KEYS, LLC Privacy Policy

Last updated: January 15, 2019

 

KEYS, LLC (hereinafter referred to as "KEYS, LLC", "we", "us" or "our") operates KEYS.ME and ASIAROOM.COM.

KEYS, LLC provides an online platform that connects hosts who have accommodations and guiding services to list and book with guests seeking to book such accommodations and guiding services (collectively, the "Platform"), which Platform is accessible at Keys.me and AsiaRoom.com websites through which KEYS, LLC makes the Platform available (collectively, the "Site") and as applications for mobile, tablet and other smart devices and application program interfaces (collectively, the "Application").

This Privacy Policy describes how we use and process your personal data in a readable and transparent manner. This Policy applies to any kind of information we collect through our websites or platform or other means connected to them. We might amend the Privacy Policy from time to time. If you care about your privacy, please visit this page regularly. If we make changes to the Privacy Policy which will have an impact on you, we will notify you of these changes before making the changes.

If you do not agree to any part of this Privacy Policy, you should discontinue using our services and deactivate your KEYS, LLC Account. You can find out more about how to deactivate your KEYS, LLC Account by email to admin@keys.me.

 

1. DEFINITIONS

Where the definition of a term does not appear in this Privacy Policy (such as “Listing”, “Accommodation”, “Content,” “Guiding Services” etc.), it shall be given its definition as outlined in our Terms of Service.

“Affiliates” means companies related by common ownership or control. They can be financial and non-financial companies.

“Aggregated Information” means information about all of our users or specific groups or categories of users that we combine together so that it no longer identifies or references an individual user.

“Data Controller” means KEYS, LLC, the company responsible for the use and processing of Personal Information.

“Third Parties” means companies or persons not related by common ownership or control (i.e. non-affiliates) or other unrelated individuals. Third Parties can be financial and non-financial companies, or persons other than you and KEYS, LLC.

“Personal Information” means information (which may include sensitive information) relating to a living individual who is or can be identified either from that information or from that information in conjunction with other information that is in, or is likely to come into, the possession of the Data Controller.

2. WHAT TYPES OF INFORMATION DOES KEYS, LLC GATHER ABOUT ITS USERS?

A. Information that you give us

We receive, store and process information, including Personal Information that you make available to us when accessing or using our Platform and Services. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services.

B. Information we get from your use of our Platform

We also receive, store and process information, possibly including Personal Information, when you access or use our Platform and Services, including but not limited to:

3. HOW KEYS, LLC USES AND PROCESSES THE INFORMATION THAT YOU PROVIDE OR MAKE AVAILABLE

A. We use, store and process information about you for the following general purposes:

B. How KEYS, LLC Uses and Processes User Communications
We may, either directly or through Third-Parties we engage to provide services to us, review, scan, or analyze your communications with other users exchanged via the Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research and customer support purposes. For example, as part of our fraud prevention efforts, the Platform may scan and analyze messages and attachments to mask contact information and references to other websites. This helps to prevent fraudulent actors from asking Guests to send them money outside of the Platform, such as by bank transfer or other money transfer methods. We may also scan, review or analyze messages for research and product development purposes to help make search, booking and user communications more efficient and effective, as well as to debug, improve and expand product offerings. We will not review, scan, or analyze your communications for sending Third-Party marketing messages to you. We will also not sell these reviews or analyses of communications to Third Parties. We will also use automated methods to carry out these reviews or analyses where reasonably possible. However, from time to time we may have to manually review some communications. By using the Platform, you consent that KEYS, LLC, in its sole discretion, may, either directly or through Third-Parties we engage to provide services to us, review, scan, analyze, and store your communications, whether done manually or through automated means.


4. SHARING & DISCLOSURE OF YOUR PERSONAL INFORMATION

IMPORTANT: When you use the Platform, your data may be sent to the United States and possibly other countries in accordance with this Privacy Policy.

We may transfer, store, use and process your information, including any Personal Information, to countries outside of the European Economic Area (“EEA”) including the United States and possibly other countries. By using the Platform, you consent to transferring your data to these countries. Please note that laws vary from jurisdiction to jurisdiction, and so laws and regulations relating to privacy and data disclosure, applicable to the places where your information is transferred to or stored, used or processed in, may be different from the laws and regulations applicable to the place where you are resident.
Your Personal Information may be transferred, stored, used, processed and disclosed as follows:


5. STATE PRIVACY LAWS

For California & Vermont residents: KEYS, LLC Payments will not share information it collects about you with Affiliates or Third Parties, except as required or permitted by your state’s law.


6. BUSINESS TRANSFERS BY KEYS, LLC

If KEYS, LLC undertakes or is involved in any merger, acquisition, reorganization, sale of assets or bankruptcy or insolvency event, then we may sell, transfer or share some or all of our assets, including your Personal Information. In this event, we will notify you before your Personal Information is transferred and becomes subject to a different privacy policy.


7. HOW TO ACCESS, CHANGE OR DELETE YOUR INFORMATION, OR CANCEL YOUR KEYS, LLC ACCOUNT

You may review, update, correct or delete the Personal Information in your KEYS, LLC Account. If you would like to correct your information or cancel your KEYS, LLC Account entirely, you can do so by logging in to your KEYS, LLC Account. Please also note that any reviews, forum postings and similar materials posted by you may continue to be publicly available on the Platform in association with your first name, even after your KEYS, LLC Account is cancelled.


8. SECURING YOUR PERSONAL INFORMATION

We are continuously implementing and updating administrative, technical, and physical security measures to help protect your Personal Information against unauthorized access, destruction or alteration. However, no method of transmission over the Internet, and no method of storing electronic information, can be 100% secure. So, we cannot guarantee the security of your transmissions to us and of your Personal Information that we store.


9. YOUR PRIVACY WHEN YOU ACCESS THIRD-PARTY WEBSITES AND RESOURCES

The Platform will contain links to other websites not owned or controlled by KEYS, LLC. KEYS, LLC does not have any control over Third-Party websites. These other websites may place their own cookies, web beacons or other files on your device, or collect and solicit Personal Information from you. They will have their own rules about the collection, use and disclosure of Personal Information. We encourage you to read the terms of use and privacy policies of the other websites that you visit.


10. SPECIAL FEATURES AND PROGRAMS


11. CHANGES TO THIS PRIVACY POLICY

We may change how we collect and then use Personal Information at any time and without prior notice, at our sole discretion. We may change this Privacy Policy at any time. If we make material changes to the Privacy Policy, we will notify you either by posting the changed Privacy Policy on the Platform or by sending an email to you. We will also update the “Last Updated” date at the top of this Privacy Policy. If we let you know of changes through an email communication, then the date on which we send the email will be deemed to be the date of your receipt of that email.
It’s important that you review the changed Privacy Policy. If you do not wish to agree to the changed Privacy Policy, then we will not be able to continue providing the Platform and Services to you, and your only option will be to stop accessing the Platform and Services and deactivate your KEYS, LLC Account. You can request the information by email us at admin@keys.me.


12. PROTECTION OF DATA: CHILDREN AGED 16 YEARS OR BELOW

The services offered by KEYS, LLC are not directed at children under 16 years old. For children younger than 16 years old, the use of any of our services is only allowed with the valid consent of a parent or a guardian. In limited cases as part of a reservation, purchase of other travel-related services, or in exceptional other circumstances (such as features addressed to families), KEYS, LLC may collect and use information of children only as provided by the parent or guardian or with their consent. If we become aware that we process information of a child under 16 years old without the valid consent of a parent or guardian, we reserve the right to delete it.


13. YOUR RIGHTS

You may exercise any of the rights described in this section before your applicable Data Controller by sending an email to admin@keys.me. Please note that we may ask you to verify your identity before taking further action on your request.

Managing Your Information.
You may access and update some of your information through your Account settings. If you have chosen to connect your KEYS,LLC Account to a third-party application, like Facebook or Google, you can change your settings and remove permission for the app by changing your Account settings. You are responsible for keeping your personal information up-to-date.

Rectification of Inaccurate or Incomplete Information.
You have the right to ask us to correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself within your KEYS,LLC Account).

Data Access and Portability.
In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).

Data Retention and Erasure.
We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information to provide the Platform to you, you can request that we erase your personal information and close your KEYS, LLC account. Please note that if you request the erasure of your personal information:
We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend an account for fraud or safety reasons, we may retain certain information from that account to prevent that member from opening a new account in the future.
We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, KEYS, LLC and KEYS, LLC Payments may keep some of your information for tax, legal reporting and auditing obligations.
Information you have shared with others (e.g., Reviews, forum postings) may continue to be publicly visible on the Platform, even after your account is cancelled. However, attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
Because we maintain the Platform to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

Withdrawing Consent and Restriction of Processing.
Where you have provided your consent to the processing of your personal information by us you may withdraw your consent at any time by changing your account settings or by sending a communication to us specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims. ; or (iv) you have objected to the processing and pending the verification whether the legitimate grounds of Airbnb override your own.

Objection to Processing.
In some jurisdictions, applicable law may entitle you to require KEYS, LLC and KEYS, LLC Payments not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing KEYS, LLC and/or KEYS, LLC Payments will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims.
Where your personal information is processed for direct marketing purposes, you may, at any time ask us to cease processing your data for these direct marketing purposes by sending an e-mail to admin@keys.me.

Lodging Complaints.
You have the right to lodge complaints about the data processing activities carried out by KEYS, LLC and KEYS, LLC Payments before the competent data protection authorities.


14. FOR USERS RESIDING IN THE EU AND JAPAN ONLY: YOUR RIGHTS TO REVIEW AND UPDATE INFORMATION

If you reside in the EU or Japan, you may request in writing copies of your Personal Information held by us. We will provide you with a copy of the Personal Information held by us as soon as practicable and in any event not more than 40 days after receiving a valid request in writing. There may be a charge to access your personal data (which will not exceed €6.35 in Ireland and £10 in the United Kingdom, and will not be applicable in Japan). We may also request proof of identification to verify your access request. All requests should be addressed to our Data Protection Compliance Officer.
We endeavor to keep your information accurate, complete and up to date. If your Personal Information that we hold is inaccurate, please let us know and we will make the necessary amendments, erase or block the relevant information and notify you within 40 days of your valid request that the relevant action has been taken.
You may also request the erasure of your Personal Information if you believe we are otherwise in breach of relevant data protection legislation. All requests should be addressed to our PO Box 92597 Washington, DC 2009. There is no charge for making such a request.


15. FOR USERS RESIDING IN THE EU: YOUR RIGHT TO SEE AND CHALLENGE INFORMATION PROVIDED TO US BY THIRD PARTIES

You are entitled to see and challenge any information that Third Parties may provide to us as part of our fraud detection, prevention and risk assessment efforts in circumstances where all of the following factors apply: (i) if we use Third Parties to carry out automated checks or risk assessments, and (ii) if we make a decision which has legal consequences for you or which significantly affects you, and (iii) if such decision is based solely on such automated checks or risk assessments. In order to request this, please address your request directly to KEYS, LLC address. Please state clearly in your request that you wish to see and/or challenge the information that Third Parties may have provided to KEYS, LLC as part of our fraud detection, prevention and risk assessment efforts. We may request proof of identification to verify your request.
KEYS, LLC is subject to the authority of the Federal Trade Commission and has certified with the Privacy Shield as required by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from the European Union member countries. KEYS, LLC certifies that it adheres to the Privacy Shield principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. Consistent with these principles, where KEYS, LLC uses service providers to process personal data of European Union residents, KEYS, LLC shall remain liable where the agent processes such personal data of European Union residents in a manner inconsistent with the Privacy Shield principles, except where KEYS, LLC establishes that KEYS, LLC is not responsible for the damages caused by the agent. To learn more about the Privacy Shield program, and to view the list of entities who have current certifications under the Privacy Shield, please visit the U.S. Department of Commerce’s Privacy Shield List.
If you have any questions or complaints about KEYS, LLC’s privacy practices, you may contact KEYS, LLC at KEYS, LLC address, telephone or email contact and we will work with you to resolve your issue. As a resident of the European Union, you may also contact your appropriate European Data Protection Authority with questions or complaints about our privacy practices.
Residents of the European Union who are dissatisfied with the way in which we have addressed your concerns about our privacy practices may seek further assistance from our designated Privacy Shield independent recourse mechanism, JAMS.
Residents of the European Union who have unresolved complaints after: (1) contacting KEYS, LLC to resolve the issue; (2) seeking assistance from our independent recourse mechanism; and (3) contacting the U.S. Department of Commerce (either directly or through a European Data Protection Authority) and giving the Department of Commerce time to attempt to resolve the issue, may elect to arbitrate certain claims. Claims shall be arbitrated free of charge by our arbitration provider, the American Arbitration Association ("AAA"), though each party will be responsible for its own attorney’s fees. Please be advised that, pursuant to the Privacy Shield, the arbitrator(s) may only impose individual-specific, non-monetary, equitable relief necessary


16. COOKIE POLICY

KEYS, LLC uses “cookies” in conjunction with the Platform to obtain information. A cookie is a small data file that is transferred to your device (e.g. your phone or your computer) for record-keeping purposes. For example, a cookie could allow the Platform to recognize your browser, while another could store your preferences and other information.
Your browser may allow you to set how it handles cookies, such as declining all cookies or prompting you to decide whether to accept each cookie. But please note that some parts of the Platform may not work as intended or may not work at all without cookies.