Privacy Statement

Happy Gears, Inc./NetSpyGlass.com. and any subsidiaries (collectively “HGI/NSG”) are committed to protecting your personal information and privacy. This Privacy Statement applies to HGI/NSG websites and services that link to or reference this Statement. It describes how we handle personal information and the choices available to you regarding the collection, use and access to that information. It also instructs you on how to update and correct your personal information that we store. Additional information on our personal information practices may be provided in supplemental privacy statements, or notices provided prior to or at the time of data collection. Certain HGI/NSG websites may have their own privacy statement that describes how we handle personal information for those websites specifically. To the extent a notice provided at the time of collection, or a website or Service specific privacy statement, conflicts with this Privacy Statement, such specific notice or supplemental privacy statement will supersede this Statement.

PERSONAL INFORMATION

“Personal information” is any information that can be used to identify you as an individual, and may include your name, address, email address, phone number, login information (account number, password), marketing preferences, and/or social media account information. If we link other data with your personal information, we will also treat that linked data as your personal information. Credit card information is also personal information.

WHY HGI/NSG COLLECTS YOUR PERSONAL INFORMATION

We collect and use your personal information for several reasons. These reasons include fulfilling orders, providing customer support, sending security notices, and tailoring marketing communications, to name a few. Additional reasons include, but are not limited to:

• Creating an account;
• Providing customer service and/or support;
• Enabling the use of certain features of our services;
• Personalizing your online experience;
• Sending marketing communications;
• Providing you with a newsletter subscription;
• Managing a job application; and
• Collecting information during the testing admissions process when a computer-based certification test is administered to you.

HOW HGI/NSG COLLECTS YOUR PERSONAL INFORMATION

HGI/NSG obtains information about you from a variety of resources including this website, interactions with you at trade shows, direct marketing campaigns, third party services, purchase agreements, public databases, and social media platforms,and other sources.

In some cases, HGI/NSG and the third parties we engage may automatically collect data through cookies, web logs, web beacons, and other similar applications. This information is used to better understand and improve the usability, performance, and effectiveness of the website and to help tailor content or offers for you. Please read “Use of Cookies and other Web Technologies” below for more information.From time to time, HGI/NSG may also obtain information about you from third party sources, such as our resellers and channel partners, our joint marketing partners, our technology partners and, to the extent involved in the sales and marketing of our collective products and services, their appointed partners.

Examples of the information HGI/NSG may receive from other sources include: account information, job role and public employment profile, service and support information, information about your product or service interests or preferences, page-view information from some business partners with which HGI/NSG operates co-branded services or joint offerings, and credit history information from credit bureaus. HGI/NSG may use the information HGI/NSG receives from you to better understand you and/or maintain and improve the accuracy of the records HGI/NSG holds about you as well as to position, promote or optimize our products and services. HGI/NSG may also use this information in conjunction with your browsing habits/preferences (as obtained from our data partners) and your contact details, professional information and HGI/NSG transaction history (as obtained from our customer relationship management database) to deliver targeted advertising and marketing to you, where permitted by applicable law and in accordance with your advertising / marketing preferences.

If you choose to provide HGI/NSG with a third party’s personal information (such as name, email, and phone number), you represent that you have that third party’s permission to do so. Examples include forwarding reference or marketing material toa friend or sending job referrals. Third parties may unsubscribe from any future communication by following the link provided in the initial message or by contacting privacy@netspyglass.com.

Use of Cookies and other Web Technologies
Like many websites, HGI/NSG uses automatic data collection tools, such as cookies, embedded web links, and web beacons. These tools collect certain standard information that your browser sends to our website. Examples include your browser type and the address of the website from which you arrived at our website.They may also collect information about:

• Your Internet Protocol (IP) address. This is a number automatically assigned to your computer or device whenever you connect to the Internet. It is a unique address assigned by your Internet service provider or IT department on a TCP/IP network. Among other things, the IP address allows web servers to locate and identify your device.
• Clickstream behavior. This includes, for example, the pages you view and the links you click. These tools help make your visit to our website easier, more efficient, and more valuable by providing you with a customized experience and recognizing you when you return.
• Our website uses widgets. Widgets are interactive mini-programs that run on our site to provide specific services from other companies. An example is the sign-up form on our website. Personal information, such as your email address, may be collected through widgets. Widgets may also set cookies to enable them to function properly. Information collected by a widget is governed by the privacy policy of the company that created the widget.

HOW WE USE YOUR PERSONAL INFORMATION

HGI/NSG may use your personal information for the purposes of operating our business, providing support, delivering, improving, and customizing our websites and Products, to enhance our ability to provide relevant marketing, products, services and recommendations to you, to help monitor, prevent and detect fraud, and for other legitimate purposes permitted by applicable law. Some of the ways we may use personal information include:

• Delivering a Product you have ordered.
• Analyzing, supporting, and improving our Products and your online experience.
• Personalizing websites, newsletters and other communications.
• Administering and processing any certification exams.
• Sending communications to you, including for marketing or customer satisfaction purposes, either directly from HGI/NSG or from our partners.You can change your communication preferences at any time. See “Your Choices and Selecting Your Communication Preferences” below.

HOW WE MIGHT SHARE YOUR PERSONAL INFORMATION

HGI/NSG takes care to allow your personal information to be accessed only by those who really need to in order to perform their tasks and duties, and to share only with third parties who have a legitimate purpose for accessing it. We may share personal information in the following ways:

• HGI/NSG Affiliates: We may share your information within HGI/NSG and any of our worldwide subsidiaries for purposes of providing services and support, data processing or storage.
• Service Providers: We may share your information with third parties, such as vendors, consultants, agents and other service providers who work on our behalf. Examples include vendors and service providers who provide assistance with marketing, hosting seminar registration, administering online testing and certification programs, assisting with sales-related efforts or post-sales support,customer training, providing customer support, data analysis and insight. Unless described in this Privacy Statement, we do not share, sell, rent, or trade any of your personal information with third parties for their own promotional purposes.
• Business Partners: We may provide your information to our channel partners, such as distributors and resellers, to fulfill product and information requests, to effectively deliver unified support, and to provide customers and prospective customers with information about HGI/NSG and our products and services.From time to time, HGI/NSG may engage in joint sales or product promotions with selected business partners. If you purchase or specifically express interest in a jointly-offered product, promotion or service, we may share relevant personal information with those partners. Please be aware that HGI/NSG does not control our business partners’ use of such information. Our partners are responsible for managing their own use of the personal information collected in these circumstances. We recommend you review the privacy policies of the relevant partner to find out more about their handling of your personal information.
• Compliance with laws or any competent law enforcement body, regulatory body, government agency, court or third party: We may disclose information where we believe disclosure is necessary or required (i) by law or regulation, in order to comply with legal process or government requests (including in response to public authorities to meet national security or law enforcement requirements); or (ii) to exercise, establish or defend our legal rights.
• Business transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, acquisition, dissolution, corporate reorganization or similar event. We will inform any buyer that your information shall only be used in accordance with this Privacy Statement.
• With your consent: We may disclose your personal information for any purpose with your express written consent.
  In an aggregated format. In aggregated, anonymized, and/or de-identified form which cannot reasonably be used to identify you.
• Other legitimate business purposes: We may share your personal information when it is necessary for other legitimate purposes such as protecting HGI/NSG’s confidential and proprietary information or where necessary to support, respond to and to provide our products and services to our customers.HOW YOU CAN GET ACCESS TO AND ENSURE THE ACCURACY OF YOUR PERSONAL INFORMATIONWe need your help in keeping your personal information accurate and up to date. We provide a options to access, correct, suppress, or delete your personal information:
• You can request to view or edit your netspyglass.com personal information and preferences online by sending an email to privacy@netspyglass.com.
• Some HGI/NSG entities may act as or be considered “data controllers”. When a HGI/NSG entity is acting as a data controller, you can exercise your rights of access and request corrections, suppression, or deactivations under applicable data protection laws directly with that HGI/NSG entity as described in the specificSolution documentation.
• If you need additional assistance, or help with accessing, correcting, suppressing, or deleting your personal information, please feel free to contact us directly. We make good faith efforts to honor reasonable requests to access, delete, update, suppress, or correct your data. If we are unable to honor your request, we will provide you with an explanation.

Your Choices and Selecting Your Communication Preferences
We give you the choice of receiving a variety of information related to our Products. You can manage your communication preferences through the following methods:

• By following the instructions included in each promotional email from us to subscribe or unsubscribe from that particular mailing.
• By sending us a message through email to privacy@netspyglass.com or by mail to: Happy Gears, Inc. / NetSpyGlass.com, Attention:Privacy, 718 University Avenue #212, Los Gatos, California, 95054 USA. Please be sure to include your name, email address, and specific, relevant information about the material you no longer wish to receive.

These choices do not apply to service notifications or other required communications that are considered part of certain Products, which you may receive periodically unless you stop using or cancel the Product in accordance with its terms and conditions.

By using our websites, Products, or otherwise providing personal information to us,you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use. For example, if we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our websites, by sending an email, or otherwise contacting you.

THE SECURITY OF YOUR PERSONAL INFORMATION

We intend to protect the personal information entrusted to us and treat it securely in accordance with this Privacy Statement. HGI/NSG implements physical, administrative, and technical safeguards designed to protect your personal information from unauthorized access, use, or disclosure. We also contractually require that our suppliers protect such information from unauthorized access, use, and disclosure. The Internet, however, cannot be guaranteed to be 100% secure, and we cannot ensure or guarantee the security of any personal information you provide to us.

Retention of Personal Information
We will retain your personal information as needed to fulfill the purposes for which it was collected. We will retain and use your personal information as necessary to comply with our business requirements, legal obligations, resolve disputes, protect our assets, and enforce our agreements.

Children’s Privacy
HGI/NSG takes children’s privacy seriously. We do not knowingly collect personal information from children under the age of 13 through our websites. If you are under 13 years of age, please do not submit any personal information through our websites without the express consent and participation of a parent or guardian.

Your California Privacy Rights
Residents of the State of California, under California Civil Code § 1798.83, have the right to request from companies conducting business in California a list of all third parties to which the company has disclosed personal information during the preceding year for direct marketing purposes. Alternatively, the law provides that if the company has a privacy policy that gives either an opt-out or opt-in choice for use of your personal information by third parties (such as advertisers) for marketing purposes, the company may instead provide you with information on how to exercise your disclosure choice options. HGI/NSG qualifies for the alternative option. We have a comprehensive privacy statement, and provide you with details on how you may either opt-out or opt-in to the use of your personal information by third parties for direct marketing purposes. Therefore, we are not required to maintain or disclose a list of the third parties that received your personal information for marketing purposes during the preceding year. If you are a California resident and request information about how to exercise your third party disclosure choices, please email our privacy team at: privacy@netspyglass.com

Note about Linked Websites
We may provide links to other third-party websites and services that are outside our control and not covered by this Privacy Statement. We encourage you to review the privacy statements posted on those websites (and all websites) you visit

Note about Forums and Chat Rooms
If you participate in a discussion forum, local communities, or chat room accessed through or on a HGI/NSG website, you should be aware that the information you provide there (i.e. your public profile) will be made broadly available to others, and could be used to contact you, send you unsolicited messages, or for purposes neither HGI/NSG nor you have control over. Also, please recognize that individual forums and chat rooms may have additional rules and conditions. HGI/NSG is not responsible for the personal information or any other information you choose to submit in these forums. To request removal of your personal information from our blog or community forum, contact us at privacy@netspyglass.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

How to Contact Us
We value your opinions. Should you have questions or comments related to this Privacy Statement, contact our privacy team by sending us a message through email to privacy@netspyglass.com or by mail to: Happy Gears, Inc. / NetSpyGlass.com, Attention:Privacy, 718 University Avenue #212, Los Gatos, California, 95054 USA.

Updates to this HGI/NSG Privacy Statement
We may update this Privacy Statement from time to time. If we modify our Privacy Statement, we will post the revised version here, with an updated revision date. You agree to visit these pages periodically to be aware of and review any such revisions. If we make material changes to our Privacy Statement, we may also notify you by other means prior to the changes taking effect, such as by posting a notice on our websites or sending you a notification. By continuing to use our website after such revisions are in effect, you accept and agree to the revisions and to abide by them.

This HGI/NSG Privacy Statement was revised and posted as of October 31, 2019.