YOL Privacy Statement (revised December 2019)
3.1. Active Information Collected
- Certain features in this Application may require Personally Identifiable Information, which is information such as your name, title, occupation, employer name, business address, business telephone number, business fax number, business e-mail address or home phone number (collectively, Personally Identifiable Information or “PII”).
- When you visit and respond to the Application, our web servers may automatically collect web site usage information. Application usage information is non-PII that describes how visitors use and navigate in this Application. Application usage information may include, without limitation, the number and frequency of visitors to each web page, the length of stay on each web page, browser type, the preceding and subsequent page viewed, and an Internet Protocol (“IP”) address.
- As part of the process for submitting your personal information, we may use that information for several general purposes: to tell users about products, seminars and services if users or a user’s organization so request, to fulfill such a request, to contact users if we need to obtain or provide additional information; to verify the accuracy of our records, and to contact users regarding customer satisfaction surveys.
- A cookie is a small text file containing information that a web site transfers to a computer’s hard disk for record-keeping purposes. Cookies allow us to analyze our site traffic patterns and to provide a user-friendly YOL registration and log-in process. A cookie cannot give us access to a user’s computer or to information beyond what is provide to us by users. Most web browsers automatically accept cookies; consult browser’s manual or online help for additional information on restricting or disabling the browser’s handling of cookies. If cookies are disabled, participants can still view the publicly available information on our web site, but users will not be able to take advantage of offers or activities requiring a YOL account.
3.2. Use of Information Provided by You
- To perform the services that YOL has been engaged to perform by the Client (who may be your employer)
- To respond to your inquiries, comments, questions or requests;
- To monitor and statistically analyze usage of the Application and to improve the Application and/or our product and services offerings;
- To administer the Application’s systems, to audit the Application and for other internal business purposes;
- To comply with a judicial, administrative or similar proceeding or order such as a subpoena, search warrant, discovery request or other valid law enforcement measure or investigation;
- To protect the legal rights, interests and safety of the Application, our users or others in cooperation with copyright owners, internet service providers, wireless service providers and law enforcement agencies;
- When we employ third parties to perform functions or services on our behalf, including, without limitation, third party hosting companies, communication services and data analysts; or
- To share with and among our affiliates or in the event there is any transfer, sale, or assignment of any of our business and/or assets or in the event of any other corporate change.
YOL may also disclose personal information if required to do so by law or in the good faith belief that such action is necessary in connection with a sale, merger, transfer, exchange or other disposition (whether of assets, stock or otherwise) of all or a portion of a business of YOL and/or its subsidiaries or to:
- conform to legal requirements or comply with legal process served on YOL or this web site;
- protect and defend the rights or property of YOL and this web site;
- enforce its agreements with users or a user’s organization, or
- act in urgent circumstances to protect personal safety or the public.
3.3. Information Collected by Automated Means
- We use various tools to enhance the Application user experience and track users of the Application, including cookies. Cookies are small pieces of text that a website places on your computer to help remember information about your visit. Cookies cannot read data off our computer’s hard drive or collect your personal information. We use information collected from cookies to improve your experience and the overall quality of our services. To access the features of the Application you must enable cookies using your browser’s preferences.
- Information collected through passive means may be non-identifying or may be associated with you. In the latter case, it will be treated as PII.
3.4. Our Commitment to Security
- Your privacy is important to us. YOL uses reasonable efforts and safeguards to protect the PII we collect on this Web Site from unauthorized access, use, modification or disclosure. The Application and all information that you submit through the application is collected, stored and processed within Company-controlled databases. We restrict access to your PII to those employees of ours and to those service providers who need to use it to manage the Application. Client data is retained in accordance with the retention policy of the applicable Client master service agreement / contract. We have implemented physical, administrative, and technical safeguards to protect your PII from unauthorized access. However, as effective as our security measures are, no security system is impenetrable. We cannot guarantee the security of our systems nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet. YOL is certified and compliant with the international information security standard ISO 27001:2013.
3.5. Data Subject Rights
- Right of Access: An individual has the right to ask whether we process data about them and to have access to that data.
- Right to Rectification: Where personal data is inaccurate or incomplete, an individual has the right to request that it be corrected or completed.
- Right to Erasure: An individual has the right to require that YOL erases personal data without undue delay.
- Right to Restrict Processing: An individual can exercise the right to a restriction of processing of their personal data under certain circumstances.
- Right to Data Portability: An individual has the right to request that their personal data be provided to them and to transfer that data to another party.
- Right to Object: An individual has the right to object to processing under certain circumstances
- Automated Decision-Making Rights: An individual has the right to not be the subject of automated decision-making where the decision may impact them.
3.6 California Residents
The California Consumer Privacy Act provides some California residents with the additional rights listed below. To exercise these rights, contact us at email@example.com.
Right to Know. You have the right to know and see what data we have collected about you over the past 12 months, including:
- The categories of personal information we have collected about you;
- The categories of sources from which the personal information is collected;
- The business or commercial purpose for collecting your personal information;
- The categories of third parties with whom we have shared your personal information; and
- The specific pieces of personal information we have collected about you.
Right to Delete. You have the right to request that we delete the personal information we have collected from you (and direct our service providers to do the same). There are a number of exceptions, however, that include, but are not limited to, when the information is necessary for us or a third party to do any of the following:
- Complete your transaction;
- Provide you a good or service;
- Perform a contract between us and you;
- Protect your security and prosecute those responsible for breaching it;
- Fix our system in the case of a bug;
- Protect the free speech rights of you or other users;
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.);
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interests that adheres to all other applicable ethics and privacy laws;
- Comply with a legal obligation; or
- Make other internal and lawful uses of the information that are compatible with the context in which you provided it.
Other Rights. You can request certain information about our disclosure of personal information to third parties for their own direct marketing purposes during the preceding calendar year. This request is free and may be made once a year. You also have the right not to be discriminated against for exercising any of the rights listed above.
Exercising Your California Privacy Rights. To request access to or deletion of your personal information, or to exercise any other data rights under California law, please contact us using one of the following methods:
Email: You may write to us to exercise rights. Please include your full name, email address, and phone number, along with why you are writing, so that we can process your request in an efficient manner. You can email us at firstname.lastname@example.org.
Response Timing and Format. We aim to respond to a consumer request for access or deletion within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing.
3.7. Exercising Data Subject’s Rights and Contacting YOL
This Application may contain pages through which you can change your preferences or update the PII. You can contact YOL directly in order to:
- Update or correct the PII that we store about you;
- Direct us to render inactive on our systems all your PII; or
- Make a request related to the data subject rights listed in section 4.5.
We may be reached at email@example.com.
Please note that if you request us to render inactive your PII, we may still use aggregated non-PII, and some PII that you provided may continue to reside on backup servers and other non-active systems for data restoration purposes. We will not manually delete PII from such backup media.
3.8. User Consent
- You can withdraw your consent at any time.
3.9. Consent to Transfer
- Please be aware that any information you provide to us may be transferred within and/or outside of the country of origin to another YOL location. YOL carefully reviews international data transfers before they take place to ensure that they fall within the limits of local and international laws and regulations. By using the Application or by providing us with your information, you consent to this transfer.
- The YOL applications are not intended for use by children. If you are under eighteen (18) years of age, you may use the YOL Application only with the involvement of a parent or guardian. Further, YOL’s services are not directed to children or anyone under 18 years of age. YOL will not knowingly collect, maintain or use any personally identifiable information about anyone under 18 years of age. In the event we discover that a child under the age of eighteen (18) has responded to this Application with personally identifiable information, we will delete such child’s personally identifiable information from our database.
3.11. Breach Notification
- It is the policy of YOL to be fair and proportionate when considering the actions to be taken to inform affected parties regarding breaches of personal data. Where a breach is known to have occurred which is likely to result in a risk to the rights and freedoms of individuals, the relevant supervisory authority will be informed within 72 hours. This will be managed in accordance with our Information Security Incident Response Procedure which sets out the overall process of handling information security incidents.
Unless otherwise indicated, this Web Site and its contents, including but not limited to all text, HTML code, CGI scripts, graphics, button images, and the site design and “look and feel,” are the property of YOL and are protected pursuant to U.S. and foreign copyright and trademark laws. By accessing this Web Site, you agree to the following terms and conditions, which govern this Web Site:
- This Web Site and the material on this Web Site may not be modified, copied, distributed, republished, downloaded, uploaded or commercially exploited in any manner without the prior written consent of YOL except that you are permitted to download a copy of any of the materials on this Web Site on a single computer for personal noncommercial use, provided no copyright, trademark or other proprietary notices are removed. No intellectual property or other rights in or to this Web Site or its contents are transferred to you.
- The information on this Web Site is provided solely for illustrative purposes and does not create any business, contractual or employment relationship.
- THE MATERIAL ON THIS WEB SITE IS PROVIDED ’AS IS’ AND IS WITHOUT WARRANTY OF ANY KIND. YOL DISCLAIMS ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING WITHOUT LIMITATION, THE IMPLIED WARRANTIES OF TITLE, NON-INFRINGEMENT, MERCHANTIBILITY AND FITNESS FOR A PARTICULAR PURPOSE, WITH RESPECT TO THIS WEB SITE AND THE MATERIAL ON THIS WEB SITE. YOL ALSO MAKES NO REPRESENTATIONS OR WARRANTIES AS TO WHETHER THE INFORMATION ACCESSIBLE ON THIS WEB SITE IS ACCURATE, COMPLETE OR CURRENT.
- TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAWS, IN NO EVENT SHALL YOL BE LIABLE FOR ANY DAMAGES OF ANY KIND OR CHARACTER, INCLUDING WITHOUT LIMITATION ANY COMPENSATORY, INCIDENTAL, DIRECT, INDIRECT, SPECIAL, PUNITIVE, OR CONSEQUENTIAL DAMAGES, LOSS OF USE, LOSS OF DATA, LOSS OF INCOME OR PROFIT, LOSS OF OR DAMAGE TO PROPERTY, CLAIMS OF THIRD PARTIES, OR OTHER LOSSES OF ANY KIND OR CHARACTER, EVEN IF YOL HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES OR LOSSES, ARISING OUT OF OR IN CONNECTION WITH THIS WEB SITE OR THE CONTENTS OF THIS WEB SITE.
- The posting of any content or material to this Web Site and the creation of a link from this Web Site to any other Web Site are expressly prohibited without the prior written consent of YOL
- YOL does not regularly review materials on Web Sites linked to this Web Site and does not necessarily endorse the materials appearing on any linked Web Sites.
- YOL reserves the right to change these terms and conditions at any time by updating this posting. Use of this Web Site following any such changes shall constitute acceptance of such changes.
This policy was last updated on December 2, 2019. For a list of the exact changes, please reach out to firstname.lastname@example.org.