Last updated: 22 July 2020
1.1 The website yaya.co (the Site) is operated by YaYa Digital Ltd. (“we”, “us”, “our”), a company incorporated in England and Wales under company number 11954846. Our registered office is at Unit 4.18 37 Cremer Street, London, E2 8HD .
1.2 We are committed to protecting your privacy and complying with our data protection obligations under the Data Protection Act 2018 (the DPA 2018), the General Data ProtectionRegulation 2016/679 (the GDPR) and any other applicable UK legislation (together, Data Protection Law).
1.4 This policy was last updated on the date shown at the top. We may change this policy at any time by posting an updated version on the Site and will make reasonable efforts to bring any material changes to your attention. You may wish to check it before using the Site as any changes will be effective from the date that they are made.
2.1 If you have any concerns or would like further information about our use of data or this policy in general, you can contact Phill Bolland at email@example.com.
3.1 We collect, store and use the types of personal data set out in the table at the end of this policy.
4.1 We will use your personal data for the purposes set out in the table at the end of this policy.
5.1 When we share personal data, we do so in accordance with Data Protection Law. We may share certain personal data, where necessary, with employees, contractors, consultants or advisers, to facilitate sales and for general commercial purposes.
In addition, where necessary, your personal data may be shared:
5.1.1 if the company or business is sold, transferred or integrated with another business, with our advisers, a prospective purchaser, a prospective purchaser’s advisers or the new owner of the company or business to facilitate the process.
5.2 We may also provide third parties with aggregated but anonymised information and analytics about our customers. Before we do so we will make sure that it does not identify you.
6.1 This Site contains links to other websites over which we have no control. We are not responsible for and do not review or endorse the privacy policies or practices of other sites which you choose to access from this Site. We encourage you to review the privacy policies of those other sites, so you can understand how they collect, use and share your personal information.
7.1 We respect your rights to privacy and will respond to requests for access or control over information about you in accordance with Data Protection Law. We may require you to verify your identity before we take any action.
7.2 Depending on the reason we have your personal data, you have a right to:
7.2.1 access the personal information we hold about you (commonly known as subject access);
7.2.2 request that we correct or complete personal information we hold about you that is inaccurate or incomplete;
7.2.3 request that we erase your personal information in some circumstances, or object to our processing it as detailed at paragraph 7.5;
7.2.4 restrict how we use your personal information, in certain circumstances;
7.2.5 request that we provide you with copies of your personal information in a machine-readable format or transfer it across different services; and
7.2.6 where we have asked for your consent to process your data, to withdraw this consent.
7.3 These rights are limited in some situations under Data Protection Law – for example, where we can demonstrate that we are under a legal obligation to process your data.
7.4 If you wish to exercise any of these rights, please contact us using the details in paragraph 2 above.
7.5 Your right to object
You have a right to object to our processing of your personal data and ask us to stop doing so. If we are processing your personal data for direct marketing purposes (which includes profiling to the extent that it is related to such direct marketing) and you object to this, we will stop processing your personal data immediately.
If our processing of your personal data is in the public interest or pursuant to our legitimate interests and you object to this, we will stop processing your personal data unless we have compelling reasons which override your interests, or our use of your personal data is for the establishment, exercise or defence of legal claims.
7.6 We hope that we can satisfy any queries you may have about the way we process your data. However, if you have unresolved concerns you also have the right to complain to data protection authorities (in the UK, the Information Commissioner’s Office). You can call the ICO on 0303 123 1113 or go to their website: https://ico.org.uk/make-a-complaint/).
8.1 Your personal data will only be kept for as long as necessary for our purposes. Specific periods are set out in the table at the end of this policy.
9.1 We process your personal data in accordance with the following principles:
9.1.1 we process your personal data lawfully, fairly and in a transparent way;
9.1.2 we collect your personal data for specified, explicit and legitimate purposes; any further processing we do is compatible with the original purposes for which for which we collected it;
9.1.3 we only process personal data which is adequate, relevant and limited to what is necessary to achieve the purpose for which it is processed;
9.1.4 we take reasonable steps to ensure that all personal data is accurate and kept up to date where necessary;
9.1.5 we do not store personal data in a form which identifies you for any longer than is necessary for the purposes of processing; and
9.1.6 we process personal data securely and in a way that protects against unauthorised or unlawful processing, accidental loss, destruction or damage.
9.2 When we ask for your personal data we will tell you whether you are required by law or contract to provide it, and what will happen if you do not provide the data.
9.3 Any request for consent to the processing of your personal data will be made directly to you and will include information about why we require the personal data and what will be done with it.
10.1 We will only process personal data when we have a lawful basis for doing that processing. The table at the end of this policy sets out the lawful basis we rely on for each type of data we process.
10.2 We will choose one of the lawful bases in the GDPR to justify how we use your personal data. These are:
10.2.1 Consent: You have given consent to the processing of your personal data for one or more specific purposes.
10.2.2 Contract: The processing is necessary for the performance of a contract with you or in order to take steps at your request before entering into a contract.
10.2.3 Legal obligation: We need to process your personal data to comply with a legal obligation.
10.2.4 Vital interests: The processing is necessary to protect the vital interests of you or another person.
10.2.5 Public interest: Processing is necessary for the performance of a task carried out in the public interest or in the exercise of some official authority.
10.2.6 Legitimate interests: Processing is necessary for the purposes of legitimate interests pursued by us or someone else, except where such interests are overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.
This statement sets out the steps taken by Yaya Digital Limited (“Yaya”) to ensure that slavery and human trafficking are not taking place in our supply chains or in any part of our business. Slavery and human trafficking can occur in many forms, such as forced labour, child labour, domestic servitude, sex trafficking and workplace abuse.
Given the nature of the work that we do, we believe that there is a low risk of slavery or human trafficking having any connection with our business. We must, however, not be complacent, and all staff have a responsibility to be aware of any risks in our business and in our wider supply chains, no matter how remote the possibility, and report any concerns to senior management.
Our supply chains Our supply chains comprise primarily services, including professional advisory services.
We have reviewed our supply chains and believe the overall risk of modern slavery is low owing to:
We have a zero-tolerance approach to modern slavery and human trafficking, and we are fully committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We believe in paying people fairly and properly for their work. This policy and our internal policies reflect our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
As part of our initiative to identify and mitigate risk we have in place systems to:
We set clear expectations for our suppliers by informing them that Yaya does not tolerate modern slavery or any form of human trafficking within its business or supply chains and that Yaya does not allow harsh or inhumane treatment and we expect our suppliers to share our values.
We verify the practices of any new recruitment agency as part of our terms of business with them and before accepting any workers from that agency.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we will be providing training to appropriate members of staff.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Yaya’s slavery and human trafficking statement for the financial year ending 30 April 2022. Following its initial adoption, this Modern Slavery and Human Trafficking Statement will be reviewed by Yaya’s Board of Directors at least annually and may be amended from time to time.