Privacy Policy

Last updated May 13, 2019

Thank you for choosing to be part of our community at Happy Watch 99 ("Company", "we", "us", or "our"). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at support@happywatch99.com.

When you visit our website www.happywatch99.com, mobile application, and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy notice, we describe our privacy policy. We seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it We hope you take some time to read through it carefully, as itis important If there are any terms in this privacy policy that you do not agree with, please discontinue use of our Sites or Apps and our services.

This privacy policy applies to all information collected through our website (such as www.happywatch99.com), mobile application, ("Apps"), and/or any related services, sales, marketing or events (we refer to them collectively in this privacy policy as the "Sites").

Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.

TABLE OF CONTENTS

1. HOW DO WE COLLECT YOUR PERSONAL DATA?

2. WHAT PERSONAL DATA DO WE COLLECT FROM YOU?

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

4. WHO WILL YOUR INFORMATION BE SHARED WITH?

5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

6. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

7. HOW LONG DO WE KEEP YOUR INFORMATION?

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

9. DO WE COLLECT INFORMATION FROM MINORS?

10. WHAT ARE YOUR PRIVACY RIGHTS?

11. CONTROLS FOR DO-NOT-TRACK FEATURES

12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

13. DO WE MAKE UPDATES TO THIS POLICY?

14. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

1. HOW DO WE COLLECT YOUR PERSONAL DATA?

We collect your personal data in the following ways:

1. When you sign up for the Happy Watch 99 Service - when you sign up to the Happy Watch 99 Service, we collect certain personal data so you can use the Happy Watch 99 Service such as your email address, birth date, gender, and country.

2. Through your use of the Happy Watch 99 Service - when you use the Happy Watch 99 Service, we collect personal data about your use of the Happy Watch 99 Service, such as what songs you have played and what playlists you have created.

3. Personal data collected that enables us to provide you with additional features/functionality - from time to time, you also may provide us with additional personal data or give us your permission to collect additional personal data e.g. to provide you with more features or functionality. As described further below (see Voluntary Music Data), we will not collect photos, precise mobile device location, voice data, or contacts from your device without your prior consent. You always will have the option to change your mind and withdraw your consent at any time.

4. From third parties - we will receive personal data about you and your activity from third parties, including advertisers and partners we work with in order to provide you with the Happy Watch 99 Service (please see ‘Sharing your personal data’ Section 7 below). We will use this personal data either where you have provided your consent to the third party or to Happy Watch 99 to that data sharing taking place or where Happy Watch 99 has a legitimate interest to use the personal data in order to provide you with the Happy Watch 99 Service.

We use anonymized and aggregated information for purposes that include testing our IT systems, research, data analysis, creating marketing and promotion models, improving the Happy Watch 99 Service, and developing new features and functionality within the Happy Watch 99 Service.

2. WHAT PERSONAL DATA DO WE COLLECT FROM YOU?

We have set out in the tables below the categories of personal data we collect and use about you:

Personal data collected when you sign up for the Happy Watch 99 Service

Account Registration Data

This is the personal data that is provided by you or collected by us to enable you to sign up for and use the Happy Watch 99 Service. This includes your email address, birth date, gender, postal code, and country.

Some of the personal data we will ask you to provide is required in order to create your account. You also have the option to provide us with some additional personal data in order to make your account more personalized.

The exact personal data we will collect depends on the type of Happy Watch 99 Service plan you sign up for and whether or not you use a Third Party Service (as defined in the Terms and Conditions of Use, such as Facebook) to sign up and use the Happy Watch 99 Service. If you use a Third Party Service to create an account, we will receive personal data via that Third Party Service but only when you have consented to that Third Party Service sharing your personal data with us.

Personal data collected through your use of the Happy Watch 99 Service

Happy Watch 99 Service Usage Data

This is the personal data that is collected about you when you are using the Happy Watch 99 Service - this may include:

• Information about your type of Happy Watch 99 Service plan.

• Information about your interactions with the Happy Watch 99 Service which includes the date and time of any requests you make, content you have played, lists you create, video content you’ve watched, and your interactions with other Happy Watch 99 users. This also may include details of your use of Third Party Applications and advertising you receive.

• User Content (as defined in the Terms and Conditions of Use) you post to Happy Watch 99 including messages you send and/or receive via Happy Watch 99 and your interactions with the Happy Watch 99 Customer Service team.

Personal data collected with your permission that enables us to provide you with additional features/functionality

Voluntary Mobile Data

In addition to the mobile data we collect to provide you with the Happy Watch 99 Service (outlined above), you also have the option to give us your consent to collect additional personal data from your mobile device to provide you with features/functionality that will enhance your Happy Watch 99 Service experience.

We will not access any of the personal data listed below without first obtaining your consent:

• Your photos - If you give us permission to access your photos or camera, we will only access images that you specifically choose to share with us and metadata related to those images, such as the type of file and the size of the image. We will never scan or import your photo library or camera roll;

• Your precise mobile device location - If you give us permission to access your precise location, this enables us to access your GPS or Bluetooth to provide location-aware functionality in the Happy Watch 99 Service. Please note that this does not include your IP address. We use your IP address to determine non-precise location, for example, what country you are in to comply with our licensing agreements;

• Your voice data - If you give us permission, this enables us to access the voice commands captured via your device microphone to enable you to interact with the Happy Watch 99 Service with your voice. Please note you will always have the ability to turn off the microphone feature; and,

• Your contacts - If you give us permission to access your contacts, this enables us to access individual contacts stored on your device to help you find friends who use Happy Watch 99.

Payment Data

We may collect such personal data if you sign up for a Trial or purchase any of our Paid Subscriptions (as defined in the Terms and Conditions of Use) or make other purchases through the Happy Watch 99 Service. The exact personal data collected will vary depending on the payment method (e.g. direct via your mobile phone carrier or by invoice) but will include information such as:

• Name;

• Date of birth;

• Credit or debit card type, expiration date, and certain digits of your card number;

• Postal code;

• Mobile phone number; and

• Details of your transaction history.

If you choose to pay by invoice, we will provide your personal data to our payment processors to enable them to complete a credit check and to send you invoices.

Contests, Surveys and Sweepstakes Data

This personal data is used to allow you to sign up and participate in these types of promotions. The exact personal data collected will vary depending on the promotion. Marketing Data

This personal data is used to enable Happy Watch 99 and our partners / service providers to send you marketing communications either:

• Via email;

• Whilst using the Happy Watch 99 Service; and/or

• Direct from the third party.

You can find out more about the personal data collected and the controls you have in relation to the marketing communications you receive via the Privacy Center.

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short: We only share information with your consent. to comply with laws. to protect your rights. or to fulfill business

obligations.

We may process or share data based on the following basis:

Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.

Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.

Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract

Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Sites or Apps, which will enable them to collect data about how you interact with the Sites or Apps over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.

Business Transfers. We may share or transfer your information in connect on with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our bus ness to another company.

4. WHO WILL YOUR INFORMATION BE SHARED WITH?

In Short: We only share information with the following third parties.

We only share and disclose your information with the following third parties. We have categorized each party so that you may easily understand the purpose of our data collection and processing practices. If we have processed your data based on your consent and you wish to revoke your consent, please contact us.

Advertising, Direct Marketing, and Lead Generation Google AdSense

Allow Users to Connect to their Third-party Accounts and Facebook account

Invoice and Billing

Stripe

User Account Registration and Authentication Facebook login

5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our websites using a social media account, we may have access to certain information about you.

Our Sites or Apps offer you the ability to register and login using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, profile picture as well as other information you choose to make public.

We will use the information we receive only for the purposes that are described in this privacy policy or that are otherwise made clear to you on the Sites or Apps. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy policy to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.

6. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

In Short: We are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with. our websites. The Sites or Apps may contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the Sites or Apps. You should review the policies of such third parties and contact them directly to respond to your questions.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives). then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites or Apps is at your own risk. You should only access the services within a secure environment

9. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Sites or Apps, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Sites or Apps. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at support@happywatch99.com.

10. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You may review, change, or terminate your account at any time.

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

Log into your account settings and update your user account

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You Will then be removed from the marketing email list - however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may:

Access your account settings and update preferences.

11. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not Track (ONT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing ONT signals has been finalized. As such, we do not currently respond to ONT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes. if you are a resident of California. you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your requesting writing to us using the contact information provided below.

If you are under 18 years of age, res de in California, and have a registered account with the Sites or Apps, you have the right to request removal of unwanted data that you publicly post on the Sites or Apps. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Sites or Apps, but please be aware that the data may not be completely or comprehensively removed from our systems.

13. DO WE MAKE UPDATES TO THIS POLICY?

In Short: Yes. we will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

14. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may email us at

support@happywatch99.com.