The information provided may be subject to revision. Users are invited to periodically visit this page, in order to be constantly updated on the characteristics of the treatment.
Last updated: 2019/05/30
This policy explains what information we collect when you use WeYourConsult’s sites, services, mobile applications, products and content (“Services”).
Our goal is not just to respect the privacy law. It’s earning your trust.
Information we collect and how we use it
WeYourConsult does not make money from ads. We therefore do not collect data for advertising. The monitoring we do on WeYourConsult serves to make our product work in the best possible way. To give you the best possible experience using WeYourConsult, we collect information from your interactions with our Services. You actively communicate some of this information (such as your email address, which we use to track your account or communicate with you). Other information, we collect based on the actions you take while using WeYourConsult, such as which pages you view (including the quantity of a particular page and for how long) and the use of product features. This information includes records of those interactions, your Internet Protocol address, information about your device (such as your device or browser type), and referral information (how you got to a particular page).
This site and the services offered are not intended for minors under the age of 18 and the Data Controller does not intentionally collect personal data relating to minors. In the event that information on minors were unintentionally registered, the Data Controller will delete them in a timely manner, at the request of the users.
We use this information to:
- provide, test, improve, promote and customize the Services
- fight spam and other forms of abuse
- generate aggregate, non-identifying information about how people use the Services
Revelation of information
WeYourConsult will not transfer information about you to third parties for the purpose of providing you with or facilitating third party advertising. We will not sell information about you to third parties.
We may transfer your account information to third parties in certain circumstances, including: (1) with your consent; (2) to a service provider or partner who meets our data protection standards; (3) with academic or non-profit researchers, with aggregation, anonymisation or pseudonymisation; (4) when we have a good faith belief that it is required by law, such as under a subpoena or other legal process; (5) when we have a good faith belief that this will help prevent imminent harm to someone.
If we share your information in response to legal process, we will notify you so that you can contest it (for example by seeking court intervention), unless we are prohibited by law or we believe doing so may endanger others or cause illegal conduct. We will oppose lawful requests for information about users of our services that we believe are improper.
Search engines can index your WeYourConsult user profile page, public interactions (such as claps or highlights), and post pages, so that people can find these pages when they search for your name on services like Google or Bing. Users can also share links to your content on social media platforms like Facebook or Twitter.
WeYourConsult uses third party vendors and hosting partners, such as AWS, for the hardware, software, network, storage and related technology we need to run WeYourConsult. We keep two types of logs: server log and event log. By using the Services, you authorize WeYourConsult to transfer, store and use your information in the European Union and in any other country in which we operate.
Third Party Embeds
Some of the content you see displayed on WeYourConsult is not hosted by WeYourConsult. These “embeds” are hosted by a third party and incorporated into a WeYourConsult page, so that it appears to be part of that page. For example: YouTube or Vimeo videos, Screencast, TikTok, TED, Videopress, Imgur or SmugMug gifs, SoundCloud, Spotify or Mixcloud audio files, Twitter tweets, GitHub code snippets or Scribd documents, Cloudup, Crowdsignal, Isuu, Kickstarter , Meetup or Slideshare, which appear within a WeYourConsult post. These files send data to the hosted site just as if you were visiting that site directly (for example, when you load a WeYourConsult post page with an embedded YouTube video, that video is displayed due to a pointer to the files hosted by YouTube and to its Once YouTube receives data about your activity, such as your IP address and the amount of videos you watch).
When you post on WeYourConsult, you cannot embed a form that allows users to submit personal information (unless the feature is enabled). You must create an off-site link to a page that allows such submissions by users, and the appearance of that page must be sufficiently distinct from WeYourConsult to ensure that it does not cause confusion among users to whom they are submitting personal information. If not, WeYourConsult may disable the post or take other actions to limit or disable your account.
We use browser cookies and similar technologies to recognize you when you return to our Services. We use them in various ways, for example to log in, remember your preferences (such as the default language), evaluate the effectiveness of email, allow our paywall and counter to work, and personalize content and other services. Without cookies, our measured paywall would not work, so they are necessary for the basic functionality of WeYourConsult.
We track your interactions within the WeYourConsult Services (which includes weyourconsult.com, the custom domains hosted by WeYourConsult).
Change or delete your personal information
If you have a WeYourConsult account, you can access, modify or export your personal information or delete your account here: https://weyourconsult.com/en/membri/user/settings/
To protect information from accidental or malicious destruction, we may keep residual copies for a short period of time (typically several weeks). However, if you delete your account, your information and content will no longer be recoverable after this period. WeYourConsult may retain and retain copies of your information beyond this period of time when required by law.
We use encryption (HTTPS / TLS) to protect the data transmitted to and from our site. However, no data transmission over the internet is 100% secure, so we cannot guarantee security. You use the Service at your own risk and are responsible for taking reasonable steps to protect your account.
Email from WeYourConsult
We will occasionally send you emails about your account, service changes, or new policies. You cannot opt out of this type of “transactional” email (unless you delete your account). However, you can opt out of non-administrative emails such as summaries, newsletters and activity notifications via your account page: https://weyourconsult.com/my-account/?lang=en
When you interact with an email sent by WeYourConsult (for example by opening an email or clicking on a particular link in an email), we may receive information about that interaction.
We will not send you emails asking for your password or other account information. If you receive such an email, please forward it to email@example.com so we can investigate.
Changes to this Policy
WeYourConsult may periodically update this Policy. We will notify you about significant changes to it. The most recent version of the policy will always be here: https://weyourconsult.com/privacy-policy/?lang=en
We welcome feedback on this policy at firstname.lastname@example.org.
Data protection declaration for users of the European Union
This section constitutes information provided pursuant to art. 13 and 14 of EU Regulation 2016/679 (GDPR). Further information may be provided on specific pages, where applicable and/or necessary.
Description of the processing activity
WeYourConsult collects and stores personal information about its users to personalize their reading experience and allow personalized content distribution. It shares minimal data with its service providers.
Holder of the treatment
WeYourConsult Srls with single shareholder
Carlo Goldoni street n.1, 20129 Milan (MI) – Italy
E-mail: email@example.com – firstname.lastname@example.org
Purpose of the processing
- Provide, test, promote and improve the Services
- Collect service usage statistics and ratings
- Provide a personalized reading experience
- Publish and distribute user-generated content
- Provide access to paid content
- Pay commissions for certain services offered by Partners, when applicable
- Fight spam, fraud and other abuse of services
We also collect data for:
- the provision of the site navigation service, the legitimate interest of the owner as well as the obligations established by law (Article 6.1.b/c/f of the GDPR).
- respond to a request for contact or information sent via the appropriate form (pre-contractual measures art. 6.1.b GDPR – maximum retention 12 months for internal management and organizational purposes).
- For sending information and commercial communications/newsletters via e-mail (specific consent art. 6.1.a GDPR – duration: 2 years for internal management and marketing purposes or immediate cancellation in case of cancellation request).
WeYourConsult also pursues its legitimate interests by collecting the minimum data of disconnected users to provide the Services, as described above, as well as to ensure that new users who try the free member preview do not exceed the maximum limit of free items per month prior to ‘paid subscription required to read further. These legitimate interests do not outweigh (nor violate) the privacy interests of our users because we collect minimal user data for these purposes and are completely transparent about these activities.
Where WeYourConsult collects and stores personal data about non-users mentioned in user generated content, it does so in fulfillment of contractual obligations to users who use the Services to post content on WeYourConsult websites. In such cases, users who create such user-generated content containing third party personal data are responsible for such content. WeYourConsult will consider related complaints in accordance with the data subject’s rights of the General Data Protection Regulation, as well as the rights of expression and access to information.
Public nature of personal data
Logged in users may choose to publicly interact with the Services in the form of applause for a post, highlighting parts of a post, following other user accounts, sharing links on linked social media accounts, or writing original posts. Where such personal data may reveal protected special category data, it is processed on the basis that it is manifestly made public by the user. More information on the potential consequences of such treatment can be found below. If you do not agree to this public use, do not create an account or use these features of the Services.
Search engines can index your WeYourConsult user profile page, public interactions (such as claps or highlights), and post pages. Users can also share links to your content on social media platforms like LinkedIn, Facebook or Twitter.
Categories of personal data collected
Logged out users:
- Read history
- IP address
- Browser information
- DNT status
- Display name
- Image of the avatar
- Email address (non-public)
- Session Activity (Security)
- Connected social media accounts (optional)
- IP address
- Domain name of the computer
- Browser information
- Reading history (only on WeYourConsult services)
- Network interactions (recommend, follow, etc.)
- Posts, replies or series published by the user
- Billing information and history
- Bank account for payments
- Commercial information, if applicable
Categories of Recipients
WeYourConsult shares minimal personal data with third party processors in order to provide the Services. These processors offer at least the same level of data protection as that established in this policy. This includes the following categories of recipients:
- Hosting, storage and other infrastructure
- Communication and support
- Payment Processors
WeYourConsult provides Services in combination with different payment processors, including: Stripe, PayPal, through which users can pay for WeYourConsult subscriptions based on participation in our Partner program. Such companies acting as payment processors may collect and store personal data related to billing information and history in order to provide their services and may collect and store personal data and business data to prevent fraud and other abuse.
When you delete your WeYourConsult account, WeYourConsult deletes your personal data as explained in this policy. However, to delete your payment or billing information, you will need to do so with your payment service provider, as WeYourConsult only has minimal secure access to those records necessary to provide the Services.
Use of algorithms to personalize the user experience
WeYourConsult collects and stores personal data about its users to personalize their reading experience by displaying personalized content based on the preferences and interests indicated by users (including through their reading history and the interactions of the Services). This does not constitute an automated decision-making process as this phrase is used in the GDPR because it does not produce legal effects or equally significant effects for users. WeYourConsult also moderates content for the purpose of fighting and preventing spam, fraud and other forms of abuse and may rely on algorithms to do so.
Potential consequences of the treatment
By creating and using an account on WeYourConsult, users can make certain personal data about themselves, their profile and through network interactions public and accessible to others. These may in some cases constitute protected data of a special category which are considered to be made manifestly public by the user.
Due to the public nature of the information posted on WeYourConsult, it may be possible for third parties to derive personally identifiable data from posts, through reading, deduction, supplementary research, or automated extraction and analysis. If you disagree and do not accept the risks of such use, you cannot use the Services.
WeYourConsult is hosted in the European Union. By using the Services, you authorize WeYourConsult to transfer, store and use your information in the European Union and in any other country in which we operate. Where your data is disclosed to our data processors, they are contractually subject to at least the same level of data protection as that set out in this policy.
WeYourConsult retains the personal data associated with your account for the duration of your account. If you wish to delete your personal information, you can delete your account at any time. Deleted account profile pages will produce a 404 “file not found” error page immediately after the deletion begins and will become unrecoverable in our system. It may take several additional days for personal data to be de-indexed from search engines, depending on the practices of those search engines, over which WeYourConsult may have limited or no control.
To delete your payment or billing information, you will need to do so with your payment service provider, as WeYourConsult only has minimal access to those records necessary to provide the Services.
Rights of interested parties
In accordance with the rights provided for in articles 15 to 22 of the GDPR:
- If you register with a WeYourConsult account, you can at any time request the export of your personal data from the Settings page: https://weyourconsult.com/members/user/settings/.
- You can correct the information associated with your account from the Settings page and from the Personalize your interests page to update your interests.
- You can withdraw consent by deleting your account at any time via the Settings page: https://weyourconsult.com/members/user/settings/, Delete Account which will completely delete your personal information (except to the extent WeYourConsult cannot delete your information by law).
- You can object to the use of your personal data at any time by contacting email@example.com. If your complaint concerns an alleged misuse of your personal data by a third party, it may lead to the suspension of that post or account in accordance with the relevant law, the public interest, our contractual obligations and the rights of expression and access to information of others.
- Under EU law, you have the right to lodge a complaint about WeYourConsult’s processing of your personal data with the dedicated Supervisory Authority of your EU member state.
Requests for access to subjects
For security and account ownership verification purposes, we process subject login requests and account deletion requests only from the account holder. We are unable to process requests made by third party services.
You can access the self-service download tool: https://weyourconsult.com/mio-account/downloads/ and the account deletion mechanism by logging into your account and navigating to https://weyourconsult.com/en/membri/user/settings/.
Consumer Privacy for California Users
If you are a California resident, the processing of certain personal data about you may be subject to the California Consumer Privacy Act (“CCPA”) and other applicable California state privacy laws. As of January 1, 2020, the CCPA grants you certain rights in relation to the processing of your personal data (known as “personal information”, as described in the CCPA).
This section provides additional privacy notices and informs you of your key additional rights as a California resident.
Request for the right to know
Under the CCPA, you have the right to request information about our collection, use and disclosure of your personal information in the previous 12 months and ask to provide you with the following information:
- Categories and specific pieces of personal information that we have collected about you.
- Categories of sources from which we collect personal information.
- Purposes for the collection, use or sale of personal information.
- Categories of third parties with whom we share personal information.
- Categories of personal information disclosed about you for business purposes.
- If applicable, categories of personal information sold about you and categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold.
To make a verifiable request for information about the personal information we have collected about you, log into your account profile to make a request by going to your Settings page here: https://weyourconsult.com/membri/user/settings, scrolling to down and clicking the Export Data button to make a request to download the information. You can also email us at firstname.lastname@example.org.
Right to cancel the request
Under the CCPA, you also have the right to request deletion of personal information, subject to certain exceptions. You can exercise your right to cancel if you have a WeYourConsult account by going to your settings page here: https://weyourconsult.com/mebers/user/settings, scrolling down to ‘Delete Account’. You can also email us at email@example.com.
We do not knowingly collect data on families. If all family members make a right to know or right to erasure request, we will respond as if the requests were individual requests.
General requests under the CCPA
If you do not have a WeYourConsult account, we will not have enough information about you to verify your Right to Know and Right to Erasure requests as we do not hold enough information to re-identify you and connect you to a previous WeYourConsult visit. You can make a verifiable consumer request for your personal information twice for a period of 12 months. We will not discriminate against you for exercising any of your rights under the CCPA.
Requests made through Agents
You can designate, in writing or by a power of attorney, an agent who is authorized to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof that you have authorized them to act on your behalf and we may need you to verify your identity directly with us.
Disclosure of personal information for a commercial purpose
In the last 12 months, WeYourConsult has disclosed some data of the following categories of personal data to the categories of recipients listed above in the “Categories of recipients” for one or more commercial purposes:
- Display name
- Image of the avatar
- Email address (non-public)
- Billing information and history
- Bank account for payments
- Commercial information, if applicable
No sale of personal information
Under the CCPA, a “sale” means providing personal information to a third party for consideration. Since WeYourConsult does not make money from ads, we do not collect data to facilitate or allow third parties to advertise to you. Currently and pending the final regulations and interpretation guidelines of the CCPA, we do not believe that any of our data practices constitute a “sale” under the CCPA.
You can contact us by sending us an email at firstname.lastname@example.org.