Privacy Policy
DATA PROTECTION UNDER THE SWISS DATA PROTECTION LAW
To run our business, we collect and process information about natural and legal persons (“Personal Data”), including information about our prospective, current and former Users (“you”) of our Services (“Services).
This Privacy Notice (“Notice") contains information on what Personal Data YODL, Gartenstrasse 6, 6300 Zug, Switzerland (“YODL”, “we”, “our”, or “us”) collects, what we do with that information, and what rights you have.
1. What does this Notice cover?
This Notice applies to any and all forms of use (“processing”) of Personal Data by us if you are a former, current or prospective User. We only process Personal Data for specific purpose and in line with applicable laws.
2. What types of Personal Data do we collect?
For existing as well as for evaluating potentially new future Users we may collect the following Personal Data:
personal identification details (such as name, address, gender, nationality, date of birth)
contact information (such as telephone, e-mail address), and family details (such as marital status)
information related to your social media profiles
details of our interactions with you and the Services you use, including electronic interactions across various channels such as e-mails and mobile applications, third-party Web3 wallet addresses, transaction data, etc.
This Personal Data will, where required, be collected when you use our Services. In case we collect Personal Data directly from third parties, then we do so only based on your consent or when this is necessary in order to provide you with the Services agreed.
When you use our Services or our website, it will contain additional information on which information we collect and how we use it, while you use the website. We may use cookies, tracking technologies and other means (e.g., web beacons, pixels, gifs, tags) to collect and process the above information from different channels and devices you use. For our usage of cookies and other tracking technologies in relation to our website please also refer to the Website Privacy Notice available on the website itself.
3. For which purposes do we process your Personal Data?
We always process your Personal Data for a specific purpose and only process the Personal Data which is relevant to achieve that purpose. In particular, we process Personal Data, within applicable legal limitations, for the following purposes:
to provide our Services to you, in particular to collect and process Personal Data on our servers and use them for the direct purposes of our Services (e. g. complete data in your Web3 wallets).
to provide you with a User profile
Depending on the context and the agreement with you, we may process Personal Data for purposes other than the ones mentioned above.
4. Basis for processing of Personal Data
We process your Personal Data within the applicable legal framework.
Where required and depending on the purpose of the processing activity (see Section 3), the processing of your Personal Data will be one of the following grounds:
necessary for taking steps to enter into or executing a contract with you for the Services or products you request, or for carrying out our obligations under such a contract, such as when we use your data for some of the purposes in Section 3 above, as well as certain of the data disclosures described in Section 6 below
necessary for the legitimate interests of YODL, without unduly affecting your interests or fundamental rights and freedoms and to the extent such Personal Data is necessary for the intended purpose
required to meet our legal responsibilities, including when we make the disclosures to authorities, regulators and government bodies referred to in Section 6 below
To the extent that we process any special categories of data relating to you, we will do so because:
the processing is necessary for the establishment, exercise or defense of a legal claim
the processing relates to Personal Data which are manifestly made public by you, or
you have given your consent to us to process that information. Such consent can also be concluded from the context or the purpose.
5. How do we protect Personal Data?
All employees accessing Personal Data must comply with our internal rules and processes in relation to the processing of your Personal Data to protect them and ensure their confidentiality.
We have implemented adequate technical and organizational measures to protect your Personal Data against unauthorized, accidental or unlawful destruction, loss, alteration, misuse, disclosure or access and against all other unlawful forms of processing.
6. Who has access to Personal Data and with whom are they shared?
Within YODL, Personal Data may be shared with our employees or with third parties we have mandated (e.g., external legal advisors). We only share Personal Data in line with the purposes outlined in Section 3 above and only if it is necessary.
In some instances, we also share Personal Data with our suppliers, who are contractually bound to confidentiality, such as IT hardware, software and outsourcing providers, logistics, mail, courier, printing services and storage providers, consultants, transportation and travel management providers and others. When we do so we take steps to ensure they meet our data security standards, so that your Personal Data remains secure.
If required, we disclose Personal Data to public authorities, regulators or governmental bodies, courts or party to proceedings, where we are required to disclose information by applicable law or regulation, under a code of practice or conduct, at their request, or to safeguard our legitimate interests.
We may need to disclose Personal Data to exercise or protect legal rights, including ours and those of our employees or other stakeholders, or in response to requests from individuals or their representatives who seek to protect their legal rights or such rights of others.
The Personal Data transferred within or outside of YODL is in some cases also processed and/or stored in other countries. We only transfer your Personal Data abroad to countries which are considered to provide an adequate level of data protection, or in the absence of such legislation that guarantees adequate protection, based on appropriate safeguards (e. g., contractual clauses). This includes our use of cloud- and other software solutions based in the USA, which are certified under the Swiss-US Privacy Shield Agreements (e.g., Dropbox, Microsoft Office 365).
7. How long do we store your data?
We will only retain Personal Data for as long as necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory, or internal policy requirements. To help us do this, we apply criteria to determine the appropriate periods for retaining your Personal Data depending on its purpose.
8. What are your rights and how can you exercise them?
You have a right to access and to obtain information regarding your Personal Data that we process. If you believe that any information we hold about you is incorrect or incomplete, you may also request the correction of your Personal Data.
You also have the right to:
object to the processing of your Personal Data
request the erasure of your Personal Data
request restriction on the processing of your Personal Data, and/or
withdraw your consent to process Personal Data
Where we process your Personal Data on the basis of your consent, or where such processing is necessary for entering into or performing our obligations under a contract with you, you may have the right to request your Personal Data be transferred to you (known as the ‘data portability’ right). You also have the right to ask us for information regarding some or all of the Personal Data we collect and process about you.
We will honor such requests, withdrawal or objection as required under applicable data protection rules but these rights are not absolute: they do not always apply and exemptions may be engaged. We will usually, in response to a request, ask you to verify your identity and/or provide information that helps us to understand your request better. If we do not comply with your request, we will explain why.
To exercise the above rights, please contact us:
YODL
Gartenstrasse 6
6300 Zug
Switzerland
info@yodlpay.com
9. Changes to your Personal Data
We are committed to keeping your Personal Data accurate and up to date. Therefore, if your Personal Data changes, please inform us of the change as soon as possible.
10. Updates to this Notice
This Notice was updated in August 2024 (Version 1.1). We reserve the right to amend it from time to time. Any amendment or update to this Notice we will make available to you.
