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PRIVACY POLICY
Effective Date: March 2026
 

1. INTRODUCTION
 
Happy Hours Ltd. (“Happy Hours”, “we”, “our”, or “us”) operates a digital promotions and rewards platform that enables brands, bars, lounges, and restaurants to engage consumers through redeemable digital offers and vouchers.
 
In operating our platform, we process limited personal data and are committed to ensuring that such data is handled lawfully, transparently, and securely in accordance with the Nigeria Data Protection Regulation (NDPR) 2019 and the Nigeria Data Protection Act (NDPA) 2023.
 
By using the Happy Hours mobile application, website, or related services, you accept the practices described in this Privacy Policy.
 
2. SCOPE OF THIS POLICY
This Privacy Policy applies to:

  • Users of the Happy Hours mobile application;

  • Individuals who scan QR codes, redeem digital coupons, or participate in promotions through the platform;

  • Visitors to our website or digital channels;

  • All processing of personal data carried out by Happy Hours, whether manually or through automated systems.

 
3. LAWFUL BASIS FOR DATA PROCESSING
We process personal data on one or more of the following lawful bases:

  • Consent: Where you have explicitly granted permission for specific data processing activities;

  • Contractual necessity: Where processing is required to provide access to platform features or promotions requested by you;

  • Legal obligation: Where processing is required to comply with applicable laws or regulatory requirements;

  • Legitimate interest: Where processing is necessary for platform operations, fraud prevention, or accountability, provided such interests do not override your fundamental rights and freedoms.

 
4. CATEGORIES OF PERSONAL DATA WE COLLECT
To operate the Happy Hours platform effectively, we may collect the following categories of personal data:

  • Identity data, such as name or username and age confirmation;

  • Contact data, including email address or phone number where provided;

  • Account and redemption data related to vouchers, rewards, or promotional activity;

  • Device and technical data, such as device type, IP address, app version, and operating system;

  • Optional location data, where explicitly enabled by the user;

  • Usage data relating to interaction with the app or customer support.

 
5. HOW WE COLLECT YOUR DATA
We collect personal data through the following means:

  • Directly from you when you register, scan a QR code, redeem an offer, or communicate with us;

  • Automatically through app usage, cookies, or similar digital technologies;

  • Indirectly from partner venues solely for redemption validation and accountability purposes;

  • From lawful public or technical sources where required for compliance or security.

 
6. PURPOSES FOR PROCESSING PERSONAL DATA
We collect and use personal data to:

  • Enable digital coupon, voucher, and reward redemption;

  • Facilitate direct engagement between users and participating brands or venues;

  • Ensure accountability, fraud prevention, and accurate reporting of promotions;

  • Manage user accounts and platform functionality;

  • Provide customer support and respond to inquiries;

  • Improve platform performance and user experience;

  • Meet legal, regulatory, and compliance obligations.

 
Happy Hours does not sell consumer personal data.
 
7. DISCLOSURE OF PERSONAL DATA
We may disclose limited personal data, under strict confidentiality, to:

  • Participating venues solely for validating redemptions;

  • Brands in aggregated and anonymized performance formats only;

  • Third-party service providers supporting hosting, analytics, communications, or security;

  • Regulatory authorities or law enforcement where required by law;

  • Professional advisers such as auditors or legal consultants;

  • Any party where you have provided explicit consent.

All third parties are contractually required to safeguard data confidentiality and security.
 
8. INTERNATIONAL DATA TRANSFERS
Where personal data is transferred outside Nigeria, such transfers will be conducted in accordance with the NDPA and subject to appropriate safeguards to protect user rights.
 
9. DATA RETENTION
We retain personal data only for as long as necessary to:

  • Fulfill the purpose for which it was collected;

  • Maintain platform accountability and audit trails;

  • Comply with legal and regulatory obligations;

  • Resolve disputes or protect our legal interests.

 
10. YOUR RIGHTS UNDER THE NDPA
You have the right to:

  • Access personal data held about you;

  • Request correction of inaccurate or incomplete data;

  • Request deletion where data is no longer required or consent is withdrawn;

  • Object to certain processing activities;

  • Restrict processing in specific circumstances;

  • Request data portability where applicable;

  • Withdraw consent at any time;

  • Lodge a complaint with the Nigeria Data Protection Commission (NDPC).

Requests may be made using the contact details provided in section 16.
 
 
11. SECURITY AND DATA PROTECTION MEASURES
Happy Hours implements appropriate technical and organizational measures to protect personal data, including:

  • Controlled access to systems and data;

  • Secure hosting and encrypted communications;

  • Regular monitoring and security assessments;

  • Internal policies governing data confidentiality and handling.

 
12. USE OF COOKIES AND TRACKING TECHNOLOGIES
Our digital platforms may use cookies and similar technologies to improve functionality, analyze usage patterns, and enhance user experience. Users may manage cookie preferences through device or browser settings.
 
13. MARKETING COMMUNICATION AND OPT-OUT
Where permitted and with explicit consent, we may send platform-related notifications or promotional updates.
 
Users may opt out at any time through in-app settings or communication controls.
 
We do not sell or share personal data for third-party advertising purposes.
 
14. CHILDREN’S PRIVACY
Happy Hours is strictly intended for individuals aged 18 years and above, which is the legal age for alcohol marketing in Nigeria.
 
We do not knowingly collect data from individuals under 18. Any such data identified will be deleted promptly.
 
 
15. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy periodically to reflect legal, regulatory, or operational changes. Updates will be published on our official channels with a revised effective date.
 
16. CONTACTING US
For privacy-related questions, data requests, or complaints, please contact:
 
Proximity Communications Nigeria
Email: proximitycommunications@gmail.com
Website: www.happyhours.com.ng

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