PRIVACY POLICY

www.yumility.com

Effective date: 1 January 2021

YumilitY Inc. (“YumilitY”, “we”, “us”, and “our”) respects your privacy and recognizes the importance of your personal information. We are committed to protecting your information through our compliance with The Personal Information Protection and Electronic Documents Act of Canada (PIPEDA), the General Data Protection Regulation (GDPR) and other data protection regulations applicable to our jurisdiction.

This Privacy Policy describes the types of information we may collect when you visit our website or use our services (collectively, our “Services”) and our practices for using, maintaining, protecting and disclosing that information.

  1. What is Personal Information?

Personal Informationcan be defined as any information, recorded in any form, about an identified individual or an individual whose identity may be inferred or determined from such information or information readily available to the public.  This includes, but is solely not limited to, your name, contact information and email address.

  1. Collection of Personal Information

Any interaction may result in our collection of your Personal Information. We collect Personal Information directly from you, or indirectly from third party sources as otherwise permitted by applicable law. We do not knowingly collect Personal Information from children under 18 years old.

  • Log Data: Our servers’ automatically record information (“Log Data”) related to your actions on the Website. Log Data may include information such as your IP address, browser type, internet service provider, date/time stamps, the referring domain and pages visited. Other actions, such as interactions with the Website may be also included in Log Data. Log Data may also be recorded by third party websites.
  • Links: The Website may keep track of how you interact with links by redirecting clicks or through other means. We do this to help improve our Services, and to be able to share aggregate click statistics such as how many times a particular link was clicked on. We also use web beacons, tags and pixels to record information about how you browse the Website.
  • Cookies: Please refer to our Cookie Policy for more information on this section.
  • Device Identifiers: When you use a mobile device like a tablet or cell phone to access our Website, we may access, collect, monitor, store on your device, and/or remotely store one or more “device identifiers.” A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to your device.
  • E-Mail and Chat: You may decide to send us Personal Information in an e-mail message or via the Chats. Before you can interact with our representatives via the Chats, you will be asked to provide your e-mail address.
  • Third Party Services: We use a variety of services hosted by third parties to help provide our Services, and to help us understand the use of our Website, such as Google Analytics. These services may collect information sent by your browser as part of a web page request, such as cookies or your IP request.
  1. How We Use Your Information

In addition to some of the specific uses of Personal Information we describe in this Privacy Policy, we may use such information or share such information to:

  • establish, maintain and manage the services that have been requested;
  • provide personalized content and information to you and others, which could include promotional emails, online ads, opportunities presented by other organizations and additional products or services that we determine may be of interest to you or other forms of marketing (you can choose not to receive any electronic marketing communication communications from us by clicking the Unsubscribe” function contained in all of our electronic communications or by emailing [email protected]
  • conduct user satisfaction surveys and provide support service to you;
  • develop and test new services and features and improve our level of service;
  • provide service notifications;
  • monitor metrics such as total number of visitors, traffic, and demographic patterns;
  • diagnose or fix technology problems; and
  • facilitate your login to the Sites via third party platforms, such as Google and Facebook; and
  • such other purposes consistent with these objectives and as may be permitted or required by applicable law.

Information about you and your use of the Services may be aggregated with other information in ways that do not personally identify you or constitute personally identifiable information. This type of aggregated or statistical information may be used by us to improve the quality of the Services or for other purposes that we may deem appropriate.

  1. Sharing of Information

We may share your Personal Information:

  • with our employees, contractors and business partners, to the extent required for them to provide the services you have requested or for the Purposes described in this Privacy Policy;
  • with unaffiliated service providers with whom we may subcontract with, including warehouses, website hosting companies, fulfillment companies, payment processing companies, and other third-party service providers; and
  • with government agencies and law enforcement officials, when required to do so to respond to subpoenas, court orders or legal process, or to establish or exercise our legal rights or defend against legal claims.
  1. Information Sharing and Disclosure

Our use of Personal Information is limited to the purposes described in this Privacy Policy and we do not otherwise sell, trade, barter, exchange or disclose for consideration any Personal Information that we have obtained. We will not share your Personal Information with any third party outside of us and our affiliated companies.  We may disclose your Private Information in the limited circumstances described herein.

  • Your Consent: We may share or disclose your information with your consent. Consent can be either express (verbally, in writing or electronically) or implied, where permitted under applicable law. In determining the appropriate form of consent, we will consider the sensitivity of the information. When you provide your Personal Information voluntarily on the Website or to us, you imply that you have consented to the collection, use and disclosure of such information. You or as parent or guardian on behalf of someone who is under the age of 18 years old, may change or withdraw your/their consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting us at [email protected] Please note that in some circumstances, a change in or withdrawal of consent may severely limit our ability to provide the services you have purchased to you.
  • Without Consent: Please note that there are circumstances where the use and/or disclosure of your Personal Information may be justified or permitted or where we are obliged to disclose information WITHOUT consent. Such circumstances are consistent with PIPEDA and the DPA and may include, but are not limited to the following: if we believe that it is reasonably necessary to comply with a law, regulation or legal request; to protect the safety of any person; to address fraud, security or technical issues; or to protect our rights or property.
  • Non-Private or Non-Personal Information: We may share or disclose your non-private, aggregated or otherwise non-Personal Information.
  • Service Providers: We engage certain trusted third parties to perform functions and provide services to us. We may share your personal information with these third parties, but only to the extent necessary to perform these functions and provide such services, and only pursuant to obligations mirroring the protections of this Privacy Policy.
  • Business Transfers: In the event that we are involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information may be sold or transferred as part of that transaction. The promises in this Privacy Policy will apply to your information as transferred to the new entity.
  1. Third Parties

You agree that we are not responsible and do not have control over any third parties that you authorize to access your content through our site. If you are using a third-party website or service and you allow them to access your Personal Information you do so at your own risk.

  1. Rights under the GDPR

YumilitY is committed to ensuring fair and transparent processing. That is why it is important to us that data subjects can not only exercise their right to object but also the following rights where the respective legal requirements are satisfied:

  • Right to information, Art. 15 of the GDPR
  • Right to correction, Art. 16 of the GDPR
  • Right to deletion (“Right to be forgotten”), Art. 17 of the GDPR
  • Right to limit processing, Art. 18 of the GDPR
  • Right to data transmissibility, Art. 20 of the GDPR
  • Right to object, Art. 21 of the GDPR

To exercise your right, please contact us as indicated in the “Contact Us” section below.

In order to be able to process your request, as well as for identification purposes, please note that we will use your personal information in accordance with Art. 6 para. 1 (c) of the GDPR.

You also have the right to lodge a complaint with a supervisory authority pursuant to Art. 77 GDPR in combination with Section 19 GDPR.

  1. Accessing and Modifying Personal Information

We endeavor to ensure that your Personal Information is accurate, current and complete as possible to fulfill the purposes for which the information has been collected, used, retained and disclosed. You may email us at [email protected] to request access to review, challenge the accuracy of or request deletion of your Personal Information held by us and to request corrections and we will respond within a reasonable time.  To guard against fraudulent requests, we may require sufficient information to allow us to confirm that the person making the request is authorized to do so before granting access or modifying any Personal Information.  We may also deny your request if permitted or required by law and if so, provide you with the reasons for the denial.

If you successfully demonstrate the inaccuracy or incompleteness of any of your Personal Information, we will amend or delete the Personal Information as required. If we do not agree on the resolution to your satisfaction, we will document the substance of the unresolved challenge.

Where appropriate, we will transmit the amended information or the existence of the unresolved challenge, as the case may be, to third parties having access to the information in question so that they may modify their records accordingly. We are however, not responsible nor liable for the failure of such third parties to update their records.

If you are a parent or guardian, you can email us to request access to review, modify, replace or request deletion of the Personal Information provided by your minor. We may require evidence of your parent or guardian rights prior to responding to your request. Please note that in some circumstances, a removal of a minor’s Personal Information without replacement with your own Personal Information may severely limit our ability to provide the Services to you.

  1. Protection of Personal Information and Disclaimer

We endeavor to maintain appropriate physical, procedural and technical security with respect to our offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of Personal Information.  This also applies to the disposal or destruction of Personal Information.  We further protect your Personal Information and any financial or payment information by restricting its access to those employees and contractors who need to have knowledge of that information in order for us to provide our Services, as determined by our management. While we continue to work hard to protect your Personal Information, no data transmission over the internet can be guaranteed to be absolutely secure, and we cannot ensure or warrant the security of any information you transmit to us via the Website or otherwise. Transmitting Personal Information is done at your own risk.

  1. Retention

We will retain your Personal Information for as long as necessary to fulfill the purposes for which the information has been collected, used, retained and disclosed, or as permitted or required by law.

  1. Modifications/Changes

We may revise this Privacy Policy from time to time. The most current version of the policy will govern our use of your information and will always be on the Website. If we make a change to this policy that, in our sole discretion, is material, we will notify you via e-mail, if known. Please check this page periodically for updates. By continuing to access or use the Services after those changes become effective, you agree to be bound by the revised Privacy Policy.

  1. Contact Us

For any questions, concerns, complains, requests or comments regarding your Personal Information or our Privacy Policy, please contact us at [email protected]