Privacy Policy

Effective Date: 2nd June 2026

This “Privacy Policy” explains how Happy Rewards Inc. (“Company” or “we”) collects, uses, discloses, and otherwise processes personal data on behalf of our customers – typically, merchants (any, a “Merchant”) – in connection with our application, Happy Rewards Inc., which runs on the Clover Point of Sale system (“Clover POS”). This Privacy Policy does not apply to the Company’s privacy practices in any other context.

This Privacy Policy and our agreements with Merchants govern the company’s processing of personal data in connection with our application. In the event of any conflict between this Privacy Policy and a customer agreement, the customer agreement will control to the extent permitted by applicable law.

This Privacy Policy is not a substitute for any privacy policy that a Merchant may be required to provide to their customers, personnel, or other individuals.

Information Clover collects

We may collect personal data from or on behalf of Merchants. Merchants determine the scope of the personal data transferred to us or collected by us, and the information we receive may vary by Merchant. Typically, the information we collect on behalf of Merchants includes:

Information that we collect when a customer of a Merchant makes a payment

When a customer makes a payment via a Clover POS, we collect transaction information, which may include personal data. Information about transactions includes the payment card used, the name associated with the payment card, the location of the merchant’s store, the date and time of the transaction, the transaction amount, and information about the goods or services purchased in the transaction.

In addition, we collect: merchant identifier, order identifier, order total or amount, reward eligibility status, reward redemption status, and related transaction timestamps and reference data necessary to process the transaction and provide the app’s tender and rewards functionality.

Additional information that customers of the Merchant provide through the Clover POS, ancillary to a payment

We may collect additional information ancillary to the payment. This information may include:

In addition, we collect: order completion status, discount or reward application details, redemption outcomes, and support or audit information related to the transaction.

Information that we collect about personnel of a Merchant

We may collect information about a Merchant’s personnel and their interactions with the Clover POS, such as clock-in and clock-out times and tips earned, as well as limited account and access information for authorized Merchant users. This may include role identifiers and activity logs and is collected only where a Merchant has configured and authorized such access.

Additional information that Merchants provide to us about their customers or personnel
Merchants may provide us with additional information directly, through access they grant to us, or by other means. The types of information that Merchants may provide to us about their customers include email addresses, phone numbers, purchase history, Merchant account identifiers, store, order history, order totals, tender or redemption status, and reward configuration data. Where applicable, this may also include authorized employee identifiers, roles, and access settings.

How we use the information we collect

We use the personal data we collect for or on behalf of Merchants to provide our services and the functionality of our application. This includes identifying the Merchant account, linking orders to the correct Merchant location, calculating and applying eligible rewards or discounts, processing tender and redemption actions, maintaining transaction and audit records, providing reporting to the Merchant, supporting customer and Merchant inquiries, and preventing fraud or unauthorized use.

We may also use personal data for related internal purposes, including:

In addition, Company may use personal data as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal processes, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern our application; (c) protect our rights, privacy, safety or property, and/or that of you or others; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

How we share information

We may share personal data that we collect with:

Company may disclose personal data to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal processes, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern our application; (c) protect our rights, privacy, safety or property, and/or that of you or others; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

Company may sell or transfer some or all of its business or assets, including your personal data, in connection with a business transaction (or potential business transaction) such as a merger, consolidation, acquisition, reorganization, or sale of assets, or in the event of bankruptcy, in which case we will make reasonable efforts to require the recipient to honor this Privacy Policy.

Your rights and choices

Data subject rights

To the extent that applicable law provides individuals with rights pertaining to their personal information, such as the right to review and request changes to their personal information, individuals should contact the Merchant with any requests pertaining to the Merchant’s use of our application. To the extent that Clover is responsible for responding to data subject rights requests under applicable law, individuals may contact Clover with applicable requests as explained in Clover’s Privacy Notice, https://www.clover.com/privacy-policy. Company will assist a Merchant, or Clover, as applicable, in responding to such requests, subject to our contract with a Merchant or Clover.

Complaints

If you have a complaint about our handling of personal data, you may contact us via the contact information provided below.

Updates

We reserve the right to modify this Privacy Policy at any time. We will notify you of updates by updating the date of this Privacy Policy.

Contact us

You may contact us with any questions, comments, or complaints about this Privacy Policy or our privacy practices via: +1-647-835-8056

Legal basis for processing

Company processes personal data as directed or permitted by the Merchant that uses our application. The Merchant is responsible for establishing a legal basis for our processing of personal data for or on behalf of the Merchant.

Data retention

Subject to our agreement with a Merchant, Company retains personal data for as long as necessary to (a) provide our products and services; (b) comply with legal obligations; (c) resolve disputes; and (d) enforce the terms of any agreement we may have with a Merchant. You may contact us for additional information about our data retention practices in connection with the application.

Right to information, access, and deletion

You can request to exercise your information, access, and deletion rights in the following ways:

Sale of personal information

We do not sell, as defined under the CCPA, your Personal Information to third parties.

In the preceding twelve (12) months, we have not sold any personal information.

Personal information that we collect, use, and share.

The chart below summarizes our collection, use, and sharing of Personal Information during the last 12 months before the effective date of this Privacy Policy. We describe the sources through which we collect your Personal Information in the section above titled The Personal Data We Collect, and describe the purposes for which we collect, use, sell, and share this information in the section above titled How We Use Your Personal Data and The Parties With Whom We Share Your Personal Data.

Category (see the glossary below for definitions) Do we collect this information? Do we share this information for business purposes?
Identifiers Yes Yes
Online Identifiers Yes Yes
Protected Classification Characteristics No No
Commercial Information Yes Yes
Biometric Information No No
Internet or Network Information No No
Geolocation Data No No
Sensory Information No No
Professional or Employment Information No No
Education Information No No
Inferences No No
Financial Information No No
Medical Information No No

Glossary

Category Definition
Categories of Personal Information Date Elements within the Category
Biometric Information An individual’s physiological, biological or behavioral characteristics, including DNA, that can be used, singly or in combination with each other or with other identifying data, to establish an individual’s identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a face print, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.
Transaction History Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Financial Information Bank account number, debit or credit card numbers, insurance policy number, and other financial information.
Geolocation Data Precise location, e.g., derived from GPS coordinates or telemetry data.
Identifiers Real name, alias, postal address, unique personal identifier, customer number, email address, account name, and other similar identifiers.
Government-issued ID Social security number, driver’s license, passport, or other government-issued ID, including an ID number or image.
Medical Information Personal information about an individual’s health or healthcare, including health insurance information.
Internet or Network Information Browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement.
Online Identifiers An online identifier or other persistent identifier that can be used to recognize a person, family or device, over time and across different services, including but not limited to, a device identifier; an Internet Protocol address; cookies, beacons, pixel tags, mobile ad identifiers, or similar technology; customer number, unique pseudonym, or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers (i.e., the identification of a person or a device to a degree of certainty of more probable than not) that can be used to identify a particular person or device.
Physical Description An individual’s physical characteristics or description (e.g., hair color, eye color, height, weight).
Professional or Employment Information Information relating to a person’s current, past, or prospective employment or professional experience (e.g., job history, performance evaluations) and educational background.
Protected Classification Characteristics Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Sensory Information Audio, electronic, visual, thermal, olfactory, or similar information.

Samkit Dharmendrabhai Maniar
57 Ripley Crescent,

Brampton. ON.

L6Y 5C4.
M: +1-647-835-8056

E: [email protected] 

 

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