Privacy Policy

Here you can find all the information regarding the data processing principles of HAPPY COACH OÜ (us/we/our). The objective of HAPPY COACH OÜ is to be a reliable partner that will respect your rights in the processing of personal data, and lead the way for the others on the market.

Definitions provide the meanings of the words and expressions that are capitalised and used frequently in this Privacy Policy.

1. WHAT DO THE USED TERMS MEAN?

1.1 Data Subject/ you is a natural person about whom we have got information or data enabling to identify the natural person. Data Subjects are, for example, the Clients, Visitors and cooperation partners, as well as the employees. 
1.2 Privacy Policy is this text which sets out the principles for Personal Data Processing by us.
1.3 Personal Data is any information concerning an identified or identifiable natural person.
1.4 Personal Data Processing is any operation or set of operations which is performed on the Personal Data of a Data Subject, such as collection, recording, organisation, structuring, storage, alteration and disclosure, enabling an access to, retrieval, consultation, use, transmission, cross-checks, alignment or combination, restriction, erasure or destruction of Personal Data, irrespective of the manner of performing these operations or the means exploited.
1.5 Client is any natural or legal person that uses or has expressed a desire to use the Services of us.
1.6 Agreement is the Service Agreement or any other agreement entered into between us and the Client. 
1.7 General Terms and Conditions set forth the general terms and conditions applied to the entry into an Agreement with us. 
1.8 Website means the following websites: 
https://thrivingfempreneurs.com
https://becomehappystayhappy.com.
1.9 Visitor is any person using the Website.
1.10 Services are any services and products offered by us. 
1.11 Cookies are the data files sometimes recorded in the device of a Visitor of the Website.

The above words and expressions are used in the meanings set out above in the Privacy Policy, Agreement, General Terms and Conditions and in the communication between the parties. Terms not capitalized have the meaning set out in EU General Data Protection Regulation no 2016/679 (GDPR).

This section tells you who is the controller of Personal Data and when the Privacy Policy applies.

2. WHO IS PROCESSING YOUR DATA?

2.1 HAPPY COACH OÜ is a legal person with a registry code of 14989977 and with a registered address of Pärnu mnt 20, 10141, Tallinn, Harju county, Estonia. 
You can contact us if you have any questions relating to Personal Data Processing, via following channel(s):
data @ becomehappystayhappy.com.
We shall respond to such requests as soon as possible and in any case within one month of the receipt of your request.

2.2 HAPPY COACH OÜ the controller of your personal data.

2.3 The Privacy Policy applies to all Data Subjects. The rights and obligations set out in the Privacy Policy shall be followed by all the employees and cooperation partners of us who come into contact with the Personal Data that is in the possession of 
HAPPY COACH OÜ. 
Please note: If you are a natural person residing in the European Economic Area, then your rights as a Data Subject are provided for in the GDPR. If you are a resident of some other country, you may have additional or different rights.

2.4 We have appointed a person who is responsible for implementing data protection principles and measures - who can be contacted by e-mail data @ becomehappystayhappy.com.

Here you can find the principles that are always followed by us while Processing your Personal Data.

3. PRINCIPLES – HOW DO WE PROTECT YOUR PERSONAL DATA?

3.1 We do our best to Process Personal Data responsibly, based on the best practice, with the aim of always being prepared to demonstrate the conformity of Personal Data Processing to the established purposes. We shall always take into account the interests, rights and freedoms of Data Subjects.

3.2 We follow all the main principles set out in the GDPR while processing your Personal Data. The principles are as follows: i) lawfulness of Processing (i.e. we have legal basis for Processing); ii) fairness and transparency of Processing (i.e. being honest and keeping in mind your rights); iii) purposefulness (i.e. we only Process Personal Data for the purposes we have set out here or communicated to you differently); iv) minimisation while Processing (i.e. we only Process Personal Data that we actually need to achieve the Processing purpose); v)accuracy of Processing (i.e. we do our best to ensure that the Personal Data is accurate and up-to-date); vi) limitation of storage (i.e. Personal Data is only kept for as long as really needed); vii) reliability and privacy by design (i.e. we do our best to ensure that the Processing be carried out in the manner ensuring the adequate security and confidentiality of Personal Data).

3.3 For example, we have access conscious staff and contractors and the external agencies with whom we work. With all important partners we have signed NDAs (Non-Disclosure Agreements). Our staff has also been trained in data protection.

Here you find information on what Personal Data we collect.

4. WHAT PERSONAL DATA DO WE PROCESS?

4.1 We collect the following Personal Data: 
(4.1.1) the full name of the Client; 
(4.1.2) the e-mail of the Client;
(4.1.3) the additional data needed (telephone number, country, home and work address, details of dependants etc.) for us to the fulfil contractual obligations within the various Services.

4.2 If Client buys the VIP-ticket or other Service/product, then we collect additional Personal Data, which are:
(4.2.1) tax or VAT identification number; 
(4.2.2) billing address;
(4.2.3) hipping address;
(4.2.4) other payment related data;
(4.2.5) additional data needed for issuing a correct invoice.

4.3 Client’s with VIP ticket will have to register as a user (for enabling the access etc. to VIP ticket perks/ bonuses etc.). For that we will Process e-mail (as a username) and password (we will not access your password; it is checked automatically).

4.4 About Visitors we may collect Personal Data via Cookies and Personal Data Visitors give us via Website or when communicating with us.

4.5 We may also Process other Personal Data that you have given us or that we have gathered, but only when we have a valid legal basis for such Processing e.g. Personal Data in Client communications, other Personal Data connected to fulfilling our obligations arising from the Agreement etc.

Here you can find out for which purposes and under which bases we can Process your Personal Data.

5. WHY AND ON WHAT LEGAL GROUNDS IS YOUR DATA PROCESSED?

5.1 In case we use consent, we shall Process Personal Data precisely within the limits of the consent.

5.2 We mostly Process Personal Data for entering into and performance of an Agreement; mainly for the following Purposes: 
(5.2.1) in order to provide the Services that we offer; 
(5.2.2) In order to be able to send information, free samples and products to our Clients;
(5.2.3) to register Clients and for classes and telecalls;
(5.2.4) to store and distribute the recordings of classes and telecalls to enable Clients play back classes or telecalls they attended.

5.3 We may also use legitimate interest which means the interest of us in the management and direction of our business in order to be able to offer the best possible Services for you. We shall Process Personal Data on a legal basis of legitimate interest only after careful consideration, based on which the Personal Data Processing is necessary and is in compliance with the interests and rights of a Data Subject (after carrying out the so-called three-step test, i.e. assessing our interests and your rights). In particular, Personal Data Processing may take place on the basis of a legitimate interest for the following purposes:
(5.3.1) for the administration and analysing the Client base to improve the availability, selection and quality of Services and products, and to make the best and more personalised offers to the Client upon the Client’s consent;
(5.3.2) for the identifiers and Personal Data collected upon the use of websites and other Services. We shall use the collected data for web analysis or for the analysis of information society services, for ensuring and improving the functioning, for statistical purposes and for analysing the behaviour and using experience of Visitors/ Clients and for providing better and more personalised Services;
(5.3.3) for the organisation of campaigns, including organisation of personalised and targeted campaigns, carrying out Client and Visitor satisfaction surveys, and measuring the effectiveness of the performed marketing activities;
(5.3.4) for the organisation of campaigns, including organisation of personalised and targeted campaigns, carrying out Client and Visitor satisfaction surveys, and measuring the effectiveness of the performed marketing activities;
(5.3.5) for monitoring of the service. We may record the messages and instructions given in its premises as well as by means of communication (e-mail, telephone, etc.), as well as information and other operations carried out by us; we can use those recordings as needed to evidence instructions or other operations;
(5.3.6) for network, information and cyber security considerations, for example for fighting against piracy and for ensuring the security of the Websites, as well as for the measures taken for making and storing backup copies;
(5.3.7) for corporate purposes, in particular for the financial management;
(5.3.8) for the establishment, exercise or defence of legal claims.

5.4 For performing a legal obligation, we shall Process Personal Data to perform the obligations set forth by law or to exercise the uses permitted by law. Legal obligations derive, for example, from adhering to the rules of payment processing and prevention of money laundering.

5.5 In case Personal Data Processing is carried out for a new purpose, different from those for which the Personal Data were originally collected, or is not based on the consent given by the Data Subject, we shall carefully assess the permissibility of such new Processing. In order to determine whether the Processing for the new purpose is in compliance with the purpose for which the Personal Data were originally collected, we shall take into consideration, inter alia, the following:
(5.5.1) any link between the purposes for which the Personal Data were collected and the intended further purposes Processing; 
(5.5.2) the context of collecting the Personal Data, in particular regarding the relationship between you and us;
(5.5.3) the nature of the Personal Data, in particular whether any special categories of Personal Data, or Personal Data are processed;
(5.5.4) possible consequences of the intended further processing for the Data Subjects;
(5.5.5) existence of appropriate protection measures which may consist in, for example, encryption and pseudonymisation.

Here you find information on when we may transfer your Personal Data to our cooperation partners.

6. WHO HAS ACCESS TO YOUR PERSONAL DATA?

6.1 Our team has access to your Personal Data to be able to fulfil our Agreements with our Clients. Our team may include communications and marketing team, event organizers and administrative staff. 

6.2 We may cooperate with persons, to whom we may transfer data regarding the Data Subjects, including their Personal Data, in the context and for the purposes of co-operation. Such partners may be our advertising and marketing partners, companies carrying out Client satisfaction surveys, debt collection agencies, credit registers, IT partners, persons, authorities and organisations intermediating or providing (electronic) mail services etc. and provided that:
(6.2.1) the respective purpose and the Processing are lawful; 
(6.2.2) the Personal Data Processing is carried out in accordance with the guidelines of us and on the basis of a valid agreement.

6.3 In addition, if you have register for one of our Access consciousness classes through our general website or through www.accessconsciousness.com, we shall share some of your Personal Data (only what is necessary) with (1) Access Consciousness, LLC, 406 Present Street, Stafford, TX 77477, United States of America, (2) Access Consciousness International Limited, 6 Greenview, Riverway, South Douglas Rd., Cork T12 DCR 4, Ireland, and (3) Access Seminars Australia PTY LTD, 55 Lorikeet Drive, Peregian Beach, QLD 4573, Australia, all three parties to be referred to as “Access Consciousness” or the “Companies”. These Companies have access to your basic data (full name, e-mail address, mailing address, country and phone number) This applies to live (in-person) classes, telecalls and online courses, as well as classes offered live via audio and live-streamed classes.
Please note: Access Consciousness gains access only to your basic data when you sign up for one of the Access Consciousness classes or calls that we offer. Access Consciousness does not have access to your other data e.g. tax or VAT number.
We do not share your data with facilitators with whom you have not taken a class. 
Access Consciousness is also bound by data protection principles.

6.4 We shall transfer Personal Data to outside the EU only if there is sufficient protection in the respective country; if protection measures have been agreed upon (e.g. binding internal rules of the group or standard data protection clauses); or the Data Subject has given a clear and informed consent for such transfer; or the transfer is clearly required by an Agreement entered into with the Data Subject; or the transfer is not repeated, it concerns only a limited number of Data Subjects; or it is necessary for protecting the legitimate interests of us which are not overridden by the interests, rights or freedoms of the Data Subject, and if all the circumstances related to the transfer have been assessed and suitable protection measures have been established to protect the Personal Data, or if there is some other legal basis therefor.

Here you can find for how long we store your Personal Data. Also, what we do to keep your Personal Data secure.

7. HOW LONG DO WE STORE YOUR PERSONAL DATA AND HOW?

7.1 We shall store the Personal Data strictly only for the minimum period required. Usually we shall keep the Personal Data stored as long as:
(7.1.1) we have a relationship with a Client or Data Subject;
(7.1.1) we are legally obliged to store the data for tax purposes;
(7.1.1) Client or interested party has not unsubscribed or asked to delete the concerning information.

7.2 The Personal Data with an expired storage period shall be destructed.

7.3 We have established procedural rules for ensuring the security of Personal Data by both organisational and technical measures. Further information on the security measures taken by us can be obtained also from the person who is responsible for implementing Data Protection (see p You can contact us if you have any questions relating to Personal Data Processing, via following channel(s):).

7.4 In case of an incident related to Personal Data, we shall take all necessary measures to mitigate the consequences and hedge any relevant risks in the future. We shall register all the incidents and shall inform the Data Protection Inspectorate and the Data Subject directly (e.g. by email) or in public (e.g. via the news) if deemed necessary by us after conducting assessment.

Your Personal Data belong to you, and here you find information on the rights you have in protecting your Personal Data.

8. WHAT RIGHTS DO YOU HAVE?

8.1 Under the GDPR, you have the rights to request from us access to and rectification or erasure of your personal data or restriction of processing your data or to object to processing your data, as well as the right to data portability. To exercise these rights, contact us as set forth above.
Please note: most rights are not absolute and are subject to requirements set in the GDPR. However, if we are Processing Personal Data under your consent – you can always withdraw it, and we will stop relevant Processing then.

8.2 Under the GDPR, you also have the right to lodge a complaint with a supervisory authority. Our jurisdictional supervisory authority is the Estonian Data Protection Inspectorate. Further information and contact details are available from https://aki.ee.

Here you can find information on the types of Cookies or other technologies we use and how you can control the use of such technologies.

9. COOKIES AND OTHER WEB TECHNOLOGIES 

9.1 We may collect data regarding the Data Subjects by using Cookies (i.e. small pieces of information stored by the Visitor’s browser on the hard disk of the computer of any other device of the Visitor) or other similar technologies and process data gathered by the Cookies (e.g. IP address, equipment information, location information etc.).

9.2 We use the collected data to enable the provision of the Service in accordance with the habits of a Visitor or Client; to ensure the best Service quality; to inform the Visitor and Client about the contents and give recommendations; to update advertisements and make marketing efforts more efficient; and to facilitate logging in and protection of data. The collected data shall also be used for counting the Visitors and recording their using habits.

9.3 Cookie solution – asking consent, your choices and more precise information on cookies is available at our Website via the cookie pop-up. You can also enable and disable cookies via you own web browser.

Here you can find information on the validity of and amendments to the Privacy Policy.

10. OTHER TERMS AND CONDITIONS 

10.1 We will be entitled to unilaterally amend this Privacy Policy. We shall inform Data Subjects about amendments on the Website or by e-mail or by other means.

10.2 The latest amendments and entry into force of the Privacy Policy:

Publication

In Force For Current Visitors And Clients

In Force For New Visitors And Clients

Main Modifications

July 10, 2020

July 10, 2020

July 10, 2020

July 10, 2020