My Keys Pocket App Privacy Notice
My Keys Pocket Information
My Keys Pocket, with headquarters in London, email info@mykeyspocket.com, as the owner of the processing of personal data (hereinafter "My Keys Pocket" or "Data Controller"), issues this notice in compliance with European and Finnish legislation on the protection of personal data to clarify and illustrate the processing of data carried out for purposes related to the use of the mykeypocket.com platform provided through a dedicated website and/or mobile application (hereinafter "My Keys Pocket"). The Data Controller has appointed a Data Protection Officer (DPO), who can be contacted at the following address: info@mykeypocket.com.
Purposes of Processing and Legal Basis
My Keys Pocket will process your data for the following purposes:
A. Service Purposes
For the activation and registration on the My Keys Pocket App platform.
To diagnose problems with the platform.
To process any payments.
To investigate and respond to any comments or complaints that the User may send.
To detect, prevent, or otherwise address fraud, technical or security issues, and piracy by helping to protect the User.
To exercise the rights of the Data Controller.
For these "Service Purposes," the legal basis of processing is the need to ensure the correct functionalities of the requested platform or to fulfill a legal obligation.
B. Promotional Purposes
To send informative material (e.g., newsletters) and promotional content regarding initiatives, promotions, and events organized by My Keys Pocket or in which My Keys Pocket participates ("Marketing"): for this purpose, your express consent is required.
To analyze user preferences, habits, and behaviors in order to send personalized commercial communications based on the commercial and behavioral profile thus created. This involves processing data from purchased products to offer personalized communication. Express consent is required for this purpose, distinct from the one mentioned in "Marketing."
To communicate the data subject’s email address and registration details to third parties so that they can pursue their marketing interests: express consent is necessary for this purpose, separate from that in "Marketing."
Existence of Automated Individual Decision Making (Profiling)
The Data Controller may analyze user data (e.g., inferred from purchases made) to send customized commercial communications and implement targeted promotional and business intelligence activities. This processing is carried out using data processing tools, which, when cross-referenced, create a web-based commercial and behavioral profile. Additionally, such data may be associated with information already in the Data Controller’s possession, including data provided by the data subject or collected through services provided.
Data Retention Period
A. For Service Purposes
Data will be retained for the time strictly necessary for the fulfillment of these purposes, after which they will be deleted or anonymized.
B. For Promotional Purposes
Marketing: Data will be retained for 24 months from the last communication unless consent is withdrawn earlier.
Profiling: Data will be retained for 12 months
If the user deletes their profile from the website or app, the collection of any further information will be immediately interrupted. However, the Data Controller may still retain the data for purposes stated above, but not exceeding five years from profile deletion.
Provision of Data and Consequences of Failure to Provide Data
A. For Service Purposes
Providing data is necessary for the operation of the My Keys Pocket platform and for fulfilling related obligations. If data is not provided, the user will not be able to use the platform.
B. For Promotional Purposes
Providing data is optional. Failure to provide data or the related consent will prevent the Data Controller from carrying out the corresponding activities. However, refusal will not prevent the use of the My Keys Pocket platform.
Categories of Recipients
For the specified purposes, My Keys Pocket may share data with the following categories of recipients:
Internal personnel authorized to process data according to their responsibilities.
Companies entrusted with creating promotions and/or commercial communications.
Companies that handle sending promotional and advertising material.
Companies responsible for managing payments and billing.
Companies managing and storing archives (electronic and/or paper-based) for My Keys Pocket.
Public and private entities, including those involved in inspections and verifications.
Companies, consultants, and professionals working on behalf of My Keys Pocket to achieve the purposes stated above.
If these recipients process data on behalf of the Data Controller, they will be appointed as data processors through specific contracts or other legal agreements.
Data Transfer to a Third Country and/or International Organizations
Your personal data will not be transferred to non-European countries.
Rights of Data Subjects
The data subject has the right to:
Request access to their personal data.
Request rectification if data is inaccurate.
Request deletion or restriction of processing if conditions are met.
Obtain portability of personal data provided.
To exercise these rights, the data subject can contact the Data Controller at: info@mykeypocket.com.
Update Date: September 2024