Privacy Policy

1. Purpose

Keye, Inc. (together with our affiliates, “Keye”, “we”, “our” or “us”) respect your privacy and

are committed to keeping secure any information we obtain from you or about you. This Privacy

Policy describes our practices with respect to Personal Information we collect from or about you

when you use our website, applications, and services (collectively, “Services”).

Our privacy policy (“Privacy Policy”), the Terms of Use, and, as applicable, the Master Services

Agreement between us and your employer comprise the entire agreement governing access to

and use of the Website and Software (collectively, the “Agreement”). By visiting our website or

using the Software, you agree to the Agreement. If your employer entered into an MSA with us,

then you represent that you are an authorized user of the Website and the Software and will abide

by the terms of the Agreement. Capitalized terms not defined in this policy shall have the

meaning set forth in our Terms of Use.

Any person accessing, browsing, or otherwise using our website or Software, either manually or

via an automated device or program, is a “User” for purposes of this Notice.

2. Personal information we collect

We collect personal information relating to you (“Personal Information”) as follows:

Personal Information You Provide

We collect Personal Information if you or your employer creates an account to use our Services

or communicate with us as follows:

‍

Account Information

When a user account is created to use our Services, we will collect information associated with

your account, including your name, title, department, company name, and contact information.

‍

User Content

We collect Personal Information that is included in Software input and prompts, 3rd party data,

data file uploads, and feedback that you and other users provide to our Services.

‍

Communication Information

If you communicate with us, we collect your name, contact information, and the contents of any

messages you send.

‍

Job Applicant Information

If you apply for a position with us, we collect your name, contact information, and the contents

of any resume you send.

Personal Information We Receive Automatically From Your Use of the

Services

When you visit, use, or interact with the Services, we receive the following information about

your visit, use, or interactions:

‍

Log Data

Information that your browser automatically sends when you use our Services. Log data includes

your Internet Protocol address, browser type and settings, the date and time of your request, and

how you interact with our website.

‍

Usage Data

We may automatically collect information about your use of the Services, such as the types of

content that you view or engage with, the features you use and the actions you take, as well as

your time zone, country, the dates and times of access, user agent and version, type of computer

or mobile device, and your computer connection.

‍

Device Information

Includes name of the device, operating system, device identifiers, and browser you are using.

Information collected may depend on the type of device you use and its settings.

‍

Cookies

We use cookies to operate and administer our Services, and improve your experience. A

“cookie” is a piece of information sent to your browser by a website you visit. You can set your

browser to accept all cookies, to reject all cookies, or to notify you whenever a cookie is offered

so that you can decide each time whether to accept it. However, refusing a cookie may in some

cases preclude you from using, or negatively affect the display or function of, a website or

certain areas or features of a website.

‍

Analytics

We may use a variety of online analytics products that use cookies to help us analyze how users

use our Services and enhance your experience when you use the Services.

‍

3. How we use personal information

We may use Personal Information for the following purposes:

•   Service Delivery: We use your personal information to provide you with the products or

      services you have requested. This may include processing your payment, shipping

      products to your address, or providing access to our online services. The lawful basis for

      this processing is typically the performance of a contract because we need to process your

      data to fulfill our contractual obligations to you.

•   Communication: We may use your contact information to communicate with you. This

      includes sending transactional emails, service updates, and responding to your inquiries or

      requests. We may also use your contact information for marketing purposes, such as

      sending newsletters or promotional offers if you have provided your consent or if we have

      a legitimate interest in doing so. The lawful basis for processing personal information for

      communication is legitimate interests and, when applicable, consent if you have provided

      it.

•   Account Management: We use your personal information to manage your account,

      including account setup, verification, and maintenance. This ensures the security and

      functionality of your account on our platform. The lawful basis for this processing is

      typically the performance of a contract to maintain your account.

•   Customer Support: Your information allows us to provide customer support when you

      have questions or encounter issues with our products or services. This may include

      troubleshooting, resolving complaints, and addressing your concerns. This processing is

      based on the legitimate interests to assist you in using our services effectively.

•   Improvement of Services: We analyze your data to understand how our services are

      used and to make improvements. This includes enhancing the user experience, developing

      new features, and optimizing the performance and security of our products. This

      processing is also based on legitimate interests to improve and maintain the quality of our

      services.

•   Legal Compliance: We may process your personal information to comply with our legal

      obligations, such as tax reporting, responding to legal requests, or assisting law

      enforcement agencies when required by law. This processing is necessary to fulfill legal

      obligations.

•   Contractual Obligations: If you are a client or business partner, we may use your

      personal information to fulfill our contractual obligations, including managing contracts,

      invoicing, and providing support as agreed upon in our business relationship. The lawful

      basis for this processing is the performance of a contract. Fraud Prevention and Security:

      We use your information to protect against fraud, unauthorized access, and other security

      risks. This may include monitoring account activities and implementing security

      measures. The lawful basis for this processing is legitimate interests to ensure the security

      and integrity of our services.

•   Aggregated and Anonymized Data: We may aggregate and anonymize your data to

      create statistical or research reports, which do not personally identify you. This

      information may be used for business analysis, marketing, and sharing with partners or

      clients. The lawful basis for processing aggregated and anonymized data is legitimate

      interests and the fact that this data is no longer considered personal information.

•   Other Purposes: In addition to the purposes listed above, we may use your personal

      information for other legitimate purposes, provided that they are compatible with the

      original reasons for which your data was collected. For these other purposes, we will rely

       on legitimate interests or other lawful bases as required by applicable laws.

We may share your personal information with the following categories of recipient:

• Service Providers:

    We may share your personal information with third-party service providers who assist us in

    delivering our products and services. These service providers may include [[service

    providers (e.g., cloud hosting providers, payment processors, customer support tools,

    customer relationship management systems, analytics providers, and security services)]].

    We will only share the minimum necessary data required for them to perform their specific

    tasks. All service providers are contractually obligated to:

• Process personal data only for the purpose of providing the agreed-upon services and not for their own benefit.
• Implement appropriate technical and organizational security measures to protect personal data.
• Comply with applicable data protection laws (e.g., GDPR, CCPA) and relevant security standards.

    If we transfer personal data outside of legally recognized jurisdictions (e.g., the EU/EEA),

    we ensure that appropriate safeguards, such as Standard Contractual Clauses (SCCs) or

    Data Processing Agreements (DPAs), are in place.

    The lawful basis for sharing data with service providers is typically the performance of a

    contract or, in some cases, legitimate interests, provided that these interests do not

    override your data protection rights.

‍

• Business Partners and Affiliates: In some cases, we may share personal information with

    our business partners and affiliates, but only when it is necessary for the performance of a

    contract, the provision of services, or as part of a legitimate business interest. For example,

    we may share data with a partner organization involved in co-branded events or services.

    Sharing data with business partners and affiliates may be necessary for the performance of a

    contract or based on legitimate interests, especially when these partnerships are essential for

    delivering integrated or co-branded services.

• Legal Authorities: We may be required to share personal information with legal

    authorities, regulatory bodies, or law enforcement agencies when necessary to comply with

    legal obligations or respond to valid requests for information, as permitted by the law. The

    lawful basis for sharing with legal authorities is the necessity to comply with a legal

    obligation.

• Merger or Acquisition: In the event of a merger, acquisition, or sale of all or part of our

    business, the sharing of personal information with the acquiring entity or parties involved in

    the transaction may be based on legitimate interests, as it's necessary for the legitimate

    interests pursued by us or the acquiring entity. We will ensure that your data remains

    protected and used in accordance with this Privacy Policy.

• Publicly Available Information: We may share personal information that is publicly

    available, such as information from public records or online sources. However, we will do

    so only when it is relevant to the purposes for which your data was collected and used.

    Sharing publicly available personal information is typically based on legitimate interests, as

    it is in the legitimate interests of our business to use publicly available data for relevant

    purposes.

• With Your Consent: We may share your personal information with third parties if you

    have provided your explicit consent for such sharing. We will always request your consent

    before sharing your data for specific purposes. If you have provided explicit consent for

    sharing your personal information with specific third parties, the lawful basis for sharing is

    your consent.

 • Other Legitimate Business Interests: In certain cases, we may share personal information

     with other parties for legitimate business interests. The sharing of this personal information

     may be based on legitimate interests. We will always ensure that such sharing is conducted

     in accordance with applicable data protection laws and respect your rights.

‍

4. Disclosure of personal information

In certain circumstances we may provide your Personal Information to third parties without

further notice to you, unless required by the law:

‍

Vendors and Service Providers

To assist us in meeting business operations needs and to perform certain services and functions,

we may provide Personal Information to vendors and service providers, including providers of

hosting services, cloud services, and other information technology services providers, email

communication software, and web analytics services, among others. Pursuant to our instructions,

these parties will access, process, or store Personal Information only in the course of performing

their duties to us.

‍

Business Transfers

If we are involved in strategic transactions, reorganization, bankruptcy, receivership, or

transition of service to another provider (collectively, a “Transaction”), your Personal

Information and other information may be disclosed in the diligence process with counterparties

and others assisting with the Transaction and transferred to a successor or affiliate as part of that

Transaction along with other assets.

‍

Legal Requirements

We may share your Personal Information, including information about your interaction with our

Services, with government authorities, industry peers, or other third parties (i) if required to do

so by law or in the good faith belief that such action is necessary to comply with a legal

obligation, (ii) to protect and defend our rights or property, (iii) if we determine, in our sole

discretion, that there is a violation of our terms, policies, or the law; (iv) to detect or prevent

fraud or other illegal activity; (v) to protect the safety, security, and integrity of our products,

employees, or users, or the public, or (vi) to protect against legal liability.

‍

Affiliates

We may disclose Personal Information to our affiliates, meaning an entity that controls, is

controlled by, or is under common control with Keye. Our affiliates may use the Personal

Information we share in a manner consistent with this Privacy Policy.

‍

5. Your rights

Depending on location, individuals in the EEA, the UK, and across the globe may have certain

statutory rights in relation to their Personal Information. For example, you may have the right to:

•   Access your Personal Information and information relating to how it is processed.

•   Delete your Personal Information from our records.

•   Rectify or update your Personal Information.

•   Transfer your Personal Information to a third party (right to data portability).

•   Restrict how we process your Personal Information.

•   Withdraw your consent—where we rely on consent as the legal basis for processing at

      any time.

•   Object to how we process your Personal Information.

•   Lodge a complaint with your local data protection authority.

You can exercise these rights by sending your request to contact@keye.co

‍

6. Additional U.S. State Disclosures

The following table provides additional information about the categories of Personal Information

we collect and how we disclose that information. You can read more about the Personal

Information we collect in “Personal information we collect” above, how we use Personal

Information in “How we use personal information” above, and how we retain Personal

Information in “Security and Retention” below.

‍

‍

To the extent provided for by local law and subject to applicable exceptions, individuals may

have the following privacy rights in relation to their Personal Information:

•   The right to know information about our processing of your Personal Information,

      including the specific pieces of Personal Information that we have collected from you;

•   The right to request deletion of your Personal Information;

•   The right to correct your Personal Information; and

•   The right to be free from discrimination relating to the exercise of any of your privacy

      rights.

‍

We don’t “sell” Personal Information or “share” Personal Information for cross-contextual

behavioral advertising (as those terms are defined under applicable local law). We also don’t

process sensitive Personal Information for the purposes of inferring characteristics about a

consumer.

Exercising Your Rights

To the extent applicable under local law, you can exercise privacy rights described in this section

by submitting a request to contact@keye.ci

‍

Verification

In order to protect your Personal Information from unauthorized access, change, or deletion, we

may require you to verify your credentials before you can submit a request to know, correct, or

delete Personal Information. If you do not have an account with us, or if we suspect fraudulent or

malicious activity, we may ask you to provide additional Personal Information and proof of

residency for verification. If we cannot verify your identity, we will not be able to honor your

request.

‍

Authorized Agents

You may also submit a rights request through an authorized agent. If you do so, the agent must

present signed written permission to act on your behalf and you may also be required to

independently verify your identity and submit proof of your residency with us. Authorized agent

requests can be submitted to contact@keye.co.

‍

Appeals

Depending on where you live, you may have the right to appeal a decision we make relating to

requests to exercise your rights under applicable local law. To appeal a decision, please send

your request to contact@keye.co.

‍

7. Children

Keye does not knowingly collect Personal Information from children under the age of 13. If you

have reason to believe that a child under the age of 13 has provided Personal Information to

Keye through the Service, please email us at contact@keye.co. We will investigate any

notification and if appropriate, endeavor to delete the Personal Information from our systems. If

you are 13 or older, but under 18, you must have consent from your parent or guardian to use our

Services.

8. Links to other websites

The Service may contain links to other websites not operated or controlled by Keye, including

social media services (“Third Party Sites”). The information that you share with Third Party

Sites will be governed by the specific privacy policies and terms of service of the Third Party

Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or

have reviewed these sites. Please contact the Third Party Sites directly for information on their

privacy practices and policies.

9. Security and Retention

We implement commercially reasonable technical, administrative, and organizational measures

to protect Personal Information both online and offline from loss, misuse, and unauthorized

access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever

fully secure or error free. In particular, email sent to or from us may not be secure. Therefore,

you should take special care in deciding what information you send to us via the Service or

email. In addition, we are not responsible for circumvention of any privacy settings or security

measures contained on the Service, or third-party websites.

We’ll retain your Personal Information for only as long as we need in order to provide our

Service to you, or for other legitimate business purposes such as resolving disputes, safety and

security reasons, or complying with our legal obligations. How long we retain Personal

Information will depend on a number of factors, such as the amount, nature, and sensitivity of

the information, the potential risk of harm from unauthorized use or disclosure, our purpose for

processing the information, and any legal requirements.

10. International users

By using our Service, you understand and acknowledge that your Personal Information will be

processed and stored in our facilities and servers in the United States and may be disclosed to our

service providers and affiliates in other jurisdictions.

‍

For EEA, UK or Swiss users

Legal Basis for Processing

Our legal bases for processing your Personal Information include:

  •   Performance of a contract with you when we provide and maintain our Services. When

      we process Account Information, Content, and Technical Information solely to provide

      our Services to you, this information is necessary to be able to provide our Services. If

      you do not provide this information, we may not be able to provide our Services to you.

  •   Our legitimate interests in protecting our Services from abuse, fraud, or security risks, or

      in developing, improving, or promoting our Services, including when we train our

      models. This may include the processing of Account Information, Content, Social

      Information, and Technical Information. See here for instructions on how you can opt out

      of our use of your information to train our models.

  •   Your consent when we ask for your consent to process your Personal Information for a

      specific purpose that we communicate to you. You have the right to withdraw your

      consent at any time.

  •   Compliance with our legal obligations when we use your Personal Information to comply

      with applicable law or when we protect our or our affiliates’, users’, or third parties’

      rights, safety, and property.

‍

Data Transfers

Where required, we will use appropriate safeguards for transferring Personal Information outside

of the EEA, Switzerland, and the UK. We will only transfer Personal Information pursuant to a

legally valid transfer mechanism. For more information on the appropriate safeguards in place

and to obtain a copy of these safeguards, please contact us at contact@keye.co.

‍

Data Controller

For the purposes of the UK and EU General Data Protection Regulation 2018, our data controller

is Keye, INC at PO Box 77 Fulton Street, New York City, NY-10038.

11. Changes to the privacy policy

We may update this Privacy Policy from time to time. When we do, we will post an updated

version on our website, unless another type of notice is required by applicable law

12. How to contact us

Please contact us at contact@keye.co or write to us at Keye, INC at PO Box 77 Fulton Street,

New York City, NY -10038 if you have any questions or concerns not already addressed in this

Privacy Policy.