PRIVACY POLICY

PRIVACY POLICY

WE CARE ABOUT YOUR PRIVACY

What is the purpose of this document?
In this Privacy Policy, we have summarized the key points regarding the protection of your personal data and how we process it. If you require more information about specific processes, you can contact us using the details provided below.

Who are we?
“HAPPINESS” Ltd. provides food and beverage delivery services from the menu of restaurant chains with the brands “Happy,” “Captain Cook,” and other commercial brands (collectively referred to as “The Restaurants” in this Privacy Policy).
As a leading home food delivery service and a representative of the largest food community in Bulgaria, HAPPY is committed to safeguarding the privacy of everyone in our community. This means we will protect the personal information of all visitors who access our websites or services via any mobile application, platform, or device.

“Happiness” Ltd. is a company registered in the Commercial Register with the Registry Agency under the Unified Identification Code (UIC) 103279218, with its registered office and management address at: Varna, “Levski” District, 25 Rоза Street, phone: +359 700 19 000, email: delivery@happy.bg. We are the data controller according to the provisions of the Personal Data Protection Act.

How to contact us?
Correspondence Address: Varna, “Odessos” District, 25 Tsar Osvoboditel Blvd., 1st floor, phone: +359 882 999 010 or +359 700 19000, email: delivery@happy.bg.

How to contact our Data Protection Officer?

Address: Varna, "Odessos" District, 25 Tsar Osvoboditel Blvd., 1st floor
Email: dataprotection@happy.bg
Data protection and information security are part of our corporate culture and policy.

What information can I find in this Privacy Policy?
This Privacy Policy will provide you with comprehensive information in clear and accessible language about what actions are taken with the personal data you provide to "Happiness" Ltd. (hereinafter referred to as "HAPPY"), including:

• What personal data do we collect about you?
• What is the purpose of collecting this data?
• For how long do we store the provided personal data?
• With whom do we share your personal data?
• How do we inform you of changes to our Privacy Policy?
• What types of cookies do we use to improve your experience on our website?
• What are your rights regarding the personal data you have provided?

With this Privacy Policy, "Happiness" Ltd. declares that it implements all technical and organizational measures for the protection of personal data of individuals as prescribed by national and European legislation.

What are personal data?
Any information and data that can identify a natural person, either directly or indirectly.
For example, indirect identification could be just your mobile phone number. In this case, a combination with another identifier would be necessary to establish your identity, such as full name and mobile phone number.
Direct identification is achieved when you provide a unique identifier such as a National ID number, Personal Identification Number (PIN), or customer code.

What personal data does HAPPY collect about you and for what purposes (why)?

To provide you with effective access to our services, HAPPY collects the following information and personal data about you.
Here are the main categories of personal data we collect about you and the reasons (purposes) for which we process this personal data:

Information you provide voluntarily:

• Registration information when you create a profile on the HAPPY website – https://dostavka.happy.bg/ so that we can:
  1. Create your profile to allow you to place orders in accordance with our Terms;
  2. Identify you when you log into your profile;
  3. Contact you to fulfill the services we offer; and
  4. Notify you about changes or updates to our Terms and Privacy Policy.

Transaction information when you place an order from a restaurant, for the following purposes:

1. To process your order and issue an invoice/charge you (we specify that HAPPY never stores your credit/debit card information in our systems);
2. Communicate your order to the restaurant;
3. Send you updates on the status of your order;
4. Respond to your requests and questions about orders and resolve any potential issues;
5. Perform analysis and surveys to improve our Services; and
6. Protect you and the Services we provide by attempting to detect and prevent fraud or other activities that violate our Terms or rules related to HAPPY’s Services.

Information about your marketing preferences, so that we can:

1. Send you personalized marketing and promotional messages about our delivery services, including the food, drinks, and restaurant services offered by the Restaurants that you may be interested in.

Information from feedback you provide regarding your opinion on our services, which we use to:

1. Respond to your questions or inquiries;

2. To publish reviews that you send us about our services, with your consent for such publication;
3. To perform analyses and surveys to improve and develop our services.

Information about your activities and actions in using our services, so that we can:

1. Provide you with a better experience when using our services;
2. Give you access to the history and details of past orders;
3. Provide you with other services at your request.

Cookies and similar technologies, so that we can:

1. Measure and analyze the usage and effectiveness of our services;
2. Personalize and optimize the targeting of ads for our services on other websites and platforms; and
3. Provide location-based services if you choose to share your geographical location.

Information we receive from other sources – third parties:

1. Analytical reports from the analysis and research of our marketing activities to measure the effectiveness of our marketing campaigns for our services; and
2. To better understand your preferences so that we can tailor our marketing campaigns and services according to your desires.

Categories of personal data we process:

• Full name, phone number, email address, date of birth, location, address, when filling out different forms on our website, for creating initial registration, subscribing to our newsletter/marketing messages, and completing the inquiry form;
• When paying with a bank card – transaction status data (successful/unsuccessful);
• Information about your orders;
• Technical data automatically sent to us when using our services through our website or mobile applications – IP address, device information you are using.

Technical data automatically sent to us when you use our mobile applications – information about your mobile device, IMSI device number, GPS coordinates;

• Cookie data – to identify your browser or device.

What does processing of personal data mean?

Processing of personal data includes collection, storage, destruction, transmission, correction, updating, deletion, destruction, and all other actions carried out with your personal data.

On what basis (why) does HAPPY process personal data for you?

The legal basis for collecting and using your personal data, as described above, will depend on the specific context in which we collect it.

The main reason for collecting and using your personal data is to fulfill our contract with you (i.e., to ensure that you receive your order when you want it).

We will also use your personal data when it is in the performance of our legitimate business interests, but only when these interests do not override your interests related to the protection of your personal data or other rights and freedoms.

In some cases, we may have a legal obligation – a legal basis to collect personal data from you (e.g., in the case of legal proceedings), or we may need to process or share it with others to "protect your vital interests" (such as saving your life) or those of another person (e.g., if someone's life is in danger).

If we ask you to provide personal data in order to comply with a legal requirement or to enter into a contract with you, we will notify you of the circumstances at the relevant time and inform you whether the provision of personal data is mandatory or not (and we will also explain the potential consequences of refusing to provide personal data).

Also, if we collect and use your personal data relying on our legitimate interests (or those of a third party), we will inform you at the relevant time about these legitimate interests.

If you have any questions or need further information regarding the legal basis on which we collect and use your personal data, please contact us using the contact details provided in the "How to contact us?" section above.

HAPPY collects personal data only after obtaining your explicit, clear, freely given, and unambiguous consent for the purposes of processing.

For example, with your expressed consent, HAPPY may use the personal data you provide for marketing purposes, to send you the latest promotions, as well as any other marketing and advertising messages, news, information, upcoming campaigns, promo codes, promotions, and special offers related to our delivery services, including the food, drinks, and restaurant services offered by the Restaurants, which you may be interested in.

It is explicitly stated that your consent to this privacy policy will not be considered as consent for using your provided data for marketing purposes. In order for your data to be used for such purposes, you must separately provide explicit consent by ticking a designated checkbox on our website, application, or by another appropriate means.

Consent for processing your personal data is given when you register on our website or fill out any forms available on our website (for inquiries and for subscribing to newsletters).

The consent you provide may be withdrawn at any time by sending an email to delivery@happy.bg or by submitting a written request to HAPPY’s correspondence address in Varna, Odessos District, Tsar Osvoboditel Blvd. No. 25, floor 1.

Withdrawal of consent can apply to one or more purposes for which your data is processed. For example, if you withdraw your consent to receive marketing messages, your contact details will continue to be used to maintain your profile on the website and to process your orders. If you withdraw your consent for the processing of data without which we cannot maintain your profile on the website, your profile will be deleted, and you will need to provide your data again in order to continue using our services.

How do we obtain your personal data? How do we process your personal data?

To provide products and services, HAPPY processes (collects) the personal data you provide concerning your physical and economic identity in the following ways:

• By filling out forms provided on HAPPY’s website. The forms are filled out on our website in the appropriate sections with fields for your personal data.
• through visiting the online portal to use the services on our website;
• when updating your data upon your request and filling out an update form either on paper or in an electronic format;
• through using our mobile applications – Happy Delivery;
• by using online identifiers to collect information about IP addresses, cookies data, operating systems, and browser types;
• by subscribing to the email newsletter.

Email / Newsletter

When you subscribe to our email newsletter, you will be asked to enter your email address. As a subscriber to the newsletter, we maintain a record of your IP address, the emails you open, and the links you click in these emails, so that we can more accurately recommend content, random offers from third parties, and products that you may find valuable. Any personal information you provide, including your email address, will not be shared or sold to third parties. However, if you participate in a raffle, your email address may be provided to the respective provider for registration/activation and ongoing support. Under no circumstances will we request credit card information for advertising purposes or for receiving the email newsletter.

Mobile Applications

HAPPY DELIVERY MOBILE
No personal data provided to us through HAPPY DELIVERY MOBILE will be shared with third parties.
HAPPY DELIVERY MOBILE will use your public IP address to identify your location and show you nearby restaurant locations or the current menu for the area (and settlement) you are in, as well as provide information on delivery availability for that area. Your IP address or location will not be used for any other purposes.

How long do we store and process your data before we delete it?

HAPPY will retain your personal information for no longer than necessary to fulfill the purposes outlined in this Privacy Policy. Depending on the legal basis on which we process your personal data, the storage period may vary.
Your personal data is stored by us for a period of 5 years from the termination of our contractual relationship if we process personal data for the execution of contractual obligations.

Contractual Obligations to You:
After the expiration of this period and if there is no legal basis for continuing the storage of your personal data, your information will be destroyed. Your personal information will be deleted from our system.

When you provide your data for the purpose of creating your user profile on the website, mobile application, etc., it is understood that you have an interest in us keeping this data until you decide to delete or deactivate it.
We may also retain certain elements of your personal information for a period after you delete or deactivate your user profile for our legitimate operations, such as maintaining archives and complying with our legal obligations. Each time we retain your information, we will do so in accordance with applicable laws.

If you have given your consent for your data to be used for receiving marketing/advertising messages, the processing period for this purpose is 5 years or until you withdraw your consent.

Call Center:
When placing an order via phone through our call center, we collect data from you – name, contact phone number, and delivery address, voice.
All calls to the call center are recorded and stored by HAPPY for up to 6 months from the time of the conversation in order to fulfill your order and ensure the accurate and timely provision of our services.
Phone conversations with suppliers, for example, to clarify an address or to notify that the delivery has arrived at the specified location, are also recorded and stored as outlined above.
If you do not wish to be recorded, please terminate the call or do not accept it, in which case, however, your order may not be able to be processed.
Your phone numbers are not visible to our call center staff or to suppliers, as we have implemented modern and up-to-date measures to protect your information, identity, and privacy by default, following the principle of "privacy by default."

Who can we share your personal data with?
HAPPY DOES NOT share your personal data with third parties without your explicit consent and does not sell its databases.

HAPPY undertakes not to disclose your personal data to third parties without your explicit consent, except when necessary for the fulfillment of contractual obligations towards you.

HAPPY may share your personal information (your personal data) with the following recipients (in each case, we will ensure that we have appropriate protective and contractual guarantees to protect it):

1. Partner companies managing the Restaurants where your orders have been placed for fulfillment;
2. HAPPY companies within our group;
3. Third parties who support our services (e.g., marketing or promotion partners in the food, beverage, and entertainment sectors based on your preferences, courier services, companies related to web hosting);
4. Any law enforcement or regulatory body, government agency, court, or other third party when disclosure is required under applicable laws or regulations;
5. New owners or reorganized entities in the event of restructuring, sale, purchase, or joint venture affecting our business;
6. Any other person, provided you give your consent. We will never sell, distribute, or share your personal information in any other way unless we have your explicit permission.

Are there other cases in which we may share your personal data?
Your personal data is shared with third parties in the following cases:

• Upon request of the individual who provided the data, the subject of personal data protection;
• Upon request of competent authorities in accordance with the laws of the Republic of Bulgaria and the European Union. In all of the above cases, the recipients of your personal data have declared that they provide an adequate level of protection for your personal data, including foreign companies positioned within the EU and EEA. Regarding companies located outside the framework of the EU and EEA,

EU and EEA, in each specific case, the relevant company guarantees that it provides an adequate level of protection for personal data, in compliance with the requirements of European legislation.

Use of "Cookies"

General Provisions
"Cookies" are small text files that are stored on your computer when you visit our website. To learn more, click HERE.

What are your rights regarding the provided personal data?

If you are a registered user of HAPPY, you have access to your profile at any time to review and update your personal information (i.e., your personal data). You can also contact us to request that we update or delete your personal data, or restrict its processing.
Additionally, you have the right to unsubscribe from marketing communications that we send to you by using the unsubscribe function in any marketing communication you receive from us, or by sending an email to delivery@happy.bg.

In addition, according to Bulgarian and European legislation, including the GDPR - Regulation (EU) 2016/679 of the EU and the Council (General Data Protection Regulation) on the protection of personal data, you can exercise the following rights:

• Right of access to your personal data processed by HAPPY and to obtain a copy of them.
• Right to request correction if you identify inaccuracies or need to update your personal data by sending an email to delivery@happy.bg.
• Right to request blocking of your personal data or restriction of its processing, in cases defined by law and the Regulation.
• Right to request deletion, i.e., the erasure of your personal data by HAPPY, if the conditions for this are met.
• Right to object to the processing of your personal data for direct marketing purposes by using the "unsubscribe" link provided in every email containing marketing information about our products.
• Right to object to the sharing of your personal data with third parties by logging into your personal profile on our website and unchecking the option related to providing personal data to third parties.
• Right to withdraw your consent at any time for the processing of your personal data for the purposes for which you have given consent, such as for marketing, by sending an email to: delivery@happy.bg.
• Right to request portability of your personal data in a structured, machine-readable format that is commonly used.
• Right to file a complaint or request protection of your rights with the Personal Data Protection Commission if the conditions for this are met.

You can exercise all these rights at any time while your personal data is being processed.

Are you obligated to provide us with your personal data?

In order to provide our products and services, we collect and process your personal data. We process them also to fulfill legal obligations.

If you refuse to voluntarily provide the requested personal data, HAPPY will not be able to provide its products and services, for example, you will not be able to receive food delivery.

Changes to Privacy Policies

In the future, it may be necessary to update this Privacy Policy from time to time in response to changing legal, technical, or business processes.

We recommend that you periodically review this page for the latest information on our privacy practices.

In the event that changes to this Privacy Policy involve new purposes for processing personal data or other circumstances requiring your explicit consent, we declare that we will notify you by sending an email to the provided email address, inviting you to kindly confirm or refuse to give your consent.

This will provide you with the opportunity to cease using some or all of the services and/or exercise your rights, some of which are explicitly mentioned above.

These privacy policies are adopted by "HAPPINESS" Ltd. and are effective as of May 22, 2018.