PRIVACY NOTICE

Last updated: January 7, 2020

Happy Address is committed to providing clear and concise information about our privacy policies and practices. This Privacy Statement describes how Happy Address and its subsidiaries (“we” or “us”) collect, use and disclose certain personal information in the course of providing our services. By accessing our website (www.happyaddress.mx) or using our services, you accept the information collection and handling practices described in this statement.

I. Happy Address Services and Scope

Happy Address provides comprehensive property management software services and solutions to property owners and managers in the rental housing industry (our “Clients”). Our line of on-demand products covers the full spectrum of accounting, leasing, operations and marketing services (collectively “Happy Address Services”). By providing this set of services, Happy Address acts as a contractual service provider to our Clients1. As a service provider, Happy Address does not control any personal information that we process on behalf of our Clients. All such personal information is collected and controlled by our Clients, and Happy Address must provide our products and services in accordance with contractual provisions and Clients' instructions regarding data collection, privacy, processing and security.

1 Happy Address offers direct-to-consumer services that collect personal data directly from residents. Unlike most Happy Address Services, these direct-to-consumer services do not operate on behalf of our Clients. These services include: eRenterPlan (insurance), eRenterDirect (insurance), Lease Terms Solutions (insurance), DepositIQ (insurance/bond) and ResidentDirect (money transmission services). Each of these services has a separate privacy policy posted on their designated websites that describes the privacy practices associated with the services.

Our Customers may manage access to the Happy Address Services for their employed end users. This management may include control over end user account access and functionality, as well as access to and monitoring of end user data and activity. Happy Address is not responsible for the privacy or security practices of our Customers, and this Privacy Statement is not intended to cover those practices of Customers. Additionally, this Privacy Statement does not apply to the privacy or security practices of any third party.

II. Information gathering

The Happy Address Services involve the collection and processing of personal information for marketing purposes. This includes Client resident and prospect information (whether provided by Clients to Happy Address or collected directly from residents by Happy Address acting on Clients' behalf) and Client employee information (collected by Happy Address to establish access from the user account to the Happy Address Services). This personal information varies depending on the individual Happy Address Services used and multiple services may be integrated into one Customer property. The personal information collected includes the following:

Contact and identification information: name, address, telephone number, email address, and emergency contact information.

Personal details: date of birth, social security number, driver's license/state-issued ID/military ID/passport number, employment history/income, gender, and marital status.

Financial account information: bank account, credit/debit card, and insurance/bond policy information

Property Ledger Information and Documents: Resident Leases, Resident Ledger History, Utility Consumption/Expenses, Property Notices and Communications, Rent/Fee Payment Receipts, and Other Property-Related Customer-Generated Content property management and resident history

Credentials and authentication information: usernames, passwords, password hints, and security questions

Technical information: IP address, device and hardware specifications, and web browser type

Usage Data: Data log that tracks service access, usage, performance metrics, and error reports.

III. Use of information

Personal information collected by the Happy Address Services is used for various purposes, including:

To fulfill the purpose for which the personal information was collected and provide the requested Happy Address Services.

To integrate with apartment community services offered by Happy Address or third party service providers engaged by Clients.

To process service requests, transactions and payments and prevent transactional fraud.

Distribute legally required communications and notices regarding the status of the Happy Address Services via telephone, email, and SMS text messages.

Provide maintenance, improvement, security, support and optimization of the Happy Address Services website.

Maintain compliance with federal and state laws related to software as a service, background investigations, financial institutions, and money services businesses.

Create, maintain, customize and protect Happy Address Services user accounts.

IV.

Information exchange and dissemination

Happy Address does not sell personal information collected through the Happy Address Services.

Happy Address may provide personal information to third parties in limited circumstances, including service providers and vendors that support or integrate with the Happy Address Services described in this statement. Happy Address only shares personal information to the extent reasonably necessary to support the requirements of the Happy Address Services, or for third party vendors or service providers to perform services on our or our Customers' behalf. We do not allow third party vendors or service providers to use or disclose your personal information except for the purpose of providing the services we request from them. However, please note that Happy Address does not maintain direct control over the privacy policies and practices of Clients or other third-party companies, agents or contractors.

Additionally, if Happy Address undertakes any business transition, restructuring, merger, sale or other transfer of assets, we reserve the right to transfer all information on the Happy Address Services, including all personal information, as part of the transaction or in connection with it. with her.

Finally, we will access, transfer, disclose and retain personal information when we believe in good faith that doing so is necessary to:

Comply with applicable law or respond to valid requests from public authorities, including law enforcement, national security agencies, or other government entities;

Operate and maintain the security of the Happy Address Services; and

Protect the rights and property of Happy Address, including both intellectual property and physical systems infrastructure.

V. Data transfers from the European Union

Data processed on behalf of Guesty Customers located within the European Union is subject to the additional privacy requirements set out in the Happy Address Privacy Shield Statement.

SAW. Cookies, web beacons and other technologies

When you access the Happy Address Services or our website, our servers may place small text files (“cookies”) on your computer for record-keeping purposes. Among other things, cookies allow us to collect information about your activity on our website in order to improve your online experience, establish secure user accounts, remember your preferences and settings, and for other similar personalization purposes.

In addition to cookies, the Happy Address Services and our website may use web beacons, clear gifs, or other technologies to collect information about how users interact and use various features. For example, these technologies may identify popular pages, viewing patterns, clicks, conversion rates and other information that may be used to improve, monitor and operate our websites, products and services.

Most Internet browsers provide controls that allow users to manage or disable the placement and use of cookies on their computer. Please note that disabling cookies may disable or otherwise restrict certain features on the Happy Address Services or our website.

VII. Third party links to other sites

The Happy Address Services may include links to third-party service providers engaged by Clients. These linked services are operated by unaffiliated third parties that have separate and independent privacy statements, terms of use, and related notices or disclosures regarding their information handling practices. We cannot be responsible for the information handling practices of independent parties and encourage you to review their practices before disclosing information.

VIII. Data security

Happy Address implements and maintains appropriate physical, administrative, technical and organizational measures to protect the information we process against unauthorized or unlawful access, use or disclosure, and against accidental loss, damage, alteration or destruction. Under our security policies and practices, access to personal information is restricted and authorized only to those who have a business need for such access. Happy Address strives to protect the personal information we process; However, no security program is 100% secure and we cannot guarantee that our security measures will prevent any unauthorized attempt to access, use or disclose personal information. We maintain security incident response policies and procedures to handle incidents involving unauthorized access to the personal data we process.

IX. Access and update of personal information

In the event that your personal information is determined to be out of date, incomplete or inaccurate, you may access and update your information by logging into your Happy Address Services account or contacting your property manager. If you require verification that your requested changes have been completed and such verification is not readily displayed in your Happy Address Services account, you may request confirmation at the email address below (see “Contact Us”).

X. Children's Online Privacy

Happy Address is not intended for children under 13 years of age.

or online information collection, and our services are not designed to attract the attention or interaction of children.

XI. California Residents: Privacy Rights

California residents may avail themselves of the rights granted by California laws and regulations. For a summary of California privacy rights, please see our Privacy Statement for California Residents.

XII. Changes to the privacy statement

Happy Address reserves the right to modify this privacy statement at our sole discretion at any time. When we make changes to this privacy statement, we will post the updated content on our applicable websites and Happy Address Services along with the effective date of the change. Your continued use of the Happy Address Services following the posting of changes constitutes your acceptance of those changes.

XII. Contact Us

If you have any questions or concerns about this Privacy Statement or its implementation, you may contact us through the following methods:

Through the Mexican Postal Service at:

Happy Address, Inc.

Attn: Privacy (Legal)

AV. 10 BETWEEN CALLE 30 & 32, DOCA LOCAL BUILDING 1, PLAYA DEL CARMEN, QUINTANA ROO, 77710.

MEXICO 52 (984)147 68 66 ·

Or by email to: BOOKING@HAPPYADDRESS.MX