PRIVACY POLICY AND COOKIE POLICY PEER PRODUCER

Data processing

1. Foreword

1.1 PPY ("PPY"), owned by YLIWAY S.R.L., with registered office in Via Cassia n. 1081, 00189 ROMA (RM), C.F./P. IVA 01224910578, REA Number RI - 77305 ("YIT"), is a web platform licensed to YLIWAY IRELAND LIMITED, BLG Chartered Floor 3, The Boathouse Bishop Street, Dublin 8, D08 HO1F, Ireland ("YIL"). The PPY platform was created with the aim of helping Peer Producers to convey their products, online courses, offline courses, Training Room, Coaching Room, Webinars, Masterclasses and Business Network Room, events and job offers (all together 'Services').

1.2 This information notice, provided pursuant to Article 13 EU Regulation No. 679/2016 (hereinafter, also "GDPR"), describes the manner and purpose of the processing of personal data of teachers, trainers, coaches, room managers, public and public schools of all levels, colleges, campuses and universities ("Peer Producers") who intend to offer online courses, offline courses, training rooms, coaching rooms, webinars, masterclasses, business network rooms and events ("Products") through the PPY platform so that such content is made available to users of the web platform YLIWAY.COM, by means of users' access to its web domains and/or software ("Platform").

1.3 PPY is an online platform that can only be accessed by teachers, trainers, coaches, room managers and learning institutions ("Peer Producers") to upload online and offline courses, training rooms, coaching rooms, webinars, masterclasses, business network rooms and events ("Products") and a range of information relating to the products, their identity and job search ("Information") to the YLIWAY.COM platform. Social content such as posts or articles can also be published. Product information, social content and Information are viewable on YLIWAY.com ("Visitors").

2. Con-Title of treatment

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

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

jointly determine some of the purposes and methods of processing your personal data;
jointly determine a procedure to provide you with timely feedback should you wish to exercise your rights under Articles 15 et seq. of the GDPR;
jointly define this policy.

3. Treatment modalities

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

4. Purpose of processing

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

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

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

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

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

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

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

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

5. Recipients of personal data

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

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

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

6. Visibility of data to other YLIWAY Users

6.1 The Peer Producer Account profile is visible to all YLIWAY Members. Any data that the Peer Producer includes in his/her profile and any content posted or any social activity (e.g. likes, followed items, comments and shares) undertaken on the platform will be viewed by third parties, in accordance with the privacy settings selected.Through the Contact Info functionality, and through the features in the User Account, you can decide which personal data you want to make visible to other users.

6.2 Other Peer Producers or other Users may publish or write something on a Peer Producer or may tag him/her.

6.3 Registered Peer Producers may publish content that includes information (such as part of articles, posts, comments and videos) within or independently of the Services offered. YLIWAY may publish feedback that relates to the Products offered by the Peer Producers.

6.4 PPY records Peer Producers' visits to and use of the Services, including mobile apps, including sites, apps and platform technology, as well as when they view or click on content or advertisements, perform a search, install or update one of YLIWAY's mobile apps, share articles or apply for jobs.

PPY uses logins, cookies, device information and Internet Protocol (IP) addresses to identify you and record the operations you perform.

Please read the Cookie Policy in its most comprehensive version.

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

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

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

6.8 PPY's Free and Paid Services (Premium Services) help Peer Producers search for and contact target Members via the Services offered, e.g. search for and contact job candidates, potential clients and collaborators, manage talent and promote content via social media; personalised search features and tools (including messaging and activity alerts). To participate in Training Rooms, Coaching Rooms, Webinars, Masterclasses and Business Network Rooms (all together 'Rooms'), to attend events at discounted prices, to create and participate in thematic groups and to apply for open job positions (all together 'Services').

6.9 PEERPRODUCER.YLIWAY.COM, with prior consent, provides personalised advertisements, through the analysis of Information provided by Members (e.g. profile, contact information, job title, profession and references of pages opened by the user on other social networks); data derived from the use of the Services (e.g. search history, feeds, content read, links, interests in specific topics, participation in groups, page visits, videos viewed, clicks on advertisements, etc.).

You can refuse the display of customised advertisements and choose not to display individual advertisements.

6.10 YLIWAY Users and Visitors will be able to find and view publicly shared content, including the User's name and other data, based on their privacy settings.

Posts published in a group are visible to other members of the group unless they are shared in the YLIWAY dashboard. In this case they become public.

Membership of groups is public and forms part of the user's profile, unless otherwise specified.

Any information shared via pages of companies or other organisations on the platform may be viewed by those entities and others who visit those pages.

6.11 The Peer Producer understands that by submitting or posting content to or via the platform, it grants YLIWAY a worldwide, non-exclusive, royalty-free licence (with the right to sub-licence) to use, copy, reproduce, process, adapt, modify, publish, transmit, display, and distribute the content (including the name and image) using all existing or future means or methods of distribution. This includes making the content available to other companies, organisations, or persons who cooperate with YLIWAY for the broadcast, transmission, distribution, or publication of the content in other media, as well as the use of the content for marketing purposes.

The Peer Producer agrees that all use of the content is free of charge, without any claim to remuneration.

7. Storage time of your personal data

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

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

8. Rights of the data subject

8.1 You can exercise your rights under the GDPR:

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

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

9. Security

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

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

Last updated on 05.12.2023

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