Privacy Policy

Last updated: April 2026

1. Introduction

Utili Software Limited, a company registered in England and Wales (company number 09315858), trading as "HappyFace" ("Company", "we", "us", or "our"), is committed to protecting your privacy. Our registered office address is 124 City Road, London, England, EC1V 2NX. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our AI platform and related services (collectively, the "Service").

By accessing or using the Service, you consent to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access or use the Service.

We are registered in England and Wales and comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

This Service is intended exclusively for business use. By using the Service, you confirm that you are acting in the course of your business, trade, or profession and that any personal data you provide relates to your business activities.

2. Data Controller

Utili Software Limited (trading as HappyFace) is the data controller responsible for your personal data. If you have any questions about this Privacy Policy or our data practices, please contact us using the details provided at the end of this document.

3. Information We Collect

3.1 Information You Provide

We collect information you voluntarily provide when using the Service, including:

  • Account Information: Name, email address, password, company name, job title
  • Payment Information: Billing address, payment card details (processed securely by our payment processors)
  • Profile Information: Profile picture, preferences, settings
  • Communications: Messages, emails, support requests, feedback
  • Content: Data, files, text, and other content you upload or create using the Service
  • Contact Data: Information about your contacts that you upload to the Service

3.2 Information Collected Automatically

When you use the Service, we automatically collect certain information, including:

  • Device Information: Device type, operating system, browser type, unique device identifiers
  • Usage Data: Features used, actions taken, time spent, frequency of use
  • Log Data: IP address, access times, pages viewed, referring URLs
  • Location Data: General location based on IP address
  • Cookies and Tracking Technologies: Information collected through cookies, pixels, and similar technologies

3.3 Information from Third Parties

We may receive information about you from third parties, including:

  • Authentication providers when you sign in using third-party services
  • Integration partners when you connect third-party services to your account
  • Analytics providers
  • Marketing partners

4. How We Use Your Information

We use the information we collect for the following purposes:

  • Provide the Service: To operate, maintain, and deliver the features and functionality of the Service
  • Process Transactions: To process payments and manage your subscription
  • Communicate: To send you service-related notices, updates, security alerts, and support messages
  • Improve the Service: To analyse usage patterns, troubleshoot issues, and develop new features
  • AI Training and Improvement: To improve and train our AI models, agents, and algorithms (see Section 5 and our AI Transparency page)
  • Personalisation: To personalise your experience and provide tailored content
  • Marketing: To send promotional communications (with your consent where required)
  • Security: To detect, prevent, and address fraud, abuse, and security issues
  • Legal Compliance: To comply with legal obligations and enforce our terms
  • Business Operations: For internal business purposes, including analytics, auditing, and reporting

5. AI Data Processing and Third-Party AI Providers

Our Service utilises artificial intelligence technology provided by third-party providers. By using the Service, you acknowledge and agree that:

  • Your data, including content you submit, may be processed by third-party AI providers
  • Third-party AI providers may process your data on our behalf to deliver the Service's features
  • Third-party AI providers have their own privacy policies and data practices
  • AI processing may occur in jurisdictions outside the UK and EEA, subject to appropriate safeguards (see Section 8)

We may use your data, including inputs and outputs from AI interactions, to:

  • Provide and improve the Service's features and functionality
  • Improve, train, and develop our AI models, agents, and algorithms
  • Develop new features and services
  • Analyse and understand usage patterns
  • Ensure quality and safety of AI outputs

Data obtained via Google APIs is subject to additional restrictions (see Section 16). For more details on how AI is used within the Service, please see our AI Transparency page.

6. Legal Basis for Processing (UK GDPR)

We process your personal data on the following legal bases:

  • Contract Performance: Processing necessary to perform our contract with you (providing the Service)
  • Legitimate Interests: Processing necessary for our legitimate business interests, such as improving the Service, marketing, fraud prevention, and security
  • Consent: Where you have given consent for specific processing activities
  • Legal Obligation: Processing necessary to comply with legal requirements

7. Data Sharing and Disclosure

We may share your information with the following categories of recipients:

7.1 Service Providers

We share data with third-party service providers who perform services on our behalf, including:

  • Cloud infrastructure and hosting providers
  • AI and machine learning providers
  • Payment processors
  • Analytics providers
  • Email and communication services
  • Customer support tools

7.2 Business Partners

We may share data with business partners for joint marketing initiatives, integrations, and co-branded services.

7.3 Legal and Safety

We may disclose your information:

  • To comply with legal obligations, court orders, or government requests
  • To protect our rights, property, or safety, or that of our users or others
  • To investigate potential violations of our terms or policies
  • To detect, prevent, or address fraud, security, or technical issues

7.4 Business Transfers

In the event of a merger, acquisition, reorganisation, bankruptcy, or sale of assets, your information may be transferred to the acquiring entity.

8. International Data Transfers

Your information may be transferred to, stored, and processed in countries outside the UK and European Economic Area (EEA), including the United States. These countries may have data protection laws that differ from those in your jurisdiction.

Where we transfer personal data outside the UK/EEA, we implement appropriate safeguards, which may include Standard Contractual Clauses approved by the UK Information Commissioner's Office or the European Commission, or reliance on adequacy decisions.

9. Data Retention

We retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including:

  • For the duration of your account and subscription
  • As required to comply with legal obligations
  • As necessary to resolve disputes and enforce agreements
  • For legitimate business purposes, such as maintaining records and improving services

Following account closure, we may retain certain data for a reasonable period for legal, regulatory, and business purposes.

10. Your Rights (UK GDPR)

Under UK data protection law, you have the following rights:

  • Right of Access: Request a copy of the personal data we hold about you
  • Right to Rectification: Request correction of inaccurate or incomplete data
  • Right to Erasure: Request deletion of your personal data in certain circumstances
  • Right to Restrict Processing: Request limitation of processing in certain circumstances
  • Right to Data Portability: Request transfer of your data to another service
  • Right to Object: Object to processing based on legitimate interests or for direct marketing
  • Right to Withdraw Consent: Withdraw consent where processing is based on consent
  • Right to Lodge a Complaint: Complain to the Information Commissioner's Office (ICO)

To exercise these rights, please contact us using the details below. We may need to verify your identity before processing your request.

11. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to collect and store information about your use of the Service. These include:

  • Essential Cookies: Required for the Service to function properly
  • Analytics Cookies: Help us understand how users interact with the Service
  • Functional Cookies: Remember your preferences and settings
  • Marketing Cookies: Used to deliver relevant advertisements

You can manage cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the Service.

12. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. However, no method of transmission over the internet or electronic storage is completely secure.

We cannot guarantee absolute security of your data. You are responsible for maintaining the confidentiality of your account credentials and for any activities that occur under your account.

13. Children's Privacy

The Service is not intended for children under the age of 18. We do not knowingly collect personal data from children. If you believe we have collected information from a child, please contact us immediately.

14. Third-Party Links

The Service may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing any personal data.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on the Service and updating the "Last updated" date. Your continued use of the Service after any changes constitutes acceptance of the updated Privacy Policy.

16. Google API Services

HappyFace uses Google API services solely for Google Sign-In (authentication) and Google Calendar synchronisation. HappyFace's use and transfer of information received from these Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.

Specifically, data obtained from Google APIs:

  • Is used only to provide and improve user-facing features of the Service (authentication and calendar synchronisation)
  • Is not used to develop, improve, or train generalised or non-personalised AI and/or ML models
  • Is not transferred to third-party AI providers for model training purposes
  • Is not used for advertising purposes
  • Is not transferred to third parties except as necessary to provide the Service or as required by law

For full details on how AI is used within the Service, please see our AI Transparency page.

17. Contact Information

If you have questions about this Privacy Policy or wish to exercise your data protection rights, please contact us:

Email: privacy@happyface.ai

Data Protection Officer: dpo@happyface.ai

Abuse reports and compliance complaints: abuse@happyface.ai

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk if you believe your data protection rights have been violated.

By using the Service, you acknowledge that you have read, understood, and agree to this Privacy Policy.