Effective Date: August 1, 2023

The Happy Sad Company, Inc. (“Happy Sad”) values the privacy of children and of all of its users. This COPPA Privacy Policy (“COPPA Policy”) is designed to comply with the Children’s Online Privacy Protection Act (“COPPA”) and contains important information about how we collect, use, and disclose the personal information we collect from children under thirteen years old who interact with our web application ‘App’ and services including interactions from our website, https://www.thehappysadcompany.com (collectively, the “Services”). 

Happy Sad develops and makes available a social emotional application and content (hosted on its own platform). Happy Sad may partner with foundations, non-profits, or for-profit entities to make our Services available to schools and other educational organizations. In the course of providing these Services, Happy Sad may come into contact with information, including personal information, from the end-user throughout out platform.

Some, but not all, content within our Services is built for children under 13. This COPPA Privacy Policy applies to the information we collect from children under 13 through Happy Sad tools and technology directed towards children.

Happy Sad will handle children’s personal information as described in this COPPA Policy. Any personal information we collect about other users (e.g., adults) will be treated in accordance with the Happy Sad Privacy Policy (“Privacy Policy”). The use of our Services and any dispute over privacy, is subject to this COPPA Policy, the Privacy Policy, and our Terms of Service, including its applicable limitations on damages and the resolution of disputes. Our Terms of Service and Privacy Policy are incorporated by reference into this COPPA Policy.

Who Will Collect Information About Children?

Happy Sad operates our application and Site and will collect children’s personal information as described in this COPPA Policy and our Privacy Policy. We can be contacted at:

• 3001 Bridgeway Blvd, Ste K 468 Sausalito CA 94965

• privacy@thehappysadcompany.com 

• What Information Do We Collect About Children and Why?

• As described in further detail below, we collect some personal information from children so that we can track their progress within our app. Data is retained for education purposes only.

How Information is Collected? 

We may collect information about children directly from children, as well as automatically through a child’s use of our Site and Application Services. We will not require a child to disclose more information than is reasonably necessary to use our Services.

Information We Collect Directly.

For all children accessing our platform, we collect the child’s first name, and last initial. We do not ask children for their full last name. A teacher within our platform is associated with their classroom. The teacher will verify through the Clever, ClassLink or Google SSO process the association of individual children in their classroom. At this point, we utilize grade, first name and last name initial. We also store native information based on feedback from each user including their emotion selection. If a parent directs us to stop collecting and using a child’s personal information, we must disable his or her use of our courses to ensure that no information is collected.

Information We Collect Automatically.

We may automatically collect the following information about a child’s use of our Site through cookies and other technologies: domain name; browser type and operating system; web pages viewed; links clicked; the length of time spent on our Site; the length of time our courses were taken; Google Analytics statistics; the referring URL, or the webpage that led the child to our Site; language information; device name and model; operating system type, name, and version; and activities within our Site. We may also collect IP address, device identifier or a similar unique identifier from users of our Site, including children; we only use such identifiers to support the internal operations of our Site and we do not use such identifiers to collect information about the child outside of our Site.

Other Information We Collect About Children.

We collect information about children’s performance and activities on our Site. This information is for internal use only and will not be disclosed to other entities; however, we do not use this information in personally identifiable form for our own commercial purposes. Before we analyze or use any activity data for our own commercial purposes, we de-identify and/or aggregate such information based on grade level.

How We Use Children’s Information
We use personal information collected from children for the following purposes:

• To provide our Application Services; and

• To respond to customer service and technical support issues and requests.

We de-identify and/or aggregate the information we collect from children under 13 before we use it for any other purposes, as noted below.

Unique Identifiers. We only collect and use unique identifiers, such as IP addresses, as necessary to operate our Site or Services, including to maintain or analyze their functioning; perform network communications; authenticate users or personalize content; and protect the security or integrity of users and our Site and Services. We never use unique identifiers to track users across third-party apps or websites.

Aggregate or De-identified Information. We may use aggregate or de-identified information about children for research, analysis, and similar purposes. When we do so, we strip out names, e-mail, contact information, and other personal identifiers. We may use aggregate or de-identified information for the following purposes:

• To better understand how users access and use our Site and Services;

• To improve our Site and Services and respond to user desires and preferences; and

• To conduct research or analysis, including research and analysis by third parties.

How We Share Children’s Information
We do not sell children’s personal information, and a child may not make his or her personal information public through our services. In general, we may disclose the personal information that we collect about children to provide our Services, to comply with the law, and to protect Happy Sad and other users of our Application Services. For example, we may share children’s personal information as follows:

• Service Providers. We may disclose the information we collect from children to third-party vendors such as Clever, ClassLink, Google, other service providers, contractors, or agents who perform functions on our behalf.

• Analytics Providers. We may work with third party analytics providers to help support the experience of our Services. Such as but not limited to: 

• Mixpanel 

• Google Analytics 

• Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the personal information we have collected from our users to the other company.

• In Response to Legal Process. We also may disclose the personal information we collect in order to comply with the law, a judicial proceeding, court order, subpoena, or other legal process.

• To Protect Us and Others. We also may disclose the personal information we collect where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service, Privacy Policy, or this COPPA Policy, or as evidence in litigation in which Happy Sadis involved.

• With Parents or Teachers. Parents and Teachers / Administrators may request information about the information we have collected from their child by contacting us at privacy@thehappysadcompany.com

• Aggregate and De-Identified Information. We may also use and share aggregate or de-identified information about users with third parties for marketing, research, or similar purposes.

• Company Merger. If we are involved in a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Happy Sad’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding or event, we may transfer the personal information we have collected or maintain to the buyer or other successor.

Your Rights to Review, Delete, and Control Our Use of Children’s Personal Information
Parents have a right to review the information we have collected about their children and students, respectively, and to delete it, and to tell us to stop using it. To exercise these rights, you may contact us at privacy@thehappysadcompany.com. You will be required to authenticate yourself as the child’s parent to receive information about that child. Please note that copies of information may remain in cached or archived form on our systems after you request us to delete it.

Changes to This COPPA Policy
This COPPA Policy is current as of the Effective Date set forth above. We may change this COPPA Policy from time to time, so please be sure to check back periodically. We will post any changes to this COPPA Policy on our Site, at  www.thehappysadcompany.com. If we make any changes to this COPPA Policy that materially affect our practices with regard to the personal information we have previously collected from a child, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site and by direct notification upon login or via email.