YES, Kids Stock Investing App (Ages 8-18)

Privacy policy

Our fine print, in normal print

Last updated: 30 September 2026

1. Who We Are

Young Early Starters NV ("YES", "we", "us", "our") is the controller of the personal data collected through the website www.youngearlystarters.com (the "Website").

Registered office: Sluisstraat 79, bus 3.1, 3000 Leuven, Belgium.

German branch: Young Early Starters NV Zweigniederlassung Deutschland, Friedrichstraße 155, 10117 Berlin, Germany.

CBE number: 1036.239.914

Contact for data protection matters: privacy@youngearlystarters.com.

We have not appointed a Data Protection Officer at this stage. If your query relates to your personal data, please contact us at the address above.

2. Scope of This Policy

This Privacy Policy explains how we collect, use, store and share personal data when you visit or interact with the Website. It does not cover data processing that will take place within the YES application once launched; that will be addressed in the application's subscriber privacy notice.

We are committed to processing personal data in accordance with the EU General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) and the Belgian Act of 30 July 2018 on the protection of natural persons with regard to the processing of personal data.

3. Data We Collect

3.1 Data You Provide Directly

When you interact with the Website, you may provide us with:

• your name and email address, when registering your interest or joining the waitlist;

• any information you include in a contact or enquiry form;

• your communication preferences.

3.2 Data Collected Automatically

When you visit the Website, we and our service providers may automatically collect:

• your IP address and approximate geographic location (country or city level);

• browser type and version, operating system and device type;

• pages visited, time spent on pages, links clicked and referring URL;

• session identifiers and cookie data (see our Cookie Policy for details).

3.3 Data We Do Not Collect

The Website is not directed at children. We do not knowingly collect personal data from children under the age of 16 through the Website. If you are a parent or guardian and believe your child has provided us with personal data, please contact us immediately and we will delete it.

We do not collect special categories of personal data (such as health, biometric, or financial data) through the Website.

4. How We Use Your Data

We use the personal data we collect for the following purposes:

4.1 To manage your waitlist registration

Legal basis: performance of a pre-contractual relationship (Article 6(1)(b) GDPR) or your consent (Article 6(1)(a) GDPR) where you have opted in to communications.

We use your name and email address to send you updates about the YES product, including launch notifications and relevant news, in accordance with your communication preferences.

4.2 To respond to your enquiries

Legal basis: our legitimate interest in responding to queries and managing our communications (Article 6(1)(f) GDPR).

4.3 To operate and improve the Website

Legal basis: our legitimate interest in maintaining and improving the Website (Article 6(1)(f) GDPR).

We use automatically collected data to monitor Website performance, diagnose technical issues, understand how visitors use the Website, and improve the user experience.

4.4 To comply with legal obligations

Legal basis: compliance with a legal obligation (Article 6(1)(c) GDPR).

We may process your data where required to comply with applicable law, including responding to lawful requests from competent authorities.

4.5 Automated decision-making

We do not use automated decision-making, including profiling, that produces legal effects concerning you or similarly significantly affects you (Article 22 GDPR).

4.6 Do you have to provide your data?

You are not under any legal or contractual obligation to provide us with personal data. However, we need your name and email address to register you on the waitlist, and the information in your enquiry to respond to it. If you do not provide this information, we cannot register you or answer your enquiry. Any other information is optional.

5. Cookies and Tracking

We use cookies and similar technologies on the Website. Please see our Cookie Policy (www.youngearlystarters.com/cookie-policy) for full details of the cookies we use, their purpose, duration and how to manage your preferences. Where cookies require your consent under applicable law, we obtain that consent before setting them.

6. How Long We Keep Your Data

• Waitlist registration data: retained until the YES application launches and you are migrated to the application's data environment, or until you withdraw your registration, whichever is earlier. In any event, we will not retain waitlist data beyond 36 months from the date of registration unless you have become an active user of the YES application.

• Contact and enquiry data: retained for 24 months from the date of last correspondence, unless a longer retention period is required to manage a complaint or legal claim.

• Website analytics data: retained in aggregated or pseudonymised form for up to 26 months.

We will delete or anonymise your personal data when it is no longer necessary for the purposes for which it was collected.

7. Who We Share Your Data With

We do not sell your personal data. We may share your data with the following categories of recipients:

• Service providers: third-party vendors who process data on our behalf. These currently include Google (Google Analytics, for website analytics), Framer (website hosting), Formspark (for processing waitlist sign-ups), and our email provider. All service providers are bound by data processing agreements and may only process data in accordance with our instructions.

• Group companies: we may share data within the YES group of companies for internal administrative purposes.

• Competent authorities: we may disclose data to regulators, law enforcement or courts where required by applicable law or to protect our legal rights.

• Acquirers: in the event of a merger, acquisition or sale of assets, your data may be transferred to the relevant third party, subject to equivalent data protection commitments.

8. International Transfers

Some of our service providers are based in, or process data in, countries outside the European Economic Area (EEA), in particular the United States. For example, Google Analytics is provided by Google Ireland Limited, and data may be transferred to Google LLC in the United States. Google LLC is certified under the EU-U.S. Data Privacy Framework, which the European Commission has recognised as providing an adequate level of protection (adequacy decision of 10 July 2023). Where a transfer is not covered by an adequacy decision, we use the European Commission's standard contractual clauses (SCCs) and, where necessary, additional safeguards to ensure a level of protection equivalent to that required under the GDPR. You can request more information about these safeguards by contacting us.

9. Your Rights

Under the GDPR, you have the following rights in relation to your personal data:

• Right of access: to request a copy of the personal data we hold about you.

• Right to rectification: to request correction of inaccurate or incomplete data.

• Right to erasure: to request deletion of your personal data, subject to applicable legal exceptions.

• Right to restriction: to request that we restrict the processing of your data in certain circumstances.

• Right to data portability: to receive your data in a structured, machine-readable format and to transmit it to another controller.

• Right to object: to object to processing based on our legitimate interests, including profiling.

• Right to withdraw consent: where processing is based on consent, to withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact us at privacy@youngearlystarters.com. We will respond within one month of receiving your request. In complex cases, we may extend this by a further two months, in which case we will notify you.

You also have the right to lodge a complaint with the Belgian Data Protection Authority (Gegevensbeschermingsautoriteit / Autorité de protection des données) at www.dataprotectionauthority.be or any other competent supervisory authority in your country of residence.

10. Security

We implement appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. These include access controls, encryption in transit, and regular review of our security practices. However, no data transmission over the internet can be guaranteed to be completely secure.

11. Children's Data

The Website is intended for adults - primarily parents and guardians who are prospective users of the YES application. We do not direct the Website at children under 16 and do not knowingly collect their personal data through the Website.

The YES application, once live, will involve children's data and will be governed by a separate, enhanced privacy notice with additional protections in line with GDPR Article 8 and applicable national law. Parental or guardian consent will be required for the processing of children's data within the application.

12. Third-Party Websites

The Website may contain links to third-party websites. This Privacy Policy applies only to the Website. We are not responsible for the privacy practices of third-party sites and encourage you to review their privacy policies before providing any personal data.

13. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the 'Last updated' date at the top of this page and, where appropriate, notify you by email if you have registered with us. We encourage you to review this Policy periodically.