PRIVACY POLICY

Policy version: 12 December 2025

1 Introduction

This Privacy Policy is provided by Netarcs Ltd, company number: 04614488 with registered offices located at C/O Mericrest, 8-10 Pembroke Building Cumberland Park Scrubs Lane, London, NW10 6RE, (‘we’, ‘our’ or ‘us’) for use of our website www.happimate.com (Website), the ‘Happimate’ App (App), and services including any applications or software we provide (Services).

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on how and why we collect, store, use and share any information relating to you (your personal data).

It also explains your rights in relation to your personal data and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your personal data is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).

We are the controller of personal data obtained via the Website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

2 What this policy applies to

This privacy policy relates to your use of the Website, App and Services only.

The Website may link to or rely on other apps, websites, APIs or services owned and operated by us or by certain trusted third parties to enable us to provide you with Website. These other apps, websites, APIs or services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other apps, websites or services, please consult their privacy policies as appropriate. For more information see the section ‘Who we share your personal data with’ below.

3 Personal data we collect about you

The personal data we collect about you depends on the particular activities carried out through the Services. We will collect and use the following personal data about you:

Category of data	In more detail
Identity and account information	· your name; · your email address; · your age or date of birth; · your username and password; · any other account or profile details you choose to provide.
Contact information	· your email address; · your telephone number; · your residential or postal address, where relevant; · information you provide when contacting us for support or enquiries.
Data you submit through the App or Services	· prompts, text inputs, and other content you submit to AI-powered features; · AI-generated outputs, including conversations, meditation content, sleep stories, and other personalised content generated through the App; · your saved preferences, favourites, feature selections, and usage history within the App; · feedback, support messages, reports, and other communications you send to us. (while such data may not always be personal data as defined at law in all cases we will assume it is and treat it in accordance with this policy as if it were)
Technical and usage information	· your activity on, and use of, the Website, App, and Services; · your preferences, interests, and manner of use; · IP address; · device type; · IMEI number or other device identifiers; · operating system; · mobile network information; · app version number; · storage usage; · data usage; · time zone settings; · crash logs, diagnostics, and performance data.
Transaction and subscription information	· information relating to your subscription status; · purchase, billing, and renewal information made available to us by the relevant app store provider; · records relating to promotional offers, trials, cancellations, or refunds.
Enquiry and support information	· your name and email address; · the content of your enquiry or support request; · any information you provide when reporting a problem or requesting assistance.

If you do not provide the personal data we ask for where it is required, this may prevent us from providing some or all of the Website, App, or Services to you.

We collect and use this personal data for the purposes described in the section How and why we use your personal data below.

4 Special category personal data or Sensitive Data

We do not intentionally require users to provide special category personal data, such as health information, in order to use the App or Services.

However, you may choose to enter information into AI-powered features or free-text fields that includes sensitive personal data. Where this occurs, we will process that information only as necessary to provide the relevant service requested by you, in accordance with this Privacy Policy and applicable law.

If you are between 13 and 17 years old, you should avoid entering sensitive personal data unless it is necessary for your use of the App.

5 How your personal data is collected

We collect Personal Data from you:

(a) directly, when you enter or send us information, such as when you:

· register for an account;

· use the App or Website;

· contact us, including by email;

· send us feedback;

· purchase or request Services;

· engage with AI-powered features within the App; and

(b) indirectly, such as through your browsing activity, technical usage data, device information, and analytics collected while using the Website, App, or Services.

We also use cookies and similar technologies on our Website. More information about this is available in our Cookies Policy.

6 How and why we use your personal data

Under data protection law, we may only use your personal data if we have a lawful basis for doing so, including:

(i) where you have given consent

(ii) to comply with our legal and regulatory obligations

(iii) for the performance of a contract with you or to take steps at your request before entering into a contract, or

(iv) for our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your information, provided that this is not overridden by your own rights and interests.

We may use your personal data for the following purposes:

What we use your personal data for	Our reasons
To provide the Website, App, and Services to you	to perform our contract with you or take steps at your request before entering into a contract.
To create and manage your account	to perform our contract with you and to keep accurate account records.
To provide AI-powered features and generate personalised content, including conversations, meditation content, sleep stories, and other outputs based on your inputs.	to perform our contract with you and provide the Services you request.
To personalise your experience, including remembering your preferences, saved content, favourites, usage history, and feature selections.	to perform our contract with you and, where appropriate, for our legitimate interests in improving usability and user experience.
To process subscriptions, purchases, renewals, cancellations, promotional offers, and refunds	to perform our contract with you and comply with legal and financial obligations.
To communicate with you about the Services, including to send service messages, important notices, changes to terms or policies, support communications, and account-related updates.	to comply with legal obligations, perform our contract with you, and for our legitimate interests in running the Services properly.
To provide customer support and respond to enquiries	to perform our contract with you and for our legitimate interests in supporting users and resolving issues.
To maintain, monitor, improve, and develop the Website, App, and Services, including through testing, analytics, debugging, quality control, product improvement, and internal reporting.	for our legitimate interests in improving our products and services.
To protect the security of systems, users, and data, including for fraud prevention, abuse prevention, enforcing our terms, monitoring for misuse, and ensuring system integrity.	to comply with legal obligations and for our legitimate interests in protecting our business, systems, users, and data.
To enforce legal rights or defend legal claims	to comply with legal obligations and for our legitimate interests in protecting our business and legal position.
To comply with legal and regulatory obligations	To comply with legal and regulatory obligations
To comply with our legal and regulatory obligations	Depending on the circumstances: · to perform our contract with you or to take steps at your request before entering into a contract ( · to comply with our legal and regulatory obligationswhere neither of the above apply, for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about their accounts and new products
To share personal data in connection with a corporate transaction or restructuring, including a merger, acquisition, investment, asset sale, or insolvency event. Where possible, information will be anonymised and only shared where necessary.	to comply with legal obligations and for our legitimate interests in protecting, managing, and developing our business.

We do not use your personal data to train third-party general AI models unless expressly stated otherwise and permitted by law.

7 Who we share your personal data with

We may routinely share personal data with trusted service providers we use to operate our business and provide the Website, App, and Services, including:

· hosting providers;

· cloud storage providers;

· analytics providers;

· app developers and technical service providers;

· customer support tools;

· payment and app store providers;

· email and communication service providers; and

· AI service providers, such as OpenAI, where needed to power certain App features.

We only allow those service providers to handle your personal data where we are satisfied that they take appropriate measures to protect it. We also put contractual safeguards in place so that they may use your personal data only for specified purposes.

We may also share your personal data where necessary with:

· professional advisers, such as solicitors, accountants, auditors, and insurers;

· regulators, courts, tribunals, law enforcement agencies, or public authorities where required by law or to protect our legal rights;

· other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, investment, or insolvency event.

If you would like more information about who we share your personal data with and why, please contact us using the details below.

We do not sell your personal data to third parties.

8 How long your personal data will be kept

We will keep your personal data for as long as necessary to provide the Website, App, and Services, maintain your account, comply with legal, tax, accounting, and regulatory obligations, resolve disputes, enforce our agreements, and protect our legitimate business interests.

In general, we will keep your personal data while your account remains active and for a period of up to 6 years afterwards where necessary for legal, accounting, tax, audit, fraud prevention, or claims-related purposes.

When personal data is no longer needed for those purposes, we will securely delete it or anonymise it.

9 Transferring your personal data out of the UK

As part of providing the Services, we may share your personal data with third parties based outside of the UK.

Under UK data protection laws, we can only transfer your personal data to a country outside the UK where: the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR; there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or a specific exception applies under relevant data protection law. Accordingly, if we were to start transferring your personal data from the UK to:

§ The EEA: we would rely on the adequacy finding granted by the UK to the EU under the Withdrawal Agreement to do; for any transfers from the EU to the UK, we would rely on the adequacy regulation granted to the UK under the Adequacy Decision.

§ Any country located outside the UK/EEA: we would rely on appropriate safeguards under the UK GDPR, such as by relying on an Adequacy Decision being in place for that country, or entering into an International Data Transfer Agreement.

In the event we could not or choose not to continue to rely on either of those mechanisms at any time we would not transfer your personal data outside the UK unless we could do so on the basis of an alternative mechanism or exception provided by UK data protection law.

10 Your rights

You generally have the following rights, which you can usually exercise free of charge. For more information regarding these rights, please visit the ICO website here.

Access to a copy of your personal data	The right to be provided with a copy of your personal data.
Correction (also known as rectification)	The right to require us to correct any mistakes in your personal data.
Erasure (also known as the right to be forgotten)	The right to require us to delete your personal data—in certain situations.
Restriction of use	The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data.
Data portability	The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.
To object to use	The right to object: · at any time to your personal data being used for direct marketing (including profiling) · in certain other situations to our continued use of your personal data, e.g. where we use you personal data for our legitimate interests.
Rights relating to automated decision-making	The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. We do not carry out solely automated decision-making of that kind based on personal data collected through the Website, App or Services.

If you would like to exercise any of your rights, please contact us using the details below. When contacting us, please provide enough information to identify yourself and let us know which right you wish to exercise and the information to which your request relates.

You can find more information about your rights on the Information Commissioner’s Office website.

11 Keeping your personal data secure

We take appropriate technical and organisational measures to protect personal data against accidental loss, unauthorised access, unlawful use, alteration, disclosure, or destruction.

We limit access to your personal data to those who have a genuine business need to access it.

We also have procedures in place to deal with suspected personal data breaches and will notify you and any applicable regulator where we are legally required to do so.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

12 How to complain

If you have any questions or concerns about how we use your personal data, please contact us first. We hope we will be able to resolve any issue.

You also have the right to lodge a complaint with the Information Commissioner’s Office.

The Information Commissioner can be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.

13 Changes to this privacy policy

We may update this Privacy Policy from time to time. When we make significant changes, we will take reasonable steps to inform you, for example through the Website, the App, or by email where appropriate.

14 How to contact us

If you have any questions about this Privacy Policy, the personal data we hold about you, or if you wish to exercise a right under data protection law or make a complaint, you can contact us at:

Email: privacy@happimate.com

Post:
Netarcs Ltd
C/O Mericrest, 8-10 Pembroke Building
Cumberland Park, Scrubs Lane
London, NW10 6RE
United Kingdom