I. PRESENTATION

Control Mode (“Control Mode”, “Us”, “We”) respects your right to privacy and understands the importance of protecting your personal data (“Data”).

We have adopted this privacy policy (the “Policy”) to explain how we collect, process, store, share, and protect the Data that you provide to Us or that We collect when you use our application (“Application”), complete any in-app activities or questionnaires (“Questionnaires”), subscribe to our services, or use any other features operated by Control Mode (our “Services”).

We reserve the right to modify the terms of this Policy at any time and at our sole discretion. If We make changes to this Policy, We will publish the updated version, depending on the medium, on the Application and/or other relevant platforms so that you are fully informed. Any changes to the Policy will take effect thirty (30) days after publication. Your continued use of the Services after the effective date constitutes acceptance of the updated Policy.

II. WHAT TYPE AND WHEN WE COLLECT YOUR DATA

On the Application

We collect the following types of Data when you use the Application and our Services:

• Account and contact information, such as your name, profile picture, email address, and password, when you create or manage your account;
• Routine and usage information, such as the times you choose to focus, take breaks, or complete habits and sessions within the Application;
• Preferences and settings, including your selected goals, reminders, quiet hours, themes, and other personalization options you choose while using the Application;
• Habit and activity data, such as focus sessions, habit check-ins, streaks, reflections, or other wellness-related inputs you provide when setting up or using the Application;
• Transaction and subscription data, such as billing information and payment details, when you subscribe to paid features of the Application to access the Services (payment processing is handled by authorized third-party providers);
• Communications and user-generated content, including messages, feedback, support requests, reflections, or other information you choose to share with Us when you interact with in-app features, chat functions, or customer support.
  

III. FOR WHICH PURPOSES AND LEGAL BASIS WE PROCESS YOUR DATA

On the Application
Processing Necessary to Perform Our Contract

We process your Data where necessary to perform our contract with you and to provide you with the Services, including for the following purposes:

• Account creation and management, enabling you to register, access, and use the Application and its features;
• Delivery of personalized routines and features, including focus sessions, habit tracking, reminders, break notifications, weekly reviews, insights, achievements, and other personalized functionality designed to support focus, consistency, and well-being;
• Delivery of personalized routines and features, including focus sessions, habit tracking, reminders, break notifications, weekly reviews, insights, achievements, and other personalized functionality designed to support focus, consistency, and well-being;
• In-app communication and content sharing, allowing you to use chat features, share progress, reflections, or achievements, and interact with others where applicable;
• Customer and technical support, including responding to your requests, resolving technical issues, managing your account, handling subscription-related inquiries, and addressing any customer service matters.

Processing Necessary to Comply With Legal Obligations
We process your Data where necessary to comply with legal obligations, including for the following purposes:

• Participation in investigations and legal proceedings conducted by public authorities or government agencies, including for the detection, investigation, and prosecution of illegal activities;
• Prevention, detection, and mitigation of unlawful or fraudulent activities, including misuse of the Services;
• Compliance with statutory information requests from third parties where legally required (e.g., intellectual property claims or other lawful requests);
• Ensuring the security and integrity of the Application and Services, including monitoring for security threats and abuse;
• Retention and storage of Data to comply with applicable legal, regulatory, or accounting requirements.

Processing Based on Our Legitimate Interests
We process your Data where necessary for the purposes of our legitimate interests, including:

• Retention and storage of Data to comply with applicable legal, regulatory, or accounting requirements.
• Personalizing and enhancing your experience, such as adapting features, recommendations, and content based on how the Application is used;
• Personalizing and enhancing your experience, such as adapting features, recommendations, and content based on how the Application is used;
• Generating aggregated and anonymized statistics to better understand how users interact with the Services.

Processing Based on Your Consent
Where required by applicable law, we process your Data based on your consent for the following purposes:

• Personalizing and measuring advertising or promotional content, where applicable;
• Enhancing user experience through optional communications, such as surveys or feedback requests;
• Placing cookies or similar technologies to support personalization and analytics, where applicable;
• Sending promotional communications about additional products or services offered by Us or our partners, where you have opted in to receive such communications.

You may withdraw your consent at any time, in accordance with applicable law.

Aggregated and Anonymized Data
We may de-identify, anonymize, and/or aggregate your Data for legitimate business purposes, including improving our products, Services, and features. Aggregated or anonymized data may also be used for internal analysis, research, and statistical purposes. Such data does not identify you personally.

IV. COOKIES AND SIMILAR TECHNOLOGIES

When you use the Services, We may use cookies and similar technologies to collect certain Data. Cookies are small text files that are automatically created by your browser and stored on your device when you access the Application and use the Services.

We use cookies and similar technologies that may be stored on your device temporarily (such as session cookies, which expire when you close your browser) or for a longer period (such as persistent cookies) for the following purposes:
(i) providing and operating the Services;
(ii) enabling technical support and improving the performance and reliability of the Services;
(iii) enhancing and personalizing your user experience; and
(iv) displaying personalized or marketing-related content, where you have provided your consent.

You have the option to accept or refuse cookies through your browser or device settings. You may also delete or disable cookies at any time by adjusting your settings. With respect to advertising or personalization-related technologies, you can choose whether or not to consent to the use of cookies for marketing purposes, in accordance with applicable laws.

V. HOW WE STORE YOUR DATA
We, including through our authorized service providers, store your Data on secure storage facilities. For users located in the European Union, Data is stored on servers located within the European Union. Your Data is retained only for the period necessary to fulfill the purposes for which it was collected and processed, and in all cases in accordance with applicable legal and regulatory requirements.

VI. TRANSFER OF YOUR DATA OUTSIDE THE EUROPEAN UNION

Some of our service providers and partners, as well as certain members of our team, may be located outside the European Union or may process Data in countries where data protection laws may differ from those in your country.

IV. COOKIES AND SIMILAR TECHNOLOGIES
When you use the Services, We may use cookies and similar technologies to collect certain Data. Cookies are small text files that are automatically created by your browser and stored on your device when you access the Application and use the Services.

We use cookies and similar technologies that may be stored on your device temporarily (such as session cookies, which expire when you close your browser) or for a longer period (such as persistent cookies) for the following purposes:
(i) providing and operating the Services;
(ii) enabling technical support and improving the performance and reliability of the Services;
(iii) enhancing and personalizing your user experience; and
(iv) displaying personalized or marketing-related content, where you have provided your consent.

You have the option to accept or refuse cookies through your browser or device settings. You may also delete or disable cookies at any time by adjusting your settings. With respect to advertising or personalization-related technologies, you can choose whether or not to consent to the use of cookies for marketing purposes, in accordance with applicable laws.

V. HOW WE STORE YOUR DATA

We, including through our authorized service providers, store your Data on secure storage facilities. For users located in the European Union, Data is stored on servers located within the European Union. Your Data is retained only for the period necessary to fulfill the purposes for which it was collected and processed, and in all cases in accordance with applicable legal and regulatory requirements.

VI. TRANSFER OF YOUR DATA OUTSIDE THE EUROPEAN UNION

Some of our service providers and partners, as well as certain members of our team, may be located outside the European Union or may process Data in countries where data protection laws may differ from those in your country.

When transferring the Data of users located in the European Union to recipients outside the European Union, We ensure that appropriate safeguards are in place to protect your Data in accordance with applicable data protection laws. Such safeguards may include, where applicable, the use of standard contractual clauses approved by the European Commission, adequacy decisions, or other lawful transfer mechanisms recognized under the General Data Protection Regulation (GDPR).

Where Data is transferred for internal operational purposes, We ensure that such transfers are subject to appropriate technical and organizational measures designed to safeguard your Data and ensure a level of protection equivalent to that required under European data protection laws.

VII. HOW WE KEEP YOUR DATA SECURED

We take appropriate measures to safeguard the security of your Data and have implemented security practices consistent with generally accepted industry standards to protect your Data and restrict unauthorized access.

In particular, We implement appropriate technical and organizational measures designed to reduce risks associated with Data loss, misuse, unauthorized access, and unauthorized disclosure. These measures may include the use of encryption technologies (such as Secure Sockets Layer (SSL) or equivalent protocols) during Data transmission and storage, access control mechanisms, and physical and logical security safeguards for our systems and infrastructure.

Despite these efforts, no method of transmission over the Internet or method of electronic storage is completely secure. While We strive to protect your Data, We cannot guarantee absolute security. There is always a possibility that unauthorized third parties may overcome our security measures or that Data transmissions may be intercepted.

For this reason, We encourage you to take appropriate precautions to protect your personal Data when using the Application or communicating with Us, such as using strong passwords and ensuring the security of your devices.

VIII. YOUR RIGHTS AS A DATA SUBJECT

You have the following rights regarding your Data and how it is processed, subject to applicable laws:

• Right of access – to obtain confirmation as to whether your Data is being processed and to access such Data;
• Right to rectification – to request the correction of inaccurate or incomplete Data;
• Right to erasure – to request the deletion of your Data, where permitted by law. This right may be limited where processing is necessary to comply with a legal obligation, exercise the right to freedom of expression and information, serve the public interest, or establish, exercise, or defend legal claims;
  • you contest the accuracy of the Data;
  • the processing is unlawful and you oppose erasure;
  • We no longer need the Data but you require it to establish, exercise, or defend legal claims; or
  • you have objected to the processing and verification is pending;
• Right to data portability – to receive a copy of your Data in a structured, commonly used, and machine-readable format, or to request that it be transferred to another data controller where technically feasible;
• Right to data portability – to receive a copy of your Data in a structured, commonly used, and machine-readable format, or to request that it be transferred to another data controller where technically feasible;
• Right to withdraw consent – to withdraw your consent at any time where processing is based on consent, without affecting the lawfulness of processing carried out before withdrawal.

You may request the deletion of your personal Data as permitted by applicable law. When such a request is made, We will make reasonable efforts to comply. In certain cases, We may be legally required to retain specific Data for a defined period; in such cases, deletion will occur once those obligations have been satisfied.
You can exercise your rights by sending a clear and specific request to Us by email at: 📧 contact@haaaaaaappy.com Your request will be reviewed and handled within a reasonable timeframe and in accordance with applicable legal obligations. You may also access, update, or delete certain Data directly within the Application by logging into your account and using the available account settings.

IX. HOW WE MANAGE THE PROTECTION OF CHILDREN

We are committed to protecting the privacy of children. The Application and Services are not designed for or directed toward children, and We do not knowingly collect personal Data from users under the age of eighteen (18).

Users are asked to confirm that they are eighteen (18) years of age or older when registering for or subscribing to the Application and Services. If a user is under eighteen (18), parental or legal guardian consent may be required before access to certain features is permitted. In all cases, We do not knowingly collect personal Data from children under the age of thirteen (13).

For users under eighteen (18), We may limit the collection, use, or storage of Data and may restrict access to certain features, challenges, or functionalities of the Application in order to comply with applicable laws and to ensure appropriate protection.

If We become aware that personal Data has been collected from a child in violation of applicable laws, We will take appropriate steps to delete such Data as soon as reasonably possible.

X. WITH WHOM WE SHARE YOUR DATA
We may share your Data with authorized employees and internal teams, such as IT, development, operations, and customer support, solely to the extent necessary to operate the Application, provide the Services, and improve your user experience.

We may also share your Data with trusted third-party service providers acting on our behalf, including providers that host or process Data, manage subscriptions and payments, deliver communications, perform analytics, or help detect, prevent, or mitigate unlawful or fraudulent activity. These service providers process Data only in accordance with our instructions and for the purposes described in this Privacy Policy.

We ensure that all third-party service providers are subject to appropriate contractual obligations requiring them to comply with applicable data protection laws and to implement adequate technical and organizational measures to protect your Data.

With your consent, We may share certain Data with selected partners in order to provide you with information or offers about their products or services that may be of interest to you. Such sharing will occur only where you have explicitly opted in and may be withdrawn at any time.

We may also disclose your Data where required to do so by law, regulation, legal process, or a request from a competent authority, or where disclosure is necessary to exercise or protect our legal rights. Unless otherwise required by law, We are not obligated to notify you of such disclosures.

XI. THIRD-PARTY WEBSITE LINKS

The Application may contain links to third-party websites, services, or content. If you choose to interact with these third-party links or services, you may be providing Data directly to those third parties. We do not control and are not responsible for how third-party websites, applications, or services collect, use, or protect your Data, and their practices may differ from those described in this Privacy Policy.

We encourage you to review the privacy policies and terms of use of any third-party websites, applications, or services that you access through the Application before providing any personal Data.

The Application may also rely on third-party advertising platforms, ad networks, or analytics providers to promote the Application or measure the effectiveness of advertising campaigns. These third parties may use cookies, SDKs, or similar technologies to collect information about user interactions with advertisements or campaigns, including across different applications or websites, in accordance with their own privacy policies.

No information that you share directly within the Application, such as account details, content, or in-app activity, is shared with third-party advertisers for their independent use. We do not control the data collection practices or tracking technologies used by third-party advertisers or platforms. If you have questions about a specific advertisement, you should contact the relevant advertiser or platform directly.