YYH NOVA SA PRIVACY NOTICE AND INFORMATION ON DATA PROTECTION

The processing and retention of personal data and/or special categories of personal data in accordance with international data protection standards and applicable data protection legislation is of great importance. Accordingly, YYH NOVA SA (hereinafter referred to as “YYH NOVA SA” or the “Company”) acts in compliance with the applicable data protection regulations with regard to the protection, retention and processing of your personal data and/or special categories of personal data.

We frequently collect data from you through online channels. Personal data and/or special categories of personal data collected and recorded when you visit our website are processed in accordance with the applicable data protection principles and legislation. In this respect, YYH NOVA SA, in its capacity as the Data Controller, collects and retains your data within the limits permitted by law. We would also like to emphasize that all personal data and/or special categories of personal data collected during your visit to our website are also protected under our Privacy Policy. You may review our Privacy Policy, which is available on our website, for further information.

This Privacy Notice has been prepared by YYH NOVA SA , in its capacity as the Data Controller, in accordance with data protection regulations and the principle of transparency.

1.WHAT IS PERSONAL DATA?

Personal data is defined as “any information relating to an identified or identifiable natural person.” As is apparent from this definition, any information that makes you identifiable constitutes personal data.

In addition, data concerning political opinions, religious or sectarian beliefs, race, religion, membership of associations or foundations, health information, philosophical beliefs, convictions, sexual preferences, criminal records, criminal convictions and biometric data constitute special categories of personal data.

2.LEGAL BASIS AND DATA CONTROLLER

The applicable data protection legislation requires data subjects whose personal data are processed to be informed prior to the commencement of data processing activities.

The Data Controller is the natural or legal person who determines the purposes and means of processing personal data and who is responsible for the establishment and management of the data filing system. A Data Processor, on the other hand, means the natural or legal person who processes personal data on behalf of and under the authority granted by the Data Controller.

In this regard, the Data Controller is YYH NOVA SA, the website of which you are visiting. The details of the Data Controller are as follows:

Company Name : YYH NOVA SA
Address : Rue du Marché 20 1204 Geneva, Switzerland
Tel : +41 79 587 52 28
E-mail : info@yyhnova.com

3.SCOPE OF THE DATA CONTROLLER YYH NOVA SA’S INFORMATION OBLIGATION

As explained above, YYH NOVA SA is the Data Controller. In its capacity as Data Controller, YYH NOVA SA informs you, through this Privacy Notice, about by whom and for what purposes your personal data may be processed, to whom and for what purposes your data may be transferred, the methods and legal grounds for collecting your data, and the rights available to you as a data subject concerning the protection of your personal data.

4.PURPOSES FOR WHICH YOUR DATA ARE PROCESSED BY YYH NOVA SA

Your personal data are processed within the limits prescribed by data protection regulations and in accordance with the applicable general principles.

As YYH NOVA SA, our purposes for processing personal data include:

- Increasing the quality of the products and services offered to you;
- Ensuring that you are promptly informed about innovations within YYH NOVA SA and about the products and services offered;
- Identifying individual needs and purposes of use and, accordingly, providing goods and services tailored to you as our customers;
- Conducting YYH NOVA SA’s commercial activities and ensuring the complete and proper performance of our obligations towards you;
- Informing you about changes and developments concerning our products and services and providing the necessary information and notices where required;
- Enabling you to benefit from the products and services offered by our Company in the best possible manner;
- Developing and determining our commercial partnerships and strategies, establishing them on a secure basis, and enabling appropriate decision-making in our commercial policies and managerial operations;
- Establishing our corporate identity on a sound basis and ensuring effective corporate operations;
- Achieving the objectives of our internal Company policies and thereby increasing customer satisfaction;
- Ensuring information security;
- Developing the goods and services offered by YYH NOVA SA through online channels;
- Resolving any issues or adverse circumstances that may arise as quickly as possible;
- Communicating with persons who submit requests or complaints to YYH NOVA SA;
- Ensuring compliance with the provisions of the Privacy Policy available on our website.

5.PRINCIPLES REGARDING THE PROCESSING OF YOUR DATA

As YYH NOVA SA, we have adopted the following principles in relation to the processing of your personal data:

Retaining personal data for the period stipulated under applicable legislation or for the period necessary for the purposes for which they are processed;
Processing data in accordance with the law and the principles of good faith;
Ensuring that data are accurate and up to date;
Not using data for purposes other than those for which they were collected and processed;
Ensuring that data processing is proportionate and limited to the purposes for which the data are processed;
Processing data in accordance with generally accepted standards of morality, customs and practices;
Processing data in compliance with all applicable legislation and universally recognized data protection principles.

6.METHOD OF PROCESSING DATA

a-Your personal data may be processed by YYH NOVA SA in the following two circumstances:

EXPLICIT CONSENT
LEGAL AND LAWFUL GROUNDS (circumstances where explicit consent is not required)

b-Circumstances Where Explicit Consent Is Not Required

Under data protection regulations, explicit consent is not required in certain circumstances for the processing of personal data. These circumstances include:

- Where the processing is expressly provided for by applicable legislation or legal regulations;
- Where processing is necessary to protect the life or physical integrity of the data subject or another person who is unable to express consent due to a de facto impossibility or whose consent is not legally recognized as valid;
- Where processing is necessary for the performance of a contract or directly related to the establishment or performance of a contract, provided that the processing concerns the personal data of the parties to the contract;
- Where processing is necessary for the Data Controller to fulfill its legal obligations;
- Where the personal data have been made public by the data subject;
- Where processing is necessary for the establishment, exercise or protection of a legal right;
- Where processing is necessary for the legitimate interests of the Data Controller, provided that such processing does not adversely affect the fundamental rights and freedoms of the data subject;

Where any of the above circumstances apply, YYH NOVA SA may process your personal data without obtaining your explicit consent.

With regard to special categories of personal data, we may process personal data other than data relating to health and sexual life without obtaining explicit consent where permitted under applicable legislation

Personal data relating to health and sexual life may, without the explicit consent of the data subject, only be processed by persons or authorized institutions and organizations subject to a duty of confidentiality for purposes such as the protection of public health, preventive medicine, medical diagnosis, treatment and care services, and the planning and management of healthcare services and their financing.

7.METHOD AND LEGAL BASIS FOR COLLECTING YOUR DATA

In today's evolving technological environment, our Company collects data through various channels. Our website is one of the channels through which personal data are collected by automated means.

Personal data and/or special categories of personal data collected through the website within YYH NOVA SA are processed on the basis of applicable legal grounds or, where required, explicit consent.

Depending on the category and type of data processed, we inform the relevant data subject accordingly. In the relevant information notices, we provide explanations regarding the purposes for which the data will be processed, the persons or entities to whom and purposes for which the data may be transferred, the method and legal basis for data collection, and the rights of the data subject, and obtain explicit consent where required.

8.TRANSFER AND PROTECTION OF YOUR DATA

a-Transfer

Your data may be transferred to third parties, where necessary, in accordance with data protection principles and the terms and conditions set forth in our confidentiality agreements.

For each category of data transferred, the Information Notice provided prior to the collection of the relevant data contains detailed information regarding the purposes for which and the persons or entities to whom such data may be transferred.

In all circumstances, YYH NOVA SA acts in compliance with applicable legislation and international standards concerning data transfers when transferring personal data. In addition, the necessary technical and administrative measures are implemented.

b-Protection

Data protection regulations primarily aim to ensure the protection of personal data and prevent unauthorized transfers.

In this regard, we ensure that our internal Company policies comply with applicable data protection principles and standards, and order to prevent the transfer of data to unauthorized third parties, particularly in accordance with applicable legislation, YYH NOVA SA takes the necessary technical and administrative measures.

In this regard, we ensure that our internal Company policies comply with applicable data protection principles and standards, and we maintain the necessary technical software and hardware for the protection of personal data.

To achieve these objectives, we take appropriate measures to prevent both our employees and the third parties with whom we conduct business from acting contrary to our Privacy Policy.

9.RIGHTS OF THE DATA SUBJECT

a-General Information Regarding Application

Under data protection regulations, data subjects are granted certain rights to make requests concerning the processing of their personal data.

Accordingly, the rights of the data subject include:

a) To learn whether their personal data are being processed;
b) To request information concerning the processing of their personal data, where such data are being processed;
c) To learn the purpose of processing their personal data and whether such data are being used in accordance with that purpose;
ç) To know the third parties, whether located domestically or abroad, to whom their personal data have been transferred;
d) To request the correction of their personal data where such data have been processed incompletely or inaccurately;
e) To request the deletion, destruction or anonymization of their personal data within the framework of the applicable legal requirements;
f) To request that third parties to whom personal data have been transferred be notified of the correction of incomplete or inaccurate data or of the deletion or destruction of such data upon the request of the data subject;
g) To object to the occurrence of a result against the data subject where the processed data have been analyzed exclusively by automated systems;
h) To request compensation for damages incurred as a result of the unlawful processing of their personal data.

You may submit requests concerning the above-mentioned rights to our Company in accordance with the procedures specified in this Privacy Notice. YYH NOVA SA will respond to such requests as soon as possible and, in any event, within thirty (30) days at the latest.

Applications must be submitted personally by the data subject. YYH NOVA SA will only consider applications submitted by the relevant data subject and will provide information concerning the application only to the applicant.

b-Application Procedure

You may submit your requests concerning the above-mentioned rights to YYH NOVA SA, in its capacity as Data Controller, in writing or through any of the following means:

Registered Electronic Mail (REM/KEP);

Secure electronic signature;

Mobile signature; or

The e-mail address previously notified by the data subject to the Data Controller and registered in the Data Controller’s system.

To exercise your rights concerning your personal data, you may review the relevant information available on our website and use the “Personal Data Information Request Form” available on our website.

c-formation Required in an Application

Your application must contain the following information:

Your full name and surname;
Your identity card or passport number;
If you are a foreign national, your nationality, passport number or, if available, identity number;
If submitting a written application, your wet-ink signature at the bottom of the request form;
A clear and specific description of your request;
Your telephone and/or fax number(s) through which we can contact you;
Your e-mail address through which we can contact you;
Your residential or business address for service of notices.

OUR COMPANY’S DETAILS ARE AS FOLLOWS:

Company Name : YYH NOVA SA
Address : Rue du Marché 20 1204 Geneva, Switzerland
Tel : +41 79 587 52 28
E-mail : info@yyhnova.com