Privacy Policy

Heading

CONTACT FORM

CLARIFICATION POLICY REGARDING PERSONAL DATA PROTECTION

We, as YellowX OU owners of the Brand Zillion Pitches, (“Zillion”),would like to inform you in accordance with the 10th Article of Personal DataProtection Law numbered 6698 (“PDPL”),about our identity, purposes of processing your data, to whom and why we transferyour data, our legal bases, our methods of processing and your rights regardingyour filling out the contact form (“Form”) through Websites with domainnames, https://www.zillionpitches.com  and https://www.zillionpitch.co as well as our ZillionApp. (“Websites”).

·       DataController: YellowX OU residing at Tammsaare Business Center A. H. Tammsaare tee 47Tallinn, 11316 Harju maakond Estonia

·       DataController Representative: Ozan Sönmez

Your personal data are;

·       being in conformity with the law and good faith,

·       being accurate and if necessary - up to date,

·       being processed for specified, explicit and legitimatepurposes,

·       being relevant, limited and proportionate to thepurposes for which data are processed,

·       being stored only for the time designated by relevantlegislation or necessitated by the purpose for which data are collected.

 

The PersonalData Types Processed by YellowX :

Identifying Data:

·       Name and Surname data of the person wishing to contact YellowX is processedautomatically by filling out the Form on the Websites. Name Surname datais being processed with the purpose of identifying the data subject who wishesto contact YellowX and with the legal basis of that it is mandatory for ourlegitimate interest to process the relevant data in accordance with the article5/2-f of PDPL. The data in question is shared with Typeform S.L. in order forus to collect your relevant data through the Form.

 

·       Age data of the person wishing to contact YellowX is processedautomatically, in cases where he/she is not a minor, by filling out the Form onthe Websites. Age data is being processed with the purpose ofidentifying the data subject who wishes to contact YellowX and with the legalbasis of that it is mandatory for our legitimate interest to process therelevant data in accordance with the article 5/2-f of PDPL. The data inquestion is shared with Typeform S.L. or other 3rd partyapplications, in order for us to collect your relevant data through the Form.

 

Contact Data:

·       Email Address data of theperson wishingto contact YellowX isprocessed automatically by filling out the Form on the Websites. Email Address data is beingprocessed with the purpose of communicating the data subject who wishing tocontact YellowX and with the legal basis of that it is mandatory for ourlegitimate interest to process the relevant data in order to respond to therequests and/or questions of the data subject to us and to provide him/her withinformation about the details of the service we offer in accordance witharticle 5/2-f of PDPL. The data in question is shared with TypeformS.L. in order for us to collect your relevant data through the Form.

 

·       Email Address data of the persons (friends)* tobe invited to the Websites is processed automatically byfilling out the Form on the Websites.Email Address data is being processed with the purpose of communicatingthe data subject’s friends to be invited to contact YellowXand with the legal basis of that it ismandatory for our legitimate interest to process the relevant data inaccordance with the article 5/2-f of PDPL.Thedata in question is shared with Typeform S.L. in order for us to collect yourrelevant data through the Form.

 

Startup Data:

·       Startup Founders Name Surname dataof the person wishing to contact YellowX is processed automatically by fillingout the Form on the Websites. Since YellowX offers pitching practice educationand software programs for founders of all ages, Founders Data is beingprocessed with the purpose of responding to the requests and/or questions ofthe data subject in connection with its startups status. The relevant data isbeing processed with the legal basis of that it is mandatory for our legitimateinterest to process the relevant data in order to provide more clear andprecise answers, information, or details to the data subject in accordance witharticle 5/2-f of PDPL. The data in question is shared with TypeformS.L. and other third party service providers in order for us to collect yourrelevant data through the Form.

 

·       Startup Name, Field of Activity, Classification and Details data of the person wishing to contactYellowX is processed automatically, byfilling out the Form on the Websites. Since YellowX offers pitching practice educationand software programs for founders of all ages, Startup Background and Details data is being processed with the purpose of responding to therequests and/or questions of the data subject in connection with its startupsstatus. The relevant data is being processed with the legal basis of that it ismandatory for our legitimate interest to process the relevant data in order toprovide more clear and precise answers, information, or details to the datasubject in accordance with article 5/2-f of PDPL. Thedata in question is shared with Typeform S.L. in order for us to collect yourrelevant data through the Form.

 

Other

·       Survey Question’s Answers dataof the founder wishing to contact YellowX is processed automatically by fillingout the Form on the Websites. Since YellowX offers pitching practice educationand software programs for founders of all ages and (data subjects), Survey Question’s Answers data is being processed with the purpose of providingservices to the data subject in connection with their level. The relevant datais being processed with the legal basis of that it is mandatory for ourlegitimate interest to process the relevant data in order to provide more clearand precise answers, information, or details to the data subject about ourservices in accordance with article 5/2-f of PDPL. The data in question isshared with Typeform S.L. in order for us to collect your relevant data throughthe Form.

* Withregard to Email Address data of the persons (friends) to be invited thatare transferred to us through the Form, the person requesting to contact is aData Controller and obliged to inform above-mentioned data subject inaccordance with the 10th Article of PDPL. About the data transferred to us, wehave an obligation to inform the data subject in a reasonable period of timeafter collecting personal data in accordance with the 10th Article of PDPL and6th Article (a) of Communique On Principles And Procedures To Be Followed InFulfillment Of The Obligation To Inform.

 

*All types of personal data included in this Clarification Policy are transferred to Websites server andinfrastructure services provider.This data transfer arises from all personal datatypes that are in need to be hosted in a server and servers located in relevant provider and thus does not require an active data transfer but occurring in the nature of hosting services.

 

Your rights may be summarized as follows:

You have the right to learn

●       whether or not yourpersonal data is being processed,

●       the purpose of theprocessing and

●       to whom yourpersonal data is transferred domestically and internationally.

You have the right to request

●       that your personaldata should be processed in accordance with the purpose,

●       rectification ofpersonal data if processed incompletely or inaccurately,

●       destruction upondisappearance of reasons which require the process,

●       notification of therectification or destruction to the third parties to whom personal data hasbeen transferred and

●       compensation forthe damage arising from the unlawful processing.

You have the right to object

●       to the processing,exclusively by automatic means of your personal data, which leads to anunfavorable consequence for you.

 

You may send us your request onusing your above-mentioned rights, together with documents providing youridentity and the scope of your request through below-mentioned manners:

·       Sending an electronically signed or unsigned e-mail to contact@yellowx.co

·       Delivering by hand, by notary or by certifiedmail to YellowX OU residing at Tammsaare Business Center A. H. Tammsaare tee 47 Tallinn,11316 Harju maakond Estonia.

We undertake to respond yourrequest as soon as possible but not more than 30 (thirty) days, and without anycharge, as long as there is no transaction cost.

 

1.      Preamble

We, as Zillion (“Zillion”) a fully owned brand of YellowX OU (“YellowX”),give utmost importance to the privacy of our Visitors and Applicants duringtheir use of our websites with brand domain names https://www.zillionpitches.com and https://www.zillionpitch.co (“Websites”) and/or itssubdomains regardless of their country of access.

2.      Purpose of This Policy

This Privacy Policy (“Policy”)is prepared with a privacy-prioritizing attitude in order to provide detailedinformation to Visitors and Applicants regarding the identity of YellowX as adata controller; data processing and its legal bases, reasons; rights ofVisitors and Applicants (collectively “DataSubject”), which can be exercised against YellowX .

This Policy shall be read by Visitors and Applicants regardless of theirresidency or location of access. The personal information subject to processingmay differ from one action to another such as accessing to Website, requestinga demo, requesting to join a quiz challenge, or contacting us; and YellowX hereininforms you about how your personal data is handled in different cases.

3.      Scope of This Policy

a.      In Terms of Legislation

Since YellowX isan Estonia based company but has numerous Visitors and Applicants fromdifferent countries; it is hard to determine which legislation should beapplied to its activities and business. Therefore, YellowX intends to reflectits compliance with different legislations about privacy and data protection.For this reason, YellowX shows considerable effort to act in accordance withGeneral Data Protection Regulation (“GDPR”),Turkish Personal Data Protection Law No. 6698 (“PDPL”), CaliforniaConsumer Privacy Act (“CCPA”), andother applicable data protection regulations.

b.     In Terms of Related Person

This Policyincludes different Data Subjects with various motives such as somehow accessingand making a demo and/or access plan request, request to join a quiz challenge,in relation with the services provided by Zillion through the onlineapplication forms (“Form”). Even though Data Subject may bereferred as Visitor and Applicant according to their intention for using the Website,they will be covered in this Policy.

c.      In Terms of Data

Informationthat makes it possible for related person to be identified directly orindirectly by any other person (“PersonalData”) is in the scope of this Policy. Accordingly, it can be safely saidthat confidential information, which cannot be considered as Personal Data, isexcluded from this Policy.

4.     Identity of YellowX as a Data Controller

For any and all data processing that occurs through accessing Website and benefiting from theservices provided through the Website, YellowX OU, a registered company havingits address at Tammsaare Business Center A. H. Tammsaare tee 47 Tallinn, 11316Harju Maakond Estonia is a datacontroller (“Controller”).  

5.     Occasions for Personal Data Processing

YellowX processes personal data during includingwithout limitation below-mentioned situations:

·       accessing to the Website,

·       contacting to Zillionthrough Form,

·       making a request tojoin the quiz challenge through Form,

·       making a demo and/oraccess plan request through the Form.

6.     Principles for Processing Personal Data

YellowX considers below-mentioned principles whileProcessing Personal Data:

·       Processing PersonalData lawfully, fairly and in a transparent manner in relation to the DataSubject,

·       Processing PersonalData accurately and where necessary, kept up to date,

·       Processing PersonalData for specific, explicit, and legitimate purposes,

·       Processing PersonalData relevantly, limitedly, and proportionately to the purposes for which theyare processed,

·       Processing PersonalData in a manner that ensures appropriate security of the Personal Data andkept in a form which allows identification of Data Subjects for no longer thanit is necessary for the processing reasons.

7.     Processed Personal Data

Personal Data Collected by Us

Name-Surname

Cookie

Age

IP Address

E-Mail Address

Device &  Browser Type

Phone Number

Usage Information

Current Location of  Residency

Survey Questions’  Answers

Educational  Background

Occupation

Startup Background

Startups Name

Startups Details

Startups Field of  Activity

8.     Reasons and Legal Bases for Processing Personal Data

Personal Data given to or collected by us shall only be processed whennecessary for a reasonable cause and when there is a legal basis forprocessing. Reasons and legal bases of processing are listed limitedly in thisPolicy and this Policy will be updated if a reason or a legal basis change.

a.     Name-Surname

Processing Reasons-Legal Bases

Identifying the person wishing to contact YellowX - Legitimate interest

Identifying the person requesting a demo/an access plan - Legitimate interest

Identifying the person wishing to join the  quiz challenge - Legitimate interest

b.    Age

Identifying the person wishing to contact YellowX - Legitimate interest

Identifying the person wishing to join the  quiz challenge - Legitimate interest

c.     E-Mail Address

Communicating with the person regarding his/her requests and/or  questions - Legitimate interest

Contacting about demo/access plan request - Legitimate interest

Contacting about quiz challenge - Legitimate interest

d.    Phone Number

Contacting about demo/access plan request to Zillion - Legitimate interest

e.     Current Location of Residency

Evaluating the demo request and eligibility for its attendance to YellowX  - Legitimate interest

Evaluating the demo request of the parent and eligibility of the high  school children for its attendance to Zillion Academy - Legitimate interest

f.      Startup Background

Responding to the requests and/or questions of the person in connection  with its startup status - Legitimate interest

Contacting about demo/access plan request - Legitimate interest

Preparing proper offers for the person wishing to join the free  Demo - Legitimate interest

g.     Startups Name

Identifying the startup wishing to contact YellowX - Legitimate interest

Identifying the startup requesting a demo/an access plan - Legitimate interest

h.    Occupation

Evaluating the demo/access plan request - Legitimate interest

i.      Startups Field of Activity

Evaluating the demo/access plan request - Legitimate interest

Listing and Sorting the Startup to   provide customized offers - Legitimate interest

j.      Startups Details

Evaluating the demo/access plan request - Legitimate interest

k.     Cookie

Improving the Website - Legitimate interest

l.      IP Address

Complying with legal obligation - Legal obligation

m.   Device & Browser Type

Improving the Website - Legitimate interest

n.     Usage Information

Improving the Website - Legitimate interest

o.     Survey Questions’s Answers

Preparing proper questions for the person wishing to join the program - Legitimate interest

Improving the Website - Legitimate interest

9.     Rights of Data Subjects

Data Subjects are endowed with some rights to ensure their Personal Datato be processed on a lawful basis. Website is designed in compliance with thePrivacy by Design and Data Protection by Design principles. Therefore, alongwith the below-mentioned rights, Data Subjects have a right to opt-out from theWebsite via an e-mail, which ends up with their Application data to be deleted.

a.      Right to be informed, by which the Data Subject may requestinformation about their Personal Data being processed by YellowX.

b.     Right of access, by which the Data Subject may request tolearn their Personal Data being processed by YellowX.

c.      Right of rectification, by which the Data Subject may request YellowXto correct or complete their Personal Data.

d.     Right to restrict processing, by which the Data Subject mayrequest to limit the way their Personal Data is used.

e.      Right to erasure, by which the Data Subject may request tohave their Personal Data erased.

f.       Right to data portability, by which the Data Subject may request to receive their Personal Data in a machine-readable format and/orrequest YellowX to transfer their Personal Data to another controller.

g.      Right to object, by which the Data Subject may request YellowX to stop processing their Personal Data.

h.     Rights in relation to automated decision-making, by which the Data Subject mayrequest YellowX to stop processing their personal data in cases where PersonalData is being processed via automated decision-making.

i. Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by Stripe. You may find their privacy notice link(s) here: https/stripe.com/privacy

10.  Transfer of Personal Data

YellowX transfers Personal Data to third parties only when there is an explicit and informed consent from the Data Subject except for the below-mentioned cases, which havetheir own legal bases for the transfer:

a.      Law Enforcement and Judiciary Authorities: YellowX may be obliged to disclose Personal Data when required to do soby law, including but not limited to legal claims, legal investigations, lawfulrequests, or legal proceedings.

b.     Server, Infrastructure Services & Form Service Providers (TypeformS.L.) : Name-Surname, Age, E-Mail Address, PhoneNumber, Number of Children, Current Location of Residency, Occupation, StartupBackground, Startups Name, Startups Details, Startups Field of Activity, SurveyQuestions’ Answers data may be transferred to the company providing server andinfrastructure services for Website and the Form.

11.  Period of Retention

YellowX storesPersonal Data in view of Data Minimization Principle, which necessitates PersonalData to be kept only for the required period. Required period is assignedconsidering the nature of the Personal Data, the potential risks of a PersonalData breach, processing reasons, and whether or not such reasons can beachieved in a different manner.

12.  Children’s Privacy

You should always check with your parents or guardians beforegiving out any information about you, especially before entering information onWebsite.

Below we summarize potential instances of collection ofPersonal Data where our services are directed at children between 13 and 18. Wealso outline how and when we will provide parental notice and/or seek parentalconsent.

In any instance that we collect Personal Data from a child,we will retain that information only so long as reasonably necessary to fulfillthe activity requested or allow you to continue to participate in the activity,and to ensure the security of our users and our services, or as required bylaw.

In the event we discover we have collected Personal Data fromor about a child in a manner inconsistent with legal requirements, we willeither delete the information or immediately seek the parent’s consent for thatcollection.

The Personal Data that we collect about children between 13and 18 generally falls within two categories: (a) information the parent provideto us, and (b) information we collect automatically when the child use oraccess our Website.

We do not aim any of our products or services directly atchildren under the age of 13 (a “Minor”). However we may offer servicesaiming high school students who are between 13 and18.

If we acknowledgethat any Personal Data processed by us, belongs to a Minor we shall take theappropriate measures to delete such Personal Data.

 

13.  Methods of Securing Personal Data

Appropriate technical and organizational measures are enacted to ensurethe safety, protection and the encryption of the Personal Data in order toprevent any Personal Data breach such that may be caused by accidental orunauthorized destruction, loss, theft or; unauthorized use, alteration anddisclosure.

In this context, YellowX ;

a.     Sign non-disclosureagreements with parties who have limited or unlimited access to Personal Data.

b.    Organize awarenesstrainings about data protection inside its organization.

c.     Entitles its employeeswith limited authorization according to their work line.

d.    Transfer Personal Dataon a ‘need-to-know’ basis.

e.     Process and storepersonal data on safely secured and encrypted cloud servers.

14.  Contact Information of YellowX

Data Subjects may contact YellowX in case of having questions,comments, or feedback via contact@yellowx.co

1.      Preamble

We, as Zillion (“Zillion”) a fully owned brand of YellowX OU (“YellowX”),give utmost importance to the privacy of our Visitors and Applicants duringtheir use of our websites with brand domain names https://www.zillionpitches.com and https://www.zillionpitch.co (“Websites”) and/or itssubdomains regardless of their country of access.

2.      Purpose of This Policy

This Privacy Policy (“Policy”)is prepared with a privacy-prioritizing attitude in order to provide detailedinformation to Visitors and Applicants regarding the identity of YellowX as adata controller; data processing and its legal bases, reasons; rights ofVisitors and Applicants (collectively “DataSubject”), which can be exercised against YellowX .

This Policy shall be read by Visitors and Applicants regardless of theirresidency or location of access. The personal information subject to processingmay differ from one action to another such as accessing to Website, requestinga demo, requesting to join a quiz challenge, or contacting us; and YellowX hereininforms you about how your personal data is handled in different cases.

3.      Scope of This Policy

a.      In Terms of Legislation

Since YellowX isan Estonia based company but has numerous Visitors and Applicants fromdifferent countries; it is hard to determine which legislation should beapplied to its activities and business. Therefore, YellowX intends to reflectits compliance with different legislations about privacy and data protection.For this reason, YellowX shows considerable effort to act in accordance withGeneral Data Protection Regulation (“GDPR”),Turkish Personal Data Protection Law No. 6698 (“PDPL”), CaliforniaConsumer Privacy Act (“CCPA”), andother applicable data protection regulations.

b.     In Terms of Related Person

This Policyincludes different Data Subjects with various motives such as somehow accessingand making a demo and/or access plan request, request to join a quiz challenge,in relation with the services provided by Zillion through the onlineapplication forms (“Form”). Even though Data Subject may bereferred as Visitor and Applicant according to their intention for using the Website,they will be covered in this Policy.

c.      In Terms of Data

Informationthat makes it possible for related person to be identified directly orindirectly by any other person (“PersonalData”) is in the scope of this Policy. Accordingly, it can be safely saidthat confidential information, which cannot be considered as Personal Data, isexcluded from this Policy.

4.     Identity of YellowX as a Data Controller

For any and all data processing that occurs through accessing Website and benefiting from theservices provided through the Website, YellowX OU, a registered company havingits address at Tammsaare Business Center A. H. Tammsaare tee 47 Tallinn, 11316Harju Maakond Estonia is a datacontroller (“Controller”).  

5.     Occasions for Personal Data Processing

YellowX processes personal data during includingwithout limitation below-mentioned situations:

·       accessing to the Website,

·       contacting to Zillionthrough Form,

·       making a request tojoin the quiz challenge through Form,

·       making a demo and/oraccess plan request through the Form.

6.     Principles for Processing Personal Data

YellowX considers below-mentioned principles whileProcessing Personal Data:

·       Processing PersonalData lawfully, fairly and in a transparent manner in relation to the DataSubject,

·       Processing PersonalData accurately and where necessary, kept up to date,

·       Processing PersonalData for specific, explicit, and legitimate purposes,

·       Processing PersonalData relevantly, limitedly, and proportionately to the purposes for which theyare processed,

·       Processing PersonalData in a manner that ensures appropriate security of the Personal Data andkept in a form which allows identification of Data Subjects for no longer thanit is necessary for the processing reasons.

7.     Processed Personal Data

Personal Data Collected by Us

Name-Surname

Cookie

Age

IP Address

E-Mail Address

Device &  Browser Type

Phone Number

Usage Information

Current Location of  Residency

Survey Questions’  Answers

Educational  Background

Occupation

Startup Background

Startups Name

Startups Details

Startups Field of  Activity

8.     Reasons and Legal Bases for Processing Personal Data

Personal Data given to or collected by us shall only be processed whennecessary for a reasonable cause and when there is a legal basis forprocessing. Reasons and legal bases of processing are listed limitedly in thisPolicy and this Policy will be updated if a reason or a legal basis change.

a.     Name-Surname

Processing Reasons-Legal Bases

Identifying the person wishing to contact YellowX - Legitimate interest

Identifying the person requesting a demo/an access plan - Legitimate interest

Identifying the person wishing to join the  quiz challenge - Legitimate interest

b.    Age

Identifying the person wishing to contact YellowX - Legitimate interest

Identifying the person wishing to join the  quiz challenge - Legitimate interest

c.     E-Mail Address

Communicating with the person regarding his/her requests and/or  questions - Legitimate interest

Contacting about demo/access plan request - Legitimate interest

Contacting about quiz challenge - Legitimate interest

d.    Phone Number

Contacting about demo/access plan request to Zillion - Legitimate interest

e.     Current Location of Residency

Evaluating the demo request and eligibility for its attendance to YellowX  - Legitimate interest

Evaluating the demo request of the parent and eligibility of the high  school children for its attendance to Zillion Academy - Legitimate interest

f.      Startup Background

Responding to the requests and/or questions of the person in connection  with its startup status - Legitimate interest

Contacting about demo/access plan request - Legitimate interest

Preparing proper offers for the person wishing to join the free  Demo - Legitimate interest

g.     Startups Name

Identifying the startup wishing to contact YellowX - Legitimate interest

Identifying the startup requesting a demo/an access plan - Legitimate interest

h.    Occupation

Evaluating the demo/access plan request - Legitimate interest

i.      Startups Field of Activity

Evaluating the demo/access plan request - Legitimate interest

Listing and Sorting the Startup to   provide customized offers - Legitimate interest

j.      Startups Details

Evaluating the demo/access plan request - Legitimate interest

k.     Cookie

Improving the Website - Legitimate interest

l.      IP Address

Complying with legal obligation - Legal obligation

m.   Device & Browser Type

Improving the Website - Legitimate interest

n.     Usage Information

Improving the Website - Legitimate interest

o.     Survey Questions’s Answers

Preparing proper questions for the person wishing to join the program - Legitimate interest

Improving the Website - Legitimate interest

9.     Rights of Data Subjects

Data Subjects are endowed with some rights to ensure their Personal Datato be processed on a lawful basis. Website is designed in compliance with thePrivacy by Design and Data Protection by Design principles. Therefore, alongwith the below-mentioned rights, Data Subjects have a right to opt-out from theWebsite via an e-mail, which ends up with their Application data to be deleted.

a.      Right to be informed, by which the Data Subject may requestinformation about their Personal Data being processed by YellowX.

b.     Right of access, by which the Data Subject may request tolearn their Personal Data being processed by YellowX.

c.      Right of rectification, by which the Data Subject may request YellowXto correct or complete their Personal Data.

d.     Right to restrict processing, by which the Data Subject mayrequest to limit the way their Personal Data is used.

e.      Right to erasure, by which the Data Subject may request tohave their Personal Data erased.

f.       Right to data portability, by which the Data Subject mayrequest to receive their Personal Data in a machine-readable format and/orrequest YellowX to transfer their Personal Data to another controller.

g.      Right to object, by which the Data Subject may request YellowXto stop processing their Personal Data.

h.     Rights in relation to automated decision-making, by which the Data Subject mayrequest YellowX to stop processing their personal data in cases where PersonalData is being processed via automated decision-making.

10.  Transfer of Personal Data

YellowX transfers Personal Data to third parties only when there is an explicit and informed consent from the Data Subject except for the below-mentioned cases, which havetheir own legal bases for the transfer:

a.      Law Enforcement and Judiciary Authorities: YellowX may be obliged to disclose Personal Data when required to do soby law, including but not limited to legal claims, legal investigations, lawfulrequests, or legal proceedings.

b.     Server, Infrastructure Services & Form Service Providers (TypeformS.L.) : Name-Surname, Age, E-Mail Address, PhoneNumber, Number of Children, Current Location of Residency, Occupation, StartupBackground, Startups Name, Startups Details, Startups Field of Activity, SurveyQuestions’ Answers data may be transferred to the company providing server andinfrastructure services for Website and the Form.

11.  Period of Retention

YellowX storesPersonal Data in view of Data Minimization Principle, which necessitates PersonalData to be kept only for the required period. Required period is assignedconsidering the nature of the Personal Data, the potential risks of a PersonalData breach, processing reasons, and whether or not such reasons can beachieved in a different manner.

12.  Children’s Privacy

You should always check with your parents or guardians beforegiving out any information about you, especially before entering information onWebsite.

Below we summarize potential instances of collection ofPersonal Data where our services are directed at children between 13 and 18. Wealso outline how and when we will provide parental notice and/or seek parentalconsent.

In any instance that we collect Personal Data from a child,we will retain that information only so long as reasonably necessary to fulfillthe activity requested or allow you to continue to participate in the activity,and to ensure the security of our users and our services, or as required bylaw.

In the event we discover we have collected Personal Data fromor about a child in a manner inconsistent with legal requirements, we willeither delete the information or immediately seek the parent’s consent for thatcollection.

The Personal Data that we collect about children between 13and 18 generally falls within two categories: (a) information the parent provideto us, and (b) information we collect automatically when the child use oraccess our Website.

We do not aim any of our products or services directly atchildren under the age of 13 (a “Minor”). However we may offer servicesaiming high school students who are between 13 and18.

If we acknowledgethat any Personal Data processed by us, belongs to a Minor we shall take theappropriate measures to delete such Personal Data.

 

13.  Methods of Securing Personal Data

Appropriate technical and organizational measures are enacted to ensurethe safety, protection and the encryption of the Personal Data in order toprevent any Personal Data breach such that may be caused by accidental orunauthorized destruction, loss, theft or; unauthorized use, alteration anddisclosure.

In this context, YellowX ;

a.     Sign non-disclosureagreements with parties who have limited or unlimited access to Personal Data.

b.    Organize awarenesstrainings about data protection inside its organization.

c.     Entitles its employeeswith limited authorization according to their work line.

d.    Transfer Personal Dataon a ‘need-to-know’ basis.

e.     Process and storepersonal data on safely secured and encrypted cloud servers.

14.  Contact Information of YellowX

Data Subjects may contact YellowX in case of having questions,comments, or feedback via contact@yellowx.co

1.      Preamble

We, as Zillion (“Zillion”) a fully owned brand of YellowX OU (“YellowX”),give utmost importance to the privacy of our Visitors and Applicants duringtheir use of our websites with brand domain names https://www.zillionpitches.com and https://www.zillionpitch.co (“Websites”) and/or itssubdomains regardless of their country of access.

2.      Purpose of This Policy

This Privacy Policy (“Policy”)is prepared with a privacy-prioritizing attitude in order to provide detailedinformation to Visitors and Applicants regarding the identity of YellowX as adata controller; data processing and its legal bases, reasons; rights ofVisitors and Applicants (collectively “DataSubject”), which can be exercised against YellowX .

This Policy shall be read by Visitors and Applicants regardless of theirresidency or location of access. The personal information subject to processingmay differ from one action to another such as accessing to Website, requestinga demo, requesting to join a quiz challenge, or contacting us; and YellowX hereininforms you about how your personal data is handled in different cases.

3.      Scope of This Policy

a.      In Terms of Legislation

Since YellowX isan Estonia based company but has numerous Visitors and Applicants fromdifferent countries; it is hard to determine which legislation should beapplied to its activities and business. Therefore, YellowX intends to reflectits compliance with different legislations about privacy and data protection.For this reason, YellowX shows considerable effort to act in accordance withGeneral Data Protection Regulation (“GDPR”),Turkish Personal Data Protection Law No. 6698 (“PDPL”), CaliforniaConsumer Privacy Act (“CCPA”), andother applicable data protection regulations.

b.     In Terms of Related Person

This Policyincludes different Data Subjects with various motives such as somehow accessingand making a demo and/or access plan request, request to join a quiz challenge,in relation with the services provided by Zillion through the onlineapplication forms (“Form”). Even though Data Subject may bereferred as Visitor and Applicant according to their intention for using the Website,they will be covered in this Policy.

c.      In Terms of Data

Informationthat makes it possible for related person to be identified directly orindirectly by any other person (“PersonalData”) is in the scope of this Policy. Accordingly, it can be safely saidthat confidential information, which cannot be considered as Personal Data, isexcluded from this Policy.

4.     Identity of YellowX as a Data Controller

For any and all data processing that occurs through accessing Website and benefiting from theservices provided through the Website, YellowX OU, a registered company havingits address at Tammsaare Business Center A. H. Tammsaare tee 47 Tallinn, 11316Harju Maakond Estonia is a datacontroller (“Controller”).  

5.     Occasions for Personal Data Processing

YellowX processes personal data during includingwithout limitation below-mentioned situations:

·       accessing to the Website,

·       contacting to Zillionthrough Form,

·       making a request tojoin the quiz challenge through Form,

·       making a demo and/oraccess plan request through the Form.

6.     Principles for Processing Personal Data

YellowX considers below-mentioned principles whileProcessing Personal Data:

·       Processing PersonalData lawfully, fairly and in a transparent manner in relation to the DataSubject,

·       Processing PersonalData accurately and where necessary, kept up to date,

·       Processing PersonalData for specific, explicit, and legitimate purposes,

·       Processing PersonalData relevantly, limitedly, and proportionately to the purposes for which theyare processed,

·       Processing PersonalData in a manner that ensures appropriate security of the Personal Data andkept in a form which allows identification of Data Subjects for no longer thanit is necessary for the processing reasons.

7.     Processed Personal Data

Personal Data Collected by Us

Name-Surname

Cookie

Age

IP Address

E-Mail Address

Device &  Browser Type

Phone Number

Usage Information

Current Location of  Residency

Survey Questions’  Answers

Educational  Background

Occupation

Startup Background

Startups Name

Startups Details

Startups Field of  Activity

8.     Reasons and Legal Bases for Processing Personal Data

Personal Data given to or collected by us shall only be processed whennecessary for a reasonable cause and when there is a legal basis forprocessing. Reasons and legal bases of processing are listed limitedly in thisPolicy and this Policy will be updated if a reason or a legal basis change.

a.     Name-Surname

Processing Reasons-Legal Bases

Identifying the person wishing to contact YellowX - Legitimate interest

Identifying the person requesting a demo/an access plan - Legitimate interest

Identifying the person wishing to join the  quiz challenge - Legitimate interest

b.    Age

Identifying the person wishing to contact YellowX - Legitimate interest

Identifying the person wishing to join the  quiz challenge - Legitimate interest

c.     E-Mail Address

Communicating with the person regarding his/her requests and/or  questions - Legitimate interest

Contacting about demo/access plan request - Legitimate interest

Contacting about quiz challenge - Legitimate interest

d.    Phone Number

Contacting about demo/access plan request to Zillion - Legitimate interest

e.     Current Location of Residency

Evaluating the demo request and eligibility for its attendance to YellowX  - Legitimate interest

Evaluating the demo request of the parent and eligibility of the high  school children for its attendance to Zillion Academy - Legitimate interest

f.      Startup Background

Responding to the requests and/or questions of the person in connection  with its startup status - Legitimate interest

Contacting about demo/access plan request - Legitimate interest

Preparing proper offers for the person wishing to join the free  Demo - Legitimate interest

g.     Startups Name

Identifying the startup wishing to contact YellowX - Legitimate interest

Identifying the startup requesting a demo/an access plan - Legitimate interest

h.    Occupation

Evaluating the demo/access plan request - Legitimate interest

i.      Startups Field of Activity

Evaluating the demo/access plan request - Legitimate interest

Listing and Sorting the Startup to   provide customized offers - Legitimate interest

j.      Startups Details

Evaluating the demo/access plan request - Legitimate interest

k.     Cookie

Improving the Website - Legitimate interest

l.      IP Address

Complying with legal obligation - Legal obligation

m.   Device & Browser Type

Improving the Website - Legitimate interest

n.     Usage Information

Improving the Website - Legitimate interest

o.     Survey Questions’s Answers

Preparing proper questions for the person wishing to join the program - Legitimate interest

Improving the Website - Legitimate interest

9.     Rights of Data Subjects

Data Subjects are endowed with some rights to ensure their Personal Datato be processed on a lawful basis. Website is designed in compliance with thePrivacy by Design and Data Protection by Design principles. Therefore, alongwith the below-mentioned rights, Data Subjects have a right to opt-out from theWebsite via an e-mail, which ends up with their Application data to be deleted.

a.      Right to be informed, by which the Data Subject may requestinformation about their Personal Data being processed by YellowX.

b.     Right of access, by which the Data Subject may request tolearn their Personal Data being processed by YellowX.

c.      Right of rectification, by which the Data Subject may request YellowXto correct or complete their Personal Data.

d.     Right to restrict processing, by which the Data Subject mayrequest to limit the way their Personal Data is used.

e.      Right to erasure, by which the Data Subject may request tohave their Personal Data erased.

f.       Right to data portability, by which the Data Subject mayrequest to receive their Personal Data in a machine-readable format and/orrequest YellowX to transfer their Personal Data to another controller.

g.      Right to object, by which the Data Subject may request YellowXto stop processing their Personal Data.

h.     Rights in relation to automated decision-making, by which the Data Subject mayrequest YellowX to stop processing their personal data in cases where PersonalData is being processed via automated decision-making.

10.  Transfer of Personal Data

YellowX transfers Personal Data to third parties only when there is an explicit and informed consent from the Data Subject except for the below-mentioned cases, which havetheir own legal bases for the transfer:

a.      Law Enforcement and Judiciary Authorities: YellowX may be obliged to disclose Personal Data when required to do soby law, including but not limited to legal claims, legal investigations, lawfulrequests, or legal proceedings.

b.     Server, Infrastructure Services & Form Service Providers (TypeformS.L.) : Name-Surname, Age, E-Mail Address, PhoneNumber, Number of Children, Current Location of Residency, Occupation, StartupBackground, Startups Name, Startups Details, Startups Field of Activity, SurveyQuestions’ Answers data may be transferred to the company providing server andinfrastructure services for Website and the Form.

11.  Period of Retention

YellowX storesPersonal Data in view of Data Minimization Principle, which necessitates PersonalData to be kept only for the required period. Required period is assignedconsidering the nature of the Personal Data, the potential risks of a PersonalData breach, processing reasons, and whether or not such reasons can beachieved in a different manner.

12.  Children’s Privacy

You should always check with your parents or guardians beforegiving out any information about you, especially before entering information onWebsite.

Below we summarize potential instances of collection ofPersonal Data where our services are directed at children between 13 and 18. Wealso outline how and when we will provide parental notice and/or seek parentalconsent.

In any instance that we collect Personal Data from a child,we will retain that information only so long as reasonably necessary to fulfillthe activity requested or allow you to continue to participate in the activity,and to ensure the security of our users and our services, or as required bylaw.

In the event we discover we have collected Personal Data fromor about a child in a manner inconsistent with legal requirements, we willeither delete the information or immediately seek the parent’s consent for thatcollection.

The Personal Data that we collect about children between 13and 18 generally falls within two categories: (a) information the parent provideto us, and (b) information we collect automatically when the child use oraccess our Website.

We do not aim any of our products or services directly atchildren under the age of 13 (a “Minor”). However we may offer servicesaiming high school students who are between 13 and18.

If we acknowledgethat any Personal Data processed by us, belongs to a Minor we shall take theappropriate measures to delete such Personal Data.

 

13.  Methods of Securing Personal Data

Appropriate technical and organizational measures are enacted to ensurethe safety, protection and the encryption of the Personal Data in order toprevent any Personal Data breach such that may be caused by accidental orunauthorized destruction, loss, theft or; unauthorized use, alteration anddisclosure.

In this context, YellowX ;

a.     Sign non-disclosureagreements with parties who have limited or unlimited access to Personal Data.

b.    Organize awarenesstrainings about data protection inside its organization.

c.     Entitles its employeeswith limited authorization according to their work line.

d.    Transfer Personal Dataon a ‘need-to-know’ basis.

e.     Process and storepersonal data on safely secured and encrypted cloud servers.

14.  Contact Information of YellowX

Data Subjects may contact YellowX in case of having questions,comments, or feedback via contact@yellowx.co

1.      Preamble

We, as Zillion (“Zillion”) a fully owned brand of YellowX OU (“YellowX”),give utmost importance to the privacy of our Visitors and Applicants duringtheir use of our websites with brand domain names https://www.zillionpitches.com and https://www.zillionpitch.co (“Websites”) and/or itssubdomains regardless of their country of access.

2.      Purpose of This Policy

This Privacy Policy (“Policy”)is prepared with a privacy-prioritizing attitude in order to provide detailedinformation to Visitors and Applicants regarding the identity of YellowX as adata controller; data processing and its legal bases, reasons; rights ofVisitors and Applicants (collectively “DataSubject”), which can be exercised against YellowX .

This Policy shall be read by Visitors and Applicants regardless of theirresidency or location of access. The personal information subject to processingmay differ from one action to another such as accessing to Website, requestinga demo, requesting to join a quiz challenge, or contacting us; and YellowX hereininforms you about how your personal data is handled in different cases.

3.      Scope of This Policy

a.      In Terms of Legislation

Since YellowX isan Estonia based company but has numerous Visitors and Applicants fromdifferent countries; it is hard to determine which legislation should beapplied to its activities and business. Therefore, YellowX intends to reflectits compliance with different legislations about privacy and data protection.For this reason, YellowX shows considerable effort to act in accordance withGeneral Data Protection Regulation (“GDPR”),Turkish Personal Data Protection Law No. 6698 (“PDPL”), CaliforniaConsumer Privacy Act (“CCPA”), andother applicable data protection regulations.

b.     In Terms of Related Person

This Policyincludes different Data Subjects with various motives such as somehow accessingand making a demo and/or access plan request, request to join a quiz challenge,in relation with the services provided by Zillion through the onlineapplication forms (“Form”). Even though Data Subject may bereferred as Visitor and Applicant according to their intention for using the Website,they will be covered in this Policy.

c.      In Terms of Data

Informationthat makes it possible for related person to be identified directly orindirectly by any other person (“PersonalData”) is in the scope of this Policy. Accordingly, it can be safely saidthat confidential information, which cannot be considered as Personal Data, isexcluded from this Policy.

4.     Identity of YellowX as a Data Controller

For any and all data processing that occurs through accessing Website and benefiting from theservices provided through the Website, YellowX OU, a registered company havingits address at Tammsaare Business Center A. H. Tammsaare tee 47 Tallinn, 11316Harju Maakond Estonia is a datacontroller (“Controller”).  

5.     Occasions for Personal Data Processing

YellowX processes personal data during includingwithout limitation below-mentioned situations:

·       accessing to the Website,

·       contacting to Zillionthrough Form,

·       making a request tojoin the quiz challenge through Form,

·       making a demo and/oraccess plan request through the Form.

6.     Principles for Processing Personal Data

YellowX considers below-mentioned principles whileProcessing Personal Data:

·       Processing PersonalData lawfully, fairly and in a transparent manner in relation to the DataSubject,

·       Processing PersonalData accurately and where necessary, kept up to date,

·       Processing PersonalData for specific, explicit, and legitimate purposes,

·       Processing PersonalData relevantly, limitedly, and proportionately to the purposes for which theyare processed,

·       Processing PersonalData in a manner that ensures appropriate security of the Personal Data andkept in a form which allows identification of Data Subjects for no longer thanit is necessary for the processing reasons.

7.     Processed Personal Data

Personal Data Collected by Us

Name-Surname

Cookie

Age

IP Address

E-Mail Address

Device &  Browser Type

Phone Number

Usage Information

Current Location of  Residency

Survey Questions’  Answers

Educational  Background

Occupation

Startup Background

Startups Name

Startups Details

Startups Field of  Activity

8.     Reasons and Legal Bases for Processing Personal Data

Personal Data given to or collected by us shall only be processed whennecessary for a reasonable cause and when there is a legal basis forprocessing. Reasons and legal bases of processing are listed limitedly in thisPolicy and this Policy will be updated if a reason or a legal basis change.

a.     Name-Surname

Processing Reasons-Legal Bases

Identifying the person wishing to contact YellowX - Legitimate interest

Identifying the person requesting a demo/an access plan - Legitimate interest

Identifying the person wishing to join the  quiz challenge - Legitimate interest

b.    Age

Identifying the person wishing to contact YellowX - Legitimate interest

Identifying the person wishing to join the  quiz challenge - Legitimate interest

c.     E-Mail Address

Communicating with the person regarding his/her requests and/or  questions - Legitimate interest

Contacting about demo/access plan request - Legitimate interest

Contacting about quiz challenge - Legitimate interest

d.    Phone Number

Contacting about demo/access plan request to Zillion - Legitimate interest

e.     Current Location of Residency

Evaluating the demo request and eligibility for its attendance to YellowX  - Legitimate interest

Evaluating the demo request of the parent and eligibility of the high  school children for its attendance to Zillion Academy - Legitimate interest

f.      Startup Background

Responding to the requests and/or questions of the person in connection  with its startup status - Legitimate interest

Contacting about demo/access plan request - Legitimate interest

Preparing proper offers for the person wishing to join the free  Demo - Legitimate interest

g.     Startups Name

Identifying the startup wishing to contact YellowX - Legitimate interest

Identifying the startup requesting a demo/an access plan - Legitimate interest

h.    Occupation

Evaluating the demo/access plan request - Legitimate interest

i.      Startups Field of Activity

Evaluating the demo/access plan request - Legitimate interest

Listing and Sorting the Startup to   provide customized offers - Legitimate interest

j.      Startups Details

Evaluating the demo/access plan request - Legitimate interest

k.     Cookie

Improving the Website - Legitimate interest

l.      IP Address

Complying with legal obligation - Legal obligation

m.   Device & Browser Type

Improving the Website - Legitimate interest

n.     Usage Information

Improving the Website - Legitimate interest

o.     Survey Questions’s Answers

Preparing proper questions for the person wishing to join the program - Legitimate interest

Improving the Website - Legitimate interest

9.     Rights of Data Subjects

Data Subjects are endowed with some rights to ensure their Personal Datato be processed on a lawful basis. Website is designed in compliance with thePrivacy by Design and Data Protection by Design principles. Therefore, alongwith the below-mentioned rights, Data Subjects have a right to opt-out from theWebsite via an e-mail, which ends up with their Application data to be deleted.

a.      Right to be informed, by which the Data Subject may requestinformation about their Personal Data being processed by YellowX.

b.     Right of access, by which the Data Subject may request tolearn their Personal Data being processed by YellowX.

c.      Right of rectification, by which the Data Subject may request YellowXto correct or complete their Personal Data.

d.     Right to restrict processing, by which the Data Subject mayrequest to limit the way their Personal Data is used.

e.      Right to erasure, by which the Data Subject may request tohave their Personal Data erased.

f.       Right to data portability, by which the Data Subject mayrequest to receive their Personal Data in a machine-readable format and/orrequest YellowX to transfer their Personal Data to another controller.

g.      Right to object, by which the Data Subject may request YellowXto stop processing their Personal Data.

h.     Rights in relation to automated decision-making, by which the Data Subject mayrequest YellowX to stop processing their personal data in cases where PersonalData is being processed via automated decision-making.

10.  Transfer of Personal Data

YellowX transfers Personal Data to third parties only when there is an explicit and informed consent from the Data Subject except for the below-mentioned cases, which havetheir own legal bases for the transfer:

a.      Law Enforcement and Judiciary Authorities: YellowX may be obliged to disclose Personal Data when required to do soby law, including but not limited to legal claims, legal investigations, lawfulrequests, or legal proceedings.

b.     Server, Infrastructure Services & Form Service Providers (TypeformS.L.) : Name-Surname, Age, E-Mail Address, PhoneNumber, Number of Children, Current Location of Residency, Occupation, StartupBackground, Startups Name, Startups Details, Startups Field of Activity, SurveyQuestions’ Answers data may be transferred to the company providing server andinfrastructure services for Website and the Form.

11.  Period of Retention

YellowX storesPersonal Data in view of Data Minimization Principle, which necessitates PersonalData to be kept only for the required period. Required period is assignedconsidering the nature of the Personal Data, the potential risks of a PersonalData breach, processing reasons, and whether or not such reasons can beachieved in a different manner.

12.  Children’s Privacy

You should always check with your parents or guardians beforegiving out any information about you, especially before entering information onWebsite.

Below we summarize potential instances of collection ofPersonal Data where our services are directed at children between 13 and 18. Wealso outline how and when we will provide parental notice and/or seek parentalconsent.

In any instance that we collect Personal Data from a child,we will retain that information only so long as reasonably necessary to fulfillthe activity requested or allow you to continue to participate in the activity,and to ensure the security of our users and our services, or as required bylaw.

In the event we discover we have collected Personal Data fromor about a child in a manner inconsistent with legal requirements, we willeither delete the information or immediately seek the parent’s consent for thatcollection.

The Personal Data that we collect about children between 13and 18 generally falls within two categories: (a) information the parent provideto us, and (b) information we collect automatically when the child use oraccess our Website.

We do not aim any of our products or services directly atchildren under the age of 13 (a “Minor”). However we may offer servicesaiming high school students who are between 13 and18.

If we acknowledgethat any Personal Data processed by us, belongs to a Minor we shall take theappropriate measures to delete such Personal Data.

 

13.  Methods of Securing Personal Data

Appropriate technical and organizational measures are enacted to ensurethe safety, protection and the encryption of the Personal Data in order toprevent any Personal Data breach such that may be caused by accidental orunauthorized destruction, loss, theft or; unauthorized use, alteration anddisclosure.

In this context, YellowX ;

a.     Sign non-disclosureagreements with parties who have limited or unlimited access to Personal Data.

b.    Organize awarenesstrainings about data protection inside its organization.

c.     Entitles its employeeswith limited authorization according to their work line.

d.    Transfer Personal Dataon a ‘need-to-know’ basis.

e.     Process and storepersonal data on safely secured and encrypted cloud servers.

14.  Contact Information of YellowX

Data Subjects may contact YellowX in case of having questions,comments, or feedback via contact@yellowx.co

1.      Preamble

We, as Zillion (“Zillion”) a fully owned brand of YellowX OU (“YellowX”),give utmost importance to the privacy of our Visitors and Applicants duringtheir use of our websites with brand domain names https://www.zillionpitches.com and https://www.zillionpitch.co (“Websites”) and/or itssubdomains regardless of their country of access.

2.      Purpose of This Policy

This Privacy Policy (“Policy”)is prepared with a privacy-prioritizing attitude in order to provide detailedinformation to Visitors and Applicants regarding the identity of YellowX as adata controller; data processing and its legal bases, reasons; rights ofVisitors and Applicants (collectively “DataSubject”), which can be exercised against YellowX .

This Policy shall be read by Visitors and Applicants regardless of theirresidency or location of access. The personal information subject to processingmay differ from one action to another such as accessing to Website, requestinga demo, requesting to join a quiz challenge, or contacting us; and YellowX hereininforms you about how your personal data is handled in different cases.

3.      Scope of This Policy

a.      In Terms of Legislation

Since YellowX isan Estonia based company but has numerous Visitors and Applicants fromdifferent countries; it is hard to determine which legislation should beapplied to its activities and business. Therefore, YellowX intends to reflectits compliance with different legislations about privacy and data protection.For this reason, YellowX shows considerable effort to act in accordance withGeneral Data Protection Regulation (“GDPR”),Turkish Personal Data Protection Law No. 6698 (“PDPL”), CaliforniaConsumer Privacy Act (“CCPA”), andother applicable data protection regulations.

b.     In Terms of Related Person

This Policyincludes different Data Subjects with various motives such as somehow accessingand making a demo and/or access plan request, request to join a quiz challenge,in relation with the services provided by Zillion through the onlineapplication forms (“Form”). Even though Data Subject may bereferred as Visitor and Applicant according to their intention for using the Website,they will be covered in this Policy.

c.      In Terms of Data

Informationthat makes it possible for related person to be identified directly orindirectly by any other person (“PersonalData”) is in the scope of this Policy. Accordingly, it can be safely saidthat confidential information, which cannot be considered as Personal Data, isexcluded from this Policy.

4.     Identity of YellowX as a Data Controller

For any and all data processing that occurs through accessing Website and benefiting from theservices provided through the Website, YellowX OU, a registered company havingits address at Tammsaare Business Center A. H. Tammsaare tee 47 Tallinn, 11316Harju Maakond Estonia is a datacontroller (“Controller”).  

5.     Occasions for Personal Data Processing

YellowX processes personal data during includingwithout limitation below-mentioned situations:

·       accessing to the Website,

·       contacting to Zillionthrough Form,

·       making a request tojoin the quiz challenge through Form,

·       making a demo and/oraccess plan request through the Form.

6.     Principles for Processing Personal Data

YellowX considers below-mentioned principles whileProcessing Personal Data:

·       Processing PersonalData lawfully, fairly and in a transparent manner in relation to the DataSubject,

·       Processing PersonalData accurately and where necessary, kept up to date,

·       Processing PersonalData for specific, explicit, and legitimate purposes,

·       Processing PersonalData relevantly, limitedly, and proportionately to the purposes for which theyare processed,

·       Processing PersonalData in a manner that ensures appropriate security of the Personal Data andkept in a form which allows identification of Data Subjects for no longer thanit is necessary for the processing reasons.

7.     Processed Personal Data

Personal Data Collected by Us

Name-Surname

Cookie

Age

IP Address

E-Mail Address

Device &  Browser Type

Phone Number

Usage Information

Current Location of  Residency

Survey Questions’  Answers

Educational  Background

Occupation

Startup Background

Startups Name

Startups Details

Startups Field of  Activity

8.     Reasons and Legal Bases for Processing Personal Data

Personal Data given to or collected by us shall only be processed whennecessary for a reasonable cause and when there is a legal basis forprocessing. Reasons and legal bases of processing are listed limitedly in thisPolicy and this Policy will be updated if a reason or a legal basis change.

a.     Name-Surname

Processing Reasons-Legal Bases

Identifying the person wishing to contact YellowX - Legitimate interest

Identifying the person requesting a demo/an access plan - Legitimate interest

Identifying the person wishing to join the  quiz challenge - Legitimate interest

b.    Age

Identifying the person wishing to contact YellowX - Legitimate interest

Identifying the person wishing to join the  quiz challenge - Legitimate interest

c.     E-Mail Address

Communicating with the person regarding his/her requests and/or  questions - Legitimate interest

Contacting about demo/access plan request - Legitimate interest

Contacting about quiz challenge - Legitimate interest

d.    Phone Number

Contacting about demo/access plan request to Zillion - Legitimate interest

e.     Current Location of Residency

Evaluating the demo request and eligibility for its attendance to YellowX  - Legitimate interest

Evaluating the demo request of the parent and eligibility of the high  school children for its attendance to Zillion Academy - Legitimate interest

f.      Startup Background

Responding to the requests and/or questions of the person in connection  with its startup status - Legitimate interest

Contacting about demo/access plan request - Legitimate interest

Preparing proper offers for the person wishing to join the free  Demo - Legitimate interest

g.     Startups Name

Identifying the startup wishing to contact YellowX - Legitimate interest

Identifying the startup requesting a demo/an access plan - Legitimate interest

h.    Occupation

Evaluating the demo/access plan request - Legitimate interest

i.      Startups Field of Activity

Evaluating the demo/access plan request - Legitimate interest

Listing and Sorting the Startup to   provide customized offers - Legitimate interest

j.      Startups Details

Evaluating the demo/access plan request - Legitimate interest

k.     Cookie

Improving the Website - Legitimate interest

l.      IP Address

Complying with legal obligation - Legal obligation

m.   Device & Browser Type

Improving the Website - Legitimate interest

n.     Usage Information

Improving the Website - Legitimate interest

o.     Survey Questions’s Answers

Preparing proper questions for the person wishing to join the program - Legitimate interest

Improving the Website - Legitimate interest

9.     Rights of Data Subjects

Data Subjects are endowed with some rights to ensure their Personal Datato be processed on a lawful basis. Website is designed in compliance with thePrivacy by Design and Data Protection by Design principles. Therefore, alongwith the below-mentioned rights, Data Subjects have a right to opt-out from theWebsite via an e-mail, which ends up with their Application data to be deleted.

a.      Right to be informed, by which the Data Subject may requestinformation about their Personal Data being processed by YellowX.

b.     Right of access, by which the Data Subject may request tolearn their Personal Data being processed by YellowX.

c.      Right of rectification, by which the Data Subject may request YellowXto correct or complete their Personal Data.

d.     Right to restrict processing, by which the Data Subject mayrequest to limit the way their Personal Data is used.

e.      Right to erasure, by which the Data Subject may request tohave their Personal Data erased.

f.       Right to data portability, by which the Data Subject mayrequest to receive their Personal Data in a machine-readable format and/orrequest YellowX to transfer their Personal Data to another controller.

g.      Right to object, by which the Data Subject may request YellowXto stop processing their Personal Data.

h.     Rights in relation to automated decision-making, by which the Data Subject mayrequest YellowX to stop processing their personal data in cases where PersonalData is being processed via automated decision-making.

10.  Transfer of Personal Data

YellowX transfers Personal Data to third parties only when there is an explicit and informed consent from the Data Subject except for the below-mentioned cases, which havetheir own legal bases for the transfer:

a.      Law Enforcement and Judiciary Authorities: YellowX may be obliged to disclose Personal Data when required to do soby law, including but not limited to legal claims, legal investigations, lawfulrequests, or legal proceedings.

b.     Server, Infrastructure Services & Form Service Providers (TypeformS.L.) : Name-Surname, Age, E-Mail Address, PhoneNumber, Number of Children, Current Location of Residency, Occupation, StartupBackground, Startups Name, Startups Details, Startups Field of Activity, SurveyQuestions’ Answers data may be transferred to the company providing server andinfrastructure services for Website and the Form.

11.  Period of Retention

YellowX storesPersonal Data in view of Data Minimization Principle, which necessitates PersonalData to be kept only for the required period. Required period is assignedconsidering the nature of the Personal Data, the potential risks of a PersonalData breach, processing reasons, and whether or not such reasons can beachieved in a different manner.

12.  Children’s Privacy

You should always check with your parents or guardians beforegiving out any information about you, especially before entering information onWebsite.

Below we summarize potential instances of collection ofPersonal Data where our services are directed at children between 13 and 18. Wealso outline how and when we will provide parental notice and/or seek parentalconsent.

In any instance that we collect Personal Data from a child,we will retain that information only so long as reasonably necessary to fulfillthe activity requested or allow you to continue to participate in the activity,and to ensure the security of our users and our services, or as required bylaw.

In the event we discover we have collected Personal Data fromor about a child in a manner inconsistent with legal requirements, we willeither delete the information or immediately seek the parent’s consent for thatcollection.

The Personal Data that we collect about children between 13and 18 generally falls within two categories: (a) information the parent provideto us, and (b) information we collect automatically when the child use oraccess our Website.

We do not aim any of our products or services directly atchildren under the age of 13 (a “Minor”). However we may offer servicesaiming high school students who are between 13 and18.

If we acknowledgethat any Personal Data processed by us, belongs to a Minor we shall take theappropriate measures to delete such Personal Data.

 

13.  Methods of Securing Personal Data

Appropriate technical and organizational measures are enacted to ensurethe safety, protection and the encryption of the Personal Data in order toprevent any Personal Data breach such that may be caused by accidental orunauthorized destruction, loss, theft or; unauthorized use, alteration anddisclosure.

In this context, YellowX ;

a.     Sign non-disclosureagreements with parties who have limited or unlimited access to Personal Data.

b.    Organize awarenesstrainings about data protection inside its organization.

c.     Entitles its employeeswith limited authorization according to their work line.

d.    Transfer Personal Dataon a ‘need-to-know’ basis.

e.     Process and storepersonal data on safely secured and encrypted cloud servers.

14.  Contact Information of YellowX

Data Subjects may contact YellowX in case of having questions,comments, or feedback via contact@yellowx.co

1.      Preamble

We, as Zillion (“Zillion”) a fully owned brand of YellowX OU (“YellowX”),give utmost importance to the privacy of our Visitors and Applicants duringtheir use of our websites with brand domain names https://www.zillionpitches.com and https://www.zillionpitch.co (“Websites”) and/or itssubdomains regardless of their country of access.

2.      Purpose of This Policy

This Privacy Policy (“Policy”)is prepared with a privacy-prioritizing attitude in order to provide detailedinformation to Visitors and Applicants regarding the identity of YellowX as adata controller; data processing and its legal bases, reasons; rights ofVisitors and Applicants (collectively “DataSubject”), which can be exercised against YellowX .

This Policy shall be read by Visitors and Applicants regardless of theirresidency or location of access. The personal information subject to processingmay differ from one action to another such as accessing to Website, requestinga demo, requesting to join a quiz challenge, or contacting us; and YellowX hereininforms you about how your personal data is handled in different cases.

3.      Scope of This Policy

a.      In Terms of Legislation

Since YellowX isan Estonia based company but has numerous Visitors and Applicants fromdifferent countries; it is hard to determine which legislation should beapplied to its activities and business. Therefore, YellowX intends to reflectits compliance with different legislations about privacy and data protection.For this reason, YellowX shows considerable effort to act in accordance withGeneral Data Protection Regulation (“GDPR”),Turkish Personal Data Protection Law No. 6698 (“PDPL”), CaliforniaConsumer Privacy Act (“CCPA”), andother applicable data protection regulations.

b.     In Terms of Related Person

This Policyincludes different Data Subjects with various motives such as somehow accessingand making a demo and/or access plan request, request to join a quiz challenge,in relation with the services provided by Zillion through the onlineapplication forms (“Form”). Even though Data Subject may bereferred as Visitor and Applicant according to their intention for using the Website,they will be covered in this Policy.

c.      In Terms of Data

Informationthat makes it possible for related person to be identified directly orindirectly by any other person (“PersonalData”) is in the scope of this Policy. Accordingly, it can be safely saidthat confidential information, which cannot be considered as Personal Data, isexcluded from this Policy.

4.     Identity of YellowX as a Data Controller

For any and all data processing that occurs through accessing Website and benefiting from theservices provided through the Website, YellowX OU, a registered company havingits address at Tammsaare Business Center A. H. Tammsaare tee 47 Tallinn, 11316Harju Maakond Estonia is a datacontroller (“Controller”).  

5.     Occasions for Personal Data Processing

YellowX processes personal data during includingwithout limitation below-mentioned situations:

·       accessing to the Website,

·       contacting to Zillionthrough Form,

·       making a request tojoin the quiz challenge through Form,

·       making a demo and/oraccess plan request through the Form.

6.     Principles for Processing Personal Data

YellowX considers below-mentioned principles whileProcessing Personal Data:

·       Processing PersonalData lawfully, fairly and in a transparent manner in relation to the DataSubject,

·       Processing PersonalData accurately and where necessary, kept up to date,

·       Processing PersonalData for specific, explicit, and legitimate purposes,

·       Processing PersonalData relevantly, limitedly, and proportionately to the purposes for which theyare processed,

·       Processing PersonalData in a manner that ensures appropriate security of the Personal Data andkept in a form which allows identification of Data Subjects for no longer thanit is necessary for the processing reasons.

7.     Processed Personal Data

Personal Data Collected by Us

Name-Surname

Cookie

Age

IP Address

E-Mail Address

Device &  Browser Type

Phone Number

Usage Information

Current Location of  Residency

Survey Questions’  Answers

Educational  Background

Occupation

Startup Background

Startups Name

Startups Details

Startups Field of  Activity

8.     Reasons and Legal Bases for Processing Personal Data

Personal Data given to or collected by us shall only be processed whennecessary for a reasonable cause and when there is a legal basis forprocessing. Reasons and legal bases of processing are listed limitedly in thisPolicy and this Policy will be updated if a reason or a legal basis change.

a.     Name-Surname

Processing Reasons-Legal Bases

Identifying the person wishing to contact YellowX - Legitimate interest

Identifying the person requesting a demo/an access plan - Legitimate interest

Identifying the person wishing to join the  quiz challenge - Legitimate interest

b.    Age

Identifying the person wishing to contact YellowX - Legitimate interest

Identifying the person wishing to join the  quiz challenge - Legitimate interest

c.     E-Mail Address

Communicating with the person regarding his/her requests and/or  questions - Legitimate interest

Contacting about demo/access plan request - Legitimate interest

Contacting about quiz challenge - Legitimate interest

d.    Phone Number

Contacting about demo/access plan request to Zillion - Legitimate interest

e.     Current Location of Residency

Evaluating the demo request and eligibility for its attendance to YellowX  - Legitimate interest

Evaluating the demo request of the parent and eligibility of the high  school children for its attendance to Zillion Academy - Legitimate interest

f.      Startup Background

Responding to the requests and/or questions of the person in connection  with its startup status - Legitimate interest

Contacting about demo/access plan request - Legitimate interest

Preparing proper offers for the person wishing to join the free  Demo - Legitimate interest

g.     Startups Name

Identifying the startup wishing to contact YellowX - Legitimate interest

Identifying the startup requesting a demo/an access plan - Legitimate interest

h.    Occupation

Evaluating the demo/access plan request - Legitimate interest

i.      Startups Field of Activity

Evaluating the demo/access plan request - Legitimate interest

Listing and Sorting the Startup to   provide customized offers - Legitimate interest

j.      Startups Details

Evaluating the demo/access plan request - Legitimate interest

k.     Cookie

Improving the Website - Legitimate interest

l.      IP Address

Complying with legal obligation - Legal obligation

m.   Device & Browser Type

Improving the Website - Legitimate interest

n.     Usage Information

Improving the Website - Legitimate interest

o.     Survey Questions’s Answers

Preparing proper questions for the person wishing to join the program - Legitimate interest

Improving the Website - Legitimate interest

9.     Rights of Data Subjects

Data Subjects are endowed with some rights to ensure their Personal Datato be processed on a lawful basis. Website is designed in compliance with thePrivacy by Design and Data Protection by Design principles. Therefore, alongwith the below-mentioned rights, Data Subjects have a right to opt-out from theWebsite via an e-mail, which ends up with their Application data to be deleted.

a.      Right to be informed, by which the Data Subject may requestinformation about their Personal Data being processed by YellowX.

b.     Right of access, by which the Data Subject may request tolearn their Personal Data being processed by YellowX.

c.      Right of rectification, by which the Data Subject may request YellowXto correct or complete their Personal Data.

d.     Right to restrict processing, by which the Data Subject mayrequest to limit the way their Personal Data is used.

e.      Right to erasure, by which the Data Subject may request tohave their Personal Data erased.

f.       Right to data portability, by which the Data Subject mayrequest to receive their Personal Data in a machine-readable format and/orrequest YellowX to transfer their Personal Data to another controller.

g.      Right to object, by which the Data Subject may request YellowXto stop processing their Personal Data.

h.     Rights in relation to automated decision-making, by which the Data Subject mayrequest YellowX to stop processing their personal data in cases where PersonalData is being processed via automated decision-making.

10.  Transfer of Personal Data

YellowX transfers Personal Data to third parties only when there is an explicit and informed consent from the Data Subject except for the below-mentioned cases, which havetheir own legal bases for the transfer:

a.      Law Enforcement and Judiciary Authorities: YellowX may be obliged to disclose Personal Data when required to do soby law, including but not limited to legal claims, legal investigations, lawfulrequests, or legal proceedings.

b.     Server, Infrastructure Services & Form Service Providers (TypeformS.L.) : Name-Surname, Age, E-Mail Address, PhoneNumber, Number of Children, Current Location of Residency, Occupation, StartupBackground, Startups Name, Startups Details, Startups Field of Activity, SurveyQuestions’ Answers data may be transferred to the company providing server andinfrastructure services for Website and the Form.

11.  Period of Retention

YellowX storesPersonal Data in view of Data Minimization Principle, which necessitates PersonalData to be kept only for the required period. Required period is assignedconsidering the nature of the Personal Data, the potential risks of a PersonalData breach, processing reasons, and whether or not such reasons can beachieved in a different manner.

12.  Children’s Privacy

You should always check with your parents or guardians beforegiving out any information about you, especially before entering information onWebsite.

Below we summarize potential instances of collection ofPersonal Data where our services are directed at children between 13 and 18. Wealso outline how and when we will provide parental notice and/or seek parentalconsent.

In any instance that we collect Personal Data from a child,we will retain that information only so long as reasonably necessary to fulfillthe activity requested or allow you to continue to participate in the activity,and to ensure the security of our users and our services, or as required bylaw.

In the event we discover we have collected Personal Data fromor about a child in a manner inconsistent with legal requirements, we willeither delete the information or immediately seek the parent’s consent for thatcollection.

The Personal Data that we collect about children between 13and 18 generally falls within two categories: (a) information the parent provideto us, and (b) information we collect automatically when the child use oraccess our Website.

We do not aim any of our products or services directly atchildren under the age of 13 (a “Minor”). However we may offer servicesaiming high school students who are between 13 and18.

If we acknowledgethat any Personal Data processed by us, belongs to a Minor we shall take theappropriate measures to delete such Personal Data.

 

13.  Methods of Securing Personal Data

Appropriate technical and organizational measures are enacted to ensurethe safety, protection and the encryption of the Personal Data in order toprevent any Personal Data breach such that may be caused by accidental orunauthorized destruction, loss, theft or; unauthorized use, alteration anddisclosure.

In this context, YellowX ;

a.     Sign non-disclosureagreements with parties who have limited or unlimited access to Personal Data.

b.    Organize awarenesstrainings about data protection inside its organization.

c.     Entitles its employeeswith limited authorization according to their work line.

d.    Transfer Personal Dataon a ‘need-to-know’ basis.

e.     Process and storepersonal data on safely secured and encrypted cloud servers.

14.  Contact Information of YellowX

Data Subjects may contact YellowX in case of having questions,comments, or feedback via contact@yellowx.co

1.      Preamble

We, as Zillion (“Zillion”) a fully owned brand of YellowX OU (“YellowX”),give utmost importance to the privacy of our Visitors and Applicants duringtheir use of our websites with brand domain names https://www.zillionpitches.com and https://www.zillionpitch.co (“Websites”) and/or itssubdomains regardless of their country of access.

2.      Purpose of This Policy

This Privacy Policy (“Policy”)is prepared with a privacy-prioritizing attitude in order to provide detailedinformation to Visitors and Applicants regarding the identity of YellowX as adata controller; data processing and its legal bases, reasons; rights ofVisitors and Applicants (collectively “DataSubject”), which can be exercised against YellowX .

This Policy shall be read by Visitors and Applicants regardless of theirresidency or location of access. The personal information subject to processingmay differ from one action to another such as accessing to Website, requestinga demo, requesting to join a quiz challenge, or contacting us; and YellowX hereininforms you about how your personal data is handled in different cases.

3.      Scope of This Policy

a.      In Terms of Legislation

Since YellowX isan Estonia based company but has numerous Visitors and Applicants fromdifferent countries; it is hard to determine which legislation should beapplied to its activities and business. Therefore, YellowX intends to reflectits compliance with different legislations about privacy and data protection.For this reason, YellowX shows considerable effort to act in accordance withGeneral Data Protection Regulation (“GDPR”),Turkish Personal Data Protection Law No. 6698 (“PDPL”), CaliforniaConsumer Privacy Act (“CCPA”), andother applicable data protection regulations.

b.     In Terms of Related Person

This Policyincludes different Data Subjects with various motives such as somehow accessingand making a demo and/or access plan request, request to join a quiz challenge,in relation with the services provided by Zillion through the onlineapplication forms (“Form”). Even though Data Subject may bereferred as Visitor and Applicant according to their intention for using the Website,they will be covered in this Policy.

c.      In Terms of Data

Informationthat makes it possible for related person to be identified directly orindirectly by any other person (“PersonalData”) is in the scope of this Policy. Accordingly, it can be safely saidthat confidential information, which cannot be considered as Personal Data, isexcluded from this Policy.

4.     Identity of YellowX as a Data Controller

For any and all data processing that occurs through accessing Website and benefiting from theservices provided through the Website, YellowX OU, a registered company havingits address at Tammsaare Business Center A. H. Tammsaare tee 47 Tallinn, 11316Harju Maakond Estonia is a datacontroller (“Controller”).  

5.     Occasions for Personal Data Processing

YellowX processes personal data during includingwithout limitation below-mentioned situations:

·       accessing to the Website,

·       contacting to Zillionthrough Form,

·       making a request tojoin the quiz challenge through Form,

·       making a demo and/oraccess plan request through the Form.

6.     Principles for Processing Personal Data

YellowX considers below-mentioned principles whileProcessing Personal Data:

·       Processing PersonalData lawfully, fairly and in a transparent manner in relation to the DataSubject,

·       Processing PersonalData accurately and where necessary, kept up to date,

·       Processing PersonalData for specific, explicit, and legitimate purposes,

·       Processing PersonalData relevantly, limitedly, and proportionately to the purposes for which theyare processed,

·       Processing PersonalData in a manner that ensures appropriate security of the Personal Data andkept in a form which allows identification of Data Subjects for no longer thanit is necessary for the processing reasons.

7.     Processed Personal Data

Personal Data Collected by Us

Name-Surname

Cookie

Age

IP Address

E-Mail Address

Device &  Browser Type

Phone Number

Usage Information

Current Location of  Residency

Survey Questions’  Answers

Educational  Background

Occupation

Startup Background

Startups Name

Startups Details

Startups Field of  Activity

8.     Reasons and Legal Bases for Processing Personal Data

Personal Data given to or collected by us shall only be processed whennecessary for a reasonable cause and when there is a legal basis forprocessing. Reasons and legal bases of processing are listed limitedly in thisPolicy and this Policy will be updated if a reason or a legal basis change.

a.     Name-Surname

Processing Reasons-Legal Bases

Identifying the person wishing to contact YellowX - Legitimate interest

Identifying the person requesting a demo/an access plan - Legitimate interest

Identifying the person wishing to join the  quiz challenge - Legitimate interest

b.    Age

Identifying the person wishing to contact YellowX - Legitimate interest

Identifying the person wishing to join the  quiz challenge - Legitimate interest

c.     E-Mail Address

Communicating with the person regarding his/her requests and/or  questions - Legitimate interest

Contacting about demo/access plan request - Legitimate interest

Contacting about quiz challenge - Legitimate interest

d.    Phone Number

Contacting about demo/access plan request to Zillion - Legitimate interest

e.     Current Location of Residency

Evaluating the demo request and eligibility for its attendance to YellowX  - Legitimate interest

Evaluating the demo request of the parent and eligibility of the high  school children for its attendance to Zillion Academy - Legitimate interest

f.      Startup Background

Responding to the requests and/or questions of the person in connection  with its startup status - Legitimate interest

Contacting about demo/access plan request - Legitimate interest

Preparing proper offers for the person wishing to join the free  Demo - Legitimate interest

g.     Startups Name

Identifying the startup wishing to contact YellowX - Legitimate interest

Identifying the startup requesting a demo/an access plan - Legitimate interest

h.    Occupation

Evaluating the demo/access plan request - Legitimate interest

i.      Startups Field of Activity

Evaluating the demo/access plan request - Legitimate interest

Listing and Sorting the Startup to   provide customized offers - Legitimate interest

j.      Startups Details

Evaluating the demo/access plan request - Legitimate interest

k.     Cookie

Improving the Website - Legitimate interest

l.      IP Address

Complying with legal obligation - Legal obligation

m.   Device & Browser Type

Improving the Website - Legitimate interest

n.     Usage Information

Improving the Website - Legitimate interest

o.     Survey Questions’s Answers

Preparing proper questions for the person wishing to join the program - Legitimate interest

Improving the Website - Legitimate interest

9.     Rights of Data Subjects

Data Subjects are endowed with some rights to ensure their Personal Datato be processed on a lawful basis. Website is designed in compliance with thePrivacy by Design and Data Protection by Design principles. Therefore, alongwith the below-mentioned rights, Data Subjects have a right to opt-out from theWebsite via an e-mail, which ends up with their Application data to be deleted.

a.      Right to be informed, by which the Data Subject may requestinformation about their Personal Data being processed by YellowX.

b.     Right of access, by which the Data Subject may request tolearn their Personal Data being processed by YellowX.

c.      Right of rectification, by which the Data Subject may request YellowXto correct or complete their Personal Data.

d.     Right to restrict processing, by which the Data Subject mayrequest to limit the way their Personal Data is used.

e.      Right to erasure, by which the Data Subject may request tohave their Personal Data erased.

f.       Right to data portability, by which the Data Subject mayrequest to receive their Personal Data in a machine-readable format and/orrequest YellowX to transfer their Personal Data to another controller.

g.      Right to object, by which the Data Subject may request YellowXto stop processing their Personal Data.

h.     Rights in relation to automated decision-making, by which the Data Subject mayrequest YellowX to stop processing their personal data in cases where PersonalData is being processed via automated decision-making.

10.  Transfer of Personal Data

YellowX transfers Personal Data to third parties only when there is an explicit and informed consent from the Data Subject except for the below-mentioned cases, which havetheir own legal bases for the transfer:

a.      Law Enforcement and Judiciary Authorities: YellowX may be obliged to disclose Personal Data when required to do soby law, including but not limited to legal claims, legal investigations, lawfulrequests, or legal proceedings.

b.     Server, Infrastructure Services & Form Service Providers (TypeformS.L.) : Name-Surname, Age, E-Mail Address, PhoneNumber, Number of Children, Current Location of Residency, Occupation, StartupBackground, Startups Name, Startups Details, Startups Field of Activity, SurveyQuestions’ Answers data may be transferred to the company providing server andinfrastructure services for Website and the Form.

11.  Period of Retention

YellowX storesPersonal Data in view of Data Minimization Principle, which necessitates PersonalData to be kept only for the required period. Required period is assignedconsidering the nature of the Personal Data, the potential risks of a PersonalData breach, processing reasons, and whether or not such reasons can beachieved in a different manner.

12.  Children’s Privacy

You should always check with your parents or guardians beforegiving out any information about you, especially before entering information onWebsite.

Below we summarize potential instances of collection ofPersonal Data where our services are directed at children between 13 and 18. Wealso outline how and when we will provide parental notice and/or seek parentalconsent.

In any instance that we collect Personal Data from a child,we will retain that information only so long as reasonably necessary to fulfillthe activity requested or allow you to continue to participate in the activity,and to ensure the security of our users and our services, or as required bylaw.

In the event we discover we have collected Personal Data fromor about a child in a manner inconsistent with legal requirements, we willeither delete the information or immediately seek the parent’s consent for thatcollection.

The Personal Data that we collect about children between 13and 18 generally falls within two categories: (a) information the parent provideto us, and (b) information we collect automatically when the child use oraccess our Website.

We do not aim any of our products or services directly atchildren under the age of 13 (a “Minor”). However we may offer servicesaiming high school students who are between 13 and18.

If we acknowledgethat any Personal Data processed by us, belongs to a Minor we shall take theappropriate measures to delete such Personal Data.

 

13.  Methods of Securing Personal Data

Appropriate technical and organizational measures are enacted to ensurethe safety, protection and the encryption of the Personal Data in order toprevent any Personal Data breach such that may be caused by accidental orunauthorized destruction, loss, theft or; unauthorized use, alteration anddisclosure.

In this context, YellowX ;

a.     Sign non-disclosureagreements with parties who have limited or unlimited access to Personal Data.

b.    Organize awarenesstrainings about data protection inside its organization.

c.     Entitles its employeeswith limited authorization according to their work line.

d.    Transfer Personal Dataon a ‘need-to-know’ basis.

e.     Process and storepersonal data on safely secured and encrypted cloud servers.

14.  Contact Information of YellowX

Data Subjects may contact YellowX in case of having questions,comments, or feedback via contact@yellowx.co

1.      Preamble

We, as Zillion (“Zillion”) a fully owned brand of YellowX OU (“YellowX”),give utmost importance to the privacy of our Visitors and Applicants duringtheir use of our websites with brand domain names https://www.zillionpitches.com and https://www.zillionpitch.co (“Websites”) and/or itssubdomains regardless of their country of access.

2.      Purpose of This Policy

This Privacy Policy (“Policy”)is prepared with a privacy-prioritizing attitude in order to provide detailedinformation to Visitors and Applicants regarding the identity of YellowX as adata controller; data processing and its legal bases, reasons; rights ofVisitors and Applicants (collectively “DataSubject”), which can be exercised against YellowX .

This Policy shall be read by Visitors and Applicants regardless of theirresidency or location of access. The personal information subject to processingmay differ from one action to another such as accessing to Website, requestinga demo, requesting to join a quiz challenge, or contacting us; and YellowX hereininforms you about how your personal data is handled in different cases.

3.      Scope of This Policy

a.      In Terms of Legislation

Since YellowX isan Estonia based company but has numerous Visitors and Applicants fromdifferent countries; it is hard to determine which legislation should beapplied to its activities and business. Therefore, YellowX intends to reflectits compliance with different legislations about privacy and data protection.For this reason, YellowX shows considerable effort to act in accordance withGeneral Data Protection Regulation (“GDPR”),Turkish Personal Data Protection Law No. 6698 (“PDPL”), CaliforniaConsumer Privacy Act (“CCPA”), andother applicable data protection regulations.

b.     In Terms of Related Person

This Policyincludes different Data Subjects with various motives such as somehow accessingand making a demo and/or access plan request, request to join a quiz challenge,in relation with the services provided by Zillion through the onlineapplication forms (“Form”). Even though Data Subject may bereferred as Visitor and Applicant according to their intention for using the Website,they will be covered in this Policy.

c.      In Terms of Data

Informationthat makes it possible for related person to be identified directly orindirectly by any other person (“PersonalData”) is in the scope of this Policy. Accordingly, it can be safely saidthat confidential information, which cannot be considered as Personal Data, isexcluded from this Policy.

4.     Identity of YellowX as a Data Controller

For any and all data processing that occurs through accessing Website and benefiting from theservices provided through the Website, YellowX OU, a registered company havingits address at Tammsaare Business Center A. H. Tammsaare tee 47 Tallinn, 11316Harju Maakond Estonia is a datacontroller (“Controller”).  

5.     Occasions for Personal Data Processing

YellowX processes personal data during includingwithout limitation below-mentioned situations:

·       accessing to the Website,

·       contacting to Zillionthrough Form,

·       making a request tojoin the quiz challenge through Form,

·       making a demo and/oraccess plan request through the Form.

6.     Principles for Processing Personal Data

YellowX considers below-mentioned principles whileProcessing Personal Data:

·       Processing PersonalData lawfully, fairly and in a transparent manner in relation to the DataSubject,

·       Processing PersonalData accurately and where necessary, kept up to date,

·       Processing PersonalData for specific, explicit, and legitimate purposes,

·       Processing PersonalData relevantly, limitedly, and proportionately to the purposes for which theyare processed,

·       Processing PersonalData in a manner that ensures appropriate security of the Personal Data andkept in a form which allows identification of Data Subjects for no longer thanit is necessary for the processing reasons.

7.     Processed Personal Data

Personal Data Collected by Us

Name-Surname

Cookie

Age

IP Address

E-Mail Address

Device &  Browser Type

Phone Number

Usage Information

Current Location of  Residency

Survey Questions’  Answers

Educational  Background

Occupation

Startup Background

Startups Name

Startups Details

Startups Field of  Activity

8.     Reasons and Legal Bases for Processing Personal Data

Personal Data given to or collected by us shall only be processed whennecessary for a reasonable cause and when there is a legal basis forprocessing. Reasons and legal bases of processing are listed limitedly in thisPolicy and this Policy will be updated if a reason or a legal basis change.

a.     Name-Surname

Processing Reasons-Legal Bases

Identifying the person wishing to contact YellowX - Legitimate interest

Identifying the person requesting a demo/an access plan - Legitimate interest

Identifying the person wishing to join the  quiz challenge - Legitimate interest

b.    Age

Identifying the person wishing to contact YellowX - Legitimate interest

Identifying the person wishing to join the  quiz challenge - Legitimate interest

c.     E-Mail Address

Communicating with the person regarding his/her requests and/or  questions - Legitimate interest

Contacting about demo/access plan request - Legitimate interest

Contacting about quiz challenge - Legitimate interest

d.    Phone Number

Contacting about demo/access plan request to Zillion - Legitimate interest

e.     Current Location of Residency

Evaluating the demo request and eligibility for its attendance to YellowX  - Legitimate interest

Evaluating the demo request of the parent and eligibility of the high  school children for its attendance to Zillion Academy - Legitimate interest

f.      Startup Background

Responding to the requests and/or questions of the person in connection  with its startup status - Legitimate interest

Contacting about demo/access plan request - Legitimate interest

Preparing proper offers for the person wishing to join the free  Demo - Legitimate interest

g.     Startups Name

Identifying the startup wishing to contact YellowX - Legitimate interest

Identifying the startup requesting a demo/an access plan - Legitimate interest

h.    Occupation

Evaluating the demo/access plan request - Legitimate interest

i.      Startups Field of Activity

Evaluating the demo/access plan request - Legitimate interest

Listing and Sorting the Startup to   provide customized offers - Legitimate interest

j.      Startups Details

Evaluating the demo/access plan request - Legitimate interest

k.     Cookie

Improving the Website - Legitimate interest

l.      IP Address

Complying with legal obligation - Legal obligation

m.   Device & Browser Type

Improving the Website - Legitimate interest

n.     Usage Information

Improving the Website - Legitimate interest

o.     Survey Questions’s Answers

Preparing proper questions for the person wishing to join the program - Legitimate interest

Improving the Website - Legitimate interest

9.     Rights of Data Subjects

Data Subjects are endowed with some rights to ensure their Personal Datato be processed on a lawful basis. Website is designed in compliance with thePrivacy by Design and Data Protection by Design principles. Therefore, alongwith the below-mentioned rights, Data Subjects have a right to opt-out from theWebsite via an e-mail, which ends up with their Application data to be deleted.

a.      Right to be informed, by which the Data Subject may requestinformation about their Personal Data being processed by YellowX.

b.     Right of access, by which the Data Subject may request tolearn their Personal Data being processed by YellowX.

c.      Right of rectification, by which the Data Subject may request YellowXto correct or complete their Personal Data.

d.     Right to restrict processing, by which the Data Subject mayrequest to limit the way their Personal Data is used.

e.      Right to erasure, by which the Data Subject may request tohave their Personal Data erased.

f.       Right to data portability, by which the Data Subject mayrequest to receive their Personal Data in a machine-readable format and/orrequest YellowX to transfer their Personal Data to another controller.

g.      Right to object, by which the Data Subject may request YellowXto stop processing their Personal Data.

h.     Rights in relation to automated decision-making, by which the Data Subject mayrequest YellowX to stop processing their personal data in cases where PersonalData is being processed via automated decision-making.

10.  Transfer of Personal Data

YellowX transfers Personal Data to third parties only when there is an explicit and informed consent from the Data Subject except for the below-mentioned cases, which havetheir own legal bases for the transfer:

a.      Law Enforcement and Judiciary Authorities: YellowX may be obliged to disclose Personal Data when required to do soby law, including but not limited to legal claims, legal investigations, lawfulrequests, or legal proceedings.

b.     Server, Infrastructure Services & Form Service Providers (TypeformS.L.) : Name-Surname, Age, E-Mail Address, PhoneNumber, Number of Children, Current Location of Residency, Occupation, StartupBackground, Startups Name, Startups Details, Startups Field of Activity, SurveyQuestions’ Answers data may be transferred to the company providing server andinfrastructure services for Website and the Form.

11.  Period of Retention

YellowX storesPersonal Data in view of Data Minimization Principle, which necessitates PersonalData to be kept only for the required period. Required period is assignedconsidering the nature of the Personal Data, the potential risks of a PersonalData breach, processing reasons, and whether or not such reasons can beachieved in a different manner.

12.  Children’s Privacy

You should always check with your parents or guardians beforegiving out any information about you, especially before entering information onWebsite.

Below we summarize potential instances of collection ofPersonal Data where our services are directed at children between 13 and 18. Wealso outline how and when we will provide parental notice and/or seek parentalconsent.

In any instance that we collect Personal Data from a child,we will retain that information only so long as reasonably necessary to fulfillthe activity requested or allow you to continue to participate in the activity,and to ensure the security of our users and our services, or as required bylaw.

In the event we discover we have collected Personal Data fromor about a child in a manner inconsistent with legal requirements, we willeither delete the information or immediately seek the parent’s consent for thatcollection.

The Personal Data that we collect about children between 13and 18 generally falls within two categories: (a) information the parent provideto us, and (b) information we collect automatically when the child use oraccess our Website.

We do not aim any of our products or services directly atchildren under the age of 13 (a “Minor”). However we may offer servicesaiming high school students who are between 13 and18.

If we acknowledgethat any Personal Data processed by us, belongs to a Minor we shall take theappropriate measures to delete such Personal Data.

 

13.  Methods of Securing Personal Data

Appropriate technical and organizational measures are enacted to ensurethe safety, protection and the encryption of the Personal Data in order toprevent any Personal Data breach such that may be caused by accidental orunauthorized destruction, loss, theft or; unauthorized use, alteration anddisclosure.

In this context, YellowX ;

a.     Sign non-disclosureagreements with parties who have limited or unlimited access to Personal Data.

b.    Organize awarenesstrainings about data protection inside its organization.

c.     Entitles its employeeswith limited authorization according to their work line.

d.    Transfer Personal Dataon a ‘need-to-know’ basis.

e.     Process and storepersonal data on safely secured and encrypted cloud servers.

14.  Contact Information of YellowX

Data Subjects may contact YellowX in case of having questions,comments, or feedback via contact@yellowx.co