This policy applies across all websites that we own and operate and all products and services we provide, including our online and mobile financial services products, and any other apps or services we may offer. For the purpose of this notice, we’ll just call them our ‘services’.
Our principles of data protection
Our approach to data protection has five key principles.
Transparency: We aim to be clear and transparent about how we process personal data.
Empowerment: We want to give our clients the best experience and the best access to their own data.
Restriction: We aim to restrict our own access to your data so we only deal with what is essential for providing the best service and maintaining our legal obligations. Data is not shared within or outside our organisation except where necessary for legitimate purposes.
Security: We follow industry leading approaches to securing the personal data entrusted to us.
Stewardship: We accept the responsibility that comes with processing personal data.
How we collect your data
When you visit our websites or use our services, we collect personal data. The ways we collect it can be broadly categorised into the following:
Information you provide to us directly: When you visit or use some parts of our websites and/or services we might ask you to provide personal data to us. For example, we ask for your contact information when you respond to an offer, join us on social media, contact us with questions or request support. If you don’t want to provide us with personal data, you don’t have to, but it might mean you can’t use some parts of our websites or services.
Information we collect automatically: We collect some information about you automatically when you visit our websites or use our services, like your IP address and device type. We also collect information when you navigate through our websites and services, including what pages you looked at and what links you clicked on. This information is useful for us as it helps us get a better understanding of how you’re using our websites and services so that we can continue to provide the best experience possible.
Some of this information is collected using cookies and similar tracking technologies.
Information we get from third parties: The majority of information we collect, we collect directly from you. Sometimes we might collect personal data about you from other sources, such as publicly available materials or trusted third parties. We use this information to supplement the personal data we already hold about you, in order to better inform, personalise and improve our services, and to validate the personal data you provide.
Where we collect personal data, we’ll only process it:
to perform a contract with you, or
where we have legitimate interests to process the personal data and they’re not overridden by your rights, or
in accordance with a legal obligation, or
where we have your consent.
If we don’t collect your personal data, we may be unable to provide you with all our services, and some functions and features on our websites may not be available to you.
If you’re someone who doesn’t have a relationship with us, but believe that a Yavrio subscriber has entered your personal data into our websites or services, you’ll need to contact that subscriber for any questions you have about your personal data (including where you want to access, correct, amend, or request that the user delete, your personal data).
How we use your data
First and foremost, we use your personal data to operate our websites and provide you with any services you’ve requested, and to manage our relationship with you. We also use your personal data for other purposes, which may include the following:
To communicate with you. This may include:
providing you with information you’ve requested from us or information we are required to send to you
operational communications, like changes to our websites and services, security updates, or assistance with using our websites and services
marketing communications (about Yavrio or another product or service we think you might be interested in) in accordance with your marketing preferences
asking you for feedback or to take part in any research we are conducting (which we may engage a third party to assist with).
To support you: This may include assisting with the resolution of technical support issues or other issues relating to the websites or services, whether by email, in-app support or otherwise.
To enhance our websites and services and develop new ones: For example, by tracking and monitoring your use of websites and services so we can keep improving, or by carrying out technical analysis of our websites and services so that we can optimise your user experience and provide you with more efficient tools.
To market to you: In addition to sending you marketing communications, we may also use your personal data to display targeted advertising to you online – through our own websites and services or through third party websites and their platforms.
To analyse, aggregate and report: We may use the personal data we collect about you and other users of our websites and services (whether obtained directly or from third parties) to produce aggregated and anonymised analytics and reports, which we may share publicly or with third parties.
How we can share your data
There will be times when we need to share your personal data with third parties. We will only disclose your personal data to:
third party service providers and partners who assist and enable us to use the personal data to, for example, support delivery of or provide functionality on the website or services, or to market or promote our goods and services to you
regulators, law enforcement bodies, government agencies, courts or other third parties where we think it’s necessary to comply with applicable laws or regulations, or to exercise, establish or defend our legal rights. Where possible and appropriate, we will notify you of this type of disclosure
an actual or potential buyer (and its agents and advisors) in connection with an actual or proposed purchase, merger or acquisition of any part of our business
other people where we have your consent.
International data transfers
When we share data, it may be transferred to, and processed in, countries other than the country you live in. These countries may have laws different to what you are used to. Rest assured, where we disclose personal data to a third party in another country, we put safeguards in place to ensure your personal data remains protected.
For individuals in the European Economic Area (EEA), this means that your data may be transferred outside of the EEA. Where your personal data is transferred outside the EEA, it will only be transferred to countries that have been identified as providing adequate protection for EEA data or to a third party where we have approved transfer mechanisms in place to protect your personal data, for example, by entering into the European Commission’s Standard Contractual Clauses. For further information, please contact us using the details set out in the Contact us section below.
Security is a priority for us when it comes to your personal data. We’re committed to protecting your personal data and have appropriate technical and organisational measures in place to make sure that happens. For more information about security, check out our security pages.
The length of time we keep your personal data depends on what it is and whether we have an ongoing business need to retain it (for example, to provide you with a service you’ve requested or to comply with applicable legal, tax or accounting requirements).
We’ll retain your personal data for as long as we have a relationship with you and for a period of time afterwards where we have an ongoing business need to retain it, in accordance with our data retention policies and practices. Following that period, we’ll make sure it’s deleted or anonymised.
It is your personal data and you have certain rights relating to it. When it comes to marketing communications, you can ask us not to send you these at any time – just follow the unsubscribe instructions contained in the marketing communication.
You also have rights to:
know what personal data we hold about you, and to make sure it is correct and up to date
request a copy of your personal data, or ask us to restrict processing your personal data or delete it
object to our continued processing of your personal data
You can exercise these rights at any time by making a request.
If you’re not happy with how we are processing your personal data, please let us know by getting in touch. We will review and investigate your complaint, and try to get back to you within a reasonable time frame. You can also complain to your local data protection authority. They will be able to advise you how to submit a complaint.
How to contact us
If you’re curious about what personal data we hold about you or you have a question or feedback for us on this notice, our websites or services, please get in touch.
As a technology company, we prefer to communicate with you by email – this ensures that you’re put in contact with the right person, in the right location, and in accordance with any regulatory time frames.
Data Protection Officer: