Privacy Policy

(Last Updated on 8th March, 2019)

 

INTRODUCTION

 

Ukey Smart Solutions Private Limited, (“Ukey”, “Company”, we”, “us” and “our”), is committed to protect the Personal Data (as defined herein below) of its users. Ukey provides software services through its (i) ‘Ukey Smart’ mobile application that enables hotel/service apartment guests to check-in, unlock the room, control room devices, view upgrade offers and request hotel/service apartment services (“Ukey Smart App”); and (ii) ‘Ukey Smart web panel that lets hotels/service apartments keep track of the guests’ requirements in an organized manner (“Ukey Web Panel”); and (iii) ‘www.ukeysmart.com’ the website of Ukey that enables the users to use the different services (“Website”) (Collectively referred to as “Services”).

 

This policy (“Privacy Policy”) discloses our information practices to handle and secure the Personal Data of (i) users and visitors of the Website; (ii) prospective and current customers; (iii) hotel/service apartment guests who use the Ukey Smart App; (iv) hotels/service apartments who use the Ukey Web Panel; (v) any person who may contact us directly, regardless of whether they have any contractual relationship with us or with our customers, including email, text and other electronic communications (Collectively referred to as “you”, “your”).

 

For the purpose of this Privacy Policy, wherever the context so requires (i) “Applicable Laws” shall mean all laws, ordinances, statutes, rules, order, decree, injunction, license, permits, registration, approval, authorization, consent, waiver, privileges, agreement, bye-laws, guidelines and regulation of any governmental authority having jurisdiction over the relevant matter as such are in effect as of the date hereof or as may be amended, modified, revoked, or enacted from time to time hereafter; (ii)“Personal Data” shall mean any information relating to you, which allows us to identify you and includes the following categories of data, viz. name, nationality, profession, email address, telephone, proof of identity and location. We are committed to minimising the Personal Data we use in our communication with you. We do not consider Personal Data to include any information that has been made anonymous or aggregated so that it can no longer be used to identify a specific person, whether in combination with other information or otherwise.

 

By using our Services, you expressly provide consent to Ukey for collection, use, disclosure, retention, and protection of your Personal Data and other information as described in this Privacy Policy. If you do not provide the information Ukey requires, Ukey may not be able to provide all of its Services to you.

 

This Privacy Policy shall not apply to any unsolicited information you provide to the Company, including but not limited to customer feedback, suggestions for new products or modification to existing products and other unsolicited submissions. All unsolicited information shall be deemed to be non-confidential and the Company shall be free to reproduce, use, disclose and distribute the same to others without limitation or liability.

 

DATA WE COLLECT

 

Ukey may collect and store any data that you may provide while using our Services. Apart from this, when you use our Services, our systems collect details about your computer system, including but not limited to your IP address & cookies. Please note that your IP address does not identify you personally. We may receive information about you from third parties, such as other users, partners (including ad partners, analytics providers, search information providers), affiliated hotels/service apartments, or our affiliated companies or if you use any of the Services we provide.

 

We will only collect Personal Data about you if you are willing to provide it. The Personal Data you provide should be accurate. Please make sure you update your Personal Data, if any of your details change and immediately delete all inaccurate information provided by you without any delay.

 

We do not need process any sensitive data pertaining to your health, cultural identity, political orientation, etc.

 

We may also collect the data available in public domain or received from any third party including social media channels, including but not limited to personal or non-personal information from your linked social media channels (like name, email address, friend list, profile pictures or any other information that is permitted to be received as per your account settings) as a part of your account information. If you sign in to the Ukey Smart App through third-party sign-in services such as Facebook, Google Plus or Gmail or any other social networking or similar site (collectively, “SNS”), an option of which may be provided to you by Ukey at its sole discretion, you will be allowing us to pass through and receive from the SNS your log-in information and other user data.

 

Ukey Smart App may also access metadata and other information associated with other files stored on your mobile device. This may include, for example, photographs, audio and video clips, personal contacts, notifications, location, camera and address book information. If you permit the Ukey Smart App to access the address book on your device, we may collect names and contact information from your address book to facilitate social interactions through our Services and for other purposes described in this Privacy Policy or at the time of consent or collection. If you permit the Ukey Smart App to access the calendar on your device, we collect calendar information such as event title and description, your response (Yes, No, Maybe), date and time, location and number of attendees. We may also track your location for providing better services through Ukey Smart App.

 

The details may be required may include your name, email address, residence address, telephone number, user/ customer account information, history, real time information, approximate location, transaction details while using the Services, hotels/service apartment, preferences, time zones, reviews, comment lists and searches.

 

CONSENT FOR PERSONAL DATA

 

Before submission of the Personal Data, you would be asked to give your consent to use your Personal Data by Ukey.

 

The consent given to use the Personal Data can be withdrawn by you at any time. All actions taken by Ukey before withdrawal of the consent by you will not be affected or invalidate due to withdrawal of the consent. Further, upon withdrawal of the consent you will not be able to use our Services (either fully or partially).

 

PERMISSIBLE AGE

 

The Services are not intended for users under the age of 16 (Sixteen) or any other age as may be prescribed under the Applicable Laws (“Permissible Age”). We do not knowingly collect Personal Data from users or market to or solicit information from anyone below the Permissible Age. If we become aware that a person submitting Personal Information is below the Permissible Age, we will delete the account and any related information as soon as possible. If you believe we might have any information from or about a user under the Permissible Age, please contact us at info@ukeysmart.com.

 

PURPOSE OF COLLECTION

 

Your Personal Data will help us manage our communication with you. In particular, we may use your Personal Data for the following purposes:

 

  • To respond to queries you send to us;

  • For providing the Services and information in relation to our Services;

  • To notify you of important changes to the Services;

  • Use your Personal Data for sending you our marketing materials and/or informing you of our new products and services or other promotions (“Marketing Purposes”). Where required by the Applicable Laws, for e.g., if you are an EU data subject, we will send you information relating to Marketing Purposes, only with your consent given at the time you provided us with your Personal Data;

  • Participate in interactive services offered by Ukey;

  • Allow the hotel/service apartment partner to contact you, if necessary;

  • Customize the content of our Website, Ukey Smart App and Ukey Web Panel;

  • Request for reviews of products or services or any other improvements;

  • To protect your vital interest or of another natural person, for carrying out the public interest or in the exercise of official authority vested in Ukey;

  • Marketing promotions, research and programs help us to identify your preferences, develop programs and improve user experience;

  • Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;

  • To provide you details regarding offers/ promotions of hotels/service apartments;

  • For any other purpose with your consent.

 

Please note that we may profile and/or compile and/or aggregate your Personal Data for our marketing analysis purpose. We may also process your Personal Data, if so, required by the Applicable Laws.

 

By disclosing any Personal Data to us, you explicitly accept and agree that we may process it, including profiling it, in the course of our legitimate business and in accordance with this Privacy Policy.

 

DISCLOSURE TO THIRD PARTIES

 

The purpose of collecting your Personal Data as set out hereinabove normally does not require disclosure or transfer to third parties. We shall therefore not disclose or transfer your Personal Data to third parties, with the following exceptions as set forth below:

 

  • We may disclose your Personal Data to our affiliates or business partners, who have developed adequate Privacy Policy.

  • We hire third parties, who have developed adequate privacy policy, to perform certain business-related functions including hosting and maintaining databases (“Service Providers”), pursuant to which the Service Providers will access, process or store your Personal Data. We provide the Service Providers with the relevant information only which they require for performing their specific function.

  • The Company facilitates interaction between you and the hotels/service apartments at which you have been or may be a guest. If you enter information in Ukey Smart App, such information will be disclosed to the concerned hotel/service apartments for which such information was provided. Our responsibility as a “data processor” of information on behalf of the hotel/service apartments is governed by our contract with the concerned hotel/service apartments and its privacy policies. We are not responsible for the privacy policies or practices of the hotels/service apartments. We advise you to contact the hotel/service apartments for information on their privacy policies and practices.

  • We may disclose your Personal Data to regulatory bodies or other competent authorities if so required by the Applicable Laws, or in good faith that such action is necessary to comply with a legal obligation or to protect and defend the rights or property of the Company or to protect the personal safety of the public.

  • In the event of a corporate sale, merger, reorganization, dissolution or similar event, your Personal Data may be part of the transferred assets.

  • With our subsidiaries, affiliates, group entities consultants, marketing partners, research firms and other service providers.

  • If you interact with social media features on our Services or use your social media credentials to log-in or post content, these features may collect information about your use of the Services, as well as post information about your activities on the social media service. Your interactions with social media companies are governed by their respective privacy policies.

  • To enforce or apply our terms and conditions and other agreements.

  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Ukey, our customers or others.

  • In any other circumstances, where we have your consent.

 

RETENTION OF YOUR PERSONAL DATA

 

Except where needed to respond to a query from you or fulfil an order, we will keep your Personal Data, after deletion of your account, for a maximum of 7 years or for the time period prescribed under the Applicable Laws for retention of Personal Data whichever is higher. Further, subject to the permissibility under the Applicable Laws, we may delete your Personal Data before the aforesaid period on request by you.

 

DO NOT TRACK SIGNALS

 

The Company does not currently respond to “Do Not Track” signals sent by your browser or mobile application. In case of any change, we will update this Privacy Policy accordingly.

 

THIRD PARTY WEBSITES

 

Our Website or Ukey Smart App may contain links to other websites which are not operated or controlled by us, including links to hotel/service apartments websites. Ukey shall not be responsible for and has no control over the practices and content of any website accessed using the links contained on the Website or Ukey Smart App. This Privacy Policy does not apply to the third party websites or services or to any hotels/service apartments collection, storage, and use of your Personal Data. We advise you to contact such third party for information on their privacy practices and policies.

 

SECURITY

 

The Company shall implement and maintain security measures to protect Personal Data via the website and/or the Ukey Smart App and/or the Ukey Web Panel, against unauthorised disclosure or access, accidental or unlawful destruction, loss or alteration. The Company will continuously be monitoring the performance and adequacy of the security measures and may modify and update the security measures from time to time.

 

DATA INCIDENT

 

In case, we become aware of any data incident, we shall promptly notify you and shall without any delay take reasonable steps to minimise harm and secure your Personal Data. Our notification of or response to a data incident shall not be construed as an acknowledgment of any fault or liability with respect to the data incident.

 

EU DATA SUBJECTS

 

This section shall be applicable solely if you are an EU data subject. For the purposes of this section, reference to EU also includes the European Economic Area countries of Iceland, Liechtenstein, Norway and Switzerland, where applicable, EU residents have the following rights:

 

  • To know the purpose to process the Personal Data.

  • To know the status of Personal Data processed.

  • Access the Personal Data that is processed.

  • To get erased or rectified the Personal Data.

  • Restrict the processing of the Personal Data.

  • Data portability of the Personal Data provided on the Website/ Ukey Smart App.

  • To have opt-out option from processing the Personal Data (unless Ukey otherwise has compelling legitimate grounds).

  • To withdraw consent for Personal Data.

  • To make complaint with the data protection authority.

  • To get free from decisions based solely on automated processing of your Personal Data.

 

The abovementioned rights can be exercised by EU residents by contacting at info@ukeysmart.com.

 

We will notify you of any changes to the data processing activities described in this Privacy Policy by email or by prominent notice on our website.

 

OPT-OUT

 

When you sign up for an account on Ukey Smart App, you are opting in to receive emails from Ukey. You can log in to manage your email preferences or you can follow the “unsubscribe” instructions in commercial email messages, but note that you cannot opt out of receiving certain administrative notices, service notices, or legal notices from Ukey. You may opt out of receiving notifications regarding promotion and offer of the hotels/service apartments through the Ukey Smart App and/ or Website.

 

COOKIES POLICY

 

What are cookies?

 

Cookies are small pieces of information saved by your browser onto your computer. Cookies are used to record various aspects of your visit and assist Ukey to provide you with uninterrupted service. Ukey does not use cookies to save Personal Data for outside users. By using this Website you agree to Ukey use of cookies as described in this Privacy Policy.

 

How do we use cookies?

 

When you make registration on Ukey Smart App or Ukey Web Panel and enter your name and details, you will become a recognized user, and we will send a cookie to your computer. A cookie is a small file that may be placed on your computer's hard disk for record-keeping purposes. Cookies do not contain any information that can personally identify you. They help us to recognize you when you visit the website and make use of the service so that the service can be tailored to your needs.

 

By using cookies, we can make your online experience more efficient. For example, they allow you to store your chosen items in your shopping basket, without losing them between visits, and to make the checkout process faster.

 

We will also use cookies for the compilation of certain statistics (which do not identify you personally) relating to the use of the Ukey Smart App, Ukey Web Panel or Website. Such information may include the number of visits, average time spent, and other statistics relating to the Ukey Smart App, Ukey Web or Website. For enhancing the Services, we may use cookies, third party scripts to track the manner of use and to understand or analyse situations, circumstances wherein the user is facing problem.

 

You may see Ukey adverts on other websites. For these adverts, we will be using software that may send a cookie to your browser. This software will allow us to monitor, if you see our adverts, if you click on them and if you go on to buy from our website.

 

How to disable cookies?

 

It may be possible to disable some (but not all) cookies through your device or browser settings, but doing so may interfere with certain functionality on the Services. Users can usually set their browsers to block all third-party cookies (which are those set by third-party companies collecting information on websites operated by other companies), block all cookies (including first-party cookies such as the ones Ukey uses to collect search activity information about its users), or block specific cookies. To modify your cookie settings, please visit your browser's help settings. You will need to opt out on each browser and each device you use to access the Services. Flash cookies operate differently than browser cookies and cannot be removed or blocked via web browser settings. Please note that removing or blocking cookies can impact user experience and parts of this Website may no longer be fully accessible.

 

AMENDMENTS

 

We will occasionally update this Privacy Policy. We may notify you the significant changes to this Privacy Policy by email or by prominent notice on our Website and Ukey Smart App. To the extent permitted under the Applicable Law, your continued use of our Services after we publish or send a notice about our changes to this Privacy Policy shall constitute your consent to the updated Privacy Policy.

 

GRIEVANCE/DATA PROTECTION OFFICER

 

For the purpose lodging any complaint regarding the Personal Data, you may contact following grievance/data protection officer:

 

Vinod Jhajharia (info@ukeysmart.com)

 

representative for eu residents

 

EU residents may contact the following EU representative for their queries or grievances:

 

Alfredo Finkelberg (info@ukeysmart.com)