Happee, Inc. — Privacy Policy

Last Updated: April 1, 2026

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use, and are responsible for certain personal information about you. When we do so, we are subject to applicable laws in the United States and, where applicable, the General Data Protection Regulation ("GDPR") which applies across the European Union and United Kingdom. We are responsible as "controller" of that personal information for the purposes of those laws.

Key Terms

Term	Meaning
We, us, our	Happee, Inc., a Delaware corporation
Data Protection Officer	privacy@happee.ai
Personal information	Any information relating to an identified or identifiable individual
Sensitive Personal Information	Personal information revealing social security numbers, driver's license or passport numbers, account credentials, precise geolocation, racial or ethnic origin, religious beliefs, union membership, health or sexual orientation data, contents of private communications, genetic data, biometric information, or citizenship/immigration status

Personal Information We Collect

We may collect and use the following personal information that identifies, relates to, describes, or could reasonably be linked with a particular individual or household:

Category	Types Collected
Identifiers	Names, email addresses, postal addresses, telephone numbers, account names, IP addresses, online identifiers
Financial information	Payment card information (processed by our payment processor), billing address, subscription tier
Commercial information	Products and services purchased, subscription history, usage patterns
Biometric information	None
Internet/electronic activity	Log-on information, feature usage, pages visited within the platform, data uploaded or downloaded
Geolocation data	Approximate location derived from IP address
Professional/employment information	Employer name, job title, work email address
Education information	None
Inferences	Usage preferences, feature adoption patterns, account configuration inferred from platform activity
Sensitive Personal Information	None collected in the ordinary course of business

This personal information is required to provide the Services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing Services to you.

How Your Personal Information is Collected

We collect most personal information directly from you — by email and via our platform. We may also collect information:

From publicly accessible sources (e.g., company directories);
From third parties with your consent (e.g., your connected accounts);
From cookies and similar technologies on our website and platform;
Via automated monitoring of our platform, including usage logs, error reports, and technical systems; and
From our payment processor when you complete a transaction.

How and Why We Use Your Personal Information

We use your personal information only when we have a lawful basis to do so. The table below explains what we use your personal information for and our reasons:

Purpose	Legal Basis
To provide the platform and Services to you	Performance of our contract with you
To process payments and manage your subscription	Performance of our contract with you
To provide customer support	Performance of our contract with you
To prevent and detect fraud and unauthorized access	Legitimate interest (protecting you and us)
To comply with legal and regulatory obligations	Legal obligation
To improve and develop the Services (using aggregated/de-identified data)	Legitimate interest
To ensure platform security and integrity	Legitimate interest
To send you transactional communications (receipts, alerts, service notices)	Performance of our contract with you
To send you marketing communications about our products and services	Legitimate interest (you may opt out at any time)
Statistical analysis to manage our business	Legitimate interest

We do not use your personal information to make solely automated decisions that produce legal effects or significantly affect you without human review.

Promotional Communications

We may use your personal information to send you updates about our products and services, including new features or offers. You have the right to opt out at any time by:

Using the "unsubscribe" link in any marketing email; or
Emailing us at privacy@happee.ai.

We will not use your personal information for direct marketing if you have opted out.

We routinely share personal information with:

Infrastructure and hosting providers — for cloud hosting and data storage;
Payment processors — to process subscription payments and SOW invoices;
AI inference providers — to power AI features within the platform (data is processed under data processing agreements);
Customer support tools — to manage support requests;
Analytics providers — using aggregated, de-identified data only;
Our employees, officers, and directors who have a need to know; and
Professional advisers — lawyers, auditors, and insurers, under confidentiality obligations.

We only allow service providers to handle your personal information if we are satisfied they take appropriate measures to protect it, and we require contractual obligations that restrict them to using it only to provide services to us.

We may disclose personal information to law enforcement or regulatory bodies where required by applicable law. We may also share personal information with potential buyers of our business during a restructuring or acquisition, subject to confidentiality obligations.

We do not sell personal information to third parties.

Where Your Personal Information is Held

Personal information is held on servers located in the United States. If you are located in the European Economic Area ("EEA") or United Kingdom, your personal information is transferred to the United States, which is outside the EEA. We ensure such transfers comply with applicable data protection law through appropriate safeguards.

How Long We Keep Your Personal Information

We keep your personal information while you have an active account with us or while we are providing Services to you. After that, we retain personal information only as long as necessary to:

Respond to questions, complaints, or claims;
Demonstrate that we treated you fairly; or
Comply with legal retention requirements.

When personal information is no longer needed, we delete or anonymize it. You may also request deletion as described below.

If you are in the EEA or UK, you have the following rights regarding your personal information:

Right	Description
Right to Access	Receive a copy of the personal information we hold about you
Right to Rectification	Require us to correct any mistakes in your personal information
Right to Erasure	Require us to delete your personal information in certain circumstances
Right to Restrict Processing	Require us to restrict processing of your personal information in certain circumstances
Right to Data Portability	Receive your personal information in a structured, machine-readable format
Right to Object	Object to processing based on legitimate interests or for direct marketing
Right Not to Be Subject to Automated Decisions	Not be subject to solely automated decisions with significant effects on you

To exercise any of these rights, contact us at privacy@happee.ai.

You also have the right to lodge a complaint with a supervisory authority in the EU/EEA member state where you work, live, or where an alleged infringement occurred.

Your Rights Under the CCPA (California Residents)

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA):

Right to Know. You have the right to know the categories of personal information we have collected, the sources, our purposes, and the third parties with whom we share it.

Right to Delete. You have the right to request deletion of your personal information, subject to certain exceptions (e.g., to complete a transaction, detect security incidents, comply with legal obligations).

Right to Opt Out of Sale. We do not sell personal information. No opt-out action is required.

Right to Non-Discrimination. We will not discriminate against you for exercising your privacy rights.

You may make a CCPA data access or portability request no more than twice in a 12-month period.

Keeping Your Personal Information Secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, used, or accessed in an unauthorized way. Access to personal information is limited to employees, contractors, and service providers with a genuine business need. We test our systems regularly and have procedures in place to deal with suspected data security breaches. We will notify you and any applicable regulator of a suspected breach where legally required to do so. See our [Security Policy] for details.

How to Exercise Your Rights

To exercise any privacy rights described in this policy, please contact us at:

Email: privacy@happee.ai

Mail: Happee, Inc., Attn: Privacy, 1343 Main Street, Suite 602, Sarasota, FL 34236

Please include enough information to identify you (e.g., full name, account email address) and a description of the right you want to exercise. We will verify your identity before processing your request.

Changes to This Privacy Policy

We may update this privacy policy from time to time. When we do, we will notify you via email or in-platform notice. The "Last Updated" date at the top of this policy reflects the most recent revision.

How to Contact Us

For questions about this privacy policy or the personal information we hold about you:

Email: privacy@happee.ai
Mail: Happee, Inc., 1343 Main Street, Suite 602, Sarasota, FL 34236

Happee, Inc. · privacy@happee.ai · Delaware, USA