(Last Updated on 8th March, 2019)
Ukey Smart SA de CV, (“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”).
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.
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).
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 firstname.lastname@example.org.
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.
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:
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
THIRD PARTY WEBSITES
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.
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 email@example.com.
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.
What are 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.
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.
GRIEVANCE/DATA PROTECTION OFFICER
For the purpose lodging any complaint regarding the Personal Data, you may contact following grievance/data protection officer:
Lilian Cohen (firstname.lastname@example.org)
representative for eu residents
EU residents may contact the following EU representative for their queries or grievances:
Alfredo Finkelberg (email@example.com)