PRIVACY POLICY

This privacy policy (“Policy”) explains how Happysales AI, Inc. or any of its affiliates or subsidiaries (“We”, “Us”, “Our”) Processes Personal Data collected from natural persons as specified in clause 2 below (“You”), as a Controller.

1. Definitions

Capitalised terms not specifically defined herein shall have the meaning ascribed thereto in the Agreement.

1.1 “Customer” means the natural or legal person that has subscribed to Platform by accepting the Agreement.

1.2 Process/Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

1.3 “Agreement” shall mean the Customer Agreement available at [www.happysales.ai/terms-of-service].

2. How we collect, use, and share your personal data

2.1 Personal data that you provide us‍

When You are a(n)	What Personal Data We Collect	How We use Your Personal Data	Whom We share Your Personal Data with
Individual who subscribes to the Platform and/or is provided with login credentials to sign into Platform on behalf of the Customer. ‍	Your contact information, such as Your full name, email address, phone number.	Creation of a User account, verification of a User’s identity and help a User log into the Platform. To communicate with a User regarding existing services availed by the Customer including notifications of any alerts or updates. To send a User information about Our other products or services, events, webinars, or programs that may be of interest to such User. To customise the services offered under the Platform.	Third-party applications that assist Us in creating Your Account, sending You notifications and information about our products, services, webinars, etc.
User who provides certain information through the Platform, while a) filling out a survey about their user experience or feedback, b) contacting Us or speaking to Our representatives	Information You have provided as part of it.	To improve the Platform. To send information about Our products, services, and any other marketing messages which may be of Your interest. To respond to Your comments, queries, or questions, if any.	Third parties who assist Us in providing these services.
Individual who requests a demo.	Your contact information includes Your first and last name, email, and phone number. ‍	To give You the demo and To inform, promote, and market the Platform to You.	Third parties who assist Us in providing these services.
Individual who a) provides information by filling out forms on Our Website, or b) contacts Us or speaks to our sales representatives	Information You have filled in or have submitted via the web forms or information You have provided in Your interaction with Us.	To respond to Your queries, questions or requests. To send information about Our products, services, and any other marketing messages which may be of Your interest.	Third parties who assist Us in providing these services.
User who requests customer support services.	Your contact information such as Your name, email, and phone number	To respond to Your comments and questions and provide customer service.	Third parties who assist Us in providing these services.
Individual who applies for an employment opportunity with Us ‍	Your contact information, such as full name, email address, mobile number, details of Your education and previous employment, and any other information You volunteer, including during any interview or Your interactions with Us and contained in the resume that You submit to Us. ‍	To evaluate You for any position that You have applied for or that We may consider You at the time that You submitted Your resume or at a later date.	Third parties whose products we use in maintaining a record of and evaluating You for the position applied. With external recruiters and organizations like those that do reference or background checks on Our behalf.

2.2 Personal data that we collect not provided directly by you

When You are a(n)	What Personal Data We Collect	How We use Your Personal Data	Whom We share Your Personal Data with
Website visitor	Internet Protocol (IP) addresses, operating system and browser information, and Your session activity including page views, time spent on each page, scrolling activity, and event data through first-party cookies ‍	For market analysis and market research To protect Our data from threats, violations, and breaches if any. To inform, promote and offer Our Platform to You.	Third parties who provide Us with services in connection with such processing. ‍
User	Information relating to Your use of or interaction with the Platform, or query logs and Your email conversations with individuals with whom you may interact with using the Platform;	To develop, improve, support, and operate the Platform and provide personalised service to You.	Third parties who provide Us with services in connection with such processing. ‍
Individual whose information (a) third-party sources share with Us through a valid agreement without breach of any confidentiality clause and with all necessary approvals and authorizations, in accordance with applicable law; or (b) is available on public platforms. ‍	Your contact information, such as Your full name, email address, phone number, designation and business name, company-level information, and other unique identifiers which may be considered as Personal Data. We may combine this information with any Personal Data provided by You. ‍	To update, expand,and analyze our records and create more tailored advertising to provide services that may be of interest to You. To develop, improve and support our Platform.	Third-party partners who assist Us in such processing. ‍

When You are a(n)

What Personal Data We Collect

How We use Your Personal Data

Whom We share Your Personal Data with

Website visitor

Internet Protocol (IP) addresses, operating system and browser information, and Your session activity including page views, time spent on each page, scrolling activity, and event data through first-party cookies

‍

For market analysis and market research
To protect Our data from threats, violations, and breaches if any.
To inform, promote and offer Our Platform to You.

Third parties who provide Us with

services in connection

with such processing.

‍

User

Information relating to Your use of or interaction with the Platform, or query logs and Your email conversations with individuals with whom you may interact with using the Platform;

To develop, improve, support, and operate the Platform and provide personalised service to You.

Third parties who provide Us with

services in connection

with such processing.

‍

Individual whose

information (a) third-party sources share with

Us through a valid agreement without breach of

any confidentiality

clause and with all necessary approvals and authorizations, in accordance with applicable law; or (b) is

available on public

platforms.

‍

Your contact information, such as

Your full name, email

address, phone number,

designation and

business name, company-level information, and other unique identifiers which may be considered as Personal Data. We may

combine this information with any

Personal Data provided

by You.

‍

To update, expand,and analyze our records and create more tailored advertising to provide services that may be of interest to You.
To develop, improve and support our Platform.

Third-party partners

who assist Us in such

processing.

‍

‍2.3 If You provide Us with any Personal Data relating to other individuals, You represent that You have the authority to do so, and where required, have obtained the necessary consent, and acknowledge that it may be used in accordance with this Policy. If You believe that Your Personal Data has been provided to Us improperly, please contact Us by using the information in clause 11 below.

2.4 In addition to the details provided in the table above, We may also share Your Personal Data with

a. an entity to which we divest all or a portion of Our business, or otherwise in connection with a merger, consolidation, change in control, reorganisation or liquidation of all or a portion of Our business.

b. Law enforcement authorities, government authorities, courts, dispute resolution bodies, regulators, auditors, and any party appointed or requested by applicable regulators to carry out investigations or audits of Our activities.

c. Professional advisors who advise and assist Us in enforcing Our contracts and policies, handling Our claims, effective management of Our company and in relation to any disputes We may become involved in.

2.5 AI Sales Agent Capabilities
Our Platform includes an AI Sales Agent feature that accesses Your Gmail inbox to read, analyze, and generate email responses on Your behalf. This feature allows for automated email sequencing and sending from drafts created in Our web application.
Personal Data Processed:

Email content, including received and sent emails.
Metadata associated with email communications.

How We Use Your Personal Data:

To read and analyze email content for generating appropriate responses.
To create, sequence, and send automated email responses based on drafts in the web application.

Whom We Share Your Personal Data With:

Third-party applications that assist Us in email processing and automation, ensuring compliance with our data protection standards.

3. Legal basis for processing (EEA region)

3.1 If You are a data subject from the European Economic Area, Our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which We collect it.

3.2 We will normally collect Personal Data from You only where it is needed to perform a contract with You, where the Processing is in Our legitimate interests and not overridden by Your data protection interests or fundamental rights and freedoms, or where We have Your consent. In some cases, We may also have a legal obligation to collect Personal Data from You. If We Process Personal Data with reliance on Your consent, You may withdraw Your consent at any time.

3.3 If You have questions or need further information concerning the legal basis on which We collect and use Your Personal Data, please contact Us using the contact details provided under clause 11.

4. International transfer

4.1 We mainly Process Personal Data in the United States of America and India. However, We may transfer Personal Data outside these regions only for the purposes referred to in clause 2. We will ensure that the recipient of Your Personal Data offers an adequate level of protection that is at least comparable to that which is provided under applicable data protection laws.

4.2 If You are a resident of the European Economic Area and when Your Personal Data is Processed outside EEA, We will ensure that the recipient of Your Personal Data offers an adequate level of protection, for instance by entering into standard contractual clauses for the transfer of Personal Data as approved by the European Commission (Article 46 General Data Privacy Regulation, 2016), or We will ask You for Your prior consent to such international data transfers.

4.3 Specific Data Security Measures for AI Sales AgentWe implement stringent security measures to protect the email data accessed by Our AI Sales Agent, including encryption, access controls, and regular security audits to prevent unauthorized access and ensure data integrity.

5. Security of personal data

We use appropriate technical and organizational measures to protect the Personal Data that We collect and Process. The measures We use are designed to provide a level of security appropriate to the risk of Processing Your Personal Data. If You have questions about the security of Your Personal Data, please contact Us using the contact details provided under clause 11.

6. Retention of personal data

6.1 We retain Personal Data collected where an ongoing legitimate business requires retention of such Personal Data.

6.2 In the absence of a need to retain Personal Data under clause 6.1 above, We will either delete it or aggregate it or, if this is not possible then We will securely store Your Personal Data and isolate it from any further processing until deletion is possible.

7. Your rights

You are entitled to the following rights:

7.1 You can request Us for access and correction of Your Personal Data

7.2 If We have collected and processed Your Personal Data with Your consent, then You can withdraw Your consent at any time. Withdrawing Your consent will not affect the lawfulness of any processing We have conducted prior to Your withdrawal, nor will it affect Processing of Your Personal Data conducted in reliance on lawful processing grounds other than consent.

7.3 You have the right to complain to a data protection authority about Our collection and use of Your Personal Data. For more information, please contact Your local data protection authority as specified by the applicable data protection laws.

7.4 You have the right to opt out of marketing communications We send You at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails We send You.

7.5 If You are a resident of the EEA, UK, or Switzerland, You are also entitled to the following rights:

You can request Us for deletion and erasure of Your Personal Data.
You can object to the Processing of Your Personal Data, ask Us to restrict the Processing of Your Personal Data, or request portability of Your Personal Data.

7.6 If You seek to exercise Your rights under this clause, please contact Us at the details provided in clause 11. We will verify any requests before acting on the request and respond to all requests We receive from individuals wishing to exercise their data protection rights within a reasonable timeframe in accordance with applicable data protection laws.

7.7 User Control Over AI Sales Agent
You have the right to manage Your preferences regarding the AI Sales Agent functionalities:

You can opt-out of allowing the AI Sales Agent to access Your Gmail inbox.
You can limit the AI Sales Agent's actions to only creating email drafts without sending them automatically.
To exercise these options, please contact Us using the details provided in clause 11.

8. Cookie policy

8.1 Cookies are text files that are placed on Your computer to collect standard internet log information and visitor behaviour information by Us. When You visit the Website(s), We may collect Personal Data automatically from You through cookies or similar technology. We also set cookies to collect information that is used either in aggregate form to help Us understand how Our Website(s) is being used or how effective Our marketing campaigns are, to help customise the Website(s) for You or to make advertising messages more relevant to You

8.2 Necessary Cookies: We set these cookies to help Us improve Our Website(s) by collecting and reporting information on how You use it. The cookies collect information in a way that does not directly identify anyone.

8.3 Statistics, Preference, and Marketing Cookies: We set these cookies to help Us improve Our Website(s) by collecting and reporting information on how You use it. The cookies collect information in a way that does not directly identify anyone.

8.4 When You visit the Website(s), a cookie banner will be displayed providing additional information about cookies and options to opt out of non-essential cookies as required by applicable laws.

9. Privacy of children

We recognize the importance of children's safety and privacy. We do not request, or knowingly collect, any Personal Data from children under the age of 18. If a parent or guardian becomes aware that his or her child has provided Us with Personal Data, they should write to Us at the email address provided in clause 11.

10. Notice to user and other exclusions

10.1 Our Platform is intended for use by businesses. Except for the Personal Data collected from You for the purposes mentioned under clause 2, this Policy is not applicable to Our Processing of any Personal Data transmitted by the Customer. We may receive End- Users’ Personal Data as a part of the Customer Data for which We will only act as a Processor and such Processing will be governed by the Agreement. In such a case, the End-User’s data privacy questions and requests should be submitted to the Customer in its capacity as a Data Controller. We are not responsible for Customers’ privacy or security practices which may be different from this notice. Customers of the Platform are solely responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, as well as any and all privacy policies, agreements, or other obligations, relating to the collection of Personal Data in connection with the use of Platform by the Customer or the End-Users.

10.2 Our Website(s) contain links to other Websites. Our Policy applies only to Our Website(s), so if You click on a link to another Website, You should read their privacy policy. We encourage You to review the privacy statements of any such other Websites to understand their Personal Data practices.

11. Contact information

You may contact Us if You have any inquiries or feedback on Our data protection policies and procedures, or if You wish to make any request, in the following manner:

Kind Attention: [__________]

Email Address: [___________]

Address: [______________]

12. Changes to the policy

We keep this Policy under regular review and may update this webpage at any time. This Policy may be amended at any time and You shall be notified only if there are material changes to this Policy.

Privacy Policy

1. Definitions

Capitalized terms not specifically defined herein shall have the meaning ascribed thereto in the Agreement.

1.1 “Customer” means the natural or legal person that has subscribed to Platform by accepting the Agreement.

1.3 “Agreement” shall mean the Customer Agreement available at [www.happysales.ai/terms-of-service].

2. How we collect, use, and share your personal data

2.1 Personal data via the Happysales AI App:

What Personal Data We Collect:

Professional identification data (e.g. last name, first name, position, company, etc.) and contact data (e.g. email address and business phone number, etc.)
Email address
Connection data
Technical session cookies

Why do we process your data?

‍To provide our services, we have to process your personal data for :

To use and benefit from our service and all its features on the basis of our general terms of use.
To provide user account management (e.g., account creation, service access, and account deletion) based on our Terms of Service.
To receive our technical emails (e.g. modification of passwords, etc.) essential to the proper functioning of our service on the basis of our general conditions of use.
To be able to upload and import documents to our platform on the basis of our general terms of use.
To ensure and enhance the security and quality of our services on a day-to-day basis (e.g., statistics, data security, etc.) based on our legal obligations, our terms and conditions of use and our legitimate interest in ensuring the proper functioning of our services.

Your data is collected directly from you when you use our website and we undertake to process your data only for the reasons described above. ‍

How We Use Your Personal Data:

Creation of a User account, verification of a User’s identity, and help a User log into the Platform.
To communicate with a User regarding existing services availed by the User, including notifications of any alerts or updates.
To send a User information about Our other products or services, events, webinars, or programs that may be of interest to such User.
To customize the services offered under the Platform.

Whom We Share Your Personal Data With:

WE NEVER TRANSFER OR SELL YOUR PERSONAL DATA TO THIRD PARTIES OR BUSINESS PARTNERS. ALL OF YOUR PERSONAL DATA ARE USED EXCLUSIVELY BY OUR STAFF OR BY OUR IT SERVICE PROVIDERS.‍
Your personal data can also be transferred to our service providers for the sole purpose of technically operating our service.
We specify that we audit every service provider before recruiting them in order to verify that they are strictly complying with the applicable rules regarding personal data protection.

2.2 AI Sales Agent Capabilities

Our Platform includes an AI Sales Agent feature that accesses Your Gmail inbox to read, analyze, and generate email responses on Your behalf. This feature allows for automated email sequencing and sending from drafts created in Our web application.

Personal Data Processed:

Email content which is retained to a maximum of 90 days to create and send automated email responses via the Happysales AI application.

How We Use Your Personal Data:

We do not retain your email data to develop, improve, or train non-personalized AI and/or ML models.
No Personal Data Sharing: Happysales ensures that no personally identifiable information (PII) of our users is shared with any third-party vendors
User Consent: We prioritize obtaining your explicit consent before any interaction with these models. This is achieved through clear opt-in procedures within our platform's user interface.
Your emails remain private and secure: they will not be accessed, read, or deleted by anyone.
Happysales accesses only the necessary information from your email server to ensure our service functions properly.
Happysales server stores only the emails sent via Happysales and their replies to detect responses and provide access through the application.

What data do we process and for how long?

We have summarized the categories of personal data that we collect and their respective duration of retention.
If you wish to obtain further details on the retention periods applicable to your data, you can contact us at: privacy@happysales.ai
Professional identification data (e.g. last name, first name, position, company, etc.) and contact data (e.g. email address, social media URLs, etc.) are kept for the entire duration of the provision of the service, plus the legal statute of limitations, which is generally 5 years.
Email address to receive our technical messages kept until your account is deleted.
Connection data (e.g. logs, IP address, etc.) kept for a period of 1 year.
Technical session cookies kept for a maximum of 13 months. These cookies do not require your prior consent.
Once the retention periods described above have expired, the deletion of your personal data is irreversible and we will no longer be able to provide it to you after this period. At most, we may only retain anonymous data for statistical purposes.
Please also note that in the event of litigation, we are required to retain all of your data for the duration of the processing of the case even after the expiration of the retention periods described above.

How do we protect your data?

We implement all the technical and organizational means required to guarantee the security of your data and, in particular, to fight against any risk of destruction, loss, alteration or unauthorized disclosure of your data

2.3 Personal data that you provide us‍ via the website
The following section is defined for when you are a website visitor, a User Who Provides Certain Information Through the website, You Are an Individual Who Requests a Demo, You Are an Individual Who Provides Information by Filling Out Forms on Our Website or Contacts Us or Speaks to Our Sales Representatives or Customer Support Services or when you apply for an Employment Opportunity with Us

What Personal Data We Collect:

Internet Protocol (IP) addresses, operating system and browser information, and Your session activity including page views, time spent on each page, scrolling activity, and event data through first-party cookies.
Information provided by You while filling out a about your user experience or feedback, contacting Us, or speaking to Our representatives.
Your contact information, including Your first and last name, email, and phone number.
Information You have filled in or have submitted via the web forms or information You have provided in Your interaction with Us.
For employment: Your contact information, such as full name, email address, mobile number, details of Your education and previous employment, and any other information You volunteer, including during any interview or Your interactions with Us and contained in the resume that You submit to Us.

How We Use Your Personal Data:

To improve the Platform.
To send information about Our products, services, and any other marketing messages which may be of Your interest.
To respond to Your comments, queries, or questions, if any and provide customer service
To give You the demo and to inform, promote, and market the Platform to You.
For market analysis and market research.
To protect Our data from threats, violations, and breaches, if any.
To evaluate You for any position that You have applied for or that We may consider You for at the time that You submitted Your resume or at a later date.

Whom We Share Your Personal Data With:

No personal information is shared with any third party service providers
In case of employment, we may reach out to External recruiters and organizations like those that do reference or background checks on Our behalf.

3. Legal basis for processing (EEA region)

3.3 If You have questions or need further information concerning the legal basis on which We collect and use Your Personal Data, please contact Us using the contact details provided under clause below.

4. International transfer

5. Security of personal data

6. Your rights

You are entitled to the following rights:

6.1 You can request Us for access and correction of Your Personal Data

6.2 If We have collected and processed Your Personal Data with Your consent, then You can withdraw Your consent at any time. Withdrawing Your consent will not affect the lawfulness of any processing We have conducted prior to Your withdrawal, nor will it affect Processing of Your Personal Data conducted in reliance on lawful processing grounds other than consent.

6.3 You have the right to complain to a data protection authority about Our collection and use of Your Personal Data. For more information, please contact Your local data protection authority as specified by the applicable data protection laws.

6.4 You have the right to opt out of marketing communications We send You at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails We send You.

6.5 If You are a resident of the EEA, UK, or Switzerland, You are also entitled to the following rights:

You can request Us for deletion and erasure of Your Personal Data.
You can object to the Processing of Your Personal Data, ask Us to restrict the Processing of Your Personal Data, or request portability of Your Personal Data.

6.6 If You seek to exercise Your rights under this clause, please contact Us at the details provided in clause below. We will verify any requests before acting on the request and respond to all requests We receive from individuals wishing to exercise their data protection rights within a reasonable timeframe in accordance with applicable data protection laws.

7. Cookie policy

7.1 Cookies are text files that are placed on Your computer to collect standard internet log information and visitor behavior information by Us. When You visit the Website(s), We may collect Personal Data automatically from You through cookies or similar technology. We also set cookies to collect information that is used either in aggregate form to help Us understand how Our Website(s) is being used or how effective Our marketing campaigns are, to help customize the Website(s) for You or to make advertising messages more relevant to You

7.2 Necessary Cookies: We set these cookies to help Us improve Our Website(s) by collecting and reporting information on how You use it. The cookies collect information in a way that does not directly identify anyone.

7.3 Statistics, Preference, and Marketing Cookies: We set these cookies to help Us improve Our Website(s) by collecting and reporting information on how You use it. The cookies collect information in a way that does not directly identify anyone.

7.4 When You visit the Website(s), a cookie banner will be displayed providing additional information about cookies and options to opt out of non-essential cookies as required by applicable laws.

8. Privacy of children

9. Notice to user and other exclusions

9.1 Our Platform is intended for use by businesses. Except for the Personal Data collected from You for the purposes mentioned under clause 2, this Policy is not applicable to Our Processing of any Personal Data transmitted by the Customer. We may receive End- Users’ Personal Data as a part of the Customer Data for which We will only act as a Processor and such Processing will be governed by the Agreement. In such a case, the End-User’s data privacy questions and requests should be submitted to the Customer in its capacity as a Data Controller. We are not responsible for Customers’ privacy or security practices which may be different from this notice. Customers of the Platform are solely responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, as well as any and all privacy policies, agreements, or other obligations, relating to the collection of Personal Data in connection with the use of Platform by the Customer or the End-Users.

9.2 Our Website(s) contain links to other Websites. Our Policy applies only to Our Website(s), so if You click on a link to another Website, You should read their privacy policy. We encourage You to review the privacy statements of any such other Websites to understand their Personal Data practices.

10. Contact information

You may contact Us if You have any inquiries or feedback on Our data protection policies and procedures, or if You wish to make any request, in the following manner. You can write to us privacy@happysales.ai

11. Changes to the policy

We keep this Policy under regular review and may update this webpage at any time. This Policy may be amended at any time and You shall be notified only if there are material changes to this Policy.