USERS' PRIVACY POLICY

Data processing

1. Foreword

YLIWAY.COM ("YLIWAY"), operated by YLIWAY IRELAND LTD, with its registered office at 3RD FLOOR, THE BOATHOUSE, BISHOP STREET, Dublin 8, Ireland, D08 H01F, (hereinafter "YIL"), is a platform consisting of the website https://www.yliway.com and the mobile application ("Platform") which was created with the aim of helping users to grow professionally and do business.

The platform offers social functionalities, features that make it possible to build a professional growth model, to take online courses or courses outside the platform, different types of rooms such as Training Room, Coaching Room, Webinar, Masterclass, Business Network Room, Events, Circles, Topic and Squad (all together 'Room'), to participate in events, to participate in Topics, to create Circles or participate in them, to create and participate in working groups and to apply for open job positions (all together 'Services').

YLIWAY is an online platform where registered users ("Users") share their professional identity, interact with their connections, exchange professional knowledge and information, publish and display relevant content, discover and develop new skills, and find job, career, and business opportunities. Some of the content and data relating to registered Users on our platform, by way of example but not limited to the User profile, posts and articles published, may be viewable by non-registered Users but registered Users may choose what information to make visible to non-registered Users ("Visitors").

This policy describes the methods and purposes of the processing of personal data of Users who interact with YLIWAY web services, through access to its domains and/or web software ("The Platform").

In summary

In this Policy we list the types of information we collect:
Information you provide when you register on the Platform and create a profile;
Activity you engage in on the Platform (content you view, posts, photos and messages you send. If you use messages with end-to-end encryption, we cannot read them unless they are flagged for us to check);
Who are the users you interact with and their activities;
Information from the phone, computer or tablet on which you use our services, such as the type of device and the version of our app you use;
Information from persons, companies, organisations or entities that use or integrate our services to advertise, market or support their products and services.

2. Con-Title of treatment

YLIWAY ITALIA S.R.L., with registered office in Via Cassia n. 1081, 00123 ROMA (RM), C.F./P. IVA 01224910578, REA Number RI - 77305, e-mail: dpo@yliway.com; and YLIWAY IRELAND LTD, with registered office at 3RD FLOOR, THE BOATHOUSE, BISHOP STREET, Dublin 8, Ireland, D08 H01F, are the joint controllers of your personal data (hereinafter also referred to as "Joint Controllers").

The Joint Holders have entered into an agreement pursuant to Article 26 of the GDPR by which they have undertaken, inter alia, to:

- jointly determine some of the purposes and methods of processing your personal data;

- jointly determine a procedure to provide you with timely feedback should you wish to exercise your rights under Articles 15 et seq. of the GDPR;

- jointly define this policy.

3. Treatment modalities

Data processing is carried out exclusively in electronic form, by means of IT tools and media designed to ensure the security and confidentiality of the data. The information stored is protected against unauthorised access. The processing is based on the principles of correctness, lawfulness, transparency and protection of confidentiality, in compliance with the provisions of Article 32 of the GDPR.

4. Purpose of processing

4.1 The table below provides an overview of the categories of personal data we process, their purpose and the legal basis for processing.

4.2 It is likely that, when using some of the services offered, you will be asked for additional information to that already provided by you when registering on the website or subscribing to the platform.

If necessary, you will be provided with additional details on the processing of your personal data directly on the web page dedicated to the service so that you can evaluate them and decide whether to join (and use) the service or not.

4.3 It is likely that not all of the purposes listed here apply to your specific case.

Whenever you read examples, be aware that they are provided purely as examples and not as an exhaustive list.

4.4 The fields marked with (*) in the website registration form are mandatory. If you do not provide them, we will not be able to provide you with the requested service.

Data	Purpose	Legal basis
Legend: (CT) Joint Treatment; (I) YLIWAY ITALIA S.R.L. Treatment; (IRL) YLIWAY IRELAND LTD Treatment
Personal data (name, surname, tax code, day and place of birth), contact data (e-mail, telephone number, address of residence/domicile), pictures, username and password for logging in to the platform.	Registration to the www.yliway.com website platform and/or related sites/pages (CT)	Execution of contractual or pre-contractual measures: by registering on our website you agree to use our services. Compliance with a legal obligation.
Personal data, contact details, username and password for logging in to the platform. Fiscal and banking data (e.g. IBAN or credit card).	Managing your services and subscriptions, processing related requests (IRL)	Execution of contractual or pre-contractual measures; compliance with a legal obligation.
Personal data, contact details, username and password for logging in to the platform.	Notices from YLIWAY to the User in relation to the User Account and any breach of the Licence Agreement and/or Policies. Dispute Resolution, Complaints and Fraud Prevention (CT)	Execution of contractual or pre-contractual measures; compliance with a legal obligation. Legitimate interest in protecting the interests of the co-owners.
Personal data, contact details.	Suggestions of opportunities related to professional growth and/or business growth, including but not limited to sending your CV and skills information when applying for a job offer. Suggesting professional connections aligned with your professional and/or business growth objectives. Creation of direct contacts between the User and authors of Content to which you subscribe. (IRL)	Consent or legitimate interest in interacting with participants; performance of contractual or pre-contractual measures; compliance with a legal obligation.
Personal data, contact details.	In case of participation in Online Courses, Training rooms, Coaching rooms, Webinars, Masterclasses, Business Network rooms, Events, Topics and Circles, and in order to facilitate the direct relationship between Creators and Users. (IRL)	Consent or legitimate interest in interacting with participants; performance of contractual or pre-contractual measures; compliance with a legal obligation.
Browsing data: login data, cookies, information on devices used and Internet Protocol (IP) addresses	Statistics based on your use of our products or services. Statistical monitoring of only aggregated data relating to browsing activity on the platform. YLIWAY then uses the data to identify clusters of users and to record the operations they perform.(CT)	Consent where necessary and legitimate interest in improving our offer.

4.5 You may object to all or some of the processing referred to in point 4.4 by writing to e-mail: dpo@yliway.com.
In carrying out such processing, the Data Controllers shall assess the possible prevalence of your rights and freedoms over their legitimate interest in sending you their communications.

5. Recipients of personal data

5.1 In order to properly carry out all processing activities necessary to achieve the purposes set out in Section 4 of this notice, your personal data may also be processed by the following parties:

third parties who, on the basis of a contract, carry out part of the Processing activities and/or activities connected and instrumental to the same on behalf of one or both of the Data Controllers. In such case, these entities have been appointed as Data Processors pursuant to Article 28 of the GDPR (hereinafter the "Data Processor");
individuals, employees and/or collaborators of one or both of the Data Controllers, who have been entrusted with specific and/or multiple processing activities on your personal data and who have been appointed as "Authorised Persons" within the meaning of Article 29 of the GDPR;
public bodies or the judicial authorities, if this is required by law or to prevent or suppress the commission of an offence;
According to Article 4(9) of the GDPR, 'public authorities that may receive communication of personal data in the context of a specific investigation in accordance with Union or Member State law are not considered recipients';
third parties that cooperate with YLIWAY ITALIA S.R.L. and/or YLIWAY IRELAND LTD in the structuring of other services or products. In this case, the third parties will only receive the data strictly necessary for the purposes of providing these products and/or services. These third parties are appointed by the Data Controllers as Data Processors.

5.2 YLIWAY ITALIA S.R.L. and/or YLIWAY IRELAND LTD or its Processors may use information technology and/or technical services offered by companies located in third countries, for example, YLIWAY INDIA LTD. YLIWAY shares information globally in Amazon Web Services data centres. In any case, YLIWAI ITALIA S.R.L. ensures that those companies are compliant in accordance with Art. 44 et seq. of the GDPR.

6. Visibility of data to other YLIWAY Users

6.1 Through the Contact Info functionality, and through the functionalities in the User Account, you can decide which personal data to make visible to other users.

6.2 In the event of participation in Online Courses, Training rooms, Coaching rooms, Webinars, Masterclasses, Business Network rooms, Events, Topics and Circles, and in order to facilitate the direct relationship between Creator and Users, you agree that the Creator of the activity in which you have chosen to participate may view the following data: your first and last name, current job position, address and email.

6.3 Other users may publish or write something about you or may tag you if through the Account Settings you have authorised this function.

6.4 With respect to the use of the Platform, YLIWAY records the visits, browsing data and use of the Services by all Users as part of specific clusters and does not keep track of individual User usage behaviour.

Please read the Cookie Policy in its most comprehensive version.

6.5 YLIWAY allows communications between Members. Such communications are not normally visible to YLIWAY, its employees and its partners. Where, however, detection systems detect violations that may relate to public safety, more specifically acts of violence or acts of terrorism, YIL is obliged by law to inform the public safety authorities and to make such information visible to them.

6.6 YLIWAY, with prior consent, provides personalised advertisements by analysing the Information provided by the Users (including but not limited to profession, educational background, work experience, topics followed, interests, pages opened on the YLIWAY Platform or on other platforms or websites).

6.6 Your User profile is visible to all other YLIWAY Users according to the settings you choose in the Settings section. You can set your profile to be visible, in whole or in part, to both YLIWAY Users and Visitors. Any data you include in your profile and any content you post or any social activity (including but not limited to posts, articles, comments, shares, followers, and contacts) you engage in on the platform will be viewed by third parties in accordance with the Account settings you select.

6.7 The Services offered by the YLIWAY platform also allow you to view and share information by publishing posts, adding recommendations, following other users and commenting on content. When you publicly share an article or post (e.g. an update, an image, a video or an article), this article or post can be viewed by everyone and shared again anywhere (depending on your privacy settings). Users and Visitors will be able to find and view publicly shared content, including your name and other data, based on the privacy settings you choose.

6.8 Posts and articles published in a Topic or Circle are visible to other members of the Topic or Circle. Membership of Topics and Circles is public and forms part of the user's profile.

6.9 When recommending, sharing or commenting on a third-party content (including advertisements), other Users will be able to view the 'social actions' performed and associate them with the User who is the author of them.

7. Storage time of your personal data

7.1 Unless you request deletion, we will keep your personal data for the duration of your registration on the YLIWAY platform and in any case no longer than 5 years after your last interaction with us (or update).

7.2 If you have purchased services, we will retain your personal data for a period not exceeding 10 years from the date of termination of your subscription, in accordance with tax and civil law. This retention is also necessary to comply with, for example, the GDPR and current legislation. The data thus retained will only be used for this purpose, with limited access and, if necessary, pseudonymised. At the end of this period they will be deleted.

8. Rights of the data subject

8.1 You can exercise your rights under the GDPR:

right of access to personal data;
the right to obtain the rectification or erasure of the data or the restriction of the processing of the data concerning you;
right to object to the processing, to withdraw consent;
right to lodge a complaint with the supervisory authority.

In relation to the processing of your personal data, you may contact YLIWAY ITALIA S.r.l., located at Via Cassia 1081, 00189 Rome (Italy) by writing to the email address dpo@yliway.com.

9. Security

YLIWAY ITALIA S.R.L. AND YLIWAY IRELAND LTD adopt appropriate technical and organisational security procedures and measures to ensure the secure processing of personal data.
These measures include, but are not limited to, imposing confidentiality obligations on our employees and suppliers; limiting access to personal data; and destroying or anonymising personal data if it is no longer necessary for the purposes for which it was collected.

Since the security of your information depends in part on the security of the computer or device you use to interact with us and the security you use to protect (where applicable) usernames and passwords, please pay particular attention to how you store this data.

Last updated on 05.12.2023