PRIVACY POLICY FOR YOMENTO MANAGEMENT AB

 

Update date: October 6 2020

1. GENERAL INFORMATION

1.1 We are Yomento Management AB, company registration number 559015-5262 with registered address at Kyrkslingan 11, 111 49 Stockholm (“Yomento” “we” or “us”). This document contains a policy statement regarding our collection, use and processing of personal data (“Privacy Policy”). This Privacy Policy is applicable when you use the Yomento mobile application or any version thereof (“Application”) and our website www.yomento.com (“Website”).

1.2 Our terms and conditions, available at www.yomento.com/terms-and-conditions, regulates the use of the Application (the “Terms and Conditions”)

1.3 You are using this service either because your employer or a company you are engaged by (the “Customer”) has decided to offer our Application to its employees, participants and consultants or because you have subscribed to the Service via Appstore, Gplay or another appropriate appstore.

1.4 The definitions in this Privacy Policy shall be interpreted in accordance with the Data Protection Regulation (Regulation 2016/679) (GDPR) and national implementations and other applicable national legislation, including Act (2018:218) with supplementary provisions to the EU Data Protection Regulation.

 

2. PROCESSED DATA 

2.1 We are using sub-contractors as cloud-based servers, CRM-systems, notification systems for processing of our data and we are using our best endeavour to ensure they are compliant with the relevant legal framework,

2.2 We will process personal data as below when you register and use the Application:

(a) first name and last name;
(b) gender
(c) email address;
(d) IP address;
(e) age group;
(f) what industry you work in;
(g) number of team members and team member’s name and email address;
(h) information about your use of the Application;
(i) content that you choose to post, upload and/or contribute to the Application;
(j) technical data, which may include unique device type & ID, network, language and operating system version, system performance information.
(k) Information about your geographical location.

We are unable to provide you with the Application in accordance with our Terms and Conditions unless you provide us with the personal data above. If you don’t want to share your personal data as set out in this Privacy Policy, you should not accept this Privacy Policy and you should not download and use the Application.

2.3 We will process the following personal data when you visit our Website:

(a) information about your use of the Website;
(b) content that you choose to provide us with on the Website, such as information you provide when completing forms;
(c) technical data, which may include the URL you are redirected to the Website from, your IP address, unique device ID, network and computer performance, browser type, language and identifying information and operating system.

 

 

3. PURPOSES OF PROCESSING 

3.1 We will process the personal data set out above for the following purposes:

(a) to provide personal and relevant feedback to you;
(b) to provide the Customer with information on an aggregated basis in order for the Customer to optimize its leadership initiatives. The only personal data that the Customer can see about you, as a user of the Application, is if you have been active in the Application the last 30 days in order to understand if their leaders are using the services as expected;
(c) to administrate your account, to enable and provide the Application and the Website and integration with third party services, and to provide, personalize and improve your experience with the Application and the Website, and to otherwise provide the Application according to the Terms and Conditions;
(d) to inform you about updates of the Application and Website, the Terms and Conditions and this Privacy Policy;
(e) to improve and develop the Application and Website and to analyse your use of the Application and Website;
(f) to ensure the technical functioning of the Application and Website and to prevent use of in breach of the terms and conditions; and
(g) to enforce the Terms and Conditions, including to protect our rights, property and safety and also the rights, property and safety of third parties if necessary.

 

4. LEGAL GROUND

4.1 Consent. When registering to use the Application you consent to the processing of the personal data above as set out in this Privacy Policy.

4.2 Fulfilment of contract. We process your personal data to be able to provide the Application to you as set out in the terms and conditions and to be able to provide our services to the Customer.

 

5. DISCLOSURE OF PERSONAL DATA

5.1 We share and transfer your personal data for storage to third parties as stipulated below. In the event that your personal data is subject to transfer outside EU/EEA, we guarantee that adequate security measures have been taken for such transfer in accordance with applicable data protection laws.

(i) Amazon AWS – server
(ii) Cloudways – server
(iii) Mailgun – email
(iv) Mixpanel – analytics
(v) OneSignal – push notifications

5.2 When using the Application and the Website you may be directed to other websites where the personal data collected is outside of our control. The privacy policy of the other website will govern the personal data obtained from you on that website.

5.3 We will never sell or resell any personal data to any third party. We will not engage in any advertising set-ups using the personal data for commercial reasons. We may use aggregated personal data for marketing purposes but individual personal data will never be disclosed.

 

6. RESPONDING TO LEGAL REQUESTS AND PREVENTING HARM

We may access, preserve and share your personal data in response to a legal request (like a search warrant, court order or a subpoena or the like), or when necessary to detect, prevent and address fraud and other illegal activity, to protect ourselves, you and other users, including as part of investigations.

 

7. COOKIES, PIXELS AND OTHER SYSTEM TECHNOLOGIES

We collect information by using technology such as cookies, pixels and tags (on your browser or device), pursuant to our Cookie Policy available at www.yomento.com/cookie-policy/.

 

8. RETENTION

We store your personal data as long as necessary in order to fulfil the purposes for which it was collected pursuant to this Privacy Policy or as long as we have legal grounds to do so. We may also keep anonymous versions of your data and process it for statistical purposes indefinitely as it will no longer constitute personal data.

 

9. CHILDREN

The Services are not directed to persons under the age of 18. If you are a parent or guardian of a person under the age of 18 and you become aware of that the child has provided personal data to us without your consent, please contact support@yomento.com to exercise your access, rectification, erasure, limiting of processing and objection rights.

 

10. YOUR RIGHTS

10.1 You have an absolute right to object to the processing of your personal data for direct marketing. You also have the right to recall your prior given consent. The withdrawal of your consent does not affect the lawfulness of the processing based on the consent before its withdrawal, and we may continue processing your personal data based on other legal grounds, except for direct marketing.

10.2 You have the right to request access and further information concerning the processing of your personal data, or request that we correct, rectify, complete, erase or restrict the processing of your personal data. You have the right to obtain a copy of the personal data that we process relating to you free of charge once (1) every calendar year. For any additional copies requested by you, we may charge a reasonable fee based on administrative costs.

10.3 If the processing is based on the legal grounds consent or fulfilment of contract you have the right to data portability. Data portability means that you can receive the personal data that you have provided to us, in a structured, commonly used and machine-readable format, and have the right to transfer such data to another data controller.

 

11. CONTACT INFORMATION

11.1 To exercise your rights, or if you have any questions regarding our processing of your personal data, please contact us at support@yomento.com or the following address Yomento Management AB, Kyrkslingan 11, 111 49 Stockholm, Sweden. In your letter/email please state your full name and email address that you have signed up with in our services. Note that you should sign the request to receive information of the processing of your personal data yourself.

11.2 If you have any complaints regarding our processing of your personal data, you may file a complaint to the Swedish data protection authority (Sw. Datainspektionen), https://www.datainspektionen.se/.

 

12. NOTICE OF CHANGES TO THE PRIVACY POLICY

We reserve the right to unilaterally amend the terms of this Privacy Policy from time to time. The Terms of Service can be downloaded from our website, www.yomento.com/privacy-policy/.If your consent is required due to the changes, we will provide you additional prominent notice as appropriate under the circumstances and, ask for your consent in accordance with applicable law.

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