Privacy Policy

Last Updated: March 14, 2020 

HAPPYFORCE, S.L. (hereinafter “HAPPYFORCE“) with C.I.F. B-66581547 and address at Passeig Isabel II, no. 12, 08003 Barcelona, registered in Registro Mercantil de  Barcelona at Volume 44929, Folio 205, Page 471645, Registration 1, I declare that he owns the domain https://myhappyforce.com/ (hereinafter, the “Web” ) and the “Happyforce” application (hereinafter, the “Application“) in accordance with the obligations set forth in Law 34/2002, of July 11, on services of the information society and electronic commerce (hereinafter , the “LSSI-CE“).

1. Identity and contact details of the Data Controller

In the terms of the applicable data protection regulations and, in particular, of Regulation (EU) 2016/679, of the European Parliament and of the Council, of April 27, 2016, regarding the protection of natural persons in what Regarding the processing of personal data and the free circulation of these data (hereinafter, the “RGPD”) and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (hereinafter , the “LOPDGDD”), the Data Controller is:

2. Protection of personal data in accordance with applicable regulations 

HAPPYFORCE has adapted the Web and the App to the RGPD and the LOPDGDD. To do this, it has put in place those technical, organizational policies, means and procedures to guarantee and protect the confidentiality, integrity and availability of your personal data.

3. Principles that we will apply to your personal information 

In the treatment of your personal data, we will apply the following principles, which are adjusted to the requirements of the RGPD: 

Principle of legality, loyalty and transparency: We will always require your consent for the processing of your personal data for one or more specific purposes that we will inform you of in advance with absolute transparency. 

Principle of minimization of data: We are only going to request the strictly necessary data in relation to the purposes for which we require them. 

Principle of limitation of the conservation period: The data will be kept for no longer than necessary for the purposes of the treatment, depending on the purpose, we will inform you of the corresponding conservation period. 

Principle of integrity and confidentiality: Your data will be treated in such a way that adequate security of personal data is guaranteed and confidentiality is guaranteed. You should know that we take all the necessary precautions to avoid unauthorized access or improper use of our Users’ data by third parties.

4. Data collection and its confidentiality 

The data provided to HAPPYFORCE by different means, contact forms, surveys or procedures used during the collection, will be made in accordance with the current data protection regulations, and for the sole purpose of providing the service that has been reported to you. 

The transmission of data by the User of the services of HAPPYFORCE [in particular, employees or managers of the client company] (hereinafter, the “User”) through the Web or the App, is done voluntarily and is they are informed prior to the treatment of the use and its purposes. 

HAPPYFORCE informs the User that only the information necessary to achieve the purpose of the treatment is collected and, only the data that has been provided for the purpose / s for which / they were informed and, subsequently, authorized. 

HAPPYFORCE, in its capacity as Data Controller, guarantees confidentiality in the treatment of all the personal data of the User to which it has access. The Data Controller, like any other person involved in any phase of the treatment, is subject to the strictest professional secrecy, with a special commitment to adopt the levels of protection and the necessary measures, both technical and organizational, to guarantee the safety of personal data and avoid alteration, misuse, loss, theft, treatment or unauthorized access. 

All the information that the User provides to HAPPYFORCE, must be truthful, and will be solely responsible for the false or inaccurate statements that it makes and for the damages that it causes to HAPPYFORCE or to third parties. 

HAPPYFORCE reserves the right to exclude from the services any User who has provided false information, without prejudice to other legal actions that may be applicable.

5. Personal data 

They refer to any information or data that can identify you directly (for example, your name or surname) or indirectly (for example, your national identity document or ID). 

Personal data includes information such as email / date of birth, professional category, gender, salary range, employer / company and professional information, job titles, user-generated content; as well as, all the information that is generated by this part on the occasion of the development of the services that HAPPYFORCE provides to the User in the development of its activity. 

It could also include unique numerical identifiers such as the IP address of your computer or the MAC address of your mobile device, as well as the information we obtain through cookies.

6. Data processing and treatment purposes 

HAPPYFORCE will process the following User data, manually and / or automatically, for the following specific purposes:

The legitimacy by HAPPYFORCE to carry out the processing of personal data for the contracting of services is the contractual relationship itself; In the case of the data provided for the request of a demo or a contact form, the consent of the interested party is found for the specific case. The legitimacy for the interaction of users for the operation of HAPPYFORCE products and services is the consent of the interested party accepting the corresponding privacy policy. In order to send commercial communications and newsletters to HAPPYFORCE clients, the legitimate interest may be used, consent being necessary to carry out said treatment with users who are not HAPPYFORCE clients. 

For the purposes indicated, we may rely on automated decisions, including the preparation of recommendation reports for our clients. In any case, we will limit ourselves to using those data necessary for the preparation of the profile that will be previously encrypted as a security measure.

7. Treatment of data by third parties and session 

Depending on the fines for which personal data is collected, the following people can access this information, interchangeably: 

• Personal authorization of HAPPYFORCE or its representatives acting on their behalf, subject to the applicable data protection regulations that apply. 
• Regulatory authorities or other third parties in accordance with applicable laws. 
• Third parties [IT service providers that process information, hosting servers, maintenance of support for databases, software and applications]. All this only after taking the necessary measures to ensure that we can share such information in compliance with data protection regulations. 

HAPPYFORCE will not disclose to third parties any information or personal data that you have provided on the Web or the application and that can identify you directly or indirectly, except by legal mandate. 

If there is a sale, merger, consolidation, change in social control, transfer of dangerous assets, reorganization or liquidation of HAPPYFORCE, then, in our discretion, we can control, sell or assign the information collected on the Web or App to one or more relevant parts.

8. Retention of data 

The personal data will be kept for the time strictly necessary until the end for which they were collected ends, and as long as the cause that legitimized the processing of this personal data is maintained. After the cause that legitimized the treatment, personal data will be kept duly blocked for the period of time that is appropriate in order to comply with the statutory limitation periods to avoid possible infractions.

9. Marketing directo

HAPPYFORCE no utiliza sus datos personales para fines de marketing directo sin su expreso consentimiento previo.

Si en algún momento decide dejar de recibir información comercial de HAPPYFORCE puede, sin cargo alguno y sin tener que facilitar una justificación, darse de baja de campañas de marketing directo y oponerse al procesamiento futuro de sus datos personales para dichos fines enviando un correo electrónico a gdpr@myhappyforce.com.

Tenga en cuenta que, aunque decida no suscribirse o se dé de baja de los correos electrónicos comerciales, promocionales o newsletter, puede que sigamos necesitando contactar con usted en referencia con información importante de índole no comercial, así como cualquier comunicación que sean necesarias para cumplir con nuestras obligaciones legales.

10. Direct Marketing 

HAPPYFORCE does not use your personal data for direct marketing purposes without your express prior consent. 

If at any time you decide to stop receiving commercial information from HAPPYFORCE you can, without any charge and without having to provide a justification, unsubscribe from direct marketing campaigns and oppose the future processing of your personal data for such purposes by sending an email to gdpr@myhappyforce.com. 

Please note that even if you choose not to subscribe or unsubscribe from commercial, promotional or newsletter emails, we may still need to contact you regarding important non-commercial information, as well as any communications that are necessary to comply with our legal obligations.

11. Security measures 

HAPPYFORCE adopts the security levels required by the RGPD appropriate to the nature of the data that is subject to treatment at all times by its activity. 

In this regard, HAPPYFORCE has implemented appropriate technical and organizational measures designed to guarantee an appropriate level of security for the risk, which includes as appropriate: (a) pseudonymization (such as when data is separated from direct identifiers so that it is not possible to link them to an identity without additional information being kept separately) and encryption, (b) protect the ongoing confidentiality, integrity, availability and resilience of systems and services used to process your personal information, (c) provide the ability to restore availability and access to personal information in a timely manner in the event of a physical or technical incident; and (d) maintain a process for regularly testing, evaluating and evaluating the effectiveness of technical and organizational security measures. When you submit information to us through our website, your information is protected both online and offline. All data transferred to / from the internal HAPPYFORCE network, from / to an external entity, is encrypted according to industry standards. Please note that messages you send us via Internet email may not be secure. We maintain adequate physical, electronic and procedural safeguards to guarantee the security, integrity and privacy of your personal information within our company. Only those employees who may require your information to perform a specific job have access to your organization’s identifiable information. Additionally, all employees are kept up-to-date on our security and privacy practices. 

We maintain adequate physical, electronic and procedural safeguards to guarantee the security, integrity and privacy of your personal information within our company. Only those employees who may require your information to perform a specific job have access to your organization’s identifiable information. Additionally, all employees are kept up-to-date on our security and privacy practices. 

Likewise, you can also carry out secure anonymization techniques for personal data [anonymization of data / non-personal data] that you try to carry out your activity. 

However, technical security in a medium such as the Internet is not impregnable and there may be malicious acts by third parties, although HAPPYFORCE applies the means at its disposal to avoid such actions.

12. Rights of the interested parties and their exercise 

In accordance with the RGPD and the LOPDGDG, Users can exercise the following rights: 

• Right of access: The User may ask HAPPYFORCE if they are processing their data and, if so, access them. 
• Right of rectification: The User may request the rectification of the data if they are inaccurate, or complete the data that we have incomplete. 
• Right to request the deletion of your data. 
• Right to request the limitation of their treatment: In this case we will only keep them for the exercise or defense of claims. 
• Right to oppose the treatment: HAPPYFORCE will stop processing personal data, with the exception that they must continue to be processed for legitimate reasons or for the exercise or defense of possible claims. 
• Right to data portability: In case the User wants their data to be processed by another data controller, HAPPYFORCE will facilitate the transfer of their data to the new data controller. 

• Right not to be the subject of a decision based solely on the automated processing of your personal data.

If the User has given consent for a specific purpose, he may withdraw it at any time, without affecting the legality of the treatment based on the consent prior to its withdrawal. 

In any case, at the moment in which the User exercises his deletion rights, all the personal data linked to his account, as well as the information and contents that are integrated into his profile, will be canceled. Likewise, in the event that the User exercises the right of deletion over the data necessary for HAPPYFORCE to provide the services of the Web, HAPPYFORCE will be forced to terminate its relationship with the User, proceeding to unsubscribe, without right to any claim by him. 

To exercise your rights, including to make a claim in case you consider that HAPPYFORCE is improperly treating your data, you must send a written communication to the registered office of HAPPYFORCE or to the email address gdpr@myhappyforce.com, including in both cases a photocopy of your DNI, NIE or other equivalent identification document. 

You can use the models and forms on the rights referred to above by going to the official website of the Spanish Agency for Data Protection (https://www.aepd.es/). If you consider that HAPPYFORCE is treating your personal data inappropriately, you can direct your claims to this Control Authority.

13. International data transfers 

We also transfer personal information that we process to countries outside the European Economic Area (“EEA”) (for example, when one of our service or equipment providers is outside the EEA, for example to host your personal information). We have put in place adequate safeguards regarding the protection of your privacy, fundamental rights and freedoms, and the exercise of your rights, for example, we establish an adequate level of data protection, generally through the EU standard contractual clauses based on the model of the EU commission clauses.

14. Changes in privacy policy 

We will only use personal data as established in the Privacy Policy that is in force at the time such data is collected. 

HAPPYFORCE reserves the right to modify this Privacy Policy at any time, publishing such modifications on the Web, so it is recommended to visit it each time it is accessed. If at any time we decide to use personal data differently from what was stated at the time it was obtained, the User will be notified by email, as long as we have it. At that time, you will be given the option to authorize other uses or disclosures of personal data that you would have provided to us prior to the amendment of our Privacy Policy. 

In the event that any clause of this Privacy Policy is annulled or considered null, the rest of the conditions will not be affected, fully retaining their validity and validity, in accordance with the current regulations applicable at all times.

15. Links to other websites 

Hyperlinks that allow a link to other pages or websites are used or can be used on our website. HAPPYFORCE is not responsible for the content of such websites nor are they responsible for their privacy policies. It is recommended to take into account and read the privacy policies of all the websites you visit. Remember that what is indicated in this Privacy Policy only applies to the data that HAPPYFORCE collects and / or processes. 

HAPPYFORCE is present on social networks and, in addition to these, it provides Users with the possibility of communicating through different means of social communication. The treatment of the data of the people who become followers, establish a link or relate to HAPPYFORCE through social networks or the media made available to them, will be governed by the legal notice of our website and the conditions of use, privacy policies and other regulations of access, use and the like of the corresponding social network or medium. The User is aware of them and will have previously accepted them.

16. Applicable law 

The privacy of all the information provided, both that provided by the User through the different personal data request forms, and that accessible through the Web and / or the App, is regulated by current data protection regulations. , especially, by the RGPD and by the LOPDGDD.