Effective as of December 26, 2021
Last updated: December 26, 2021
Information We Collect
Information we collect falls into one of two categories: “voluntarily provided” information and “automatically collected” information.
- “Voluntarily provided” information refers to any information you knowingly and actively provide us when using or participating in any of our services and promotions.
- “Automatically collected” information refers to any information automatically sent by your devices in the course of accessing our products and services.
When you visit our website, our servers may automatically log the standard data provided by your web browser. It may include your device’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details about your visit.
Additionally, if you encounter certain errors while using the site, we may automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical details about your device, what you were trying to do when the error happened, and other technical information relating to the problem. You may or may not receive notice of such errors, even in the moment they occur, that they have occurred, or what the nature of the error is. Please be aware that while this information may not be personally identifying by itself, it may be possible to combine it with other data to personally identify individual persons.
When you visit our website or interact with our services, we may automatically collect data about your device, such as:
- Device Type
- Operating System
- Unique device identifiers
- Device settings
- Geo-location data
Data we collect can depend on the individual settings of your device and software. We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us.
We may ask for personal information — for example, when you submit content to us or when you contact us — which may include one or more of the following:
- Social media profiles
- Date of birth
- Phone/mobile number
- Home/mailing address
- Sensitive Information
“Sensitive information” or “special categories of data” is a subset of personal information that is given a higher level of protection. Examples of sensitive information include information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation, sexual practices or sex life, criminal records, health information, or biometric information.
The types of sensitive information that we may collect about you include:
- Sexual orientation
- Sexual practices or sex life
- Health information
- Biometric information
We will not collect sensitive information about you without first obtaining your consent, and we will only use or disclose your sensitive information as permitted, required, or authorized by law.
Protected Health Information
By setting up an account with Happy Head, you are establishing a direct customer relationship with Happy Head to use the Service. During your use of the Service, you may provide to Happy Head information, including but not limited to, your name, email, social media profiles, date of birth, phone number, address, and transactional information, that we do not consider “protected health information” or “medical information”.
You may also provide to Happy Head certain health or medical information protected under applicable laws. Happy Head is not a “covered entity” under the Health Insurance Portability and Accountability Act of 1996, Public Law 104-191, and its related regulations and amendments (“HIPAA”). Additionally, the Pharmacies, Medical Groups, and/or Providers of the Service may or may not be a “covered entity” or “business associate” under HIPAA. However, in certain cases, Happy Head may be considered a “business associate” of a Pharmacy or Medical Group.
Legitimate Reasons for Processing Your Personal Information
We only collect and use your personal information when we have a legitimate reason for doing so. In which instance, we only collect personal information that is reasonably necessary to provide our services to you.
Collection and Use of Information
We may collect personal information from you when you do any of the following on our website:
- Register for an account
- Enter any of our competitions, contests, sweepstakes, and surveys
- Sign up to receive updates from us via email or social media channels
- Use a mobile device or web browser to access our content
- Contact us via email, social media, or on any similar technologies
- When you mention us on social media
We may collect, hold, use, and disclose information for the following purposes, and personal information will not be further processed in a manner that is incompatible with these purposes:
- to provide you with our platform’s core features and services
- to enable you to customize or personalize your experience of our website
- to deliver products and/or services to you
- to contact and communicate with you
- for analytics, market research, and business development, including to operate and improve our website, associated applications, and associated social media platforms
- for advertising and marketing, including to send you promotional information about our products and services and information about third parties that we consider may be of interest to you
- to consider your employment application
- to enable you to access and use our website, associated applications, and associated social media platforms
- for internal record keeping and administrative purposes
- to run competitions, sweepstakes, and/or offer additional benefits to you
- to comply with our legal obligations and resolve any disputes that we may have
- to attribute any content (e.g. posts and comments) you submit that we publish on our website
- for technical assessment, including to operate and improve our app, associated applications, and associated social media platforms
We may combine voluntarily provided and automatically collected personal information with general information or research data we receive from other trusted sources. For example, Our marketing and market research activities may uncover data and insights, which we may combine with information about how visitors use our site to improve our site and your experience on it.
Security of Your Personal Information
When we collect and process personal information, and while we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use, or modification.
Although we will do our best to protect the personal information you provide to us, we advise that no method of electronic transmission or storage is 100% secure, and no one can guarantee absolute data security.
You are responsible for selecting any password and its overall security strength, ensuring the security of your own information within the bounds of our services. For example, ensuring any passwords associated with accessing your personal information and accounts are secure and confidential.
How Long We Keep Your Personal Information
However, if necessary, we may retain your personal information for our compliance with a legal, accounting, or reporting obligation or for archiving purposes in the public interest, scientific, or historical research purposes or statistical purposes.
We do not aim any of our products or services directly at children under the age of 13, and we do not knowingly collect personal information about children under 13.
Disclosure of Personal Information to Third Parties
We may disclose personal information to:
- a parent, subsidiary, or affiliate of our company
- third-party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, ad networks, analytics, error loggers, debt collectors, maintenance or problem-solving providers, marketing or advertising
- providers, professional advisors, and payment systems operators
- our employees, contractors, and/or related entities
- our existing or potential agents or business partners
- sponsors or promoters of any competition, sweepstakes, or promotion we run
- credit reporting agencies, courts, tribunals, and regulatory authorities, in the event you fail to pay for goods or services we have provided to you
courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or
- in order to establish, exercise, or defend our legal rights
- third parties, including agents or sub-contractors, who assist us in providing information, products, services, or direct marketing to you
- third parties to collect and process data
- an entity that buys, or to which we transfer all or substantially all of our assets and business
Third parties we currently use include: Google Analytics, Mixpanel, Klaviyo, Google Adsense, Bing Ads, Facebook Ads, Reddit Ads, Pinterest Ads, Friendbuy, Rakuten.
International Transfers of Personal Information
The personal information we collect is stored and/or processed in the United States, or where we or our partners, affiliates, and third-party providers maintain facilities.
Your Rights and Controlling Your Personal Information
- Marketing permission: If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below.
- Access: You may request details of the personal information that we hold about you.
- Non-discrimination: We will not discriminate against you for exercising any of your rights over your personal information. Unless your personal information is required to provide you with a particular service or offer (for example providing user support), we will not deny you goods or services and/or charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, or provide you with a different level or quality of goods or services.
- Downloading of personal information: We provide a means for you to download the personal information you have shared through our site. Please contact us for more information.
- Notification of data breaches: We will comply with laws applicable to us in respect of any data breach.
- Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.
- Restrict: You have the right to request that we restrict the processing of your personal information if (i) you are concerned about the accuracy of your personal information; (ii) you believe your personal information has been unlawfully processed; (iii) you need us to maintain the personal information solely for the purpose of a legal claim; or (iv) we are in the process of considering your objection in relation to processing on the basis of legitimate interests.
- Objecting to processing: You have the right to object to processing of your personal information that is based on our legitimate interests or public interest. If this is done, we must provide compelling legitimate grounds for the processing which overrides your interests, rights, and freedoms, in order to proceed with the processing of your personal information.
- Data portability: You may have the right to request a copy of the personal information we hold about you. Where possible, we will provide this information in CSV format or other easily readable machine format. You may also have the right to request that we transfer this personal information to a third party.
- Deletion: You may have a right to request that we delete the personal information we hold about you at any time, and we will take reasonable steps to delete your personal information from our current records. If you ask us to delete your personal information, we will let you know how the deletion affects your use of our website or products and services. There may be exceptions to this right for specific legal reasons which, if applicable, we will set out for you in response to your request. If you terminate or delete your account, we will delete your personal information within 30 days of the deletion of your account. Please be aware that search engines and similar third parties may still retain copies of your personal information that has been made public at least once, like certain profile information and public comments, even after you have deleted the information from our services or deactivated your account.
A cookie is a small piece of data that a website stores on your device when you visit. It typically contains information about the website itself, a unique identifier that allows the site to recognize your web browser when you return, additional data that serves the cookie’s purpose, and the lifespan of the cookie itself. Cookies are used to enable certain features (e.g. logging in), track site usage (e.g. analytics), store your user settings (e.g. time zone, notification preferences), and to personalize your content (e.g. advertising, language). Cookies set by the website you are visiting are usually referred to as first-party cookies. They typically only track your activity on that particular site. Cookies set by other sites and companies (i.e. third parties) are called third-party cookies They can be used to track you on other websites that use the same third-party service.
Types of Cookies and How We Use Them
- Essential cookies: Essential cookies are crucial to your experience of a website, enabling core features like user logins, account management, shopping carts, and payment processing. We use essential cookies to enable certain functions on our website.
- Performance cookies: Performance cookies track how you use a website during your visit. Typically, this information is anonymous and aggregated, with information tracked across all site users. They help companies understand visitor usage patterns, identify and diagnose problems or errors their users may encounter, and make better strategic decisions in improving their audience’s overall website experience. These cookies may be set by the website you’re visiting (first-party) or by third-party services. They do not collect personal information about you. We use performance cookies on our site.
- Functionality cookies: Functionality cookies are used to collect information about your device and any settings you may configure on the website you’re visiting (like language and time zone settings). With this information, websites can provide you with customized, enhanced, or optimized content and services. These cookies may be set by the website you’re visiting (first-party) or by third-party services. We use functionality cookies for selected features on our site.
- Targeting/advertising cookies: Targeting/advertising cookies help determine what promotional content is most relevant and appropriate to you and your interests. Websites may use them to deliver targeted advertising or limit the number of times you see an advertisement. This helps companies improve the effectiveness of their campaigns and the quality of content presented to you. These cookies may be set by the website you’re visiting (first-party) or by third-party services. Targeting/advertising cookies set by third-parties may be used to track you on other websites that use the same third-party service.We use targeting/advertising cookies on our site.
If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data, including your personal information, among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may, to the extent permitted by applicable law, continue to use your personal information according to this policy, which they will be required to assume as it is the basis for any ownership or use rights we have over such information.
Limits of Our Policy
Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.
Changes to This Policy
If the changes are significant, or if required by applicable law, we will contact you (based on your selected preferences for communications from us) and all our registered users with the new details and links to the updated or changed policy.
If required by law, we will get your permission or give you the opportunity to opt in to or opt out of, as applicable, any new uses of your personal information.
Legal Bases for Processing Your Personal Information
We will only collect and use your personal information when we have a legal right to do so. In which case, we will collect and use your personal information lawfully, fairly, and in a transparent manner. If we seek your consent to process your personal information, and you are under 16 years of age, we will seek your parent or legal guardian’s consent to process your personal information for that specific purpose. Our lawful bases depend on the services you use and how you use them. This means we only collect and use your information on the following grounds:
Consent From You
Performance of a Contract or Transaction
Where you have entered into a contract or transaction with us, or in order to take preparatory steps prior to our entering into a contract or transaction with you. For example, if you contact us with an enquiry, we may require personal information such as your name and contact details in order to respond.
Our Legitimate Interests
Where we assess it is necessary for our legitimate interests, such as for us to provide, operate, improve and communicate our services. We consider our legitimate interests to include research and development, understanding our audience, marketing and promoting our services, measures taken to operate our services efficiently, marketing analysis, and measures taken to protect our legal rights and interests.
Compliance with Law
Additional Disclosures for California Compliance (US)
Do Not Track
Some browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not respond to browser “Do Not Track” signals.
Cookies and Pixels
CCPA-Permitted Financial Incentives
In accordance with your right to non-discrimination, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels for the goods or services we provide. Any CCPA-permitted financial incentive we offer will reasonably relate to the value of your personal information, and we will provide written terms that describe clearly the nature of such an offer. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
California Notice of Collection
In the past 12 months, we have collected the following categories of personal information enumerated in the California Consumer Privacy Act:
- Identifiers, such as name, email address, phone number, account name, IP address, and an ID or number assigned to your account.
- Customer records, such as billing and shipping address, and credit or debit card data.
- Demographics, such as your age or gender. This category includes data that may qualify as protected classifications under other California or federal laws.
- Commercial information, such as products or services history and purchases.
- Internet activity, such as your interactions with our service.
- Audio or visual data, such as photos or videos you share with us or post on the service.
- Geolocation data.
- Employment and education data, such as data you provide when you apply for a job with us.
- Inferences, such as information about your interests, preferences and favorites.
For more information on information we collect, including the sources we receive information from, review the “Information We Collect” section. We collect and use these categories of personal information for the business purposes described in the “Collection and Use of Information” section, including to provide and manage our Service.
Right to Know and Delete
If you are a California resident, you have rights to delete your personal information we collected and know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us:
- The categories of personal information we have collected about you;
- The categories of sources from which the personal information was collected;
- The categories of personal information about you we disclosed for a business purpose or sold;
- The categories of third parties to whom the personal information was disclosed for a business purpose or sold;
- The business or commercial purpose for collecting or selling the personal information; and
- The specific pieces of personal information we have collected about you.
Shine the Light
For any questions or concerns regarding your privacy, our policies, or practices around data protection, you may contact us here.