As of October 2022
The data controller responsible in accordance with the purposes of the UK General Data Protection Regulation (UK GDPR) and other data protection regulations is:
Pass The Keys Limited
85 Great Portland Street, First Floor
W1W 7LT
United Kingdom
+442038352038
reservations@passthekeys.co.uk
Home
The designated data protection officer is:
DataCo International UK Limited
c/o One Peak Partners, 41 Great Pulteney Street 2nd floor
London W1F 9NZ
United Kingdom
+49 89 7400 45840
1. Scope of processing personal data
In general, we only process the personal data of our users to the extent necessary in order to provide a functioning webshop with our content and services. The processing of personal data regularly only takes place with the consent of the user. Exceptions include cases where prior consent technically cannot be obtained and where the processing of the data is permitted by law.
2. Legal basis for data processing
Art. 6 (1) (1) (a) UK GDPR serves as the legal basis to obtain the consent of the data subject for the processing of their data.
As for the processing of personal data required for the performance of a contract of which the data subject is party, Art. 6 (1) (1) (b) UK GDPR serves as the legal basis. This also applies to processing operations required to carry out pre-contractual activities.
When it is necessary to process personal data in order to fulfil a legal obligation to which our company is subject, Art. 6 (1) (1) (c) UK GDPR serves as the legal basis.
If vital interests of the data subject or another natural person require the processing of personal data, Art. 6 (1) (1) (d) UK GDPR serves as the legal basis.
If the processing of data is necessary to safeguard the legitimate interests of our company or that of a third party, and the fundamental rights and freedoms of the data subject do not outweigh the interest of the former, Art. 6 (1) (1) (f) UK GDPR UK GDPR will serve as the legal basis for the processing of data.If the processing of data is necessary to safeguard the legitimate interests of our company or that of a third party, and the fundamental rights and freedoms of the data subject do not outweigh the interest of the former, Art. 6 (1) (1) (f) UK GDPR UK GDPR will serve as the legal basis for the processing of data.
3. Data removal and storage duration
The personal data of the data subject will be erased or restricted as soon as the purpose of its storage has been accomplished. Additional storage may occur if it was provided for by the European or national legislator within the EU regulations, law, or other relevant regulations to which the data controller is subject. Restriction or erasure of the data also takes place when the storage period stipulated by the aforementioned standards expires, unless there is a need to prolong the storage of the data for the purpose of concluding or fulfiling the respective contract.
When your personal data is processed, you are a data subject within the meaning of the UK GDPR and have the following rights:
1. Right to information
You may request the data controller to confirm whether your personal data is processed by them.
If such processing occurs, you can request the following information from the data controller:
2. Right to rectification
You have a right to rectification and/or modification of the data, if your processed personal data is incorrect or incomplete. The data controller must correct the data without delay
3. Right to the restriction of processing
You may request the restriction of the processing of your personal data under the following conditions:
4. Right to erasure
a) Obligation to erase
The right to deletion does not exist if the processing is necessary
6. Right to data portability
You have the right to receive your personal data given to the data controller in a structured and machine-readable format. In addition, you have the right to transfer this data to another person without hindrance by the data controller who was initially given the data, if:
7. Right to object
For reasons that arise from your particular situation, you have, at any time, the right to object to the processing of your personal data pursuant to Art. 6 (1) (1) (e) or 6 (1) (1) (f) UK GDPR; this also applies to profiling based on these provisions.
If the personal data relating to you are processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data in regard to such advertising; this also applies to profiling associated with direct marketing.
10. Right to complain to a supervisory authority
Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in the Member State of your residence, or your place of work or place of alleged infringement, if you believe that the processing of the personal data concerning you violates the UK GDPR. If you are located in the United Kingdrom, you shall have the right to complain to the ICO if you are unhappy with how we have used you data and/or believe that the processing of the personal data concerning you violates the applicable law. The ICO´s address: Information Commissioner´s OfficeWycliffe HouseWater LaneWilmslowCheshireSK9 5AFHelpline number: 0303 123 1113ICO website: https://www.ico.org.uk
The supervisory authority to which the complaint has been submitted shall inform the complainant of the status and results of the complaint, including the possibility of a judicial remedy pursuant to Art. 78 UK GDPR.
1. Description and scope of data processing
Each time our website is accessed, our system automatically collects data and relevant information from the computer system of the calling device.
The following data is collected:
This data is stored in the log files of our system. This data is not stored together with other personal data of the user.
2. Purpose of data processing
The temporary storage of the IP address by the system is necessary for the delivery of the website to the computer of the user. For this purpose, the user’s IP address must be kept for the duration of the session.
The storage in logfiles is done to ensure the functionality of the website. The data is also used to optimize the website and to ensure the security of our IT systems. An analysis of the data for marketing purposes does not take place.
For the aforementioned purposes, our legitimate interest lies in the processing of data in compliance with Art. 6 (1) (1) (f) UK GDPR UK GDPR.
3. Legal basis for data processing
The legal basis for the temporary storage of data and logfiles is Art. 6 (1) (1) (f) UK GDPR UK GDPR.
4. Duration of storage
The data will be deleted as soon as it is no longer necessary for the purpose of its collection. The session is complete when the collection of data for the provision of the website is accomplished.
If the data is stored in log files, this is the case after seven days at the latest. Storage beyond this is possible. In this case, the IP addresses of the users are deleted or alienated so that an assignment of the calling client is not possible.
5. Objection and removal
The collection of data for the provision of the website and the storage of the data in log files is mandatory for the operation of the website. The user can object to this. Whether the objection is successful is to be determined in the context of a balancing of interests.
1. Description and scope of data processing
Our website uses cookies. Cookies are text files that are stored in the internet browser or the internet browser on the user’s computer system. If a user calls up a website, a cookie can be stored on the user’s operating system. These cookies contain a string of characters that allows the browser to be uniquely identified when the website is reopened.
We use cookies to make our website more user-friendly. Some elements of our website require the calling browser to be identified even after a page break.
The following data is stored and transmitted in the cookies:
We also use cookies on our website, which enable us to analyse the browsing behaviour of our users.
As a result, the following data will be transmitted:
The user data collected in this manner is pseudonymised by technical measures. It is therefore not possible to assign the data to the user accessing the site. The data is not stored together with other personal data of the users.
2. Purpose of data processing
The purpose of using technical cookies is to simplify the use of websites for users. Some functions of our website cannot be offered without the use of cookies. These require that the browser is recognized even after a page change.
We need cookies for the following purposes:
The user data collected by technical cookies are not used to create user profiles.
The analysis cookies are used for the purpose of improving the quality of our website and its content. Through the analysis cookies, we learn how the website is used and thus can constantly optimize our offer.
Marketing, re-targeting, and website usage analytics.
3. Legal basis for data processing
The legal basis for the processing of personal data using non-technical cookies is Art. 6 (1) (1) (a) UK GDPR.
The legal basis for the processing of personal data using technical cookies is Art. 6 (1) (1) (f) UK GDPR UK GDPR.
4. Duration of storage and possibility of objection and removal
Cookies are stored on the user’s device and transmitted to our site by the user. Therefore, you as a user also have full control over the use of cookies. You can deactivate or restrict the transmission of cookies by changing the settings in your Internet browser. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it is possible that not all functions of the website can be used to their full extent.
If you use the Safari browser version 12.1 or higher, cookies will be automatically deleted after seven days. This also applies to opt-out cookies, which are used to prevent the use of tracking mechanisms.
1. Description and scope of data processing
We offer users the opportunity to register by providing personal data. The data is entered into an input mask and transmitted to us and stored. The data will not be passed on to third parties. The following data is collected as part of the registration process:
As part of the registration process, the user’s consent to the processing of this data is obtained.
2. Purpose of data processing
Registration of the user is required for the provision of certain content and services on our website.
Fulfilment of booking reservation
3. Legal basis for data processing
The legal basis for the processing of the data is Art. 6 (1) (1) (a) UK GDPR if the user has given his consent.
4. Duration of storage
The data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected.
This is the case for the data collected during the registration process if the registration is cancelled or modified on our website.
5. Objection and removal
As a user you have the possibility to cancel the registration at any time. You can request a change to the data stored about you at any time.
Email reservations@passthekeys.co.uk to request your data is deleted.
We offer a web shop on our website. For this we use the following web shop software:
Homey and in-house developed software.
The website and the web shop are hosted on external servers by a service provider commissioned by us.
Our service provider is:
Digital Ocean
The servers automatically collect and store information in so-called server log files, which your browser automatically transmits when you visit the website. The stored information is:
This data will not be merged with other data sources. The data is collected on the basis of Art. 6 (1) (1) (f) UK GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of his website – and server log files are therefore recorded.
We have concluded a data processing agreement with the relevant service provider in which we oblige the relevant service provider to protect user data and not to pass it on to third parties.
The server of the website is geographically located in the United Kingdom.
1. Description and scope of data processing
We offer our customers various payment options for processing their orders. Depending on the payment option, we transfer customers to the platform of the payment service provider in question. After completion of the payment process, we receive the customer’s payment data from the payment service providers or our house bank and process these in our systems for billing and accounting purposes.
Payment via credit card
It is possible to complete the payment process by credit card.
If you have chosen to pay by credit card, payment details will be passed on to payment service providers for payment processing. All payment service providers comply with the requirements of the “Payment Card Industry (PCI) Data Security Standards” and have been certified by an independent PCI Qualified Security Assessor.
The following data will be transmitted regularly as part of payment via credit card:
Payment data is passed on to the following payment service providers:
Further information on the data protection guidelines as well as robjection and removal options for payment service providers can be found here:
Stripe:
2. Purpose of data processing
The transmission of payment data to payment service providers serves to process payments, e.g. if you purchase a product and/or use a service.
3. Legal basis for data processing
The legal basis for data processing is Art. 6 (1) (1) (b) UK GDPR, since the processing of the data is necessary for the execution of the concluded sales contract.
4. Duration of storage
All payment data as well as data on possible chargebacks are only stored as long as they are required for payment processing and a possible processing of chargebacks and debt collection as well as for combating misuse.
Furthermore, payment data may be stored beyond this if and as long as this is necessary to comply with statutory retention periods or to prosecute a specific case of misuse.
Your personal data will be deleted at the end of the statutory retention period, i.e. after 10 years at the latest.
5. Objection and removal
You can withdraw your consent to the processing of your payment data at any time by notifying the data controller or the payment service provider used. However, the payment service provider used may still be entitled to process your payment data if and as long as this is necessary for the contractual payment processing.
1. Description and scope of data processing
If you order products or services on our website that are delivered by a shipping service provider, you will receive your order and shipping confirmation via your email address and, depending on the shipping service provider, notification that your shipment has arrived and/or notification of package arrival and possible delivery options.
The data will be transmitted to the following shipping service providers:
The data transmitted are regular:
2. Purpose of data processing
The purpose of processing personal data is to give Shipping service providers the opportunity to inform recipients of the progress of a shipment by email and thus increase the probability of successful delivery.
3. Legal basis for data processing
The legal basis for the transmission of the email address to the respective shipping service provider and its use is Art. 6 (1) (1) (f) UK GDPR, based on our legitimate interest in being able to offer the notification service to our customers and thus to make shipping as customer-friendly as possible.
4. Duration of storage
The transmitted data will be deleted by the respective shipping service provider if the package was delivered successfully.
5. Objection and removal
The notification service provided by the shipping service provider may be terminated by the user concerned at any time. For this purpose, there is a corresponding opt-out link in every email.
1. Description and scope of data processing
It is possible to subscribe to a newsletter free of charge. When you register for the newsletter, the following data from the input mask will be transmitted to us:
Your consent will be obtained for the processing of your data during the registration process and reference will be made to this privacy policy.
If you purchase goods or services on our website and enter your email address, we may subsequently use it to send you a newsletter. In such a case, only direct advertising for similar goods or services will be sent via the newsletter.
No data will be passed on to third parties in connection with data processing for the dispatch of newsletters. The data will be used exclusively for sending the newsletter.
2. Purpose of data processing
The user’s email address is collected to deliver the newsletter to the recipient.
3. Legal basis for data processing
The legal basis for the processing of data provided by the user after registration for the newsletter is Art. 6 (1) (1) (a) UK GDPR if the user has given his consent.
4. Duration of storage
The data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. The user’s email address will therefore be stored as long as the newsletter subscription is active.
The other personal data collected during the registration process is generally deleted after a period of seven days.
5. Objection and removal
The subscription for the newsletter can be cancelled by the data subject at any time. For this purpose, every newsletter contains an opt-out link.
Through this, it is also possible to withdraw the consent to the storage of personal data collected during the registration process.
1. Description and scope of data processing
You can contact us via the email address provided on our website. In this case the personal data of the user transmitted with the email will be stored.
The data will be used exclusively for the processing of the conversation.
2. Purpose of data processing
If you contact us via email, this also constitutes the necessary legitimate interest in the processing of the data.
3. Legal basis for data processing
The legal basis for the processing of data transmitted while sending an email is Art. 6 (1) (1) (f) UK GDPR. Our legitimate interest is to optimally answer your request that you send by e-mail. If the purpose of the email contact is to conclude a contract, the additional legal basis for the processing is Art. 6 (1) (1) (b) UK GDPR.
4. Duration of storage
The data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. For personal data sent by email, this is the case when the respective conversation with the user has ended. The conversation ends when it can be concluded from the circumstances that the matter in question has been conclusively resolved.
The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.
5. Objection and removal
The user has the possibility to withdraw the consent to the processing of their personal data at any time. If the user contacts us by email, he can object to the storage of his personal data at any time.
Email reservations@passthekeys.co.uk requesting that your details are deleted.
In this case, all personal data stored while establishing contact will be deleted.
Email reservations@passthekeys.co.uk requesting that your details are deleted.
Use of corporate profiles on social networks
Instagram:
Instagram, Part of Facebook Ireland Ltd., 4 Grand Canal Square Grand Canal Harbour, Dublin 2 Ireland
Our corporate presence in social networks is used for communication and information exchange with (potential) customers. We use the company’s profile for:
Marketing of products and services
Publications on the company profile can contain the following content:
Every user is free to publish personal data.
As far as we process your personal data in order to evaluate your online behavior, to offer you sweepstakes or to conduct lead campaigns, this is done on the basis of your express declaration of consent, Art. 6 (1) (1) (a), Art. 7 UK GDPR.The legal basis for processing personal data for the purpose of communicating with customers and interested parties is Art. 6 (1) (1) (f) UK GDPR. Thereby, our legitimate interest is to answer your request optimally or to be able to provide the requested information. If the aim of contacting you is to conclude a contract, the additional legal basis for the processing is Art. 6 (1) (1) (b) UK GDPR.
The data generated on the company profile are not stored in our own systems.
For the processing of your personal data in third countries, we have provided appropriate guarantees in form of standard data protection clauses pursuant to Art. 46 (2) (c) UK GDPR. We have concluded these standard data protection clauses with the above-mentioned providers. A copy of the standard data protection clauses can be requested from us.
Instagram: https://help.instagram.com/519522125107875
Twitter:
Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, Ireland
Our corporate presence in social networks is used for communication and information exchange with (potential) customers. We use the company’s profile for:
Marketing of products and services
Publications on the company profile can contain the following content:
Every user is free to publish personal data.
As far as we process your personal data in order to evaluate your online behavior, to offer you sweepstakes or to conduct lead campaigns, this is done on the basis of your express declaration of consent, Art. 6 (1) (1) (a), Art. 7 UK GDPR.The legal basis for processing personal data for the purpose of communicating with customers and interested parties is Art. 6 (1) (1) (f) UK GDPR. Thereby, our legitimate interest is to answer your request optimally or to be able to provide the requested information. If the aim of contacting you is to conclude a contract, the additional legal basis for the processing is Art. 6 (1) (1) (b) UK GDPR.
The data generated on the company profile are not stored in our own systems.
For the processing of your personal data in third countries, we have provided appropriate guarantees in form of standard data protection clauses pursuant to Art. 46 (2) (c) UK GDPR. We have concluded these standard data protection clauses with the above-mentioned providers. A copy of the standard data protection clauses can be requested from us.
Twitter: https://twitter.com/en/privacy
YouTube:
YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, United States
Our corporate presence in social networks is used for communication and information exchange with (potential) customers. We use the company’s profile for:
Marketing of products and services
Publications on the company profile can contain the following content:
Every user is free to publish personal data.
As far as we process your personal data in order to evaluate your online behavior, to offer you sweepstakes or to conduct lead campaigns, this is done on the basis of your express declaration of consent, Art. 6 (1) (1) (a), Art. 7 UK GDPR.The legal basis for processing personal data for the purpose of communicating with customers and interested parties is Art. 6 (1) (1) (f) UK GDPR. Thereby, our legitimate interest is to answer your request optimally or to be able to provide the requested information. If the aim of contacting you is to conclude a contract, the additional legal basis for the processing is Art. 6 (1) (1) (b) UK GDPR.
The data generated on the company profile are not stored in our own systems.
For the processing of your personal data in third countries, we have provided appropriate guarantees in form of standard data protection clauses pursuant to Art. 46 (2) (c) UK GDPR. We have concluded these standard data protection clauses with the above-mentioned providers. A copy of the standard data protection clauses can be requested from us.
YouTube: https://policies.google.com/privacy?gl=DE&hl=en
1. Scope of data processing
We use corporate profiles on professionally oriented networks. We maintain a corporate presence on the following professionally oriented networks:
LinkedIn:
LinkedIn, Unlimited Company Wilton Place, Dublin 2, Ireland
On our site we provide information and offer users the possibility of communication.
The corporate profile is used for job applications, information, public relations, and active sourcing.
We do not have any information on the processing of your personal data by the companies jointly responsible for the corporate profile. Further information can be found in the privacy policy of:
LinkedIn:
https://www.linkedin.com/legal/privacy-policy
If you carry out an action on our company profile (e.g. comments, contributions, likes etc.), you may make personal data (e.g. clear name or photo of your user profile) public.
2. Legal basis for data processing
The legal basis for the processing of personal data for the purpose of communication with customers and interested parties is Art. 6 (1) (1) (f) UK GDPR. Our legitimate interest is to answer your request optimally or to be able to provide the requested information. If the aim of contacting you is to conclude a contract, the additional legal basis for the processing is Art. 6 (1) (1) (b) UK GDPR.
3. Purpose of the data processing
Our corporate web profile serves to inform users about our services. Every user is free to publish personal data.
4. Duration of storage
We store your activities and personal data published via our corporate web profile until you withdraw your consent. In addition, we comply with the statutory retention periods.
5. Objection and removal
You can object at any time to the processing of your personal data which we collect within the scope of your use of our corporate web profile and assert your rights as a data subject mentioned under IV. of this privacy policy. Please send us an informal email to the email address stated in this privacy policy.
You can find further information on objection and removal options here:
LinkedIn:
https://www.linkedin.com/legal/privacy-policy
We use the IP address and other information provided by the user (e.g. the postal code used for registration or ordering) to approach regional target groups (so-called “geotargeting”).
The regional target group approach is used, for example, to automatically display regional offers or advertisements that often are more relevant to users. The legal basis for the use of the IP address and any other information provided by the user (e.g. postal code) is Art. 6 (1) (1) (f) UK GDPR, based on our legitimate interest in ensuring a more precise target group approach and thus providing offers and advertising with greater relevance for our users.
Part of the IP address and the additional information provided by the user (e.g. postal code) are merely processed and not stored separately.
You can prevent geotargeting by, for example, using a VPN or proxy server that prevents accurate localisation. In addition, depending on the browser you are using, you can also deactivate a location localisation in the corresponding browser settings (as far as this is supported by the respective browser).
We use geotargeting on our website for the following purposes:
CloudFlare
1. Description and scope of data processing
On our website we use functions of the content delivery network CloudFlare of CloudFlare Germany GmbH, Rosental 7, 80331 Munich, Germany (Hereinafter referred to as CloudFlare). A Content Delivery Network (CDN) is a network of regionally distributed servers connected via the Internet to deliver content, especially large media files such as videos. CloudFlare offers web optimization and security services that we use to improve the load times of our website and to protect it from misuse. When you visit our website you will be connected to the servers of CloudFlare, e.g. to retrieve content. This allows personal data to be stored and evaluated in server log files, the user’s activity (e.g. which pages have been visited) and device and browser information (e.g. IP address and operating system).
Further information on the collection and storage of data by CloudFlare can be found here:
https://www.cloudflare.com/de-de/privacypolicy/
2. Purpose of data processing
The use of CloudFlare’s features serves to deliver and accelerate online applications and content.
3. Legal basis for data processing
The data is collected on the basis of Art. 6 (1) (1) (f) UK GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of his website – and server log files are therefore recorded.
4. Duration of storage
Your personal information will be retained for as long as necessary to fulfil the purposes described in this Privacy Policy or as required by law.
5. Objection and removal
Information about objection and removal options regarding CloudFlare can be found at:
https://www.cloudflare.com/de-de/privacypolicy/
We use plugins for various purposes. The plugins used are listed below:
1. Description and scope of data processing
We integrate certain plugins on our website via external service providers in the form of content delivery networks. When you access our website, a connection is established to the servers of the providers used by us to retrieve content and store it in the cache of the user’s browser. This allows personal data to be stored and evaluated in server log files, in particular device and browser information (e.g. IP address and operating system). We use the following services:
2. Purpose of data processing
The use of the functions of these services serves the delivery and acceleration of online applications and content.
3. Legal basis for data processing
This data is collected on the basis of Art. 6 (1) (1) (f) UK GDPR. The website operator has a justified interest in the technically correct presentation and optimization of the website.
4. Duration of storage
Your personal information will be retained for as long as necessary to fulfil the purposes described in this Privacy Policy or as required by law.
5. Objection and removal
Information about objection and removal options regarding Cloudflare finds you under:
https://www.cloudflare.com/de-de/privacypolicy/
You can find information on objection and removal options regarding Google at: https://policies.google.com/privacy?hl=en-GB
This privacy policy has been created with the assistance of DataGuard.
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