Privacy Policy

Introduction

1.1. Keytrack Holdings Ltd (“Keytrack”), a company incorporated in New Zealand. Our address and contact details are set out in Part 3 of this policy, respects the privacy of our users.

1.2. This Privacy Policy (“Policy”) describes our privacy practices concerning information collected in connection with Keytrack’s website, online applications and all services that we provide including but not limited to Transaction Status Reports (TSR), and electronic identity verification (the “Services”).

1.3. Part 1 describes how we will treat Personal Information collected or processed by us when you use our services. Part 2 of this policy describes how we use cookies, and Part 3 tells you how you can get in touch with us.

1.4. This policy is governed by New Zealand law (refer to paragraph 12).

1.5. Keytrack makes the Services available to third parties for integration into those third parties’ websites, applications, and online services. Keytrack collects, uses, and discloses individual users’ information only as directed by these third parties and, accordingly, Keytrack is a mere processor of user information with respect to the Services and not a controller.

1.7. Notwithstanding the above, Keytrack may process certain individual users’ information for its own purposes and on legitimate legal grounds (refer to paragraph 3).

2.1 “Personal Information” is the term for “Personal Data” as defined in the GDPR. It means any information that can identify you either directly or indirectly (i.e. by reference to other information we have access to).

2.2. "Data Subject" is the individual who is the subject of Personal Information.

2.3. The term “processing” is used in this policy as defined in the GDPR. It includes collection, storage, and all of the ways we use Personal Information when we provide the Services to you. Services are as defined in Keytracks Terms of Service policy on https://Keytrack.me/terms-of-service

2.4.Data Controller” means the entity which determines the purposes and means of the processing of Personal Information and who authorizes to give Keytrack Personal Data processing instructions. And “data processor” means the entity which processes Personal Information on behalf of the Data Controller.

2.5. Keytrack may collect, store and use the following kinds of Personal Information that you provide to us:

  1. information that you provide when registering to use our services or completing your profile on our website (including but not limited to your name, address, phone number, company name, company address, company email, company phone number and profile picture/logo);
  2. information that you provide to us when using our services, or that is generated in the course of the use of those services (including personal documents, files, informational content, and the meta data associated with the content);
  3. any other Personal Information that you choose to send to us in use of Keytrack’s services.

2.6. We may collect store and use the following kinds of Personal Information automatically when you use the Services:

  1. information about your computer and about your visits to and use of our services (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths). We collect this Personal Information by using cookies and other similar technologies. Please refer to Part 2 for further details on our use of cookies.

2.6. Keytrack processes Personal Information on behalf of the Data Controller. This information varies depending on the Keytrack application and the Data Controller in question, but may include such information as:

2.6.1. name, physical address, email address, telephone number, social security number, driver’s license number, state or national ID card number, passport number, other ID card number, date of birth.

2.6.2. Payment information is processed by an external payment provider.

2.6.3. Keytrack, through our third-party identity verification provider and depending on the service selected by the Data Controller (on consent of the Data Subject), collects and processes Personal Data for the purpose of identification and client due diligence compliance in accordance with the laws governing the Data Controller’s intended business relationship with the Data Subject - a visually scanned or photographed image of the Data Subject’s face and/or identification card, driver’s license, passport, utility bill, bank account statement, insurance card, or other requested identity document.  Images may include your photograph, and other information from the imaged document, such as your eye colour, weight, height, and organ donor status.

2.6.4 the Personal Data is processed via automated reading, verification of the authenticity and other automated processing of photos and scanned copies of documents and with further checks against the data in multiple databases, including inter alia International politically exposed persons (PEPs) and Sanctions, Country Specific Sanctions Lists, Criminal Lists and Financial Lists. Once the Personal Data has been processed by our third-party identity verification provider and securely retrieved by Keytrack, all metadata and cached information related to the Personal Data is then erased off the third-party’s servers. Once the Personal Data is not any more necessary for the purposes of applicable compliance rules, Keytrack shall erase the data completely off its servers without leaving any backup copies or, based on the same condition, transfer the data to the relevant Controller.

2.7. The Data Controller retains control of the Personal Information and remains responsible for its compliance obligations under the applicable Data Protection Legislation, including providing any required notices and obtaining any required consents, and for the processing instructions it gives to Keytrack.

2.8. Before the Data Controller discloses to us the Personal Information of another person, the Data Controller must obtain that Data Subject’s consent to both the disclosure and the processing of that Personal Information in accordance with the terms of this policy, with respect to Keytrack’s Terms of Service and on acceptance by the Data Subject to Keytrack’s Consent to Personal Data Processing.

2.8.1. This includes where any Content contained in your clients' documents or files includes Personal Information. In respect of that Content, we will act as a processor of the Personal Information and process and use it only in accordance with your instructions.

3.1 We rely upon a number of lawful grounds to ensure that our use of your Personal Information is compliant with applicable law. We set out the type of Personal Information, purpose for process and the legal grounds below.

  1. Provide you with services that you have signed up for, including customer support services. Legal Ground: Performance of a contract. This processing is necessary for the performance of the contract with our customer, where we process Personal Information about other individuals, in order to provide our services this processing is necessary for the purposes of the legitimate interests pursued by us in providing services to our customer.
  2. Administer our website and business and personalize our services for you. Legal ground: Legitimate interests. This processing is necessary for the purposes of the legitimate interests pursued by us to administer, manage and develop the Keytrack platform and services.
  3. Send you non-marketing commercial communications. Legal ground: Legitimate interests. This processing is necessary for the purposes of the legitimate interests pursued by us to keep you informed about changes to our services or terms and conditions.
  4. Send you email notifications that you have specifically requested. Legal Ground: Consent. You have the right to withdraw your consent at any time.
  5. Send you marketing communications relating to our business or the businesses of carefully selected third parties which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology. Legal Ground: Consent. You can inform us at any time if you no longer require marketing communications.
  6. Deal with enquiries and complaints made by or about you relating to our services. Legal ground: Legitimate interests. This processing is necessary for the purposes of the legitimate interests pursued by us to administer, manage and develop our business and services.
  7. Keep our website secure and prevent fraud. Legal Ground: Legitimate interest. This processing is necessary for the purposes of the legitimate interests pursued by us to ensure network and information security, manage risks to our business and check the quality of our service;
  8. Verify compliance with the terms and conditions governing the use of our website (including monitoring messages sent through our website messaging service). Legal ground: Legitimate interests. This processing is necessary for the purposes of the legitimate interests pursued by us to administer and manage the Keytrack platform.

3.1. However, we will only use Personal Information (ie, information contained within documents and files sent by you or your clients using the Services) as strictly necessary to provide our services to you.

3.2. If you submit Personal Information for publication on our website, we will publish and otherwise use that information in accordance with the licence you grant to us in order to operate the Services.

3.3. We will not, without your express consent, supply Personal Information to any third party for the purpose of their or any other third party's direct marketing.

4.1. We may disclose your Personal Information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy. Keytrack represents and guarantees that on entering into written contracts with suppliers, sub-processors or subcontractors, that the agreements contains terms substantially the same as those set out in Keytrack’s Terms of Service, Privacy Policy, and in particular, in relation to requiring appropriate technical and organisational data security measures;

4.2. Service providers and sub-processors we use to provide you with our services, or who provide functionality contained within our services include:

Services Entity Country
Cloud infrastructure service provider (dashboard) United States
SMS Service Provider and Transactional Email Processing United States
Email services United States
Cloud infrastructure service provider (website) Australia
Electronic Identity Verification Provider for KYC / AML compliance England
Web site performance and security United States

4.3. We may disclose your Personal Information:

  1. to the extent that we are required to do so by law;
  2. in connection with any ongoing or prospective legal proceedings;
  3. in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
  4. to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling;
  5. to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that Personal Information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that Personal Information; and
  6. to other people, where we you consent to do so, such as participant’s to the TSR where you or you adviser have enabled visibility settings to share certain documents.

4.4. Except as provided in this policy, we will not provide your Personal Information to third parties.

5.1. Information that we collect may be stored, transferred to, and stored or processed in, countries other than the country you live in. As a New Zealand-headquartered company, your information will be stored in (or accessible from) New Zealand, but it may also be stored in or accessible from countries where our service providers and sub-processors are located (including the United States). No matter which countries in the world your information is stored in, we take steps to ensure that it is kept secure and only used in accordance with this policy and with applicable privacy laws.

5.2. Information may be transferred outside the EEA. However, it will only be transferred to countries (like New Zealand) that have been recognised by the European Commission as providing an adequate level of protection of Personal Information, or to third parties who approved transfer mechanisms in place (such as the European Commission's Standard Contractual Clauses or by ensuring that the third party is Privacy Shield certified).

6.1. This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of Personal Information.

6.2. Personal Information that we process for any purpose or purposes in relation to the Services provided shall not be kept for longer than is necessary for that purpose or those purposes.

6.3. Notwithstanding the other provisions of this policy, we will retain documents (including electronic documents) containing Personal Data:

  1. to the extent that we are required to do so by law;
  2. if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
  3. in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

7.1. We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your Personal Information.

7.2. We will store all the Personal Information you provide on our secure password and firewall-protected servers.

7.3. All data entered through our website or exchanged via our services will be protected by encryption technology. This includes the Content of any documents or files sent using the Keytrack platform.

7.4. You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

7.5. You are responsible for keeping the password you use for accessing our services confidential; We will not ask you for your password (except when you log in to our services).

8.1. We may update this policy from time to time by publishing a new version on our website.

8.2. You should check this page occasionally to ensure you are happy with any changes to this policy.

8.3. We may notify you of changes to this policy by email or through the login area on our website.

9.1. We are committed to protecting and respecting your privacy; therefore, we have extended the following rights granted under the GDPR to all users of the Keytrack Platform, regardless of where you live you can:

  1. ask to receive information regarding the nature, processing and disclosure of your Personal Information (right to information);
  2. request a copy of your Personal Information we hold (right to access);
  3. request that we update or correct your Personal Information held by us at any time (right to rectification);
  4. request, on legitimate grounds, that we erase your Personal Information (right to erasure) subject to legally required data controlled by the Data Controller, and data that Keytrack requires to conduct it’s legitimate business purpose as set out in this policy and in its Terms of Service.
  5. request, on legitimate grounds, that we restrict the processing of your Personal Information (right to restrict processing);
  6. ask for a copy of your Personal Information in machine readable form that supports re-use and you can request that we transfer your Personal Information to another data controller (right to data portability);
  7. where our processing of your Personal Information is based solely on your consent (refer to paragraph 4 to understand the legal basis we process your Personal Information), you have the right to withdraw your consent at any time (right to withdraw consent). Once we have received notification that you have withdrawn your consent, we will as soon as practicable halt processing your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so; and
  8. If you’re not happy with how we are processing your Personal Information, you have the right to complain to your local information protection authority. Your local data protection authority will be able to give you more information on how to submit a complaint (right to lodge a complaint).

If you wish to exercise any of your rights, please contact us using the details set out in Part 3.

10.1. Our website includes hyperlinks to, code snippets from, and details of, third party websites.

10.2. We have no control over, and are not responsible for, the privacy policies and practices of third parties.

11.1. Please let us know if the Personal Information that we hold about you needs to be corrected or updated.

12.1. Although this policy accords with global and accepted privacy principles and regulations, this policy is ultimately governed by the laws of New Zealand and you submit to the jurisdiction of the New Zealand courts.

13.1 Google Analytics

If you have given consent to cookies, our website uses Google Analytics, a web analytics service provided by Google Inc. ("Google"), 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

Google Analytics uses so-called "cookies", which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of our website (including the shortened IP address) is usually transmitted to and stored by Google on servers in the United States.

Our website uses Google Analytics exclusively with the extension "_anonymizeIp ()", which ensures anonymization by truncating the IP address and thereby preventing a direct personal reference.

By activating IP-anonymisation your IP address will be truncated within the area of Member States of the European Union or other parties to the Agreement on the European Economic Area. Only in exceptional cases the whole IP address will be first transferred to a Google server in the USA and truncated there.

Google will use this information on behalf of the operator of this website for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing them with other services relating to website activity and internet usage. The IP-address, that your Browser conveys within the scope of Google Analytics, will not be associated with any other data held by Google.

You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to make full use of all the functions on this website. You can also opt-out from your data concerning the use of the website (incl. your IP address) being tracked with the use of cookies and processed by Google Analytics with effect for the future by downloading and installing the Google Analytics Optout Browser Addon for your current web browser: tools.google.com/dlpage/gaoptout.

US-based Google LLC is certified to the US-European Privacy Shield, which enforces compliance with the EU level of data protection.

For more information on the handling of user data by Google Analytics, please visit the Google Privacy Policy: support.google.com/analytics/answer/6004245.

13.2 Hotjar

If you have given your consent to cookies, we use Hotjar in order to better understand our users' needs and to optimize our service and users' experience. This is provided by Hotjar Ltd, Level 2, St Julians Business Center, 3, Elia Zammit Street, St Julians STJ 1000, Malta, Europe.

Hotjar is a technology service that helps us better understand our users' experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don't like, etc.) and this enables us to build and maintain our service by means of user feedback. Hotjar uses cookies and other technologies to collect data on our users' behavior and their devices (in particular the IP address of the device (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar's Privacy Policy.

If you do not want to be recorded by Hotjar, you can disable it by setting the DoNotTrack header in your browser. For more information and more about Hotjar's data processing, please visit: www.hotjar.com/legal/compliance/opt-out.

13.3 Social Media Sharing

We offer the possibility to share blog articles of our website on social media like Facebook, Twitter, LinkedIn and Google+.

In order to increase the protection of your data when visiting our website, these buttons are only embedded in the page by means of an HTML link and not fully integrated. This ensures that when you visit a page on our site that contains such buttons, it will not automatically connect to the Facebook, Twitter, LinkedIn, or Google+ servers. If you click the button, a new browser window will open and call up the Facebook, Twitter, LinkedIn or Google+ page, where you can interact with the plugins there (if necessary after entering your login data).

Further information on these plugins, which open in a new browser window, can be found here:

13.4 Facebook-Plugin

Our website links to a browser window that uses so-called social plugins ("plugins") of the social network Facebook operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA ("Facebook").

US-based Facebook Inc. is certified to the US-European Privacy Shield, which ensures compliance with the level of data protection in the EU.

For more information on the purpose and scope of the data collection and the further processing and use of the data by Facebook as well as your related rights and settings options for the protection of your privacy, please refer to the Privacy Policy of Facebook: www.facebook.com/policy.php.

13.5 Twitter-Plugin

Our website links to a browser window that uses Twitter microblogging plug-ins operated by Twitter Inc., 1355 Market St, Suite 900, San Francisco, CA 94103, USA ("Twitter"). The plugins are marked with a Twitter logo, for example in the shape of a blue "Twitter bird". An overview of the Twitter plugins and their appearance can be found here: dev.twitter.com/web/tweet-button.

For more information on the purpose and scope of the data collection and the further processing and use of the data by Twitter as well as your related rights and settings options for the protection of your privacy, please refer to the Privacy Policy of Twitter: twitter.com/privacy.

13.6 LinkedIn-Plugin

Our website links to a browser window that uses LinkedIn plugins provided by the LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA (hereinafter referred to as "LinkedIn"). You can recognize the plugins of LinkedIn by the corresponding logo or the "Recommend-Button".

For details on the collection of data and your legal as well as settings options, visit LinkedIn at: www.linkedin.com/static?key=privacy_policy.

13.7 Embedded services and third party content

We use third-party services and content within our online offering based on our legitimate interests in the provision, optimization and economic operation of our online offerings to integrate their content and services. This usually requires that the respective third-party providers of this content receive the IP address of the users, as they would not be able to send the requested content to their correct browser without the IP address. The IP address is therefore required for the presentation of this content and the use of the incorporated services.

13.8 Google Web Fonts

This site uses so-called web fonts provided by Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google") for consistent presentation of fonts. When you visit a page, your browser loads the required web fonts into its browser cache to display texts and fonts correctly.

To do this, the browser you use must connect to Google's servers. As a result, Google learns that our website has been accessed via your IP address. The use of Google Web Fonts is in the interest of a consistent and attractive presentation of our online services. This constitutes a legitimate interest. If your browser does not support web fonts, a default font will be used by your computer.

US-based Google LLC is certified to the US-European Privacy Shield, which ensures compliance with the level of data protection in the EU.

More information on Google Web Fonts can be found at developers.google.com/fonts/faq and in Google's Privacy Policy www.google.com/policies/privacy.

We offer the possibility to share blog articles of our website on social media like Facebook, Twitter, LinkedIn and Google+.

In order to increase the protection of your data when visiting our website, these buttons are only embedded in the page by means of an HTML link and not fully integrated. This ensures that when you visit a page on our site that contains such buttons, it will not automatically connect to the Facebook, Twitter, LinkedIn, or Google+ servers. If you click the button, a new browser window will open and call up the Facebook, Twitter, LinkedIn or Google+ page, where you can interact with the plugins there (if necessary after entering your login data).

Further information on these plugins, which open in a new browser window, can be found here:

Cookies

When you use the Services, Keytrack automatically receives and records certain information from your computer (or other device) and/or your web browser.

This may include such information as the third-party website or application into which the Services are integrated, the date and time that you use the Services, your IP address and domain name, your software and hardware attributes (including operating system, device model, and hashed device fingerprint information), and your general geographic location (e.g., your city, state, or metropolitan region). We will process such data only as instructed by the Third-Party Data Controller.

1.1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

1.2. Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

1.3. Cookies do not typically contain any information that personally identifies a user, but Personal Information that we store about you may be linked to the information stored in and obtained from cookies.

1.4. Cookies can be used by web servers to identity and track users as they navigate different pages on a website and identify users returning to a website.

We will use both session and persistent cookies on our website. Consent to use Cookies will be sought before they become active. The purposes for which they are used, are set out below:

  1. recognize a computer when a user visits the website
  2. track users as they navigate the website
  3. improve the website's usability
  4. analyses the use of the website
  5. administer the website
  6. prevent fraud and improve the security of the website
  7. personalize the website for each user;

3.11 We will use Google Analytics, to analyse the use of our website. Our analytics service providers generate statistical and other information about website use by means of cookies.

3.2. The information generated relating to our website is used to create reports about the use of our website. Our analytics service provider's privacy policy is available at: http://www.google.com/policies/privacy.

4.1. Most browsers allow you to refuse to accept cookies; for example:

  1. in Internet Explorer (version 10) you can block cookies using the cookie handling override settings available by clicking "Tools", "Internet Options", "Privacy" and then "Advanced";
  2. in Firefox (version 24) you can block all cookies by clicking "Tools", "Options", "Privacy", selecting "Use custom settings for history" from the drop-down menu, and unticking "Accept cookies from sites"; and
  3. in Chrome (version 29), you can block all cookies by accessing the "customize and control" menu, and clicking "Settings", "Show advanced settings" and "Content settings", and then selecting "Block sites from setting any data" under the "Cookies" heading.

4.2 Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website.

5.1. You can delete cookies already stored on your computer; for example:

  1. in Internet Explorer (version 10), you must manually delete cookie files (you can find instructions for doing so at http://support.microsoft.com/kb/278835;
  2. in Firefox (version 24), you can delete cookies by clicking "Tools", "Options" and "Privacy", then selecting "Use custom settings for history", clicking "Show Cookies", and then clicking "Remove All Cookies"; and
  3. in Chrome (version 29), you can delete all cookies by accessing the "Customize and control" menu, and clicking "Settings", "Show advanced settings" and "Clear browsing data", and then selecting "Delete cookies and other site and plug-in data" before clicking "Clear browsing data".

5.2 Deleting cookies will have a negative impact on the usability of many websites.

5.3 If you delete cookies, you will not be able to use all the features on our website.

Our Details

1.1 The services are provided by Keytrack Holdings Limited.

1.2 We are a company registered in New Zealand with company registration number 7109233.

If you are resident outside the European Union:

1.3 Our registered office is 19 Moore Street, Howick, Manukau, 2014, New Zealand.

1.4 You can contact us by writing to the postal addresses given above, or by email at [email protected].

1.5 If you are resident in the European Union: Please contact our data protection officer, with any questions, concerns, complaints or comments about this Policy, your Personal Data, our use and disclosure practices, or your consent choices by email at [email protected].

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