LAST UPDATED AND EFFECTIVE : OCTOBER 5th 2018
When you use these services, you’ll share some information with us. So, we want to be upfront about the information we collect, how we use it, and the controls we give you to access, update, and delete your information.
About This Policy
For the purposes of applicable data protection laws, our parent company, Alternative Ideas Limited is the controller of your data. This means we are the primary entity who decides the purposes and means for dealing with your personal data.
This policy outlines the way in which we manage any personal data obtained through the YEO app (the “App”), (the “Website”) or otherwise provided by or about individuals (“you”, “your”) in the course of you signing up for and using our private messaging platform (the “Services”). It explains:
- what personal data we collect about you in the course of your use of our Services, why we collect it, who it goes to and how long we keep it
- how we use your personal data
- how we protect your personal data
- your legal rights in respect of your personal data, including how to access and update the information we hold about you.
Please note that some of the provisions here will only apply if you are based in the EU.
By continuing to use our Services, you agree to our use of your personal data on the terms outlined in this policy. Please also read the YEO end user license agreement www.youreyeonly.com/terms-of-use (“Terms“), which describes the terms under which you use our Services.
What information do we collect about you?
We need to receive or collect some information to operate, provide, improve, understand, customize, support, and market our Services, including when you install, access, or use our Services. This includes:
Personal information we collect directly from you
- Information required to set up your profile to create a YEO account and manage our provision of the Services to you, name, mobile telephone number, email and photos (for both your profile picture and setting up your profile through our face recognition technology).
- Any other personal information included in the messages and content you share with other YEO users through the App, including your chats, photos, videos and files. To provide maximum security for your messages, your conversations and content will only be stored on our cloud servers and never on the recipient’s device. All messages are sent and received through double ratchet end-to-end encryption technology, which means that your messages are encrypted to protect against us and third parties from reading them and can only be decrypted through positive facial recognition of your profile.
- Information regarding your contacts and how you communicate with others, such as the profiles of people in our YEO contacts list and the names, profiles and members of any groups you have created or joined.
- Payment details required to process your Service subscriptions.
- Information you provide when you submit queries or request customer services from us in relation to the Services, including copies of your messages, communications with us and your profile details.
- Your email address if you sign up to receive marketing updates from our Website.
- Various technical information we automatically collect from your device depending on your chosen use of our Services, e.g. usage and log information regarding how you use our Services, your location information if you are receiving geo-fenced content, and cookies used to operate, provide and improve your experience of the Services.
We also collect some device and connection-specific information when you install, access, or use our Services. This includes information like hardware model, operating system information, battery level, signal strength, app version, mobile operator or ISP, language and time zone, device operations information, and device identifiers. This information does not personally identify you and is used for service-related, diagnostic, performance information only.
Personal information we receive from other sources
- Information we receive about you from other YEO users, g. to add you as a contact, send you a message or to raise a query or complaint about your account.
- Information provided by third party service providers to provide the Services, e.g. the app stores who may provide us reports to help diagnose and fix services issues, process subscription payments on our behalf, or to discuss a refund request you have made through them.
- Information provided by third party services used in connection with the Services, e.g. if you use the Facebook or Twitter share button to invite your social media contacts to join YEO, we will receive information about your social media profiles. Please note that third-party services or plug-ins to the Services will be governed by their own terms and privacy.
We will let you know at the point of collecting your information whether this is optional, or whether it is necessary for you to provide this information to meet certain statutory or contractual requirements. If the latter and you do not wish to provide us with this information, this may limit the services we are able to provide you.
You will be responsible for the accuracy of any personal data you provide us. If the data we hold about you is inaccurate in any way, please contact us to have your personal information corrected.
Why do we collect your information and on what grounds?
We will only use your personal data if we have a permitted lawful basis to do so. Generally we collect your personal data because is it necessary for:
- performing our contract for the Services with you.
- the pursuit of our legitimate interests (as set out below).
- complying with our legal obligations.
- capture your biometric data to enable the facial recognition requirements of our Services.
- collect and use information you allow us to receive through your device-based settings when you enable them (e.g. access to your GPS location, camera, photos, contacts list, finger ID) so we can provide the features and services described when you enable the settings.
- send you marketing updates, promotions, news and offers via email.
You have the right to withdraw your consent to these activities at any time, which will mean (unless another lawful basis applies to your data) that we will cease to process the affected data after consent is withdrawn. However, please note this may result in us being unable to provide you with certain features of the Services.
Why do we collect your information?
The primary purpose for which we collect information about you is to operate the Services (i.e. to perform a contract with you). We also use your personal information for the following purposes:
To perform our contract for provision of the Services with you
- To operate and provide our Services, including to set up your profile, process your communications with other users of the Services, provide customer care support, manage payments for your subscriptions and to provide you with information, products or other services you request from us.
For our legitimate interests
- For market research and analytical purposes, e.g. to improve our understanding of users’ usage of the Services.
- Improving, troubleshooting, customizing, testing and developing new features for our Services.
- For verifying accounts and activity to promote the safety and security of our Services, including by investigating suspicious activity or violations or our Terms, and taking legal action against third parties who have committed criminal acts or are in breach of their legal obligations to YEO.
- For promoting, marketing and advertising our Services.
- Making important service communications about the Services (e.g. alerting you to changes in our terms of service).
- To handle any legal claims or regulatory enforcement actions taken against us.
To comply with our legal obligations
- To prevent, investigate and detect crime, fraud or anti-social behavior and prosecute offenders, including by working with law enforcement agencies.
- To comply with our legal and regulatory obligations (including under applicable data protection laws).
Who do we share your information with?
We do not sell, store or commercialize your personal data. However, you share your information as you use and communicate through our Services, and we share your information to help us operate, provide, improve, understand, customize, support, and market our Services. This means we may share your information with the following third parties:
- Other users of the Services, including your chosen recipients of messages sent through the Services and those who may search your name to send you a contact request.
- Our third party service providers where necessary to provide the Services, including Apple Inc and Google LLC in connection with their hosting of the App on the app stores and associated payment services, Amazon, the host of our data servers and Luxand, our facial recognition partners.
- Any potential or actual third party buyer of our business and/or assets in the event that we sell, trade or licence ownership of any part of the YEO business or assets (including management of the app and our website).
- Third parties we may be required to disclose such personal data to in order to comply with our legal obligations or enforce our legal rights, e.g. any relevant authority or enforcement body and fraud protection agencies.
Will my data be sent abroad?
Our main data servers are located in the UK, and the USA. We are committed to maintaining GDPR compliance and therefore will only permanently store personal details from EEA residents on European Servers with all US users’ data being held on our US servers. Occasionally we may need to transfer your personal information to other countries outside of the European Economic Area (including the United States) in order to provide you with the Services, which are not subject to equivalent data protection standards. Where this is the case, we will ensure that these are made subject to appropriate safeguards as required by applicable data protection laws, to ensure that a similar degree of protection is afforded to your personal data. These will include the use of EU Commission approved standard contractual clauses, making transfers to countries deemed to provide an adequate level of protection for personal data by the European Commission, or transferring data to recipients certified under the Privacy Shield regime. You can obtain further information about the safeguards in place for your international transfers of personal data by contacting us.
How long do you keep my personal data?
We keep your data for as long as necessary to meet the relevant purposes for which we’ve collected your data. Generally this will be until it is no longer necessary to use that data to provide our Services, meet any legal, accounting or reporting requirements or until your account is deleted, whichever is earlier.
To determine the appropriate length of time for holding your data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm, from unauthorized use or disclosure of your personal data, the purpose for which we process your data and whether we can achieve those purposes through other means, along with the applicable legal requirements.
You can delete your YEO account at any time by clicking “Delete My Account” on your profile. This will delete all your stored data and messages. Please note that if you only delete our app from your device rather than through this in-app feature, your information may be stored with us for a longer period. Deleting your account also does not affect the information other users have relating to you, such as their copy of the messages you sent them. Please note that your subscription will need to be cancelled manually through your phone or app store settings.
You can also change or limit your information by changing your settings within the YEO app to manage your contacts, groups, edit your profile picture and name, or delete users from your contacts list or messages.
Your rights in respect of your personal data
In certain circumstances you have rights under data protection laws in relation to the personal data we hold about you. You can request to:
- access information held about you.
- rectify any incorrect or incomplete data we hold about you. It is both in our interest and yours that any personal information we hold about you is accurate, complete and current. If the data we hold about you is inaccurate in any way, please contact us to have your personal information corrected. You can also update information in your profile by changing the settings in your account.
- delete, restrict or remove the data we hold about you.
- transfer the data we hold about you to another party.
- object to any further processing of your data.
You can make all such requests via email to firstname.lastname@example.org.
We will endeavor to respond to your requests within one month and free of charge. Please note that in respect of all these rights, we reserve the right to:
- refuse your request based on the exemptions set out in the applicable data protection laws.
- request for proof of your ID to process the request or request further information
- charge you a reasonable administrative fee for any repetitive, manifestly unfounded or excessive requests
If we refuse your request to exercise these rights, we will give reasons for our refusal and allow you to challenge our decision.
If you have any concerns about how we handle your data, please contact us. If you are not satisfied after we’ve tried to resolve your issue, you’ll be entitled to lodge a complaint with our regulator, the Information Commissioner’s Office in the UK.
Cookies and other technologies
In common with many websites and apps, we use “cookies” to help us understand, secure, operate, and provide our Services.
A cookie is a small data file that our server sends to your browser when you visit the Website.
You can delete cookies at any time or you can set your browser to reject or disable cookies or do this by changing your device settings, however if you do this certain aspects of our Services may not function properly. You can obtain information about how to manage cookies by clicking “help” on your browser’s menu, visiting www.aboutcookies.org or the FAQ pages of your device manufacturer.
We primarily use information from cookies for the following purposes:
- Traffic monitoring, e.g., the IP address from which you access the site, the type of browser and operating system used to access the site, the date and time of your access to the site, the pages you visit, and the Internet address of the website from which you accessed the site.
- To provide the Services for web and desktop and other Services that are web-based, improve your experiences, understand how our Services are being used, and customise our Services
- To recognize repeat visitors for statistical/analytical purposes.
- To understand which of our FAQs are most popular and to show you relevant content related to our Services
- To remember your choices, such as your language preferences, and otherwise to customize our Services for you
- To rank the FAQs on our website based on popularity, understand mobile versus desktop users of our web-based Services, or understand popularity and effectiveness of certain of our web pages
Third party links connected to the Services
The YEO app, website and the Services may, from time to time, contain links to and from the websites, apps or other services of our partners, service providers or social media pages. If you follow a link to any of these external websites or apps, please note that websites have their own privacy policies and that we are not in control of, and do not accept any responsibility or liability for these policies or any third party websites or apps connected from these Services. Please check these policies before you submit any personal information through these websites or apps.
According to CalOPPA, we agree to the following:
Users can visit our site anonymously.
You can change your personal information through your profile in our App or by emailing us.
We honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.
Changes to this policy
If you have any queries relating to this privacy notice (including any requests to exercise your legal rights in respect of your data), you can contact us at email@example.com.
Alternative Ideas Limited
C/O The Office Group,
12 Melcombe Place,
London, NW1 6JJ
(Registration no. 10785061)