key.guru App Privacy Policy
Privacy Policy for the key.guru App
- Responsible data controller
The responsible data controller for the key.guru app is key.guru Ltd. Registered at Suite 3 Middlesex House, Rutherford Close, Stevenage, United Kingdom, SG1 2EF
If you have any question, please do not hesitate to contact us via hello@key.guru
- What qualifies as personal data?
Personal data means information relating to an identifiable natural person, such as your name, e-mail address, telephone number, postal address or the IP address of your computer.
- What data do we use for what purposes?
In the following we explain which personal data we process. As far as such data is processed or stored, this occurs on your smartphone and /or in a IT environment.
Unless it is explicitly stated otherwise in the following sections the legal basis for this processing of data is Art. 6 (1) b) GDPR (performance of a contract).
3.1 Technical communication data
We collect and use personal data which your smartphone automatically transmits to us and which is used for communication with your smartphone. These are in particular
- the name of the device
- the operating system and app version
- the mobile phone provider
- different identification numbers in order to be able to uniquely assign the device to you
- the time of occurrence of app disturbances for troubleshooting, and
- the IP address assigned to you.
3.2 Tracking Information
We also use tools to collect “tracking information” which can be used to track your usage of the app. This involves the following information:
- Which pages and contents of our app did you visit and view when, how often and in which order,
- which entries do you make within the app,
- which device functions of your smartphone are available and activated,
- what is the connection speed to the internet,
- what changes are detected by the motion sensors of your smartphone,
- which other apps do you have installed,
- which location do you have when using our app (localization),
- which photos did you take (camera data)
Both the localization and the possibility of taking photos are optional features that serve the functional diversity of our app (see section 6).
The legal basis for the associated processing of your personal data is Art. 6 (1) f) GDPR (balancing of interests, based on our legitimate interest in constantly and profitably improving the content, functionality and attractiveness of the app by analyzing your usage) as well as Art. 6 (1) b) GDPR (performance of a contract) and Art. 6 (1) a) GDPR (your consent).
Statistics
In order to ensure and improve the quality of the services we collect statistical data through various service providers. Please find below in this document all service providers we use for statistical purposes.
Personalization
In order to display personalized content, we use various service providers to track the usage of the app. Please find below in this document all service providers we use for personalization purposes.
Registration
In order to be able to use the functions of this app, you must set up a user account (hereinafter “account”).
In order to set up a user account, users must enter their email address and a PIN will be assigned to the user by the system, which at the same time serve as an access code for the account. With the same access data, the user can also log on the key.guru portal, which is part of the app, at https://portal.key.guru
After successful registration, the user automatically receives confirmation by e-mail. In this way, the user concludes the contract for the provision of the account with us. In addition, users can store their personal contact details in their account and update these details at any time.
Unless you “log off” by clicking, so-called persistent cookies are stored on your terminal device, which serve to ensure that the user does not have to log on again during subsequent visits to the app.
The legal basis for the associated processing of your data and for the display of corresponding information in the App is Art. 6 (1) b) GDPR (performance of contract) or Art. 6 (1) f) GDPR (balancing of interests, based on our legitimate interest in providing users with a simple and customer-friendly user experience).
The user can terminate his / her contract for the provision of the account at any time and without giving any reasons. The way to do this is by speaking to the dealership key.guru administrator.
- App permissions
In order to provide you with the functionalities of the app, the app must be able to access various functions and data on your mobile device.
For this purpose, it is technically absolutely necessary that you grant the app the following access permissions for the purposes described in each case. Otherwise, the app is not fully usable for technical reasons. The reason for this is that the permission settings in smartphone operating systems are usually programmed in such a way that some authorizations can only be granted or requested together and not in the form of individual partial authorizations. Therefore, key.guru is dependent in such cases on requesting the entire authorization from customers, even if only part of it is required and used specifically.
In the following, we will inform you about the permissions required by this app, whereby we will only use these to the extent required in each case, even if an authorization technically includes more.
The legal basis for the associated processing of your data is Art. 6 (1) b) GDPR (performance of contract) respectively Art. 6 (1) a) GDPR (your consent).
4.1 Your location
Your consent to the collection of your current location is required for location-based services. If you give your consent, your device may use your GPS data, WLAN identifiers and/or Bluetooth to determine your location, depending on what you have activated.
In any case, the app only collects your location only if you have previously agreed to this in the corresponding device settings. For Android versions, consent is given after confirmation when downloading the app or in the device settings. For Windows Mobile and iPhone versions, consent is given in a dialog box when the app is first opened as well as in the device settings.
Right of withdrawal:
You are entitled to revoke your consent at any time for the future.
The legal basis for location processing is Art. 6 (1) a) GDPR (your consent).
4.2 Location mapping
Our app allows you to display your location on a map, provided you have consented to the collection of your location.
The app uses the HereMapping Service, supplied by HERE Global B.V., Kennedyplein 222-226, 5611 ZT Eindhoven, Netherlands, which receives your location information through satellite, mobile, Wi-Fi, Bluetooth Low Energy (“BLE”) or other network based positioning methods to display the map. The legal basis for this is Art. 6 (1) f) GDPR (balancing of interests, based on our interest in offering you the most attractive app possible).
The relevant privacy policy of this third-party provider can be found at legal.here.com/en-gb/privacy
4.3 Network Communication (full internet access)
This permission is needed to enable the app to establish a connection to us via the Internet and to communicate with us regarding the services you require.
The legal basis for the data processing associated herewith is Art. 6 (1) b) GDPR (performance of a contract).
4.3 Camera
Your consent to access your system-side camera is required so that you can digitize a room while using our app.
Right of withdrawal:
You are entitled to revoke your consent at any time for the future.
The legal basis for access to your system camera is Art. 6 (1) a) GDPR (your consent).
- Microsoft App Center Analytics (Category “Statistics”)
We also use Microsoft App Center Analytics, an analysis service provided by Microsoft, Microsoft App Center Analytics uses Cookies stored on your smartphone or tablet PC that enable an analysis of your use of the app.
The information generated by Microsoft App Center Analytics about your use of this app will be transmitted to and stored by Microsoft on it servers. Microsoft will use this information for the purpose of evaluating your use of the app, compiling reports on app activity for the app operators and providing other services relating to app activity and internet usage.
As far as Microsoft collects data related to the individual terminal device (MAC address, IMEI number, device identifier), these will be deleted immediately after collection and replaced by a Microsoft-specific code. key.guru receives the information obtained via Microsoft in aggregated form, such as: e.g. number of users in a period, number of users per device type, period of use. key.guru does not evaluate personal data.
It should be noted that there is currently no decision by the EU Commission that the USA generally provides an adequate level of data protection.
For more information on the handling of user data on Microsoft App Center Analytics, please see the Microsoft App Center Security and Compliance or the Privacy Policy
The legal basis for the associated data processing is Art. 6 (1) f) GDPR, i.e. the processing is necessary for the perception of our legitimate interest in constantly improving the content, functionality and attractiveness of the app on the basis of the analysis of your usage behaviour.
- Data Security
As far as this app communicates with key.guru, this is done in encrypted form. Please note, however, that personal data stored locally on your device may be misused by third parties, e.g. if your mobile phone is stolen. We therefore recommend that you carefully secure your device accordingly, e.g. with a code lock.
If the app is uninstalled, all personal data in the app will be deleted.
- Retention Periods
We store personal data only as long as it is necessary for the purposes described herein, or as long as it is necessary to comply with statutory storage periods.
Automatically collected technical communication data and tracking information within the meaning of sections 3.1 and 3.2 will be deleted or anonymized after a period of 3 years at the latest.
- Your rights
You have the following rights with regard to the personal data concerning you:
Insofar as the legal basis for the processing of data is Art. 6 (1) f) GDPR (the processing of data serves our legitimate interests), you have the right to object to the processing of data at any time. In order to do so, you may send us an email support@key.guru
You furthermore have the following rights with regard to the personal data concerning you:
- right of information,
- right of rectification or deletion,
- right to limitation of processing,
- right to data portability.
You also have the right to complain to a data protection supervisory authority about our processing of your personal data.
November 2020
Last updated: December 1 2020