Privacy Policy

Privacy Policy

1. Who processes your data?

The data controller is Happy Brain Training, 41 avenue Lacassagne, 69003 Lyon, France.

For any question about your personal data or to exercise your rights, please email happybraintrainings@gmail.com.

This policy explains how we process personal data collected through https://happybraintraining.com, our training activities and services, our communications with you, and our newsletters.

2. Data we may process

Depending on the services you use, we may process:

• contact details such as your first name, last name, email address, country and, if provided, telephone number or postal address;
• professional details such as your specialty, occupation, organisation and preferred language;
• information relating to your account, registrations, orders, payments and invoices;
• the content of requests you send through our forms or by email;
• your subscription and privacy preferences, together with the date and version of the information associated with your choice;
• technical data necessary for the operation and security of the website, such as IP address, browser type, connection logs and cookie information;
• only with your consent, the open and click data described in section 5.

Please do not send identifiable patient health data through our forms, emails or training tools unless an appropriate channel and legal framework have been expressly provided for this purpose.

3. Purposes and legal bases

Where we rely on consent, you may withdraw it at any time without affecting processing carried out lawfully before withdrawal.

4. Newsletter

When you subscribe, we use your email address and, where provided, your first name, last name, country, specialty and preferred language to manage your subscription and send the communications you requested.

Every newsletter contains an unsubscribe link. Unsubscribing is separate from declining audience measurement as described below.

5. Tracking pixels and newsletter audience measurement

Our newsletters and mailing list are managed through Mailchimp, a service provided by The Rocket Science Group LLC, an Intuit company, acting as a processor when it handles data on our instructions.

Only with your consent, some newsletters may contain an invisible pixel and individualised links that indicate whether the email was opened and whether its links were visited. These technologies may process:

• your email address and a contact or campaign identifier;
• whether the email was opened and the date and time of the opening;
• links visited and the date and time of clicks;
• IP address and certain technical information sent by your email software or device when making the request.

We use this data to produce campaign statistics and improve newsletter content and frequency. We do not use it to target you on other websites or apps.

Your choice is voluntary:

• if you allow measurement, tracking may be enabled in newsletters sent to you;
• if you decline or make no choice, newsletters sent to you must not contain individualised open or click measurement;
• declining measurement does not unsubscribe you.

You can change your choice at any time through the “Manage my privacy preferences” link in our newsletters. Withdrawal applies to future mailings. Earlier individualised tracking data is deleted where no other legal basis requires its retention, and any later request from an old pixel associated with the withdrawn consent must be ignored.

Emails that ask you to make this choice are themselves sent without open or click tracking. We will not ask a person who declined again for at least six months unless the service changes significantly or the person requests it.

6. Website cookies and trackers

Strictly necessary cookies may be used to operate and secure the website. Non-essential cookies or trackers, including audience measurement, personalisation or advertising tools, are used only after consent where required. You can accept, decline or change your choices through the cookie-management tool displayed on the website.

Your website cookie choice does not replace your specific choice about pixels in emails.

7. Recipients and service providers

Your data is available only to authorised Happy Brain Training personnel and, to the extent required for their tasks, to our service providers, including:

• Mailchimp for newsletter delivery, subscription management and, where consent is given, audience measurement;
• providers needed for hosting, maintenance, security, account management, training delivery, payments and accounting;
• authorities, courts or professional advisers where required by law or necessary to defend our rights.

We do not sell personal data.

8. Transfers outside the European Economic Area

Some providers may process data outside the European Economic Area, including in the United States. Where they do, we ensure that a transfer mechanism recognised by the GDPR applies.

For Mailchimp, European transfers are covered, as applicable, by the EU-U.S. Data Privacy Framework and/or the European Commission Standard Contractual Clauses incorporated into its Data Processing Addendum: Mailchimp Data Processing Addendum.

You may contact us for further information about the relevant safeguards.

9. Retention periods

We retain data only for as long as necessary for the relevant purpose, then delete or anonymise it, subject to legal duties and the defence of legal claims:

Effectively anonymised statistics may be retained for longer because they no longer identify an individual.

10. Your rights

Depending on the circumstances, you may request:

• access to and a copy of your data;
• correction or deletion;
• restriction of processing;
• portability of data you provided where processing is automated and based on consent or contract;
• objection to processing based on legitimate interests or to direct marketing;
• withdrawal of consent at any time;
• instructions concerning the use of your personal data after death, where provided by French law.

To exercise these rights, email happybraintrainings@gmail.com. To protect your information, we may request only the information needed to verify your identity. We normally respond within one month, subject to the extensions permitted by the GDPR.

If you believe your rights have not been respected, you may lodge a complaint with the French data-protection authority, the CNIL: https://www.cnil.fr/fr/adresser-une-plainte.

11. Security

We apply technical and organisational measures proportionate to the risks to protect data against unauthorised access, loss, alteration or disclosure. As no online service can offer absolute security, we reassess these measures when our services or the risks change.

12. Updates to this policy

We may update this policy to reflect changes to our services, providers or applicable law. The update date appears at the top of the page. If a material change affects your rights or choices, we will inform you through an appropriate channel.