Privacy Policy

Privacy Policy

Last Updated: November 1, 2023

This Privacy Policy describes the data protection practices of Keys2Eternity & Beyond, LLC. (“K2E”, “we,” “us,” or “our”). K2E provides services to users throughout the world and is the data controller of your information. This Privacy Policy applies to all websites and mobile applications owned and operated by us or our affiliates under common ownership or control of K2E that link to this Privacy Policy (“Affiliates”) and related online and offline services thereto (including our social media pages (collectively, the “Services”).

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES.

Please read the following (“Privacy Policy”) to learn about our privacy practices. This Privacy Policy explains how we collect, use, and disclose data when you use our platform and associated services, and tells you how to contact us.

Privacy Policy Summary

This is a summary of our Privacy Policy. To review our Privacy Policy in full please scroll down.

What does this Privacy Policy cover?

This Privacy Policy is designed to describe:

• How and what type of personal information we collect and use
• When and with whom we share your personal information
• What choices you can make about how we collect, use, and share your personal information

What personal information do we collect and use, and how do we collect it?

We collect personal information when:

• You give us the information
• We collect it automatically
• We receive it from others

When you create an account on one of our sites, sign up to receive offers or information, or otherwise use our platform, you give us your personal information. We also collect such information through automated technology such as cookies placed on your browser, with your consent where applicable, when you visit our sites. We also receive information from business partners and other third-parties, which help us improve our platform and associated tools and services, update and maintain accurate records, potentially detect, and investigate fraud, and more effectively market our services. 

How is your personal information shared?

Your personal information may be shared with third parties for several purposes, including: to help provide you information, services, assist with your use of our services, communicate with you (including when we send information on products and services or enable you to communicate with others), and comply with the law, where applicable, depending on your interaction with the site. The full Privacy Policy below details how personal information is shared.

What are your rights and choices?

You can exercise your data protection rights in various ways. For example, you can opt out of marketing by clicking the “unsubscribe” link in the emails, in your account as applicable, or contacting our customer service. Our full Privacy Policy has more information about the options and data protection rights available to you.

How to contact us

More information about our privacy practices is in our full Privacy Policy below. Please contact us as to ask questions about how we handle your personal information or make requests about your personal information at info@keys2eternity.com.

Privacy Policy

Categories of Personal Information we collect

Use of Personal Information

Sharing of Personal Information

Your Rights and Choices

Security

Record Retention

Updates to Privacy Policy

Contact Us

Categories of Personal Information we collect

We receive and store any information you provide to us through the Site or given to us in any other way. This includes information that can identify you, such as your first and last name, telephone number and postal and email addresses (“personal information”). We may collect the following categories of personal information:

• Name, email address, telephone number, business, and billing addressees
• Payment information such as payment card number, expiration date, and billing address where required
• Non-specific geolocation data
• Images, videos, and other recordings
• Social media account ID and other publicly available information
• Communications with us
• Searches you conduct, transactions, and other interactions with you on our online services
• The searches and transactions conducted through the platform
• Data you give us about other people associated with you or your company
• We also may periodically obtain both personal and non-personal information about you from affiliated entities, business partners and other independent third-party sources.

Sensitive Personal Information. We only collect sensitive personal information either with consent or in accordance with local law. This may include information which could reveal your racial or ethnic origin, religious or philosophical beliefs, sexual orientation, trade union or other professional membership, and health or disability information.

Automatically Collected Information. We automatically collect some information about your computer and your online activity when you visit the Site. For example, we may collect your IP address and information about what web browser software you use to access the Site (such as Google Chrome, Firefox, Safari or Internet Explorer) and referring website. Where permitted by local law, we may also automatically collect information you enter into any data fields shown on the Site, including your email address and log-in credentials. We may also collect information about your online activity, such as trips viewed or bookings made. Our goals in collecting this automatic information include helping to customize your user experience and inhibiting fraud.

Use of Personal Information

We use information about you for the following general purposes:

• Provide you with the products and services you request;
• Communicate with you in general;
• Respond to your questions and comments;
• Measure interest in and improve our products, services and the Site;
• Customize your experience with this Site;
• Solicit information from you, including through surveys; to resolve disputes, or troubleshoot problems;
• Prevent, investigate or take action on potentially prohibited or illegal activities;
• Enforce the Site’s Terms of Use;
• Activities related to our business; and
• As otherwise described to you at the point of collection.

Email Communications. We want to make it easy for you to take advantage of opportunities on our Site, by sending email messages regarding information and services. Please note that you will have the opportunity to choose not to receive these email messages in any such email we send.

Sensitive Personal Information. We will only use your personal information for the purposes for which it was collected.

Lawful bases for processing:

We will collect personal information from you only (i) where the personal information is necessary to perform an agreement with you (e.g., process payments, or create an account at your request), (ii) where the processing is in our legitimate interests and not overridden by your rights (as explained below), or (iii) where we have your consent to do so (e.g., sending you marketing communications where consent is required). In some cases, we will have a legal obligation to collect personal information from you such as where it is necessary to use your transaction history to complete our financial and tax obligations under the law.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). 

Certain countries and regions allow us to process personal information on the basis of legitimate interests. If we collect and use your personal information in reliance on our legitimate interests (or the legitimate interests of any third-party), this interest will typically be to operate or improve our platform and communicate with you as necessary to provide our services to you, for security verification purposes when you contact us, to respond to your queries, undertaking marketing, or for the purposes of potentially detecting or preventing illegal activities. 

We may use artificial intelligence, machine learning, and other automated decision-making to enhance your user experience and keep our site safe.

For example, we may use it in relation to:

• the sort order you see on our site,
• the content you upload on our site (e.g., images of your properties) to ensure they meet our quality or formatting requirements, and to identify relevant services included in your listing,
• the reviews you share with us to ensure they do not contain identifiable personal information or to assess customer satisfaction,
• the prevention and detection of breach of our terms and conditions or other fraudulent activities to keep our site safe,

Automated decisions may be made by putting your personal information into a system and the decision is calculated using automatic processes.

We will not engage in automated decision-making that involves a decision with legal or similarly significant effects solely based on automated processing of personal information, unless you: (1) explicitly consented to the processing, (2) the processing is necessary for entering into a contract, or (3) when otherwise authorized by applicable law.

You may have rights in relation to automated decision making, including the ability to request a manual decision-making process instead or contest a decision based solely on automated processing. If you want to know more about your data protection rights, please see the Your Rights and Choices section below.

Sharing of Personal Information

We share your personal information as described below and in this Privacy Policy, and as permitted by applicable law.

• Legal rights and obligations. We may disclose your personal information to enforce our policies, as necessary to satisfy our tax or regulatory reporting requirements, or where we are permitted (or believe in good faith that we are required) to do so by applicable law, such as in response to a request by a law enforcement or governmental authority, in connection with actual or proposed litigation, or to protect and defend our property, people and other rights or interests. We may also share your personal information pursuant to a subpoena or other legal request, or as necessary to remit certain taxes in the course of processing payments as required by law or legal process.
• Companies within our corporate family. To the extent that our corporate affiliates have access to your information, they will follow practices that are at least as restrictive as the practices described in this Privacy Policy.
• Corporate Transactions. We may share your personal information in connection with a corporate transaction, such as a divestiture, merger, consolidation or asset sale, or in the unlikely event of bankruptcy.

Other than as set forth above, you will be notified when personal information about you will be shared with third parties, and you will have an opportunity to choose not to have us share such information.

We also may share aggregate or anonymous information with third parties, including advertisers and investors. This information does not contain any personal information and is used to develop content and services we hope you will find of interest.

Your Rights and Choices

You have certain rights and choices with respect to your personal information, as described below:

• You can update the accuracy of your information at any time by contacting us
• If you no longer wish to receive marketing and promotional emails, you may unsubscribe by clicking the ‘unsubscribe’ link in the email. Please note that if you choose to unsubscribe from or opt out of marketing emails, we may still send you important transactional and account-related messages from which you will not be able to unsubscribe
• If we are processing your personal information on the basis of consent, you may withdraw that consent at any time by contacting us. Withdrawing your consent will not affect the lawfulness of any processing that occurred before you withdrew consent, and it will not affect our processing of your personal information that is conducted in reliance on a legal basis other than consent

Certain countries and regions provide their residents with additional rights relating to personal information. These additional rights vary by country and region, and may include the ability to:

• Request a copy of your personal information
• Request information about the purpose of the processing activities
• Delete your personal information
• Object to our use or disclosure of your personal information
• Restrict the processing of your personal information
• Opt out of the sale of your personal information
• Port your personal information
• Request information about the logic involved in our automated decision-making that is used in our fraud prevention practices, and the result of such decision

In addition to the above rights, you may have the right to complain to a data protection authority about our collection and use of your personal information. However, we encourage you to contact us first so that we can do our best to resolve your concern. You may submit your request to us using the information in the Contact us section. We respond to all requests that we receive from individuals wanting to exercise their personal data protection rights in accordance with applicable data protection laws.

Security

We want you to feel confident about using our platform and all associated tools and services, and we are committed to taking appropriate steps to protect the information that we collect. While no company can guarantee absolute security, we do take reasonable steps to implement appropriate physical, technical and organizational measures to protect the personal information that we collect and process.

Record Retention

We will retain your personal information in accordance with all applicable laws for as long as it may be relevant to fulfil the purposes set forth in this Privacy Policy unless a longer retention period is required or permitted by law. We will de-identify, aggregate, or otherwise anonymize your personal information if we intend to use it for analytical purposes or trend analysis over longer periods of time.

The criteria that we use to determine our retention periods include:

• Whether we have a legal obligation related to your personal information, such as laws requiring us to keep records of your transactions with us
• Whether there are any current and relevant legal obligations affecting how long we will keep your personal information, including contractual obligations, litigation holds, statutes of limitations and regulatory investigations

Updates to Privacy Policy

We may update this Privacy Policy in response to changing laws or technical or business developments. You can see when this Privacy Policy was last updated by checking the 'last updated' date displayed at the top of this policy. Provider is responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Us

If you have any questions or concerns about our use of your personal information, please contact our customer service team at info@keys2eternity.com