HAPPLAY SOFTWARE PTE.LTD., Ltd. (“Happlay”) is a data-driven Connected TV (CTV) advertising and operation company. We know how important privacy is to our users, and we strive to be clear about how we collect, use, disclose, transfer, and store (collectively, “process”) your personal information.

This Privacy Policy (“Privacy Policy”) explains our personal information processing practices, and applies to all Happlay products, software, services and websites (collectively, the “Services”) and our corporate website at www.happlay.tech (“Site”). This Privacy Policy applies regardless of whether you use a computer, mobile phone, tablet, TV, set-top box or other smart device (“Device”) to access our Services or our Site.

It is important that you read the Privacy Policy carefully because it provides information on how your personal information is processed anytime you use our Services.

It is also important that you check back often for updates to the Privacy Policy. If we update the Privacy Policy we will let you know in advance of any material changes, by placing a notice on the relevant Services or by e-mailing you, when appropriate. The most current version of the Privacy Policy will always be available here https://www.happlay.tech/privacy-policy. You can check the “Last Updated Date” posted at the top to see when the Privacy Policy was last updated.

 

Controller of Personal Information

HAPPLAY SOFTWARE PTE.LTD., Ltd., with its principal business address at 60 PAYA LEBAR ROAD #04-15 PAYA LEBAR SQUARE SINGAPORE (409051), is the data controller of personal information processed through Happlay’s Services and Site. Details can be found at www.happlay.tech.

 

Description of Processing Activities and Legal Grounds for Collection

We collect your personal information for the purposes listed and explained here below for the purposes listed and explained here below.

1.       Contact Information We Collect To Provide Services

We collect and store any information you directly give to us in relation to our Services. The information you may provide is listed as follow:

Ÿ   If you want to subscribe our newsletters to get our latest news, we will collect your e-mail address and name.

Ÿ   If you contact our Data Protection Officer to discuss your personal information issues, we will collect information from you regarding the service you require from Happlay. Such information collected may include your name, e-mail address, home address, telephone number, or other unique identifiers that would allow us to identify you.

This personal information is used to provide the Services you request and in order to communicate with you in relation to Happlay Services via different channels (e.g., by phone, e-mail, online chat).

This type of data processing is necessary for the performance of your contract (or necessary to conclude the contract) with Happlay.

To the extent permitted by any applicable mandatory laws and regulations, this type of personal information is stored for as long as you are a user of Happlay Services and then Two (2) years thereafter for evidentiary reasons and in accordance with the applicable statute of limitations.

You can choose not to provide certain information, but then you may not be able to take advantage of many of our Services. Any information required by law or contract will be marked with an asterisk.

2.       Statistics

We generate statistical metrics based on some application events, such as daily active users (DAU), daily new users (DNU), etc. Its purpose is to understand the use of our application. We may collect certain information including the following:

Ÿ   Unique Device ID (“UUID”), or other unique identifiers of your Device;

Ÿ   Events for the application, such as open/exit application, and so on;

Information processing in this regard is based on Happlay’s legitimate interest in knowing how our products are being used (article 6.1.f GDPR).

To the extent permitted by any applicable mandatory laws and regulations, this type of personal information is stored for as long as you are a user of Happlay Services and then Two (2) years thereafter for evidentiary reasons and in accordance with the applicable statute of limitations.

3.       Information We Collect To Provide Services and Advertising

Our technology enables our partners to show application users more relevant advertising that is based on users’ interest in applications. If you are a user that uses application or software containing our Services, or downloads and uses an application which contains the Happlay SDK or otherwise interacts with the Services, we may collect certain information including the following:

Ÿ   Device make, model and operating system;

Ÿ   Device properties related to screen size & orientation, resolution, audio volume and battery, device memory usage;

Ÿ   Name and properties of application through which a user interacts with the Services;

Ÿ   Country, time zone and locale settings (country and preferred language);

Ÿ   Network connection type and speed;

Ÿ   Live streaming data: channel ID, channel name, and program name;

Ÿ   IP Address and MAC Address;

Ÿ   Internet browser user-agent used to access the Services;

Ÿ   Identifier for advertisers (IDFA); and

Ÿ   Clickstream data, which is a record of advertising content (which might be web pages, videos or images) you have viewed.

This Device information may be collected across apps and websites over time. We may also combine information we collect with other information we derive through analytical techniques, and we use that combined information to offer the Services. This type of information may include data related to a consumer’s interaction with an application, such as information about the actions taken in an application by end users, like purchases within Happlay’s applications, or end user’s application installations.

Ads can be served based on your general location. This can include location derived from the Device’s IP address. This includes activity stored in your web app activity, which can be used for more useful ads.

Using the abovementioned information we collect, we are able to deliver the Services (including advertising contents), improve them, and research and develop new ones. Such information can make your experiences across Happlay more relevant and helpful.

Any such processing will be based on if you consent to it. You can choose not to provide certain information, but then you may not be able to take advantage of many of our Services.

To the extent permitted by any applicable mandatory laws and regulations, this type of personal information is stored for as long as you are a user of Happlay Services and then Two (2) years thereafter for evidentiary reasons and in accordance with the applicable statute of limitations.

4.      Provide, Troubleshoot, and Improve Happlay Services

In order to improve our Services’ functionalities and to rectify any problems in connection or the provision of Service. We may collect the following information:

Ÿ   device and software characteristics such as SoC model, TV brand, software version number, operating system version, and settings of the Device you use to access the Services;

We use your personal information to provide functionality, analyze performance, fix errors, and improve usability and effectiveness of Happlay Services.

This data processing is necessary for the performance of the contract and based, in part, on Happlay’s legitimate interest to improve its Services and provide optimal Services to clients.

To the extent permitted by any applicable mandatory laws and regulations, this type of personal information is stored for as long as you are a user of Happlay Services and then Two (2) years thereafter for evidentiary reasons and in accordance with the applicable statute of limitations.

In certain cases, we will have a legal obligation to collect and process your personal information. You will be informed of the specific purposes, when the case arises.

 

Does Happlay Share Your Personal Information?

We may disclose your information internally within our business to the relevant teams, such as, without limitation the customer services team, the legal team, the finance team, the sales team and where you have chosen to receive marketing messages, to the marketing teams. We may only disclose your information to a third party under one of the following conditions:

Ÿ   Sharing With Affiliates

We may share the information we collect through the Services to our affiliates or subsidiaries for the purposes described in this privacy policy; however, if we do so, their use and disclosure of your personal information will be subject to this Privacy Policy.

Ÿ   Sharing with Third Party Partners: 

We may share information we collect or derive with advertising clients and business partners, such as to deliver relevant advertising, and to provide attribution. For example, we may share your Device ID, IP address and MAC address with our business partners (e.g. Ads exchanges and demand side platforms). Advertising clients using these Ads exchanges or demand side platforms will buy our ad placements through programmatic ad auctions. Those companies are responsible as independent controllers of the data used to deliver their ads on Happlay’s network.

In addition, we employ other companies and individuals to perform functions on our behalf. Examples include cloud-based data storage, sending postal mail and e-mail, analyzing data, providing marketing assistance, providing search results and links (including paid listings and links), processing payments, transmitting content, and providing customer service. These third-party service providers have access to personal information only as needed to perform their functions, but may not use it for other purposes. Further, they must process the personal information in accordance with and as permitted by applicable data protection laws.

Ÿ   Advertising, Measurement and Analytics Services (Non-Personally Identifiable Information Only):

We may also provide our affiliates and third party partners with information about the reach and effectiveness of their advertising without providing information that personally identifies you, or if we have aggregated the information so that it does not personally identify you. For example, we may tell an advertiser how its ads performed, or how many people viewed their ads or installed an app after seeing an ad.

Ÿ   Business Transfers: 

As we continue to develop our business, we might sell or buy other businesses or services. In such transactions, user personal information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Policy (unless, of course, the user consents otherwise). Also, in the unlikely event that Happlay or substantially all of its assets are acquired, user personal information will of course be one of the transferred assets.

Ÿ   Protection of Happlay and Others: 

We release certain personal information when we believe such release is appropriate to comply with the law; in response to subpoenas, court orders, or other legal processes; enforce or apply our Terms of Use and other agreements; or protect the rights, property or safety of Happlay, our users or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.

Other than as set out above, you will receive notice when personal information about you might be shared with third parties and you will have an opportunity to choose not to share the information.

 

Transfers out of the European Economic Area

WE MAY TRANSFER AND STORE YOUR DATA OUTSIDE THE EUROPEAN UNION (“EU”) AND EUROPEAN ECONOMIC AREA (“EEA”) IN ORDER TO PROVIDE YOU WITH OUR SERVICES (49.1(B) GDPR). More specifically, we may transfer your data to our headquarters at HAPPLAY SOFTWARE PTE.LTD., with its principal business address at 60 PAYA LEBAR ROAD #04-15 PAYA LEBAR SQUARE SINGAPORE (409051), for the purposes outlined in this Privacy Policy. We will ensure that the information is transferred in accordance with this Privacy Policy and as permitted by the applicable laws on data protection. In particular we will ensure an adequate level of protection and implement the necessary safeguard measure, such as the conclusion of EU standard clauses (for a copy of these clauses please write to: dpo@happlay.tech.

 

How Secure is Information about Me?

We take protection of your data seriously, we use reasonable administrative, logical, physical and managerial measures to safeguard your personal information against loss, theft and unauthorized access, use and modification. These measures are designed to provide a level of security appropriate to the risks of processing your personal information.

Ÿ   We use the method of pseudonymization when processing some of your personal information. After pseudonymization, your personal information can no longer be attributed to you without the use of additional information, and such additional information will be kept separately and is subject to technical and organizational measures to ensure that the personal information are not attributed to you;

Ÿ   We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personal information. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you or respond to any of your requests relative thereto;

Ÿ   Our Services offer security features to protect them against unauthorized access and loss of data. You can control these features and configure them based on your needs;

Ÿ   We restrict access to personal information to Happlay employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations; and

Ÿ   It is important for you to protect against unauthorized access to your password and to your Devices, and applications.

However, please note that although we take reasonable steps to protect your information, no website, Internet transmission, computer system or wireless connection is completely secure. You should take steps to protect against unauthorized access to your password and Device by, among other things, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

 

What about Third-Party Advertisers and Links to Other Websites or Applications?

Happlay Services may include third-party advertising and links to other websites or platforms. These third parties may collect information about you when you interact with their content, advertising, and services. Please note that these third parties have separate and independent privacy or data policies, privacy statements, notices and terms of use, which we recommend you read carefully, and we are not responsible for the security or privacy of any information collected by them.

 

Additional Disclosures for Individuals in Europe

If you are located in the European Economic Area or Switzerland, you have certain rights and protections under the law regarding the processing of your personal data.

Legal Basis for Processing. When we process your personal data, we will do so, e.g., on the following basis:

Ÿ   The data processing is necessary for the performance of your contract (or necessary to conclude the contract) with Happlay (6.1.b GDPR);

Ÿ   The data processing is based on if you consent to it (article 6.1.a GDPR);

Ÿ   This data processing is based on Happlay’s legitimate interest to improve its Services and provide optimal Services to clients (article 6.1.f GDPR).

Ÿ   In certain cases, we will have a legal obligation to collect and process your personal data. You will be informed of the specific purposes, when the case arises (article 6.1.c GDPR).

Data Subject Requests. You have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred.  You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you may contact us as indicated below.

 

Opt-Out From Happlay Personalized Advertising

Depending on the Device, application, web browser and service you use, you may be able to opt out from our personalized ads. Please follow the below instructions:

Ÿ   To opt-out from your web browser in any devices:

If you opt-out, you will still see ads, including contextually tailored ads (i.e., ads tailored to the current website or app you are viewing) and ads based on your current location; they just may not be relevant to your interests.

The opt-out mechanism will only opt you out of personalized advertising delivered by Happlay in this browser or in applications on this Device. It will not opt you out on other devices or in other browsers you use.

Most web browsers are set to accept cookies by default.  If you prefer, you can usually choose to set your browser to remove or reject browser cookies.   Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services. Opt-out information is stored in a cookie If you delete your cookies, this information will also be deleted, and you will need to renew your opt-out choices.

Ÿ   To opt-out from an in an app environment:

If you opt-out, you will still see ads, including contextually tailored ads (i.e., ads tailored to the current website or app you are viewing) and ads based on your current location, they just may not be relevant to your interests.

If you want to disable Happlay personalized ads, please refer to your operating system settings.

Some Device system software are providing mechanisms that allow users to opt-out of the use of information about their usage of apps to deliver targeted ads to their Device. For more information, or to opt-out using these mechanisms, you may consult your Device settings, contact the manufacturer or retailer of your Device, or the operator of the application. Please note that a Device setting may disable personalized ads from all providers, and not just for Happlay.

If your Device’s advertising identifier is reset, you will need to renew your opt-out choice for that device.

 

Are Children Allowed to Use Happlay Services?

You must be 18 years of age or older to use our Service. In certain jurisdictions, the age of majority may be older than 18, in which case, you must satisfy that age. While individuals under the age of 18 may utilize our Service, they may do so only with the involvement, supervision, and approval of a parent or legal guardian.

 

How Long Does Happlay Keep Your Personal Information?

We will not keep your personal information for longer than is necessary for the purpose it was collected. This means that data will be destroyed or erased from our systems when it is no longer required.

Personal information is held:

Ÿ   at least the duration for which the information is used to provide you with Services;

Ÿ   as may be required under law, a contract, or with regard to our statutory obligations; or

Ÿ   only for as long as is necessary for the purpose for which it was collected, is processed, or longer if required under any contract, by applicable law, or for statistical purposes, subject to appropriate safeguards.

For more detail see the description of our activities.

 

Changes to This Privacy Policy

We will update this Privacy Policy from time to time in response to changing legal, regulatory or operational requirements. We will provide notice of any such changes (including when they will take effect) in accordance with the law.

Your continued use of the Happlay Services after any such updates take effect will constitute acknowledgement and acceptance of those changes. If you do not wish to acknowledge or accept any updates to this Privacy Policy, you may stop your use of Happlay Services.

At the beginning of this Privacy Policy, you can see when this Privacy Policy was updated and when it took effect.

 

Contacting Us

If you have any concern about privacy or questions related to data protection at Happlay, please contact our data protection officer, in doing so please include a thorough description of your issues and we will try to resolve them for you. The data protection officer mentioned above can be contacted at dpo@happlay.tech. If you are an individual in European Economic Area, you can also contact our representative at european-representative@happlay.tech.

Please note that if you contact us to assist you, for your safety and ours we may need to authenticate your identity before fulfilling your request.

You may lodge a complaint with the relevant supervisory authority if you consider that our processing of your personal information infringes applicable law.