Privacy Policy (Updated May 24th 2018 in compliance with new GDPR Regulations)

1. Introduction
Kruegerkey works to ensure that your privacy is protected when using our Services. We therefore have a policy setting out how your Personal Data will be processed and protected. Please stay updated on any changes to this Privacy Policy by visiting our websites and mobile applications (“Platform”).

This Privacy Policy only concerns Kruegerkey Customers and users of our Platform and Services.

2. What information do we collect
Kruegerkey collects information to operate our business and provide you the opportunity to subscribe to our loss protection services. We collect both Personal Data and Other Information in support of these efforts.

"Personal Data" is information that can be used, directly or indirectly, alone or together with other information, to identify you as an individual Customer and to connect you with the finder of your missing items. This may include your precise Location Data.

"Other Information" is information that is anonymous, aggregate, de-identified, or otherwise does not reveal your identity. Some examples include browser and operating system, time spent using our Services, and webpages visited. We collect and use this information to understand how you and our Customers as a whole use our Services and constantly tune, enhance, innovate and build products and services to reflect the needs of our Customers. We also collect responses from trusted Payment Service Providers when you make purchases on the Platform. Depending on payment method, this may include a subscription ID that is sent to the Payment Service Provider. To complete purchases via Kruegerkey we require you to provide certain financial information (e.g. your PayPal user name or credit card information) in order to facilitate the processing of payments.

Where Applicable The Payment Service Provider needs to collect payment information (credit card information), as it is necessary for the adequate performance of the contract with you and to comply with applicable law (such as anti-money laundering regulations), without it, you will not be able to use the Kruegerkey platform. Kruegerkey will only keep a payment token to process your payment.

When you are using a mobile device, we also collect and use your Apple Identifier for Advertising (IDFA) and Google Advertising ID (AAID) to recognize your device and support activities on our Services. These number values are not permanently tied to your device and, depending on your operating system, you can reset it through your device settings.

We collect Personal Data in the following ways:

INFORMATION YOU GIVE TO US: When you register with us, we collect registration and demographic details, e.g., name, email address, password, country and a contact phone number. 


INFORMATION WE AUTOMATICALLY COLLECT FROM YOUR USE OF THE Kruegerkey SERVICE: When you use the Kruegerkey Platform, we automatically collect information, including personal information, about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the Kruegerkey service.

When you use or interact with our Services, we may collect information about your precise or approximate location as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services in the device’s Settings menu. We collect information about your interactions with the Kruegerkey service. We automatically collect log data and device information. We use cookies and other similar technologies. Kruegerkey collects information related to your payment transactions through Kruegerkey Subscriptions. This information is necessary for the adequate performance of the contract between you and Kruegerkey.

We collect Location Data in several ways:

from your wireless carrier,
directly from the device on which you use our Services.
The way in which we collect Location Data is different depending on whether you are accessing the Services through a website or a mobile application.

If you are accessing the Services through one of our mobile applications, the way we collect Location Data will differ depending on your mobile device’s operating system. In all events, we do not collect Location Data, unless you have allowed its collection when prompted. If you decline to allow Location Data collection in the app, we will not collect your Location Data unless you manually enter it in.

Other Information: We may collect Other Information about your use of our Services. This includes, for example, your device type, carrier provider, browser type, operating system, internet domain and host name, date and time of access as well as referring and onward URL, as well as transactional data about the activities you undertake and how you interact with the Services, such as what data is displayed, clicked on or shared, the click stream patterns, and the length of time spent on each site or page; and searches you may conduct on the Services.

When you connect with us through social media, we may collect account or profile information.

You may choose to enable, log into or sign on to the Services through Facebook or other networking services ("Social Networking Services"). When you connect using your Social Networking Services accounts, we may collect Personal Data that you have provided to that Social Networking Service. For example, when you log in with your Facebook credentials, with your consent we may collect Personal Data from your Facebook profile that is permitted under Facebook’s Terms of Use, such as your email address. If you do not want to provide us with this information, you will need to amend the privacy settings on your Social Networking Services account. For more information, please review the privacy disclosures and terms of your Social Networking Services account, which govern how that account information is collected and shared with us.

5. When you take surveys and enter promotions, contests, and sweepstakes, we collect contact, demographic and eligibility information.

We may sponsor contests, sweepstakes and other promotions ("Promotions") and we may request that you provide Personal Data, such as name, address, email address, telephone number and age and other information that may be appropriate in order to participate. 

We may also launch surveys that ask you to answer questions about a range of topics from personal information to brand and product preferences.

3. How do we use your Personal Data
We use the data we collect to operate our business, advertise and improve our existing Platform, develop new services and to improve and personalize your experiences interacting with us. We also use your Personal Data to communicate with you.

We will use your Personal Data for the following purposes:

Operate our business and run our Services.

We use your Personal Data to create and manage your personal account at Kruegerkey and to process your payments.

We use your Personal Data to anonymously connect you with the finder of a missing item. 

Personalize experiences on our Services, better understand our Customers and gain customer insights

We use your Personal Data to conduct analyses in order to provide you with relevant functionality.

We may conduct profiling based on your interactions with the Kruegerkey service, your purchase history, your profile information and preferences, and other content you submit to the Kruegerkey platform.

We process this information given our legitimate interest in improving the Kruegerkey service and our Customers’ experience with it, and where it is necessary for the adequate performance of the contract between you and the Store.

Communicate with you and respond to your requests

When registering an account with us, you have a choice of receiving announcements about us and our products and Services via email and/or push notifications. If you consent to such messages, we may use your Personal Data and Other Information to communicate with you about the Services you have purchased or used and to notify you of other products, promotions and Services we think may be of interest to you. You can manage your communication preferences at any time.

We may use your Personal Data to respond to your requests for technical support, online services, product information or to any other communication you initiate. This includes accessing your account to address technical support requests.

Additionally, when you request it, we will use your Personal Data to enroll you in contests, programs, or offers. We also may use your Personal Data to notify you of promotions and other special offers.

Please note that irrespective of your email and push notifications settings, we may send you notifications pertaining to the performance of our Services, such as revision of our Terms or this Privacy Policy or other formal communications relating to products or Services you have purchased or use. 
Tailor our advertising and marketing

We use Personal Data and Other Information to assist us in our advertising and marketing campaigns, to provide you with information on the products and Services that we think are most relevant to you.

Given you have provided your consent, we may send you promotional messages, marketing, advertising and other information that may be of interest to you based on your preferences and social media advertising through social media platforms. This includes contests, sweepstakes and other promotional activities. You always have the possibility to demand Kruegerkey not to send you any promotional material or information.

We will process your personal information for the purposes described above given our legitimate interest in undertaking marketing activities to offer you products that may be of your interest.

Create and Maintain a Trusted and Safe Environment

We may use Personal Data to detect and prevent fraud, spam, abuse, security incidents, and other harmful activity. To conduct security investigations and risk assessments, and to verify or authenticate information or identifications provided by you.

4. Where is your Personal Data stored
Kruegerkey uses a variety of third party service providers to help us provide services related to the Kruegerkey services. Service providers may be located inside or outside of the European Economic Area (“EEA”). Any such transfer of your Personal Data will be carried out in compliance with all applicable laws.

These providers have limited access to your information to perform these tasks on our behalf and are contractually bound to protect and to use it only for the purposes for which it was disclosed and consistent with this Privacy Policy. We have - prior to sharing your information with third parties – established the necessary means to ensure an adequate level of data protection. This may be an agreement on the basis of the EU Model Clauses (a set of clauses issued by the European Commission).

5. For how long is your Personal Data stored
Kruegerkey will retain your Personal Data for as long as you maintain an Account or as needed to provide you the Services. We will also retain and use your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

6. Who is responsible for your Personal Data
Kruegerkey, is the controller of the Personal Data you submit to us and responsible for your Personal Data.

7. Who has access to your Personal Data
Your data may be shared within the Keyfetch LTD corporate family of companies that are related by common ownership or control Keyfetch Group. We never pass on, sell or swap your data for marketing purposes to third parties outside the Keyfetch group. Data that is forwarded to third parties is only used to provide you with the services mentioned above, for example media services and agencies for distribution of newsletter and credit reference or debt collection agencies for the purpose of credit rating checks, identity checks and debt collection.

Kruegerkey may disclose your information, including personal information, to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against Kruegerkey, (iii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iv) to enforce and administer our Terms of Service or other agreements with Members, or (v) to protect the rights, property or personal safety of Kruegerkey and its Members.

8. How do we protect your Personal Data
We have taken technical and organizational measures to protect your data from loss, manipulation and unauthorized access. We continually adapt our security measures in line with technological progress and developments. To make card purchases with us as secure as possible, all information is sent in encrypted form. This means that the information is passed through a secure connection and that external parties cannot read your Personal Data. For card purchases, we work with PCP compliant Payment Service Providers that help us to check directly with your bank that the card is valid for purchases. Our Payment Service Providers process your card details according to the international security standards PCI DSS, which was developed by the card companies VISA, MasterCard, Diners, American Express and JCB. This means that your card details are processed with a very high level of security. When you pay by card, we reserve the right to carry out an identity check.

9. What are your rights
You may exercise any of the rights described in this section before by sending an email to [email protected]. Please note that we may ask you to verify your identity before taking further action on your request.

9.1 Managing Your Information
You may access and update some of your information through your Account settings. If you have chosen to connect your Kruegerkey Account to a third-party application, like Facebook or Google, you can change your settings and remove permission for the app by changing your Account settings. You are responsible for keeping your personal information up-to-date.

9.2 Rectification of Inaccurate or Incomplete Information
You have the right to ask us to correct inaccurate or incomplete personal information concerning you and which you cannot update yourself within your Kruegerkey Account.

9.3 Data Access and Portability
You are entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).

9.4 Data Retention and Erasure
We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information to provide the Kruegerkey services to you, you can request that we erase your personal information and close your Kruegerkey Account. Please note that if you request the erasure of your personal information:

We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety.

We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Kruegerkey may keep some of your information for tax, legal reporting and auditing obligations.

Information you have shared with others (e.g., Reviews may continue to be publicly visible on the Kruegerkey Platform, even after your Account is cancelled). Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.

Because we maintain the Kruegerkey Platform to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

9.5 Withdrawing Consent and Restriction of Processing
You may withdraw your consent at any time by sending a communication to Kruegerkey. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.

9.6 Objection to Processing
You are entitled to object to Kruegerkey's processing of your personal information. If you object to such processing Kruegerkey will no longer process your personal information but may also be required to close your account.

Kruegerkey can continue processing of personal data for specific purposes if Kruegerkey can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims.

Where your personal information is processed for direct marketing purposes, you may, at any time ask Kruegerkey to cease processing your data for these direct marketing purposes by sending an e-mail to [email protected].

10. Business Transfer
If Kruegerkey undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

11. Lodging Complaints
You have the right to lodge complaints about the data processing activities carried out by Kruegerkey before the competent data protection authorities.

12. Controller of Personal Data
Keyfetch LTD

Michelin House 

81 Fulham Road

London 

SW3 6RD

UK

Company Number: 08721867

VAT Number: GB179099846

E-mail: [email protected]

Mail address: Keyfetch LTD, 81 Fulham Road, London, SW3 6RD, UK 

Version May 25, 2018