Privacy Policy

Last Updated: 2024-03-09

Who are we?

Happyfication, Inc. (“Happyfication,” “we,” “us,” and/or “our”) is a company that blends data science with media trading. Happyfication does NOT collect personal data, including sensitive personal data, which can be used to identify you or a specific individual (“Personal Data”).

We build data intelligence respectfully by collecting anonymous behaviors and data, and we believe in giving you a choice when it comes to the collection of this anonymous data (“Non-Personal Data”).

If you do not want us to collect your Non-Personal Data, please opt-out here:

What is the purpose of this privacy policy?

This privacy policy ("Privacy Policy") describes how Happyfication collects and uses anonymous data collected in connection with the services we provide to partners, including advertisers, suppliers of advertising inventory, and publishers, as well as end users of our websites and applications (collectively, the “Services”).

Your privacy is very important to us, and we are committed to protecting it. We abide by applicable laws and regulations. We believe that there are effective ways to increase the relevance of advertising messages by using Non-Personal Data.

If you are located in the European Union, Switzerland, or other regions with laws governing Personal Data collection and use that may differ from U.S. data privacy laws, please note that Happyfication complies with the Data Privacy Framework. Please see the What if I have a complaint? section below for more information about our certification to and compliance with the Data Privacy Framework. 

What data do we collect?

Non-Personally Identifiable Information Collected Independently from the Use of Our Services.

We may collect and use Non-Personal Data, which includes de-identified location and other mobile and online usage information (i.e., statistical IDs and/or cookies), from our clients and partners in order to create de-identified profiles which we aggregate into audience segments. This information does not enable us to personally identify you. Non-Personal Data collected directly from our clients and partners is subject to their respective privacy policies and terms of services, not this Privacy Policy.

Non-Personally Identifiable Information Collected When Using Our Services

We may collect information about your device from third-party ad exchanges and/or publishers when delivering an advertisement to your device through a third-party service, site, or application. Any such information is received in accordance with the third-party application or website's privacy policy and subject to their terms and conditions. 

We may collect statistical IDs which use a probabilistic method of identifying a device based on a set of its attributes that have a reasonable likelihood of being unique in aggregate. For example, using a hash of the IP address, user-agent string, and screen resolution would provide a higher probability of uniquely identifying a device than using any of those attributes independently. 

We may also collect cookies, which are small pieces of data sent from a website and stored in a user's web browser, while the user is browsing that website. Every time you load our website, your browser sends the cookies back to the server to notify our website of your previous activity (e.g., pages visited or items clicked on). This data allows us to understand behaviors of an anonymous segment of people using devices. 

How do we use the data we collect?

We use the Non-Personal Data to predict where, when, and how to deliver the right advertising content to people. Happyfication will never use Non-Personal Data to identify you or anyone personally.

We store advertising identifiers collected via our services for a maximum of 180 days, and we store targeting data associated with those identifiers on a 90-day rolling basis.

Do we share the data we collect?

We may share Non-Personal Data with partners, clients, and vendors in order to provide our service to predict, where, when, and how to deliver the right advertising content to people. We require our clients, partners, and vendors to comply with our Privacy Policy, to limit their use of such information, and to protect the security and confidentiality of such information.

Please note that we may be required to disclose Non-Personal Data we collect to other third parties when we believe that the law requires it and/or if compelled to do so by law enforcement or government agencies, to meet national security requirements, to protect our rights, or by other legal action.

How do we secure the data we collect?

We take commercially reasonable efforts to maintain security protections to protect data we collect from loss, alteration, destruction, misuse and unauthorized access or disclosure. Please note, however, no data transmission over the Internet can be guaranteed to be completely secure. Accordingly, we cannot ensure or warrant the security of any information that you transmit or provide to us, so you do so at your own risk.

We have policies to help maintain control and physical security of the facilities used to store Non-Personal Data and restrict access to such data to those employees, contractors, and agents that have a need to know the information in order to provide and support our Services.

What if I have a complaint?

Happyfication only processes Non-Personal Data, but in the event we process your Personal Data for any reason and you reside in the European Union or Switzerland, we comply with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”) and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) as set forth by the U.S. Department of Commerce. Happyfication has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. DPF Principles with regard to the processing of Personal Data received from the European Union in reliance on the EU-U.S. DPF and to the Swiss-U.S. DPF Principles with regard to the processing of Personal Data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Privacy Policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

With respect to personal data received or transferred pursuant to the Data Privacy Framework, Happyfication is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

Pursuant to the Data Privacy Framework, EU and Swiss individuals have the right to obtain our confirmation of whether we maintain Personal Data relating to you in the United States. Upon request, we will provide you with access to the Personal Data that we hold about you. You may also correct, amend, or delete the Personal Data we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate Personal Data transferred to the United States under the Data Privacy Framework, should direct their query to privacy@happyfication.com. If requested to remove Personal Data, we will respond within a reasonable timeframe.

In certain situations, we may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Happyfication’s accountability for Personal Data that it receives in the United States under the Data Privacy Framework and subsequently transfers to a third party is described in the Data Privacy Framework Principles. In particular, Happyfication remains responsible and liable under the Data Privacy Framework Principles if third-party agents that it engages to process Personal Data on its behalf do so in a manner inconsistent with the Data Privacy Framework Principles, unless Happyfication demonstrates that it is not responsible for the event giving rise to the damage.

In compliance with EU-U.S. DPF Swiss-U.S. DPF, Happyfication commits to resolve complaints about our collection or use of your Personal Data transferred to the U.S. pursuant to the EU-U.S. DPF and the Swiss-U.S. DPF. EU and Swiss individuals with inquiries or complaints should first contact Happyfication. Please see the How can you contact us? section below for our contact details.

Happyfication has further committed to refer unresolved DPF Principles-related complaints to a U.S.-based independent dispute resolution mechanism, BBB NATIONAL PROGRAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.bbbprograms.org/dpf-complaints for more information and to file a complaint. This service is provided free of charge to you.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. Please visit https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf for more details. 

What happens when changes are made to this Privacy Policy?

Happyfication may amend this Privacy Policy from time to time. Please refer back to this Privacy Policy periodically to review any updates. If we make material changes to this Privacy Policy, we will notify you by posting an announcement on this site. The revised version of the Privacy Policy will be effective immediately (as indicated by the “Last Updated” date above) but will not apply retroactively.

How can you contact us?

If you have any questions related to the collection of Personal Data and/or Non-Personal Data or this Privacy Policy, please contact us via email at legal@happyfication.com or via mail to:

Happyfication, Inc.
Attn: Legal Department
68 Harrison Avenue #605
PMB 14953
Boston, Massachusetts 02111