Privacy policy

These Privacy Policy were published on 6 of July 2022.

This Privacy Policy describes the privacy practices for the Website hapify.us (hereinafter "Website", "Site") operated by IPL GROUP PTY LTD, registered address: Level 3 845 Pacific Highway, Chatswood NSW 2067, AUSTRALIA, reg. number 638 003 728 (hereinafter “we”, “us”, “our”, “Company”) and how the Website, operated by Company, collect and use the personal data you provide to the Company, with the purpose to use hapify.us It also describes the choices available to you regarding our use of your personal information and how you can access, update and delete this information.

The use of the Website is possible without any indication of personal data; however, if a user wants to use the hapify.us, collecting and processing of personal data could become necessary. If the processing of personal data is necessary, we generally obtain consent from the user as a data subject, except cases when personal data processing is available under other grounds (legitimate interests, contract executing, etc.).

The processing of personal data, such as the address, e-mail address or billing information, etc., of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to Company. By means of this Privacy Policy, we would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects (users) are informed, by means of this Privacy Policy, of the rights to which they are entitled.

This Privacy Policy is an integral part of the Terms of Use.

As the controller, Company has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this Website. In this Privacy Policy IPL GROUP PTY LTD (registered address: Level 3 845 Pacific Highway, Chatswood NSW 2067, AUSTRALIA, reg. number 638 003 728) as the Controller of personal data.

Sharing with our Academic Partners (if applicable)
We partner with academic institutions such as universities to further scientific understanding of how hapify.us can help relationships. To do this, we generate anonymised information (so you or anyone else can never be identified) from your use of the Services, and we share this information with our academic partners so they may analyse it and publish academic papers on how using hapify.us impacts relationships.

1. DEFINITIONS

Personal data – means any information relating to an identified or identifiable natural person (“data subject/user”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Controller – for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is the Company.

Processing – is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Data subject/user – is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing; a user of the hapify.us Services.

Pseudonymization – is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject/user without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

Encryption – is a security protection measure for personal data; as a form of cryptography, it is a process whereby personal data gets turned into an encoded and unintelligible version, using encryption algorithms and an encryption key, and whereby a decryption key or code enables users to decode it again

Consent of the data subject/user – is any freely given, specific, informed and unambiguous indication of the data subject/user`s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. PERSONAL DATA COLLECTION AND USE

Anyone can access our Website without necessity to provide its personal data. The purpose of processing your personal data by the Company and collection of information about you are as follows (the “Purpose”):

• Your intention to use hapify.us;
• For the performance of a contract to which the user is a party, in accordance with Article 6.1.b of the GDPR and the collected data are necessary in order for hapify.us to identify and bill the user and to charge its bank card number;
• For verifying your identity and providing customer care service and assistance;
• Analyze your use of our Website and hapify.us to better understand how they are being used so we can improve our Services and the user experience, and engage and retain users.

We may use your Personal data to: (a) improve your browsing experience by personalizing the Website and to improve the hapify.us; (b) send information to you by email regarding registration status, password verification, payment confirmation; (c) send you communications relating to your use of the hapify.us, and (d) provide our partners with statistical information about our users by secured channels under data processing agreements (DPA); (e) send you marketing and promotional materials and messages. As you are willing to use hapify.us you are required to provide your personal data (to register an account and purchase the hapify.us), thus becoming a user of hapify.us Please be aware that you are not obliged to provide us with your personal data. However, if you do not provide us with your email address and payment information, you may not be able to create an account to log into and make a purchase of hapify.us.

Data we may collect

• Identity Information: full name, email, password, unique user code we supply with to allow users to pair our Services; your device id to be able to identify a customer as one of our users (for registration and subscription purposes).

• Personal Information: cover photo, profile photo, username, couple anniversary date, and other relationship information in order to personalise the profile.

• Activity Information: responses to our quizes, games and conversations so that we may share these answers and your progress with the user and his/her partner.

• Demographic Information: age, gender, preferences, interests, lifestyle information, sex life and sexual orientation to create personalized plan and for marketing purposes.

• Usage Information: responses to surveys so that we may improve the services we offer; information about the time user spends and the activities engages in order to better understand needs and preferences and improve the user journey and experience; IP address in order to know general location so that we can manage the security of our platforms; device ID and email address so that we may communicate via email, push notifications about the activities. Additionally, we collect and store certain information via the use of technologies such as device identifiers, pixels and cookies (Cookie Policy)

• Banking/Payment information: transactional and financial information such as payment card and other payment information.

• Geolocation information.

3. LAWFUL BASES FOR THE USE OF YOUR PERSONAL DATA

The storage of this data takes place against the background that this is the only way to prevent the misuse of hapify.us, and, if necessary, to make it possible to investigate committed offenses.

The personal data are not transferred to third parties, except events, when it’s necessary with an aim to provide hapify.us and/or there is a lawful obligation to transfer these data under request of government authorities and/or the transferring is executed in respect of criminal proceedings.

We do not authorize the use of your personal data by any third party (only under exceptional conditions as described under "Legal Matters" below). We operate and maintain a variety of online security measures to safeguard and keep your personal information private and secured.

We will also communicate with you in response to your inquiries, regarding any information or services you request.

You may always opt-out (unsubscribe) from any communication in your account (except operational and/or non-marketing notification as following: payment acceptance, payment notification, necessary updates notification, refunds issue etc.).

All Personal Data is stored in encrypted way on hapify.us servers with using of the last encryption and protection technologies and standards.

If you use a computer in a public place or share a computer with others, remember to log out/sign out and close your browser window when you finish accessing hapify.us in order to prevent others from accessing your personal information. You are solely responsible for the control and use of each password you create.

Payment information
We implemented all necessary measures and standards in an area of payment security for hapify.us. We cooperate with different payment service providers and before our cooperation we check them according to our policies for the availability of licenses and other permits for the acquirer transactions. Within a payment execution you provide the following information to the payment service provider: (i) credit/debit card number; (ii) expiration date of credit/debit card; (iii) your full name; (iv) your e-mail. This information is collected and stored by the payment service provider and we don’t store and collect any bank cards data.

Data that we collect automatically.
We also collect and store information that is generated automatically as you navigate through our Website to enhance your experience on our Website by using tracking technologies such as Cookies, Log Files and Pixel tags.

As you navigate our Website information that we automatically collect is information in "log files" about your device’s connection to the Internet, length of time spent on the Website, and the pages accessed during each visit to the Website. We use this information to analyze trends, administer the Website, track user movement on the Website, and gather broad statistical information for aggregate use.

4. ENCRYPTED DATA

We have put in place security hardware, software and software update and network scanning procedures designed to safeguard and secure the information (including personal data) under our control and follow generally accepted industry standards. We work with third party service providers and vendors that use encryption and authentication to maintain the confidentiality of your personal data. If stored, we house personal information on systems behind firewalls that are only accessible to limited personnel, who are under DPA.

We store personal data of all our users in an encrypted way. We use asymmetric public-private key cryptosystem RSA with key size is 4096 bit (further RSA) and symmetric-key algorithm AES with key size is 256 bit (further AES).

Asymmetric public-private key cryptosystem RSA (key size is 4096 bit) use public encryption key and private decryption key. The public encryption key is storing in database (DB) in open way. The private decryption key is storing in DB encrypted using AES 256 using key which consist of the user’s password and secret key. It cannot be decrypted without user’s password and secret key.

User’s credentials are user’s login is stored in DB. User’s password is not stored. We store only hash of the password. We generate public-private key pair for cryptosystem RSA during user’s sign up. This public-private key pair is unique for each user. The key pair is stored in DB encrypted format using AES 256.

Login process: We use user’s password for decrypting user’s original private key.

Encryption data: We get opened data from devices using encrypted https protocol. We immediately start encryption process of the data on the server in the RAM without storing on server`s disks. We encrypted data using RSA using user’s public encryption key. The encrypted data is saved to our servers.

Decryption: We get user’s decrypted private key. We decrypt user’s text data using user`s original private decryption key. We show this information to user.

Decryption: We get user’s decrypted private key. We decrypt user’s text data using user`s original private decryption key. We show this information to user.

5. LEGAL MATTERS

We consider your use of hapify.us to be private. However, we may disclose your personal information stored in your account and/or on our servers and databases, in order to:

- comply with the law or legal process served on us;
- enforce and investigate potential violations of this Privacy Policy, Terms of use; including use of this Service to participate in, or facilitate activities that violate the law;
- investigate potential fraudulent activities;
- or protect the rights, property, or safety of our Company, its employees, its customers or the public.

In the event of a change of control of hapify.us (such as asset transfers through a merger, sale, assignment or liquidation of the business entity, or any of its properties, assets or equity) or, in the event of a direct or indirect sale of any of its publishing properties and/or its Website(s)in our possession will be transferred to the new owner/successor. You will be notified of any such transaction and have an ability to exercise your legal rights under GDPR. You may always change or delete your personal data or opt out by contacting us as provided below, or if the acquirer posts a new Privacy Policy with new contact information, you may change or delete your personal data or opt out by following any new instructions that are posted.

As a controller, we may also transfer to one or more processors (e.g. a payment provider under DPA) personal data of a data subject for (a) payment processing purpose, which is attributable to the controller and without which a user would not be able to purchase the hapify.us; (b) telecommunication purpose and without which a suers would not be able to use the hapify.us.

As we use third party technological services for the provision of Services, we may transfer your personal data internationally. Providers of such technological services may process personal data collected in the course of providing us their services as sub-processors only under DPA in accordance with GDPR.

In case there might be a risk of unauthorized disclosure of personal data the controller communicates the personal data breach to the data subject without undue delay. However, as the controller has implemented appropriate technical and organizational protection measures, as encryption, and it was applied to the personal data affected by the personal data breach, the controller is not required to communicate the data subject.

However, the encryption is useless if the access password or other credentials are weakly protected and stored by data subject. In this case the controller is not responsible for personal data breach.

In the case of a personal data breach, we, as a controller, shall without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the competent supervisory authority.

6. WHERE DATA SUBJECT’S PERSONAL DATA ARE STORED

Usually, Personal data, which are provided by users are stored on the servers in Germany and Netherlands. Personal data, which are provided by users may be stored outside the EU. In some cases, these personal data and information may be stored in Canada. We adopted all necessary security measures for protection of your Personal Data according to the best practices of security, protection and confidentiality. If we transfer your Personal data to third party service providers, we will compel each third-party service provider to adopt necessary security measures for protection of your Personal Data according to our data protection agreement.

7. YOUR RIGHTS AS A DATA SUBJECT

Access.
You have right to request an explanation of the personal data we process about you. Also, you can request a copy of your personal data undergoing processing.

Data portability.
You have a right to receive the personal data concerning you, which you provided to us. You can make a request to transmit this data directly to another data controller in a structured, commonly used and machine-readable format. We will transmit your data directly to another controller in cases where it is technically feasible.

Restrict processing.
You have right to request us to temporarily or permanently stop processing all or some of your personal data.

Rectification.
You have right to request to rectify/correct any inaccurate data about you.

Erasure.
You have a right to be forgotten which means that we will delete all personal data that you have provided to us. Note, we may retain certain information as required by law and for legitimate business purposes permitted by law.

Object processing.
You can, at any time, object to the processing of your personal data on grounds relating to your particular situation. You have the right to object your personal data being processed for direct marketing purposes.

Right to lodge complaints.
You have the right to lodge complaints in relation to the data processing activities carried out by us to the competent data protection authorities.

Not to be subject to automated decision-making.
You have a right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.

Right of confirmation.
Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed.

Right to withdraw data protection consent.
Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.
If one of the aforementioned reasons applies, data subject may at any time contact us, as instructed at the end of this Privacy Policy. We shall promptly ensure that the request is complied with immediately.

8. CHILDREN’S PRIVACY

Provision of hapify.us generally not aimed at children. This Website is not intended for use by children under the age of 18.

The Company is acting in compliance with COPPA. We do not knowingly collect information from children and minors. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide information on our Website without their permission.

Our Website and Service is not directed to, nor do we knowingly collect personal data from children under the age of 13. If we obtain actual knowledge that we have collected personal data from a child, we will comply with industry guidelines and applicable laws and will promptly delete it, unless we are legally obligated to retain such data.

9. DATA STORAGE AND DATA REMOVAL

The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period and when we no longer need personal data, we routinely and securely delete or destroy it, as long as it is no longer necessary for the Purpose. As the data controller, we shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of hapify.us provision, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.

However, in case of conflict situations in progress we may store personal data for 180 days period or more if the processing is necessary for the establishment, exercise or defense of legal claims and for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject in case of an expired account or in case data subject requested to delete his personal data. Upon the expiry of this period or earlier, if a conflict situation is settled, all personal data gets deleted.

To opt out of further e-mail communications from us, just contact us as instructed at the end of this Privacy Policy. We may need up to 30 (thirty) calendar days to assure compliance with your request.

To change your personal data that you have provided to us, please contact us as instructed at the end of this Privacy Policy.

10. MISCELLANEOUS

We may modify this Privacy Policy at any time and post any changes to the Privacy Policy on the Website, so please review it frequently.

We indicate the date of the current version of this Privacy Policy, so you know when it was last updated.

Changes to this Privacy Policy may not affect your personal data we have previously collected from you or after such changes.

If you object to the changes, please contact us as provided below.

This Privacy Policy is governed by and construed with the laws of Australia.

The Australia courts shall have exclusive jurisdiction to settle any claim or dispute which might arise out of or in connection with this Privacy Policy.

If you have any questions or propositions, please, get in touch with us by the e-mail: [email protected]