Store and the Google Play Store and on the HAPPN Webapp: https://www.happn.com 

Account: The Member’s dedicated personal area within the Application, which he or she accesses when he or she registers and connects to the Application. It enables the Member to access the Services. A Member may only have one Account.

Boost: a function enabling Members to increase the visibility of their profile during the time that this option is activated.

Crossing point: your Geographical position, as recorded when you crossed paths with another Member, if the geolocation feature is enabled.

Crush: An event that is created between two profiles, triggered by a Like on both profiles. It represents mutual interest and sends out a “You have a Crush” notification, allowing Members to start a conversation.

Facebook Connect: A feature enabling Members to use their Facebook account to log in to the Application, in order to simplify the registration process.

FlashNote (function only available in certain countries): a function that sends a notification to the Member to whom you address it, and which also enables you to send him or her a private, personalized message to start a private conversation.

Geographical position: your location, recorded by HAPPN and updated regularly when this option is enabled.

HAPPN: HAPPN, a French joint stock company (Société par Actions Simplifiée) registered with the Paris RCS (trade and companies registry) under no. 535 217 723, and owner and sole operator of the HAPPN application and trademark.

Hello (Chat request): Non-confidential function suggested before and/or after the Like which triggers a notification to the Member to whom you’re sending it and constitutes an invitation to chat with this person.

Like: An action represented by a heart, expressing interest. Premium Members have access to the list of Likes. Except for the first Like, this function remains hidden from non-Premium Members until they receive a reciprocal Like.

Map (Mapping): A map that allows you to find Members with whom you’ve crossed paths.

Member: A person registered with the Application. 

Member characteristics: Information provided by the Member describing his or her lifestyle and personal characteristics on the profile. The Member can choose the information he or she wishes to appear on the profile and filter other Members on the Application based on this information.

Messages and/or voice messages: Only Members who have a Crush (or a FlashNote, if eligible) can use the Application’s “Chat” function to send each other Messages. Messages are stored in the inbox, which is accessible via the icon on the top right of the homepage.

Premium Member: A Member who has a HAPPN Premium subscription.

Profile Certification: a function that enables the authentication of a Member’s Profile picture(s) to obtain the “Certified Profile” badge, which enables other Members to see that the photo of the Member’s face posted on his or her profile corresponds to his or her real visual identity while moving (via the video).

Profile Photos: photos on your profile enabling the easy identification of the Member. The Member accepts to, at the very least, provide a photo of his or her face in which he or she is clearly recognizable, and place it in first position. These two criteria combined are an essential condition for using the Services.

If the photo of the Member’s face is not placed in first position, it will be automatically placed in first position by default. If the Member has several photos of his or her face, he or she will be able to choose their order of appearance.

Services: All services, whether charged or free-of-charge, offered by HAPPN to encourage virtual or real-life meet-ups between Members who have crossed paths and who have a mutual interest in one another, according to the selected search criteria.
Shortlist: A free feature enabling Members to access a selection of three profiles recommended by HAPPN every day. The Shortlist feature is available from Members’ third day of activity on their profiles.

Video Call: feature offered only to Members who have a Crush, enabling them to call and talk to each of their Crushes spontaneously, for a limited duration. This feature can be accessed from the “Messages” page, by clicking the icon in the top right corner to start the Video Call. During the Video Call, Members have access to the following options:

• Pick up
• Mute
• Disable video
• Switch to frontcam
• Hang up

 

2. Data controller

 

The data collected is processed by SAS HAPPN, a company registered under number 535 217 723 in the Paris Trade and Companies Register. The company’s headquarters are located at 5 rue Feydeau 75002 Paris, France, and it is represented by its CEO, Ms Karima Ben Abdelmalek. 

 

HAPPN is extremely concerned about the protection of your personal data and respect for your privacy. The purpose of this privacy policy (along with our document on the use of cookies and our terms of service and any other document it refers to) is to inform you on the way we process the personal data you share with us and that we collect when you use the Application and Services. Please read this document carefully to better understand how we process your personal data, and to know your rights. 

 

This Privacy Policy applies to all Services published by HAPPN that you use (with the exception of services supplied and operated by third parties, in which case, their privacy policy will apply). 

 

3. Information we collect

 

HAPPN collects and processes personal data on you when you use the HAPPN application or when you communicate with HAPPN. It may be information you share with us directly, or data we collect automatically. 

 

To make sure our privacy policy is clear, we are providing below an overview of the personal data HAPPN collects and processes. Information is given below for each type of data collected. 

 

• Mandatory data

• Identification data

• Depending on how you signed up, email address and/or telephone number

• Data relating to your activity on the application

• Technical data of the cell phone or device

• Your city (if you refuse the geolocation feature)

 

• Data required for certain purposes

• Data relating to taking part in games and competitions, to your experience and your satisfaction

• Geographical position or at least your city

• Crossing points with other Members

• Search preferences - people whom you would like to cross paths with (age and gender)

• In-app messages and in-app voice messages sent and received

• Data on Video Calls (the contents of such Calls are not collected)

• Data relating to reports made and requests sent to the HAPPN customer service 
• Data relating to purchases and payments
• Biometric data for profile verification (with your consent) 

 

• Optional data

• Professional career and education

• Interests, lifestyle, Member Characteristics

• Depending on how you signed up, email address and/or telephone number

• Description

 

3.1 Data you share directly 

 

When you use our Services, you share information with us, some of which may be used to identify you. When you communicate this information, you accept that some of the data will be visible to the other Members of the Application, and therefore made public on the Application. In an effort to help you identify this information easily, it is signaled as ‘public’ below. HAPPN cannot be held liable for data published on its platform and disclosed by a Member. However, information not marked as Public will not be visible or accessible by other Members; such information is signaled as ‘private’ below. 

 

HAPPN collects and processes data relating to your registration and data relating to your interactions with HAPPN. 

 

3.1.1. Registration data 

 

Information required for registering

 

This is the basic data required for you to register and access our Services. 

This data is collected by HAPPN using different methods depending on the type of registration you choose. 

 

If you choose to register using your Facebook, Apple or Google account, your data will be collected from the relevant platform in an effort to reduce formalism. By selecting “Log in with Facebook/Apple/Google,” you agree to having these platforms provide us with such data.

 

In addition, you can register using a cell phone number and, if this is the case, your data will be sent to HAPPN directly by you. 

This data relates to your identity. 

 

Depending on how you registered, some data must be collected in order to provide our Services. If such data is not obtained, HAPPN will not be able to provide you with its Services via the Application, and you will not be able to create an Account. In all cases, your first name (public), age (public), birthdate (private), gender, and at least one Profile Photo (public) are required to register with the Application. Subsequently, you may add or remove Profile Photos at any time, providing you have added at least one Profile Photo containing a person’s face. As stated in paragraph 1, “Definitions,” the first Profile Photo should be a photo of a person’s face, otherwise one of your photos of your face will automatically be put in first position.

 

If you register using your phone number, you must provide said phone number in order to register.

When you register via Facebook, we must collect your first name and your age. You may also allow Facebook to provide HAPPN with your last name, birthdate, gender, email address, and to transfer your Profile Photos from Facebook.

When you register via Apple or Google, we must collect your first name and email address. Said platforms may also provide HAPPN with your last name.

 

In addition, if you refuse the geolocation feature when registering, and thereby the possibility for HAPPN to collect your location data to suggest Member profiles with whom you have crossed paths, you must provide the name of your city. This information will enable HAPPN to suggest Member profiles near you.

 

Optional information to complete your profile 

 

You may add additional information to improve your profile. This information is optional, shared at your own discretion, and is your sole responsibility. You can add this information directly to your profile on the Application and/or via Facebook Connect by syncing your Account with Facebook. This data is as follows: 

 

• professional career and education (public): profession or studies;

 

• interests and habits (public): personal preferences, leisure activities, musical preferences, lifestyle, Member Characteristics;

 

• height (public);

 

• profile description (public): if you would like to, you can share additional information about you in the space provided for this purpose. This information will be visible to HAPPN Members. Moreover, if you so wish, you can also answer the questions on your lifestyle (personality traits, sports, travel, type of meeting expected, etc.).

 

 

Your description is a free text area, HAPPN does not encourage Members to share data that can be perceived as sensitive with other Members, or with HAPPN through the Application. Sensitive data refers to data that is legally qualified as “sensitive” by the General Data Protection Regulation (“GDPR”). More specifically, it includes information on race or ethnicity, political opinions, religious or philosophical beliefs or affiliation with a union, along with information on health, sexual life or sexual preferences (“Sensitive Data”). If a Member decides to share such information on his/her profile regardless, it is deemed to have been “clearly made public” by the Member who shared it, according to the GDPR. 

 

3.1.2. Data relating to interactions with HAPPN: 

 

When you contact our customer or support services, report an issue with our services, ask for help, exercise your personal data rights, or participate in promotional activities, games, competitions or surveys, when you share your experience of our services, give testimonies, or answer one of our questionnaires, HAPPN will collect, depending on the case, the following personal data: 

 

• Data relating to reports and requests sent to the HAPPN customer service (private): Date and time of the report, nature and reason for the report, data relating to the reported user. Furthermore, proof of identity may be requested as part of the exercise of your rights over your personal data, and for safety/confidentiality reasons.

 

This data will be collected by HAPPN when you ask for help from our customer service, exercise your rights over your personal data, report a problem or another user. Such information is required to handle reports or answer your requests. This information will also be handled if a report is made about you. In fact, HAPPN has a legal obligation to collect reports from its Members brought to its knowledge regarding contents or behavior likely to infringe our Terms of Service.

 

• Data relating to taking part in games and competitions, to your experience and satisfaction (private): participation, responses, satisfaction level, suggestions, experience.

 

Such data is collected by HAPPN when you take part in our games and competitions, answer our surveys and satisfaction questionnaires, share your experiences. This data is mandatory if you wish to take part in the games and competitions organized by HAPPN. Without this data, HAPPN may not register you for games or competitions. However, data on your experiences and satisfaction is optional.

 

3.2 Data we collect automatically

 

When you use our services and features, we collect information on your activities on the Application: 

 

• Activity data (private) (registration date, login dates, on or offline status, interactions with Members and third-party accounts, number of transactions, notifications received, notification preferences, etc.) 

 

When you access our Services and use the Application and its features, information on the way you use them is collected and processed. Most of the information collected by HAPPN is necessary to the provision of its Services. Without this data HAPPN cannot supply the Services linked to the HAPPN application. 

More specifically, this includes your registration date, login dates, on or offline status, the type and number of interactions with other Members (such as FlashNotes, Hellos, Likes, crossings, and Crushes), with the third-party accounts connected to your Account (such as Spotify, Instagram), or the number of transactions made (purchases of Hellos, FlashNotes, or subscriptions), notifications received and notification preferences. 

 

• Geographical positions and Crossing points with other Members (public)

 

The Application’s main value and purpose is to allow Members to find other Members they have or may have crossed paths. Your Geographical position is collected with your express consent only. In fact, you will be asked to authorize the collection and processing of your location data to allow HAPPN to identify your crossing points with other Members who have agreed to be geolocated.

Unless you have chosen stricter settings on your device, HAPPN will collect your Geographical position regularly.

When the Geographical positions of two Members are within a certain radius, HAPPN pinpoints a Crossing point.

Your Crossing points will be displayed on your profile, but Members with whom you cross paths can never see your exact location. Each Member sees his/her location when the Crossing point was registered in a radius defined by HAPPN. They cannot see the other Member’s location.

During your registration, if you do not provide your consent for geolocation, you must provide the name of your city. This information will enable HAPPN to suggest profiles of Members near you.

 

These Crossing points can be displayed as a news feed or on a Map (Mapping).

You may, at any time, withdraw your consent by disabling geolocation on your smartphone. If you choose to do so, your news feed will no longer be updated, and you will not be able to see who you have crossed paths with after disabling the geolocation option. When you have no more profiles in your newsfeed, we will ask you the name of your city in order to suggest new Member profiles near you.

 

You can also ask that your profile, and therefore your crossing points, are no longer displayed on the Map (Mapping). In this case, you will only appear in the news feed of other Members. Equally, you will no longer be able to see the profiles of Members you have crossed paths with on the Map (Mapping); you will only see these profiles on your news feed. For this, go to the application and click on “My preferences” then go to the bottom of your screen and disable the option “Share my crossing cluster”.

 

• Text messages and voice messages sent and received (private)

 

Messages are sent and stored on HAPPN’s servers, to provide the Service to allow Members with a Crush to have a conversation or when a Member uses the FlashNote function. Messages and voice messages are strictly private and only implicate the Members involved. HAPPN’s authorized managers do not exercise any rights to view these conversations. These Messages are not transmitted or communicated to third parties except in cases of judicial requests, and/or in compliance with the applicable legislative or regulatory provisions. Moreover, Messages are strictly private and are not accessible to other Members who are not involved in the conversation, nor to any third party. 

 

• Information relating to Video Calls (start and end time/date of calls, etc.) (private)

 

If you wish to make a Video Call using HAPPN, your telephone’s technical data is required in order to establish communication between the two Members. HAPPN will collect the start and end time/date of Video Calls, but not their content. Such Video Calls are instant.

 

• Search preferences - people whom you would like to cross paths with (age and gender) (private)

 

The Application lets you set preferences by age, gender, and the Member Characteristics they have provided. You can change these settings in the Application and specify the age range and Member Characteristics, and, after agreeing to HAPPN collecting and processing your data, the gender of people you are looking for, so you can be matched exclusively with profiles you crossed paths with and who meet your search criteria. You will then only see the Members you have crossed paths with and who share your search preferences on your news feed. 

 

• Technical data of the cell phone or device (IP, mobile ID, application version, telephone version and model advertisement ID, etc.) (private)

 

We collect information from the devices and equipment you use to access our Services, including server logs, which may contain information such as IP addresses, version of the application, device version and model, language used, operating system, application crashes, and advertisement ID. Data may be collected with cookies or other tracking tools: to learn more about this, please refer to our document on the Use of Cookies. 

 

Transaction Data: HAPPN does not collect or process any banking data. Apple’s App Store and Google’s Play Store have opted to refrain from sending certain types data to mobile applications, which includes any banking and financial information. This data is collected and processed solely by the above platforms, and HAPPN does not have the option of changing this payment method. The only information exchanged between HAPPN and Apple’s App Store or Google’s Play Store is technical data that does not allow us to identify you (for example, a transaction number), and is used to validate transactions. HAPPN will therefore retain a history of your purchases and subscriptions but will not store any information relating to the payment methods you use.

 

4. How do we use your data?

 

4.1. Supply of services and features according to our terms of service

 

• Creation and management of your Account as a Member:

• Creation of your profile.

• Registration, deregistration, deactivation of your Member profile.

• Management of parameters and preferences.

• Management of subscriptions.

• Management of access to the Services proposed by HAPPN.

 

• Managing and storing messages exchanged between Members (Messages, FlashNotes, Hellos, Crushes, Likes).

 

• Managing Video Calls between Members

 

• Managing subscriptions and paid Services purchased (Hellos, FlashNotes, call credit, etc.)

 

• Sending information messages relating to the Services or your interactions with other Members (notifications).

 

Legal basis: Execution of the contract

The data collected by HAPPN is required to make sure the Application is running smoothly and to supply the Services, which it is contractually obliged to provide to Members under the service contract biding the two parties (Terms of Service).

 

4.2. Suggesting profiles you have crossed paths or may cross paths with

 

• Geolocation to suggest profiles of Members you have crossed paths or may cross paths with. 

 

Legal basis: Consent 

When you have given your consent, you are free to withdraw it any time by disabling the geolocation option on your smartphone. Withdrawal of consent does not affect any processing carried out before the withdrawal.

 

Additional information 

The aim of the Application is to help you find other Members whose paths you have crossed or may cross. In fact, it allows you to identify your crossing points with other Members who have agreed to be geolocated. These crossing points allow HAPPN to show you profiles of Members you have crossed paths or may cross paths with and who meet your search criteria. 

 

• Based on your activity in the Application, your position and the information on your profile, your profile may be suggested to other Members. We can also recommend, via your Shortlist, other Members who may interest you, with whom you have crossed paths, or with whom you could cross paths, and, inversely, recommend your Profile to other Members. Your profile is also suggested when you use the Boost feature as defined in paragraph 1.

 

Legal basis: Execution of the contract

Processing this data enables us to provide our Services, and thus, to increase your likelihood of meeting Members with whom you are a good match.
 

• Recommend your Profile via email to other Members with whom you have crossed paths or with whom you could cross paths.
   

Legal basis: Legitimate interest

This processing is based on the legitimate interest of HAPPN to offer Members relevant Profiles as part of its Services. You can contest this data use at any time by contacting us (see section 11. Contact).

- Suggest Members based on your favourite locations

 

 

- Suggest meeting places based on your preferences

 

Legal basis: Legitimate interest

This processing is based on the legitimate interest of HAPPN to offer Members relevant Profiles and meeting places.
 

4.3. Suggesting relevant offers and contents (marketing and advertisements)

 

• Sending marketing or advertisement messages or contents:

 

•   Send the HAPPN editorial newsletter by email. We will stop sending the newsletter to Members who have not opened it in over a year.
•   Send a newsletter suggesting Profile recommendation that can be viewed on the Application (your Shortlist).
•   Distribute marketing contents and advertisements related to HAPPN offers and services on the application and by emails.
•   To offer Members personalised or non-personalised offers and/or promotions on HAPPN services.

Legal basis: Legitimate interest

This processing is based on the legitimate interest of HAPPN to share its offers. As relates to the newsletter, you can object to receiving emails from HAPPN at any time by clicking on the “Click here to unsubscribe” link provided for this purpose in the emails you receive.

 

• Conducting marketing operations and advertising outside of the application: we conduct marketing operations and advertising outside of the HAPPN application outside of third-party sites, social networks and third-party applications. If you are already a Member of the Application, we may share you email address and telephone number with such entities to exclude you from our Marketing campaigns. This information is provided for “hashing” purposes. This can also help HAPPN disseminate its campaigns to profiles similar to yours, who may be interested in our Services. The existence of your profile will never be disclosed to these similar profiles. The social networks which may receive your data for this purpose appear in the list of our service providers, available here. 

 

Legal basis: Consent

If you have given your consent, your data will be shared with these social networks in order to exclude you from HAPPN's promotional content on these social networks and to publicise the Services on third-party sites to non-Members. You may withdraw your consent at any time by contacting us (see section 11. Contact) or directly in the application by going to "My data" and then "Manage my Choices". By withdrawing your consent, we will no longer be able to exclude you from our advertising on these networks.

 

• Display personalized advertisements on the HAPPN Application with regard to third-party products and services to ensure they are relevant to the Member. These advertisements are personalized based only on your age group, gender and the country and/or city where you live. Your personal preferences will not be analyzed in disseminating such advertising. Personalized advertising also includes the restricting of identical advertisements. As a result, when a Member consents to it, repeated or irrelevant advertisements are limited and the Member will see more diverse content.

Legal basis: Consent

The advertisements displayed on the HAPPN Application are personalized if you have given your consent. At any time, you may withdraw your consent to personalized advertising based on your age group and your gender by clicking “My Data” then “Manage my Choices.” Premium Members do not have advertisements on the HAPPN Application.

 

 

• Disseminating on the HAPPN application non-personalized advertisements (based solely on your country), on the products and services of partners and advertisements relating to the products and services of HAPPN. 

 

Legal basis: Legitimate interest

This processing activity is based on HAPPN’s legitimate interest in displaying non-personalized advertising in the Application to non-Premium Members

 

4.4. Improving and optimizing our services and our knowledge of how you use them

 

• Improvement and optimization of the services of HAPPN, of the knowledge of its Members and the manner of using the Services:

• Statistical studies.

• Satisfaction survey.

• Analyses of the use of the Application and Services by Members.

• Understanding how our Application and its features are used

• Improving our Application, offers and features

• Understanding your needs

 

Legal basis: legitimate interest

This processing activity is based on HAPPN’s legitimate interest in improving and optimizing its services, knowing its users and how its services are used.

 

• Provide Members with advice on which Profile Photos to publish by analyzing all Members’ profiles, so Members can, if they wish to do so, optimize the way their profile is presented.

 

Legal basis: legitimate interest

This processing activity is based on HAPPN’s legitimate interest in improving the way profiles are presented in the Application. You may oppose this use at any time by contacting us (see Section 11, Contact).

 

4.5. Guaranteeing the security of your personal data

 

• Detecting or preventing breaches of the security of the Services by identifying and analyzing fraudulent behavior.

 

Legal basis: Legitimate interest 

This processing is based on HAPPN’s legitimate interest in guaranteeing the security of its application and the data it processes. You can object to this use at any time by contacting us (see section 11. Contact). However, HAPPN may continue to implement the processing if it justifies legitimate and compelling reasons.

 

4.6. Preventing and combating illegal or unauthorized activities (breaches of the terms of service), ensuring the trust of Members and complying with legal requirements

 

• Analysing and processing reports of fraudulent/undesirable behavior.

 

• Managing undesirable behavior and warning, suspending, blocking or deleting the Member’s Account.

 

• Managing requests to exercise Members’ rights over their data.

 

Legal basis: Legal obligation

These processes are based on HAPPN’s legal obligation, as a data host, to remove illegal content as soon as it becomes aware of it (Article 6 of the French Trust in the Digital Economy Act [Loi pour la Confiance dans l’Économie Numérique) of 21 June 2004]) and on its obligation to respond to requests to exercise Members’ rights over their personal data (Articles 12 to 22 of GDPR). 

 

• Detecting or preventing fraudulent activities or activities which breach our Terms of Service:

 

•   Automated analysis of profile data, application activity to detect fake profiles, fraudulent behavior or behavior that breaches the Terms of Service.

 

• Guarantee the quality of profiles:

 

•   Automated analysis of Members’ Profile Photos in order to detect faces, and, as much as possible, exclude fake profiles from the Application, combat fraudulent behavior and guarantee Member identification. You will not be able to create an account if your face cannot be detected in one of your Profile Photos upon registering. If you are prevented from registering even though your Profile Photo does show your face, you may contact us at any time.

 

Legal basis: Legitimate interest

This processing is based on HAPPN’s legitimate interest in preventing and stopping fraudulent activities that may be carried out on its Services or breach its Terms of Service, and in protecting users’ safety though profile identification. You can object to this use at any time by contacting us (see section 11. Contact). However, HAPPN may continue to implement the processing if it justifies legitimate and compelling reasons.

• To reinforce the security of Members on the Application by automatically excluding the profiles of Members whose previous account had previously been suspended following fraudulent behaviour or behaviour that contravened our General Terms and Conditions of Use.

 

Legal basis: Execution of the contract

This processing allows us to provide you with the Services while preserving your peace of mind and security on the Application in accordance with our General Terms and Conditions of Use and to ensure compliance therewith.

 

 

• Profile certification (as defined in paragraph 1): in order to certify the profile of a member, HAPPN must, having obtained the Member’s consent, collect the his or her biometric data using a video of his or her face, and compare this data with the Member’s Profile Photos. If the faces correspond, a “Certified Profile” badge will be granted. The biometric data are immediately deleted after the comparison. However, the video will be stored in order to reverify the Member’s profile should he or she add or delete other photos. In this case, the biometric data will be collected once again from the same video, then deleted again after comparison with the Member’s new photos.

 

Legal basis: Consent

Your consent for the use of your biometric data for Profile certification is requested when you start the certification process. You can withdraw this consent at any time by clicking on “My Data” then “Manage My Choices.” If you withdraw your consent, your video will be deleted and your biometric data will no longer be able to be collected. If you add new Profile Photos or delete your current Profile Photos, you may lose your “Certified Profile” badge as the comparison with your face will no longer be possible.

 

4.7. Providing Members with help and technical support

 

• Responding to the requests for support submitting by Members using the Application

 

Legal basis: legitimate interest

This processing activity is based on HAPPN’s legitimate interest in ensuring that its Members can use the Application in proper technical and operational conditions.

 

5. Cookies and tracking tools 

 

Cookies may be used on our showcase website for technical, advertising reasons or for measuring audiences. In the Application, cookies and tracking tools may be used for technical reasons and for measuring audiences.

To learn more, read our document on the Use of Cookies on our website. 

 

6. How data is shared

 

Only certain HAPPN employees from customer services and authorized managers process Members’ personal data for the purposes described above. These employees and authorized managers only have access to the data necessary to perform their duties.

 

Authenticated and reliable service providers and partners, who may access and/or process Members’ personal data, in compliance with the Privacy Policy, and ensuring the security and privacy of the Members’ personal data. These service providers help us operate and improve our Services, including

• our sub-contractors in charge of data infrastructure and hosting
• suppliers of the analysis software we use
• technical sub-contractors for using the Application and/or ensuring that the Application functions properly
• our customer service to provide Members with the support they need and manage reports;
• our Marketing partners to provide HAPPN Members and non-Members with relevant messages, offers and content.

 

As part of marketing and advertising operations outside the Application intended for non-Members, your data may be provided to partner social networks in order to exclude you from our campaigns, unless you oppose that.

 

For more detail, please refer to the list of our sub-contractors and partners.

 

In addition, at the request of state bodies, in particular the judicial authorities, and in order to comply with any judicial or legal request, HAPPN may transmit the personal data of its Members. 

 

Lastly, we may be required to share your data for the purposes of corporate operations, which include, but are not limited to, a restructuring, a change in control of the company, a merger, an acquisition, a transfer, or a termination of the company.

 

7. Transfer of Personal Data outside the EU

 

The personal data of Members processed as part of their use of the Application is hosted in the European Union.

 

However, the personal data of Members are transferred to HAPPN subcontractors located outside the European Union, for Member support, report management, advertising and marketing. 

 

Transfers of data outside the European Union may be made to countries in relation to which no adequacy decision has been taken by the European Commission on the protection of personal data. HAPPN guarantees that transfers are made under conditions ensuring the confidentiality and security of the data and providing an adequate level of protection compliant with regulations. These transfers are governed by standard contractual clauses of the EuropeanCommission. To obtain a copy of these, please contact our Data Protection Officers at dpo@happn.fr. 

 

For the exact location of our recipients, please refer to the list of our sub-contractors and partners.

 

8. Exercising your rights over your Data

 

Your rights

In compliance with the French Data Protection Act of January 6th, 1978 (Loi Informatique et Libertés, 78-17), and the GDPR, every Member has a right to access, rectify, and a right to data portability and removal of his/her personal data, along with a right to object to or limit processing of his/her personal data, and the right to decide on the way to handle the personal data after his/her death. In an effort to address its Members’ concerns, HAPPN commits to respecting the protection of personal data and to process requests as soon as possible. 

 

Exercising your rights

Members may exercise their rights, subject to proving their identity, by sending an email to support@happn.com, by exercising their rights directly via the Application, or by sending a letter to the following postal address: for the attention of the Data Protection Officer, HAPPN - 8 rue du Sentier 75002 Paris – France. For confidentiality reasons, if there is a doubt on the requesting party’s identity, proof of identity may be requested.

 

For any other claim, the Member may lodge a request with the national authority responsible for data protection.

 

Description of rights

• The right to access allows a Member to ask HAPPN for data pertaining to him/her in an accessible format, based on the terms and conditions of Article 15 of the GDPR. Your right of access must not infringe on the privacy of third parties, which is why you will only have access to your personal data and not that of third parties (for example, only messages that you have sent will be communicated to you and not those that you have received).
• The right to correct grants a Member the right to demand HAPPN corrects, adds to, updates or removes any personal data on him/her that is inaccurate, incomplete, ambiguous, out-of-date, or whose use, communication or storage is prohibited based on the terms and conditions of Article 16 of the GDPR. You can modify or rectify some data directly on the Application. You just need to go on your profile and make changes directly in the sections “My photos”, “Work and Education (Job, Employer, School)”, and “About me”. When you have registered via Facebook Connect, to change your first name, age, or gender, go to your Facebook page and update the “About me – contact and basic info” section of your profile. When you have registered via a cell phone number, you must send a letter or contact customer support at the addresses listed above, to change your first name, age or gender. In case of error, your age can be rectified once, directly on the Application.
• The right to data portability grants a Member the right to receive the personal data he/she gave to HAPPN, in a structured, commonly used format, legible on a machine, and to forward them to another processing entity, in compliance with Article 20 of the GDPR. 
• The right to contest grants a Member the right to object, free of charge and at his/her own discretion, to the use of his/her data by HAPPN for canvassing, especially commercial canvassing, and to the processing based on HAPPN’s legitimate interest, in compliance with Article 38 of the French Data Protection Act and Article 21 of the GDPR. For processing based on legitimate interest, HAPPN retains the option to justify legitimate and compelling reasons to continue processing. 
• The right to delete grants a Member the right to demand the removal, free of charge and at his/her own discretion, of data transmitted to HAPPN, within the limits of the rights based on Article 17 of the GDPR. Also, you can delete your Account using the corresponding feature on the Application. We inform you that all your data will be deleted from the HAPPN application. However, HAPPN, as the host, has a legal obligation to retain your personal data for one year under Article 6-II) of the French Trust in the Digital Economy Act no. 2004-575 of 21 June 2004. Your data will be kept in an archive database kept separate from our production databases and only for the purpose of responding to a court order. Data will be permanently deleted after one year.
• The right to limitation grants Members the right to request the temporary suspension of the processing of their data by HAPPN under the conditions set out in Article 18 of GDPR.
• The right for the Member to set the guidelines for the retention, deletion and communication of his/her personal data after his/her death, in compliance with Article 85 of the French Data Protection Act.

 

These rights may only be exercised within the limits of HAPPN’s resources as it relates to its use of Facebook, Google and Apple to log into the Application. Some data sent to HAPPN by Facebook, Google or Apple cannot be corrected without Facebook, Google or Apple’s cooperation.

 

9. How long will we keep your data?

 

HAPPN has introduced a process for automatically deleting your account and your personal data with regard to the storage time limits defined below. When certain data must be stored for statistical uses beyond these storage time limits, this data is anonymized irreversibly to ensure you can no longer be identified.

HAPPN will store the Member’s data for as long as required in order for the Member to use his/her Account, namely: 

 

• For the length of the Member’s registration, plus 24 months. After 24 months of inactivity on an Account, the Account will be deleted and the Member’s data will be retained for another year, before being permanently destroyed or irreversibly anonymized. An account is considered inactive when the Application of the Member has not established contact with HAPPN’s servers (including due to deactivation of the geolocation process); and the Member has not used the Application. In any event, the Account of a Premium Member is not considered inactive. Furthermore, please note that in accordance with its status as a hosting provider, HAPPN has a legal obligation to retain some of its Members’ personal data for a period of one year based on Article 6, II of the French Trust in the Digital Economy Act (Loi pour la Confiance dans l’Économie Numérique) of 21 June 2004.
• When a Member is banned, his/her Account becomes inactive. Information from this Account is retained in an active database for 24 months, in order cross check it with information provided with new registrations to the Application, in order to prevent, to the extent possible, banned users from registering again. Subsequently, the personal data is archived for one more year, after which it is deleted permanently or irreversibly anonymized.
• When the Member deletes his/her Account or requests its deletion from Customer Service, it will be deleted from the Application. However, the Member’s data will be kept in a separate archive for one year before being permanently destroyed or irreversibly anonymized, in order to enable HAPPN to comply with its obligation to keep it as host.
• Some of the Member’s data, such as email address and telephone number, will be retained for prospecting or Marketing purposes (see Article 4.3) or to be analyzed in order to improve and optimize our service (see Article 4.4) for one year after an Account has been inactive for 24 months. If a Member deletes his/her Account, this data will not be used for prospecting or marketing purposes.

 

With regard to your Geographical Positions and Crossing Points, shorter storage times apply:

-  Your last Geographical Position is stored for one month from their collection in order to determine your Crossing Points with other Members;

- Your Crossing Points are stored for six months from the time they are collected in order to display the Profiles of Members you have crossed on the Application.

 

 

HAPPN undertakes to make every effort and to invest all means at its disposal to guarantee that the stored data is kept as secure as possible. However, it is the Member’s responsibility to take appropriate measures to protect his/her data.

 

10. Personal data of minors

 

HAPPN shall not collect data from minors. Should a Member lie about his/her date of birth, and particularly if he/she fraudulently claims to be an adult, the parents of the minor in question should inform HAPPN of this fact by sending an e-mail to one of the contacts mentioned in Article 11 “Contact”, requesting the data to be deleted. HAPPN commits to deleting all data on the minor in question as soon as possible.

 

11. Contact 

 

If you have any questions regarding this privacy policy, or any other request concerning your personal data, you can contact us:

• By sending an e-mail to our contact e-mail address support@happn.com.
• By sending an email to the Data Protection Officer dpo@happn.fr. 
• By sending a letter to the following address: for the attention of the Data Protection Officer, HAPPN - 5 rue du Feydeau 75002 Paris – France.