PRIVACY POLICY

1. Preamble
This privacy policy (hereinafter the "Policy") informs you of how HAPPY CLIENT processes, as data controller, your personal data collected during your browsing and as part of your subscription to the website. www.happy-client.r (hereinafter the "Site").
HAPPY CLIENT is a simplified joint-stock company with a capital of 60,000 euros, registered with the Trade and Companies Register of Marseille under number 898 485 909 and whose registered office is located at 69 Avenue de la Timone, Marseille 13010, whose VAT number is FR 11898485909.
This Policy implements the principles resulting from Regulation (EU) 2016/679 – General Regulation on the Protection of Personal Data (“GDPR”) and Law No. 78-17 of January 6, 1978 as amended (“Data Protection Act”). Freedoms”).

2. What data do we collect?
As part of the creation of your subscriber account and for the proper execution of your subscription or for the management of any registration for a game for a non-subscriber, we are required to collect certain data about you such as:
- Your first and last names;
- Your email address ;
- Your phone number ;
- The postal address of the participants in a game who have won a prize requiring its delivery;
- Data relating to your activity on the Site through the use of cookies.
To carry out transactions, we use the online payment provider Viva Wallet and PayPal. We do not receive or process any of your bank details. This information is collected and processed by our service providers and subcontractors Viva Wallet and PayPal. For more information, we invite you to consult their privacy policies.

3. Why and how do we collect your data?
HAPPY CLIENT processes your personal data for the purpose of managing your subscription, the HAPPY CLIENT service offer and monitoring the subscriber relationship. This processing is based on the contract concluded between the subscriber and HAPPY CLIENT, formalized by the general conditions of sale (“GTC”).
HAPPY CLIENT also processes your personal data in order to send you a newsletter, on the basis of your consent, once you have subscribed to it. You will have the possibility to unsubscribe from the newsletter at any time if you wish.
Finally, HAPPY CLIENT processes your data in order to ensure overall statistical monitoring relating to its activities, to improve the Site and its offers, on the basis of its legitimate interest.

4. Who are the recipients of the data?
Your data is processed by the internal services of HAPPY CLIENT. They are likely to be transmitted to third parties to allow the delivery of prizes to winners during their participation in games.
The recipients of data undertake to comply with the GDPR and the Data Protection Act. They implement the appropriate technical and organizational measures to ensure that the GDPR is respected.

5. How long are they kept?
We keep your data for the time necessary to fulfill the purposes set out above.
As part of the use of your data for the purpose of managing your subscription, the HAPPY CLIENT service offer and monitoring the subscriber relationship, we keep your data for a period of three (3) years from of the end of your subscription.
With regard to the data processed in order to ensure global statistical monitoring relating to its activities, to improve the Site and its offers, we keep them for a period of three (3) years from the last contact with the persons to whom they relate.
When the data is no longer needed, HAPPY CLIENT strictly ensures that it is deleted.

6. How do we ensure the security of your data?
In order to ensure and guarantee the security of your data, we have implemented all the technical and organizational measures at our disposal to prevent your data from being unintentionally and accidentally lost, used, altered, or made available to you. available to the public without your permission.
If an event of such a nature were to occur, we have implemented measures to react promptly and inform you, as well as the CNIL, when necessary.

7. Is your data transferred outside the EU/EEA?
HAPPY CLIENT does not transfer any data outside the EU/EEA zone.
On the other hand, the service providers and any subcontractors we use may be required to transfer data outside the EU/EEA. When this is the case, we ensure that these transfers are made on the basis of appropriate guarantees to ensure the security of your data.

8. What are your rights and how can you exercise them?
Under the terms of the GDPR and the Data Protection Act, you have rights relating to the processing carried out using your personal data, listed below:
- The right of access: this right allows you to request information on the processing that we implement as well as a copy of your processed data.
- The right of rectification: you have the possibility to rectify, correct and update your data at any time.
- The right of opposition: you can oppose in certain cases the processing of your information.
- The right to limit processing: you can ask us to limit processing operations to the sole storage of your data, under certain conditions.
- The right to erasure: in certain cases, you can request the erasure of your data.
- The right to portability: you have the option of requesting the recovery of your data or their transfer to another service provider, under certain conditions.
- You also have the right to define directives relating to the fate of your personal data after your death, as well as the right to lodge a complaint with the CNIL.
We also inform you that we do not carry out any automated decision- making, including profiling, using your data.
The exercise of these rights is free, and can be carried out at any time, subject to proving your identity, by writing to the address support@happy-client.fr

9.Cookies
Use of the Site may lead to the deposit of a cookie on your equipment.
A cookie is a file composed mainly of letters and numbers, of limited size and stored on the user's equipment.
A cookie can be installed on your computer in order to record information relating to your navigation, with the aim of improving the technical conditions of navigation and the user experience.
You will always be informed before a cookie is installed. In addition, your consent will always be required before the installation of a cookie unless it is strictly necessary for the services offered on the Site or if its exclusive purpose is to allow or facilitate communication by electronic means.
The Site uses cookies whose function is to facilitate and streamline your connection and your navigation on the Site. You can deactivate them when you access the Site through the cookie banner that will be displayed on your screen.
However, you will not be able to disable cookies that are strictly necessary for the operation of the Site. In order to deactivate them you will have to configure your internet browser to this effect. However, this could affect the proper functioning of the Site.
The data collected using these cookies are kept for a maximum of thirteen (13) months from their deposit on your equipment.

10. Modification of the Policy
We may modify this Policy from time to time, in particular to take into account all future legislative and regulatory developments. This Policy may also be amended to reflect any changes in the conditions of the processing of your data as well as for any other reason that we deem useful at our discretion.
When this is the case, we will keep you informed by email, or by displaying an information banner on the Site.

11. How to contact us?
For more information about this Policy, the processing of your data and the exercise of your rights, please contact us by sending an email to support@happy-client.fr Or by post the following postal address: 69 Avenue de la Timone, 13010 Marseille.