Applicable to all services and software applications operated by You. Smart. Thing. Limited (“YST”), a UK company registered in England with company number 09329352.

Our Principles, Privacy Policy & Terms of Use cover all YST applications, including www.yousmartthing.com, www.tocability.com and the ‘Travel Assistant’ web application (www.travel.yousmartthing.com). They are designed for viewing by partners, clients, prospects and the general public.

YST is committed to protecting your personal information and providing safe and secure environments for users of its services. Our Principles, Privacy Policy & Terms of Use are intended to inform you about how we publish, collect and use information and how we operate our business in an ethical manner.

OUR PRINCIPLES

YST’s provision of personal information management applications is based on Hub-of-All-Things (HAT) research, a unique approach to secure personal data management developed through a program of consultation between industry and the UK’s leading Universities. As such in addition to our Privacy Policy & Terms of Use (detailed below) our applications adhere to 5 key principles:

YST reserves the right to change how we handle the information we collect and process through our applications at any time. We will update our Terms of Use and Privacy Policy to reflect any changes and such changes will take effect immediately upon being published.

OUR PRIVACY POLICY

What type of information do we collect from you and how do we use it?

Visitors to YST websites and applications may use them without providing us with any personally identifiable information (“PII”), such as your name, address, email address, and phone number. You may, however, submit PII to us by sending an email to the YST addresses listed on the ‘Contact’ section of www.yousmartthing.com, via contact or registration forms and otherwise by participating in events that we may sponsor from time to time. Unless you provide PII to us in this manner, we will collect only non-PII from you. If you do not want us to have any of your PII, please do not email us.

There are several ways that we may collect non-PII from you. For instance, we may collect information about your use of YST applications by using cookies, action tags and other methods. Cookies are small text files that identify your computer. We may use cookies to, among other things, monitor application usage, customise features, and identify your computer’s operating system and browser. (An action tag is a small, graphic image on a webpage that is designed to allow the website owner or a third party to monitor who is visiting a website by collecting the IP address of the computer to which the tag is sent, the URL of the webpage that the tag comes from and the time that such webpage was viewed. Such tags also may be associated with cookie information.)

Do I have the ability not to be identified by YST?

Yes. If you do not want to be identified by us when visiting YST websites, you can set your browser to warn you before accepting cookies and refuse cookies when your browser alerts you to its presence. You can also adjust the settings in your browser to refuse all cookies. If you do not want us to have any of your PII, do not submit any of your PII to us. If you do not want to be identified by us when using YST mobile applications you have the option to use them without registering your personal details.

Do we transfer or release any PII collected from you?

If you provide PII to us, we will use such PII for internal purposes only, in our sole discretion, unless we otherwise expressly disclose other uses to you. YST will not sell your PII to third parties unless you consent in writing to such use of your PII by YST.

Notwithstanding the foregoing, in the event that you do provide us with PII, we may release such PII if (i) we believe that such a release is necessary to comply with the law (e.g., a legal process or a statutory authorisation), (ii) to protect our rights or property, or (iii) in the event of any reorganisation, merger or consolidation involving YST.

Do we provide links to other websites or applications?

YST may provide links to other websites, applications or resources of possible interest to you. Because we have no control over such websites, applications or resources, their collection and use of your PII and other information shall be subject to the policies and procedures of such services and not this Privacy Policy. We encourage you to always review the privacy policy of each website you visit to determine how your information will be collected and used.

How do we store information?

YST takes steps consistent with commercially reasonable industry standards to secure any PII collected from you from loss, misuse, unauthorized access and destruction while under our control. Please note that despite our efforts to protect information provided to us, we cannot guarantee that such information will not be lost, disclosed or accessed by accidental circumstances or by the unauthorised acts of others.

What are our policies regarding children?

YST does not knowingly collect personally identifiable information from anyone under thirteen (13) years of age.

Do we have a mechanism to address complaints about the handling of information that we collect?

If you have questions or concerns about any of our information collection or handling practices, please contact us using the details on our ‘Contact’ page.

TERMS OF USE

By accessing, browsing and/or using YST applications, you acknowledge that you have read, understood, and agree, to be bound by these terms and to comply with all applicable laws and regulations. If you do not agree to these terms, please do not use YST applications.

YST applications may contain other proprietary notices and copyright information, the terms of which must be observed and followed. Information in YST applications may contain technical inaccuracies or typographical errors. Any information that is sent to YST through a website will be deemed not to be confidential. If you do send information to YST via a website you grant us the right to use, reproduce, display, perform, modify, transmit and distribute that information, however, WE WILL NOT DISTRIBUTE ANY PERSONAL DETAILS UNLESS WE OBTAIN YOUR PERMISSION TO DO SO OR ARE REQUIRED TO DO SO BY LAW.

Restrictions on use:

YST reserves the right to authorise you to solely view and retain a copy of the pages on YST applications for your own personal use. You must not duplicate, modify or distribute the material on the site unless specially authorised in writing by YST to do so.

Disclaimer:

YST assumes no responsibility regarding the accuracy of the information that is provided by YST and use of such information is at the recipient’s own risk. YST provides no assurances that any reported problems will be resolved with regard to the use of any information that it provides, but will always endeavour to help assist to the best of the companies capabilities. By furnishing information, YST does not grant any licenses to any copyrights, patents or any other intellectual property rights.

YST may change or update information without notice and also make improvements and/or changes in the applications, products and/or the programs described in this information at any time without notice.

MODERN SLAVERY & HUMAN TRAFFICKING POLICY

Introduction

Modern slavery is a heinous crime and a morally reprehensible act that deprives a person’s liberty and dignity for another person’s gain. It is a real problem for millions of people around the world, including many in developed countries, who are being kept and exploited in various forms of slavery. Every company is at risk of being involved in this crime through its own operations and its supply chain.

At You. Smart. Thing. (“YST”) we have a zero-tolerance approach to modern slavery and are fully committed to preventing slavery and human trafficking in our operation and supply chain. We have taken concrete steps to tackle modern slavery, as outlined in our statement. This statement sets out the actions that we have taken to understand all potential modern slavery risks related to our business, and to implement steps to prevent slavery and human trafficking during the financial year 2020.

Our business and supply chains

YST provides is a cloud-based destination management platform for organisations that need to manage people-flow, travel demand and visitor experience. Uniquely positioned in this £14Bn global market, it combines identity governance technology with an innovative distributed ‘Travel Assistant’ interface. By embedding the Travel Assistant into existing customer touchpoints, its licensors can offer up-to-date personalised travel assistance, manage travel demand and curate the visitor experience to venues and events, anywhere in the world.

Customers and their location

Since 2015, YST has pioneered a new approach to personal data management. Its application in the field of intelligent mobility has led to research and development contracts with Arriva UK Trains, the Rail Safety Standard Board, Rail Delivery Group, the West Midlands Combined Authority and Transport for London. Whilst continuing to deliver R&D consultancy to this established public-sector client base, during 2019, building on successful proof-of-concept trials, YST launched its ‘Travel Assistant’ Software-as-a-Service platform via a series of regional deployments. Our UK partnerships are being expanded to maximise domestic coverage, creating a stepping- stone to export markets.

Suppliers and their location

System capabilities are enabled through our hybrid state-of-the-art technology stack, utilising Microsoft, Linux, Docker; Apache, NGINX, Mongo Db, Gravitee, SAP; our propriety consent matrix and an Application Programming Interface (API), allowing the Travel Assistant to perform a ‘digital handshake’ and data exchange with external systems. Our core platform is hosted in Digital Ocean cloud.

We establish a relationship of trust and integrity with all our suppliers, which is built upon mutually beneficial factors. Our supplier selection and on-boarding procedure includes due diligence of the supplier’s reputation, respect for the law, compliance with health, safety and environmental standards, and references. We haven’t been made aware of any allegations of human trafficking/slavery activities against any of our suppliers, but if we were, then we would act immediately against the supplier and report it to the authorities.

Risk Assessment

We conduct ongoing risk assessment of our supply chain by taking into account:

• The risk profile of individual countries based on the Global Slavery Index
• The business services rendered by the suppliers
• The presence of vulnerable demographic groups
• A news analysis and the insights of labour and human rights groups

This assessment determines our response and the risk controls that we implement.

Polices

YST conducts due diligence on all new suppliers during on-boarding and on existing suppliers at regular intervals. This includes:

• Assessing risks in the provision of particular services
• Auditing the suppliers, and their health and safety standards, labour relations and employee contracts
• Requiring improvements to substandard employment practices
• Sanctioning suppliers that fail to improve their performance in line with our requirements

We require all suppliers to attest that:

• They don’t use any form of forced, compulsory or slave labour
• Their employees work voluntarily and are entitled to leave work
• They provide each employee with an employment contract that contains a reasonable notice period for terminating their employment
• They don’t require employees to post a deposit/bond and don’t withhold their salaries for any reasons
• They don’t require employees to surrender their passports or work permits as a condition of employment

Awareness

YST has raised awareness of modern slavery issues by sending an email that is focused specifically on modern slavery to all our staff, which explains:

• Our commitment in the fight against modern slavery
• Red flags for potential cases of slavery or human trafficking
• How employees should report suspicions of modern slavery

Training

In addition to the awareness programme, YST has circulated a the UK Government Home Office awareness video to all employees, which covers:

• Various forms of modern slavery in which people can be held and exploited
• The size of the problem and the risk to our organisation
• How employees can identify the signs of slavery and human trafficking, including unrealistically low prices
• How employees should respond if they suspect slavery or human trafficking
• What external help is available for the victims of slavery
• What terms and guidance should be provided to suppliers in relation to slavery policies and controls
• What steps YST will take if a supplier fails to implement anti-slavery policies or controls
• An attestation from employees that they will abide by YSTs anti-slavery policy

Measuring how we’re performing\

YST has defined a set of key performance indicators and controls to combat modern slavery and human trafficking in our organisation and supply chain. These include:

• How many employees have completed mandatory training, read and understood our Modern Slavery & Human Trafficking
• How many suppliers have rolled-out a staff awareness that is equivalent to ours?

This statement covers 1 January 2024 to 31 December 2024 and has been approved by the board of YST at the board meeting held on 7 November 2023.