HappyMe Privacy Policy
Your privacy matters to us. This policy explains what personal information Happy Solutions Limited collects when you use HappyMe (our mobile app and website) and associated services, why we collect it, how we protect it, and the rights you have over it.
Personal information is any information that can be used to identify you. HappyMe is built around collecting as little of it as possible. The only piece of personal information we require is your email address, which we use to create and secure your account.
HappyMe has no chat, messaging, comments or other user-generated content, and we do not share or sell your personal information to third parties. Our in-app analytics are first-party only, and we do not use any third-party advertising or tracking in the app.
1. Who we are
HappyMe is developed and operated by Happy Solutions Limited, a company registered in the Isle of Man with company number 131430C, whose registered address is Glen Wyllin Lodge, Glen Wyllin, Kirk Michael, IM6 1AN, Isle of Man.
Happy Solutions Limited is the data controller for the personal information you provide to us. This means we determine the purposes for which, and the way in which, your personal information is processed. We are registered with the Isle of Man Information Commissioner (registration number R819352).
Our software is developed and maintained in-house and self-hosted on our own Amazon Web Services account, which means we retain full control over how your personal information is handled and keep the number of third parties involved to a minimum.
2. The information we collect
Information you provide to us
- Email address when you register for an account, contact us, or subscribe to updates. This is the only personal identifier we require.
- Content you choose to enter in optional features such as journaling, mood tracking or exercises. Entering this text is never required for the app to work. It is encrypted on your device before it reaches us (see ‘Sensitive information’ below).
- Self-assessment responses, where you choose to complete a reflective questionnaire (for example about anxiety or burnout). These are reflective tools, not clinical diagnoses.
- Any information you include when you contact us by email or through our support channels.
Information collected automatically
When you use the app, we automatically collect limited technical data so that the service works and we can fix problems. This may include your device’s IP address, device type and version, your activity within the app, and, if the app encounters an error, technical details about that error. This data is processed on a first-party basis and is not shared with any third-party analytics or advertising provider.
Sensitive (special category) information
Some of the content you may enter in the app relates to your state of mind or mental health. This is ‘special category’ data under data protection law and is given a higher level of protection.
We do not ask for health information for diagnosis or analysis, and we do not analyse or use this content for any purpose. It is encrypted on your device before it is saved to our backend, and is decrypted only within the app when you ask to see it again. When our developers view the database they see encrypted text, not what you actually wrote. We rely on your explicit consent to store this content, and entering it is entirely optional.
Referral source
If you were referred to HappyMe by a partner organisation, we tag your account with that referral source. We use this to recognise the referral and to show you relevant signposting within the app, such as a route back to that organisation’s support. This tag is held by us and is not routinely shared. Where you have been referred by a partner organisation, we may share information about your use of HappyMe with that organisation only where you have consented, or where it is necessary to protect you or someone else from harm (safeguarding).
3. How and why we use your information
We only use your personal information where we have a lawful basis to do so. We use it to:
- provide the app’s core features and secure your account;
- personalise your experience of the app;
- contact and communicate with you, including sending service messages;
- send you marketing emails, where you have opted in;
- keep the service secure and prevent misuse;
- operate, maintain and improve the app using first-party analytics.
Our lawful bases, depending on the feature and how you use it, are:
- Consent – for example to store the optional content you enter, and to send you marketing emails. You can withdraw consent at any time.
- Performance of a contract – to create and operate your account and provide the service you have signed up for.
- Legitimate interests – to keep the service secure, and to understand and improve how the app is used, balanced against your rights.
- Explicit consent (Article 9) – for any health-related content you choose to enter.
- Legal obligation – where we are required to keep certain information, for example financial records.
4. Who we share your information with
We do not sell your personal information, and we do not use third-party advertising or tracking in the app. We share personal information only with the service providers we rely on to run HappyMe, and only to the extent they need it:
- Amazon Web Services (Ireland) – hosting of our database, application programming interfaces, authentication, storage, backups and transactional email.
- Brevo (France) – sending automated transactional emails and, where you have opted in, marketing emails. Brevo receives your email address. It is the only third party that can access this personal data, and only for the purpose of sending email.
- Google Firebase – delivering push notifications to your device.
- Google Workspace – our internal email and support mailboxes.
- Apple and Google – processing subscription payments made through the App Store or Google Play. We do not receive or store your payment card details.
- Google Analytics – anonymised website analytics only, subject to cookie consent. Google Analytics is not used within the app.
We may also disclose personal information where required by law, to establish or defend legal claims, to protect someone from harm (safeguarding), or in the event that our business is transferred to another owner, in which case any new owner would be bound by this policy.
5. How we keep your information secure
- Encryption in transit: all traffic between the app and our backend is protected with TLS.
- Encryption at rest: our database, storage and backups are encrypted using our hosting provider’s encryption.
- On-device encryption: the content you enter is encrypted on your device before it reaches us, so we cannot read it.
- Passwordless login: we use a passwordless login, where you receive a code to enter to complete sign-in. Please keep your email account secure, ideally with two-factor authentication, as it is the key to your account.
- Restricted access: access to our systems is tightly restricted, and our internal reporting portal is protected by multi-factor authentication.
No method of electronic transmission or storage is completely secure, but we protect your information using appropriate technical and organisational measures.
6. How long we keep your information
We keep your personal information only for as long as we need it:
- Active accounts: we retain your account information for as long as your account is active.
- Inactive accounts: if your account is inactive for 12 months, we email you to ask you to log in to keep it. If you do not, we permanently delete your account and data 7 days later.
- Deletion on request: you can delete your account at any time from within the app, or request deletion via myhappyme.co.uk/deletion-request. We delete your data immediately on request, and check that any residual data is removed from the third-party services we use.
- Legal retention: where the law requires it, for example financial or accounting records, we may retain certain information for up to 7 years.
7. International transfers of your information
Your personal information is stored within the European Economic Area, in our hosting provider’s Ireland region. The Isle of Man and the United Kingdom recognise the EEA as providing an adequate level of data protection.
Some of the service providers we use (such as Google) are based in, or transfer data to, the United States. Where personal information is transferred outside the Isle of Man, UK or EEA, we ensure it is protected by an appropriate safeguard, such as the EU-US Data Privacy Framework and its UK extension, or Standard Contractual Clauses and the UK International Data Transfer Addendum.
8. Your rights
You have the following rights over your personal information:
- Access – request a copy of the information we hold about you.
- Rectification – ask us to correct information that is inaccurate or incomplete.
- Erasure – ask us to delete your information (subject to any legal reasons we must keep it).
- Restriction – ask us to limit how we use your information in certain circumstances.
- Objection – object to processing based on our legitimate interests.
- Portability – ask for a copy of the information you gave us in a machine-readable format, or ask us to transfer it, where technically feasible.
- Withdraw consent – where we rely on your consent, withdraw it at any time.
To exercise any of these rights, contact us using the details below. We will respond within one month. Using HappyMe is free of charge and we do not charge a fee for exercising your rights.
Complaints: we would like the chance to resolve any concern first, so please contact us. You also have the right to complain to the Isle of Man Information Commissioner, the supervisory authority for data protection in the Isle of Man (inforights.im), First Floor, Prospect House, Prospect Hill, Douglas, Isle of Man, IM1 1ET.
9. Children’s privacy
HappyMe is intended for users aged 13 and over, and is rated accordingly on the App Store and Google Play. At registration we ask users to select an age range. HappyMe is not intended for children under 13, and anyone selecting the under-13 range is not permitted to create an account. We do not knowingly collect personal information from children under 13, and if we become aware that we have, we will delete that account and information.
We design HappyMe with regard to the Information Commissioner’s Age Appropriate Design Code (the Children’s Code), including considering the best interests of the child, applying privacy-protective settings by default, and collecting the minimum personal information necessary.
We never direct marketing at anyone under 18. Where consent is our lawful basis and a user is under the age at which they can consent for themselves (13 in the Isle of Man and the UK, or 16 in parts of the EU), we will seek the consent of a parent or guardian.
10. Cookies
We use cookies to provide core features, to remember your preferences, and to measure website usage on an anonymised basis. We do not use cookies to serve advertising. You can control cookies through your browser settings. Please see our Cookie Policy for more information.
11. Users outside the Isle of Man, UK and EEA
HappyMe is available internationally. If you use HappyMe from a country whose privacy laws give you additional or different rights (for example in the EEA, United States, Canada or Australia), you may exercise those rights by contacting us, and we will honour the rights that apply to you under the relevant law.
12. Changes to this policy
We may update this policy to reflect changes to our service, practices, or the law. We will post any changes here, and where the changes are significant, or the law requires it, we will contact registered users.
13. Contact us
For any questions about this policy or your personal information, or to exercise your rights, contact our Data Protection Lead:
Simon King, Data Protection Lead
Happy Solutions Limited, Glen Wyllin Lodge, Glen Wyllin, Kirk Michael, IM6 1AN, Isle of Man
Email: support@happymeapp.co.uk