Privacy policy

Updated: 07/29/2019

 

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

 

Terms starting with a capital letter have the meanings of the terms defined in the Terms of Service.

 

2. Processing manager

 

The data collected is processed by SAS HAPPN, a company with a capital of €36 486,44 registered under number 535 217 723 in the Paris Trade and Companies Register. The company’s headquarters are located at 8 rue du Sentier 75002 Paris, France, and it is represented by its CEO, Mr. Didier Rappaport. 

 

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
    • Data relating to your activity on the application
    • Technical data of the cell phone

 

  • Data required for certain purposes
    • Data relating to taking part in games and competitions, to your experience and your satisfaction
    • Crossing points with other Members
    • Geographical position
    • Search preferences - people whom you would like to cross paths with (age and gender)
    • Text messages and voice messages sent and received
    • Data relating to reports made and requests sent to the HAPPN customer service 

 

  • Optional data
    • Professional career and education
    • Personal interests
    • Email address or telephone number (when this data is not mandatory for registration)
    • 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 

 

Mandatory information

 

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. 

 

Data can be collected from Facebook, via Facebook Connect, to minimize the formalities (using the procedure you choose at registration). When you click on “Facebook Connect”, you agree to let Facebook share this data with us. 

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. 

 

  • Your identification data
    • The following data is collected whether the Member uses Facebook Connect or registers using a cell phone number:
      • your first name (public);
      • your age (public); Only your age, as deduced from your date of birth, will be visible to other HAPPN members. You can also hide your age by subscribing to an option;
      • your date of birth (private);
      • your gender (private);
      • your photographs (public); Via Facebook: At least, one of your public profile photos from Facebook. You then have the option of removing your photos and/or adding other photos to your Account from your Facebook account or smartphone. Via a cell phone number: you must add a photo. You then have the option of removing this photo and/or adding other photos to your Account, other photos from your smartphone.
    • The following data is collected depending on the type of registration:
      • via Facebook Connect: your last name (private);
      • via a cell phone number: your telephone number (private).

 

Depending on your type of registration, this information is mandatory for the supply of the Services. If you do not share it, HAPPN will not be able to supply the Services offered in the Application and you will not be able to create an Account.

 

Optional information 

 

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;

 

  • personal interests (public): personal preferences, leisure activities, musical preferences;

 

  • height (public);

 

  • email address or telephone number when this data is not mandatory for registration (private): You are not obliged to provide your email address when registering via a cell phone and you are not obliged to supply your telephone number or email address when registering via Facebook Connect. However, you may choose to share this information with HAPPN in order to facilitate communications with the latter;

 

  • 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.

 

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. Without this information, the report or your request cannot be handled. This type of information must also be processed when a report has been made against 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, last connection, interactions with Members and third-party accounts, number of transactions, etc.) 

 

When you access our Services and use the Application and its features, information on the way you use them is collected and processed. HAPPN is obliged to collect such information when you use the Services. Without this data HAPPN cannot supply the Services linked to the HAPPN application. 

More specifically, this includes your registration date, last connection, the type and number of interactions with other Members (such as Hellos, Likes, crossings, and Crushes), with the third-party accounts connected to your Account (such as Spotify, Instagram), or the number of transactions performed (purchasing Hellos or subscription(s)). 

 

  • Crossing points with other Members (public)

 

The Application’s main value and purpose is to allow Members to find other Members they have crossed paths with to facilitate virtual and/or real-life meet ups. Your crossing points are only collected with your consent. 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 agreed to be geolocated. 

 

The crossing points let HAPPN show you profiles of Members you have crossed paths with and who meet your search criteria. These crossing points can be displayed as a news feed or as a Map (Mapping).

 

You are free to withdraw your consent at any time and disable the geolocation option 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.

 

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”.

 

  • Geographical position (private)

 

HAPPN can, if you expressly agree, access your position, approximately or more precisely depending on the technology you use. After you have given consent, you are free to withdraw your consent at any time and disable your smartphone’s geolocation option. 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. The exact position or the itinerary of a Member is never available to other Members.

 

  • 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. 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. 

 

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

 

The Application lets you set search preferences by age and gender. You can change these settings in the Application and specify the age range 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 (IP, mobile ID, application version, 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, mobile model, mobile ID, language used, operating system, application crashes, and advertisement ID. Data may be collected with cookies: 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. 

 

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.

 

  • Help and technical support to Members.

 

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

 

  • 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. Geolocation to suggest profiles you have crossed paths with

 

  • Geolocation to suggest Profiles of Members you have crossed 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. 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 with and who meet your search criteria. 

 

 

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

 

  • Sending marketing or advertisement messages or contents:

 

  • Send the HAPPN newsletter by email.

 

  • Distribute marketing contents and advertisements related to HAPPN offers and services on the application and by emails.

 

  • 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 in order to find profiles similar to yours and who could be interested by our Services. To find similar profiles, we use and transmit with an encrypted code to websites, applications and social networks your first and last names, email address, telephone number, postcode, country and mobile advertisement ID. The existence of your profile will never be disclosed to these similar profiles. These similar profiles (non-Members) will see HAPPN advertisements on websites, social networks and third-party applications. 

 

Legal basis: Legitimate interest

This processing is based on the legitimate interest of HAPPN to share its offers and to provide information on its service to third-party websites. 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. You may also object to sharing data with third-party websites, social networks and third-party applications, by contacting us (see section 11. Contact).

 

  • Disseminating on the HAPPN application advertisements, on the products and services of partners and the products and services of HAPPN. These advertisements are targeted based on your age, gender and location (non-specific, only by the city concerned).

 

Legal basis: Execution of the contract

This processing is required for the performance of the contract between HAPPN and the Member since the dissemination of these advertisements constitutes the counterpart of using the application.

 

 

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.

 

Compatible subsequent use

This processing for statistical purposes is compatible with the following purposes; the provision of services and features; the provision of relevant offers and content; data security and combating illegal activities.

 

 

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) 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:

 

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

 

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. 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.

 

5. Cookies 

 

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

  • data hosting;
  • the detection and prevention of fraud and swindling;
  • studies, analyses and statistics;
  • the use of the Application and/or the proper functioning of the Application;
  • the provision of necessary assistance to Members;
  • management of reports;
  • marketing and advertising to address relevant offers, messages and content to HAPPN Members and HAPPN non-Members. 

As part of the marketing and advertising operations outside the application intended for non-Members, your data will be transmitted to third-party sites, social networks and third-party applications unless you object.

 

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 by 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. 

 

Companies to whom we transfer personal data located in the United States adhere to the EU-US Privacy Shield. This mechanism has been recognized by the European Commission as providing an adequate level of protection for personal data.

 

However, transfers of data outside the European Union may also 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 European Commission

 

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 [email protected], 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 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 Article 39 of the French Data Protection Act and 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 Article 40 of the French Data Protection Act and 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. 
  • 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. 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 limitation 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 40-1 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 Connect. Some data sent to HAPPN by Facebook Connect cannot be corrected without Facebook’s assistance.

 

9. How long will we keep your data?

 

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 one year. After one year 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. 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 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, in order to enable HAPPN to comply with its obligation to keep it as host.
  • The email address of the Member will be kept for commercial canvassing purposes for one year after a period of one year of inactivity of the Account. If the Member deletes his Account, the email address will not be used for commercial canvassing purposes.
  • Requests for the exercising of rights: for the time that allows HAPPN to prove that it has responded to requests in case of disputes or inspections: 1 year from the month following your request.
  • For cookies: see the Use of Cookies

 

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 [email protected].
  • By sending an email to the Data Protection Officer [email protected]
  • By sending a letter to the following address: for the attention of the Data Protection Officer, HAPPN - 8 rue du Sentier 75002 Paris – France.