YAPA Privacy Policy

Last updated: 18 September 2026

This Privacy Policy explains how Inyeon Telecoms Ltd, trading as YAPA ("YAPA", "we", "us", "our"), collects, uses and protects personal data when you visit yapaclub.com, buy a YAPA device (the "Device"), or use the YAPA-2-YAPA or YAPA-Pro services (together, the "Services").

1. Who we are
  • Company: Inyeon Telecoms Ltd
  • Registered office: 167–169 Great Portland Street, 5th Floor, London, W1W 5PF
  • Contact: info@yapaclub.com
  • ICO registration number: ZC194367

We are registered with the Information Commissioner's Office (ICO) as a data controller under the Data Protection Act 2018 and the UK GDPR.

2. Scope

This policy covers personal data we collect from Account Holders (who are parents or guardians who buy and manage a device from us “Device”) and, to a limited extent, from children who use a Device with their parent’ or guardians’ consent. The Device is intended for use by children aged 5 and upwards under the supervision and account of a parent or guardian; children do not create their own account or provide information to us directly.

3. Personal data we collect
3.1 From the Account Holder, directly:
  • Contact details: name, email address, phone number, billing and delivery address.
  • Registered Location: the home address associated with a Device, used to route emergency calls where relevant (YAPA-Pro only).
  • Payment information: handled by our payment processor; we do not store full card details ourselves.
  • Account and contact-list information: the names and numbers of contacts the Account Holder approves for their child's Device.
  • Communications: anything you tell us via customer support, email, or social media.
3.2 Automatically, through the Device:
  • Device information: hardware identifiers, IP address, connectivity and operational status.
  • Call logs: the numbers called or received, and the time and duration of calls. We do not record or store the content of calls.
  • Configuration data: settings such as quiet hours and approved contacts.
3.3 Automatically, through the Site:
    • Usage data: pages visited, browser and device type, IP address.
    • Cookies and similar technologies (see our separate Cookie Policy for details).

    We do not require or ask for sensitive personal data (such as health information, racial or ethnic origin, or religious belief), and we ask that you do not send us this information.

    4. Children's information — how we treat it differently

    Because the Device is designed for use by children aged 5 and upwards, we take extra care with any information connected to a child's use of it:

    • We do not create profiles of children or use their information for advertising or marketing, targeted or otherwise.
    • The information we hold connected to a child's use of the Device is limited to what is needed to operate it safely - for example, the approved contact list set up by the parent, and call logs.
    • We do not ask children to provide personal information directly to us, and a Device cannot be used to create an account.
    • Contacts, quiet hours, and all other settings on a child's Device are controlled by the Account Holder, not the child.
    • A parent or guardian can ask us at any time to tell them what information we hold connected to their child's Device, and to have it deleted, subject to what we need to keep for safety, security, or legal reasons (for example, a limited call-log retention period).

    We design our approach to children's data with the ICO's Age Appropriate Design Code in mind, including data minimisation and privacy-protective default settings for anything connected to a child's use of the Device.

    5. How and why we use your personal data

    The table below sets out our main processing activities and the legal basis we rely on for each.

     Purpose Data used Legal basis

    Providing the Device and Services, including connecting calls and routing 999 calls on YAPA-Pro

    Contact details, Registered Location, call logs, device information

    Performance of a contract; and, for 999 routing, our legitimate interest and legal obligations relating to emergency call handling

    Processing orders, payments, returns

    Contact and payment information, transaction data

    Performance of a contract

    Billing and subscription management

    Contact and payment information

    Performance of a contract

    Customer support

    Whatever you share with us

    Legitimate interests (resolving your query); performance of a contract

    Improving the Device, Services and Site

    Device and usage data, call-quality metrics

    Legitimate interests (improving product and service reliability)

    Marketing communications

    Contact details

    Consent, or legitimate interests / soft opt-in for existing customers about similar products - you can opt out at any time

    Complying with the law, preventing fraud, safety and security

    Any relevant data

    Legal obligation; legitimate interests

    Corporate transactions (e.g. a sale or merger)

    Any relevant data

    Legitimate interests
    6. Cookies

    Our Site uses essential cookies needed for it to function, and — only with your consent — analytics and marketing cookies. You can manage your preferences using the cookie settings tool on our Site. See our Cookie Policy for more detail.

    7. How long we keep data
    Data  Retention period

    Account and Registered Location data

    For as long as your account is active, plus 6 years after closure

    Call logs

    6 years - kept only as long as needed for billing, technical support and safety

    Transaction and financial records

    6 years, in line with HMRC requirements

    Marketing consent records

    3 years from your last interaction

    Website usage / analytics data

    Up to 13 months

    We securely delete or anonymise personal data once we no longer need it for these purposes.

    8. Who we share data with

    We do not sell personal data. We share it only where necessary, with:

    • our telecoms platform and network partners, who help us connect and route calls (including 999 calls on YAPA-Pro);
    • payment processors;
    • delivery and fulfilment partners;
    • IT hosting and software providers;
    • email marketing platforms, for communications you've agreed to receive;
    • professional advisers (lawyers, accountants), where needed;
    • emergency services and law enforcement, where required to handle a 999 call or as required by law;
    • any future buyer of our business, in the event of a merger, sale or similar transaction.

    All third parties who process data on our behalf are required to protect it and use it only for the purposes we specify.

    9. International transfers

    Some of our service providers may process data outside the UK. Where this happens, we use appropriate safeguards - such as the UK's International Data Transfer Agreement or an adequacy decision - to protect your data to a standard equivalent to the UK GDPR.

    10. Security

    We use appropriate technical and organisational measures (such as encryption, access controls, and restricting access to staff who need it) to protect personal data. No system is completely secure, but we take this seriously, and we will notify the ICO and affected individuals where the law requires us to in the event of a personal data breach.

    11. Your rights

    Under UK GDPR you can ask us to: give you access to your data; correct inaccurate data; erase your data; restrict how we use it; provide it to you in a portable format; or object to processing based on legitimate interests or for direct marketing. Where we rely on your consent, you can withdraw it at any time. To exercise any of these rights, contact us at info@yapaclub.com. We aim to respond within one month.

    12. How to complain

    If you're unhappy with how we've handled your personal data, please contact us first at info@yapaclub.com and we'll do our best to put it right. If you're not satisfied with our response, you can complain to the Information Commissioner's Office:

    • Website: ico.org.uk/make-a-complaint
    • Telephone: 0303 123 1113
    • Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF
    13. Changes to this policy

    We may update this policy from time to time. If we make material changes, we will let you know - for example, by email or a notice on the Site. The date at the top shows when it was last updated.

    14. Contact us

    Inyeon Telecoms Ltd, trading as YAPA

    167–169 Great Portland Street, 5th Floor, London, W1W 5PF

    info@yapaclub.com