PRIVACY POLICY

Last updated April 20, 2025

This Privacy Notice for Silke Holguin-Butters ('we', 'us', or 'our'), describes how and why we might access, collect, store, use, and/or share ('process') your personal information when you use our services ('Services'), including when you:

Visit our website at https://www.happyhealthywfh.com

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at [email protected].

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

When and with whom do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have adequate organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.

TABLE OF CONTENTS

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request ...

If you are located outside the United States, and you provide personal information to us, please be aware that your information may be transferred to, stored by, and processed by us in our facilities and in the facilities of the third parties with whom we may share your personal information (see 'WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?' above), in and other countries.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law.

European Commission's Standard Contractual Clauses:

We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

Data Privacy Framework

We comply with the EU-US Data Privacy Framework (EU-US DPF) and the UK Extension to the EU-US DPF as set forth by the US Department of Commerce. We have certified to the US Department of Commerce that we adhere to the EU-US Data Privacy Framework Principles (EU-US DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-US DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-US DPF. If there is any conflict between the terms in this Privacy Notice and the Data Privacy Framework Principles, the Principles shall govern. Learn more about the Data Privacy Framework program.

Pursuant to the Data Privacy Framework, EU individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under the Data Privacy Framework, should direct their query to [email protected]. If requested to remove data, we will respond within a reasonable timeframe.

If we have received your personal information in the United States and subsequently transfer that information to a third party acting as our agent, and such third party agent processes your personal information in a manner inconsistent with the Data Privacy Framework Principles, we will remain liable unless we can prove we are not responsible for the event giving rise to the damage.

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorised. To request to limit the use and disclosure of your personal information, please submit a written request to [email protected].

In compliance with the Data Privacy Framework Principles, we commit to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the Data Privacy Framework. EU individuals with Data Privacy Framework inquiries or complaints should first contact us by email at [email protected]. If you do not receive a timely acknowledgement of your complaint or if your complaint is not satisfactorily addressed, ...

If your Data Privacy Framework complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms.

We are subject to the investigatory and enforcement powers of the . In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Please be sure to review the following sections of this Privacy Notice for additional details relevant to our participation in the Data Privacy Framework program:

WHAT INFORMATION DO WE COLLECT? To learn more about the types of personal data we collect.
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When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the ...

If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at [email protected].

WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section ...

CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognising or honouring DNT signals, we do not respond to them at this time.

DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Depending on where you are located, you may have certain rights regarding your personal information.

State privacy laws have granted consumers residing in certain states with the right to request information about whether their personal information is sold or shared, to opt out of the sale or sharing of their personal information, and to know:

the categories of personal information collected by us
the categories of sources from which the personal information is collected
the business or commercial purpose for collecting, selling, or sharing personal information
the categories of third parties to whom we disclose personal information
the specific pieces of personal information we have collected about you

We may have collected the following categories of personal information in the past twelve (12) months and disclosed them for a business or commercial purpose:

Category of Personal Information	Examples	Disclosed for a Business or Commercial Purpose?
A. Identifiers	Contact details, such as your real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name	YES
B. Personal information categories listed in California Customer Records statute	Name, contact information, education, employment, employment history, and financial information	YES
C. Protected classification characteristics under California or federal law	Gender and date of birth	NO
D. Commercial information	Transaction information, purchase history, preferences, and content you engage with	NO
E. Biometric information	Fingerprints and voiceprints	NO
F. Internet or other similar network activity	Browsing history, search history, online behaviour, interest data, and interactions with our and other websites, applications, systems, and advertisements	YES
G. Geolocation data	Device location	NO
H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information	NO
I. Professional or employment-related information	Current job position and prior job history	NO
J. Non-public personal information (non-Pll)		NO
K. Inferences drawn from other personal information	Inferences used to create a profile about your interests and preferences	NO
L. Sensitive personal Information	Account login information and health data	YES

We only collect sensitive personal information, as defined by applicable privacy laws or the purposes allowed by law or with your consent. Sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You may have the right to limit the use or disclosure of your sensitive personal information. We do not collect or process sensitive ...

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information to in the section, 'WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?'.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be 'selling' of your personal information.

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

Your rights regarding your personal information

Right to request deletion of the data - You can ask for the deletion of your personal information that we collect and store, subject to certain exceptions.

Right to request correction of inaccurate data - You have the right to request that we correct inaccurate personal information we maintain about you.

Right to Opt-Out of the Sale or Sharing of Personal Information - You have the right to direct us not to sell or share your personal information. To submit such a request, please contact us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.

Right to Know - Depending on the applicable law, you may have the right to know and see the following about your personal information that we have collected over the past twelve (12) months, including:

The categories of personal information we have collected about you
The categories of sources from which the personal information is collected
The business or commercial purpose for collecting, selling, or sharing your personal information
The categories of third parties to whom we disclosed your personal information
The specific pieces of personal information we have collected about you

You also have the right to obtain a list of the categories of third parties to whom we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland)

Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)
Right to review, understand, question, and correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Minnesota)
Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California)
Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law ...

Under certain US state data protection laws, you can designate an authorised agent to make a request on your behalf. We may deny a request from an authorised agent that does not submit proof that they have been validly authorised to act on your behalf in accordance with applicable laws.

Request Verification Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorised agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at [email protected]. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California 'Shine The Light' Law California Civil Code Section 1798.83, also known as the 'Shine The Light' law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?'.

Cookies and other tracking technologies

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Our Cookie Notice provides specific information about how we use such technologies and how you can refuse certain cookies.

We may share your information with third-party vendors, service providers, contractors, or agents ('third parties') who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. Your personal information may be transferred to, stored, and processed in the United States and other countries. Our third parties are not allowed to use your personal information for their own business purposes.

Google Analytics We may share your information with Google Analytics to track and analyse the use of the Services. The Google Analytics Advertising Features that we may use include: Remarketing with Google Analytics, ...

To the extent these online tracking technologies are deemed to be a 'sale'/'sharing' (which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under section 'DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?'.

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

HOW LONG DO WE KEEP YOUR INFORMATION?

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

DO WE MAKE UPDATES TO THIS NOTICE?

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated 'Revised' date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO) by email at [email protected], or ...

You can also find more information and updates on our FAQ page.

YOUR PRIVACY RIGHTS

California Residents

The California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) requires us to provide additional information to California residents about their privacy rights.

Categories of personal information we collect and the purposes for which we use and disclose that information can be found in the table titled "DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?" above.

Your Rights under the CCPA/CPRA

Right to Know You have the right to know and see what personal information we have collected about you, including the categories of personal information; the categories of sources from which the personal information is collected; the business or commercial purpose for collecting, selling, or sharing your personal information; the categories of third parties to whom we disclose personal information; and the specific pieces of personal information we have collected about you.
Right to Correct You have the right to request that we correct any inaccurate personal information we maintain about you.
Right to Delete You have the right to request that we delete your personal information that we have collected from you and retain, subject to certain exceptions.
Right to Opt Out of the Sale or Sharing of Personal Information We do not sell or share personal information. If our business practices change in the future, we will update our privacy notice and enable you to opt out.
Right to Limit Use and Disclosure of Sensitive Personal Information You have the right to direct us to only use your sensitive personal information for those purposes that are necessary to provide the Services or goods reasonably expected by an average consumer.
Non-Discrimination We will not discriminate against you for exercising any of your CCPA/CPRA rights.

Exercising your rights

To exercise your rights described above, please submit your request to us by either:

Emailing us at [email protected]
Visiting https://app.termly.io/notify/635d3238-614a-48c6-aa98-d37e5463bbed

We will respond to your request within 45 days of receipt. We may need to verify your identity before completing your request.

If you use an authorised agent to make a request on your behalf, we may require that you:

Provide the authorised agent signed permission to make such requests
Verify your own identity directly with us

We may deny a request from an authorised agent that does not submit proof that they have been validly authorised to act on your behalf in accordance with the CCPA/CPRA.

Right to Appeal If we decline to take action regarding your request, you have the right to appeal our decision. You can submit your appeal by emailing us at [email protected]. Within 60 days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to the California Attorney General at https://oag.ca.gov/contact/consumer-complaint-against-business.

You have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to request we limit the use or disclosure of your personal information or withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please fill out and submit a data subject access request.

PRIVACY POLICY

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