We Are Happy Place Ltd, a company registered in England and Wales with company number 11417974 and its registered office at C/O YM&U Business Management Limited, 180 Great Portland Street, 4th Floor, London, England, W1W 5QZ and its affiliates (collectively referred to as WAHP, we or us) are committed to protecting your privacy.
For the purpose of the EU GDPR, the version of the General Data Protection Regulation as implemented by the United Kingdom (UK GDPR) and the Data Protection Act 2018 (Act), we act as a controller in relation to your personal data.
This Privacy Notice explains how we collect, use and share personal information in the course of our business activities.
If you have any concerns about the use of your personal information by us please email us at email@example.com or write to WAHP, 180 Great Portland Street, London, W1W 5QZ.
IMPORTANT INFORMATION ABOUT WAHP
The WAHP entity responsible for your personal information will be the entity that originally collects information from or about you. This will be explained at the point at which your personal information is first collected by that WAHP entity, for example where you or the business you work for engages us to provide a service or where we engage you to provide a service to us.
You might find external links to third party websites on our service. This Privacy Notice does not apply to your use of any third-party site. We are not responsible for the privacy policies and practices of other websites even if you accessed the third-party website using links from our service. We recommend that you check the policy of each website you visit and contact the owner or operator of such website if you have concerns or questions.
If you do not agree with this Privacy Notice, you must not use our service or submit information to us through or in connection with our service.
THE INFORMATION WE COLLECT
We may collect and process the following data about you:
- Information you give to us. You may give us information about you by signing up to use our app, by filling in forms on our service, by purchasing products from us, by signing up to our mailing list or otherwise asking us to correspond with you, or by corresponding with us by phone, message, email or otherwise.
- The information you give us may include your name, address, email address, password/passcode, bank or other payment details and phone number, and any other information you provide or which is collected on registration, through surveys and through competitions.
Information third parties provide to us. Third parties may send us information about you in certain circumstances, for example if you purchase a ticket for our festival and agree to being contacted by us, then our ticketing partner will provide your information to us to allow us to contact you.
- We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on our service.
If you visit or use our service, we may automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer or mobile phone to the Internet, your login information, browser type and version, CPU, system language, memory, wi-fi status, device motion parameters and carrier, time zone setting, browser plug-in types and versions, operating system and platform, user agent, identifier for advertisers, Android ID; Google advertiser ID, customer issued user ID and other similar unique identifiers;
- location data to determine your current location; some of our location-enabled services require your personal data for the feature to work;
engagement information relating to ad campaigns and end user actions, including clicks on ads, ad impressions viewed, audiences or segments to which an ad campaign is attributed, the type of ads and the webpage or application from which such ads were displayed, the webpages on our website visited, the URL from the referring website, downloads and installations of Applications, and other interactions, events and actions to measure (e.g. add to cart, in-app purchases made, clicks, engagement time etc.); and
- information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our service (including date and time); pages within our service you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
- Google Analytics or other software will be used in order to help us understand how our users interact with our service. The information gathered from this service is anonymous, but will ultimately help us shape a better user experience for our customers.
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data where it is necessary in order for us to perform our contract with you, or necessary for our legitimate interests (or those of a third party), and your interests, rights and freedoms do not override those interests, or where we need to in order to comply with a legal or regulatory obligation.
We will use your personal data in the following ways, on the legal bases that it is necessary for us to perform our contract with you and for our legitimate interests (or those of a third party), and that your interests, rights and freedoms do not override those interests:
- we will provide you with access to our service (including allowing you to create an account on our app) and the ability to register as a new service user, including allowing you to access all of the services we agree to provide to you;
dealing with your inquiries and requests;
- we will carry out any other obligations arising from the contract entered into between us and you, including providing you with customer support;
- we will administer and protect our business and our service including troubleshooting, data analysis and system testing;
providing and personalising our service;
- to take and process any payments, fees and charges;
carrying out market research campaigns;
- we may send you direct marketing communications in relation to similar products or services to those you have ordered where we think they may be of interest to you (provided that you have an absolute right to opt-out of any of these communications at any time, including at the time of providing us your personal data or at any time thereafter);
- we may send you emails as part of our mailing list or other direct marketing communications if you have provided your consent to us doing so (provided that you have an absolute right to opt-out of any of these communications at any time); and
- we will use your personal data to regularly update and rectify any personal data we hold in relation to you and to notify you of any changes to our service or any other services.
Generally we do not rely on consent as a legal basis for processing your personal data, provided that:
- if you sign up to our mailing list then you are providing consent to receive emails as part of our mailing list (which may include direct marketing); and
- we will obtain your consent before we send you any third party direct marketing communications via email or text message,
- and you have the right to withdraw any such consent at any time by contacting us.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. We also gather information and statistics for the purposes of monitoring usage and may provide such aggregate information to third parties. These statistics will not include information that can be used to identify you.
If you stop using our service or your permission to use our service is terminated, we may continue to use and disclose your personal information in accordance with this Privacy Notice and as permitted by law.
DISCLOSURE OF YOUR INFORMATION
We may share your personal information with any member of our company, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may share your information with selected external third parties, including third party consultants, contractors or other service providers who may access your personal information when providing services to us (including but not limited to IT support or hosting providers, marketing service providers, app developers, auditors, contractors, payment providers and other advisers).
We may disclose your personal data:
- if we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- if WAHP or substantially all of its assets are acquired by a third party, in which case personal data held by WAHP about its customers will be one of the transferred assets;
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our end user agreement or other agreements, or to protect the rights, property, or safety of WAHP, our customers or others.
WHERE WE STORE YOUR PERSONAL DATA
The data that we collect from you may be transferred to, and stored at, a destination outside the UK or the European Economic Area (EEA). It may also be processed by staff operating outside the UK or the EEA, who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your orders, the delivery of our service, the processing of your payment details and the provision of support services.
If you are a UK citizen based in the UK or an EU citizen based in the EEA, then whenever we transfer your personal data out of the UK or the EEA (other than from the UK to the EEA or vice versa), we will only transfer your personal data:
- to countries that have been deemed to provide an adequate level of protection for personal data;
- if an appropriate safeguard has been put in place; and/or
- if one of the exceptions under Article 49 of the GDPR applies.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In particular:
- we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know;
- all personal data is stored on secure servers; and
- payment transactions will be encrypted using SSL technology.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our service, and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our service, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
We adopt appropriate policies, rules and technical measures to protect the personal data that we have under our control (having regard to the type and amount of that data) from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction or accidental loss. All of our employees and data processors that have access to, and are associated with, the processing of your personal information are obliged to respect the confidentiality of our visitors’ information.
HOW LONG WE KEEP YOUR PERSONAL DATA
We will retain your personal data in line with our data retention policy. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing at any time by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at firstname.lastname@example.org.
You have various statutory rights in relation to your personal data. In particular, you have the right to:
- object to direct marketing communications at any time;
- request and obtain access to your personal data;
- rectification or erasure of your personal data in certain circumstances;
- object to or restrict the processing of your personal data in certain circumstances;
- have your personal data stored in a manner in which it is portable from the environment in which it is stored by us to another environment; and
- file a complaint with the Information Commissioner’s Office.
To contact us or to exercise any of these rights please email us at email@example.com or write to WAHP, 180 Great Portland Street, London, W1W 5QZ. We reserve the right to request that you provide evidence of your identification if you ask us to carry out any steps in relation to your personal data.
For further information from us on data protection and privacy or any requests concerning your personal information please email us at firstname.lastname@example.org or write to WAHP, 180 Great Portland Street, London, W1W 5QZ.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We use the following cookies:
Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
- Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
Cookie Name Purpose
This cookie is set by Facebook to display advertisements when either on Facebook or on a digital platform powered by Facebook advertising, after visiting the website.
The test_cookie is set by doubleclick.net and is used to determine if the user’s browser supports cookies.
This cookie is installed by Google Analytics.
The _ga cookie, installed by Google Analytics, calculates visitor, session and campaign data and also keeps track of site usage for the site’s analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognize unique visitors.
Provided by Google Tag Manager to experiment advertisement efficiency of websites using their services.