Privacy Notice

In this Privacy Notice, we, imkeys.com, explain how we handle your personal data when you visit IMKEYS website (www.imkeys.com) and use our services. All personal data are processed in accordance with the General Data Protection Regulation (EU) 2016/679 ("GDPR") and applicable local EU Member State and/or other national data protection law.

Our platform incorporates privacy controls which provide you with controls on deciding how we will process your personal data. By using privacy controls, you can specify whether you would like to receive direct marketing communications.

In this notice you will find the answers to the following questions:

how we use your data;
when we provide your data to others;
how long we store your data;
what is our marketing policy;
what rights related to personal data you possess;
how we use cookies;
other issues that you should take into account.
In case of any inquiries or if you would like to exercise any of your rights provided in this notice, you may submit such inquiries and requests by means provided in Contacts section.

You may contact us regarding all privacy-related issues by email: [email protected].

General data protection principles and confidentiality

imkeys.com shall process all personal data adhering to the general data processing principles:

Lawfully, fairly and in a transparent manner in relation to the data subject (lawfulness, fairness, and transparency);

Collect and process personal data only for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes (purpose limitation);

Ensure that personal data is adequate, relevant and limited to what is necessary for relation to the purposes for which they are processed (data minimization);

Ensure that personal data is accurate and, where necessary, kept up to date (accuracy);

Ensure that personal data is kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed (storage limitation);

Process personal data in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures (integrity and confidentiality).

All and any information processed by imkeys.com is treated as strictly confidential. All information is stored securely and is accessed by qualified and authorized personnel only.

So, what personal data do we collect and why?

We process data about your use of our Platform and services ("usage data"). The usage data may include your IP address, geographical location, browser type, and version, operating system, referral source, length of visit, page views, and platform navigation paths, as well as information about the timing, frequency, and pattern of your service use. We obtain such data through the use of cookies and similar technologies. We process such data to have a better understanding of how you use our Platform and services. The legal basis for this processing is our legitimate interest, namely monitoring and improving our Platform and accommodating the services for the individual interests of every user.

We process your account data ("account data"). The account data may include your name and email address, phone number, and other data that you provide while registering as well as your purchase history. We obtain such data directly from you. We process account data for the purposes of operating our Platform, providing our services, ensuring the security of our Platform and services, and communicating with you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract as well as our legitimate interest, namely monitoring and improving our Platform and services.

We process information relating to the provision of services by us to you on our Platform ("transaction data"). The transaction data may include your contact details, bank account details, and transaction details. The transaction data is processed to assist in you supplying or purchasing goods and provide services and keep proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our Platform and business.

We process information related to anti-money laundering prevention measures ("AML data"). AML data may additionally include address or residence, ID documentation, including your photo, documents regarding your source of wealth, utility bill, and others. In some cases, we are required by the law to request such information to carry out "know your client" obligations.

We have a dedicated fraud detection process in place to detect and prevent any fraudulent transactions ("fraud detection data"). To ensure timely risk and fraud detection, effective prevention of fraudulent transactions and to improve our fraud detection process we collect and process various account data, transaction data and usage data which allows us to determine whether user's actions demonstrate suspicious behavior (e. g. whether the user is a bot, has attempted to defraud us in the past and similar indications related to fraudulent behavior). Our internal system may generate additional information such as unique identifiers in addition to collected transaction, account, usage or other data.

We may process information that you provide to us for the purpose of subscribing to our email messages and newsletters  ("messaging data"). The messaging data is processed to send you the relevant messages and newsletters. The legal basis for this processing is your consent. Also, if we have already sold goods or provided services for you on our Platform and you do not object, we may also process messaging data on the basis of our legitimate interest, namely seeking to maintain and improve customer relations

In addition to the specific purposes for which we may process your personal data set out in this Section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

How long we store your data?
account data will be retained for no longer than 5 (five) years following your last update on the account;
transaction data will be retained for no longer than 10 (ten) years following the end of provision of services
AML data  will be retained as long as it is necessary to comply with the related legal requirements;
fraud detection data will be retained as long as account data, or longer if the User Account has been deemed as likely to commit fraud;
messaging data  will be retained for as long as your Account is active unless you withdraw your consent earlier;
correspondence data  will be retained for no longer than 6 (six) months following the end of such communication.
In some cases, it is not possible for us to specify in advance the periods for which your personal data will be retained. 

If you consider that our processing of your personal information infringes data protection laws, you have a legal  right to lodge a complaint with a supervisory authority responsible for data protection. Or you can contact us via Contacts. or via [email protected].

About cookies
We use the cookies on our Platform, to customize the functioning of our Platform as much as possible, and can contribute to ease of use when navigating our Platform.

What is a cookie?
A cookie is a small text file placed onto your device that enables our Platform features and functionalities. For example, cookies enable us to identify your device, secure your access to the Platform. They enable the Platform to store the data, such as:
Login data (IP address of the logging-in device, login time, location from which the login is attempted);
Type of browser;
Demographic data (age group, gender);
Data about the fact how you browse the Platform (which sections you visit, what products are you interested in).

Cookies that we use
We use cookies of four main types, for the following purposes:

Necessary Cookies – these cookies are necessary for a website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work;

Analytical Cookies – these cookies allow us to count visits and traffic sources, so we can measure and improve the performance of our site. They help us know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies, we will not know when you have visited our site;

Preference cookies – these cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred region.

Marketing cookies – these cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

Children personal data
Our Platform and services are targeted at persons over the age of 16 or another age under respective country's law which allow you to assume responsibility for obligations emerging from contractual relations and have a full capacity to take legal actions. 

If we have reason to believe that we hold personal data of a person under that age in our databases without having consent from the parent rights holder, we will delete that personal data.

Updating your data
Please let us know if the personal information that we hold about you needs to be corrected or updated.

Changes to the notice
Any changes to this notice will be published on the Platform and, in case of material changes, we may inform you about such via email