Privacy policy
This privacy policy explains what information we collect, for what purpose, how we receive data, what your rights are and how you can adjust your preferences.
What is personal data and what is meant by data processing?
Personal data is data that tells something about you, or that can be associated with you. It concerns data that says something about you as a person. Examples of personal data are your name, your address and your contact details such as e-mail address and telephone number. Your citizen service number (BSN), your date of birth and the IP address of your computer are also personal data. Information that says something about your personality, such as your interests, is also personal data.
The law also recognizes a special category personal data. This is information about you that is extra confidential. Examples of special personal data are data about your medical health, race, sexual orientation, religion and political preference.
Processing is a concept from European privacy legislation (GDPR). Processing includes almost everything that can be done with personal data, from collection to consultation and destruction. The General Data Protection Regulation (GDPR), article 4, describes processing as “collecting, recording, organizing, structuring, storing, updating or changing, retrieving, consulting, using, forwarding, distributing or otherwise making available, aligning (bringing ) or combining, blocking, deleting and destroying data”.
Legal bases for Processing
The primary basis is Execution of the Law, Execution of the Agreement and/or Legitimate interest of Yenlo.
Subsidiary the legal basis is Consent of the Data Subject, if the law requires the Consent of the Data Subject or if the aforementioned primary basis is insufficient. Permission is in any case required (as a legal basis) for the processing by Yenlo (including further sharing in the chain) of Special Data, newsletters, marketing and advertisements (cookies).
The aforementioned does not detract from the fact that on top of that there must be necessity and that the processing does not go beyond what is necessary. Yenlo only processes personal data insofar as this is necessary for the performance of its ICT services and activities. And only in ways that are (derived) compatible with the purposes for which this information was collected or subsequently authorized by you.
When does Yenlo act as an independent Data Controller or as a Data Processor on behalf of another?
See preamble of the Data Processing Agreement (DPA) at https://www.yenlo.com/data-processing-agreement-v5-1/
Regarding the processing of any personal data related to this Website (including any web form and handling thereof) and/or the acquisition of Customers, Suppliers, Partners or prospects and/or in the context of handling the order process for Finance, Sales or Marketing of Yenlo, Yenlo is processing for its own purposes and Yenlo acts in that respect as an independent Data Controller (and not as a Data Processor). This is important because a Data Controller is responsible for correctly and completely informing as well where necessary acquire the consent of Data Subject. Because Data Controller is responsible for all statutory tasks under the GDPR, such as providing for a Processor Agreement (if applicable), confidentiality, adequate security for the entire chain, informing the Data Subject, obtaining the Data Subject’s consent (where necessary), externally reporting a data breach to the privacy Authority and the respective Data Subjects and the handling of any other GDPR rights exercised by a Data Subject (such as inspection, deletion, data portability). And that for the entire supply chain (including all its subcontractors). A Data Processor, on the other hand, is only responsible for providing a Processor Agreement (if applicable), confidentiality and adequate security. But only for its own processing part in the supply chain.
From whom does Yenlo receive personal data?
Yenlo receives data primarily from Yenlo affiliates, Customers, Suppliers, Partners, parties Yenlo works with, and public sources.
With which parties does Yenlo share personal data?
Various parties may be involved in Yenlo’s services. These external parties have been carefully selected. Yenlo requires them to handle privacy-sensitive data just as carefully as Yenlo itself. This applies exhaustively to the following TYPE/KIND of receivers:
• The relevant Customer, Suppliers or Partner concerned
• Affiliated companies belonging to the Yenlo group
We may share your personal information with our Yenlo affiliates. Our affiliates will use your personal information that we share with them in a manner consistent with this Privacy Policy. For the intra-group processing and/or sharing of personal data within the Yenlo group, a Data Exchange Agreement is foreseen in accordance with the GDPR , which will be sent upon request of User/Data Subject, (which, among other things, determines which Yenlo entity is operationally responsible for a particular application, which personal data is shared and for what concrete purposes the personal data is used), unless and insofar as the Data Processing Agreement with a specific Customer, Supplier or Partner provides otherwise.
• Parties with whom Yenlo cooperates for the implementation of its ICT services and/or activities.
To ensure that Yenlo works as effectively and efficiently as possible, some services are outsourced to other companies. These concerns:
– Datacentres (being Amazon and Microsoft Azure).
– Software providers (including hosting platform providers) (such as WSO2, Apache, AFAS, Boomi, Mulesoft, Azure, InterSystems, Redwood/Cerberus FTP).
This also includes the suppliers of the software packages for the implementation of Yenlo’s own Finance, HR and Sales administration (such as Exact, AFAS, Microsoft, DocuSign/E-sign, Recruitee, My Justiz, EasyCV, Share, Trackadoo, LIFT, Pipedrive, Topdesk Marktplaats, Tableau, WeTransfer, Training Portal).
– Integration partners
– Externally hired software developers and consultants (including web designers)
– The cookie suppliers below.
– Various recruitment-, consultancy and/or marketing agencies.
– Archive managers,
– Debt collection and bailiff agencies, and
– parties that are given access to data in the context of certification processes (such as ISO and NEN).
Which personal data each of the above Type of Recipients (such as External Developers, Integration Partners, Archive Managers) has access to and for what concrete Purpose the above Type of Recipients use the personal data is described below or in Yenlo’s Data Processing Register. A copy of the relevant pages for the Data Processing Agreement will be sent upon request.
• Government agencies and external parties who must be informed due to legal obligations.
These parties only see your personal data if they need it to perform their task and when this is legally permitted. Yenlo never shares medical health data with other parties without your permission, unless there is a legal obligation or court order to do so. If the law is being violated or if there is a suspicion of this, Yenlo can choose to inform government parties.
• In addition, Yenlo may also share information with third parties in the context of scientific, statistical or historical research (including internship assignments). In that context, Yenlo can share information with government agencies (such as CBS) and recognized collective sector organizations in the context of scientific, statistical or historical research for non-commercial purposes in accordance with Article 24 GDPR. The same applies to internship assignments of Yenlo employees. Starting point for this is, in principle, your further consent or that the personal data cannot be traced directly or indirectly to persons in any way.
• Other companies or individuals, if you ask.
Contact persons, such as next of kin or court appointed administrators may request information about you if you have given explicit permission for this. If you wish, Yenlo can exchange information with other parties in specific cases. For example, your new or old employer or a doctor who gives you a second opinion or a lawyer. This only happens if you ask for it and with your explicit permission.
Yenlo expressly points out that the above recipient(s), also after termination of your Yenlo account, insofar as necessary and during the retention period prescribed below by law, may have access to your personal data.
What personal data collect and /or are shared by or with Yenlo with aforementioned recipients?
This varies per Type of Recipient (including per Customer, Supplier, Partner or relation) and even per project within the same Recipient, Customer, Supplier or Partner. In this context, we refer to the relevant Data Processing Agreement of the Customer, Supplier, Partner or Relation or to Yenlo Data Processing Register, which lists per application which personal data we process (for which purposes). A copy of the relevant pages for the Data Processing Agreement will be sent upon request. This mainly includes:
• Contact details: Name, address, place of residence, gender, telephone number, email address,
• Profile data, Performance feedback, IP address/Device and browser.
• E-mail messages.
• Job application: Job profile and profile photo, passport photo, CVs, Employment history and work related data, Comments about Candidates, Marital status, date of birth, place of birth.
• Sensitive: BSN number, passport, financial data.
For what purpose does Yenlo use personal data?
It concerns at least the following possible goals:
• Carrying out legal obligations.
• Execution of the Agreement.
• For the proper functioning and/or improvement of the Website, services and/or company/business operations of Yenlo.
• Carrying out quality tests.
Quality tests are carried out on the basis of ‘legitimate interest’ and, where necessary, ‘explicit consent’. Yenlo carries out quality tests to comply with its duty of care and to maintain the quality of the services offered.
• Recruiting and/or maintaining contacts with Customers, Suppliers, Partners and/or Relations.
• Marketing and advertising.
• Handling any question and/or complaint.
• Telephony and video calling.
In Yenlo’s Data Processing Register, it is further and more concretely determined per application for which concrete and/or further to be achieved Purposes the processing serves. A copy of the relevant pages for the Data Processing Agreement will be sent upon request.
Minors
We only process personal data of minors (persons under the age of 16) if written permission has been given by the parent, caregiver or legal representative
Cookies
This Website and portal systems use cookies. Cookies enable the Website and portal systems to recognize computers. This facilitates the use of these services: thanks to cookies, settings are remembered while forms and videos on the Website gains insight for Yenlo into what does and does not function (effectively).
Non-Intrusive Necessary Functional Cookies
Non-Intrusive Necessary Functional Cookies help make our Website more usable by enabling basic functions such as page navigation and access to secure areas of the Website. Without these cookies, the Website cannot function properly. These Cookies consist of:
Cookies that ensure that the Website functions
Strictly necessary functional cookies ensure that the Website functions properly. These are cookies that are necessary for the operation of our Website. For example, they contain cookies that enable you to log into secure areas of our Website or use a shopping cart to create an account (such as “session cookies”).
Cookies to improve the performance of the Website.
Information about the use of our Website and the feedback we receive from our visitors helps us to improve and further develop our Website.
Preference cookies enable a Website to remember information that influences the behaviour and design of the Website, such as your preferred language (“language cookies”) or the region in which you live. Preference cookies are used to improve the performance and functionality of the Website. These are small files that are sent to the User’s browser and stored on the User’s PC. Such cookies remember, among other things, the language settings and personal preferences of the User. Such cookies aim to make the Website more user-friendly by tracking User behaviour and storing certain User preferences.
Cookies to analyse Website usage.
Web analytics: Analytical cookies collect information that Yenlo uses to understand how the Website is used and monitor its performance. In addition, these cookies help Yenlo to customize the Website and improve your user experience. We may also use this data to compile reports to help us analyse how the Website is used, what the most common problems are and how we can improve the Website; In short, we use analytical cookies to analyse our Website traffic in an anonymous way, so that we can adjust functionality and effectiveness.
To do this, we use Google Analytics to keep track of how users use the Website and how effective our advertisements are on Google search results pages. Google Analytics also includes interest and demographic reports. The information thus obtained, including the address of your computer (IP address), is transferred to and stored by Google on servers in the United States.
Read Google’s privacy policy for more information, as well as the specific privacy policy of Google Analytics. We have signed a new processor agreement with Google and the data is encrypted and processed anonymously. We have also disabled “data sharing” with Google. Our Google Analytics settings are privacy friendly.
Statistical cookies
Statistics: Our statistics cookies help us understand how our visitors use our Website. We do this by collecting and reporting data anonymously. For example, Yenlo uses cookies to collect statistical data about visits to the Website. Analytical cookies are placed with the Google Analytics program (owned by Google). An agreement has been concluded with these parties. Additional measures have also been taken to ensure that your privacy remains protected. For example, these companies do not receive your entire IP address.
Non-Intrusive necessary functional cookies are, in accordance with the law, exempt from the prior consent of the User. At the request of the User, a full detailed overview of all (necessary functional) cookies will be sent for information. With regard to all Non-Intrusive necessary functional cookies, Yenlo International Holding B.V., established at Beechavenue 16, 1119 PT Schiphol-Rijk, the Netherlands (Chamber of Commerce number 28117017, acts as Data Controller.
Retention period: Non-Intrusive Necessary Functional cookies that are exempt from the consent requirement only have a lifespan directly related to the purpose for which it is used and are set to expire when no longer needed, taking into account the reasonable expectations of the average user. Therefore, these cookies generally expire when the browser session ends or even earlier (including Google Analytics Cookie Collect, _gid, _gat, _gat, _gat_UA-* and_gtag_UA_* ), except that the following cookies are even longer as 24 hours after ending Session retained:
– Google Analytics Cookies: _ga_* and _Ga_ which have a maximum retention period of 1 respectively 2 years, and
– Complianz Cookies which have a maximum retention period of 1 year.
Opt out of Google Analytics: If you do not want Google Analytics to record data about you (even if it is anonymised), you can opt out completely. You need to install a plug-in in the web browser. Click here for an overview of opt-out plug-ins for different browsers. You can also adjust the privacy setting of your browser.
Intrusive Tracking and Marketing Cookies (including third party cookies)
Tracking and marketing cookies (for marketing and social media purposes)
With tracking and marketing cookies your surfing behaviour can be monitored (by Yenlo (as Data Controller) and/or advertising companies (as Data Processor)). We use marketing cookies to track visitors when they visit our Website and to improve our digital marketing campaigns. These type of cookies allow us to recognize repeat visitors to our sites. By matching an anonymous, randomly generated identifier, a tracking cookie tracks where users of our Websites have come from, what search engine they used, what link they clicked, what keywords they used and where they were when they accessed the Website. By tracking this data, we can improve our Website. This allows Yenlo to show you advertisements based on your interest profile and surfing behaviour (for the purpose of remarketing). In addition, these cookies prevent you from constantly seeing the same advertisement. We use track and/or marketing cookies, after your explicit unambiguous consent, to personalize content and advertisements and to provide social media integration on our Website for sharing our content.
Third party cookies (for social media integration)
This Website includes buttons to promote or share pages on social networks with Facebook, LinkedIn and Twitter. These buttons are realized by a code provided by Facebook, LinkedIn, Twitter and YouTube themselves. Among other things, this code places a cookie. These cookies ensure that the content of the Yenlo Website is shared on social media. For more information about the data that social media companies collect, we refer to the relevant privacy and cookie statements of these companies.
https://www.facebook.com/privacy/policy/
https://help.twitter.com/en/rules-and-policies/twitter-cookies
https://nl.linkedin.com/legal/cookie-policy?
https://support.google.com/youtube/answer/10364219?hl=nl
| Name intrusive cookie | Maximum retention period | Placed by | Goal |
| Active Campaign ac_enable_tracking prism_ | 1 month 2 Year | Active Campaign | Storage and trace of interactions |
| Facebook (including _fbp) | As long as the Facebook account is not deactivated | Facebook Ireland | Identify the web browser used to connect to Facebook |
| Google Adsense _gci_au google_adsense_settings (including Doubleclick.net) | Persistent but Google keeps a tracking of days Persistent | Google Ireland Ltd | Placing Advertisements. |
| Google reCaptcha and Google NID (*.google.com) Rc::C Rc::B Rc::A | Session Session Persistent | Captcha Inc, which is owned by Google.com | The reCAPTCHA uses marketing cookies. These verify that you are a person and not a robot. It also prevents abuse by bots. Anonymously checks whether you are a person to prevent ‘spam bots’ from automatically sending messages or leaving comments, for example. The IP address is abbreviated and therefore made anonymous in countries that are part of the EU. The IP address transmitted by reCAPTCHA is not merged with other Google data. View the Google privacy information. https://measuredcollective.com/gdpr-recaptcha-how-to-stay-compliant-with-gdpr/ |
| Google Maps API | Expires immediately | Google Ireland Ltd/LLC | Figuring out and navigating your world |
| Leadfeeder _lfa_* | 2 years | Leadfeeder | Show which Companies/Users visit the Yenlo Website and what they see. |
| As long as LinkedIn account is not deactivated. Sponsored posts are automatically archived in your Archive folder after 60 days of receipt | Identification and verification of User (account) | ||
| Twitter (including t.co) | 18 months for log data. | Authentication and security Functionality User preferences Analytics Research and development Personalized content Ads Marketing Personalization across devices | |
| Wistia Wistia-Video-Progress-* Wistia | Persistent But Wistia has as policy 24 months, unless otherwise prohibited by the Privacy Laws. | Wistia Inc. | In-depth analytics see how your audience consumes and interacts with your videos. You can get an overall picture of a video’s performance through engagement graphs, or drill down to see how individual viewers view your videos through Wista’s heatmap. |
| YouTube | 8 months for YouTube “pref” cookie and 30 minutes for the ‘pm_sess’ browser session cookie | YouTube uses the “PREF” cookie to store information such as your preferred page configuration and playback preferences, such as explicit autoplay choices, shuffle content, and player size. For YouTube Music, these preferences include volume, repeat mode, and autoplay. |
Opt in: intrusive “tracking, marketing cookies and/or cookies from third parties” require further consent from the Data Subject. At least for the use of these sort of cookies, Yenlo will request the further explicit unambiguous prior consent of the User via a cookie pop-up.
Opt out: Even if you have given your consent, you can still block or delete tracking and/or marketing and/or third party cookies at any time by changing your browser settings. How you can block or delete these cookies can be found in the help center of each browser concerned:
- Google Chrome (including YouTube)
- Internet Explorer
- Firefox
- Safari
- Safari Mobile
- Opera
In addition to the foregoing, Yenlo will, as far as possible, avoid the use of “third party cookies” that are not requested by the User and that persist after deletion, and if this does happen in exceptional cases, Yenlo will request the further explicit unambiguous prior consent from the User.
Web/contact form
If you fill in a web/contact form on our Website, we ask for your name, company name, telephone number and e-mail address. The purpose of this is to contact you or answer your question. The processing of this data is necessary for the proper handling of your request and to take action. The web/contact form will be sent to a mailbox. This mailbox is accessible to employees of Yenlo’s business office and they will then contact you. These web/contact forms are kept for as long as the nature of the relevant web form requires for the complete answering and/or handling thereof and up to a maximum of 6 months after handling for any follow-up questions. The provisions regarding non-intrusive functional cookies apply analogously to this section.
If and insofar as the User has explicitly granted further opt-in permission for this, the web/contact form can also be used for 6 months after the aforementioned processing of the Web/contact form (or much shorter if you use your right to opt out) and/or to approach and attempt to recruit you as a Yenlo prospect, customer, supplier, partner or relation. In that case, the provisions regarding marketing cookies apply analogously to this section.
Sign up for our newsletter and blog notification
If you have subscribed to our newsletter, you can indicate at any time that you no longer wish to receive it. Each newsletter and each offer shows how you can easily unsubscribe from receiving newsletters or offers. Your data will only be shared with selected third parties for sending you offers that may interest you if you have explicitly given your consent.
Retention periods within Yenlo
Yenlo adheres to the legal retention periods. If there is no legal retention period, Yenlo does not store data longer than is necessary for the performance of the task.
Retention periods for Website visitors and cookies
For the retention period of the respective Cookies and the Web/contact form, see above. E-mails are stored for a maximum of 1 year after receipt unless it is necessary to store them for longer.
Other retention periods
Yenlo is legally obliged to keep financial data for 7 years from the end of the calendar year.
For a complete overview of the retention periods used, see https: https://id.atlassian.com/join/user-access?resource=ari%3Acloud%3Aconfluence%3A%3Asite%2F2ef99e95-a576-4fe9-a11e-f8f408a7ec1a&continue=https%3A%2F%2Fgoyenlo.atlassian.net%2Fwiki%2Fspaces%2FYISO%2Fpages%2F3516301336%2FOverview%2Bof%2Blaws%2Band%2Bretention%2Bperiods
The most important information security measures within Yenlo
Yenlo pays a lot of attention to the security of your personal data. Yenlo maintains confidentiality with regard to the information you provide. All data that you exchange with us via our Website is encrypted with TLS security based on the HTTPS protocol.
Data minimization/Minimum collection of personal data
Yenlo only collects the personal data that is necessary to help you as Supplier, Partner, Customer or its end customer as well as possible. The collection of this personal data is purely for the implementation of the ICT services and activities. So no data is collected for other purposes. Yenlo only asks for certain information when it is really necessary for the performance of its tasks.
Risk analyses are carried out on a regular basis and new technological possibilities or threats are examined. There is a continuous improvement process to respond appropriately to current risks, technical possibilities and legal obligations. Our personal data is stored in highly secured data centers. We also test the operation of our information security system. We use and are certified in accordance with the ISO27001 and NEN7510 standard and guidelines for information security. For a more complete overview of all security measures per application, we refer to https://www.yenlo.com/terms-and-conditions/dpa_sec_measurements/.
Making use of your rights
Do you want to know what personal data Yenlo has about you? Do you want to have certain data corrected or transferred? If you think that Yenlo has or stores information about you that it should not have, or if you want to withdraw a previously given permission? Or would you like to have parts of your file destroyed or your entire file removed from the administration? If you can and want to exercise your rights, you can send a request to legal@yenlo.com or call 0031-20-2700700. Before Yenlo processes your request, it will verify your identity. This can be done by enclosing a copy of your proof of identity (without a readable BSN) with your request. What rights do you have when it comes to the processing of your personal data?
The GDPR describes which rights you have as a person. In short, these are the following rights:
- The right of access. You may request your file and other registrations of your personal data from Yenlo and view it yourself. This means that you can request an electronic copy of the processed personal data that Yenlo has from you free of charge (including the log filing so that you can see with whom the personal data has been shared, or who has had access). Yenlo will comply with your request for a right to an electronic copy, unless the privacy of another person outweighs your right to a copy.
- The right to rectification and addition. Is the information incomplete or incorrect? Then you can have this supplemented and/or corrected.
- The right to restriction of processing. This means that Yenlo is (temporarily) not allowed to process your data.
- The right to object. Do you want certain data that Yenlo has from you not to be processed? Then you can object to that.
- The right to data portability. This means that you can receive the personal data you have shared with Yenlo at any time in a machine-readable format, so that you can transfer it to third parties.
- The right to have your file or personal data destroyed (the right to be forgotten). This means that all personal data that you want destroyed will be deleted, as long as this does not conflict with the legal obligations that Yenlo must comply with.
To exercise the aforementioned rights, you must contact the Dat Controller. Insofar as Yenlo acts as a Data Controller, Yenlo is responsible for handling these rights. If Yenlo is not the Data Controller, it will also forward your request internally to the relevant Data Controller.
Complaint or question about Privacy, our Digital Service (including on content moderation or algorithm)
GDPR
Do you believe that Yenlo has not handled your personal data correctly? Or do you have a question or complaint about Yenlo in the field of privacy protection? You can also reach our Legal Counsel by emailing legal@yenlo.com or calling 0031-20-2700700. You can also submit a privacy complaint to the Dutch Data Protection Authority or the applicable district court as set out in article 20 Yenlo’s General Terms and Conditions (hereafter “Yenlo’s GTC”). This is only possible after you have first submitted the complaint to Yenlo.
Digital Service Act
If the Recipient of our (Digital) Service is located within the EU, then the EU Digital Services Act applies (regardless of where the contracting Yenlo entity is established).
For avoidance of any doubt: Insofar as Yenlo only provides an interface (Bid koppeling) it is only acting as an intermediary service. Insofar as Yenlo only provides Apps it is acting as a cloud provider. Insofar as Yenlo provides Connext platform, Connext Go or an Ipaas solution, Yenlo act as an online platform provider, with Amazon or Azure as it’s subcontracted hosting provider.
Notwithstanding aforementioned, Yenlo qualifies as a micro, small or medium enterprise (SME enterprise) (and on top of that its (end) customers are in principle Not Consumers).
This implicates that only Section 1 and 2 + article 24 sub 3 (with exception of article 15) of the EU Digital Service Act applies mandatory to Yenlo, (respectively that article 15, Section 3, 4 and 5 of the EU Digital Service Act are not mandatory applicable to Yenlo). For Yenlo’s Vendors/Suppliers this assessment can be different.
Single Point of contact
Yenlo’s Legal Counsel (legal@yenlo.com) (0031-20-2700700) (situated at Beechavenue 16, 1119 PT Schiphol-Rijk) will act as Single Point of contact for any communication from and/or to any of the Authorities and/or the Recipient of the Services.
The communication language shall be in Dutch or English. This does not diminish the right of Recipients of the Service to choose the means of communication and to not solely rely on automated tools.
Complaint or Legal question
Any Recipient of our Service (including individuals or entities that have submitted notices) has a right to lodge a question or complaint in respect to any aspect of our Website or (Digital) Service whatsoever, electronically and free of charge and to choose from the options set out below:
– A) at Yenlo, in accordance with Yenlo’s internal claim handling procedure as set out below.
Questions, Notices and/or complaints can even be done “anonymously” at Yenlo (“or under the Klokkenluider regeling”).
Complaints submitted by bodies, organisations or associations that act on behalf of recipients of the service are processed and decided upon with priority and without undue delay.
For Yenlo’s complaint formular and procedure see:
The right to lodge a complaint is under EU law limited to 6 months from the day on which the recipient of the service is informed about a decision that the information provided by the recipients constitutes illegal (or harmful) content or is incompatible with its terms and conditions (including decision whether or not to suspend or terminate: i.) recipients account, ii.) provision of services (in whole or part) , iii.) otherwise restrict the ability to monetise information provided by the recipients, and/or iv.) to remove or disable access to or restrict visibility of the information)
or
– B) with the Digital Service Coordinator (of the territory where the recipient received the service or of the Netherlands) without prejudice to this Regulation’s rules on allocation of competences and to the applicable rules on handling of complaints in accordance with national principles of good administration. The Dutch Digital Service Coordinator being the Autoriteit Consument & Markt (ACM), see https://www.acm.nl/nl/contact/tips-en-meldingen/melden-bij-de-acm, Postbus 16326, 2500 BH Den Haag , phone 070-722200, email acm-post@acm.nl
or
– C) with any of the by the Dutch Digital Service Coordinator (ACM) (to be) appointed out of court dispute settlement procedure (s) (including complaints that have not been resolved by means of the internal complaint-handling system). We point out that verdicts of this out of court dispute settlement are non-binding.
Notwithstanding the aforementioned the Recipient of the Service has the possibility to initiate, at any stage, judicial proceedings at the applicable district court as set out in article 20 Yenlo’s-GTC.
All complaints that Yenlo receives will be registered in Yenlo’s internal complaint register.
Responsible party in relation to this Website (including Web/contact Form and/or Cookies)
The private limited liability company Yenlo International Holding B.V., established at Beechavenue 16, 1119 PT Schiphol-Rijk, the Netherlands (Chamber of Commerce number 28117017) is operationally responsible for the management of this Website, as the sole and independent Data Controller, and therefore the legal (data controlling) entity to be addressed for any complaints or questions, at least with regard to the use and/or functioning of this Website, any Web/contact Form and/or Cookies or the processing of personal data therein.
Disclaimer
The information on this Website respectively provided with the (Digital) Services is for general information purposes only. The information is provided by Yenlo and selected third parties as we strive to keep the information up to date.
In addition to article 1.8 Yenlo’s GTC: Yenlo can change this Privacy Policy and it Terms & Conditions at any time for any reason (for example if we change our website or if the rules regarding privacy and/or cookies change). We therefore recommend that you periodically review this Privacy Policy and our Terms & Conditions. Changes will be communicated via the Website. In case of significant changes made to Privacy Policy or our Yenlo Terms and Conditions, for instance when we modify the rules on information that is permitted on our Service, or other such changes which could directly impact the ability of the Recipients of the service to make use of the service, Yenlo will try as much as possible to also sent a direct mail update for information purpose only to the respective Recipient of the Service. Changes to the Privacy Policy will become effective and apply to the information collected from the date that Yenlo posts the revised Privacy Policy on the Website. Where we are required by applicable data protection laws to obtain your consent to changes regarding the use of your personal information in our updated Privacy Policy, we will do so.
Restriction on the Use of Service (including Monitoring, Content Moderation, Suspension and Suspension of the Service)
Yenlo Security and IT department has the right to Monitor, Moderate Content (if and where Yenlo even has access to any kind of Content) and Restrict the Use of Service in respect of any reasonable suspected illegal (or harmful) content or use in violation of Yenlo’s or its Vendor/Supplier (EULA) (license) tems & conditions (including Code of Conduct. Especially in respect of the examples cases as set as out below:
a. If you remove or alter any copyright or license notices that appear in or on the Software.
b. If you modify/adapt, alter, decompile, decrypt, disassemble, translate, or reverse engineer, create or prepare derivative works of the Software, or attempt to discover or modify in any way the underlying source code of the Software.
c. If you resell, sublicense, transfer, loan, lease, rent, distribute, commercial exploit, permit use or otherwise make available the Software/Services or associated access credentials to any third party.
d. If you (intend to make) the Software available as commercial Software-as-a-Service (to third parties), unless and to the extent authorized by Yenlo and its suppliers.
e. If your use the Services to create or enhance a competitive offering or for any purpose which is competitive to Yenlo or its suppliers,
f. If you perform or fail to perform any other act, intentionally or not, which would result in a misappropriation or infringement of any (intellectual property or privacy) rights of any third party or Yenlo and its supplier intellectual property.
g. If you transmit through the Service any data or information without the legal right to do so.
h. If (there is a reasonable suspicion your use of the Software (or provided Content or information) might) violate any applicable laws in the world, including if perform or failure to perform any other act could result in a non-compliance of any applicable law in the world.
i. If you otherwise engage in fraudulent, offensive or illegal (or harmful) activity (intentionally or not)
j. If so, required by law enforcement or legal process.
k. If you transmit unsolicited bulk or commercial messages or distribute worms, Trojan horses, viruses, corrupted files, harmful or corrupted codes or any similar items.
l. In the event of any other possible (imminent) security risk to Yenlo, its supplier or its customer(s), including any attempt to hack, use or gain unauthorized access to Yenlo’s or to any of its supplier or third-party’s networks or equipment as well any attempt to hack, probe, scan or test the vulnerability of the Service, or a system, account or network of Yenlo or any of Yenlo’s supplier(s), partner(s) or customer(s). Any kind of Pentests and/or load tests and/or any other tests which impact Yenlo’s Service is not allowed without formal upfront approval by Yenlo.
m. If you restrict, inhibit, interfere or attempt to interfere with the ability of any other person, regardless of purpose or intent, to use or enjoy the Services or a user’s network, or cause a performance degradation to any facilities used to provide the Services.
n) any consumption of bandwidth, storage and other resources beyond what has been agreed between Parties, or that otherwise exceed Fair Use Policy
In addition to Article 16 of Yenlo’s GTC: Yenlo has in such example cases as set out above, after a prior notice of default with statement of reasons (on best commercial effort bases), also the right to Suspend or Terminate the Service due to illegal (or harmful) content or use in violation of Yenlo’s or its Vendor/Supplier (EULA) (license) tems & conditions (including Code of Conduct) without Yenlo incurring any liability.
For the right of the Customer to terminate the use of the Service, see article 15 Yenlo’s GTC.
At the moment Yenlo itself does not use Artificial Intelligence or algorithm and any decision is not fully automatic robot made, and we do foresee in human review.
– Rules as set out in article 16 to 18 of the EU Digital Service Act (in respect of Suspension and/or termination of Services due to illegal content or incompatible with T&C’s of service provider (or the EULA’s of its Suppliers) as well how to inform and keep the Recipient of the Service (including notifier) up to date), apply accordingly.
Accuracy
Yenlo makes every effort to ensure that the information on this Website respectively provided with the (Digital) Services is as accurate and up to date as possible. It also strives for good accessibility to the site and of the services it offers electronically. Yenlo reserves the right to change the content of the information on this Website or provided with the Service.
Despite the constant care and attention that Yenlo pays to the composition of the Website or its (Digital) Services, it is possible that the information on the Website or provided with its Services is incomplete or incorrect. The information on the Website or in respect of its (Digital)Services is regularly updated. Any changes can always be made with immediate effect and without any notice. If, nevertheless, there are inaccuracies in the data or if the information is no longer up to date, we regret this. However, Yenlo accepts no liability.
Yenlo does not guarantee that e-mails or other electronic messages sent to it will be received and processed in a timely manner and accepts no liability for the consequences of not receiving or processing them or processing them too late.
It is the responsibility of the counterparty of Yenlo to provide Yenlo with accurate personal information. Except as otherwise set out in this Privacy Policy and to the extent necessary for the processing purposes, Yenlo will take reasonable steps to ensure that personal data is accurate, complete, current and relevant to its intended use.
Unfortunately, it cannot be guaranteed that data distributed on or accessible via the internet is 100% secure. Therefore, although Yenlo tries to protect all personal data, Yenlo cannot guarantee that personal data will be completely secure against misuse by hackers or other criminal or criminal activities, or in the event of a failure of computer hardware, software or a telecommunications network.
Yenlo does not guarantee the security of the information/personal data that is sent to Yenlo via the internet or on systems that are not under the control of Yenlo. Yenlo is not responsible for any loss or damage that the Data Subject, Recipient of the Service, User or third parties may suffer as a result of the loss of confidentiality of such information during its transmission over the Internet or through systems beyond Yenlo’s control.
Intellectual Property
All of the information available on this Website, provided with or through it’s (Digital) Services and its composition (texts, graphic material, logos, icons, videos, software, Feedback, databases, data, etc.) are Yenlo’s intellectual property rights (including copyrights, trademark rights, patents). The Visitor of the Website does not obtain any form of license with regard to that information, except to the extent strictly necessary for viewing the Website online. In particular, the Visitor to the Website is not permitted to copy, reproduce, display, modify, transmit, publish, adapt, provide, distribute, license this Website, transfer, sell, on any medium, by any means, or exploit in any way, either in whole or in part, without further express written permission from Yenlo.
Hyperlinks
Yenlo accepts no responsibility for the content of sites to which or from which reference is made by hyperlink or otherwise.
Viruses
Yenlo does not guarantee that the information, software or references or hyperlinks accessible through this Website or it’s (Digital) Services are free of viruses or similar harmful components.
Limitation of Liability
Article 4 to 6 of the EU Digital Service Act applies accordingly to Yenlo (meaning that an intermediary service provider (mere conduit or caching) and hosting/ cloud provider is NOT liable for the transmitted or storage information provided by the Recipient of the Service (including provision of access to the network), provided certain conditions are met (like the service provider does not initiate transmission and select receiver of transmission, has not modified the information, is not aware of illegal content and act when becomes aware)
Yenlo does not guarantee that the Website respectively it’s (Digital) Services will function without errors or interruptions. Yenlo does not guarantee the proper functioning of the Website and cannot be held liable in any way for the malfunctioning or temporary (un)availability of the Website or for any form of damage, direct or indirect, that would result from access to or use of the Website.
Yenlo makes great efforts to ensure that the information made available on the Website or through its Services is complete, correct, accurate and up to date. Despite these efforts, inaccuracies may occur in the information provided. If the information provided contains inaccuracies or if certain information on or via the Website or (Digital) Service is unavailable, Yenlo will make every effort to rectify this as quickly as possible.
Yenlo is not responsible for any error or omission in the information made available on the Website or through its (Digital) Services and accepts no liability in this respect. The information made available on the Website or provided with or through its (Digital) Services is not intended as a substitute for expert advice. If the visitor / user of the Website respectively Recipient of the Services uses the information provided without verification or further advice, the visitor to the Website respectively Recipient of the Service does so at his own expense and risk.
Yenlo cannot be held liable for direct or indirect damage to the Visitor or User of the Website respectively Recipient of the Service that arises from the use of the information on the Website or the (Digital) Service. Yenlo can at no time to whomever be held liable for any damages resulting from the use of this Website, (Digital) Service or any other activity (particularly as a result of links or hyperlinks), including, without limitation, any loss, interruption of work, equipment, corruption of computer programs or other data or any other goods or rights of the visitor / user of the Website, Recipient of the Service or third parties. Insofar as not explicitly stated otherwise from the previous liability text or from mandatory law follows otherwise, the limitation of liability in Article 9 of Yenlo’s GTC hereby applies mutatis mutandis to personal data and damage related thereto.
Jurisdiction
For the applicable “in court” jurisdiction, reference is made to article 20 of Yenlo’s GTC, implicating that in principle the district court in Amsterdam has jurisdiction, unless and to the extent that from article 20 of Yenlo’s GTC follows otherwise.
