1. This document explains what data is collected in connection with Yolio.
2. It also explains how we use that data, where we store it and how we protect it. In short:
* In order to provide you with our services, we need to process some of your data. Should we need to process your data for any other purpose than offering you our products and services, we will always ask you for your consent in advance.
* To be able to uphold our contractual obligations with you, we need to share some of your data with our Trusted Partners, such as Google, Paypal Services, Stripe.
* Our calls are recorded for training and monitoring purposes.
3. Finally, it explains your rights in relation to your personal data.
Who we are
What this policy covers
We recognise we have a special obligation to protect personal data obtained from children. We do not and will not knowingly collect personal data from any child under the age of 16 without consent from a parent or guardian. If you are a parent or guardian and are concerned about the transfer of personal data about your child, please contact email@example.com
Information we collect
When you Use Yolio Ltd services, we may collect the following data if relevant (how we use it is described later in this policy).
1. Your name and surname
2. Your email address and contact number
3. Your correspondence address
4. IP address
5. Technical details about any device which you use to access our services, including: Internet and or/network connection; any mobile device identifier, your operating system, browser type or other software, or your hardware or other technical details. This is technical data about our users and their actions and patters which does not provide personal data.
6. Details of your use of our services including, but not limited to: metrics data about when and how you use the services; traffic data; and your geographical location data.
How data about you is collected
We may collect and process data about you in the following ways:
1. Data you give us via Yolio Ltd services
2. Data given when you contact us or report a problem with Yolio Ltd services
3. Data about your activity as a user of our services (in addition to your IP address, country of origin, purchases) – is collected automatically
4. We may also ask you to complete surveys that we use for research purposes. However, your response to surveys is not required. We may collect this data via Yolio Ltd services or trusted partners connected with us for optional services such as surveys or polls. We will not receive or store any of your payment details, this is fully handled by the relevant payment platform and/or payment method/processor. If/when you make purchases in Yolio Ltd service, we are notified by the payment processor once the transaction takes place and then ensure you receive your purchase. We do not, however, receive any of your actual payment details. We only keep the data concerning transaction dates, currencies, value and the products of the transaction.
Why do we use your data (legal basis for data processing)
When we process personal data about you, we do so only as necessary to provide Yolio Ltd the services you use (ie. To perform the agreement between us), to meet our legal obligations or to fulfil the so called ‘legitimate interests’ of Yolio Ltd, or in accordance with the other cases described in the section ‘How is your data used?’ To clarify, by legitimate interests, we mean lawful purposes that be reasonably expected (protecting the security of the data we process, marketing Yolio Ltd services as well as ensuring our marketing is relevant for you, conducting anti-fraud checks). When we rely on the legitimate interest, we consider and balance any potential impact on you and your rights. For other purposes, we will ask for your consent and you will be entitled to withdraw this consent at any time with no impact on the validity of the processing before your consent has been withdrawn. When we transfer your data outside the European Economic Area (hereafter referred to as the ‘EEA’), we do so on the basis of a variety of legal mechanisms, as described in ‘Trusted Partners’.
How do we handle your personal information
1. We will keep data that is associated with the services you use for the duration of the agreement to access the services. Following account closure, limited data that we collect about you will still be retained for an additional few years for tax, legal or accounting purposes.
2. If you contact us and don’t use our services, we will retain correspondence with you as long as necessary to assist you, following by a period necessary for legal or accountability purposes.
3. For marketing purposes, we will store data as long as we have valid consent. If consent is withdrawn, we will delete all personal data without undue delay and no later than within 30 days from the moment we receive a request to unsubscribe.
How is your information used
Your data may be used for the following purposes;
1. To carry out our obligations arising from any agreements between you and us.
2. To provide you with marketing information (including personalised and targeted marketing emails), which we feel may interest you. For example, we may send you newsletters or emails about Yolio Ltd services (of course, this is optional and we will ask you for permission first).
3. To provide you with products or services that you request from us.
4. To communicate with the users of our services
5. To notify you about changes to Yolio Ltd services
6. To maintain, improve or modify Yolio Ltd services
7. To conduct competitions organised by Yolio Ltd (including contact with participants, evaluation of applications, distribution of prizes, payment of tax on prizes).
8. To calculate conversion rates and other elements of Yolio Ltd services performance
9. For tax, legal and accounting purposes
10. For the accountability purposes as defined by EU legislation
11. To target and personalise our marketing communications, offers and advertisements that we display on our websites and services as well as those of third parties based on the combined data we have collected about you.
Whenever we’re personalising or targeting our marketing communications, offers and advertisements, we may profile your personal data, which means that we may use the data we collect to adjust the communication addressed to you to meet your needs. In such cases, we do not, however, use your personal data for profiling, which would constitute automated decision making that could affect your legal situation (ie. We do not use algorithms to make decisions which would have an impact on your individual legal rights or affect your legal status or rights under the agreement between us.)
If you decide that you no longer want to receive personalised offers, product recommendations from us or any advertising news at all, you can object to this service at any time.
We might process some aggregated and general non-personal data on user behaviour (eg. Sales per region) with third party partners who work with us to provide Yolio Ltd services to you (for example, with payment providers) in order to support, improve or amend Yolio services. We may also share non-personal data with data analysis services to help us run Yolio Ltd services.
Please remember that any communications you have via Yolio Ltd services may reveal details about you. Also any data you post publicly using Yolio Ltd services will be publicly available to Yolio Ltd users and others. We are not responsible for your use of any private personal data which you choose to make available via Yolio Ltd services, or the activities of other users or other third parties to whom you give or make available your data.
Third party information collection and external services
Our Trusted Partners
In order to fulfil your order, we may need to share your information with the following Trusted Partners who were engaged by us to help deliver our services and functionalities with you. Please rest assured that we always provide our partners with the minimum data necessary for them to achieve the purpose of their cooperation with us. They may have access to limited data about you and process it on our behalf. When required by law, we may also share your data with the police or other government authorities (including your IP address and details of suspected unlawful or fraudulent activity such as unauthorised use of payment methods and security risk scores). We will retain details of your order for 6 years in order to comply with HMRC requirements.
Please be aware that we are subject to various laws and we may be required to release personal data to comply with law enforcement or other legal requirements. If, at any point, you wish to see a copy of the data we hold on you, details of how we use and store your data, or receive further details regarding your rights, you can request this from us via email using the details outlined earlier in this policy. If any data we hold regarding you is incorrect, you may request a correction to your data at any time. You may also request that we cease processing your data at any time or to object to our continued use of your data. This does not affect any processing that has been carried out prior to your request being received. It is also important to note that should you object to the processing of your data, we will be unable to fulfil the required contract between ourselves and you. You have the right to request that we delete any or all personal data Yolio Ltd holds on you at any time. The only reason we would not carry out this request is if it would result in us being in breach of other legal or regulatory obligations we have, but we would always inform you at the time were this the case. You also have the right to request that we transmit all or any data we hold regarding you to a third party in a commonly used electronic format. You have given us consent to use your personal data to contact you in the future regarding products and services from Yolio Ltd that we believe you may be interested in. We do not share your data for marketing purposes with any organisations outside of Yolio Ltd and your data will only be used for the aforementioned purposes. You have the right to withdraw your consent at any time. This wouldn’t affect any use of your data carried out up until that point but would have immediate effect when we receive your request. You can withdraw your consent by contacting us via phone or e-mail, or by writing to us at the address outlined previously in this policy. While you do not have to give us permission to use your data, unfortunately we would be unable to fulfil your order and our ongoing contractual obligations, and we would therefore need to cancel your account with us.
You have the right to object to the processing of your personal data in certain situations and for marketing purposes at any time. You can do so by contacting us on the email address: firstname.lastname@example.org
You have the following additional rights:
* You have the right to access data held about you
* You may contact us to request that we delete your personal data from our system
* You may ask us to rectify your personal data if appropriate
* You may ask us to restrict the processing of your data
* You have the right to transfer your data to another entity
* You have the right to file a complaint with a data protection authority
You can exercise these rights by contacting us at email@example.com
In case of any concerns or questions about your privacy, please do contact us and we will do our best to assist you. You can reach us at: firstname.lastname@example.org or contact our Data Protection Officer in writing. If, however, you feel we have no satisfactorily dealt with your concern, you can report it to your local data protection authority.