I- Aims and Principles:

YUVO (“YUVO”) is committed to protecting the privacy, confidentiality, and security of your Personal Data. This Data Protection Policy outlines YUVO’s approach to ensuring that all Personal Data collected, stored, controlled and processed by YUVO is handled in strict compliance with applicable legal frameworks and best practices.

YUVO’S Data Processing activities are guided by the following key principals:

    Personal Data will be processed lawfully, fairly, and in a transparent manner. Data subjects will be provided with clear, accessible, and concise information about how their Data is collected, used, and protected.

    Personal Data will be collected for specified, explicit, and legitimate purposes. It will not be further processed in a manner that is incompatible with these original purposes unless legally permitted.

    YUVO will collect and process only the minimum amount of Personal Data necessary for the intended purpose, ensuring that excessive or irrelevant Data is not retained.

    Reasonable steps will be taken to ensure the accuracy and completeness of Personal Data. Inaccurate or outdated information will be rectified or erased promptly to maintain Data integrity.

    Data will be retained only for as long as necessary for the purposes for which it was collected, in accordance with YUVO’s Data retention policies and legal obligations.

    YUVO will implement appropriate technical and organizational security measures to prevent unauthorized access, disclosure, alteration, or destruction of Personal Data. These measures include encryption, access controls, regular security assessments, and staff training on Data protection.

    YUVO is responsible for demonstrating compliance with Data protection principles and will implement robust governance frameworks, conduct regular staff training, and carry out internal audits to ensure ongoing adherence to legal and regulatory requirements.

    II- Applicable Laws:

    YUVO complies with all applicable Data protection laws and regulations, including but not limited to:

    For residents outside the European Union and the United Arab Emirates, local Data Protection laws may also apply when engaging with YUVO’s websites, services, or products. In such cases, YUVO provides additional disclosures and implements necessary measures to ensure compliance with relevant local legal frameworks.

    III- Definitions:

      Personal Data refers to any information relating to an identified, or identifiable natural person. This may include the person’s name, identification number, location Data, or online identifier; it may also include factors specific to the person’s physical, physiological, genetic, mental, economic, cultural or social identity.

      A Data Subject is any identified or identifiable natural person whose Personal Data is being processed by a Data controller or Data Processor.

      Data Processing refers to any operation or set of operations performed on Personal Data, whether by automated or manual means. This includes collection, recording, organization, structuring, storage adaptation, retrieval, consultation, use, disclosure by transmission, dissemination, alignment or combination, restriction, erasure or destruction.

      A Third Party refers to any individual or legal entity that is not the Data Subject, but is authorized to access and process Personal Data under specific conditions.

      Consent is a freely given, specific, informed, and unambiguous indication of the Data Subject’s agreement to the processing of their Personal Data. Consent may be withdrawn at any time without affecting the lawfulness of processing conducted before its withdrawal.

      Profiling refers to any automated processing of Personal Data to evaluate certain aspects related to a person, such as their preferences, behavior, location, or movements.

      HTTPS Data refers to the protocol Data generated when websites are visited using the Hypertext Transfer Protocol (Secure). This Data may include the IP address, browser type and version, operating system, specific page visited, previous page visited, and the date and time of the visit.

      Cookies are small text files stored on a user’s device through a web browser during a website visit. These files allow information to be read and processed upon returning to the website using the same device. Cookies leverage the processing and storage capabilities the user’s browser, enabling the collection of information from the browser’s storage area.

      IV- Legal Grounds and Data Processing Principles

      1. Legal Grounds for Data Processing

      We base our Data Processing on several legal grounds under the General Data Protection Regulation (GDPR) and the Personal Data Protection Law (PDPL). The primary legal basis for processing your personal Data is your explicit consent, as outlined in Article 6(1)(a) of the GDPR and Article 4 of the PDPL. Consent must be freely given, specific, informed, and unambiguous. We will ask for your consent before processing your personal Data for any purpose.

      However, in specific circumstances outlined by law, we may process your Data without explicit consent, provided the legal requirements are met. The following exceptions apply:

      2. Rights of Data Subjects

      We value your control over your Personal Data. Under GDPR and PDPL, you are granted several key rights that allow you to manage and protect your personal Data effectively:

      1. Right to Information: You have the right to request information at any time regarding the Personal Data we are processing about you.
      2. Right to Rectification: If your Personal Data is incorrect or incomplete, you have the right to request corrections or updates.
      3. Right to Erasure: You can request the erasure of your Personal Data at any time, as long as we are not bound by legal obligations that require or allow us to retain your Data.
      4. Right to Restriction of Processing: You can request a restriction to the processing of your Personal Data, if the applicable legal requirements are met.
      5. Right to Object: You have the right to object to the Processing of your Data, particularly if it’s based on profiling or direct marketing purposes.
      6. Right to Object to Legitimate Interests: If the processing is carried out based on legitimate interests, you have the right to object to the processing by stating reasons specific to your particular situation.
      7. Right to Withdraw Consent: If Data Processing is based on a consent, you have the right to withdraw your consent at any time, with effect for future processing.
      8. Right to Data Portability: If the processing of your Data is based on consent or contract, you may request that your Data be transferred to another controller in a structured, commonly used, and machine-readable format, provided it does not adversely affect the rights of others.
      9. Right to File a Complaint: You have the right to file a complaint at any time with a Data Protection supervisory authority, if you believe that Data Processing has been carried out in violation of the applicable law.

      3. Data Processing of Personal Data coming from Children Under 13 Years

      We do not knowingly collect or process personal Data from children under the age of 13 without obtaining verifiable consent from their parent or legal guardian. If we become aware that we have inadvertently processed such Data, we will take steps to promptly delete it and ensure compliance with applicable regulations.

      V- Cross-Border Data Transfers:

      Personal Data processed by YUVO may be transferred across borders and handled by its affiliated companies, which include sister companies, parent companies, and subsidiaries. In such instances, we are committed to ensuring the protection of your personal Data during international transfers, in line with applicable laws and regulations. To achieve this, YUVO adheres to the following safeguards:

      By adopting these measures, YUVO ensures that personal Data is processed and transferred in compliance with the highest standards of Data protection, regardless of geographical location.

      VI- Data Processing Overview for Various User Groups:

      This section provides a detailed overview of how your personal Data is typically handled based on different user groups or Data subject categories. The following groups are identified:

      1. Regular website visitors
      2. YUVO Account Users & Product Customers
      3. Newsletter Recipients
      4. Participants in Surveys, Interviews, and Usability Tests
      5. Job Applicants
      6. Users Seeking Help and Support
      7. Development Partners

      1. Regular Website Visitors

      1.1 Server-log Personal Data

      When you visit our website, specific Personal Data is automatically shared with our servers by the browser on your device. This Data is then stored and processed on our server. This Data is necessary for the basic functionality of the website, and without it, the website cannot operate properly. As such, we collect and process server-log Data during your interaction with our website.

        The primary purpose for processing this Data is to provide you with the content of the website, maintain and enhance the security and integrity of our IT infrastructure, troubleshoot errors, improve search functionalities, and manage cookie settings. This helps ensure a smooth and efficient user experience while you interact with our website.

        As per the Article 6 Paragraph 1 (f) of the GDPR, the Processing of the Personal Data is considered lawful if the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party. Accordingly, and since we have a legitimate interest in the operation of an online presence, in communication with our partners, and in internal compliance reporting, therefore the processing of the Personal Data in this case is deemed to be lawful.

        The Processed Data includes HTTPS server-log Data, which typically consists of IP addresses, browser information, device details, and usage Data generated when accessing the website.

        1.2 Cookies Policy

        We use different types of cookies on our website to enhance user experience and ensure the smooth operation of our site. Cookies are small text files stored on your device that help us remember user preferences, optimize website functionality, and collect Data about your browsing behavior. We categorize cookies into two main types: Technically Required Cookies and Tracking Cookies.

        1.2.1 Technically required cookies:

        Technically required Cookies are essential for the proper functioning of our website, and they cannot be turned off using the site’s cookie management feature. While you can disable Cookies through your device browser settings, you should take into consideration that doing so may affect certain website functionalities, potentially rendering parts of the website unusable. We use three types of Technically Required Cookies: Consent Cookies, Session Cookies, and Security Cookies.

        i- Consent Cookies:

        These Cookies record and store User preferences regarding the acceptance or rejection of various types of Cookies on our website, helping to streamline and personalize the browsing experience. Without the disclosure of the required Personal Data here, the use of our website is not possible.

          Our purpose of Data Processing here is to track and record the user’s decision concerning Cookies usage on our website.

          According to Article 6(1)(f) of the GDPR, the Processing of the Personal Data is lawful if the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party. Since we have a legitimate interest in managing and controlling Cookies according to the User’s preferences in order to improve the User’s experience, the processing of the Personal Data in this case is deemed to be lawful.

          The processed Data is limited to the HTTPS Data and the User’s decision on Cookies preferences.

          The Data stored will be deleted after one year. Exceptionally, if the user’s decision was to reject Cookies, the Data will be deleted at the end of the session.

          ii- Session Cookies:

          These are temporary Cookies that store Data like user preferences and account information for the duration of a website visit, ensuring smoother navigation and personalized user experiences. Without the disclosure of the required Personal Data here, the website may not function optimally.

            Our purpose of Data Processing here is to enable login and store preferences such as language, country selection, and cookie settings.

            As per the Article 6(1)(f) of the GDPR, the Processing of the Personal Data shall be lawful if the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party. Accordingly, and since we have a legitimate interest in providing a better experience to our website’s users, the processing of the Personal Data in this case is deemed to be lawful.

            The processed Data includes user’s account details, language selection, country, and Cookies settings. The Data will be automatically transmitted by the browser of the user.

            The Data stored will be deleted after one year.

            iii- IT Security Cookies:

            These Cookies enhance the security of our website by protecting against cyber threats such as cross-site request forgery and other potential cyberattacks, ensuring a safer browsing environment for users. Without the disclosure of the required Personal Data here, the use of our website is not possible.

              Our purpose of Data Processing here is to prevent IT security attacks in order to insure a safe and secure experience for our website users.

              According to the article the Article 6(1)(d) of the GDPR and the article 4(7) of the PDPL, the Processing of the Personal Data is lawful if the processing is necessary in protecting the Data subject interests. Since we use IT security Cookies in order to protect our website users from cyber threats, the processing of the Personal Data in this case is deemed lawful.

              The processed Data is limited to the HTTPS Data and the IT security test results. The Data will be automatically transmitted by the browser of the user.

              The Data stored will be deleted at the end of the session.

              1.2.2 Tracking Cookies

              Tracking cookies are designed to monitor and record users’ online activities over a period of time. They collect Data about the user’s preferences and behaviors, browsing habits, and interactions on the website. The use of these Tracking Cookies requires the user’s consent, and they will only be activated once the user provide such consent.

              When your visit to our website, a cookie banner will appear, giving you the option to make a choice regarding the use of tracking cookies. You are required to choose between:

              We store your cookie preferences in a cookie on your device to remember your choices for future visits. This allows us to respect your settings and avoid repeatedly asking for your consent.

              2. YUVO Account Users & Product Customers

              A YUVO Account User refers to an individual or an entity that has registered and established an account with YUVO to access and engage with the brand’s offerings, encompassing consultations, support, updates on product enhancements and new releases A YUVO Product Customer is an individual or an entity that has purchased a YUVO product through a transaction.

              Since a contractual relationship cannot be established without certain personal Data, the disclosure of personal Data is mandatory for account users and product customers.

                Our purpose of Data Processing here is:

                As per the Article 6(1)(b) and (c) of the GDPR and the article 4 (9) and (10) of the PDPL, the Processing of the Personal Data shall be lawful if the processing is necessary for the performance of a contract, and if the processing is necessary for compliance with a legal obligation to which the controller is subject to. Accordingly, and since the processing of Data is crucial for us in order to perform our contractual obligations, therefore the processing of the Personal Data of our Account Users and Product Costumer is deemed to be lawful.

                Furthermore, and as per the Article 6 Paragraph 1 (f) of the GDPR, the Processing of the Personal Data shall be lawful if the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party. Accordingly, and since we have a legitimate interest in communicating with our customers, in advertising our Products, in improving our products and services, in defending ourselves in any future legal dispute, therefore the processing of the Personal Data in this case is deemed to be lawful.

                Kindly note that the legal basis for the transfer of historic order and payment information to payment providers is your consent (Article 6 Paragraph 1 (f) of the GDPR, and Article 4 of the PDPL).

                The processed Data includes: name, username, IP address, contact Data, language settings, Data of the registration of the account, account events, communication Data, usage Data, and content preferences. If you acquire a YUVO product, the processed Data will also include billing address and details, Data of the registration of the YUVO license, type of YUVO Product, download Data, account events including validation, timestamps, and details on your usage behavior related to the YUVO products.

                All Data stored related to contracts and bookkeeping will be stored for a period of ten years after the contract’s end. Data that become relevant for a defense against possible claims is stored for three years.

                3. Newsletter Recipients

                YUVO use newsletters to provide subscribers with information and updates about YUVO, about our products, about our partners, about our offers and promotions, and other relevant information. Subscription to our newsletter requires the disclosure of certain personal Data, as we cannot deliver our communications without it. Subscribers may unsubscribe from the newsletter at any time by using the opt-out link included in each email or by contacting us directly.

                  Our purpose of Data Processing here is:

                  The legal ground of our lawful Data Processing here is your consent, as per the terms of the Article 6(1)(f) of the GDPR, and the Article 4 of the PDPL.

                  Furthermore, as per the Article 6(1)(f) of the GDPR, the Processing of the Personal Data shall be lawful if the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party. Since we have a legitimate interest in the keeping you updated, in improving our services, and in showing our subscribers a more relevant content, the processing of the Personal Data in this case is deemed to be lawful.

                  The processed Data is limited to the HTTPS Data, the name, the email address, the web extend identifiers, and the opening and reading times of the newsletter. The Data will be transmitted by you when you subscribe to our newsletter, or when engage in a contractual relationship with us.

                  The Data stored regarding newsletters will be deleted when you unsubscribe from the newsletters. The remaining Data will be deleted after one year, except the case where we find a legitimate interest in keeping your Data or where we need to comply with our legal retention obligations of the Data.

                  4. Participants in Survey, Interview, and Usability Test

                  As part of our continuous effort to enhance YUVO’s products and services with the needs and preferences of our users, we conduct surveys, interviews, and usability tests to gain valuable insights from our users. Participation in these activities is entirely voluntary, and your feedback helps us refine our offerings, improve user experience, and develop innovative solutions tailored to your needs.

                    Our purpose of Data Processing here is to conduct Surveys, Interviews, and Usability Tests in order to assess user satisfaction, identify areas for improvement, collect feedback, and Analyzing responses to make Data-driven enhancements to YUVO’s offerings.

                    The legal ground of our lawful Data Processing here is your consent, as per the terms of the Article 6(1) (f) of the GDPR, and the Article 4 of the PDPL.

                    Furthermore, as per the Article 6(1)(f) of the GDPR, the Processing of the Personal Data shall be lawful if the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party. Since we have a legitimate interest in improving our products and services according to our users’ opinions, the processing of the Personal Data in this case is deemed to be lawful.

                    The processed Data is limited to the content of the Surveys, the Interviews and the Usability Tests, and to the timestamp and the metadata of the participation.

                    The Data stored regarding Surveys, Interviews and Usability Tests will be deleted after one year or at the end of the Contract, except the case where we find a legitimate interest in keeping your Data for follow-up or for compliance with our legal retention obligations.

                    5. Job Applicants

                    At YUVO, we are committed to fostering a transparent, responsible, and fair recruitment process. Candidates interested in joining YUVO can submit job applications, which we carefully review for current and future employment opportunities. Providing personal Data is necessary for consideration, and without it, we will not be able to process your application.

                      Our purpose of Data Processing here is evaluating applications to select candidates for available jobs, and maintaining a talent pool for future job opportunities that matches the applicant’s profile.

                      The legal ground of our lawful Data Processing here is your consent, as per the terms of the Article 6(1)(f) of the GDPR and the Article 4 of the PDPL, and our Legitimate Interest in selecting the most suitable candidates for available roles and maintaining a Database of potential hires for future openings according to theArticle 6(1)(f) of the GDPR.

                      The processed Data is limited to the Name, Contact Information, Attached Documents (CV, Cover Letter, Certifications, …) and to the timestamp and the metaData of the communication.

                      The Data stored regarding Job Applications will be deleted three months after the application process has ended if your application is unsuccessful. In the event of a requested inclusion in our applicant pool, your Data will be deleted if you withdraw your consent or after two years. If hired, your Data will be processed as part of the employment relationship.

                      6. Users Seeking Help and Support

                      YUVO is committed to providing a comprehensive knowledge base and responsive costumer support to assist users with sales inquiries, technical issues, and general support requests. Help and Support features are available exclusively to YUVO Account Users, and without the disclosure of the required Personal Data we won’t be able to provide you with Help and Support.

                        Our purpose of Data Processing here to provide you with the support, help and assistance upon your request, and to resolve technical issues and service inquiries efficiently.

                        YUVO processes help and support Data based on Contractual Necessity (Article 6(1)(b) GDPR; Article 4(9) PDPL), since Data Processing is required for the performance of our contractual obligations, allowing us to provide support to YUVO Account Users. Furthermore, we have Legitimate Interest in enhancing customer service, resolving user concerns, and improving our products and services according to the Article 6(1)(f) of the GDPR.

                        The processed Data is limited to the Name, Contact Information, Login Data of the YUVO Account, and the Description and attached files and Data of your request.

                        Help and support Data is retained as long as your YUVO account is active. If you delete your YUVO account, associated help and support Data will be deleted. Contractual and accounting-related Data will be retained for 10 years in compliance with legal obligations.

                        7. Development Partners

                        A development partner refers to an individual or an entity that collaborates with YUVO on projects or initiatives aimed at fostering growth, innovation, or improvement. These partnerships may take various forms, including research collaborations, product development, and technical cooperation.

                          Our purpose of Data Processing here the preparation and execution of a contractual relationship, and improving YUVO services and products

                          As per the Article 6(1)(b) and (c) of the GDPR and the article 4 (9) and (10) of the PDPL, the Processing of the Personal Data shall be lawful if the processing is necessary for the performance of a contract, and if the processing is necessary for compliance with a legal obligation to which the controller is subject to. Since the processing of Data is crucial for us in order to perform our contractual obligations, the processing of the Personal Data of our development partners is deemed to be lawful.

                          Furthermore, as per the Article 6(1)(f) of the GDPR, the Processing of the Personal Data shall be lawful if the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party. Since we have a legitimate interest in verifying your contact Data, and in improving our services and products accordingly, the processing of the Personal Data in this case is deemed to be lawful.

                          The processed Data is limited to the Name, Contact Information, Data about development activities, usage Data, and license contract Data.

                          Contractual Data will be deleted ten calendar years after termination of the contract.

                          VII. Security Measures and Data Protection Safeguards

                          At YUVO, we are committed to ensuring the highest level of security when processing Personal Data. We have implemented comprehensive technical and organizational safeguards to prevent unauthorized access, Data breaches, and misuse of personal Data.

                          1. Technical and Organizational Security Measures

                          2. Data Access Controls and Encryption

                          3. Incident Response and Data Breach Management

                          VIII. Updates to the Data Protection Policy

                          1. Policy Review and Amendments

                          YUVO regularly reviews and updates its Data Protection Policy to reflect changes in:

                          2. Communication of Changes to Users

                          For any purpose related to the subject of this Data Protection Policy, you can reach our Data Protection officer by sending an email to Dataprotectionoffcer@YUVO.com or by sending a letter …………

                          You may also contact us at any time via email at contact@YUVO.com.