YPDi AB, a limited liability company registered in Sweden with company registration no. 559129-7659, YPDi AB (YourPDi) We Work Malmskillnadsgatan 32 111 51 Stockholm, Sweden (“YPDi” or “we”), offers a mobile application where users can organize and manage their personal information, material and documents (the “App”) and a website where additional information about the App is provided (the “Site”). The App and the Site are collectively referred to herein as the “Service”).
1. PERSONAL DATA CONTROLLER
1.1 When YPDi is processing personal data on your behalf, e.g. by providing storage space for your User Data in the App and by erasing data as per your instructions, YPDi is acting as your data processor. You are responsible for ensuring that your use of personal data in the User Data is in compliance with applicable data protection legislation with respect to, inter alia, legal ground for the processing and information to those individuals whose personal data you are uploading in the App. When acting as a data processor to you, YPDi undertakes to comply with the provisions in the relevant data protection legislation applicable to data processors (as set forth, namely, in Article 28 of the General Data Protection Regulation, EU 2016/679).
2. WHAT PERSONAL DATA DO WE COLLECT AND WHEN DO WE COLLECT IT
2.1 Personal data is information which directly or indirectly can identify a living individual, such as but not limited to name, address, photo and location data. YPDi collects personal data pertaining to you when you (i) create an account for the Service, (ii) when you use the Service, (iii) when you interact with us, e.g. on the Site, in our social media, via email, mail or phone and via our support service and (iv) when you are visiting our Site.
2.2 Due to the nature of the Service, the personal data that we collect and process will vary from one user to another depending on what User Data he or she uploads to the Service.
Notwithstanding the foregoing, the personal data processed by us in connection with the Service typically include names, addresses, e-mail addresses, photos, gender, login information, age, IP address, MAC address, other device information and payment information. The personal data processed may include sensitive personal data, e.g. related to health, political opinion or religious belief if you choose to upload User Data in the App which includes such information. YPDi will not process sensitive personal data for its own purposes, merely to provide you the Service.
3. PURPOSES OF OUR PROCESSING OF DATA
YPDi will process the personal data we have collected directly from you or through third parties for the following purposes:
a) to provide the Service you have signed up to by downloading the App, and to administer our agreement with you (including but not limited to processing your payment);
b) to communicate with you, e.g. through our social media accounts and our customer service;
c) to verify your identity when you sign in to the App and to prevent or detect fraud;
d) to obtain statistics over the use of our Service and to maintain, develop, test and improve our Services;
4. LEGAL BASIS FOR OUR PROCESSING OF PERSONAL DATA
We will always adhere to applicable data protection legislation in the EU when processing your personal data. The legal basis for our processing of your personal data is the performance of an agreement with you. We may also process your personal data based on a balancing of interest, i.e. YPDi’s interest of processing the data outweighs the impact and risk that the processing may have on your integrity. Such interest can for example be to market ourselves to our App users and visitors on our Site, or an interest in developing our services. If YPDi’s processing of personal data requires your consent, we will obtain your prior consent to such processing, by having you actively tick a box after having been provided with more information on the processing requiring your consent. You may at any time withdraw your consent where applicable by following the instructions described in Section e) above. Please note that if you withdraw your consent, we will not be able to send you personalized offers and recommendations.
5. HOW WE SHARE YOUR PERSONAL DATA
5.1 We acknowledge that the User Data that you upload to the App is very sensitive information. YPDi will not share any personal data that we collect with any third party, except as otherwise expressly stipulated herein.
5.2 We may engage external partners to perform services on behalf of YPDi, e.g. to provide IT services, payment services or to assist in marketing, analysis or statistics. The performance of these services may entail such parties obtaining access to your personal data. YPDi has got agreements in place with these external partners, which are aimed at ensuring the protection of your personal data.
5.3 Your personal data may also be disclosed, if needed, to comply with statutory legal requirements or requirements from authorities or agencies, to safeguard YPDi’s legal interests or to detect or prevent fraud and other security or technical issues.
5.4 We may share aggregated, non-identifiable information with our partners in order to provide you with relevant offers consistent with your permission. We will never share your personal information or your User Data with these partners in such a manner as to allow them to identify you.
5.6 Please note that the App includes a sharing feature which allows the User to send other users of the App certain User Data via the App. YPDi is not responsible for the interactions of users who engage with each other on the App, and is not liable for any damage that may result from such engagement.
6. HOW LONG DO WE KEEP YOUR PERSONAL DATA
6.1 YPDi will only process personal data for as long as it is necessary to fulfil the purposes of the processing or to fulfil YPDi’s legal obligations. User Data is typically erased three (3) months after a user account in the Service has been terminated. YPDi has procedures in place for the safe deletion of data once the purposes of the processing has been fulfilled.
6.2 Aggregate and/or anonymous data derived from your account in the Service or from your use of the Site may remain on YPDi’s servers indefinitely.
7. USE OF INFORMATION FROM YOUR MOBILE DEVICE
7.1 The mobile application offered by YPDi requires access to certain information from your mobile device (such as, inter alia, your mobile phone or tablet) in order to function as intended. We will never collect this data, unless you have given your explicit consent hereto.
Below you will find information on how we may use information from your mobile device, if you have consented to such use.
Location: YPDi will never collect or use information on the location of your device.
Photos and camera: YPDi will not gain access to your photos or your camera without first obtaining your explicit consent and we will never import the picture library on your mobile device. If you give YPDi permission to access the photos on your mobile device, we will only have access to the photos that you have explicitly given us permission to use.
Contacts: YPDi will never import the contacts stored on your mobile device unless you have explicitly consented hereto.
Microphone: YPDi will never get access to the microphone on your mobile device unless you have explicitly consented hereto.
8. SECURITY MEASURES
8.1 Maintaining your integrity and the security of your User Data uploaded to the Service and preventing unauthorized access to it or use thereof is our number one priority. We use generally accepted industry standard technologies and internal procedures to achieve this and all content provided by you in the App is encrypted and cannot be read by YPDi. The personal data and User Data are hosted on third party servers which provide advanced strict security standards (both physical and logical). In addition, we employ highly secure services using state of the art encryption and architectures mechanisms. Furthermore, we implement a secure permission management and auditing system using specific and proprietary firewall and network access filtering as well as security group mechanisms. Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use will never occur.
9. LINKS TO THIRD PARTY WEBSITES
Certain links provided in the App and/or Site may permit users to leave our App and/or Site and enter non-YPDi sites or services. Those linked sites and services are provided solely as a convenience to you. Those linked sites and services are not under the control of YPDi and we are not responsible for the availability of such external sites or services. It is always advisable to read such documents carefully before using those sites and services in order to know what kind of information they are collecting.
10. YOUR RIGHTS
10.1 Applicable data protection legislation grants you a number of rights in relation to personal data which you have shared with us. These rights include a right to request access to the personal data concerning you which we are processing, to have incorrect personal data corrected, to request that YPDi ceases its processing of your personal data, to have the processing of your personal data limited, to exercise your right to data portability and to object to our processing of your personal data. You may exercise these rights at any time by contacting us at firstname.lastname@example.org. Please note that some of the rights above only may be exercised in certain situations, e.g. the right to data portability, which only applies when the processing is carried out on the basis of an agreement or a consent and if the processing is carried out by automated means.
10.2 You may also lodge a complaint with the applicable supervisory authority if you believe that your personal data has been or is being processed in contradiction with applicable data protection legislation.
(30) days after such notice was provided on our App, the Site and/or sent to you via e-mail, whichever is the earlier.
12. CONTACT INFORMATION
If you have any questions regarding how we process your personal information, want to exercise any of your rights or want to know more about the rights, please contact us as indicated below.
Address: YPDi AB (YourPDi) We Work Malmskillnadsgatan 32 111 51 Stockholm.
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