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Privacy Policy

  • Updated

Mobile Application Privacy Policy 

Effective Date: July 2021 

 

The Keyholding Company Limited takes data protection very seriously. It is important to us that you know that your personal information and privacy are well protected. Personal Information is information that identifies you as an individual, such as your name, surname, date of birth, email address and residential address. 
 

We ask that you read this Privacy Policy carefully as it contains important information about i) how and why we collect, store, use and share your Personal Information, ii) your rights in relation to your Personal Information and iii) how to contact us and supervisory authorities in the event you have a complaint relating to your Personal Information. When we collect, store, use and share your Personal Information we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws. 

How do we collect Personal Information from you? 

We collect and use your Personal Information in accordance with this Privacy Policy. 

Personal Information which we collect about you via the App 

When you use our App, we will automatically collect the following information: 

  • Usage Information: we collect information about your interactions with our App such as the date and time that you log in and out of the App, and the features and functionality that you use. 
  • Location information: when you log into the App to begin an allocated job, the App will track your location so that we can estimate your time of arrival at a property and can verify to our clients that an Officer has attended their property at a specific date, time and place. The App will not track your location in the background while it is not being used; 
  • Log data and device information: we capture information about what device you use to access the App including how you’ve used the App, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, and the features you’ve used while using the App. This data is only accessible on an anonymous basis.  

Personal Information which others provide to us 

We may receive information from other parties, such as your employer, where you have authorised that third party to provide Personal Information to us. For example, we may have a copy of your name, email address and telephone number, but this is not viewable or accessible via the App.  

How will we use personal data about you? 

We collect, process and store personal data about you so that we can: 

  • Provide real time tracking information, as well as evidence via time, date and location stamps to our clients about the attendance of an Officer at a client’s property; 
  • Verify that you have completed allocated jobs in order to process payment to you for completion of the same;  
  • conduct research, statistical analysis and behavioural analysis about the use of the App; and 
  • improve our App. 

We may monitor and record communications with you (such as telephone conversations and emails) for the purpose of quality assurance, training and compliance. 

What Personal Information do we collect and use via the App? 

Personal Information we collect about you may include the following: your location, including the time and date while you are using the App. The App will not monitor your location in the background.  

How do we use your Personal Information? 

We use your Personal Information to do some or all of the following: 

  • communicate with you as part of our business; 
  • send you important information regarding changes to our App, services requirements, policies and other administrative information; 
  • conduct research, statistical analysis and behavioural analysis; 
  • manage our infrastructure and business operations, and comply with internal policies and procedures, including those relating to auditing; finance and accounting; billing and collections; IT systems; data and website hosting; business continuity; and records, document and print management; 
  • resolve complaints and handle requests for data access or correction; 
  • comply with applicable laws and regulatory obligations (including laws outside your country of residence), such as those relating to anti-money laundering and anti-terrorism; comply with legal process; and respond to requests from public and governmental authorities (including those outside your country of residence); and 
  • provide improved quality, training and security and manage other commercial risks. 

We may monitor and record communications with you (such as telephone conversations and emails) for the purpose of quality assurance, training and compliance. 

Who do we share your Personal Information with? 

We routinely share your Personal Information with: 

  • our related entities and other group companies; 
  • our external service providers (and their subcontractors), including our service partners, accountants, auditors, experts, lawyers and other outside professional advisors; IT systems, support and hosting service providers; printing, advertising, marketing and market research and analysis service providers; document and records management providers; technical engineers; data storage and cloud providers and similar third-party vendors and outsourced service providers that assist us in carrying out business activities. We only share your Personal Information with external service providers who have provided us with appropriate assurances that they will keep your Personal Information safe and protect your privacy; and 
  • we may also need to share your Personal Information with fraud prevention agencies and law enforcement or other authorities if required by applicable law. 

How long will we keep your Personal Information for? 

Whenever we collect your Personal Information, we will only keep it for as long as is necessary for the purpose for which it was collected, and we will retain it in accordance with any applicable laws and regulations regarding data retention. At the end of that retention period, your Personal Information will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning. 

What lawful basis do we rely on to process your Personal Information? 

Legitimate Interests 

We process your Personal Information to pursue our legitimate interests in a way which might reasonably be expected as part of running our business, and which does not materially impact your rights, freedom or interests. For example, ensuring the security and integrity of our services, selling and supplying services to our customers, improving existing products and services, developing new products and services and fulfilling our duties to our customers. 

Legal compliance 

We may be required to process your Personal Information to comply with our legal and regulatory obligations. For example, preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies. 

International Transfers of Personal Information 

Personal Information which you supply to us is generally stored and kept inside the European Economic Area. However, due to the nature of our business and the technologies required, your Personal Information may be transferred to third party service providers outside the EEA, in countries where there may be a lower legal level of data protection. In such situations, we transfer the minimum amount of data necessary, anonymise it where possible and enter legal contracts to aim to ensure these third parties handle your Personal Information in accordance with this Privacy Policy and the European levels of data protection. 

Your rights 

Under the General Data Protection Regulation you have a number of important rights (which are available to you free of charge). In summary, those include rights to: 

  • fair processing of information and transparency over how we use your use personal information; 
  • access to your personal information and to certain other supplementary information that this Privacy Policy is already designed to address; 
  • require us to correct any mistakes in your information which we hold; 
  • require the erasure of personal information concerning you in certain situations; 
  • receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations; 
  • object at any time to processing of personal information concerning you for direct marketing; 
  • object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you; 
  • object in certain other situations to our continued processing of your personal information; 
  • otherwise restrict our processing of your personal information in certain circumstances. 

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individual's rights under the General Data Protection Regulation. If you would like to exercise any of those rights, please email us at clientservices@keyholding.com. 

Security of your Personal Information 

We have appropriate security measures in place to prevent your Personal Information from being accidentally lost or used or accessed in an unauthorised way. Our security measures include: 

  • limiting access to your Personal Information to those who have a genuine business need to know it; 
  • those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality; 
  • limiting access to our business premises; 
  • having access controls to our IT environment; 
  • regularly monitoring our systems for vulnerabilities; 
  • using computer safeguards such as firewalls and data encryption; 
  • using enforced patching for our hardware and software systems. 

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so. If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses. 

How to complain 

We hope that we can resolve any query or concern you raise about our use of your Personal Information. If you wish to contact us, please send an email to clientservices@keyholding.com. The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113. 

Changes to this Privacy Policy 

We may amend or update this Privacy Policy from time to time. If we believe that the changes are material, we will provide you with additional notice (such as by sending you a notification). We encourage you to regularly review our Privacy Policy which will always be accessible via the App. This will keep you informed about our information practices and the ways you can help protect your privacy. 

How to contact us 

We welcome any questions you have about this Privacy Policy or the information we hold about you. You can email us at clientservices@keyholding.com. 

 

 

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