KeepMe ("KeepMe") understands that the privacy of customers and website users (collectively the "Customer") who visits the website at www.keepmee.ai (the "Site") is important and that the Customer care about how personal data is used. KeepMe respects and value the privacy of everyone and will only collect and use personal data in ways that are described here, and in a way that is consistent with KeepMe's obligations and the Customers' rights under the law.
In this Policy the following terms shall have the following meanings:
"Account" means an account required to access and/or use certain areas and features of the services provided by KeepMe;
"Cookie" means a small text file placed on the Customer's computer or device by the Site when the Customer visit certain parts of the Site. Details of the Cookies used by the Site are set out in Part 14, below; and
"Cookie Law" means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003.
The Site is operated by KeepMe, a company registered in England and Wales under company no. 11714351.
Registered address: 27 Parliament Street, Liverpool, Merseyside, L8 5RN, United Kingdom.
Email address: firstname.lastname@example.org
Personal data means all such "personal data" as is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the "GDPR") for as long as it is directly applicable in the United Kingdom and any successor legislation in the United Kingdom to the GDPR, and the Data Protection Act 2018 (collectively, "the Data Protection Legislation"). The GDPR defines Personal Data as 'any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier'.
Personal data is, in simpler terms, any information about the Customer that enables the Customer to be identified. Personal data covers obvious information such as the Customer's name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
Under the Data Protection Legislation, the Customer has the following rights, which KeepMe will always work to uphold:
b) The right to access the personal data that KeepMe hold about the Customer. Part 13 will tell the Customer how to do this.
c) The right to have the Customer's personal data rectified if any of the Customer's personal data held by KeepMe is inaccurate or incomplete. Please contact KeepMe using the details in Part 15 to find out more.
d) The right to be forgotten, i.e. the right to ask KeepMe to delete or otherwise dispose of any of the Customer's personal data that KeepMe hold. Please contact KeepMe using the details in Part 15 to find out more.
e) The right to restrict (i.e. prevent) the processing of the Customer's personal data.
f) The right to object to KeepMe using the Customer's personal data for a particular purpose or purposes.
g) The right to withdraw consent. This means that, if KeepMe is relying on the Customer's consent as the legal basis for using the Customer's personal data, the Customer is free to withdraw that consent at any time.
h) The right to data portability. This means that, if the Customer has provided personal data to KeepMe directly, KeepMe is using it with the Customer's consent or for the performance of a contract, and that data is processed using automated means, the Customer can ask KeepMe for a copy of that personal data to re-use with another service or business in many cases.
i) Rights relating to automated decision-making and profiling.
For more information about the use of the Customer's personal data or exercising the Customer's rights as outlined above, please contact KeepMe using the details provided in Part 15.
It is important that the Customer's personal data is kept accurate and up-to-date. If any of the personal data KeepMe hold about the Customer changes, please keep KeepMe informed as long as KeepMe have that data.
Further information about the Customer's rights can also be obtained from the Information Commissioner's Office or the Customer's local Citizens Advice Bureau.
If the Customer has any cause for complaint about the use of the Customer's personal data, the Customer hast he right to lodge a complaint with the Information Commissioner's Office. KeepMe would welcome the opportunity to resolve the Customer's concerns ourselves, however, so please contact KeepMe first, using the details in Part 15.
|Data Collected||How KeepMe Collect the Data|
|Identity Information including name||Upon creating an account and signing up to the services provided by KeepMe|
|Contact information including address, email address, telephone number||Upon creating an account and signing up to the services provided by KeepMe|
|Business information including business name and business address||Upon creating an account and signing up to the services provided by KeepMe|
|Payment information including card details or bank account numbers||Upon creating an account and signing up to the services provided by KeepMe|
|Profile information including login details, purchase and login history||From KeepMe's ASP communications infrastructure when Customer logs in|
|Technical information including IP address and operating system||From KeepMe's ASP communications infrastructure when Customer logs in|
Under the Data Protection Legislation, KeepMe must always have a lawful basis for using personal data. The following table describes how KeepMe may use the Customer's personal data, and the lawful bases for doing so:
|What KeepMe Do||What Data KeepMe Use||the Lawful Basis|
|Registering the Customer for the services provided by KeepMe or preparing offer for Customer||Business name and business address, name, email address, telephone number||The performance of contract and/or taking steps, at Customer's request, to enter into such a contract|
|Providing and managing the Customer's Account.||Login details, purchase and login history||Legitimate interests, namely the proper administration of the Website and business|
|Providing and managing the Customer's access to the Site.||Login details||Legitimate interests, namely the proper administration of the Website and business|
|Administering the business||Purchase and login history||Legitimate interests, namely the proper administration of the Website and business|
|Supplying the services to the Customer||Login details, email address, IT infra structure info||The performance of a contract|
|Managing payments for the services||Payment information including card details or bank account numbers||Legitimate interests, namely the proper administration of the business|
|Communicating with the Customer||Email address||The performance of a contract and/or taking steps, at Customer's request, to enter into such a contract|
|Supplying the Customer with information by email that the Customer has opted-in-to||Email address||The performance of a contract and/or taking steps, at Customer's request, to enter into such a contract|
With the Customer's permission and/or where permitted by law, KeepMe may also use the Customer's personal data for marketing purposes, which may include contacting the Customer by email, telephone, text message and/or post with information, news, and offers on the services. The Customer will not be sent any unlawful marketing or spam. KeepMe will always work to fully protect the Customer's rights and comply with the obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and the Customer will always have the opportunity to opt-out. KeepMe will always obtain the Customer's express opt-in consent before sharing the Customer's personal data with third parties for marketing purposes and the Customer will be able to opt-out at any time.
Third Parties whose content and/or services appears on the Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that KeepMe do not control the activities of such third parties, nor the data that they collect and use themselves, and KeepMe advise the Customer to check the privacy policies of any such third parties.
KeepMe use the following automated systems for carrying out certain kinds of decision-making and/or profiling. If at any point the Customer wish to query any action that KeepMe take on the basis of this or wish to request 'human intervention' (i.e. have someone review the action themselves, rather than relying only on the automated method), the Data Protection Legislation gives the Customer the right to do so. Please contact KeepMe to find out more using the details in Part 15.
KeepMe will only use the Customer's personal data for the purpose(s) for which it was originally collected unless KeepMe reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use the Customer's personal data for that purpose. If KeepMe do use the Customer's personal data in this way and the Customer wish KeepMe to explain how the new purpose is compatible with the original, please contact KeepMe using the details in Part 15.
If KeepMe need to use the Customer's personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, KeepMe will inform the Customer and explain the legal basis which allows KeepMe to do so.
In some circumstances, where permitted or required by law, KeepMe may process the Customer's personal data without the Customer's knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and the Customer's legal rights.
KeepMe will not keep the Customer's personal data for any longer than is necessary in light of the reason(s) for which it was first collected. The Customer's personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
|Type of Data||How Long KeepMe Keep It|
|Identity Information||Three years after termination of contract|
|Contact information||Three years after termination of contract|
|Business information||Until termination of contract|
|Payment information||Until termination of contract|
|Profile information||Until termination of contract|
|Technical information||Until termination of contract|
KeepMe may store or transfer some or all of the Customer's personal data in countries that are not part of the European Economic Area (the "EEA" consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as "third countries" and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that KeepMe will take additional steps in order to ensure that the Customer's personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:
KeepMe share the Customer's data within the group of companies of which KeepMe is a part. Where this involves the transfer of personal data outside the EEA, the group ensures that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage. These are known as "binding corporate rules". More information on binding corporate rules is available from the European Commission.
Where KeepMe transfer the Customer's data to a third party based in the US, the data may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission.
Please contact KeepMe using the details below in Part 15 for further information about the particular data protection mechanisms used by KeepMe when transferring the Customer's personal data to a third country.
The security of the Customer's personal data is essential to KeepMe, and to protect the Customer's data, KeepMe take a number of important measures, including the following:
• limiting access to the Customer's personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
• procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, the Customer's personal data) including notifying the Customer and/or the Information Commissioner's Office where KeepMe is legally required to do so;
11.1 In addition to the Customer's rights under the Data Protection Legislation, set out in Part 5, the Customer may be given options to restrict the use of the Customer's personal data via the Customer account log-in control panel. In particular, KeepMe aim to give the Customer strong controls on the use of the Customer's data for direct marketing purposes (including the ability to opt-out of receiving emails from KeepMe which the Customer may do by unsubscribing using the links provided in emails or at the point of providing the Customer's details and by managing the Customer's Account).
11.2 The Customer may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service ("the TPS"), the Corporate Telephone Preference Service ("the CTPS"), and the Mailing Preference Service ("the MPS"). These may help to prevent the Customer receiving unsolicited marketing. Please note, however, that these services will not prevent the Customer from receiving marketing communications that the Customer has consented to receiving.
The Customer may access the Site without providing any personal data at all. However, to make use of the services provided by KeepMe the Customer may be required to submit or allow for the collection of certain data.
If the Customer want to know what personal data KeepMe have about the Customer, the Customer can ask KeepMe for details of that personal data and for a copy of it (where any such personal data is held). This is known as a "subject access request".
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.
There is not normally any charge for a subject access request. If the Customer's request is 'manifestly unfounded or excessive' (for example, if the Customer make repetitive requests) a fee may be charged to cover the administrative costs in responding.
KeepMe will respond to the Customer's subject access request as soon as reasonably possible and, in any case, not more than one month of receiving it. Normally, KeepMe aim to provide a complete response, including a copy of the Customer's personal data within that time. In some cases, however, particularly if the Customer's request is more complex, more time may be required up to a maximum of three months from the date KeepMe receive the Customer's request. The Customer will be kept fully informed of the progress.
To contact KeepMe about anything to do with the Customer's personal data and data protection, including to make a subject access request, please use the following details:
Email address: email@example.com
Postal Address: KeepMe, 71-75 Shelton Street, Covent Garden, London WC2H 9JQ, United Kingdom