Last revised on January 12, 2022
We respect and value your privacy as well as the integrity of the information you have provided and/or permitted us to collect. Thus, we endeavor to follow industry standards to ensure the security and confidentiality of your Personal Information (as defined below) when you access the Yield Platform or use the Yield Services.
When accessing, registering, downloading, using, clicking or engaging in any of the Yield Services provided on the Yield Platform, you are strongly advised to carefully read, acknowledge, understand
GDPR"), in particular with regard to the rules governing the processing of Personal Information within the European Economic Area (EEA) and the United Kingdom respectively.
Unifi Group Limited, YieldApp OÜ and Yield App Limited are the joint controllers (as defined in GDPR and UK GDPR) of your Personal Information, with registered addresses as follows:
Unifi IP Holdings Limited is the UK representative for Unifi Group Limited, YieldApp OÜ and Yield App Limited with its registered address at 71-75 Shelton Street, Convent Garden, London, WC2H
9JQ, United Kingdom.
YieldApp OÜ is the EEA representative for Unifi Group Limited and Yield App Limited with its registered address at Harju Maakond, Tallinn, Nõmme Linnaosa, Rännaku pst 12, 10917.
- Unifi Group Limited is incorporated under the laws of the British Virgin Islands.
- YieldApp OÜ is an Estonian Limited Liability Corporation incorporated under the laws of the Republic of Estonia.
- Yield App Limited is an International Business Company incorporated under the laws of the Republic of Seychelles.
3. Personal Information that we collect
Information provided by you when registering to the Yield Platform
When you first sign up to use the Yield Services by opening a Yield Account, you may be required to provide with us your real name, date of birth, nationality, home address, email address, signature and other information which can be used to verify your identity.
Generally, we will not collect nor process "Sensitive Information" (defined in GDPR and UK GDPR as “special categories of personal data”), such as racial or ethnic origin, political opinions, religious
or philosophical beliefs, trade union membership, genetic data, biometric data that uniquely identify specific persons, or any information concerning health or sexual orientation. However, if you are
using biometric authentication methods to sign into your Yield Account and so are required to provide us with your fingerprint data or facial recognition data we shall need to seek your explicit consent to process such biometric data to comply with our legal obligations.
Information collected by us for compliance purposes
In order to comply with domestic and international industry standards, government rules and regulations, in particular the Anti-Money Laundering (AML) regulations, Know Your Customer (KYC)
rules and Counter-Terrorist Financing (CTF) regulations, the Yield Operators and Third Party Service Providers are required to collect and retain your Personal Information from identification documents, such as your passport, national identification card, driver’s license, tax identification and visa. Other documents which we may use are, including but not limited to, your proof of address, source of funds declaration, purpose and source of wealth.
Information collected by us during your usage of the Yield Services
When you engage or use the Yield Services, we will monitor and track your Personal Information in relation to your usage of the Yield Services such as your IP address, phone number, blockchain addresses, the type of device you use to access the Yield Platform, device information, operating system and hardware settings, browser type and network operator. This information shall either be directly obtained by the Yield Operators or through Third Party Service Providers.
We collect this type of information to ensure that our interface and/or the Yield Platform is seamlessly accessible for all permitted Users around the world and in order to provide you with the
Communication of Personal Information
You hereby agree that we are entitled to collect and use the Personal Information you have provided on the Yield Platform or generated through your usage of the Yield Services for the purpose of communicating with you through messages, requests, emails, telephone conversions, voicemails, live chats. Such information will include file attachments in connection with your transactions on the Yield Platform, or any other information related to your contact with the Yield Operators.
during the usage of the Yield Services. This includes, without limitation, your transaction history, such as your initial transfer of cryptoassets, withdrawal requests, digital wallet/blockchain address(es), bank name, bank account information and payment card number.
We also collect and process this financial information to monitor any suspicious financial activities in order to protect Users from fraud, resolution of legal cases, as well as any other purposes as
4. How we collect Personal Information
We will automatically collect and process Personal Information provided by you under the following situations:
Where we ask you for your Personal Information which you are obliged to provide to us you may decline to provide it to us but if you do so we may not be able to enter into or to perform our contract with you to provide the Yield Services and we may have to terminate our relationship. For other Personal Information which you may not be under an obligation to provide to us but which we seek from you, if you do not provide it then we may not be able to properly perform our arrangements with you.
Information collected by the third-party
We shall collect your Personal Information from third parties as required or to the extent permitted under any Applicable Laws. Information from the third-party sources shall include, but not be limited
to, public databases, credit bureaus, ID verification partners, blockchain data, marketing partners and resellers, advertising partners, and analytics providers.
Anonymised and Aggregated Data
We will also process other Personal Information to convert it into the form of anonymised and aggregated information, where all information shall be combined and then anonymised making it
5. How we use Personal Information
Your Personal Information shall be made available to the Yield Operators, our affiliates and service providers, and/or within our group of companies. This will include, but not be limited to, the employees and/or any persons or Third Party Service Providers working with the Yield Operators who are responsible for using and protecting your Personal Information. Where it is necessary (e.g., to protect the vital interest of the users or other natural persons, to fulfil the purpose of public interest, or to pursue our legitimate interest without overriding your rights and freedoms), we may use and process your Personal Information without obtaining your consent.
We use and process your Personal Information for the following purposes or in the following manners:
To provide the Yield Services
We use your Personal Information, either collected or delivered, in order to maintain and provide efficient Yield Services in accordance with our contractual obligations owed to you (including, but not limited to, processing transactions) and, for our and your legitimate interests, to improve the efficiency of day-to-day Yield Services and, to comply with our legal obligations, to verify your identity. We use IP addresses and unique identifiers stored in your device's cookies to help us authenticate your identity and activities and provide the Yield Services.
To protect Users as part of the provision of Yield Services
In order to comply with our legal obligations we use the information collected to protect the Yield Platform, Users' Yield Accounts and archives. We also use IP addresses and cookies to detect any suspicious activities and to protect against automated abuse, such as spam, phishing and Distributed Denial of Service (DDoS) attacks.
To comply with the relevant legal rules and regulations
For our legitimate interests and to comply with our legal obligations, we shall use the Personal Information in compliance with our legal obligations, global and local industry standards, government requests and our AML/KYC/CTF procedures.
For measurement, research and development purposes
For our and your legitimate interests, we actively measure and analyse your Personal Information to understand the way you use and interact with the Yield Services. This review is continuously conducted by our operational teams to continuously improve the Yield Platform's performance and to resolve issues with User experience.
In addition for the same reasons, we use such information to customise, measure and improve the Yield Services, our administration, the content and layout of the Yield Platform, and to develop new services for you.
For communication purposes
To enforce the Terms
Personal Information is also used, for our legitimate interests, to continuously and actively enforce our Terms among our Users. Activities in this regard include, but are not limited to, reviewing, investigating and preventing any potentially prohibited or illegal activities that may violate preceding provisions, or disclose relevant information to third parties in accordance therewith. In light of this, we reserve the right to suspend or terminate any of the Yield Services to any Users who are found to be engaged in any activities that violate our Terms.
For marketing and advertising
For our legitimate interests, we may share your Personal Information with our marketing partners for the purposes of targeting, modelling and/or identifying analytics as well as marketing and advertising services which are the same as or similar to the Yield Services. In any marketing communications which are sent to you, you will be advised as to how you can opt-out of receiving any further marketing communications from us or such partners.
For your referrer’s and our legitimate interests, we shall share the Personal Information collected from you, including but not limited to, your identification information and transaction information, with your referrer for the purposes of rebates and other benefits.
For other purposes
6. How we store your Personal Information
We shall take great care in implementing and maintaining the security of the Yield Services as well as that of your Personal Information. We employ procedures and policies that incorporate industry best practices to ensure the integrity of your Personal Information and to prevent instances of unauthorised use.
The Yield Platform’s security is fully integrated into Amazon Web Services, covering all aspects of security such as identity management, connection security, application security and database security for User’s interactions with the Yield Platform.
Please note that it is impossible to fully guarantee the security of your Personal Information. While we take reasonable steps to safeguard your Personal Information, we disclaim any liability for the acts committed by those who gain unauthorised access or abuse your information and services unless caused by our gross negligence. Thus, you are recommended to understand this responsibility and to independently take the necessary safety precautions to protect your Personal Information, in particular your credential information, such as your username and password. You hereby agree that we shall not be liable for any information leakage and/or other losses not caused by our gross negligence, including but not limited to, hacker attacks, power interruptions or unavoidable technical failures.
7. How long we retain your Personal Information
We may be required by Applicable Laws to retain certain information, including Personal Information of Users, Users' profiles, identification verification materials, information relevant to AML/KYC/CTF procedures, account information, account agreements, and other agreements between us and third-parties, account statements, and other records.
Such records shall generally be retained as required by law for the minimum amount of time necessary to accomplish the purpose for which it is collected and thereafter no longer than is permitted under Yield Operators’ Information Retention Policy.
However, even after you have deactivated your Yield Account, we may retain copies of information about you and any transactions or services which you may have participated in for a period of time in accordance with the applicable laws, statute of limitations or as we believe as reasonably necessary to comply with the applicable laws, regulations, legal procedures or governmental requests in order to detect or prevent fraud, outstanding fees, resolve disputes, address problems with the Yield Services, assist with investigations, enforce any of our Terms or other applicable agreements or policies, or to take any other actions consistent with Applicable Laws.
9. Sharing your Personal Information
We may share, transfer, disclose, or allow access to your Personal Information to the following third parties for the purposes described below:
Other circumstances under which we may disclose your Personal Information are as follows:
10. Third-Party Collection of Personal Information
11. Your Legal Rights
Under certain circumstances, you have the rights under the data protection laws in relation to your Personal Information. These rights include but are not limited to the following:
Right to be informed
Right of access
You have the right to obtain access to the Personal Information we hold about you and specific information regarding our processing of this information.
Right to rectify
You have the right to require us to rectify your Personal Information that is inaccurate. You can check your account details at any time by signing into your Yield Account and clicking the profile.
Right to erasure
You may require us to have your Personal Information deleted from our records where certain conditions are met.
Right to data portability
You reserve the right to request to transfer a machine-readable copy of your Personal Information to you or the third-party of your choice. We shall provide you, or the third-party, your Personal Information in a machine-readable format. This right only applies to Personal Information you have provided to us to use.
Right to restrict processing
You may request us to restrict or suppress the processing of your Personal Information under certain circumstances as follows:
Right to object
You may object to our reliance on our legitimate interests as the basis of us processing your Personal Information which may impact your personal rights. You may also object to our processing of your Personal Information for any direct marketing purposes.
Right to withdraw consent ("Opt-out")
You reserve the right to withdraw your consent at any time where we are relying on it to process your Personal Information.Withdrawing your consent does not affect the lawfulness of our processing of your Personal Information prior to withdrawing and we are entitled to continue processing your Personal Information where we have other legal bases for doing so.
If you wish to exercise these rights as aforementioned, please inform and contact us via the Yield Platform as set out below.
Right to lodge a complaint with a privacy regulator
You have the right to make a complaint to your local privacy regulator. If you wish to make a complaint, we would ask that you contact us before you contact the regulator so that we may see if the issue can be resolved first. You can also contact your local privacy regulator if you have any concerns regarding your rights under local law.
12. Rights of the residents of the EEA
If you are a resident of the EEA, United Kingdom, or Switzerland at the time your Personal Information is collected, you still reserve every legal right as stipulated in Clause 11 as mentioned above. Also, we shall specifically apply legal requirements under the GDPR and UK GDPR (as applicable) for collecting, using, or processing your Personal Information.
In the case where some recipients are located outside the EEA, Switzerland or the UK, we shall transfer your Personal Information only to such countries as approved by the European Commission or the UK’s Information Commissioner (as relevant) as providing an adequate level of data protection or enter into legal agreements ensuring an adequate level of data protection in the jurisdiction of the party receiving the information.
13. Limitations for age and data breaches
The Yield Services are not designed for the individuals who are under the age of 18 or under the legal age to provide consent under the applicable laws of the country or jurisdiction where you are using the Yield Services.
If you are not over 18 or of the legal age of your country, you shall not provide any Personal Information to us, or to engage in the Yield Services. We reserve the right to access and verify any Personal Information collected from you. If we become aware that you are under 18 or under the legal age and you have already shared your Personal Information with us, we shall then discard such information and terminate your Yield Account immediately.
We cannot guarantee that any losses, misuses, unauthorised accession, or alteration of your Personal Information shall not occur. You hereby agree that you play a vital role in protecting your Personal Information, including your credentials. When registering with the Yield Services, you are strongly recommended to choose a password with the sufficient length and complexity and to not reveal this password to any third parties or unauthorised persons. Also, you agree that you shall immediately notify us if you become aware that unauthorised persons have accessed or might
access your Yield Account.
14. Transferring your Personal Information outside the UK and the EEA
16. How to contact Yield Operators