PRIVACY POLICY

DATA PROTECTION POLICY/PRIVACY POLICY

Last updated: October 9, 2024

Keyhole is the data controller for the processing of your personal data. Keyhole determines the purpose and methods of data processing. Respect for your personal data is extremely important to us, and we have taken measures to ensure that your personal information is processed responsibly and securely. All data processing at Keyhole is carried out in accordance with the General Data Protection Regulation (GDPR).

 

DEFINITIONS

Personal data: Any information that can be directly or indirectly linked to a natural person, e.g., name, CPR number, address, phone number, and email address.

Data subject: An identifiable natural person who can be identified, directly or indirectly, by reference to a name, identification number, location data, etc.

Data processing: Any operation or set of operations that is performed on personal data, including collection, recording, and storage.

Data controller: The entity that determines the purposes and means of processing personal data and has ultimate responsibility for compliance with GDPR and data protection laws.

Data processor: An entity that processes personal data on behalf of the data controller.

 

PERSONAL DATA AND HOW WE PROCESS IT

Keyhole only processes personal data that is necessary to offer our products and services. The personal data we collect depends on your relationship with Keyhole. This may include your name, title, address, payment information, phone number, email address, and credit rating. We only collect the personal data necessary to provide our services.

For tenants: We collect information from you and various registers for credit assessments. You provide personal data when you request a guarantee, and we obtain information from the CPR register and the debtor register to fulfill our obligations under the Credit Agreement Act.

For landlords: We collect personal data from you, including name, address, and account information, as specified in the contract you prepare with us. We also collect and use your IP address to analyze your use of our website, as described in our cookie section.

 

PURPOSES OF PROCESSING PERSONAL DATA

Keyhole processes your personal data for (i) entering into a contract in which you are a party, (ii) fulfilling contractual obligations as a beneficiary, and (iii) sending information and direct marketing via email or otherwise. We require a legal basis for each data processing activity, which is as follows: the processing is necessary for entering into a contract, at the request of the data subject, or to fulfill our legal obligations as creditors, including the rules in the Credit Agreement Act.

AUTOMATED DECISION-MAKING

Keyhole uses automated decision-making processes in credit assessments, but these are not exclusively automated. Employees review the decisions before they are applied and have discretion to modify them. However, any termination is subject to human oversight.

 

MARKETING

We process personal data such as name, title, email address, and phone number for direct marketing of our products and services. Direct marketing may occur via phone, email, or our website. If you wish to unsubscribe from direct marketing, or do not want us to use your personal data for this purpose, you can unsubscribe through your account on our website or by contacting us at info@usekeyhole.com.

STORAGE OF PERSONAL DATA

Your personal data will only be stored as long as necessary to fulfill the purpose of the data processing. Personal data will be deleted or anonymized when they are no longer relevant to the purpose for which they were collected, unless there are legal requirements to retain them for a longer period. We store personal data in accordance with insurance legislation and may retain it for up to 30 years when legally necessary. Data will be removed upon request if there is no associated product.

 

TRANSFER OF PERSONAL DATA

Your personal data will only be transferred to the extent necessary to achieve the purpose of the data processing. Your personal data may be transferred to and used by Keyhole's future offices located within the EU/EEA. Your personal data will only be transferred if it is relevant to achieve the purpose of the data processing. We may exchange necessary personal data with landlords in connection with issuing a deposit guarantee to ensure proper administration of the rental agreement. Keyhole uses data processors to handle specific tasks, such as the operation and support of our IT environment, archiving, and sending information via email. These data processors may access your personal data, but they must not process it for any purposes other than those we specify.

Keyhole has entered into data processing agreements with our data processors, which regulate the extent to which they may process your personal data. Some data processors may have operations in countries outside of Denmark or the EU/EEA ("third countries"). If we transfer your personal data to a data processor in a third country, we will take the necessary security measures to ensure that the transferred personal data is processed in accordance with applicable law. We enter into agreements with our data processors that include clauses approved by the European Commission regarding the protection of personal data.

We will not share, sell, transfer, or otherwise disclose personal data beyond the terms of this privacy policy unless we are legally obligated to do so.

DATA CORRECTION PROCEDURES

We take the accuracy of data seriously and have established processes to ensure that the personal data we hold is correct. We receive requests for data corrections via email and respond to these requests. When new information is provided for an existing person, the tenant will be informed.

YOUR RIGHTS

As a data subject, you have a number of rights, including:

• Right to access: You can request written documentation of the personal data that Keyhole processes about you and how it is used in our business.
  
  
• Right to object: You have the right to object to the collection and further processing of personal data. You may also request that we rectify, restrict, or delete personal data as specified in the GDPR.
  
  
• Right to rectification or deletion: If you believe that any of your personal data is inaccurate, please contact us to have it corrected.
  
  
• Right to data portability: In certain cases, you have the right to request that the information you have provided to us be transferred to another data controller. Such requests should be submitted in writing to Keyhole at info@usekeyhole.com.
  
  
• Right to complain: If you believe that the processing of your personal data is in violation of the data protection regulation, you have the right to lodge a complaint with the relevant data protection authority, which in Denmark is the Danish Data Protection Agency.
  
  
• Right to object to direct marketing: When personal data is used for direct marketing, you have the right to object. Such objections should be submitted in writing to Keyhole at info@usekeyhole.com.

 

COOKIES

Keyhole uses cookies on our website. Cookies are small text files that are stored on your computer when you visit a website. Cookies are used for certain functions that enhance the user experience or provide us with statistics about the use of our website. Your consent is required before we can use cookies for statistical purposes. You give your consent by clicking "Accept cookies."

Everyone visiting a website must be informed about what cookies are used for. Users should be offered the option to consent to cookies being used to store or retrieve data, e.g., on a mobile device or computer. Most web browsers allow you to block cookies.

CONTACT INFORMATION

If you have any questions regarding the content of this privacy policy, or wish to submit any of the above requests, please contact us:
Keyhole ApS
CVR: 40 32 03 77
Email: info@usekeyhole.com

 

DISCLAIMER: This privacy policy has been automatically translated for convenience. The original policy in Danish is the authoritative version. In case of any discrepancies or inconsistencies between the translated version and the original Danish version, the Danish version shall prevail.