Personal Data Policy

regarding the processing and protection of personal data on the Yasno service

1. General provisions

This policy regarding the processing of personal data (hereinafter - "Policy") is developed in accordance with the Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (United Arab Emirates) and applies to all personal data, which YASNO PORTAL L.L.C, License No.1081093 (hereinafter - "Operator") receives from the subjects of personal data - individuals (hereinafter - "Subject of personal data") in connection with providing them with access to the online platform (software ) "Yasno", located in the Internet at: https://yasno.world (hereinafter - "Service"). The Subject of personal data are both users of the Service and psychologists providing services through the Service (hereinafter "User" and "Psychologist" respectively), as well as other persons using the Service.

1.2 This Policy has been developed in accordance with the current legislation of the UAE on personal data:

  • - Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (United Arab Emirates) (hereinafter - “the Law”), establishing the basic principles and conditions of personal data processing, the rights, duties and responsibilities of participants in relations related to the processing of personal data;
  • - Other laws and regulations.

1.3. The Policy applies to the Personal Data received both before and after the approval of this Policy.

1.4. The Operator has the right to amend this Policy. When changes are made, the header of the Policy indicates the date of the last update of the revision. The new version of the Policy becomes effective as soon as it is posted on the Internet at: https://yasno.world/personaldata, unless otherwise provided by the new version of the Policy. The Operator shall provide unrestricted access for all interested subjects of personal data to the amendments made to the Policy.

1.5. Personal data is processed by the Operator for the following purposes:

  • - Providing access to the functionality of the Service to the Subjects of Personal Data;
  • - Concluding a contract with the Psychologist providing services to the Users on the Service;
  • - provision of services by the Operator under the agreement concluded with the Subject of personal data;
  • - providing the Subjects of personal data with the Service, as well as information about the development and implementation by the Operator of new features of the Service, services or promotions;
  • - Processing and distribution of the summarized and analytical data of the Subjects of personal data, collected with the help of Internet statistics services, serving to collect information about the actions of the Subjects of personal data on the Service, to improve the quality of the Service and its content;
  • - Sending to the Subjects of personal data informational messages by e-mails, instant messengers and sms;
  • - Performing other functions, powers and duties imposed on the Operator by the legislation of the UAE and the subjects of the UAE.

1.6. The Subject of personal data, acting freely, of their own free will and in their own interest, and confirming their capacity, gives their consent to the processing of personal data by the Operator, to the processing of their personal data in accordance with the conditions set forth in this Policy.

Consent
I hereby give my consent to the processing of my personal data, freely, willingly and in my own interest, to the extent enumerated in this Policy, for the purposes set forth in this Policy.

2. Composition of personal data

 

2.1. The list of Personal information, subject to processing and protection, is formed in accordance with the Law. Information constituting the Personal Data is any information relating to a directly or indirectly defined or identifiable individual: the User or the Psychologist.

2.2. In connection with providing access to the Service to the Subject of Personal Data, the Operator processes the following Personal Data:

2.2.1. the User:

  • - surname, first name or pseudonym (at the discretion of the Subject of Personal Data);
  • - age;
  • - telephone number;
  • - e-mail address;
  • - Data on the number of consultations held through the Service;
  • - Subjects of interest for discussion.

2.2.2. the Psychologist:

  • - Surname, first name, patronymic;
  • - Date of birth (date, month, year);
  • - Nationality;
  • - Profile data on social networks;
  • - Phone number;
  • - E-mail address;
  • - Information about education (including retraining programs and/or additional education);
  • - Passport data;
  • - Documents confirming education;
  • - Information about the length of consulting experience;
  • - Information on the number of clients;
  • - Photo.

2.3. The Operator shall ensure that the content and scope of the processed Personal Data is consistent with the stated processing purposes and, if necessary, shall take measures to eliminate their redundancy in relation to the stated processing purposes.

2.4 The Operator does not process special categories of Personal Data relating to race, ethnicity, political views, religious or philosophical beliefs, or intimate life.

2.5 The Operator entrusts the processing of individual Personal Data of the User (surname, name or pseudonym, age) to third parties - Psychologists, who provide the User with services, for the purpose of sending information messages and the proper provision of services.

2.6. The Operator entrusts the processing of the Personal Data of the User (last name, first name or pseudonym, age) to third parties - Psychologists who provide services to the User, for the purpose of sending information messages and proper provision of services.

2.7. The User hereby expresses their consent to the transfer of their personal data to the Psychologists selected by the User on the Service, with whom they will enter into a corresponding agreement.

 

3. Confidentiality of Personal Data

3.1 Information relating to Personal Data is confidential and protected by the law of the UAE.

3.2 The Operator shall not provide or disclose the processed information containing Personal Data to any third party without the written consent of the Subject of Personal Data, except in the cases specified in this Policy.

3.3. Personal data of the Subject of Personal Data may be transferred by the Operator without his consent upon a motivated request - solely to perform the powers and functions imposed by the legislation of the UAE:

  • - to judicial authorities in connection with the administration of justice;
  • - To the state security bodies;
  • - to the prosecution authorities;
  • - to police bodies;
  • - to the investigating authorities;
  • - to other public authorities and organizations in the cases stipulated by regulatory legal acts mandatory for execution.

3.4. Employees and contractors of the Operator, who process Personal Data, shall not disclose the processed Personal Data. The Operator's employees and contractors, who get access to the processed Personal Data, shall be warned about possible disciplinary, administrative, civil or criminal liability in case of violation of norms and requirements of the legislation of the UAE, regulating the rules of processing and protection of Personal Data.

 

4. Procedure and methods of processing of the Personal data

4.1. Processing of the Personal Data by the Operator shall be carried out in the following ways:

  • - non-automated processing of personal data;
  • - Automated processing of personal data with transfer of received information via information and telecommunication networks or without such;
  • - Mixed processing of personal data.

4.2. The list of actions performed by the Operator with Personal Data: collection, systematization, accumulation, storage, clarification (updating, modification), use, distribution (including transfer), compilation, blocking, destruction, as well as any other actions in accordance with applicable laws of the UAE.

4.3. The Subject of personal data decides to provide his/her consent to the processing of personal data in accordance with this Policy and gives it freely, willingly and in his/her own interest.

4.4. The condition for termination of the Personal data processing may be achievement of the Personal Data processing objectives, expiration of the Consent or revocation of the Consent by the Subject of personal data, as well as detection of unlawful processing of the Personal data.

4.5. Consent may be withdrawn by written notice sent to the Operator by registered mail or e-mail: [email protected].

4.6. The Operator shall take or ensure taking the necessary legal, organizational and technical measures to protect Personal Data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of Personal Data, as well as from other unlawful actions in relation to the Personal Data.

4.7. The Consent to processing of Personal Data of the Subject of personal data shall come into force from the date of its acceptance and shall be valid for 5 (five) years from the date of deletion of the personal account, unless a longer period is established by the legislation of the UAE or a legitimate interest of the Operator, and may also be revoked on the basis of a written application of the Subject of Personal Data in an arbitrary form.

4.8. The storage of the Personal Data shall be in a form that makes it possible to identify the Subject of Personal Data for a period no longer than required by the purposes of Personal Data processing, except in cases where the period of storage of Personal Data is established by laws, an agreement to which the Subject of Personal Data is a party, a beneficiary or a guarantor under which the Subject of Personal Data is a beneficiary.

4.9. The Operator shall not disclose information about the specific means and methods used to ensure information security of the Personal Data in order to ensure an adequate level of protection of the Personal Data in accordance with the requirements of the legislation of the UAE.

4.10. If the Subject of Personal Data of the Service has made their Personal Data or part thereof available to the general public, the Operator has the right not to process such Personal Data and is not responsible for them.

4.11. At the same time, the Operator has the right to process and make public the generalized and analytical data of the Subject of personal data in order to analyze, improve, make changes in the Service, as well as place statistical data in the Internet, at conferences, provide analytics to third parties, and the Subject of personal data gives his consent to it.

5. Rights of Personal Data Subjects

 

5.1. The Subject of personal data decides to provide his Personal data and gives his consent to their processing freely, willingly and in his own interest.

5.2. The Subject of personal data has the right to demand from the Operator clarification of his Personal data, their blocking or destruction if Personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as to take statutory measures to protect their rights.

5.3. The Subject of personal data has the right to request a revocation of their consent to the processing of the Personal data. In this case, the services of the Service can not be provided to the Subject of personal data.

5.4. In order to exercise the aforementioned rights, the Subject of personal data has the right to apply to the Operator with a corresponding request. In order to fulfill the request, the Operator has the right to request additional information.

5.5. Information must be provided to the Subject of Personal Data by the Operator in an accessible form, and it must not contain Personal Data relating to other subjects of Personal Data, unless there are legitimate grounds for disclosure of such Personal Data.

5.6. The Subject of Personal Data has the right to receive information regarding the processing of his or her Personal Data, including information containing:

  • - confirmation of the fact of processing of Personal Data by the Operator;
  • - confirmation of the fact of processing of Personal Data by the Operator;
  • - The purposes and methods of processing of Personal Data used by the Operator;
  • - Name and location of the Operator, information about persons who have access to Personal Data or to whom Personal Data may be disclosed on the basis of a contract with the Operator or on the basis of federal law;
  • - Processed Personal Data pertaining to the respective Subject of Personal Data, their source, unless otherwise provided by the Law;
  • - terms of processing of Personal Data, including their retention period;
  • - Procedure for exercising by the Subject of Personal Data of their rights under the Law;
  • - Information about the performed or expected cross-border transfer of data;
  • - Name or full name and address of the person processing the Personal Data by order of the Operator, if the processing has been or will be assigned to such person;
  • - Other information as provided by the Law or other laws.

5.7. The right of the Subject of Personal Data to access his Personal Data may be restricted by certain regulatory and legal acts of the UAE.

5.8. Persons, who provided the Operator with false information about themselves, or information about another subject of personal data without the consent of the latter, shall be liable in accordance with the legislation of the UAE.

6. Security of Personal Data

6.1. The Operator shall take the necessary technical and organizational information security measures to protect the Personal Data from unauthorized access, modification, disclosure or destruction, through internal audits of data collection, storage and processing processes and security measures, and implementation of physical data security measures to prevent unauthorized access to the Personal Data.

 

7. Measures to ensure protection of Personal Data

7.1. the Operator shall take the following organizational and technical measures aimed at ensuring the established level of protection of personal data when processing them in the Operator's information systems:

  • - The Operator is the person responsible for ensuring the security of personal data in the information systems of the Service;
  • - Establishes the security regime of the premises where information systems are located, preventing uncontrolled entry or stay of unauthorized persons in the premises;
  • - ensures security of the Personal data carriers;
  • - Ensures use of information security means in the field of information security, in case when application of such means is necessary for neutralization of actual threats;
  • - Provides backup and restoration of the Personal data, operability of technical means and software, information protection means in personal data information systems, modified or destroyed as a result of unauthorized access thereto;
  • - Ensures observance of conditions ensuring safety of the Personal Data and excluding unauthorized access to such data;
  • - Detecting facts of unauthorized access to the Personal Data and taking measures;
  • - Performs other measures established in the field of protection of Personal Data.
  

8. Cookies policy

8.1. By continuing to work at the site I give my consent to the Operator for automatic processing of my personal data (cookies, information on actions of the user on the site, information on the user's equipment, date and time of the session), including with use of metric programs, with performance of actions: collection, recording, systematization, accumulation, storage, specification (updating, change), extraction, use, depersonalization, blocking, removal, destruction, transfer (provision, access), including cross-border, by providing service Cookies are used on the Service to improve the quality of interaction of visitors with the Service, allowing the Service to remember visitors during their first or repeat visits. In some cases, cookies are used to personalize information on the Service based on location.
This consent is effective from the time it is given and for the entire period of use of the Service. In case of refusal to process personal data by metric programs I am informed of the need to stop using the Service or to disable cookies in the settings of the browser.

8.2. The Operator uses cookies which are necessary for movement of visitors on Service or work of certain basic functions. Cookies are used to improve the functionality of the Service, for example by saving the visitor's settings. The Operator also uses cookies to improve the operation of the Service in order to improve the quality of visitors' interaction with the Service. The Operator does not use cookies to collect personally identifiable information.
Data automatically transmitted to the Service during their use by the software installed on the Subject of Personal Data's device, including information about the location; OS type and version; browser type and version; device type and its screen resolution; source where the user came to the site/application; from which site or through which advertisement; OS and browser language; what pages are opened and what buttons are pressed; IP address.

8.3. The following cookies may be used while visiting the Service:

9. Final Provisions

9.1. After registration on the Service, the Subject of personal data may receive periodic newsletters to the registered email address and/or cell phone number, as well as automatic payment confirmation and service notifications.

9.2. The Subject of personal data may receive newsletters to the e-mail address and/or cell phone number. You can unsubscribe from receiving emails and/or SMS at any time by using the special link which is placed at the end of each email, or by writing to us at [email protected] with the subject line "DISSUBSCRIBE" - and thereby stop sending emails to your email address.

9.3. The operator takes reasonable steps to maintain the accuracy and relevance of available Personal Data, as well as to delete Personal Data if it is outdated, inaccurate or unnecessary, or if the purposes of its processing have been achieved.

9.4. Personal Data subjects are responsible for providing the Operator with accurate information, as well as for updating the provided data in a timely manner in case of any changes.

9.5. In cases where the Subject of personal data wants to know what personal data about the subject the Operator has, or to supplement, correct or delete any incomplete, inaccurate or outdated Personal data, or wants to stop processing of their Personal data by the Operator, or has other legal requirements, the subject of personal data may, in due course and in accordance with applicable law, exercise such right by contacting the Operator at e-mail address [email protected].

9.6. At the same time in some cases (for example if the Subject of personal data wants to delete his personal data or stop its processing) such a request via the Service or sending an inquiry to the Operator's e-mail may also mean that the Operator can no longer provide access to the Service to the Subject of personal data, and the contract with the Subject of personal data will be terminated.

9.7. In order to fulfill the requests of the Subject of personal data, the Operator may require to establish the identity of the Subject of personal data and request additional information confirming participation in the relationship with the Operator, or information otherwise confirming the fact of processing of personal data by the Operator. In addition, applicable legislation of the UAE may impose restrictions and other conditions relating to the aforementioned rights of the Subject of Personal Data.

10. the Operator's details: