Privacy Notice and Policy

Last updated: September 7, 2024

Effective Date 03-Oct-2022

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

Affiliate means an entity that controls, is controlled by or is under common control with a party, where \”control\” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
Account means a unique account created for You to access our Service or parts of our Service
Automated Decision-Making (ADM): when a decision is made which is based solely on automated processing (including profiling) which produces legal effects or significantly affects an individual. The GDPR prohibits Automated Decision-Making (unless certain conditions are met) but not automated processing.
Accountability Principle means that controllers will be responsible for, and be able to demonstrate compliance with the GDPR which requires the controller to implement appropriate technical and organizational measures to ensure and be able to demonstrate that data processing is performed in accordance with the GDPR, and review and update those measures where necessary.
Anonymization: Irreversibly de-identifying personal data such that the person cannot be identified by using reasonable time, cost, and technology either by the controller or by any other person to identify that individual. The personal data processing principles do not apply to anonymized data as it is no longer personal data.
Breach A “breach” is any incident, or potential incident, likely to result in unauthorised disclosure, damage, destruction or loss of Personal Data.
Consent: Consent is given by a clear affirmative act establishing a freely given, specific, informed and unambiguous indication of the data subject’s agreement to the processing of personal data relating to him or her, such as by a written statement, including by electronic means, or an oral statement.
Cross-border processing of personal data: Processing of personal data which takes place in the context of the activities of establishments in more than one Member State of a controller or processor in the European Union where the controller or processor is established in more than one Member State; or processing of personal data which takes place in the context of the activities of a single establishment of a controller or processor in the Union but which substantially affects or is likely to substantially affect data subjects in more than one Member State;
Country refers to: France
Company (referred to as either \”the Company\”, \”We\”, \”Us\” or \”Our\” in this Agreement) refers to Action Media Solutions, 2 Quater Rue Benoit Oriol 42400 St Chamond.
Content refers to content such as text, images, or other information that can be posted, uploaded, linked to or otherwise made available by You, regardless of the form of that content.
Data Processing Agreement means an agreement that forms part of the master agreement between a controller and a processor to reflect the parties\’ agreement with regard to the processing of personal data, in accordance with the requirements of Data Protection Laws.
Data Protection impact assessment (DPIA): tools and assessments used to identify and reduce risks of a data processing activity. DPIA can be carried out as part of Privacy by Design and should be conducted for all major system or business change programs involving the processing of personal data.
Data controller: The organisation or individual that determines the purpose and means of data processing.
Data processor: An organisation or individual that processes data on behalf of a data controller.
Data Protection Legislation “Data Protection Legislation” refers to both the General Data Protection Regulations (2018) and the Data Protection Act (2018).
Data Subject “Data subject” means an individual who is the subject of the personal data.
Data Protection Impact Assessment “Data Protection Impact Assessment” means a formal assessment of the impact of processing on the individual including the risks and any impact on their rights and freedoms.
Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
Feedback means feedback, innovations or suggestions sent by You regarding the attributes, performance or features of our Service.
GDPR means the General Data Protection Regulation, being Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.
Gillick Competence – whether or not a child is capable of giving the necessary consent will depend on the child’s maturity and understanding and the nature of the consent required. The child must be capable of making a reasonable assessment of the advantages and disadvantages of the treatment proposed, so the consent, if given, can be properly and fairly described as true consent.\” (Gillick v West Norfolk, 1984)
Information Commissioner The Information Commissioner oversees the implementation of Data Protection Legislation.
International organization means an organization and its subordinate bodies governed by public international law, or any other body which is set up by, or on the basis of, an agreement between two or more countries.
Lead supervisory authority: The supervisory authority with the primary responsibility for dealing with a cross-border data processing activity, for example when a data subject makes a complaint about the processing of his or her personal data; it is responsible, among others, for receiving the data breach notifications, to be notified on risky processing activity and will have full authority as regards to its duties to ensure compliance with the provisions of the EU GDPR;
Orders mean a request by You to purchase Products from Us.
Privacy statement A “privacy statement” is a document informing the data subject of the legal basis, purposes of processing etc.
Personal data breach: A breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.
Personal data: Any data relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Processing: Any operation/set of operations which performed on personal data, whether or not by automated means, including collection, recording, organisation, structuring, storage, adaption or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction, and ‘process’ and ‘processed’ shall be construed accordingly.
Privacy Notices: separate notices setting out information that may be provided to data subjects when the Company collects information about them. These notices may take the form of general privacy statements applicable to a specific group of individuals or they may be stand-alone, one-time privacy statements covering processing related to a specific purpose.
Products refer to the products or items offered for sale on the Service.
Promotions refer to contests, sweepstakes or other promotions offered through the Service.
Service refers to the Website.
Staff Unless otherwise applicable, all references to staff include all current, past and prospective staff, full time, part time staff and Members of the Board of Governors as well as agency workers, temporary workers and contractors.
Special Category Data “Special Category data” consists of personal data relating to:
- ethnic origin,
- physical and mental health (including, for example, details of the reasons for an individual’s sick leave),
- sex life,
- genetics
- biometrics (where used for ID purposes)
- religion or belief,
- political opinion
- Trade Union membership.
- Greater protections are required when processing this data. Criminal conviction data should be treated with similar care.
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
Pseudonymisation means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
Profiling: any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to an individual, in particular to analyse or predict aspects concerning that individual’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements. Profiling is an example of automated processing.
Recipient means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
Supervisory Authority: An independent public authority which is established by a Member State pursuant to Article 51 of the EU GDPR;
Terms and Conditions (also referred as \”Terms\”) mean these Terms and Conditions that form the entire agreement between You and the Company regarding the use of the Service.
Third-party Social Media Service means any services or content (including data, information, products or services) provided by a third-party that may be displayed, included or made available by the Service.
Third party means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
Website refers to YSP Publishing, accessible from yspweb.com
You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Purpose, Scope and Users

The purpose of this document is to provide a general privacy notice and policy, applicable to all services and products the Company provides, and act as a template or starting point for a service or product-specific privacy notice or informed consent.

This document must be presented to data subjects before processing personal data and made public on the services’ or products’ website.

Users of this document are all employees of the Company, client organizations, and end users of products and services.

By accessing or using the Service, you are consenting to the collection, use and disclosure of your information in accordance with this Privacy Policy. If you do not consent to the same, please do not access or use the Service.

Collecting and Using Your Personal Data

HOW WE COLLECT YOUR INFORMATION

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

Email address
First name and last name
Phone number
Role
Address, State, Province, ZIP/Postal code, City
Social Media Profile
Usage Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device\’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be \”Persistent\” or \”Session\” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

We use both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
Functionality Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.
Tracking and Performance Cookies
Type: Persistent Cookies
Administered by: Third-Parties
Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new pages, features or new functionality of the Website to see how our users react to them.

Please refer to our Cookie Policy for more information.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

To provide and maintain our Service, including to monitor the usage of our Service.
To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application\’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
To manage Your requests: To attend and manage Your requests to Us.
For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
Transactional emails following a commercial transaction or specific action performed by You, such as a purchase or a password reset request.
For Email Marketing purposes (Mailing List): We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.
For SMS Marketing purposes: We may use Your Personal Data to contact You with marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the instructions provided in any SMS We send or by contacting Us.
For Testimonials
For Customer feedback collection
For Enforce T&C
For Site protection
For Targeted advertising
For Support
For Processing payment
For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

You may opt-out of receiving any, or all, of these communications from Us by following the instructions provided or by contacting Us.

The Company processes your personal information on one of the following lawful bases depending on the purposes:

for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
for compliance with a legal obligation to which the controller is subject.
in order to protect the vital interests of the data subject or of another natural person.
for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Company.
for the purposes of the legitimate interests pursued by the Company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject (you) which require protection of personal data, in particular where the data subject is a child.
If no other lawful basis applies, the Company processes your information after you have given consent to the processing of your personal information for the purposes described in this document and/or the privacy notice or informed consent of the provided service or product.

We may share Your personal information in the following situations:

With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

The Company shall not keep personal data for any longer than is necessary in light of the purpose or purposes for which that personal data was originally collected, held, and processed.
When personal data is no longer required, all reasonable steps will be taken to erase or otherwise dispose of it without delay.

Where The Company processes data on the basis of an individual’s consent, once consent has been withdrawn, our systems will be updated immediately and the personal data will be removed from use (as defined within the request for the withdrawal of consent) and will be deleted. For the performance of contracts, a defined period for the retention of data will be agreed with the data controller.

Staff should regularly review their records to ensure that the documents they hold are destroyed within the relevant destruction time limit in accordance with the Records Retention Schedule.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company\’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

When appropriate and in accordance with the Legislation, the Company may not transfer personal data of some Data Subjects to countries outside of the European Economic Area (EEA) (the European Union Member States along with Iceland, Liechtenstein and Norway) unless the country or territory has an adequate level of protection for personal data.

There are however a number of non-EEA countries recognised by the European Commission to have adequate level of personal data protection (“approved countries”). Transfer of information to these countries will not breach the Data Protection Legislation.

The Company may transfer personal data where the organisation receiving the personal data has provided adequate safeguards. Individuals’ rights must be enforceable and effective legal remedies for individuals must be available following the transfer. These adequate safeguards may be provided for by:

a legally binding agreement between public authorities or bodies;
binding corporate rules (agreements governing transfers made between organisations within in a corporate group);
standard data protection clauses in the form of template transfer clauses adopted by the Commission;
standard data protection clauses in the form of template transfer clauses adopted by Supervisory Authority and approved by the Commission;
compliance with an approved code of conduct approved by the Supervisory Authority;
contractual clauses agreed authorised by the Supervisory Authority

The legislation permits that a transfer, or set of transfers, may also be made where the transfer is:

made with the individual’s informed consent;
necessary for the performance of a contract between the individual and organizationtion or for pre-contractual steps taken at the individual’s request;
necessary for the performance of a contract made in the interests of the individual between the controller and another person;
necessary for important reasons of public interest;
necessary for the establishment, exdefense or defence of legal claims;
necessary to protect the vital interests of the data subject or other persons, where the data subject is physically or legally incapable of giving consent; or
made from a register which under EU law is intended to provide information to the public (and which is open to consultation by either the public in general or those able to show a legitimate interest in inspecting the register).

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

Our Service may give You the ability to delete certain information about You from within the Service.

You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

Comply with a legal obligation
Protect and defend the rights or property of the Company
Prevent or investigate possible wrongdoing in connection with the Service
Protect the personal safety of Users of the Service or the public
Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

The legislation requires personal data to be processed in a manner that ensures its security. This includes protection against unauthorized or unlawful processing and against accidental loss, destruction or damage. It requires that appropriate technical or organizational measures are used.

All staff are responsible for ensuring personal data are kept securely and accessible only to those who need to use it. Appropriate security measures are to be taken to prevent accidental loss of, or damage to, personal data. This will mean the use of passwords or encryption for electronic documents and keeping papers under lock and key.

The transport of personal data in any format (laptop, hard copy, memory stick etc.) should be avoided as far as possible. This applies especially to special categories data, large volumes of personal data, or information which could cause particular harm or distress if lost. Only in exceptional circumstances should this information be transported outside of the Company premises. Staff who do so should always ensure that it is kept with them at all times. Staff should:

Where possible use remote login to their Company account to access information as an alternative to transporting data.
Only carry the minimum amount of personal data (e.g. avoid carrying the whole file if only one document is needed).
It is the Company\’s intention that all mobile devices (laptops, smartphones, tablets) and external storage media (USB sticks, external hard drives, DVDs, CDs, etc.) used to transport personal data and special categories data outside the Company will be secured by deploying strong encryption.

When working remotely staff should:

Use secure remote access facilities (VPN) instead of carrying work home;
Never save documents containing personal data to a personal PC;
Consider that the means of connection may not always be secure.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

Analytics

We may use third-party Service providers to monitor and analyze the use of our Service.

Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

Email Marketing

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.

Payments

We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).

We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

PayPal
Their Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full
Braintree
Their Privacy Policy can be viewed at https://www.braintreepayments.com/legal/braintree-privacy-policy
FastSpring
Their Privacy Policy can be viewed at http://fastspring.com/privacy/

Usage, Performance and Miscellaneous

We may use third-party Service Providers to provide better improvement of our Service.

‍Third Party Data Processors We May Use

The Company uses services from Calendly to enable booking on Our website. You have the chance to opt in to Calendly’s cookies separately and you can read more about their cookie policy here. You can read about their GDPR compliance here.
Google (Privacy policy)
Google Fonts: For GDPR compliance and privacy we host and load Google Fonts locally.
Hostinger (Privacy Policy)
Noysi (Privacy Policy)
LiteSpeed Cache (Privacy Policy): This Website utilizes caching in order to facilitate a faster response time and better user experience. Caching potentially stores a duplicate copy of every web page that is on display on this site. All cache files are temporary and are never accessed by any third party, except as necessary to obtain technical support from the cache plugin vendor. Cache files expire on a schedule set by the site administrator, but may easily be purged by the admin before their natural expiration, if necessary.
WPForms (Privacy Policy)
Apollo.io (Privacy Policy)

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

Any special category data (sensitive types of personal data as defined in Article 9(1) of the GDPR) must further be processed only in the line with one of the conditions specified in Article 9(2).

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU. The GDPR includes the following rights for individuals:

The right to be informed that is the right to be told how their personal data is used in clear and transparent language.
The right of access to the personal data which is processed and information about how it is being used.
The right to rectification if personal data is inaccurate or incomplete.
The right to be forgotten or erased in certain circumstances where there is no reason for the Company to continue to process the data.
The right to restrict further processing of personal data.
The right to data portability of personal data between different service providers.
The right to object to certain types of processing
The right to purpose limitation. The right to limit the extent of the processing of their personal data.
The right not to be subject to decisions based solely on automated decision-making, including profiling.

Individuals have a right to make a ‘subject access request’ to gain access to personal information
that the Company holds about them. This includes:

 Confirmation that their personal data is being processed
 Access to a copy of the data
 The purposes of the data processing
 The categories of personal data concerned
 Who the data has been, or will be, shared with
 How long the data will be stored for, or if this isn’t possible, the criteria used to determine this period
 The source of the data, if not the individual
 Whether any automated decision-making is being applied to their data, and what the significance and consequences of this might be for the individual

Subject access requests must be submitted in writing.
They should include:

 Name of individual
 Correspondence address
 Contact number and email address
 Details of the information requested

If staff receive a subject access request they must treat the request or, if they have concerns, forward it to their direct reports.

When responding to requests, we:


May ask the individual to provide 2 forms of identification
May contact the individual via phone to confirm the request was made
Will respond without delay and within 1 month of receipt of the request. We may require further time (up to a maximum of 2 further months) if the request for information is complex – in this case, we will inform the data subject accordingly
Will provide the information free of charge

If the request is unfounded or excessive, we may refuse to act on it, or charge a reasonable fee
that takes into account administrative costs.
A request will be deemed to be unfounded or excessive if it is repetitive or asks for further copies of
the same information.
When we refuse a request, we will tell the individual why, and tell them they have the right to
complain.

In addition to the right to make a subject access request and to receive information when we are collecting their data about how we use and process it individuals also have the right to:

Withdraw their consent to processing (if the lawful basis is consent of the data subject)
Ask us to rectify, erase or restrict processing of their personal data, or object to the processing of it (in certain circumstances)
Prevent use of their personal data for direct marketing
Challenge processing which has been justified on the basis of public interest
Request a copy of agreements under which their personal data is transferred outside of the European Economic Area
Object to decisions based solely on automated decision making or profiling (decisions taken with no human involvement, that might negatively affect them)
Prevent processing that is likely to cause damage or distress
Be notified of a data breach ( in certain circumstances)
Make a complaint to the relevant authorities
Ask for their personal data to be transferred to a third party in a structured, commonly used and machine-readable format (in certain circumstances)

Individuals should submit any request to exercise these rights:

By visiting this page on our website: yspweb.com/contact
By email: [email protected]

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

Facebook Fan Page

Data Controller for the Facebook Fan Page

The Company is the Data Controller of Your Personal Data collected while using the Service. As operator of the associated Facebook Fan Page https://www.facebook.com/YSPPublishing, the Company and the operator of the social network Facebook are Joint Controllers.

The Company has entered into agreements with Facebook that define the terms for use of the Facebook Fan Page, among other things. These terms are mostly based on the Facebook Terms of Service: https://www.facebook.com/terms.php

Visit the Facebook Privacy Policy https://www.facebook.com/policy.php for more information about how Facebook manages Personal data or contact Facebook online, or by mail: Facebook, Inc. ATTN, Privacy Operations, 1601 Willow Road, Menlo Park, CA 94025, United States.

Facebook Insights

We use the Facebook Insights function in connection with the operation of the Facebook Fan Page and on the basis of the GDPR, in order to obtain anonymized statistical data about Our users.

For this purpose, Facebook places a Cookie on the device of the user visiting Our Facebook Fan Page. Each Cookie contains a unique identifier code and remains active for a period of two years, except when it is deleted before the end of this period.

Facebook receives, records and processes the information stored in the Cookie, especially when the user visits the Facebook services, services that are provided by other members of the Facebook Fan Page and services by other companies that use Facebook services.

For more information on the privacy practices of Facebook, please visit Facebook Privacy Policy here: https://www.facebook.com/privacy/explanation

CCPA Privacy

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if You provided such personal information directly to Us.

Category A: Identifiers.
Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver\’s license number, passport number, or other similar identifiers.
Collected: Yes.
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver\’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
Collected: Yes.
Category C: Protected classification characteristics under California or federal law.
Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Collected: No.
Category D: Commercial information.
Examples: Records and history of products or services purchased or considered.
Collected: Yes.
Category E: Biometric information.
Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Collected: No.
Category F: Internet or other similar network activity.
Examples: Interaction with our Service or advertisement.
Collected: Yes.
Category G: Geolocation data.
Examples: Approximate physical location.
Collected: No.
Category H: Sensory data.
Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
Collected: No.
Category I: Professional or employment-related information.
Examples: Current or past job history or performance evaluations.
Collected: No.
Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Collected: No.
Category K: Inferences drawn from other personal information.
Examples: Profile reflecting a person\’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Collected: No.

Under CCPA, personal information does not include:

Publicly available information from government records
Deidentified or aggregated consumer information
Information excluded from the CCPA\’s scope, such as:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
- Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver\’s Privacy Protection Act of 1994

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

Directly from You. For example, from the forms You complete on our Service, preferences You express or provide through our Service, or from Your purchases on our Service.
Indirectly from You. For example, from observing Your activity on our Service.
Automatically from You. For example, through cookies We or our Service Providers set on Your Device as You navigate through our Service.
From Service Providers. For example, third-party vendors to monitor and analyze the use of our Service, third-party vendors for payment processing, or other third-party vendors that We use to provide the Service to You.

Use of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose personal information We collect for \”business purposes\” or \”commercial purposes\” (as defined under the CCPA), which may include the following examples:

To operate our Service and provide You with our Service.
To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Service.
To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Service, We will use that personal information to respond to Your inquiry. If You provide Your personal information to purchase a product or service, We will use that information to process Your payment and facilitate delivery.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to You when collecting Your personal information or as otherwise set forth in the CCPA.
For internal administrative and auditing purposes.
To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.

Please note that the examples provided above are illustrative and not intended to be exhaustive.

If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy.

Disclosure of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

Category A: Identifiers
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Category D: Commercial information
Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.

When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Sale of Personal Information

As defined in the CCPA, \”sell\” and \”sale\” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer\’s personal information by the business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

Please note that the categories listed below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact sold, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been shared for value in return.

We may sell and may have sold in the last twelve (12) months the following categories of personal information:

Category A: Identifiers
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Category D: Commercial information
Category F: Internet or other similar network activity

Share of Personal Information

We may share Your personal information identified in the above categories with the following categories of third parties:

Service Providers
Payment processors
Our affiliates
Our business partners
Third party vendors to whom You or Your agents authorize Us to disclose Your personal information in connection with products or services We provide to You

Sale of Personal Information of Minors Under 16 Years of Age

We do not knowingly collect personal information from minors under the age of 16 through our Service, although certain third party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies and we encourage parents and legal guardians to monitor their children\’s Internet usage and instruct their children to never provide information on other websites without their permission.

We do not sell the personal information of Consumers We actually know are less than 16 years of age, unless We receive affirmative authorization (the \”right to opt-in\”) from either the Consumer who is between 13 and 16 years of age, or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, You (or Your authorized representative) may submit a request to Us by contacting Us.

If You have reason to believe that a child under the age of 13 (or 16) has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information.

Your Rights under the CCPA

The CCPA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:

The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
The right to request. Under CCPA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information. Once We receive and confirm Your request, We will disclose to You:
- The categories of personal information We collected about You
- The categories of sources for the personal information We collected about You
- Our business or commercial purpose for collecting or selling that personal information
- The categories of third parties with whom We share that personal information
- The specific pieces of personal information We collected about You
- If we sold Your personal information or disclosed Your personal information for a business purpose, We will disclose to You:
  - The categories of personal information categories sold
  - The categories of personal information categories disclosed
The right to say no to the sale of Personal Data (opt-out). You have the right to direct Us to not sell Your personal information. To submit an opt-out request please contact Us.
The right to delete Personal Data. You have the right to request the deletion of Your Personal Data, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our Service Providers to delete) Your personal information from our records, unless an exception applies. We may deny Your deletion request if retaining the information is necessary for Us or Our Service Providers to:
- Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with You.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information\’s deletion may likely render impossible or seriously impair the research\’s achievement, if You previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which You provided it.
The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer\’s rights, including by:
- Denying goods or services to You
- Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
- Providing a different level or quality of goods or services to You
- Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services

Exercising Your CCPA Data Protection Rights

In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can contact Us:

By visiting this page on our website: https://yspweb.com/contact/

Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.

Your request to Us must:

Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative
Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it

We cannot respond to Your request or provide You with the required information if we cannot:

Verify Your identity or authority to make the request
And confirm that the personal information relates to You

We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice.

Any disclosures We provide will only cover the 12-month period preceding the verifiable request\’s receipt.

For data portability requests, We will select a format to provide Your personal information that is readily useable and should allow You to transmit the information from one entity to another entity without hindrance.

Do Not Sell My Personal Information

You have the right to opt-out of the sale of Your personal information. Once We receive and confirm a verifiable consumer request from You, we will stop selling Your personal information. To exercise Your right to opt-out, please contact Us.

The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Service that sells personal information as defined by the CCPA law. If you wish to opt out of the use of Your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.

Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that You use.

Website

You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:

The NAI\’s opt-out platform: http://www.networkadvertising.org/choices/
The EDAA\’s opt-out platform http://www.youronlinechoices.com/
The DAA\’s opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

The opt out will place a cookie on Your computer that is unique to the browser You use to opt out. If you change browsers or delete the cookies saved by your browser, You will need to opt out again.

Mobile Devices

Your mobile device may give You the ability to opt out of the use of information about the apps You use in order to serve You ads that are targeted to Your interests:

\”Opt out of Interest-Based Ads\” or \”Opt out of Ads Personalization\” on Android devices
\”Limit Ad Tracking\” on iOS devices

You can also stop the collection of location information from Your mobile device by changing the preferences on Your mobile device.

\”Do Not Track\” Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track signals.

However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.

Children\’s Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent\’s consent before We collect and use that information.

Your California Privacy Rights (California\’s Shine the Light law)

Under California Civil Code Section 1798 (California\’s Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties\’ direct marketing purposes.

If you\’d like to request more information under the California Shine the Light law, and if You are a California resident, You can contact Us using the contact information provided below.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account.

Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Who we share your data with

If you request a password reset, your IP address may be included in the reset email.

Where your data is sent

Visitor comments may be checked through an automated spam detection service.

Usage, Performance and Miscellaneous

We may use third-party Service Providers to provide better improvement of our Service.

Google Places
Google Places is a service that returns information about places using HTTP requests. It is operated by Google
Google Places service may collect information from You and from Your Device for security purposes.
The information gathered by Google Places is held in accordance with the Privacy Policy of Google: https://www.google.com/intl/en/policies/privacy/

Children\’s Privacy

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party\’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

THIRD PARTY LINKS & USE OF YOUR INFORMATION:

Our Service may contain links to other websites that are not operated by us. This Privacy Policy does not address the privacy policy and other practices of any third parties, including any third party operating any website or service that may be accessible via a link on the Service. We strongly advise you to review the privacy policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Comments

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

GRIEVANCE / DATA PROTECTION OFFICER:

If you have any queries or concerns about the processing of your information that is available with us, you may email our Grievance Officer at Action Media Solutions SAS, 2Q Rue Benoit Oriol, email: [email protected]. We will address your concerns in accordance with applicable law.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the \”Last updated\” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Details

If you have any questions about this Disclaimer, You can contact Us:

By email: [email protected]
By visiting this page on our website: https://yspweb.com/contact

Contact details of the controller for the service subject to this Privacy Notice:
Action Media Solutions, 2 Quater Rue Benoit Oriol 42400 St Chamond