Privacy Policy
Welcome to Happy Club United (hereinafter the “APP”). This policy applies to you and Happy Club
Discounts Ltd, irrespective of your country of residence or location.
This Policy describes our privacy practices in plain language, keeping legal and technical jargon to a
minimum to make sure you understand the information we collect, why we collect it, how it is used
and your choices regarding your information.
This Privacy Policy sits in line with Trinidad and Tobago`s Data Protection Act (DPA) and the
General Data Protection Regulation (GDPR).
The Data Controller
The person that is responsible for your information under this Privacy Policy (the “data controller”) is:
Happy Club Discounts Ltd
Lot 10 Emerald Lane Cunupia,
Trinidad and Tobago
E-Mail: info@happyclubunited.com
Web: www.happyclubunited.com
Overview of processing operations
The following overview summarises the types of data processed and the purposes of their processing
and refers to the data subjects.
Types of data processed
● Inventory data
● Content data
● Contact data
● Identity data
● Financial data
● Meta/communication data
● Usage data
Purposes of the processing
● Provision of the APP and user experience
● Contact requests and communication
● Security measures
● Provision of contractual services and customer services
● Administration and response to enquiries
Relevant legal basis
In the following, we inform you about the legal basis of the DPA and the GDPR on the basis of which
we process personal data. If more specific legal bases apply in individual cases, we will inform you of
these separately.
o Consent - The data subject has given his/her consent to the processing of personal data
relating to him/her for a specific purpose or purposes.
o Performance of a contract and pre-contractual enquiries - Processing is necessary for the
performance of a contract to which the data subject is a party or for the performance of
pre-contractual measures carried out at the data subject's request.
o Legitimate interests - Processing is necessary for the purposes of the legitimate interests
of the controller or a third party, unless such interests are overridden by the interests or
fundamental rights and freedoms of the data subject which require the protection of
personal data.
Security measures
We take appropriate technical and organisational measures in accordance with the law, taking into
account the state of the art, the costs of implementation and the nature, scope, circumstances and
purposes of the processing, as well as the different probabilities of occurrence and the level of threat
to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the
risk.
The measures include, in particular, ensuring the confidentiality, integrity and availability of data by
controlling physical and electronic access to the data as well as access to, input of, disclosure of,
assurance of availability of and segregation of the data. We also have procedures in place to ensure the
exercise of data subjects' rights, the deletion of data and responses to data compromise. Furthermore,
we already take the protection of personal data into account in the development or selection of
hardware, software and procedures in accordance with the principle of data protection, through
technology design and through data protection-friendly default settings.
However, you must understand that no Internet transmission is completely secure. Therefore, we can
never guarantee that unauthorised access, hacking, data loss and other incidents can be completely
excluded.
Your rights
The data protection laws in your country may give you the following rights:
● Right to information: what personal data a company processes and why (this policy).
● Right of access: You can request information about data collected.
● Right to rectification: If data collected is not correct, you can ask for it to be corrected.
● Right to erasure: Under certain circumstances, you can request the erasure of your data.
● Right to restriction of processing: In certain circumstances, you can request the further
processing of your data, but the data will remain stored.
● Right to data portability: You can have the data collected about you transferred to another
provider in a machine-readable format.
● Right to object: In certain circumstances (including where your data is processed on the basis
of legitimate interests or for marketing purposes) you may object to processing.
● Rights in relation to automated case-by-case decisions, including profiling: This includes
several rights where data is processed solely by automated means, and this has a legal or
significant impact on an individual. In these circumstances, you have, among other things, the
right to human intervention in the decision-making process.
If you wish to exercise any of the rights listed above, you can contact us by email at
info@happyclubunited.com. For your protection and the protection of all our users, we may need to
request certain information from you to help us confirm your identity before we can respond to the
above requests.
If you feel that we have not resolved your concern, you have the right to make a complaint at any
time. You can also contact your local data protection supervisory authority. We would, however,
appreciate the chance to deal with your concerns before you approach any supervisory authority.
Do you have to provide personal data?
The term ‘personal data’ as used in this section refers to (i) an individual’s name, picture,
geographical location, gender, marital status, age, date of birth, country and phone number (ii) credit
or debit card information, average spending (iii) internet protocol (IP) address (iv) biometric
characteristics. The provision of personal data is neither legally nor contractually required, nor is it
necessary for the conclusion of a contract. You are also not obliged to provide the personal data.
However, failure to provide the data could result in you not being able to use our APP or not being
able to use it to its full extent. The legal basis for this data processing is consent.
Installation of our APP
The App can be downloaded and installed from the "Google Playstore" and "Apple App Store".
Downloading the App may require prior registration with the respective App store and/or installation
of the respective App store software.
As far as we are aware, Google collects and processes the following data: License check, network
access, network connection, WLAN connections, and location information. And Apple collects and
processes the following data: device identifiers, IP addresses, and location information.
It cannot be ruled out that Google and Apple also transmit the information collected to a server in a
third country. We cannot influence which personal data Google and Apple processes with your
registration and the provision of downloads in the respective App store and App store software. The
responsible parties in this respect are solely Google and Apple.
Google and Apple may collect information from and about the device(s) you use to access our APP,
including hardware and software information such as IP address, device ID and type, device-specific
and app settings and properties, APP crashes, advertising IDs information about your wireless and
mobile network connection such as your service provider and signal strength; information about
device sensors such as accelerometer, gyroscope, and compass.
Firebase
We use the Google Firebase developer platform and related features and services provided by Google
Inc. Google Firebase is a platform for developers of apps for mobile devices. The Google Firebase
developer platform offers a variety of features. A list of these features can be found at:
https://firebase.google.com/terms/. Firebase's key security and privacy information can be found
here: https://firebase.google.com/support/privacy
Push Notifications
This Mobile Application includes push notifications as a method of electronic mobile communication.
By agreeing to this Policy, you consent to receive push notifications from the application. The
notifications may be delivered to your device even when the App is running in the background. You
have the ability, and it is your responsibility, to control the notifications you do, or do not, receive
through your device.You can opt out of receiving push notifications through your device settings. It is
your responsibility to keep your personal information secure when using this feature.
Cookies and Web Beacons
We may use cookies, web beacons, tracking pixels, and other tracking technologies on the Application
to help customize the Application and improve your experience. When you access the Application,
your personal information is not collected through the use of tracking technology. Most browsers are
set to accept cookies by default. You can remove or reject cookies, but be aware that such action could
affect the availability and functionality of the Application. You may not decline web beacons.
However, they can be rendered ineffective by declining all cookies or by modifying your web
browser’s settings to notify you each time a cookie is tendered, permitting you to accept or decline
cookies on an individual basis.
Authorisations and Access
We may request access or permission to certain functions from your mobile device. Those are:
● your geo-location for showing you the nearest venue,
● a user's device token to facilitate the One-time password (OTP) function, and
● Push notifications to keep subscribers updated about news and Happy Club in general.
The legal basis for data processing is our legitimate interest and the provision of contractual or
pre-contractual measures. You can change your permissions at any time via the Settings Menu of your
device.
Contacting Us
If you contact us and send us general enquiries the contact details you provide, will be stored, and
used by us to fulfil the purpose associated with the transmission, e.g., to process your enquiry or in the
event of follow-up questions.
The basis for this storage and use of your personal data is your consent which you give us by sending
us a message. Insofar as you provide us with your personal data for the purpose of responding to your
questions, the entry of personal data is required as without this information, we cannot process your
request.
You have the right to revoke your consent to the data processing described above at any time with
effect for the future. In this case, we will no longer process your data. Your personal data will be
deleted even without your revocation in any case if we have processed your request or if the storage is
inadmissible for other legal reasons.
Creating an account and a profile
A user profile will be created for you based on the information you provide during the sign up (your
Email and Password). You have the option of adjusting, changing, or deleting the information in your
account and profile to edit within the app or by contacting us. The data processing carried out in this
context is necessary to provide our service on the basis of the requests made by you. We store the data
until you delete your account. Insofar as legal retention periods are to be observed, storage also takes
place beyond the time of deletion of a user account.
Purchases and Payment Details
When you subscribe through the APP’s web portal, we may collect the following data from you to
process the desired order:
● Email address and Password
● Invoice records including; payment confirmation from the payment data collected by our
payment processor depending on the payment method
● Billing address
● Payment Method
● Cardholder or account holder name
● Payment amount
● Payment date
How we share information
We may share some user information with service providers and partners who help us operate the
Services, and in some cases with legal authorities.
We use third parties to help us operate and improve our services. These third parties assist us with
various tasks, including data hosting and maintenance, customer support, marketing, and security
measures.
We follow a rigorous vetting process before engaging a service provider or working with a partner. All
our service providers and partners should commit to strict confidentiality.
We may transfer your information if:
● we are involved in whole or in part in a merger, sale, acquisition, divestiture, restructuring,
reorganisation, dissolution, bankruptcy or other change of ownership or control.
● reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or
search warrant, government/legal investigation, or other legal requirement; (ii) to assist in the
prevention or detection of crime (in each case, subject to applicable law); or (iii) to protect the
safety of any person.
● disclosure would reduce our liability in actual or threatened litigation; (ii) if necessary to
protect our legal rights and the legal rights of our users, business partners or other interested
parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other
action regarding illegal activities, suspected fraud or other misconduct.
We may ask for your consent to share your information with third parties. In any such case, we will
make clear why we want to share the information.
We may use and share non-personal information such as device information, general demographic
information, general behavioural information, and personal information in hashed, non-human
readable form in the above circumstances.
Uninstall
You can stop the collection of information by the APP by uninstalling it using the standard uninstall
procedure for your device.
Storage and retention
Unless a more specific retention period is stated within this privacy policy, we will retain your
personal data on our server until the purpose for processing it no longer applies. If you assert a
legitimate request for deletion or revoke your consent to data processing, your data will be deleted
unless we have other legally permissible reasons for storing your personal data (e.g., retention periods
under tax or commercial law); in the latter case, the data will be deleted once these reasons no longer
apply.
Data Breaches/Notification
Databases or data sets that include Personal Data may be breached inadvertently or through wrongful
intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose
Personal Data may have been compromised, and the notice will be accompanied by a description of
action being taken to reconcile any damage as a result of the data breach. Notices will be provided as
expeditiously as possible after which the breach was discovered.
Updating your information
If you believe that the information, we hold about you is inaccurate or that we are no longer entitled to
use it and want to request its rectification, deletion, or object to its processing, please do so in your
account or contact us. For your protection and the protection of all of our users, we may ask you to
provide proof of identity before we can answer the above requests.
Exercising your rights
If you wish to access your personal data or exercise any of the rights listed above, you should apply in
writing, providing evidence of your identity. Any communication from us in relation to your rights as
detailed above will be provided free of charge. However, in case of requests that are manifestly
unfounded or excessive, in particular because of their repetitive character, we may charge a reasonable
fee taking into account the administrative costs of providing the information or communication or
taking the action requested; or refuse to act on the request.
Insofar as you have given us consent to process personal data for specific purposes, the lawfulness of
this processing is given on the basis of your consent. Consent given can be revoked at any time.
Automated individual decision-making including profiling
We do not make automated decisions in individual cases, including profiling.
Accuracy
It is important that the data we hold about you is accurate and current, therefore please keep us
informed of any changes to your personal data.
Changes, Queries and Complaints
This policy and our commitment to protecting the privacy of your personal data can result in changes
to this policy. Please regularly review this policy to keep up to date. Any comments or queries on this
policy should be directed to us. If you believe that we have not complied with this policy or acted
otherwise than in accordance with data protection law, then you should notify us. Furthermore, you
will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted
the changes in any revised Privacy Policy by your continued use of the Application after the date such
revised Privacy Policy is posted.
