SERVICES PRIVACY POLICY

INTRODUCTION

  1. Keyring (“Services“) that enable users  (collectively, “Customer(s)“) to: (i) to bundle their subscriptions (ii) split their subscription bills with family and household members, and (iii) let family and household members try their accounts. 
  2. This Services Privacy Policy describes Keyring’s privacy practices in relation to the information collected from Customers and End Users and received by Keyring when Customers use our Services. This Services Privacy Policy does not apply to information collected through use of Keyring’s publicly accessible website or marketing activities, which is described under our Website Privacy Policy. To view the Website Privacy Policy. Furthermore, Keyring and its Customers have entered into an agreement that governs the provision of Services by Keyring and their use by Customers (“Agreement(s)“). Such Agreements may contain additional obligations on the parties with respect to the handling of information. Nothing in this Services Privacy Policy derogates from such additional obligations.
  3. For the purpose of this Services Privacy Policy: (i) any reference to “End User(s)” means end users who have interacted with, or viewed, Customer’s advertising and marketing materials, or use or have used Customer’s Applications, websites, products and services; and (ii) any reference to “Keyring” “we” “us” or “our” shall means Keyring Ltd. and its affiliates.


END USER DATA RECEIVED AND PROCESSED BY KEYRING

When a Customer uses the Services, the following End User information may be received and processed by Keyring (collectively, “End User Data”).

  1. “Technical Information”: this refers to technical information related to an End User’s mobile device or computer, such as: browser type, device type and model, CPU, system language, memory, OS version, Wi-Fi status, time stamp and zone, device motion parameters and carrier.
  2. “Technical Identifiers”: this refers to various unique identifiers that generally only identify a computer, device, browser or Application. For example, IP address (which may also provide general location information), User agent, IDFA (identifier for advertisers), Android ID (in Android devices); Google Advertiser ID, Customer issued user ID and other similar unique identifiers.
  3. “Engagement Information”: this refers to information relating to the Customer’s ad campaigns and End User actions, such as: clicks on Customer ads, ad impressions viewed, audiences or segments to which an ad campaign is attributed, the type of ads and the webpage or Application from which such ads were displayed, the webpages on Customer’s website visited by an End User, the URL from the referring website, downloads and installations of Applications, and other interactions, events and actions Customers choose to measure and analyze within their Application or website (e.g. add to cart, in-app purchases made, clicks, engagement time etc.).
  4. While End User Data does not generally contain any information that directly identifies an individual, such as names, addresses, credit cards or other similarly regulated financial information, health information, or any other type of sensitive personal information (“PII“), we acknowledge that under certain jurisdictions the End User Data we do receive when a Customer uses the Services may be deemed personal data and therefore, where applicable, will be treated as such. Within the scope of the engagement between Customers and Keyring, Customers are contractually prohibited from collecting PII, unless otherwise agreed by Keyring. However, Customers have sole control over their properties (including their websites and Application) and configuration of the Services and thus Customers have the technical ability to configure the Services to collect PII. This includes, for example, a Customer using an End User’s email address as a Customer issued user ID Technical Identifier. If a Customer has configured the Services to collect PII then we may receive and process such data.
  1. REGISTRATION INFORMATION RECEIVED AND PROCESSED BY Keyring
  2. When a Customer registers to use the Services, we may collect certain information related to such Customer (“Registration Information”and together with the End User Data, “Customer Data”), including Customer name and Customer details, billing information and names and contact details of Customer employees and representatives who are using the Services (e.g. email, phone number and address). When a Customer uses the Services, Keyring may also collect certain log data, such as IP address from which a Customer is connecting to the Services, information related to the device being used to connect to the Services (e.g. browser type, device type, OS version) and the features and functions of the Services used by the Customer (“Log Data”).

HOW DATA IS COLLECTED

  1. Customer Data may be collected through various methods, including:
  1. When provided voluntarily (e.g. Customer’s Registration Information).
  2. When the Customer integrates Keyring’s SDK’s, API’s, pixels, redirect links, JavaScript tags, cookies or similar data collection technologies into their Applications, websites and/or ads (“Collection Technologies”).
  3. From the various advertising networks and third parties that are used by the Customer in connection with the measurement and analysis of Customer’s marketing campaigns and that have partnered with Keyring (“Partners”).

HOW DATA IS USED BY KEYRING

  1. When Keyring receives End User Data from a Customer, it uses such End User Data as follows:
  1. With regards to Registration Information and Log Data, we use such information to authenticate login to the Services, to communicate with Customer and to process any payments in connection with the Services. Additionally, we may use: (i) Registration Information to inform Customer of any updates to the Services, including new features and functionalities; and (ii) Log Data to understand how Customers are using the Services so that we may efficiently audit, maintain and improve the Services provided to Customers.
  2. Keyring may use information derived from the aggregation of End User Data and/or Log Data with other data for research and analytics purposes and improvement and marketing of the Services (“Aggregated Data”). Aggregated Data shall be anonymous and in no way reveal the identity of the Customer or any End User.

SHARING DATA

Keyring does not share or disclose Customer Data with any third party, except:

  1. Upon our Customer’s request– (e.g. to Partners);
  2. To our subsidiaries and global branches as necessary to help us support and maintain the Services provided to Customers;
  3. To our service providers who help to support our Services – such as data hosting providers and payment processors;
  4. When legally required (e.g. court orders or other lawful requests by public authorities), including to meet national security or law enforcement requirements;
  5. To respond to, or prevent, fraud or to protect the safety of Keyring, its Customers, End Users or the public;
  6. As part of any merger or acquisition of Keyring, in which case End User Data may be transferred to the surviving or acquiring entity.

CROSS BORDER TRANSFERS AND EU-US AND SWISS-US PRIVACY SHIELD

  1. Keyring may need to transfer Customer Data to countries other than the country from which the Data originated. Any such transfer shall be done in compliance with all applicable laws. With regards to the collection, use and retention of personal data transferred from the European Economic Area or Switzerland to the United States, Keyring Inc. complies with the EU-U.S. and Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce.

PROTECTING DATA AND RETENTION

  1. Keyring implements appropriate technical and organizational measures designed to protect against unauthorized access, accidental loss, destruction or damage of Customer Data. 
  2. Keyring will not retain: (i) End User Data for more than twenty four months except where otherwise directed by Customers or required or allowed by law; and (ii) Registration Information, Log Data or Platform Data for more time than is needed to serve the legitimate business need for which it was collected.
  3. RELATIONSHIP, LAWFUL BASIS AND END USER CHOICES
  4. Under the laws of certain jurisdictions, when processing End User Data in connection with the provision of Services to a Customer, Keyring is deemed a ‘data processor’ while its Customers are deemed ‘data controllers’.
  5. Therefore, End Users should closely review the Privacy Policies of the Applications and websites they use in order to learn about the privacy practices of our Customers.
  6. Where Keyring may be deemed a data controller under the laws of certain jurisdictions (e.g. in connection with its processing of Platform Data, Log Data or Registration Information), Keyring shall comply with all applicable laws related to its status as a data controller and shall only use the data as described in this Services Privacy Policy. The lawful basis relied on by Keyring to process Platform Data is its legitimate interest: Keyring may also rely, where appropriate, on consent obtained by Customers on Keyring’s behalf. With regards to Registration Information and Log Data, the lawful basis Keyring relies on is its need to perform its obligations under the Agreement between Keyring and Customer and on its legitimate interests to maintain, analyze and improve the Services.
  7. The laws of certain jurisdictions may provide End Users with various rights in connection with the processing of End User Data, including:
  1. Where Keyring is deemed a data processor, End Users should contact our Customers to pursue any such legal data subject rights. Keyring will cooperate with its Customers to support and comply with any such data subject rights requests. Where Keyring is deemed a data controller, End Users may exercise their rights by contacting Keyring at: privacy@joinkeyring.com. Please note these rights may be limited in certain circumstances as provided by applicable law. In any event, Keyring provides End Users with the ability to opt-out of being tracked by the Services by emailing a request to privacy@joinkeyring.com or by completing the form here. You may also send any question regarding your exercise of data subject rights to privacy@joinkeyring.com.
  2. UPDATES AND QUESTIONS
  3. We may update this Services Privacy Policy from time to time. Any material changes will be notified to the Customer either through the Services, email or as otherwise agreed by the parties in the Agreement. We will also indicate that an update has occurred on the top of this page so Customers and End Users are encouraged to review this Services Privacy Policy from time to time.
  4. For any questions relating to this Services Privacy Policy or to contact our data protection officer please send us an email to: privacy@joinkeyring.com.  

WEBSITE PRIVACY POLICY

This Website Privacy Policy applies to: (i) use of the Keyring Websites (joinjoinkeyring.com, onelink.me and their subdomains); (ii) our marketing activities including, registrations as part of webinars, conference events, emails etc.; and (iii) any other product or activity that links to, or otherwise references, this privacy policy (collectively, the “Marketing Platforms”). This Website Privacy Policy does not apply to information collected through use by customers of the Keyring service, which is described under our Services Privacy Policy.

INFORMATION WE COLLECT

  1. When using or interacting with our Marketing Platforms, we may collect or receive the following types of information (collectively, “Information”).
  1. “Personal Information” such as name, email, contact details or any other personal content that you provide to us whether through a form or field on our website or any other communication (e.g. email, phone, post etc.).
  2. “Technical Information” such as browser type, operating system, device type, IP address and other similar technical information typically received from a browser or device when visiting or interacting with our Marketing Platforms. This may include the referring URL that led you to our website.
  3. “Usage Information” such as the pages you visited on our website, where you clicked, searches performed on our website and other similar information related to how you have used our website. It may also include information related to whether you receive, opened or clicked on any links in an email sent to you.
  1. We understand that certain Technical information or Usage Information may, either alone or when combined with other data, be deemed personal data under various laws and jurisdictions and we are committed to treating such data in compliance with applicable laws.
  2. THE METHODS WE USE TO COLLECT AND RECEIVE INFORMATION
  3. Depending on the type of Information, we may collect or receive Information in the following ways:
  1. When you voluntarily share Information with us. For example, when you register to one of our events, request that we contact you through our online forms, submit your CV, or when you request to receive certain content that we may make available (e.g. research and white papers).
  2. Through use of cookies and other similar technologies (e.g. HTML5 Local Storage, LSO, web beacons, JavaScript, etc.). These technologies help us to analyze how our Marketing Platforms are used and to tailor content that is relevant to you. It also helps us to deliver more relevant advertisements to you on our own or third party sites. For more information on such technologies, including how to manage your cookie preferences please see our Cookie Policy.
  3. Information obtained from third party sources. This includes Information received through the various business support tools and services that we use (e.g. marketing platforms, analytics services etc.) and public sources such as social media sites. We may combine the Information received through these sources with other Information we have in order to ensure our records are up to date and so that we are able to provide you with relevant content. You have choices in how we collect and use Information. 

THE PURPOSES

We use Information for the following purposes:

  1. To process your inquiries and to respond to your requests. For example, when you contact us to learn more about our products or services or when you request to receive certain materials from us (e.g. white papers, research papers, product and services information). Additionally, if you submit your CV us, we use it to evaluate your candidacy (including by assessing your qualifications and skills).
  2. To send you information related to our services and products that we believe may interest you, such as newsletters or product and service updates. Such communications will be sent to you when you have chosen to receive such communication or when we have a legitimate interest to market our products and services. In any event, you will always be able to opt-out of receiving such communications. Opting out may be done either directly in the communication received or through the ways described in the instructions in the “Your Choices” section below.
  3. To understand how you have used our Marketing Platforms and to customize them in accordance with your interests and past actions and choices. We do this based on our legitimate interest to operate our Marketing Platforms, diagnose any problems with the Marketing Platforms and to improve the Marketing Platforms and your experience when navigating through them.
  4. In our legitimate interest to prevent fraud or harm to us or to any third party, and ensure the security of our network and services.
  5. Where it is necessary for Keyring to comply with its legal obligations and to exercise and enforce its legal rights.
  6. We may use certain third-party marketing and advertising networks to help us market our products on our own website and on third party websites (e.g. re-marketing ads across the Internet by Google).

WHO WE SHARE INFORMATION WITH

In order to conduct our business and operate our Marketing Platforms, we may share Information with various third parties, such as:

  1. Our subsidiary companies and global branches.
  2. Third parties that help us operate our Marketing Platforms or provide advertising to you (e.g. hosting company, recruitment platforms and agencies, payment processors, business management and email distribution service providers and other similar service providers).
  3. When required by law, such as to comply with court orders, search warrants, regulatory orders, subpoenas, and other lawful requests by public authorities, including to meet national security or law enforcement requirements;
  4. Legal authorities, consultants, advisors or service providers when required to investigate, respond to, or prevent, fraud; or when required to ensure the security of our network and services and protect the safety of Keyring or the public.
  5. As part of any merger or acquisition of Keyring, Information may be transferred to the merging or acquiring company, as well as to any advisors representing a party during discussions of such merger or acquisition.
  6. Keyring resellers, agents, partners or service providers acting on our behalf in connection with the offering of Keyring’s products or services.
  7. Without derogating from the foregoing, Keyring may publish general aggregate and unidentifiable information (e.g. statistical information) relating to use of its Marketing Platforms.

EU-U.S. AND SWISS-US PRIVACY SHIELD AND CROSS BORDER TRANSFER

  1. We may need to transfer Information to countries where we and/or our service providers operate. Such countries may be different from the country in which the data originated and where data protection laws may not be equivalent to, or offer the same protection as, those in your country. By using our Marketing Platforms, you agree to any such transfers. In any event, where appropriate given the nature of services, we will put in place agreements with our service providers to ensure a level of privacy consistent with the terms of this policy.
  2. With regards to the collection, use, and retention of personal information transferred from the European Economic Area or Switzerland to the United States, we comply with the EU-U.S., and Swiss-US Privacy Shield Framework, as set forth by the U.S. Department of Commerce.

PROTECTING YOUR INFORMATION

  1. We strive to meet the highest standards of security measures across our business units. We have implemented appropriate technical and organizational measures based on industry-leading standards. Such measures are designed to protect against unauthorized access or unlawful processing of Personal Information and against accidental loss, destruction or damage of Personal Information. As part of such measures, we have established various policies and procedures that guide us, including in respect of asset management, access management, physical security, people security, product security, cloud and network infrastructure security, third-party security, vulnerability management, security monitoring, and incident response.

INFORMATION STORAGE AND RETENTION

We may store Information on our own servers as well as those operated by third party data hosting providers. As specified in Section 5 above (EU-US AND SWISS-US PRIVACY SHIELD AND CROSS BORDER TRANSFERS), such servers may be located worldwide. We will only retain your Personal Information for as long as necessary to pursue the purpose of the collection. We may also retain your Personal Information for such time needed to pursue our legitimate business interests, in connection with any legal claims and compliance with legal obligations. When we use your information for direct marketing purposes, we will retain your data until you opt-out from receiving the marketing materials; provided that we will need to retain certain information to maintain a record of your request.

MODIFICATIONS TO THIS POLICY

  1. Keyring may amend this Website Privacy Policy at any time, provided that in the event of a material change we shall provide notice on this page and/or a note near the link to this page. The updates shall apply immediately for new Information collected or provided as of the day of the update and following thirty (30) days for any Information collected or provided to Keyring prior to the update date. If you do not agree to the terms of the new policy you are requested to contact the Legal Department using the contact details listed in Section 11 below. We encourage you to periodically review this page for any updates.

YOUR CHOICES

  1. We provide you with various choices on how we may use Information in connection with: (i) our marketing activities; and (ii) our use of cookies and similar technologies to serve your interest-based advertisements and to analyze usage of our Marketing Platforms.
  1. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page, or you can contact us at support@joinkeyring.com
  2. You can manage your preferences related to our use of cookies and similar technologies that we use, among other things, to provide you with targeted interest-based advertisements and to analyze your use of our product.
  3. In addition, the laws of some jurisdictions may provide you with various rights in connection with our processing of certain Information. Such rights may include:

The right to lodge a complaint with the appropriate data protection authority. Please note these rights may be limited in certain circumstances as provided by applicable law. For any additional information regarding such rights or to exercise any such rights please contact Keyring at: privacy@joinkeyring.com

SOCIAL MEDIA AND THIRD PARTY SERVICES

Our website may offer a blog with ‘comments’ section and various social media features, such as a ‘share’ button or links to third party websites and services, including Twitter, LinkedIn, Google+ and Facebook. When using any such features, certain information may be collected by such third parties, including your IP address or which page you are visiting on our website, and such third parties may set a cookie to enable the feature to function properly. Any data collected by such third parties is governed by such third party’s privacy policy. You are encouraged to carefully review such third party privacy policies.

CHILDREN'S PRIVACY

Keyring does not knowingly collect or process personal data from or with respect to children under the age of 16, and you must be 16 years of age or older in order to establish an account for Keyring’s Services. If you are a parent or legal guardian and believe that your child under the age of 16 has submitted his or her personal data or other data without your consent, permission, or authorization – please let us know immediately, and we will promptly act to remove your child’s data from our database, cease the use of such data and inform any other party we suspect to have access to such data to do the same.

CONTACTING US

If you have any questions or concerns about this Website Privacy Policy, the information we collect, the practices of Keyring, contact us by sending an email to: privacy@joinkeyring.com.


Cookie Statement

When we say “we,” “us,” “our,” and “Keyring,” we are referring to Keyring Inc., 111 S Jackson St. Seattle, WA 98104 USA.

This Cookie Statement explains how we use cookies and similar technologies in the course of our business, including through our websites that link to this Cookie Statement, or any website or application owned, operated or controlled by us (collectively, “Websites” or “websites”), and when our users’ subscribers visit websites or e-commerce stores operated by our users or open or interact with emails delivered through our Services. It explains what these technologies are and why we use them, as well as your rights to control our use of them. This Cookie Statement is and will be treated as part of our Privacy Policy, and is automatically incorporated therein. Capitalized terms used and not otherwise defined in this Cookie Statement have the meanings given to those terms in our Privacy Policy.

In some cases we may use cookies and other tracking technologies described in this Cookie Statement to collect Personal Data, or to collect information that becomes Personal Data if we combine it with other information. 

Definition

Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by online service providers in order to (for example) make their websites or services work, or to work more efficiently, as well as to provide reporting information.

Cookies set by the website owner or service provider (in this case, Keyring) are called “first party cookies”. Cookies set by parties other than the website owner are called “third party cookies”. Third party cookies enable third party features or functionality to be provided on or through the website or service you are using (such as advertising, interactive content and analytics). The third parties that set these third party cookies can recognize your computer both when it visits the website or service in question and also when it visits certain other websites or services. 

Why do we use cookies and other tracking technologies?

We use first party and third party cookies for several reasons. Some cookies are required for technical reasons in order for our Websites and Services to operate, and we refer to these as “essential” or “strictly necessary” cookies. Other cookies enable us and the third parties we work with to track and target the interests of visitors to our Websites, and we refer to these as “performance” or “functionality” cookies. For example, we use cookies to tailor content and information that we may send or display to you and otherwise personalize your experience while interacting with our Websites and to otherwise improve the functionality of the Services we provide. We also enable our users to employ cookies and similar tracking technologies in connection with their use of our Services in order to allow us and our users to track their subscribers. Finally, third parties serve cookies through our Websites and Services for advertising, analytics, and other purposes. 

Cookies served through our Websites

The specific types of first and third party cookies served through our Websites and the purposes they perform are described in further detail below: 

Essential Website Cookies

These cookies are strictly necessary to provide you with services available through our websites and to use some of its features, such as access to secure areas. Because these cookies are strictly necessary to deliver the websites, you cannot refuse them without impacting how our websites function. You can block or delete them by changing your browser settings, as described under in the Cookie Statement.

Performance and Functionality Cookies

These cookies are used to enhance the performance and functionality of our websites but are non-essential to their use. However, without these cookies, certain functionality may become unavailable.

Analytics and Customization Cookies

These cookies collect information that is used either in aggregate form to help us understand how our websites are being used or how effective our marketing campaigns are, or to help us customize our websites and application for you in order to enhance your experience.

Advertising (Targeting) Cookies

These cookies are used to make advertising messages more relevant to you and your interests. They also perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed, and in some cases selecting advertisements that are based on your interests. For further information, see the section of the Cookie Statement entitled "Targeted online advertising."

Other tracking technologies

We and our third party partners may use other, similar technologies from time to time, like web beacons, pixels (or “clear gifs”) and other tracking technologies. These are tiny graphics files that contain a unique identifier that enable us to recognise when someone has visited our Websites or, in the case of web beacons, opened an email that we have sent them. This allows us, for example, to monitor the traffic patterns of users from one page within our Websites to another, to deliver or communicate with cookies, to understand whether you have come to our Websites from an online advertisement displayed on a third-party website, to serve targeted advertisements to you and others like you, to improve site performance, and to measure the success of marketing campaigns. While you may not have the ability to specifically reject or disable these tracking technologies, in many instances, these technologies are reliant on cookies to function properly; accordingly, in those instances, declining cookies will impair functioning of these technologies. 

Targeted online advertising

We have engaged one or more third party service providers to track and analyse both individualized usage and volume statistical information from interactions with our Websites.

These third parties use cookies, web beacons, pixel tags and similar tracking technologies to collect and use certain information about your online activities, either on our Websites and/or other sites or mobile apps, to infer your interests and deliver you targeted advertisements that are more tailored to you based on your browsing activities and inferred interests.

Our third party service providers may also use cookies or web beacons to collect information about your visits to our Websites and/or other sites to measure and track the effectiveness of advertisements and our online marketing activities. The information collected by these third parties does not include personal information that enables you to be specifically identified (e.g. by reference to your name or email address). 

Cookies served through the Services

User email campaigns

We automatically place single pixel gifs, also known as web beacons, in every email sent by our users. These are tiny graphic files that contain unique identifiers that enable us and our users to recognize when their subscribers have opened an email or clicked certain links. These technologies record each subscribers email address, IP address, date, and time associated with each open and click for a campaign. We use this data to create reports for our users about how an email campaign performed and what actions subscribers took. 

User sites

If a user elects to use certain Keyring add-ons or features, the use of those may permit or require additional cookies or tracking technologies to be employed. If a user connects his or her website or e-commerce store (in each case, a “Site”) to a Keyring account, Keyring installs a JavaScript tracking snippet (“Snippet”) on that user’s Site. This Snippet will allow cookies, pixels, and other technologies to be set on that user’s Site to facilitate the use of certain automations, features and functionality offered by Keyring through the Services. The specific cookies, pixels, or other technologies that will be set on a user’s Site depend on the particular add-ons or features that the user chooses to use as part of the Services. Subscribers should therefore review the relevant user’s privacy notice and cookie disclosures for further information about the specific types of cookies and other tracking technologies used on the Site.

How can you control cookies

You have the right to decide whether to accept or reject cookies.

You can set or amend your web browser controls to accept or refuse cookies. If you choose to reject cookies, you may still use our Websites though your access to some functionality and areas of our Websites may be restricted. As the means by which you can refuse cookies through your web browser controls vary from browser-to-browser, you should visit your browser’s help menu for more information.

How often will this Cookie Statement be updated?

We may update this Cookie Statement from time to time in order to reflect, for example, changes to the cookies we use or for other operational, legal or regulatory reasons. Please therefore re-visit this Cookie Statement regularly to stay informed about our use of cookies and related technologies.

The date at the bottom of this Cookie Statement indicates when it was last updated.

If you have any questions about our use of cookies or other technologies, please email us at support@joinkeyring.com.