KeySoft Holding Limited is a private liability company incorporated in the British Virgin Islands with company number 1953576 and whose registered office is 30 De Castro Street, Wickhams Cay 1, Road Town, Tortola, British Virgin Islands . Please note that KeySoft Holding Limited, which is incorporated in the State of Nevada, United States, is an independent distributor of KeySoft products and, as such, it does not collect any personal information (as such information is defined in NRS 603A.040) and is not a “data collector” (as such term is defined in NRS 603A.030)
PERSONAL INFORMATION COLLECTED
We collect personal information to provide you with our Services. When we require certain personal information from users it is because we are required by law to collect this information or it is relevant for specified purposes. Any information you provide to us that is not required is voluntary. You are free to choose whether to provide us with the types of personal information requested, but we may not be able to serve you as effectively or offer you all of our Services when you do choose not to share certain information with us.
We collect information directly from you when you choose to participate in our offers and programs, create an account on our websites or in our mobile applications, call or email us, or otherwise provide information directly to us. The following are examples of information we may collect directly from you:
- Email address
- Postal address
- User name and password
- Telephone and/or fax number
- Date of birth
- Demographic information
- Payment information (such as a credit card) and bank account details
- Future communication preferences
- Telephone number and recordings when you call our customer service line
INFORMATION COLLECTED WHEN YOU VISIT OUR SITE OR USE OUR MOBILE APPLICATION OR OTHER SERVICES
- Information about your device browser and operating system.
- IP address
- Web pages you view
- Links you click
- Our emails you open
INFORMATION COLLECTED THROUGH MOBILE APPLICATIONS
When you download our mobile applications to your mobile device, we may also collect information that you provide. We also automatically collect information through our applications.
The following are examples of the types of information we may automatically collect through our applications:
- Marketing ID or similar identifier
- Information about your devices’ operating system
- Information about the way you use the application
You can opt out of continued information collection by our mobile application by deleting the application from your device.
Our mobile applications may collect precise location information from your device if you consent to the collection of this information. We may use third-party service providers to provide location services using the location data you provide. You may opt out at any time to the continued collection of this information by adjusting the settings on your device.
HOW YOUR PERSONAL INFORMATION IS USED
We use the information we collect to provide you products, offers and services, to deliver to you advertisements, offers or other content tailored to your interests, and to conduct other KeySoft Holding business operations. The following are examples of how we may use the information we collect:
- Answer your questions or respond to your requests.
- Develop new products and services.
- Create and manage your account.
- Protect against or identify possible fraudulent transactions.
- Send you email and/or postal messages with information about KeySoft Holding and other content we think may be of interest to you.
- Personalize your experience on our websites by presenting products and information tailored to you.
- Analyze the use of, and develop, our products, services and marketing.
- Enforce our Terms and Conditions and otherwise manage our business.
KeySoft Holding will only process your information in pursuance of our legitimate interest if we receive any requests related to, for example, a product or service, a call-back, or specific marketing materials; we will use your personal information to fulfill your request. Where we need to manage your account and protect you against or identify possible fraudulent transactions, we will do so in accordance with our legal obligation placed on us under law. We will seek consent from you if we need to process your data solely identified purposes. To ensure meaningful consent is obtained from you, KeySoft Holding will provide you with reasonable notice ensuring that your consent is provided on an informed basis.
We share your personal information within KeySoft Holding and as described in this statement. We do not share personal information with marketers outside of KeySoft Holding unless you consent to such sharing, or as described within this statement.
We engage third-party service providers to perform a variety of business operations on our behalf. In so doing, we may share your Personal Information with them. We provide our service providers with only the Personal Information they need in order to perform the services we request, and we contractually require that they protect this information appropriately and not use it for any other purpose.
For example, we may rely on a 3rd party service provider to:
- Fulfill your service requests and answer your questions.
- Host our sites and deliver our email or other communications.
- Analyze our data, sometimes combined with data from other sources, to send you communications.
- Conduct research and analyze data to improve our products, services and sites.
- Perform other services that we request.
Where permitted by law, we combine Personal Information about you that KeySoft Holding has collected with Personal Information about you that a business partner has collected so we can jointly send tailored promotional communications to you. In such instances, our business partner will not be permitted to use KeySoft Holding data or the combined data for its own, independent marketing purposes. Our service provider will only be allowed to use the combined set of information to send you joint communications that we hope will be of interest to you. If you prefer not to receive these joint communications, you can always opt out by following the instructions provided in any such communication or through this Privacy Statement as indicated above.
We may transfer or otherwise process your personal information:
- As part of the sale of KeySoft Holding to another company.
- To protect, defend or exercise the rights and property of KeySoft Holding (including enforcing our Terms and Conditions).
- When required by law and/or government authorities.
We may share aggregated and/or anonymous information with our business partners for their own business purposes. For example, we may disclose the number of visitors to KeySoft Holding sites or services.
You can stop receiving promotional email messages from KeySoft Holding by following the opt-out instructions provided in any such message you receive.
We only send you promotional mobile text messages if you explicitly ask to receive these (you opt in). You can stop receiving promotional text messages by following the instructions to opt out provided within that text messaging program.
RIGHTS IN RELATION TO THE USE OF YOUR PERSONAL INFORMATION
Rights of access, correction and deletion
You have a right of access to the personal information that we hold about you under European General Data Protection Regulation, and to some related information. You can also require any inaccurate personal information to be corrected or deleted.
Right to object
You can object to our use of your personal information for direct marketing purposes at any time and you may have the right to object to our processing of some or all of your personal information (and require them to be deleted) in some other circumstances.
If you wish to exercise any of these rights, please contact us as set out below.
RETENTION OF PERSONAL INFORMATION
We will only retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting obligations or to resolve disputes. While retention requirements vary by jurisdiction, information about our typical retention periods for different aspects of your personal information are described below.
Contact Information such as your name, email address and telephone number for marketing purposes is retained on an ongoing basis until you un-subscribe. Thereafter we will add your details to our suppression list indefinitely.
Information collected via technical means such as cookies is kept for a period of up to one year from expiry of the cookie.
If you have a complaint about our privacy practices and our collection, use or disclosure of personal information please contact us at firstname.lastname@example.org
European Economic Area (EEA) Residents have the following rights, which can be exercised by contacting us at email@example.com so that we may consider your request under applicable law.
Right to withdraw consent. You have the right to withdraw your consent to the processing of your personal information collected on the basis of your consent at any time. Your withdrawal will not affect the lawfulness of KeySoft Holding’s processing based on consent before your withdrawal.
Right of access to and rectification of your personal information. You have a right to request that we provide you a copy of your personal information held by us. This information will be provided without undue delay subject to some fee associated with gathering of the information (as permitted by law), unless such provision adversely affects the rights and freedoms of others. You may also request us to rectify or update any of your personal information held by KeySoft Holding that is inaccurate. Your right to access and rectification shall only be limited where the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question, or where the rights of persons other than you would be violated.
Right to erasure. You have the right to request erasure of your personal information that: (a) is no longer necessary in relation to the purposes for which it was collected or otherwise processed; (b) was collected in relation to processing that you previously consented, but later withdraw such consent; or (c) was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing. If we have made your personal information public and are obliged to erase the personal information, we will, taking account of available technology and the cost of implementation, take reasonable steps, including technical measures, to inform other parties that are processing your personal information that you have requested the erasure of any links to, or copy or replication of your personal information. The above is subject to limitations by relevant data protection laws.
Right to data portability. If we process your personal information based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another “controller”, where technically feasible, unless exercise of this right adversely affects the rights and freedoms of others. A “controller” is a natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of your personal information.
Right to restriction of or processing. You have the right to restrict or object to us processing your personal information where one of the following applies:
(a) You contest the accuracy of your personal information that we processed. In such instances, we will restrict processing during the period necessary for us to verify the accuracy of your personal information.
(b) The processing is unlawful and you oppose the erasure of your personal information and request the restriction of its use instead.
(c) We no longer need your personal information for the purposes of the processing, but it is required by you to establish, exercise or defense of legal claims.
Restricted personal information shall only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest. We will inform you if the restriction is lifted.
Notification of erasure, rectification and restriction. We will communicate any rectification or erasure of your personal information or restriction of processing to each recipient to whom your personal information has been disclosed, unless this proves impossible or involves disproportionate effort. We will inform you about those recipients if you request this information.
Right to object to processing. Where the processing of your personal information is based on consent, contract or legitimate interests you may restrict or object, at any time, to the processing of your personal information as permitted by applicable law. We can continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.
Right to lodge a complaint. If you believe that we have infringed your rights, we encourage you to contact us first at firstname.lastname@example.org so that we can try to resolve the issue or dispute informally. You can also complain about our processing of your personal information to the relevant data protection authority. You can complain in the EU member state where you live or work, or in the place where the alleged breach of data protection law has taken place.
Please note that the British Virgin Islands (BVI) has not enacted formal legislation to regulate data protection. However, BVI accepts English common law as persuasive authority. BVI courts accordingly recognize the common law duties of privacy and confidentiality. Thus, KeySoft Holding has a duty to maintain confidentiality in a person’s details, unless an applicable exception applies. The duty of confidentiality has been statutorily codified in various aspects of BVI legislation. The common law duty of privacy and confidentiality is limited by specific exceptions under applicable anti-money laundering legislation, primarily regulated under the BVI Proceeds of Criminal Conduct Act, 1997, and the Anti-Money Laundering Regulations, 2008.
Storage of your personal information. KeySoft Holding will try to limit the storage of your personal information to the extent that storage is necessary to serve the purpose(s) for which the personal information was processed, to resolve disputes, enforce our agreements, and as required or permitted by law.
Data Protection Officer: You may reach the KeySoft Holding Data Protection Officer at email@example.com
Your rights to personal information are not absolute. Access may be denied when:
Denial of access is required or authorized by law;
Granting access would have a negative impact on other’s privacy;
Granting access would have a negative impact on other’s privacy;
To protect our rights and properties; and
Where the request is frivolous or vexatious.
HOW TO CONTACT US
KeySoft Holding Limited
30 De Castro Street, Wickhams Cay 1
Road Town, Tortola
British Virgin Islands
You can also complain about our processing of your personal information to the relevant data protection authority. You can complain in the EU member state where you live or work, or in the place where the alleged breach of data protection law has taken place.
Last updated: 25 March, 2019