Last Modified: December 3, 2021

This privacy notice (“Privacy Notice”) governs how we, Key Academy Ltd (“Key Academy” “we”, “our” or “us”) use, collect and store information pertaining to you (“User”, “you”), amongst other, in the following use cases: (i) When you browse, visit, sign up/login and make use of our website www.keyevents.bg (“Website”); (ii) When you sign up as an “influencer” or “creator”; (iii) When you provide us with your Personal Data via/through any of the forms made available by us or when you correspond with us (e.g. through our chat); (iv) When you request a demo, show interest in our Startup plan or download our free reports; (vi) When an organization with which you are associated (an “Organization”) signs up to use our platform (“Platform”) in which case we may receive Personal Data about you in connection with our provision of the Platform to your Organization (however, note that this Privacy Notice does not apply where your Organization is the data controller or we have a data processing agreement in place with your Organization which governs our obligations as data processor); (vii) when you apply for a job with us; and/or (viii) When we use the personal data of the employees of our vendors, service providers and suppliers.

We greatly respect your privacy. Please read this Privacy Notice carefully, so you can fully understand our practices in relation to Personal Data. Please note that this is a master privacy notice and some of its provisions only apply to individuals in certain jurisdictions. For example, the legal bases described below are only relevant for GDPR-protected individuals in limited contexts. “Personal Data” or “Personal Information” means any information that can be used, alone or together with other data, to uniquely identify any living human being.

This Privacy Notice can be updated from time to time and, therefore, we ask you to check back periodically for the latest version. If we implement significant changes to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.

Our contact details Name: Key Academy, Ltd
E-mail: info@keyacademy.bg

Table of contents:

1. What Information we Collect
2. How we Protect and Store your Personal Data
3. How we share your Personal Data
4. Additional Information Regarding Transfers of Personal Data
5. Your Rights
6. Use by Children
7. How to Contact Us

WHAT INFORMATION WE COLLECT

1.1 When you browse or visit our website www.keyevents.bg (“Website”):

• We collect navigational information including information about your computer and your visits to our Website such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed, information about your computer hardware and software, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times and referring website addresses and log files. Our Website also uses cookies, analytic tools and tracking technologies.
• We use the above information to provide and improve our Website and its features, and analytics.

• Without this information, we cannot provide our Website efficiently.

1.2 When you provide us with your Personal Data via/through any of the forms made available by us or when you correspond with us (e.g. through our chat) and/or when you request a demo or show interest in our Startup plan or download our free reports:

• We collect information that you chose to provide or share with us, including contact information, such as your name, e-mail address, company name, address, country or phone number.
• We use it to provide you with the requested service, document or feature in question (e.g. to answer and process your queries, to provide a demo, to provide our free reports) and for internal operations (such as bug fixing, analytics, R&D, or generation of statistics).
• Legal basis: legitimate interest and, in certain contexts, consent or pre-contractual discussions (i.e. steps at your request prior to entering into a contract).

• Without this information, we cannot process your queries, provide a demo or share our free reports with you.

1.3 When you sign up as an “influencer” or “creator”:

• We collect information that you chose to provide or share with us, including contact information, such as your name, e-mail address, password, credentials, performance information, social accounts and activity. In some contexts, we collect data from third party sources about influencers. You can read more in our Privacy Notice for Influencers available at www.keyevents.bg (“legal” section).
• We use this information to communicate with you, provide our platform to you, manage your account, operate and improve our Website and Platform, provide support, send you requested materials, internal operations (such as bug fixing, analytics, R&D, statistics), security and fraud detection purposes.
• Legal basis: depending on the context, legitimate interest (e.g. fraud detection), consent (e.g. to receive certain messages or communications), pre-contractual discussions (i.e. steps at your request prior to entering into a contract) or performance of a contract (e.g. our terms of use ).
• Note that some of your Personal Data may also be viewed by other users of the Platform.

• Without this information, we cannot communicate with you, provide our Platform and its features, or improve our service offering.

1.4 When an organization with which you are associated (an “Organization”) signs up to use our platform (“Platform”):

• We collect signup/login data, CRM data, user name, passwords. We also collect notes that Organization users write on the Platform about Influencers.
• Note that this Privacy Notice does not apply where your Organization is the data controller or we have a data processing agreement in place with your Organization, which governs our obligations as data processor.
• We use this information to communicate with you, provide our Platform and our services to you, manage your account, operate and improve our Platform, provide support, send you requested materials, internal operations (such as bug fixing, analytics, R&D, statistics), security and fraud detection purposes.
• Legal basis: depending on the context, legitimate interest (e.g. fraud detection), or performance of a contract (e.g. our terms of use). Note that in some cases a data processing agreement with the Organization governs and applies to the use of this data. Without this information, we cannot communicate with you, provide our platform and its features or improve our service offering.

1.5 When you apply for a job:

• We collect your CV, resume, contact details and cover letter
• We use it to assess your candidacy and suitability and correspond with you
• Legal basis: legitimate interest and pre-contractual discussions (i.e. steps at your request prior to entering into a contract)

• Without this information, we cannot process your CV and consider your request.

1.6 We also collect contact details of the employees and staff of our suppliers, service providers and vendors. This information is used to communicate with them and perform the relevant agreements. The legal basis is either legitimate interest or performance of a contract (e.g. the relevant agreement with the supplier, service provider or vendor). Without this information, we cannot communicate with them.

Finally, please note that some of the abovementioned Personal Data will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your Personal Data and further use it for internal and external purposes, including, without limitation, to improve the services and for research purposes. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services, or de-identified information. To the maximum extent permitted by law, we may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).

HOW WE PROTECT AND STORE YOUR PERSONAL DATA

2.1 Security.
We have implemented appropriate technical, organizational and security measures designed to protect your Personal Data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

2.2 Retention of your Personal Data.
We store and retain data for as long as we need it (amongst other, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements). In some circumstances we retain your Personal Data as follows: (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.

HOW WE SHARE YOUR PERSONAL DATA

The abovementioned Personal Data is stored on third party hosting providers. We share your information as follows:

• With our business partners with whom we jointly offer products or services (e.g. Key Academy Partners) and brands that work with us.
• With trusted partners to contact you based on your request to receive such communications, help us perform statistical analysis, or provide customer support. We partner with trusted third parties to provide you with co-marketing content that we think may be relevant to you.
• With service providers that we employ (e.g. other companies and people to provide services to visitors to our Websites, our customers, us and users of the Platform) and who may need some of your information to provide information, products or services to you or us (e.g. IT, system administration, and other services). Examples may include removing repetitive information from prospect lists, analyzing data or performing statistical analysis, providing marketing assistance, processing credit card payments, supplementing the information you provide us in order to provide you with better service, and providing customer service or support.
• With our affiliated companies, companies/entities of the Key Academy group and our consultants/sales teams.
• With professional consultants and advisors, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• Third parties with whom we may be required to communicate in order to enforce or apply the terms of our agreements; or to protect the rights, property, or safety of Key Academy, our customers, our users or others.
• To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order.
• If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we may disclose your Personal Data to such third party (whether actual or potential) in connection with the foregoing events. In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your Personal Data in connection with the foregoing events, including, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company.

• Where you have provided your consent to us sharing or transferring your Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).

Contact us for more information.

ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA

Transfers to, and access from, Israel are covered by the European Commission’s Adequacy Decision regarding Israel. You can read more here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en. Where we transfer your Personal Data outside of Key Academy, for example to third parties who help provide our products and services, we will obtain contractual commitments from them to protect your Personal Data. Feel free to contact us if you need further information on specific transfer mechanisms used by us when transferring your Personal Data out of the EEA.

YOUR RIGHTS

The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):

• You have a right to access Personal Data held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law.
• You have the right to request that we rectify any Personal Data we hold that is inaccurate or misleading.
• You have the right to request the erasure/deletion of your Personal Data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your Personal Data, for example for the establishment, exercise or defense of legal claims.
• You have the right to object, to or to request restriction, of the processing.
• You have the right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller.
• You have the right to object to profiling.
• You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
• You also have a right to request certain details of the basis on which your Personal Data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality.

• You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.

You can exercise your rights by contacting us at info@keystars.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Data requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law. In addition, should you ever decide to delete your account, you may do so by emailing us.

Separately, we may enable or allow you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service. For example, our website may contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that, to the maximum extent permitted by law, we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Personal Data to these websites.

USE BY CHILDREN

We do not offer our products or services for use by children. If you are under 18, you may not use the Website, the Platform or provide us with your Personal Data. We do not knowingly collect information from, and/or about children.

CONTACT US

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at info@keystars.com.