Privacy Policy
and Cookie Policy

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Privacy Notice for website and Happeo platform

This Privacy Notice was last updated on 2022/09/07.

This Privacy Notice concerns Happeo’s (“Happeo”, “we” or “us”) personal data processing in the context of the Happeo website www.happeo.com (“Website”) and Happeo’s social intranet platform accessible through the Website (“Happeo Platform”). Together, these are referred to as the “Services”.

The Privacy Notice describes how we process personal data concerning the visitors of the Website, the users of the Happeo Platform, the contact persons of our customers, potential customers, suppliers and other business partners when we offer and promote our services to existing and potential customers and users, and maintain business relationships with customers and other business partners.

The word “you” refers to all the aforementioned individuals whose personal data is processed in accordance with this Privacy Notice.

We are committed to processing personal data in compliance with this Privacy Notice and applicable laws. This Privacy Notice contains information about what personal data we collect, what are the purposes of processing and what rights you have relating to any personal data that concerns you.

Our services may contain links to other services or websites run by parties other than Happeo (“Third-Party Services”). Our provision of these links does not amount to our endorsement of these Third-Party Services, nor their content, owners, or practices. This Privacy Notice does not apply to Third-Party Services, but those are governed by their own terms and policies, as applicable. Happeo does not control or assume any responsibility for the content or practices of any Third-Party Services.

DATA CONTROLLER’S CONTACT DETAILS

The data controller regarding processing of personal data pursuant to this Privacy Notice is:

Happeo Oy (Business ID: 2802188-2)
Address: Fredrikinkatu 48, 00100 Helsinki, Finland
Email: dpo@happeo.com

PERSONAL DATA PROCESSED

The personal data collected and processed by us in accordance with this Privacy Notice can be divided into the following categories:

1. Identity Data includes first and last name, title, and company information.
   
   
2. Contact Data includes email, telephone number and address.
   
   
3. Communication Data includes your correspondence with Happeo or users of Happeo Platform.
   
   
4. Analytics data includes IP address, geographical location, browser type, referral source; length of visits; pages viewed; heat mapping.
   
   
5. Transaction Data includes invoicing and billing information, purchases history.
   
   
6. Technical Data includes IP address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access Happeo Platform or this website.
   
   
7. Marketing and Communications Data includes your preferences in receiving marketing communications from us and our partners and your communication preferences.
   
   
8. User Data includes your user ID to Happeo Platform and access tokens.
   
   
9. Feedback includes feedback and claims made by you.

The above data may also include information about you that is publicly available, such as information available on sites like LinkedIn, Twitter, Facebook and Google.

SOURCES OF DATA

The personal data we collect and process is largely provided by yourself. With respect to potential customers and their contact persons, we also receive personal data from external or public sources, as we constantly look for new companies whom we think may benefit from our services. These sources include services such as Zoominfo, LeadIQ and Linkedin.

Some data is also generated during your use of the Website or Happeo Platform. When you visit the Website, you are not required to provide any Contact Data. However, when you contact us via the chat function on the Website or when you sign up to receive information from us, you are required to provide some Contact Data.

COOKIES

We use cookies on our Website to provide our visitors the best possible user experience. You can find more information about our cookie practices in our Cookie Policy.

PURPOSES AND LEGAL BASIS OF PROCESSING

Legitimate grounds for processing

We will only process your personal data when the law allows us to. Most commonly, we will process your personal data in the following circumstances:

1. Where you have provided your consent (GDPR Article 6(1)(a)).
   
   
2. Where we need to perform a contract we are about to enter into or have entered into with you (GDPR Article 6(1)(b)).
   
   
3. Where it is necessary to comply with legal obligations (GDPR Article 6(1)(c)).
   
   
4. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (GDPR Article 6(1)(f)).

When choosing to process your personal data on the basis of our legitimate interests, we weigh our interests against your right to privacy and provide e.g., an easy-to-use opt-out from our marketing communications and process pseudonymised or non-personally identifiable data when possible.

You may be requested to grant your consent for the processing of personal data. When the processing of personal data is based on consent, you may withdraw your consent at any time.

We have set out below a description of the ways in which we plan to process your personal data and the legal bases on which we rely to do so. We have also identified what our legitimate interests are, where appropriate.

Website

Happeo Platform

PERSONAL DATA RECIPIENTS

Personal data is mainly stored in electronic format and only authorised personnel within our organisation have access to the data.

Our services integrate some services provided by third parties. We may share some of your information with these service providers in order for them to provide their services, including removing repetitive information from prospect lists, analysing data, providing marketing assistance, conducting customer and/or user profiling, and providing customer service. As such, the terms and privacy policies of these service providers may apply to you as well, in particular: Google Analytics, Hubspot, Zoominfo, Google Optimize, Google Adwords, Capterra, Google Tag Manager, Google Recaptcha, LinkedIn, Twilio, Hotjar, Funnelytics, Clearbit, Amplifier, Grow, LeadIQ, Segment, and Zendesk.

To the extent the third parties act on Happeo’s behalf as data processors, Happeo seeks to conclude data processing agreements with each service provider before third party services are implemented into Happeo’s services in order to ensure that your personal data is used, stored, and transferred securely and in accordance with European Union law. This Privacy Notice does not apply to the services of the third parties to the extent the services are provided by the third parties acting as data controllers and are governed by their own policies and terms.

We may also disclose or transfer personal data to fulfil legal obligations or when a supervisory authority requires a disclosure. We may also disclose personal data if we are a subject to certain business activities such as merger or an acquisition or a funding process.

TRANSFERS OUTSIDE THE EEA

In order to provide our services, we transfer personal data outside the European Economic Area if our service provider is located there.

If personal data is transferred outside the European Economic Area, we make sure that (i) the transferee is located in a country with adequate safeguards (as decided by the EU commission from time to time), or (ii) the transfer occurs by using appropriate safeguards such as Standard Contractual Clauses published by the EU commission.

DATA STORAGE PERIOD AND SECURITY

We will not store personal data for a longer period than is necessary for its purpose or required by contract or law. The retention periods for personal data may vary based on its purpose and the situation. The retention periods may also be based on applicable laws (e.g. accounting, tax laws, employment contracts act). We may also update data from time to time. You may contact us in order to get detailed knowledge about the retention times of the data we have about you.

Personal data is stored and secured in accordance with general industry standards and practices. We consider and keep personal data confidential. Subcontractors that we use for processing personal data are selected also based on their data security measures. For our own systems and data storage, we use only well-established service providers and robust software tools. Access to personal data is also protected with user-specific logins, passwords and user rights. Our premises are also safe and secure.

USER’S RIGHTS

Right to access

You have the right to know whether we are processing personal data concerning you and also to know what data.

Right to withdraw consent

If we process personal data based on your consent, you can withdraw your consent at any time by contacting us. Withdrawing a consent may lead to fewer possibilities to use our services. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

Right to rectify

You have the right to request that we correct any inaccurate or outdated personal data we have about you by contacting us.

Right to prohibit direct marketing

You have the right to request that your personal data is not processed for direct marketing purposes.

Right to unsubscribe marketing communications

You may unsubscribe from receiving our marketing communications at any time by clicking the "unsubscribe" link located on the bottom of our emails or by contacting us.

Right to object

If we process your personal data based on Happeo’s or a third party’s legitimate interest, you have the right to object to the processing of your data, to the extent that there is no such significant other reason that would override your rights or the processing is not necessary for handling legal claims. Please notice that in this situation we may not be able to serve you anymore.

Right to restriction of processing

You may request us to restrict processing of personal data for example when your data erasure, rectification or objection requests are pending and/or when we do not have legitimate grounds to process your data. This may lead to fewer possibilities to use our services.

Right to data portability

If we process your personal data based on your consent or fulfilling of a contract, you have the right to request transfer of the data you have provided to us to another service provider in a commonly used electronic format.

How to use the rights

You can exercise your rights by sending us an email to dpo@happeo.com. In such a case, we are required to verify your identity, for example with a written and signed (and scanned) request, or a copy of your personal ID, but without social security number and other such information that we don’t need. If you consider that the processing of your personal data is not lawful, you can also make a notification to a supervisory authority.

In Finland, the competent supervisory authority is the Office of the Data Protection Ombudsman: https://tietosuoja.fi/en/notification-to-the-data-protection-ombudsman 

PRIVACY NOTICE UPDATES

We may update this Privacy Notice when our operations change or develop. Also changes in law may make it necessary to update this Privacy Notice. The changes become valid once we have published them in the form of an updated privacy notice. Therefore, please visit this page and read this Privacy Notice from time to time.

Privacy Notice Job Applicants

Happeo respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we collect, process and share your personal data when you apply for a job with us, and will tell you about your privacy rights.

1. WHO IS DATA CONTROLLER?
2. INFORMATION WE COLLECT AND HOW WE COLLECT IT
3. THE PURPOSES AND THE LAWFUL BASIS
4. SHARING OF INFORMATION COLLECTED
5. TRANSFER TO THIRD COUNTRIES
6. DATA RETENTION
7. HOW TO EXERCISE YOUR DATA PROTECTION RIGHTS
8. CHANGES TO THIS PRIVACY NOTICE

1. WHO IS DATA CONTROLLER?

The data controller for the processing described in this notice is:

Happeo Oy

Happeo B.V.

Happeo Inc.

Happeo Ltd.

Happeo Software Services S.R.L.¨

All of the controllers mentioned above are described together as “Happeo Group” and individual controllers as “Happeo”. As an employee or other worker, your respective controller is the company with whom you have signed your employment or other similar contract.

If you have questions regarding this Privacy Notice, please contact us by email at dpo@happeo.com.

2. INFORMATION WE COLLECT AND HOW WE COLLECT IT

In the following we will tell you which types of personal data we may collect about you and how we collect it. In section 3 we have in a table explained the purposes for which we process your personal data and the lawful basis we rely on.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

1. Identity and Contact Data includes first name, last name, birthday and photo identification, email, telephone number and address.
   
   
2. Recruitment Data includes the information collected in the process of recruiting you, such as information you have included in your application and CV; including documentation and information about your education, previous work experience, qualifications, language skills, any photos, video or other recorded material which you at your own discretion chooses to make available to us.
   
   
3. References includes information obtained from previous employees at our request.
   
   
4. Work Permits includes information on your passport, citizenship, residence and work permit where needed.
   
   
5. Test data include your replies to aptitude, skills or personality tests.
   
   
6. Qualification records includes authorisations and certifications, professional experience, qualifications and training records.

The information is collected directly from you by your application, CV or other material made available to us before or during interviews; we also process personal data from candidate profiles you are uploading to recruitment platforms.

3. THE PURPOSES AND THE LAWFUL BASIS

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

1. To take steps prior to entering into a possible employment contract at your request by submitting your job application to us cf. GDPR Article 6 (1) (b).
   
   
2. Where it is necessary for the purposes of carrying out the obligations and exercising specific rights of you or us in the field of employment cf. GDPR Art 9 (2) (b).
   
   
3. Where we need to comply with a legal or regulatory obligation cf. GDPR Article 6 (1) (c) or if necessary for the establishment, exercise or defence of a legal claim cf. GDPR Art 9 (2) (f).
   
   
4. Where you have provided your consent cf. GDPR Article 6 (1) (a) or Article 9 (2) (a). Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests cf. GDPR Article 6 (1) (f).
   
   
   

We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Necessary for the establishment, exercise or defence of a legal claim

4. SHARING OF INFORMATION COLLECTED

We may disclose your personal data within the Happeo Group where required for the above specified purposes. We base this processing on our legitimate interest to transmit personal data within the Happeo Group for internal administrative purposes, such as for the purposes of using centralized IT systems and alignment of Group HR Administration, and business operations and strategies. We may disclose personal data to third parties:

• when it is necessary for the purposes listed in section 3
  
  
• when required by law we may disclose your personal data to public authorities
  
  
• we may assign your personal data, to any person or entity that acquires all or substantially all of our business, stock or assets, or with whom we merge.
  
  
• when we believe in good faith that disclosure is necessary to establish or exercise our legal rights or defend against legal claims, protect your safety or the safety of others, investigate fraud, or respond to a government request.
  
  

We share information, including personal information, with our trusted third-party service providers that we use to provide services to us and process your data on our behalf and under our instruction, e.g. hosting of data and maintenance IT-systems, hosting and maintaining recruitment portals and platforms, certain recruitment services and test providers. These third-party service providers may have access to or process your personal information for the purpose of providing these services for us. We do not permit our third-party service providers to use the personal information that we share with them for any other purpose than in connection with the services they provide to us. We have entered into data processor agreements with our data processors.

We may also share information with third parties that act as independent controllers regarding the personal data. This includes [•] firms and other institutions that independently decide the purposes and means of personal data processing.

5. TRANSFER TO THIRD COUNTRIES

We will not transfer your personal data to recipients outside EU or EEA unless we have ensured compliance with GDPR Chapter V.

Some of our third-party service providers are established outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA. However, to ensure that your personal information receive an adequate level of protection we have ascertained that sufficient safety measures have been implemented to allow for the transfer, including where the European Commission have deemed the country to provide an adequate level of protection for personal data; or by use of specific contract clauses approved by the European Commission (Standard Contractual Clauses) which give personal data essentially equivalent protection as it has in the EEA.

If you require further information on our current data processors or sub-processors established outside the EEA and the safety measures in place to allow for the transfer of personal data, you can request it from us – please send your request to us by email at dpo@happeo.com.

6. DATA RETENTION

We retain the personal information we collect where we have an ongoing legitimate need or obligation to do so. Where we are no longer obliged to keep your records and do not have an ongoing need to process your personal information, we will either delete or anonymize it.
In relation to applicants who are not offered employment we will normally delete all data within 12 months from the decision not to offer employment. We will retain applicant data for longer periods if the applicant has consented.

For applicants who are hired personal data will be retained in accordance with our Privacy Notice for Employees.

Data may be retained for longer period if we are legally obliged to do so, or if retention is necessary to establish, exercise or defend legal claims. For specific retention times, please contact us at dpo@happeo.com.

7. HOW TO EXERCISE YOUR DATA PROTECTION RIGHTS

You have certain choices available to you when it comes to your personal information. Below is a summary of those choices, how to exercise them and any limitations.
Under certain circumstances, you have the right to:

• Request access to your personal information. This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  
  
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  
  
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it.
  
  
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
  
  
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  
  
• Request the transfer of your personal information to another party (also known as data portability).

Where our processing is solely based on your specific consent you have the right to withdraw your consent at any time. Such withdrawal will not affect the lawfulness of processing based on consent before its withdrawal.

If you wish to exercise any of the data protection rights that are available to you then please send your request to us by email at dpo@happeo.com and we will action your request in accordance with applicable data protection laws.

You have the right to complain to your local data protection authority if you are unhappy with our data protection practices.

In Finland you can lodge a complaint with the Office of the Data Protection Ombudsman at https://tietosuoja.fi/en/notification-to-the-data-protection-ombudsman.

In Netherlands you can lodge a complaint with the Office of the Data Protection Ombudsman at https://autoriteitpersoonsgegevens.nl/.

In Romania you can lodge a complaint with the Office of the Data Protection Ombudsman at http://www.dataprotection.ro/.

In United Kingdom you can lodge a complaint with the Office of the Data Protection Ombudsman at https://ico.org.uk/make-a-complaint/ .

8. CHANGES TO THIS PRIVACY NOTICE

This privacy notice may be updated from time to time to reflect changing legal, regulatory, or operational requirements. We will provide you with a new notice when we make any substantial updates.

Happeo Cookie Policy

This Cookie Notice was last updated on 2023/12/22.

This Cookie Notice applies to use of cookies at www.happeo.com provided by Happeo Oy (hereinafter referred to as "Happeo", "we" or "us"). You may access and change your cookie preferences at any time by clicking Cookie Settings . 

1. What are cookies?

A cookie is a very small text document, which often includes an anonymous unique identifier. Cookies are created when your browser loads a particular website. The website sends information to the browser which then creates a text file. Every time the user goes back to the same website, the browser retrieves and sends this file to the website's server. 

To the extent personal data is processed via these cookies, processing of personal data is carried out in accordance with our Privacy Notice.

2. What cookies do we use and what information do they collect?

Necessary cookies:

These cookies are required to enable core functionality. Without these cookies, services you have asked for, such as logging in or filling in forms, cannot be provided. If you disable these cookies certain parts of the website will not function for you.

Necessary cookies we use:

Analytics cookies:

These cookies help us improve or optimise the experience we provide. They allow us to measure how our website visitors interact with our website and we use this information to improve the user experience and performance of the website.

These cookies are used to collect technical information such as the last visited website, the number of pages visited, whether or not email communications are opened, which parts of our website or email communication are clicked on and the length of time between clicks.

Analytics cookies we use:

Functional cookies:

We may use cookies that are not essential but enable various helpful features on our websites.

For example, these cookies collect information about your interaction with services provided on the website and may be used on our website to remember your preferences, your interests and the presentation of the website (such as the font size).

Functional cookies we use:

Advertising cookies:

We use these cookies to collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advert as well as help measure the effectiveness of an advertising campaign. We may share this information with other parties who help manage online advertising – please see the "Third Parties" section below for more details.

Advertising cookies we use:

3. What third parties do we use?

Your use of our website may result in some cookies being stored that are not controlled by us. This may occur when the part of the website you are visiting makes use of a third-party analytics or marketing automation or includes content displayed from a third-party website. You should review the privacy and cookie policies of these third-party services to find out how these third parties use cookies.

Below you can find a table describing what third-party cookies are used on our website and for what purposes they are used and how long the cookie is retained.

We use the following third parties:

4. How can you change your cookie settings?

You can change your cookie preferences at any time by clicking on the link Cookie Settings . You can then ‘activate’ or ‘deactivate’ cookies used for different purposes. You may need to refresh your page for your settings to take effect.

Alternatively, most web browsers allow some control of most cookies through the browser settings.

List of authorized sub-processors for Happeo Application

The list can be found here.