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Privacy Policy

Last updated: May 31, 2021

This Privacy Policy explains in detail how we collect, use and disclose your personal data when you use Yuansfer. Please read this document carefully before submitting any personal data to us.

1. General Information

1.1 About the Private Policy.

This Yuansfer Privacy Policy (the “Privacy Policy”) governs the processing of personal data collected from natural persons (“you” and “your”) through the website https://www.yuansfer.com, the related domain names, software applications, and payment solution services (collectively, “Yuansfer”). The Privacy Policy does not cover any third-party websites, applications, software, products or services that integrate with Yuansfer or are linked to from Yuansfer.

1.2 Our role as a data controller and data processor.

We act in the capacity of a data controller and a data processor with regard to the personal data processed through Yuansfer in terms of the applicable data protection laws, including the EU General Data Protection Regulation (GDPR). Our role depends on the specific situation in which personal data is handled by us, as explained in detail below:

1.3 Your consent.

Before you submit any personal data through Yuansfer, you are encouraged to read this Privacy Policy that is always available on Yuansfer to understand what legal bases (other than your consent) we rely when handling your personal data. In some cases, if required by the applicable law, we may seek to obtain your informed consent for the processing of your personal data. For example, you consent may be necessary if: (i) we intend to collect other types of personal data that are not mentioned in this Privacy Policy; (ii) we would like to use your personal data for other purposes that are not specified in this Privacy Policy; or (iii) we would like to transfer your personal data to third parties that are not listed in this Privacy Policy.

1.4 Minors.

Yuansfer is not intended for use by children (i.e., persons who are minors in their country of residence). Therefore, we do not knowingly collect minors’ personal data. If you, as a parent or a legal guardian of a child, become aware that the child has submitted his/her personal data to us, please contact us immediately. We will delete your child’s personal data from our systems without undue delay.

1.5 Term and termination.

This Privacy Policy enters into force on the effective date indicated at the top of the Privacy Policy and remains valid until terminated or updated by us.

1.6 Amendments.

The Privacy Policy may be changed from time to time to address the changes in laws, regulations, and industry standards. We encourage you to review our Privacy Policy to stay informed. For significant material changes in the Privacy Policy or, where required by the applicable law, we may seek your consent.

2. WHAT PERSONAL DATA DO WE COLLECT AND FOR WHAT PURPOSES DO WE USE IT?

2.1 We respect data minimization principles.

Thus, we collect only a minimal amount of personal data through Yuansfer that is necessary to ensure the proper provision of Yuansfer as described below. We use your personal data for limited, specified and legitimate purposes explicitly mentioned in this Privacy Policy. We do not use your personal data for any purposes that are different from the purposes for which it was provided. When processing personal data, we make sure that we do so by relying on one of the available legal bases. You can find more information about the legal bases below:

2.2 Sensitive Data.

We do not collect or have access to any special categories of personal data as defined by Art. 9 of the GDPR (“sensitive data”) from you, unless you decide, at your own discretion, to provide such data to us. Sensitive data is information that relates to your health, genetics, biometrics, religious and political beliefs, racial origins, membership of a professional or trade association, sex life, or sexual orientation. If you decide, at your sole discretion, to include the said sensitive data into Your Data, we will process such data for the purpose of fulfilling our contractual obligations.

2.3 Processing of Your Data.

When you upload or create Your Data on Yuansfer, we process Your Data as requested by you. We process Your Data in order to (i) provide you with the requested services and (ii) perform our contractual obligations. The legal basis on which we rely is ‘performing a contract with you’. The duration of processing is the term of your service contract with us.

2.4 Refusal to provide personal data.

If you refuse to provide us with your personal data when we ask to, we may not be able to perform the requested operation and you may not be able to use the full functionality of Yuansfer or get our response. Please contact us immediately if you think that any personal data that we collect is excessive or not necessary for the intended purpose.

2.5 Sources of personal data.

We obtain your personal data from the following categories of sources:

3. WHAT TECHNICAL (NON-PERSONAL) DATA DO WE COLLECT?

3.1 Log files and analytics data.

In order to analyse your use of Yuansfer, we and our analytics service provider Google Analytics automatically collects certain technical non-personal data about your use of Yuansfer. Such data does not allow us to identify you as an individual person in any manner. The non-personal data includes your activity on Yuansfer (e.g., what functionalities you use, how much time you spend on Yuansfer, how long it takes for Yuansfer to load and process your requests, and what errors occur).

3.2 Your feedback.

If you contact us, we may keep records of any questions, complaints, recommendations, or compliments made by you and any subsequent responses. Where reasonably possible, we remove all personal data that is not necessary for keeping such records.

3.3 Purposes of technical (non-personal) data.

We use your technical (non-personal) data for the following purposes:

3.4 Aggregated and de-identified data.

If we combine your non-personal data with certain elements of your personal data and such a combination allows us to identify you as a natural person, we will handle such aggregated data as personal data. If your personal data is de-identified in a way that it can no longer be associated with a natural person, it will not be considered personal data and we may use it for any business purpose.

4. HOW DO WE COMMUNICATE WITH YOU?

4.1 Newsletters.

If we have your email address, we may, from time to time, send you a newsletter informing you about the latest developments related to Yuansfer and our special offers. You will receive our newsletters in the following instances:

4.2 Opting-out.

You can opt-out from receiving our commercial communication at any time free of charge by clicking on the “unsubscribe” link included in our newsletters, adjusting the settings of your user account, or by contacting us directly.

4.3 Tracking pixels.

The newsletters sent by us may contain tracking pixels that allow us to conduct analysis of our marketing campaigns. Tracking pixels allow us to see whether you opened the newsletter and what links you have clicked on. We use such information to conduct analytics and pursue our legitimate business interests.

4.4 Service-related notices.

If necessary, we will send you important informational messages, such as confirmation receipts, payment information, technical emails, and other administrative updates. Please note that such messages are sent on an “if-needed” basis and they do not fall within the scope of commercial communication that may require your prior consent. You cannot opt-out from service-related notices.

5. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

5.1 Retention of personal data.

We store your personal data in our systems only for as long as such personal data is required for the purposes described in this Privacy Policy or until you request us to delete your personal data, whichever comes first. After your personal data is no longer necessary for its primary purposes and we do not have another legal basis for storing it, we securely delete your personal data from our systems.

5.2 Retention of technical (non-personal) data.

We retain non-personal data pertaining to you for as long as necessary for the purposes described in this Privacy Policy. For example, we can store it for the period of time needed for us to pursue our legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.

5.3 Retention as required by law.

In certain cases, we are required by law to store your personal data for a certain period of time (e.g., your payment data should be stored for business records or accountancy purposes). Thus, we keep your personal data for the time period stipulated by the applicable law and securely delete it as soon as the required storage period expires.

6. HOW DO WE SHARE AND DISCLOSE YOUR DATA?

6.1 Disclosure to data processors.

From time to time, your personal data is disclosed to our service providers with whom we cooperate (our data processors). For example, we share your personal and non-personal data with entities that provide certain technical support services to us, such as hosting and email distribution services. We do not sell your personal data to third parties. The disclosure is limited to the situations when your personal data is required for the following purposes:

6.2 List of our data processors.

We use a limited number of data processors. We choose them only if they agree to ensure an adequate level of protection of your personal data that is consistent with this Privacy Policy and the applicable data protection laws. The data processors that have access to your personal data are:

6.3 Disclosure of technical (non-personal) data.

Your technical (non-personal) data may be disclosed to third parties for any purpose. For example, we may share it with prospects or partners for business or research purposes, for improving Yuansfer, responding to lawful requests from public authorities or developing new products and services.

6.4 Legal requests.

If we are contacted by a public authority, we may need to disclose information about you to the extent necessary for pursuing a public interest objective, such as national security or law enforcement.

6.5 Successors.

In case Yuansfer is sold partly or fully, we will provide your personal data to a purchaser or successor entity and request the successor to handle your personal data in line with this Privacy Policy. We will notify you of any changes of the data controller.

6.6 Selling personal data.

We do not directly sell your personal data to third parties. However, some of your personal data, including online identifiers (e.g., cookie-generated data and IP addresses) may be used for advertising, marketing, and monetisation purposes (e.g., programmatic advertising, retargeting, third-party marketing, profiling, or cross-device tracking). To make sure that you have full transparency and control over your personal data, we provide you with a possibility to manage your personal data used for such purposes as described in our Cookie Policy.

6.7 International transfers.

Some of our data processors listed above are located outside the country in which you reside. For example, if you reside in the European Economic Area (EEA), we may need to transfer your personal data to jurisdictions outside the EEA. In case it is necessary to make such a transfer, we will make sure that the jurisdiction in which the recipient third party is located guarantees an adequate level of protection for your personal data or we conclude a data processing agreement with the respective third party that ensures such protection. We will not transfer your personal data internationally if no appropriate level of protection can be granted.

7. HOW DO WE PROTECT YOUR PERSONAL DATA?

7.1 Our security measures.

We implement organisational and technical information security measures to protect your personal data from loss, misuse, unauthorised access, and disclosure. The security measures taken by us include:

7.2 Security breaches.

Although we put our best efforts to protect your personal data, given the nature of communications and information processing technology and the Internet, we cannot be liable for any unlawful destruction, loss, use, copying, modification, leakage, and falsification of your personal data that was caused by circumstances that are beyond our reasonable control. In case a serious breach occurs, we will take reasonable measures to mitigate the breach, as required by the applicable law. Our liability for any security breach will be limited to the highest extent permitted by the applicable law.

8. WHAT RIGHTS DO YOU HAVE WITH REGARD TO YOUR PERSONAL DATA?

8.1 The list of your rights.

You have the right to control how your personal data is processed by us by exercising the rights listed below (unless, in very limited cases, the applicable law provides otherwise):

8.2 How to exercise your rights?

If you would like to exercise any of your rights, please contact us by email at [email protected] or by post (you can find our postal address at the end of this Privacy Policy) and explain your request in detail. In order to verify the legitimacy of your request, we may ask you to provide us with an identifying piece of information that allows us to identify you in our system. We will answer your request within a reasonable time frame but no later than 2 weeks.

8.3 Complaints.

If you would like to launch a complaint about the way in which we process your personal data, we kindly ask you to contact us first and express your concerns. If we receive your complaint, we will investigate it and provide you with our response as soon as possible. If you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority.

8.4 Non-discrimination.

We do not discriminate against you if you decide to exercise your rights. It means that we will not (i) deny any goods and services, (ii) charge you different prices, (iii) deny any discounts or benefits, (iv) impose penalties, or (v) provide you with lower quality services.

9. CONTACT

If you have any questions about this Privacy Policy or our data protection practices, please contact us by:

Email: su[email protected]

Postal address: 28 Liberty St 6th Floor, New York, NY 10005, the United States