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1. Acceptance
   1. By directly or indirectly accessing or making use of the services offered or made available by Happy Trainers. (the “Vendor”), including without limitation the Happy Trainers as a service platform, and any website, application, or widget associated therewith (the “Services”), and/or by clicking the acceptance button, you signify, represent, and warrant that you are older than 18 years of age and that you have, and at all times shall have, the necessary power, capacity, and authority to enter into, abide by, comply with and perform your obligations under this privacy policy (this “Privacy Policy”).
   2. The Vendor is committed to protecting the personal information of identifiable individuals and legal entities, disclosed or provided to the Vendor on or through the Services (the “Personal Information”), and this Privacy Policy outlines how the Vendor collects, uses, and discloses such Personal Information.
   3. The Vendor reserves the right to, at its sole discretion, amend this Privacy Policy at any time and without notice, the most current version of which shall always be available at https://happytrainers.com/privacy. You acknowledge and agree that your continued use of the Services, following any amendment of this Privacy Policy, shall signify your assent to, and acceptance of, such amended terms and conditions.
   4. If you do not agree to any term or condition of this Privacy Policy, or any subsequently amended term or condition thereof, you cannot use the Services.
2. Collection and Use of Personal Information
   1. You expressly acknowledge, agree, and consent to the collection and use of your Personal Information as specified in this Privacy Policy. The legal bases for our processing of Personal Information are primarily that the processing is necessary for providing the Services and that the processing is carried out in our legitimate interests, which are further explained below. Without limiting the generality of the foregoing, the Vendor may on occasion, in specific circumstances, ask you to consent when the Vendor intends to collect or use your Personal Information.
   2. If you choose to register as a user of the Services, you will be asked to create a unique username and private password (collectively, the “ID”) which will be used to create and activate an account through which the Vendor can make the Services available to you (the “Account”). You expressly acknowledge and agree that certain information such as your name, address, telephone number, email address, billing information, financial information, and certain additional information may be required by the Vendor to make the Services available to you, or maybe disclosed by you on or through the Services.
   3. We take steps designed to ensure that only those employees who need access to your Personal Information to fulfill their employment duties will have access to it. You expressly acknowledge, agree, and consent to the Vendor collecting and using your Personal Information:

• To create and activate your Account;
• To respond to any request for customer service;
• To make the Services available to you and other users of the Services;
• As necessary to allow the Vendor to provide you with access to and use of the added services, features, and functionality of the Vendor’s partner organizations, as incorporated into and/or linked to the Services;
• To improve the quality of the Services, including without limitation, through polls, surveys, and other similar feedback gathering activities conducted by the Vendor or any third-party;
• To assess service levels, monitor traffic patterns, and gauge the popularity of different features, functionalities, and service options of, or related to, the Services;
• To create and manage your account, and to verify access rights to the Services;
• To the bill, or render invoices relating to, your Account, and to collect any debt owing to the Vendor, and to facilitate payments between you and other users of the Services as contemplated by the features and functionality of the Services;
• To communicate with you, including without limitation to provide you with notifications, content, marketing materials, commercial electronic messages, and information about your Account and/or the Services;
• To install software relating to the Services, on one or more of your electronic devices;
• To protect against fraud or error, and to respond to claims of any violation of the Vendor’s rights or those of any third-party;
• To protect the rights, property, or personal safety of yourself, the Vendor, the Vendor’s agents, the Vendor’s users, and the public;
• To enforce this Privacy Policy or any other agreement entered into between yourself and the Vendor;
• As required to comply with any applicable laws, or as authorized by any applicable laws;

And for other purposes set out in this Privacy Policy, and for any other purpose, the Vendor may disclose to you from time to time. You may at any point withdraw your consent to receive the communications. The Vendor provides an “opt-out” function within all email communications of this nature, and/or will cease communications of this nature if you inform the Vendor that you would like to “opt-out”. You however expressly acknowledge and agree that you may not “opt-out” of communications related to the Services, your Account, a bill, an invoice, or where such withdrawal of consent would frustrate the performance of a legal obligation (but the Vendor will attempt to minimize the aforementioned communications).

1. Disclosure of Personal Information
   • The Vendor will only disclose your Personal Information as set out in this Privacy Policy by your instructions, for the purposes set out in Section 2(c), and in any event, by applicable law. Without limiting the generality of the foregoing, you understand and agree that the purposes set out in Section 2(c) include the disclosure of your Personal Information to the Vendor’s partner organizations in connection with your use of the functionality of the Services. For example, if you utilize the meal planning functionality of the Services, your Personal Information may be shared with the Vendor’s partner organization that provides such meal planning service functionality.   You expressly acknowledge and agree that your Personal Information disclosed by the Vendor to others hereunder may be subject to the terms of another privacy policy other than this Privacy Policy and that the Vendor assumes no responsibility for the privacy policies or practices of any third party.
   • Your Personal Information may be stored and processed in any country where we have facilities or in which we engage third-party service providers. By using the Services, you consent to the transfer of information to countries outside your country of residence, which may have different data protection rules than in your country. While such information is outside of Canada, it is subject to the laws of the country in which it is held and may be subject to disclosure to the governments, courts or law enforcement, or regulatory agencies of such other country, under the laws of such country. However, our practices regarding your Personal Information will at all times continue to be governed by this Privacy Policy and, if applicable, we will comply with the General Data Protection Regulation (“GDPR”)requirements providing adequate protection for the transfer of Personal Information from the EU/EEA to the third country.
   • You expressly acknowledge, agree, and consent to the disclosure of your Personal Information as specified in this Privacy Policy. When we disclose your Personal Information to third parties, we take reasonable measures to ensure that the rules outlined in this Privacy Policy are complied with and these third parties provide sufficient guarantees to implement appropriate technical and organizational measures.
   • Without limiting the foregoing, you expressly acknowledge and agree that to bill your Account and fa payments between you and other users of the Services as contemplated by the features and functionality of the Services, in each case if applicable, the Vendor may disclose your Personal Information with its Payment Processing Services Provider (as defined in the Terms of Service), banks or other third parties to process payments.
2. Retention facilitate your Personal Information

Your Personal Information will be retained for as long as may be necessary or relevant for the identified purpose of collection, or as may be required or permitted by law, after which time the Vendor will no longer retain such information in a form capable of identifying an individual or legal entity.

1. Children’s Privacy

The Services are not directed to children under the age of 18, and we do not knowingly collect Personal Information from children under the age of 18 without obtaining parental consent. If you are under 18 years of age, then please do not use or access the Service at any time or in any manner. If we learn that Personal Information has been collected on the Services from persons under 18 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 18 years of age has provided Personal Information, then you may alert us as outlined in the “Contact the Vendor” section and request that we delete that child’s Personal Information from our systems.

1. Rights to Your Information

On written request and subject to proof of identity, you may access the Personal Information that we hold, used, or communicated and ask that any necessary corrections be made, where applicable, as authorized or required by law. However, to make sure that the Personal Information we maintain about you is accurate and up to date, please inform us immediately of any change in your Personal Information by mail or e-mail.

Under the GDPR, you may be entitled to additional rights, including (i) the right to withdraw consent to processing where consent is the basis of processing; (ii) the right to access your Personal Information and certain other supplementary information, under certain conditions; (iii) the right to object to unlawful data processing, under certain conditions; (iv) the right to the erasure of Personal Information about you, under certain conditions; (v) the right to demand that we restrict processing of your Personal Information, under certain conditions, if you believe we have exceeded the legitimate basis for processing, processing is no longer necessary, are processing, or believe your Personal Information is inaccurate; (vi) the right to data portability of Personal Information concerning you that you provided us in a structured, commonly used, and machine-readable format, under certain conditions; (vii) the right object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you, under certain conditions; (viii) the right to lodge a complaint with data protection authorities. If you want to learn more about your rights under the GDPR, you can visit the Privacy Canada website on Data Protection at https://privacycanada.net/gdpr-pipeda-guide/.

1. Location Information

You expressly acknowledge, agree and consent to the Vendor collecting Personal Information concerning your location, from your IP address and other sources, to match the Vendor’s products and services to areas of demand and for other business purposes of the Vendor.

1. Aggregated Data

You expressly acknowledge, agree and consent to the Vendor collecting, combining, manipulating, and using your Personal Information to create generalized, anonymous information, stripped of data capable of identifying an individual or legal entity (the “Aggregated Data”), and using, disclosing and commercializing such Aggregated Data as the Vendor deems fit. Your identity and Personal Information will be kept anonymous in the Aggregated Data.

1. Software Installation, Cookies, and Log Files

You expressly acknowledge, agree and consent to the Vendor installing software and cookies relating to the Services on one or more of your electronic devices and using tracking tools, pixel tags, cookies, and log files for purposes the Vendor deems fit, including without limitation, to track which page variants you have seen, to track if you have clicked on a page variant, to monitor traffic patterns, to gauge the popularity of service options and to gather information used to deliver relevant content and services to you.

1. Change of Ownership or Business Transition

You expressly acknowledge and agree that in the event of a change of ownership or other business transition, such as a merger, acquisition, or sale of the Vendor’s assets, your Personal Information may be transferred by applicable privacy laws.

1. Withdrawing Consent

You have the right to withdraw your consent relating to the collection, use, or disclosure of your Personal Information at any time, except where such withdrawal would frustrate the performance of a legal obligation.

1. Security
   • The Vendor will strive to prevent unauthorized access to your Personal Information and will periodically enhance its security aimed at ensuring that your Personal Information is kept safe from unauthorized access, use, and disclosure.
   • While the Vendor has technology and procedures to guard your Personal Information against unauthorized access, use, or disclosure, you expressly acknowledge and agree there is no guarantee that such technology or procedures can or will eliminate the risks of unauthorized access, use, disclosure, theft, loss or misuse.
   • The Vendor strongly recommends that you do not disclose your ID to anyone. If you forget your password, the Vendor will ask you for the username associated with your ID and will send an email containing your password to the email address associated with your ID.
   • Notwithstanding anything contained in this Privacy Policy, you expressly acknowledge and agree that ultimately, you control what Personal Information you provide while using the Services and that you are responsible for maintaining the secrecy of your Personal Information and ID.
   • You expressly acknowledge and agree that the Vendor is not responsible for, and does not control, the use by others of any information you provide to them. You should use caution in selecting the Personal Information you provide to others through the Services.
   • If we learn of a security systems breach, we will inform you and the authorities of the occurrence of the breach by applicable laws.
2. Governance
   • This Privacy Policy will be governed by the laws of the Province of Ontario and the laws of Canada applicable therein, excluding any conflict of rules that would apply to another body of law. You hereby agree to submit to the exclusive jurisdiction of the courts in Toronto, Ontario concerning any claim, proceeding or action relating to or otherwise arising out of this Privacy Policy or your access to or use of the Services, howsoever arising, provided always that the Vendor may seek and obtain injunctive relief (or an equivalent type of urgent legal relief) in any jurisdiction.
   • This Privacy Policy together with any other agreement entered into between yourself and the Vendor which specifically references this Privacy Policy constitutes and contains the entire agreement between you and the Vendor concerning its subject matter and supersedes any prior oral or written agreements.
3. Contact The Vendor

If you have any questions or comments about this Privacy Policy or your Personal Information, to make an access or correction request, to exercise any applicable rights, to make a complaint, or to obtain information about our policies and practices concerning any service providers outside Canada, our Privacy Officer (or Data Protection Officer) can be reached by email using the following contact info.

Anyone can access our Website without the necessity to register an account. Therefore, limited use of the Services is always possible without the provision of your perils (for example, browse the Website, check how Happy Trainers works, look through the list of trainers, read the Happy Trainers Blog, review the variety of services, etc.). However, whenever you access the Website, we collect log information and put cookies on your device, by which we track your activity on the Website. You can always opt-out of cookies except those, without which the Website cannot work.

When you are a registered User Happy Trainers may collect from you and process Cookie identifiers and those data you specifically provide us with upon registration, including first name, last name, email, phone number, Skype ID, or social network ID (if assigned through Facebook or Google+ or if accessing Google Calendar), time zone, interface language, IP address, and device type, as well, whereas in the case of Telegram subscription, your Telegram ID may also be processed by Happy Trainers.

Specifically, if you are a trainer, we may also collect and process, besides the aforementioned information, the other data provided by you, including zip-code, gender, year of birth, city of residence, and education experience.

Registered Users may additionally provide us with added profile pictures as well as chosen currency to perform activities underneath our Refund and Payment Policy.

You can find out more about the specific cases of data collection and the purposes of the processing of such data in a separate section of this Privacy Policy.

We may change this Privacy Policy from time to time, so please check this page to ensure that you’re happy with any changes. We will post those changes on this page and update the Privacy

Any questions regarding this Policy and our services should be sent to [email protected]

1. What Is Personal Data and the Processing of Personal Data?

Main Definitions

Personal data is any information relating to you and that alone or in combination with other pieces of information allow a person that collects and processes such information to identify you as an individual. Processing of the personal data means any operation with your person whether or not by automated means, as collection, recording, organization, structuring, storage, adaptation or the alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction. The data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing; means you as a user of Happy Trainers.

Consent of the data subject/user is any freely given, specific, informed, and unambiguous indication of the data subject/user's wishes by which he or she, by a statement or by clear affirmative action signifies agreement to the processing of personal data relating to him or her. Happy Trainers Lawful Bases for Processing Happy Trainers processes your data only when we have lawful bases.

1. Specifically, Happy Trainers processes your data:

• Processing is based on the consent you have given. As such our newsletters, collection, analysis, and publication of user feedback and reviews, analysis of videos, your participation in our events and webinars, and placement of different types of cookies, and posting of the sweepstakes winners is based on your consent;
• Processing is necessary to provide our services to you according to our Terms of Service which constitute a contract between you and us as regards to information services of Happy Trainers;
• Processing is necessary for our legitimate interests. Those legitimate interests are:

- Compliance with the Canadian financial and accounting legislation;

- The assessment of Happy Trainers business efficiency by analyzing website traffic and financial performance indicators;

- Promotion of Happy Trainers through social media networks, media outlets, and affiliates, such as bloggers or influencers;

- Performance of the contracts with enterprise clients and provision of reports on their employees’ performance.

- User session control and fraud prevention, ensuring the appropriate protection of personal data;

- Trainer verification and development of high-quality learning programs with trainers.

- Where necessary, compliance with applicable legislation (e.g., data subject request processing);

- In exceptional cases, to protect your vital interests or vital interests of another natural person, or for the performance of a task carried out in the public interest or the exercise of official authority vested in Canada.

In all cases, we will notify you about the applied legal basis for processing and other relevant details before we start processing your data on a specific legal basis unless we cannot do so by our obligations under any applicable legislation.

1. Data We Collect: Scope

Happy Trainers collects from you only the following information and only for the stated below purposes:

(1) Account for Clients

Happy Trainers collects and processes personal data submitted by you upon registration and further editing of settings in your Account. For registration purposes, you submit your login credential log username and passwords), first name, last name, and email. You may edit your Account with additional information at your sole discretion. Additional information may help you to get more from the Services, for instance, finding a necessary trainer. At the same time, you are not required to provide additional information, not specifically necessary for the registration, it is your choice.

(2) Account for Trainers

Happy Trainers collects and processes personal data submitted by you upon registration and further editing of your Profile. For registration purposes, you submit your login credentials (username and passwords), first name, last name, and email. You may edit your Profile with additional information at your sole discretion. Additional information may help you to get more from the

Services, for instance, finding clients. At the same time, you are not strictly required to provide additional information, not specifically necessary for the registration. Therefore, it is your choice whether to include additional data in your profile or not, such as zip code, country, language skills, education, and work experience. Some personal data, such as users’ names, and location that is listed in your user profiles or derived from IP Addresses may be publicly visible to other users on the Services or the web. We may implement a feature that permits you to choose what information is made public by changing your privacy setting in “Edit My Profile” within the Service.

1. Posting of Information

We process personal data freely submitted to you on Happy Trainers. This may be a survey you fill in on Happy Trainers or feedback you provide us with. Irrespective of whether you are a registered user or not, this shall also cover situations when you post an article(s) or comment(s) on the Happy Trainers, as specified in the Happy Trainers Privacy Policy. Happy Trainers may also process information provided by you (including content and messages) that you post on/through our Website, including personally identifiable information. By so doing, you acknowledge that any information you share through the Services will be available to Happy Trainers and other users of the Services (clients/trainers). You also acknowledge that parts of your content cannot be deleted from the Service as it may be connected to the Contents created by you and used by other users (clients/trainers). From our turn and unless you opt-out, we retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law. We reserve the right to terminate the accounts of visitors who use these services in a manner inconsistent with the Terms of Service.

1. Service Use, Cookies and, Other Similar Technologies

When you use our Services, we monitor and analyze web traffic and keep track of your behavior while using our Services. We may receive the information about your IP address, proxy server, operating system, web browser, or mobile carrier and location based on phone settings. Please, specifically refer to our Cookies Policy for further details as to our use of cookies and similar technologies.

1. Billing Information

Details of transactions you carry out through our Website (as ID, date, and time of transaction).

1. Enterprise

When you wish to share your contact details for more information regarding Happy Trainers Enterprise one-on-one online fitness training for international teams, as name, email, company name, and phone number.

1. Sensitive Data

Unless you expressly agree, Happy Trainers does not process your sensitive data.

1. Pages on Social Networks

We maintain Happy Trainer’s official pages on social networks, such as Facebook or Instagram. When you make interactions with our social network pages, such as subscribe to the pages, leave comments or preferences (e.g., ‘like’ our posts), we can analyze these data for measuring our efficiency and can analyze social media marketing in our legitimate interests.

1. Information Required for Submitting Tax Documentation

To comply with the applicable tax and accounting legislation, we may be required to submit various tax documentation containing your data. For example, required tax form (s) necessary to receive a sweepstakes prize or withhold taxes.

For submitting tax documentation, we may process your data including but not limited to your full name, country of citizenship, permanent residence address, mailing address, date of birth, Canadian taxpayer identification number, or foreign tax identifying number.

1. Data We Collect: Purposes

We may process the personal data you provided us voluntarily for the purposes defined below.

From our perspective, we process your personal personalize the use of Happy Trainers to the fullest extent possible and to provide you with high-quality Services under the Terms of Service.

(1) Provision of Services

Primarily, we process your data to authorize access to our Services and to fulfill our obligations under the Terms of Service for Services provision. Specifically, we use your data upon registration to help others (be it a trainer or a client) find your account or profile, schedule, and track your learning progress.

For you to use the Services, you will need to provide payment (e.g. credit card details) and billing information through our partners – third-party payment providers, which process your data opted and securely. Please see our Refund and Payment Policy for more information.

For enterprise customers, we process the personal data of their employees to create their accounts and connect with the most suitable tutors for further learning. Based on the data about lessons taken by clients, we provide the enterprise customer with statistical reports on their employees’ performance.

Please note that without your information under our Terms of Service, we will be unable to provide you with the functionality of our platform, connect you with other users, and allow you to communicate with them.

(2) Payment Services

All payment information is stored encrypted and securely by Stripe service. We do not store your payment information on our servers.

 (4) Communications

We may contact you via email and other ways, including through publicly available notices, for Services-related purposes (welcome letter, security, and legal notices, announcements, Happy Trainers updates, reminders, suggestions, etc.). We may also use your data to enable you to communicate with other users through Happy Trainers, including exchanging messages, conducting video calls, and/or leaving feedback about other users. Your contact data (including email, phone number, Skype name, etc.) may also be used for gathering feedback. We may contact you to participate in research to improve the user experience of our product. The research will be used for internal purposes only, including:

-Feature development and product updates;

-Marketing activities, including publishing them on Happy Trainers on other information resources;

-Customer Support updates;

-Other service updates for improving your experience.

Your feedback will not be video recorded, audio recorded, or webcast by the Interviewer without obtaining consent from you first. The same applies to your voice and/or image recording. Having received the communications from us, you are always able to opt-out of such communications in each message, excluding legal notices, or changes of user settings on Happy Trainers.

(5) Marketing and Promotion of Happy Trainers

We may process your first name, last name, and email on our mailing list or for the newsletter and send you messages with some commercial or promotional information about our Services. But don’t worry, we will request your consent first, and you may always opt-out marketing messages, using the mechanisms described under the respective link in each message, and through the user settings available on Happy Trainers.

To promote the Happy Trainers platform through blog and influencer channels, we allow individuals to participate in the affiliate program on our Website. When we receive the information to participate in the affiliate program, we process this information to register you as an affiliate and further track the progress of the promotion of our platform. Also, please pay attention that we may use the information provided by you as feedback. The latter, under the Terms of Service, may be used by Happy Trainers without any additional compensation to you.

(6) Analytics and Development or to find the points of interest in our Services and for the purpose, we monitor and analyze web traffic and keep track of your behavior within our Services. This enables us to provide services that are relevant to you and boost the quality of our Services. The data concerned within this activity are Cookies and Usage data, such as the parts of our Services you visit, the date and duration of your visit, and type of the device you used during your visit. All your data stated in this paragraph is collected and further processed in a manner that does not allow your identification. For these purposes, we use Google Analytics for Firebase, Hotjar Heat Maps & Recordings, Amplitude Analytics, Branch.io, Braze, and Intercom, the use of which ensures compliance with our privacy commitments. We may also carry out polls and surveys through Happy Trainers using external GDPR-compliant services. You are not obliged to respond to them and you may opt-out of such polls and surveys through user settings. To inform, optimize and serve you relevant advertising based on your past use of our Services, we may process your Usage Data and Cookies. Please, follow our Cookies Policy for additional information.

(7) Trainer Verification and Program Preparation

To ensure a high quality of sessions provided by trainers on Happy Trainers, we collect and process trainer credentials to verify their eligibility to train subjects claimed by them. Besides that, we cooperate with the trainers and use their information to help them develop the training programs.

 (8) Support and Platform Supervision

In case of any disputes on Happy Trainers and other Services-connected issues, we may use data (including communications) to resolve such matters, supervise user behavior on the platform, and respond to any complaints or requests.

(9) Events Conducted by Happy Trainers

We use the personal data we collect from you when you register and/or attend any of our events or webinars to provide you with access to such events, as well as to send you registration confirmation, reminders, associated useful materials, or the information you have requested about our Services.

(10) Compliance with Legal Requirements

We process certain payment information to comply with applicable legal requirements in the field of finances and/or accounting. We also may process the data collected on the platform in connection with legal requests we receive from you or any other competent person and/or body, and we may use this information to exercise, defend and/or establish our legal rights.

(11) Fraud Prevention

Certain information, such as your log information, payment information, and your behavior on the platform are subject to our supervision to prevent fraudulent activities on the platform and assist you in managing your user sessions.

(12) Changes

If Happy Trainers decides to change the purposes of processing specified above, we will inform you about such changes before the use of your data within the newly set purposes. The notification of such changes will be sent to your email and you will have to provide your consent for the amended purposes unless the additional purpose of processing is compatible with those listed above. In case you do not want to provide us with the requested personal data for the purposes specified above, you may not have access to certain functions of the Services.

1. How Is Personal Data Shared?

To provide high-quality services, Happy Trainers hires people, enters into agreements with independent contractors as well as cooperates with other services providers, companies, and organizations strictly under data processing agreement (DPA). For those reasons, some of your data are passed to the persons mentioned. Happy Trainers uses only secure places of storage, and other services and applications listed below.

We use social media platforms to maintain our public pages and communities, who are, in this case, joint controllers with Happy Trainers. These well-known service providers will help us to ensure that your data is secure within Happy Trainers. Happy Trainers has contractors and subsidiaries in other countries, who may have access to your data. At the same time, in all cases we pass your data to other persons we ensure that your data is being protected and used only within the purposes specified in this Privacy Policy. This is achieved by using only certified services and products, signing data processing agreements for the protection of personal data with contractors and partners, as well as taking technical measures to ensure the information is protected when stored, used, and while being processed and transferred. By ticking the respective box when providing us with your data you agree to such transfer and processing within the purposes set in this Privacy Policy.

1. How Long Will Personal Data Be Processed and Stored by Happy Trainers?

Your data will be stored by Happy Trainers no longer than is necessary for the purposes for which the personal data is processed. Generally, Happy Trainers retains your data as long as your account is active. In case your account expires or you decide to delete your account Happy Trainers retains your data no longer than 90 days after the account is expired. However, in case of conflict situations in progress, Happy Trainers may store personal data for 180 days period or more if the processing is necessary for the establishment, exercise, or defense of legal claims and for compliance with a legal obligation that requires processing by Union or Member State law to which the controller is subject in case of an expired account or the case data subject requested to delete his data. Upon the expiry of this period or earlier, if a conflict in the situation is settled, all personal data gets deleted. In case your last activity on Happy Trainers, as of the last payment date, was more than 180 (one hundred eighty) days ago, your account will be considered expired and gets deleted. Along with your account or profile, all personal data processed by Happy Trainers will be erased. As you are entitled to delete your account or profile after such a request it will be permanently removed within 30 days or earlier from our active systems, servers, and back-ups. By deleting your account or profile all your data will be removed as well within 90 days.

Personal Data collected when you registered on our mailing list or for the newsletter will be stored as long as you are interested in receiving our emails. We consider that you’re interested in this until you unsubscribe from the mailing list or the newsletter by clicking the respective link contained in each of our emails.

If you have registered for any of our events or webinars using your account credentials, we will merge and store this information along with your account data. If you have used other contact details, we will delete them within 30 days after conducting the event or webinar. Lists of participants of the sweepstakes including those who entered the sweepstakes via the alternative method of entry (mail-in) will be deleted in 30 days after the close of the sweepstakes. The names of the sweepstakes winners published on our Website will remain publicly available till the withdrawal of your consent. After the expiration of the retention period, Happy Trainers shall terminate the processing of your data, unless otherwise is set by the relevant legislation.

1. Your rights as a data subject regarding your Happy Trainers Processes

(1) Right of Confirmation

You can obtain confirmation from Happy Trainers as to whether personal data concerning you are being processed.

(2) Right of Access

You can access your data processed by Happy Trainers.

(3) Right to Rectification

You can ask Happy Trainers to have incomplete personal data requiring corrections completed.

(4) Right to Erasure (Right to Be Forgotten)

You can request Happy Trainers to erase personal data. In most cases, Happy Trainers will erase it unless otherwise required by legislation. To delete your data, you can contact us by email at [email protected]. We will respond to your request to delete your information within 30 days and notify you of the outcome.

(5) Right to Withdraw Consent at any time by Contacting Us

After we at Happy Trainers receive a withdrawal request from you, we will process it promptly and we will no longer process your data unless otherwise is set by law.

If one of the aforementioned reasons applies, please contact us, as instructed at the end of this Privacy Policy. We shall promptly ensure that the request is complied with immediately. These requests are free of charge. If you believe that our use of your data violates your rights, you can complain about the competent data protection authority. Please note that when the processing of your data is carried for direct marketing purposes, you have the right to object at any time to such processing without providing any justification and we will no longer process your data with such direct marketing purposes.

1. 29. Other Privacy Commitments

(1) Cross-border Transfers

We process your data both within Canada and outside Canada. Although countries, where we process data, may have different laws, we take measures to ensure high privacy compliance (as provided in this Privacy Policy).

(2) Time for Reply and Reaction

Happy Trainers will provide information on action taken on your request related to your rights specified above within one month of receipt of the request for the longest. That period may be extended by two further months if Happy Trainers is overwhelmed by the number of requests or the request at issue is complicated and requires a lot of action. Happy Trainers will inform you of any such extension within one month of receipt of the request, together with the reasons for such delay.

(3) Security

Happy Trainers takes technical and organizational measures to ensure the information is processed in a manner that ensures appropriate security of information, including protection against unauthorized or unlawful processing and accidental loss, destruction, or damage. For example, Happy Trainers uses verified contractors that might have access to the data with which the relevant data processing agreements are signed.

 (4) Breach Notifications

If any personal data of yours would be under the breach, we would inform you and the respective data protection agencies as to the accidents without undue delay, if there are high risks of violation of your rights as the data subject. We would also do our best to minimize any such risks.

(5) “Do Not Track” Requests

Happy Trainers does not share personal data with third parties for their direct marketing purposes. Also, our Services do not support “Do Not Track” requests.

1. Legal Matters

Happy Trainers considers your use of its Service to be private. However, we may disclose your data stored in our databases, too:

(1) Comply with the law or legal process served on us;

(2) Enforce and investigate potential violations of this Privacy Policy; including use of this Service to participate in, or facilitate activities that violate the law;

(3) Investigate potential fraudulent activities; or

(4) Protect the rights, property, or safety of Happy Trainers, its employees, its customers, or the public.

We hope this Privacy Policy helped you to understand how your data will be dealt with here at Happy Trainers. We will take care of your data, so you can use our Services and not be concerned about your privacy. Should you have anything to tell us, e-mail us at [email protected].  We will be happy to receive any information or comment from you to make our platform better for our users.

Your Happy Trainers Team