We at VA Tech Ventures Private Limited (“Happay”) are committed to protecting and respecting Your privacy. This Privacy Policy (“Policy”) sets out how We collect, use, share and otherwise process information which identifies You, either directly or indirectly, or is associated with You (“Personal Information”) in connection with Your relationship with Us. This Policy also sets out a procedure for the safeguarding, storing and utilization of Personal Information, as well as ways in which You can access and update Your Personal Information and make certain choices about how Your Personal Information is used by Us. This Policy is available for direct access on Our website at [Privacy Policy]. We will not use or share Your Personal Information with anyone except as described in this Policy.

Please read this Policy carefully to understand Our views and practices regarding Your Personal Information and how We will treat it.

For the purpose of this Policy, the terms 'Us', ‘Our’ or 'We' refers to Happay with Our registered office at 3rd Floor, Delta Block, Sigma Soft – Tech Park, No. 7 Whitefield Main Road, Ramagodanahalli, Varthur Hobli, Bangalore, Karnataka 560066, India. The term 'You' or ‘User’ refers to you, (i) a visitor of our website, (the “Website”), or (ii) user or potential user of Happay’s software, provided on Happay’s mobile application, the Website or through web-plugins (the “Services”).

  1. Collection of Personal Information From Users of the Service
    1. In accordance with applicable laws and regulations, including the European Union General Data Protection Regulation (EC Regulation 2016/679), Happay controls, owns and directs the use of the Personal Information collected on the Website and, in this regard, Happay is the data controller. For any queries regarding this Policy and the collection and use of Personal Information collected or processed under this Policy, Happay can be contacted by e-mail at
    2. Should you visit Our Website or wish to avail any of Our Services, We may collect certain Personal Information about You, to help Us serve You better. Depending upon the Services You wish to avail from Us, the Personal Information collected by Us, inter alia includes:
      1. name
      2. telephone number
      3. e-mail Address
      4. residential / service address
      5. work details
      6. financial information such as bank account, credit card, debit card, or other payment instrument details
      7. Your IP address(es)
      8. current location
      9. information about your device(s)
      10. demographic information such as postcode, preferences and interests
      11. any other Personal Information, which You give Us while using our Service or accessing our Website.
      12. If You are an Indian resident, We may also collect Know Your Customer (“KYC”) details and documentation, including, but not limited to, Aadhar card, voter ID card, passport number, driving license, and particulars thereof.
  2. Cookies
    1. You can browse Our Website without telling Us your name, address or personal details. However, some of our web pages may track certain Personal Information about You based on Your behavior on Our Website. This information may include the URL that You just came from (whether this URL is related to our Services or not), which URL You next go to (whether this URL is related to Our Services or not), Your browser information, and Your IP address.
    2. We may use data collection devices on Our Website and Services such as "cookies" on certain aspects to help analyze inter alia Our web page flow, measure promotional effectiveness, and promote trust and safety. "Cookies" are small files placed on Your hard drive that assist Us in providing Our Services. We offer certain features that are only available through the use of a "cookie". You are always free to disable our cookies at any time by using Your browser options, however if You turn off cookies You may not be able to use certain features on the Website or the Services, for which, We shall not be responsible. Additionally, You may encounter "cookies" or other similar devices on certain pages of Our Website or Our Service that are placed by third parties. You can find out more about cookies by following this link: Additionally, You can also learn about our Cookies Policy by following this link: [Cookie Policy]
  3. Third party websites
    1. When You are using Our website, You may be directed to, or come across links to, other websites that are operated and controlled by third parties that We do not control and You access these websites at Your own risk, We provide links to third party websites for your convenience only, any links to third party websites do not imply an endorsement by us to that third party website. Clicking on links to third party websites may allow such third party to collect Personal Information about You. We do not control the use of cookies by third parties nor are We responsible for the contents of any third party website, including the privacy practices employed by any of these third parties. When You leave the Website, We encourage You to read the applicable privacy statements of that third party websites to determine how they will handle Your Personal Information before submitting any Personal Information to such third parties.
  4. Legal Basis for Collection and Processing of Personal Information
    1. The legal basis for the collection and processing of any Personal Information collected and processed by Us is: (i) for the performance of the Services in accordance with the contract executed with You; (ii) You have provided us with your consent to do so; and (iii) where it is Our legitimate interests to do so and such legitimate interest is not overridden by Your rights, (as specified in Paragraph 5 below, for example to do internal research on Our Users' usage, including, without limitation, demographics, interests, patterns, and behavior to better understand, protect, and serve Our Users, while improving Our website and Services). This information is compiled and analyzed on an aggregated basis. While collecting information, We indicate fields that are mandatory and those that are optional. You may decide whether or not to provide such optional information to Us. However, non-provision of mandatory information may result in Us being unable to provide Services to You. Further, non-provision of specific or accurate Personal Information may result in a disruption in Your usage of Our Website or the Services, for which We will not be responsible. In some cases, We may also have a legal obligation to collect Personal Information about You, or may otherwise need the Personal Information to protect Your vital interests or those of another person, or where We need to comply with a legal requirement.
  5. Use of Personal Information
    1. Where it is in our legitimate interests to do so, the Personal Information collected by Us through Our Website is used by Us for various purposes to enable Us to serve You better:
      1. Internal record keeping

        We may use the Personal Information collected from You to improve Our products and Services, by way of sharing such information with third parties for the purposes of analysis. In the event that We share Your Personal Information with third parties, We require all third parties to respect the security of Your Personal Information and to treat it in accordance with the law, and such third parties will be contractually restricted from using Your Personal Information in any manner other than in helping Us;

      2. Promotional Emails or Messages

        We may periodically send promotional emails or messages about new services, special offers, or other information which We think You may find interesting using the email address and phone numbers which You have provided. You may, at any time, modify your subscription preferences;

      3. Customization

        From time to time, We may use Your Personal Information to customize Our Website according to Your interests.

      4. Customer Service

        We may use Your Personal Information to resolve disputes that may arise with the use of Our Services, help promote a safe service to all the Users, measure consumer interest in Our Services, detect and protect Us against error, fraud and other criminal activity.

      5. Troubleshooting

        We may use Your IP address to help diagnose problems with Our server, and to administer the Website.

      6. Carry out Our obligations

        We may collect Your Personal Information to carry out Our obligations arising from any agreements entered into between You, or Your employer, and Us, such as allowing our employer clients to evaluate your usage of the Services. We will use information We collect directly from You, information about how You use the Service and information about how You connect to the Service for this purpose.

      7. Notification

        We may collect Your Personal Information to notify You about changes to the Service and address complaints, comments, and issues You have in relation to Your use of the Service.

      8. Prevent illegal activities

        We may also collect Personal Information from you to prevent, detect and investigate illegal activities, breaches of any agreements entered into between You and Us and threats to the security of the Service. In the event that any Personal Information is compromised as a breach of security, We will promptly notify You in compliance with applicable law.

  6. Children’s Personal Information
    1. Our Website and Services are not intended for children under the age of 16. We do not knowingly collect Personal Information from children under the age of 16.
    2. If You are under 16, do not use or provide any information on Our website or through any of its features.
    3. If We learn We have collected or received Personal Information from a child under 16, We will delete that information.
    4. If you believe we might have any information from or about a child under the age of 16, please contact us at or at
  7. Where We Store Your Personal Information
    1. We store all Your Personal Information on servers, which are restricted and highly secured with the necessary firewalls, and this server is accessible only by Our limited authorized personnel.
    2. We take all steps necessary to ensure that Your Personal Information is treated securely and in accordance with this Policy. Once We receive Your Personal Information, We use strict procedures and security features to prevent unauthorized third party access.
    3. We process the Personal Information collected in a lawful and proper manner and take appropriate security measures to prevent unauthorized access, disclosure, modification or unauthorized destruction of the Personal Information.
  8. Disclosure of Personal Information
    1. We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of Personal Information. These include internal reviews of Our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where Your Personal Information may be accessed. We restrict access to Personal Information to Our employees, contractors, and agents who require or need to know that information in order to operate, develop, or improve our Services. These individuals are contractually bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.
    2. We use standard, industry-wide, commercially reasonable security practices such as: (i) encryption, firewalls and SSL (Secure Socket Layers) for protecting Your Personal Information; (ii) ensuring ongoing confidentiality, integrity, availability and resilience or processing systems and services; (iii) ensuring We can restore access to Personal Information in a timely manner if a physical or technical incident occurs; and (iv) regular testing, assessment and evaluation of the effectiveness of our technical and organizational measures to ensure Your Personal Information is secure. Happay is also PCI-DSS certified.
    3. We may disclose your Personal Information to third parties, without Your prior specific consent:
      1. In the event that We sell or transfer Our business or assets (in part or whole), in which case We may have to disclose Your Personal Information to the buyer or recipient of such business or assets. Such buyer or recipient shall be informed of the obligations of privacy as under this Policy and applicable law and shall be required to maintain the same norms of privacy as stated herein. You will be informed via email and/or a prominent notice on our Website of any change in ownership or uses of Your Personal Information, as well as any choices You may have regarding Your Personal Information. We will endeavor that the transferee who is the recipient of Personal Information commits to privacy measures which are substantially similar to the measures under this Policy.
      2. If we require the assistance of such third party to analyze the Personal Information We receive from You, and where it is in Our legitimate interests to do so, for improving Our Services and products, and such third party will be obliged to maintain the obligations of privacy and security under this Policy and applicable laws.
      3. In order to respond to a subpoena, summons, court order or other legal duty or obligation (including without limitations requests or demands from law enforcement and government authorities and regulators), or as required by applicable laws.
      4. In order to comply with applicable law to investigate, prevent, or take action regarding suspected or actual prohibited activities, including but not limited to, fraud, illegal transactions and situations involving potential threats to the physical safety of any person or to prevent financial loss to any person or entity, including Us, Our customers, clients, and other related parties.
    4. We may also disclose Your Personal Information to a third party when You ask us to do so or when We believe this is required by law.
  9. Data Transfer
    1. Your Personal Information which We have collected may be stored and processed in India or any other country in which Happay or its subsidiaries, affiliates or service providers maintain facilities.
    2. We may transfer information that We collect about You, including Personal Information, to affiliated entities, or to other third parties across borders and from Your country or jurisdiction to other countries or jurisdictions around the world. These countries may have data protection laws that are different to the laws of Your country and, in some cases, may not be as protective. Where We transfer Personal Information outside of the European Economic Area, We will ensure that appropriate safeguards are in place to ensure that Your Personal Information will remain protected in accordance with this Policy either by: (i) entering into signed agreements incorporating the Model Contract Clauses approved by the European Commission to ensure the adequate protection of Your Personal Information; (ii) ensuring that the transfer of Personal Information is to a jurisdiction deemed to have an adequate level of protection by the European Commission; or (iii) where a third party is in the United States, We may transfer Personal Information to them if they are part of the Privacy Shield which requires them to provide similar protection to any of Your Personal Information.
  10. Data Retention
    1. Your Personal Information will be retained with Happay as long as it is necessary in order for Happay to provide the Services to You. If You wish to cancel Your account or request that Happay no longer uses Your Personal Information to provide Services to You, You may contact Happay at Happay will promptly delete the information as requested.
    2. Happay will retain and use Your Personal Information as necessary to comply with its legal obligations, resolve disputes, and enforce its agreements or for other business purposes. When Happay has no ongoing legitimate business need to process Your Personal Information, We will either delete or anonymize it.
  11. Rights of Users
    1. You will, at all times, have access to your Personal Information and an option to modify/update the same.
    2. We provide You with the opportunity to opt-out of receiving non-essential (promotional, marketing-related) communications from Us, after providing Us with Personal Information.
    3. In addition, You also have the following rights in relation to the Personal Information:
      1. be informed about the Personal Information We collect from You and use;
      2. obtain confirmation from Us that Your Personal Information is being collected and used by Us and to access the Personal Information held about You by Us;
      3. have Your Personal Information corrected if it is inaccurate or incomplete at any time. You may correct, delete inaccuracies, or amend Your Personal Information by sending us an email on;
      4. erasure, or the right to be forgotten, which means You can request the deletion or removal of any Personal Information We hold about You at any time. Happay will delete such Personal Information based on its obligations under law;
      5. block or suppress Us from collecting and using Your Personal Information, which means We can continue to store Your Personal Information but We cannot further collect or use it in any way;
      6. obtain and reuse any Personal Information We hold about You for Your own purposes across different services, which allows You to move, copy or transfer Your Personal Information easily from Happay to another place notified by You to Us in a safe and secure way without hindrance to the usability of Your Personal Information; and
      7. object to the processing of Your Personal Information on legitimate grounds.
    4. In the event that You would like to access, correct, delete or object to any inaccuracies of the Personal Information provided by You, or to otherwise exercise any of your rights in relation to Your Personal Information, You may send Us an email at detailing your request.
    5. We will aim to respond to all legitimate requests relating to Your rights above within one month of receipt of Your request. Occasionally it may take Us longer than one month if Your request is particularly complex or if You have made a number of requests. In this case, We will notify You and keep You updated.
    6. We may need to request specific information from You to help Us confirm Your identity and to ensure Your right to access Your Personal Information (or to exercise any of Your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact You to ask You for further information in relation to Your request to speed up Our response.
    7. It is important that the Personal Information We hold about You is accurate and current. Please keep Us informed if Your Personal Information changes during Your relationship with Us.
  12. Changes to Our Policy
    1. This Policy replaces all previous disclosures we may have provided to You about our information practice. We reserve the right to change this Policy, and any changes We may make to Our Policy in the future will be posted on this page. If there are material changes to this Policy, or our information practices change in the future, We will notify You by posting the policy change on Our Website. Any updates to Our Policy will be effective upon posting.
  13. Contact
    1. Questions, comments and requests regarding this Policy are welcome and should be addressed to our Grievance Officer, Chandan Kumar available at or at .
  14. Making a complaint
    1. We pride ourselves on excellent customer service, but if You would like to make a complaint about the way in which We have collected or used Your Personal Information, please contact us at ].
    2. If You are unhappy about the way We have handled Your complaint and/or You would like to take the matter further or make a complaint directly to our regulator without contacting Us first, You can do so by contacting the Information Commissioner’s Office (“ICO”) by following this link: or telephoning the ICO helpline, which is +44 (0)303 123 1113.
  15. Version Control and Review Cycle
    1. This is version 1.0 of Happay’s Privacy Policy dated as of 29th Jan 2019. We will review this Policy, from time to time, as required under applicable law.



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Happay is a product of VA Tech Ventures. © 2019 VA Tech Ventures Pvt Ltd. All rights reserved.