This Policy also helps us in complying with our applicable global data privacy laws, including without limitation the EU General Data Protection Regulation (“EU GDPR”) if you are located in the EEA, and the UK General Data Protection Regulation (the “UK GDPR”) if you are located in the UK, as applicable (each and collectively the “GDPR”, as applicable).
Who we are
This website is operated by APNAKEY LTD, a company incorporated in England with the following registered number 13405148 and registered office at 71-75 Shelton Street, Covent Garden, London, England, WC2H 9JQ, and trading as ApnaKey. For more information on ApnaKey, see www.apnakey.com.
We collect, use, and are responsible for certain personal information about you. When we do so we are regulated under the GDPR which applies across the European Union and the United Kingdom and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
Throughout our Platform, we may link to other websites and/or mobile applications owned and operated by certain trusted third parties to make additional products and services available to you. These other third-party websites and/or mobile applications may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third-party websites and/or mobile applications, please consult their privacy policies as appropriate.
Our collection and use of your
We collect personal information about you directly when you connect to the Platform with your device (“Connect”, or “Connection”, as applicable); when you register on the Platform to create an account (“Register”); when we conduct regulatory checks on you in order to comply with our legal obligations, including without limitation to protect against anti-money laundering, fraud, credit risk and any other financial services related regulatory compliance (each and collectively “Regulatory Checks”); when you contact our customer services department with a request (“Customer Services Contact”) when you contact us and you are located in the EEA to make a request relating to your personal information pursuant to a right of yours under the GDPR or a similar regulation under another jurisdiction (“GDPR Contact”); if you make a booking (each and collectively “Bookings”); if you upload any content to the Platform (each and collectively “Uploads”); if you communicate with any other user of the Platform via the Platform (“Communications”, or “Social Media”, as applicable); if you supply an Activity to the Platform (“Activity Supply”); and when you change or add a display picture or video, or group chat picture or video for Social Media (“Video/Photo Change”).
Indirectly, we collect personal information from you when you use the Platform and a cookie is placed on your device by a third-party partner, such as Google Analytics (“Google Analytics Processing”); and when you make payments from our payment partner Stripe (see below) (“Payment Processing”).
The following details are the only personal information we collect about you:
Your email address, name details when you Register (each and collectively “Registration Details”, as applicable);
Your name, and any other information we obtain on you in support of Regulatory Checks (each and collectively “Regulatory Information”, as applicable);
Your email address and name, and any other information you provide in a GDPR Contact (each and collectively “GDPR Compliance Details”, as applicable);
Your email address and name, and any other information you provide in a Customer Services Contact (“Customer Services Details”);
Your transaction details in Payment Processing to support the making of payments for Activities (each and collectively “Payment Details”, as applicable);
Your name to support the making of any Bookings (“Bookings Information”);
Statistics in your usage behavior when you are using the Platform (each and collectively “Usage Stats”, as applicable);
Your IP address, country of location, geo-location, and TOR/VPN status when you Connect to the Platform (each and collectively “Connection-derived Information”);
Your name and email address when you make any Uploads (“Upload Details”);
Your name, email address, and message when you send any message via the Platform during any Communications (“Communication Details”);
Your name and email address in any Activity Supply (“Partner Information”);
Your unique ID in Google Analytics Processing (“Google Analytics Info”); and
Your camera and photo data during Social Media or any Video/Photo Change, as applicable (“Multimedia Data”).
We use this personal information to:
Registration Details + Payment Details + Bookings Information + Customer Services Details + Communication Details + Partner Information + Upload Details + Multimedia Data: to open your account and enable the supply of the services available on the Platform including without limitation customer administration (each and collectively as “Service Provision”, as applicable);
Regulatory Information + Connection-derived Information: to comply with the anti-money laundering, anti-terrorist financing, and any other regulations and laws that apply to the operation of the Platform (“Regulatory Compliance”);
GDPR Compliance Details: to enable you to make requests or queries to us in accordance with your rights under the GDPR (“GDPR Request Compliance”);
Usage Stats + Connection-derived Information: for our marketing and promotional activities (“Marketing”);
Usage Stats + Google Analytics Info + Connection-derived Information: to further develop and improve the Platform and Services (“Product Improvement”); and
Connection-derived Information: to enable and improve from time to time the safety and security of the Platform in compliance with our requirements under the GDPR (“GDPR Security Compliance”).
This Platform is not intended for use by children and we do not knowingly collect or use personal information relating to children.
Our legal basis for processing your
When we use your personal information we are required to have a legal basis for doing so. There are various different legal bases on which we may rely, depending on what personal information we process and why.
The legal bases we may rely on include:
“Consent” where you have given us clear consent for us to process your personal information for a specific purpose, as is the case with Marketing; Product Improvement; and Competitions and Surveys.
“Contract” where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract, as is the case for Service Provision; and
“Legal Obligation” where our use of your personal information is necessary for us to comply with the law (not including contractual obligations), such as with GDPR Security Compliance, GDPR Request Compliance, and Regulatory Compliance.
So, to summarise:
When you Register, we collect your Registration Details to enable our Service Provision on the legal basis of the Contract; With each Customer Services Contact, we collect your Customer Services Details to enable our Service Provision on the legal basis of the Contract; During Payment Processing, we collect your Payment Details to enable our Service Provision to you on the basis of the Contract; During Bookings, we collect your Bookings Information to enable our Service Provision to you on the basis of Contract; During Uploads, we collect your Upload Details to enable our Service Provision to you on the basis of Contract; During Communications, we collect your Communication Details to enable our Service Provision to you on the basis of the Contract; During Activity Supply, we collect your Partner Information to enable our Service Provision to you on the basis of Contract; During Regulatory Checks, we collect your Regulatory Information to enable our Regulatory Compliance on the basis of our Legal Obligation; With each GDPR Contact, we collect your GDPR Compliance Details to enable our GDPR Compliance on the basis of our Legal Obligation; When you use the Platform, we collect your Usage Stats and Google Analytics Info to enable our Marketing; and Product Improvement, on the legal basis of your Consent; With every Connection, we collect your Connection-derived Information to enable our Marketing and Product Improvement, on the legal basis of your Consent; and to enable our Regulatory Compliance and GDPR Security Compliance on the basis of our Legal Obligation; and During any Video/Photo Change or Social Media (as applicable), we collect your Multimedia Data to enable the Social Media function which is part of the Services, but for which we nonetheless will use the legal basis of your Consent.
Whom we share your personal information with
We routinely share certain personal information with third parties for certain purposes as detailed below:
All personal information referenced herein to any Partner that offers any Activities via our Platform;
Payment Details + Bookings Information to Stripe, to enable Payments;
Some of those third-party recipients may be based outside the United Kingdom and European Economic Area — for further information including on how we safeguard your personal data when this occurs, see ‘Transfer of your information out of the UK and EEA’ below.
We will share personal information with law enforcement or other authorities if required by applicable law.
We will not share your personal information with any other third party.
Whether information has to be provided by you, and if so why
We require you to provide the following personal information:
Registration details; Customer Services Details; Payment Details; Bookings Information; Upload Details; Communication Details; some Google Analytics Info; and Partner Information to enable our Service Provision;
Regulatory Information; some Connection-derived Information and Google Analytics Info for Regulatory Compliance; and
GDPR Compliance Details for GDPR Compliance.
We will inform you at the point of collecting information from you, whether you are required to provide the information to us.
The impact of our use of your personal information
The impact of our use of your personal information is that such use will enable the purposes referenced herein, and it will require us to secure your personal information to limit data breach risks that are inherent in our use of your personal information.
Transfer of your information out of the UK and EEA
We will not transfer your personal data outside of the area comprising the UK and EEA or to any organization (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.
Cookies and other tracking technologies
We would like to send you information about products and services, competitions and special offers, which may be of interest to you. Where we have your consent, we may do this by post, email, telephone, text message (SMS) or automated call.
We will only ask whether you would like us and other businesses to send you marketing messages when you tick the relevant boxes when during Registration.
If you have previously agreed to be contacted in this way, you can unsubscribe at any time by following the instructions within the communication.
For more information on your rights in relation to marketing, see ‘Your rights below.
Under the GDPR you have a number of important rights free of charge. In summary, those include rights to:
Fair processing of information and transparency over how we use your use personal information;
Access to your personal information and to certain other supplementary information that this Policy is already designed to address;
Require us to correct any mistakes in your information that we hold;
Require the erasure of personal information concerning you in certain situations;
Receive the personal information concerning you that you have provided to us, in a structured, commonly used, and machine-readable format and have the right to transmit those data to a third party in certain situations;
Object at any time to processing of personal information concerning you for direct marketing;
Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you;
Object in certain other situations to our continued processing of your personal information;
Otherwise, restrict our processing of your personal information in certain circumstances; and
Claim compensation for damages caused by our breach of any data protection laws.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individual's rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
Email us at firstname.lastname@example.org, or write to us at 71-75 Shelton Street, Covent Garden, London, England, WC2H 9JQ;
Let us have enough information to identify you (eg account number, user name, registration details);
Let us have proof of your identity and address (a copy of your driving license or passport and a recent utility or credit card bill); and
Let us know the information to which your request relates including any account or reference numbers if you have them.
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, used, or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from getting Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses, and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to complain
We hope that we can resolve any query or concern you raise about our use of your information.
The GDPR also gives you the right to lodge a complaint with a supervisory authority, in particular in a European Economic Area state or in the United Kingdom if you work, normally live, or if any alleged infringement of data protection laws occurred in the relevant state. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or by telephone: 0303 123 1113.
How to contact us
Please contact us at email@example.com, if you have any questions about this privacy notice or the information we hold about you.