Table des matières
Yelly, accessible at https://yelly.app/ , is a social networking network that allows you, once registered, to interact with other students from your university or school ("Yelly") .
We are committed to respecting the principles relating to the protection of personal data. For the sake of loyalty and transparency vis-à-vis our users, partners, suppliers and service providers, we take care to inform the persons concerned of each processing operation that we implement by means of information notices.
The purpose of this policy is therefore to inform you about the processing of your personal data associated with the use of Yelly, and your rights with regard to the applicable regulations on the protection of personal data.
In the context hereof, in addition to the terms introduced above, terms beginning with a capital letter have the meaning given to them by the applicable regulations on the protection of French and European personal data (the "Applicable Regulation on the protection Personal Data ”), and in particular:
the law relating to data processing, files and freedoms n ° 78-17 of 6 January 1978 as amended and any updates as well as its application texts;
the applicable European regulations, in particular Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 (general data protection regulation - GDPR) repealing Directive 95/46 / CE;
recommendations, guidelines, and deliberations emanating from supervisory authorities, in particular the National Commission for Informatics and Freedoms (the “CNIL”), and the European Committee on Data Protection (the “EDPS”).
2.Identity of the data controller
The company Explaynable, SAS with capital of € 1,110.08, registered in the Paris Trade and Companies Register, under number 885 046 755 (hereinafter the “Company”, “we”, “our”, “our” ») Acts as Data Controller.
We are available to provide you with any clarification regarding the Processing of your Personal Data:
24 rue de Téhéran, 75008 Paris
3. Treatment characteristics
The processing operations that we carry out as Data Controller are presented as follows:
Purpose of processing:
Creating an account and using Yelly
Nature of processing:
Collection, organization, structuring, conservation, adaptation, extraction, consultation, use, interconnection, limitation, erasure or destruction
Purpose of processing
The purposes of the processing are:
registration on Yelly (creation of a user account);
management of user accounts;
management of the operation and monitoring of access and use of Yelly, including in particular the production of performance and use statistics in order to offer new services or improve the operation of Yelly;
creating and joining groups;
updating your account information;
commercial prospecting by the Company or our partners;
sending a newsletter;
sending email and push notifications.
Legal basis for processing
We process Personal Data on the following basis:
our legitimate interests (providing a secure and reliable service);
where applicable, your consent;
where applicable, to fulfill our legal obligations.
Category of Personal Data
The Personal Data collected are:
identity data (surname, first name, date of birth, photograph);
contact details (e-mail address);
connection data (traces, logs);
data relating to your user account;
data relating to the messages you send and receive;
information relating to your educational background (name of the establishment, location of the establishment, name of the diploma, start year and end year);
data relating to your account;
data relating to the profiles you visit and the views of your profile;
where applicable, information relating to the identifiers associated with your Instagram and Snapchat accounts.
Catégorie de personnes concernées
Les personnes concernées sont les personnes ayant créé un compte sur Yelly.
Category of data subjects
The people concerned are the people who have created an account on Yelly.
Recipients of Personal Data
The recipients are:
the internal services of Yelly, and in particular the technical service;
Yelly's subcontractors (in particular hosts).
4. Retention period of your Personal data
We keep your Personal Data as long as you use Yelly and your account has not been deleted by you or us. This includes data that you or others have provided to us and data generated from your use of Yelly. Even if you do not use Yelly regularly, we will retain your information and keep your profile open, unless you delete your account.
In the event of deletion of your account, your Personal Data of an administrative interest, in particular in the event of litigation, will be archived for a period of five years from the date of deletion of your account (in accordance with the applicable limitation / foreclosure rules. ).
At the end of this period, we permanently delete your Personal Data.
5. Transfer of Personal Data abroad
We do not transfer your Personal Data outside of the European Union.
If your Personal Data is to be transferred outside the European Union, we undertake to comply with all the obligations regarding the transfer of Personal Data to a third country and in particular to conclude a binding legal act. with the recipient of the Personal Data, such as standard contractual clauses, without prejudice to any other measures to ensure the security of your Personal Data.
6. Hosting of your Personal Data
Yelly and the associated services are hosted on OVH servers with high levels of guarantees and security.
The hosting of Yelly and associated services is carried out on the territory of the European Union.
7. Your rights
We ensure that your rights are respected in the context of the processing of Personal Data that we implement.
7.1 Right of access to your Personal Data
You have the right to obtain confirmation that Personal Data concerning you are or are not processed and, when they are, access to such Personal Data as well as information concerning the characteristics of their Processing.
7.2 Right to rectification of your Personal Data
You can request that your Personal Data be, depending on the case, rectified or completed if they are inaccurate, incomplete, equivocal or out of date.
7.3 Right to erasure of your Personal Data
You can request the erasure of your Personal Data when one of the following reasons applies:
Personal Data are no longer necessary for the purposes for which they were collected or otherwise processed;
you object to the processing of your Personal Data because there is no overriding legitimate reason for the Processing;
the processing of Personal Data does not comply with the applicable Regulations on the protection of Personal Data.
The right to erasure of Personal Data is not a general right and can only be granted if one of the aforementioned grounds applies.
7.4 Right to limit the processing of your Personal Data
You have the right to obtain the restriction of Processing:
for the period allowing us to verify the accuracy of your Personal Data;
if the Processing is unlawful and you object to the erasure of your Personal Data;
if your Personal Data is still necessary for the establishment, exercise or defense of legal claims;
if you have objected to the Processing.
7.5 Right to object to the processing of your Personal Data
In accordance with the applicable Regulations on the protection of Personal Data, you have the right to object at any time, for reasons relating to your particular situation, to the processing of your Personal Data for which the legal basis is the legitimate interest.
We will no longer process your Personal Data, unless we demonstrate that there are legitimate and compelling reasons for the Processing which prevail over your interests, rights and freedoms, or for the observation, exercise or defense of legal rights.
7.6 Right to portability of your Personal Data
You have the right to the portability of your Personal Data. It is not a general right. Indeed, all the data of all the Processing is not portable and this right only concerns automated Processing to the exclusion of manual or paper processing.
This right is limited to Processing for which the legal basis is your consent or the execution of a contract. This right relates to the data provided.
The right to portability may not infringe the rights and freedoms of third parties such as those protected by business secrecy.
You can request the portability of your Personal Data by specifying that you wish to receive it yourself or, if this is technically possible, that we transmit it directly to another controller.
7.7 Right to lodge a complaint
You have the right to lodge a complaint with the CNIL.
7.8 Right to define post-mortem directives
You have the option of defining guidelines for the retention, erasure and communication of your Personal Data after your death. These directives are general or specific and can only concern the Processing that we implement.
The general guidelines concern all of your Personal Data and can be registered with a trusted digital third party certified by the CNIL. You also have the option of providing for special conditions.
7.9 Procedures for exercising rights
Requests relating to the exercise of your rights are made:
at the following postal address: Explaynable, 24 rue de Téhéran, 75008 Paris; Where
to the following email address: firstname.lastname@example.org
8. Update of the data protection policy
The data protection policy is subject to change at any time. In the event of a major change, you will be notified of the new data protection policy when logging into your Yelly account.
9. Age estimation
We estimate your age and your liveness based on your facial image. This is so that only young between 13 to 25 years old can access our service. To do this we collect a selfie from you as part of the app registration process. We share only your selfie with our partner Yoti (Yoti USA Inc for US users and Yoti Limited for non-US users).
We share nothing else with Yoti and Yoti will have no way of linking your selfie to any other data about you. Yoti processes this data in its UK based servers to check liveness and estimate your age, and then returns an estimated age result to us. Yoti deletes your selfie immediately once the age estimation is completed and does not use your selfie or estimated age for any other purpose at all.
Last modified: August 08, 2022