HAPPYPILLAR PRIVACY POLICY


Thank you for visiting a Site owned and operated by Happypillar Inc. or an App published by Happypillar Inc. (from which you have come via link to this Privacy Policy). “Sites” refers to Internet web sites and “Apps” refers to apps for use on mobile communication devices such as smartphones and tablets. “Platforms” refers to Sites and Apps collectively. Through the Platforms, Happypillar aims to democratize evidence-based mental health treatment for families and young people using emerging technologies.
 

Happypillar Inc. is also referred to as "Happypillar", “we,” “us” or “our” in this Privacy Policy.

 

PRIVACY PRINCIPLES


Happypillar is trusted by parents to provide safe, educational content to promote mental health. We take this trust seriously and recognize the importance of privacy concerns especially in the digital environment.
 

With this in mind, we have adopted this Privacy Policy for our Platforms. On our Platforms, we collect personal information in two forms. One form is information that we expressly request you to provide in connection with certain activities. The second form is anonymous information that we automatically collect from your computer, phone or other device.
 

Our Privacy Policy is based on the following principles:
 

1. You are free to choose whether or not to engage in any activity on our Platforms that involves your submission of personal information, such as your name, email address, phone number or other information that can be used to identify or contact an individual, whether online or offline. We will ask you for such information expressly. Through the registration process, you will provide us with your name, e-mail address, and the first name and date of birth of your child, for personalization purposes. You will also provide us with your payment transaction information if you choose to pay for Happypillar services.
 

2. When we ask you to submit personal information, we will explain in the sign-up or collection process how we will use the information (such as requesting an email address for communication). We will use the information only as we have stated, other than in Special Circumstances which are described below (such as in relation to law enforcement or a business transfer).
 

3. We use the anonymous information that is automatically collected from your device, such as a computer’s Internet Protocol address, a mobile device identifier, operating system, or general location such as zip code, to support internal operations so that we can understand and monitor the usage of our Platforms and improve the performance of the Platforms.
 

4. There is no behavioral advertising on our Platforms which means that you will not see any advertising that is targeted to you based on your combined activity on our Platforms and your activity on other sites and apps.
 

5. Third parties that we use to assist with the Platforms are required to follow this Privacy Policy.

 

ESPECIALLY FOR CHILDREN UNDER 13


6. Our collection of personal information is intended to follow the principles of the Children’s Online Privacy Protection Act (“COPPA”), a U.S. law designed to protect the online privacy of children under the age of 13.
 

7. We will obtain parental consent via our Terms and Conditions of Service before asking for children’s personal information, such as name or nickname, age or date of birth, or voice data, on our Platforms, unless the request for information falls within an exception that would be permitted under COPPA.
 

8. We do not make personal information collected from children publicly available nor do we enable children to so on our Platforms. We will not condition a child’s participation in any activity or service on the disclosure of more personal information than is reasonably necessary to participate in an activity.
 

9. Parents may contact us (at hello@happypillar.com) to review, update or delete any of their children’s personal information that we may have collected and to elect for us not to collect any additional personal information from their children.
 

10. We will update this Privacy Policy from time to time by posting the updated Privacy Policy online. We will not change how we handle previously collected information without providing notice and obtaining parental consent where necessary.

 

INFORMATION WE COLLECT AUTOMATICALLY


We use the anonymous information that is automatically collected to support the internal operations of the Platforms. Some of this information is collected through third-party analytics tools. Internal operations include the following:
 

- to monitor metrics such as total number of visitors and traffic;
 

- to understand which activities and services are most popular;
 

- to understand the pages where visitors enter our Sites and the pages viewed;
 

- to reduce the repetition in the promotional messages that users see on our Platforms;
 

- to understand generally the location of our users (e.g., zip code information);
 

- to recognize the browsers used to visit our Sites, so that the content is adapted for the relevant browser; and
 

- to diagnose and fix technology problems.

 
When you visit a Platform, we may use cookies and similar technologies like pixels and web beacons, to collect this anonymous information for the purpose of the internal operations of our Platforms. A “cookie” is a piece of information that a web site or an app transfers to a user’s device for record-keeping purposes. As a user moves from one page or one screen to another, a cookie is used to tell us that it is the same device. We also may use a cookie to keep track of your selections. You may set your device to accept or not accept cookies and you may delete any cookies that you have received. However, should you decide to disable any cookies we place on your device, you may not be able to use certain services or features on our Platforms. A “web beacon” is a one-pixel image (which may be visible or transparent), which may be embedded on a web page or e-mail message, and which may also provide us with information about usage of that page or e-mail message.

 

INFORMATION WE COLLECT VIA REQUEST


We collect the information you provide us as part of the sign up process which we use to tailor and provide the service.

 

If you give us permission, we may then collect audio recordings of you speaking to your child during the Happy Time sessions. We record these conversations entirely, but we ONLY analyze the utterances of the parent. Conversations are converted to text and then text data is scrubbed of personally identifiable information (PII) following HIPAA and SOC-2 guidelines. After conversion and anonymization, data is then analyzed.  Recording only begins when you click the recording start button, and ends automatically after 5 minutes, or sooner if you click any buttons that suggest recording cessation, such as “Stop,” “Pause” or “Reset.” We DO NOT have background recording or listening services as part of our program.

 

We use this audio for two reasons:

 

  1. To provide feedback to parents on their conversation skills, adherence to goals, and more. This allows us to provide parents personalized recommendations for improvement.

  2. To improve our product more generally. The audio data is anonymized to every extent possible, including scrubbing of personally identifiable information (PII) following HIPAA and SOC-2 guidelines)
     

Happypillar collects information based on your use of the app, like when you conduct a Happy Time session with your child. This information includes:
 

  • log information, including usage statistics on how our service is used, device event information, and the device's Internet protocol (IP) address;

  • general location information (such as city or state) based on your device’s IP address; and

  • a unique identifier, which is used to collect and store information about an app or device, such as preferred language, reading and search history, and other settings.


The app collects images of the users if they decide to add a photo to the app or if the parent decides to set up different profiles for their children, as well as a name or nickname of the parent user or they enter into the app. The app also collects voice data to provide analysis and coaching to parents.
 

HOW WE USE THE INFORMATION WE COLLECT


Happypillar uses the information collected for internal operational purposes such as spam and abuse prevention, enforcing content license restrictions, determining preferred language, analyzing usage of the app, and providing, maintaining and improving the service. We also use this data to analyze parents' adherence to the Happypillar program, and provide personalized improvement suggestions. Both child and parent utterances are recorded, but only parent utterances are analyzed. 
 

HOW WE KEEP YOUR INFORMATION SECURE


Our Platforms maintain technical and organizational steps to keep information collected secure, including limiting the number of people who have physical access to our database servers and use of electronic security systems and password protections to guard against unauthorized access.

We take your privacy seriously and treat your data as securely as private medical records. We use industry-leading cryptography and follow HIPAA and SOC 2 compliance guidelines to securely process and store your conversation data. All data collected is transcribed to text before analysis. We scrub all personally-identifiable information (PII) to anonymize your data before it reaches our servers. If ever you want your information deleted from our servers, or you have any questions about Happypillar data security, please email us at hello@happypillar.com.

 

SPECIAL CIRCUMSTANCES


Law Enforcement and Safety. We may access, preserve and share your information when we have a good faith belief that it is necessary to: (i) respond to a legal request (like a search warrant, court order or subpoena) or otherwise to take action because we believe it is required or advisable under the law; (ii) detect, prevent and address fraud and other illegal activity; (iii) respond to your requests for customer service; or (iv) limit our legal liability or to protect the rights, property, or personal safety of ourselves, any user of our Platforms, a third party or the general public including as part of investigations.
 

Business Transfer. If we sell or otherwise transfer part or the whole of Happypillar or our assets to another organization (e.g., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, liquidation), your personal information, and any other information collected through our Platforms may be among the items sold or transferred. The buyer or transferee will be required to honor the commitments we have made in this Privacy Policy.
 

Security Notice. In the unlikely event that we believe that the security of your personal information in our possession or control may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we would endeavor to do so as promptly as possible under the circumstances, and, to the extent you have given us your e-mail address, we may notify you by e-mail. You consent to our use of e-mail as a means of such notification.
 

SERVICE PROVIDERS

 

We contract with third parties to provide certain services to facilitate the operations of our Platforms (“service providers”), such as to manage the analytics information about usage of our Platforms or to process payments. Our service providers will be given access to your information only as is reasonably necessary to provide the services for which they are contracted. They will be required to abide by the terms of this Privacy Policy in their handling of personal information.
 

WHERE WE STORE YOUR INFORMATION

 

The Platforms are governed by and operated in, and in accordance with the laws of, the United States, and are intended for the enjoyment of residents of the United States. Your information collected through a Platform may be stored and processed in the United States or any other country in which we or our service providers maintain facilities. We or our service providers may transfer information that we collect about you, including personal information across borders and from your country or jurisdiction to other countries or jurisdictions around the world.
 

OTHER WEB SITES AND SERVICES
 

Our Platforms may link to other websites or apps, including content offered by third parties that we do not control and whose privacy and data collection practices may differ from ours (“Third Party Platforms”). We are not responsible for the practices employed by any websites or services linked to or from our Platforms, including the information or content contained within them.
 

When you go via our link to Third Party Platforms, you become subject to their terms of use and privacy policies rather than ours. You should review these other website privacy policies regarding any personal information that they may collect about you.
 

ONLINE SAFETY


Involvement in your family’s online lives is one of the most important safety tools available. In addition, we encourage you to educate yourself and your child on privacy concerns. We recommend, as a starting point, the following guide published by the federal government, https://www.onguardonline.gov/articles/0031-kids-privacy.

NOTE

Happypillar Inc. does not itself provide any physician, behavioral health professional, or other healthcare provider services.

 

HAPPYPILLAR INFORMATION

 

The Platforms are operated by Happypillar Inc., located at 7800 Lowdes Drive, Austin, TX 78745, ‪(512) 937-2669‬ hello@happypillar.com.
 

For questions or concerns about the Platforms, or to report potential security vulnerabilities, please write to hello@happypillar.com.
 

Effective date: June 1, 2022.