Data protection notice

Data Protection Notice Notice Keenfinity ID

Highlights

Keenfinity GmbH has set out below some important highlights of the Data Protection Notice for our Single Sign-On Service Keenfinity ID© and our Keenfinity ID© Website at https://account.keenfinity.tech/. You can also obtain more information about how we collect, use, disclose and safeguard your personal data by reviewing our full Data Protection Notice below.

Keenfinity ID© enables access to various services of the Keenfinity Group affiliates independent of your registration to the Keenfinity ID ©, such as apps, web shops, online platforms or websites as well as access to products, data, contributions, image and audio documents, information and other contents. You can obtain more information about the Service we provide by reading our terms of use (Link).

 

What personal data do we collect?

For more information, please refer to the sections “Collection of personal data” and “Sources of personal data” below.

We collect various types of personal data about those who visit our Website or who register for or use the Service, for purposes related to the services or products provided through the Website and Service, including:

-         Personal data we collect directly from you (i.e., when given by you) when you visit our Website, register for or use the Service, including your first and last name, the country where you live or from where you access the Website or Service, your language preference, your email address, your username, your account and password, and any other information you submit to us; and

-         Personal data we collect indirectly from you (i.e., collected when you visit the Website or register for or use the Service), including your Internet Protocol (“IP”) address, operating system, browser and other log files.

We also may collect information in ways that we describe to you at the point of collection or otherwise with your consent. The section titled “Collection of Personal Data” contains more information on these categories.

Why do we collect personal information and how is it used?

For more information see Collection of Personal Data below.

Processing Purposes:

-         Fulfilling or meeting the reason you provided the information, such as processing and verifying your registration and enabling your use of the Service or responding to your inquiries.

-         Technical administration of the Website and Service and investigation of Website and Service disruptions.

-         Maintaining the safety, security, and integrity of our mobile applications, websites, online platforms, products and services, databases and other technology assets and business.

-         Administering, maintaining, and improving the Website and Service, including, without limitation, to authenticate users, provide requested services and optional additional services, to understand how our users interact with the Website and Service and to improve and develop new features, products and/or services.

-         Evaluating or conducting a merger, sale of assets, consolidation or restructuring, financing or acquisition of all or a portion of any Keenfinity Group business, asset or opportunity by, with or into another business, entity or company when necessary.

-         Compliance with legal and/or regulatory requirements.

-         Responding to submitted inquiries and customer service requests and other questions and/or comments.

Keenfinity GmbH will not collect or use personal data for materially different, unrelated or incompatible purposes without providing you notice (or obtaining your consent, where required by applicable laws in the relevant jurisdiction). Additionally, Keenfinity GmbH only retains personal data for as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.

Is personal information shared or disclosed?

For more information see Disclosure, Sale, and Sharing of Personal Data, Personal Data Sales: Opt-Out and Opt-In Rights, and Use of Cookies below.

Keenfinity GmbH may share your information with:

-         Keenfinity Group affiliated entities that use the Service and that you are in a contractual relationship with.

-         Service providers and other partners and entities performing work on Keenfinity GmbH’s behalf, including those we have commissioned for programming, data hosting and as well as to operators of our IT system, administrators and customer support.

-         Other third parties where required or permitted by applicable law, including (without limitation) relevant governmental authorities in accordance with, and as Keenfinity GmbH deems required, necessary and/or appropriate by, or in connection with, applicable law, regulation, court order or legal process.

Keenfinity GmbH does not sell or share personal data, therefore we do not have an opt-out.

What are the risks?

-         We may transfer your personal data to countries other than the country where you reside, including to Keenfinity Group affiliates that integrate the Keenfinity ID© in their services, such as apps, web shops, online platforms or websites, and that you are in contractual relationship with, as well as to service providers of Keenfinity GmbH. Therefore, your personal data may be accessible to courts, law enforcement and national authorities in other countries. You can ask questions about the collection, use, disclosure or storage of personal data by such service providers, by contacting our Data Protection Officer as described in the Data Protection Notice below.

-         Keenfinity GmbH security measures related to the Website and Service are regularly reviewed and updated as necessary in accordance with the state of technological developments. However, absolute protection is not possible. We cannot guarantee the security of personal data posted or transmitted using the Keenfinity ID©.

What else should you know?

-         Your personal data will be stored in data centers in Germany and the Netherlands and accessible to Keenfinity Group affiliates responsible for the services you are accessing with Keenfinity ID©.

-         You may contact our Data Protection Officer, as described in the Data Protection Notice, with any questions about the collection of your personal data.

-         In some circumstances outside the European Union, you also may have a right to access, update, and correct inaccuracies in your personal data (e.g., pursuant to local law).

-         Any additional choices you may have are described in the full Data Protection Notice below.

Notice to Canadian Users: Please note that by visiting the Website, registering for and/or using the Service and/or otherwise voluntarily providing your personal data to us, as applicable, you are consenting to the collection, use and disclosure of your personal data as described in our Privacy Policy and summarized above.

 

Keenfinity ID© DATA PROTECTION NOTICE

I. Introduction

Keenfinity GmbH is pleased to have you use our Single Sign-On Service Keenfinity ID© and welcomes your interest in the Keenfinity ID© Single Sign-On Service.

This Data Protection Notice applies to all users of https://account.keenfinity.tech and those who register for or use the Service anywhere in the United States, Canada, and their respective territories and possessions.

The protection of your privacy is an important concern to which we pay special attention. If you access services of Keenfinity GmbH or Keenfinity Group affiliates with Keenfinity ID©, we process personal data collected during your visit to the Website, registration for or usage of the Service in compliance with this Data Protection Notice and all applicable laws and regulations. Data protection and information security are part of the Keenfinity GmbH corporate policy.

Notice to Canadian Users: Please note that by visiting the Keenfinity ID©, registering for and/or using the Service and/or otherwise voluntarily providing your personal data to us, as applicable, you are consenting to the collection, use and disclosure of personal data as described in this Data Protection Notice. If you do not consent to the processing of your personal data in accordance with this Data Protection Notice, please do not register for, access or continue to use the Website or Service or otherwise provide any personal data to us.

 

II. Scope

This Data Protection Notice covers our treatment of personal data, as defined by the European Union’s General Data Protection Regulation (GDPR), personally identifiable information, as defined by numerous statutes in the United States, personal information as defined by Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) and any applicable substantially similar national legislation, which we gather when you are accessing, viewing, completing, or using our Website or the Service, which we gather while you are accessing, viewing, completing, or using our Website or the Service.

III. Responsibility and Contact Details

We, Keenfinity GmbH, are responsible for processing your personal data on this website as a controller in accordance with Art. 24 (1) GDPR when we provide our Service to you while visiting apps, web shops, online platforms or websites as well as accessing products, data, contributions, image and audio documents, information and other contents of Keenfinity GmbH.

We, Keenfinity GmbH, are processing your personal data on this website as processors in accordance with Art. 28 GDPR on behalf of Keenfinity Group affiliates when we provide our Service to you while visiting apps, web shops, online platforms or websites as well as accessing products, data, contributions, image and audio documents, information and other contents of Keenfinity Group affiliates.

If you wish to contact us, please find us at the address stated below:

To assert your rights and to notify data protection incidents please use the following link: https://request.privacy-bosch.com/

For suggestions and complaints regarding the processing of your personal data we recommend that you contact our Data Protection Officer:

Data Protection Officer

Keenfinity GmbH

Fritz-Schäffer-Straße 9

81737 München

Deutschland

or

mail to: dataprotection.keenfinity@bosch.com

IV. Collection of Personal Data

The Keenfinity ID© collects the following personal data from users of the Keenfinity ID©.

1. Categories and Sources of Personal Data: Communication and profile data

We collect this personal data from our users, customers, and business partners. We also generate identifiers internally.

-         Examples:First name, last name, email address, username, password, user ID, roles and group membership for application access

-         Processing Purpose(s) and legal base(s): Processing and verification of your registration and enablement of the use of the service. Legal base: Fulfilment of contractual obligation in accordance with Art. 6 (1)(b) GDPR

-         Do we disclose, share or sell this data? We disclose this personal data with our service providers and with business partners, including those whom you instruct us to send this personal data.

-         Retention: We retain personal data for the length of time needed to fulfil the purposes outlined in this Data Protection Notice, unless a longer retention period is required or permitted by law. We retain personal data of inactive users for 10 years.

2. Categories and Sources of Personal Data: Internet or other similar network activity

We collect this personal data from our users, customers, and business partners. We also generate identifiers internally.

-         Examples: Log files, including

o        IP address of the terminal device that is used to access the Service (including approximate geolocation of logged-in users);

o        Mappings to external identity providers (e.g. Social Logins) and linked accounts from external providers;

o        Internet address of the website from which the Service was accessed (otherwise known as the URL of origin or referrer URL);

o        Name of the service provider that is used to access the Online Offer;

o        Name of the files or information accessed;

o        Applications accessed by the user;

o        Authentication details (e.g. date, method, use of single- or multi-factor authentication, status and result details);

o        User sessions and login history (e.g. authentication attempts and failures);

o        Date and time as well as duration of retrieval;

o        Amount of data transferred;

o        User agent information (e.g. operating system and internet browser used including add-ons installed (e.g., Flash Player));

o        http status code (e.g., “Request successful” or “File requested not found”) or request status (e.g. “Success” or “Failed”)).

-         Processing Purpose(s) and legal base(s): We save log files only for a short time and solely to determine disruptions or for security reasons (e.g., to investigate attempted attacks) and to otherwise maintain the safety, security and integrity of our Website and Service, databases and other technology assets and business. After these purposes have been completed, the log files will generally be deleted. Log files that need to be maintained for evidence purposes are excluded from deletion until the respective incident has been completely resolved or, on a case-by-case basis, has been passed on to investigating authorities. Legal base(s): Fulfilment of contractual obligation in accordance with Art. 6 (1)(b) GDPR, fulfilment of our legal obligations within the scope of data security Art. 6 (1)(c) GDPR, respectively our legitimate interest in resolving service disruptions as well as in the protection of our offers or to improve our Website and Service in accordance with Art. 6 (1)(f) GDPR.

-         Do we disclose, share or sell this data? We may share this data with our IT service providers or any provider commissioned by us and to investigating authorities on a case-by-case basis and where allowed by law. We do not sell this data.

-         Retention: We retain internet or other similar network activity for 30 days.

Keenfinity GmbH will continue to collect the personal data described above. If any additional personal data is collected by Keenfinity GmbH, we will provide any required notice(s), and where applicable obtain any required consent(s), in accordance with applicable laws in the relevant jurisdiction.

V. Sources of Personal Data

We collect personal data from the following categories of sources:

1. Directly from you - For example, when given by you or collected from you through your access to and/or use of our Website or the Service for registration and login with Keenfinity ID, for an overview and administration of master data and applications with Keenfinity ID or for contacting customer support or otherwise interact or communicate with Keenfinity GmbH, its agents, representatives, suppliers, vendors or consultants through our Website or the Service. This may include, without limitation, your first and last name, the country where you live or from where you access the Website or the Service, your language preference, email address, phone number, identifier and password, and any other information you choose to provide us.

Users are solely responsible for providing notices to, and obtaining valid consent from, any other individual whose personal data is submitted to Keenfinity GmbH in connection with the Service.

2. Indirectly from you - For example, from observing your use of our Website or the Service and/or the Services, or services related thereto. The following data may be collected automatically: the website from which you visit Keenfinity ID (referrer), duration of visit, browser used, device data (e.g., unique device identifier, IP address, serial number, hardware model, network information and operating system and version), and other relevant details and/or information.

Keenfinity GmbH will not collect additional categories of personal data or use the personal data we collected for materially different, unrelated or incompatible purposes without providing you notice or obtaining your consent, where required by applicable laws in the relevant jurisdiction.

VI. Disclosure, Sale and Sharing of Personal Data

Keenfinity GmbH may use, store, compile, manipulate, share and disclose your personal data with third parties for the purposes stated above. Your personal data is disclosed with the following:

-         Keenfinity Group affiliates to offer and improve our Services;

-         Keenfinity GmbH service providers, vendors, consultants, suppliers, licensors, and other partners and entities performing work on Keenfinity GmbH’s behalf, such as hosting vendors and delivery companies;

-         Relevant authorities in accordance with, and as Keenfinity GmbH deems required, necessary and/or appropriate by, or in connection with, applicable law, regulation, court order or legal process.

 

VII. International Data Transfer outside the European Economic Area (EEA), Data Transfer to other controllers, Data Transfer to service providers

Keenfinity GmbH may transfer your personal data to Keenfinity Group affiliates offering services that you access with Keenfinity ID© to recipients located outside the EEA into so-called third countries when processing, storing, and otherwise using personal data.

In such cases, prior to the transfer we ensure that either the data recipient provides an appropriate level of data protection (e.g. due to a decision of adequacy by the European Commission for the respective country or due to the agreement based on so-called EU model clauses with the recipient) or that you have consented to the transfer.

In general, your personal data will only be transferred to other controllers if this is necessary for the fulfillment of a contract, if we or the third party have a legitimate interest in the transfer, or if you have given your consent. For details on the legal basis and the recipients or categories of recipients, please refer to the respective processing purposes and legal bases above.

Additionally, personal data may be transferred to other controllers if we are obliged to do so by law or by enforceable official or court order. Keenfinity GmbH may also transfer your personal data to a service, provider, contractor, or third party outside the country of origin. Accordingly, your personal data may be accessible to courts, law enforcement and national authorities in countries other than the country in which you reside. You can obtain information about Keenfinity GmbH’s policies and practices with respect to foreign service providers (including affiliates), or ask questions about the collection, use, disclosure or storage of personal data by such service providers, by contacting our Data Protection Officer as described below.

VIII. Children’s Privacy

 

Please note that this website is not intended for children.

 

IX. California “Shine the Light” Privacy Rights

California’s “Shine The Light” law permits those Keenfinity GmbH customers who are residents of California to annually request a list of their personal data (if any) that Keenfinity GmbH disclosed to third parties for direct marketing purposes in the preceding calendar year, and the names and addresses of those third parties. At this time, Keenfinity GmbH currently does not share any personal data with third parties for direct marketing purposes.

X. Use of Links to Affiliated Sites

The Service and Website may provide links to other Keenfinity Group sites (“Affiliated Sites”). The Service provides these links only as a convenience. Your use of these Affiliated Sites and any related services are outside the scope of this Data Protection Notice and is governed by the Data Protection Notice and any other terms referred to or located on such Affiliated Sites.

XI. Security

Keenfinity GmbH takes commercially reasonable efforts to ensure that your personal data collected by Keenfinity GmbH through the Service and Website is protected against tampering, loss, destruction, access by unauthorized persons or unauthorized disclosure. Keenfinity security measures are being continuously improved in accordance with the state of technological developments, however, absolute protection is not possible.

To register for Keenfinity ID, you are required to provide your email address or phone number and create a password. You must not share this access information with anyone else as you are personally responsible for any information transmitted while logged in with your username and password. We disclaim any and all liability for any information transmitted due to an unauthorized log in.

XII. Use of Cookies

I. Keenfinity GmbH Cookies.

Keenfinity GmbH uses only technical or strictly necessary cookies to ensure technically functionality of the service and website. Keenfinity GmbH does not use and third-party cookies or other tracking mechanisms.

Cookies are small text files stored on your computer or device when you visit the Service and Website.

If you wish, you can delete the cookies at any time from your web browser. However, this can result in some functions no longer being available. For information on deleting the cookies, consult your browser‘s help function.

XIII. How We Respond to Do Not Track Signals

The “Do Not Track” (“DNT”) privacy preference is an option that may be made in some web browsers allowing you to opt-out of tracking by websites and online services. Keenfinity GmbH does not track users, therefore does not recognize and/or respond to DNT signals.

XIV. International Users

This is a German Website and Service that is targeted to users in the U.S. and Canada, and complies with relevant U.S. and Canadian laws, as applicable, including, without limitation, those governing the privacy and security of your information. If you visit, register for or use the Website and/or the Service, you are transferring your personal data to Keenfinity GmbH in Germany. When visiting, registering for or using the Website and/or the Service or providing your information to Keenfinity GmbH through the Website and/or the Service, the transfer of your personal data to Germany, and Keenfinity GmbH’s handling of your information will be carried out in accordance with applicable German and U.S. requirements and this Data Protection Notice. Accordingly, your personal data may be accessible to courts, law enforcement and national investigation authorities in the United States as well as in Germany. You can obtain information about Keenfinity GmbH’s policies and practices with respect to service providers (including affiliates) outside the country where you reside, or ask questions about the collection, use, disclosure or storage of personal data by such service providers, by contacting our Data Protection Officer as described below.

XV. Your Rights – EU

Please use the information in the Contact section above to assert your rights. When doing so, please ensure that we can clearly identify you.

You have the right to request access to the personal data concerning you, as well as the right to rectification, the right to erasure, the right to restriction of processing and the right to data portability:

Right to information and access (Art. 15 GDPR):

 

You have the right to obtain confirmation from us about whether your personal data is being processed, and, if this is the case, access to your personal data.

 

Right to rectification (Art. 16 GDPR) and erasure (“right to be forgotten”) (Art.17 GDPR): 

 

You have the right to obtain the rectification of inaccurate personal data concerning yourself without undue delay from us. Considering the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

This does not apply to data which is necessary for billing or accounting purposes, or which is subject to a statutory retention period. If access to such data is not required, however, its processing is restricted (see the following).

Right to restriction of processing (Art. 18 GDPR):

You have the right to demand for – as far as statutory requirements are fulfilled – restriction of the processing of your data.

Right to data portability (Art. 20 GDPR):

Insofar as Keenfinity GmbH is responsible for the processing of your data as a controller you have the right to right to have your personal data transmitted directly from Keenfinity GmbH to another controller, where technically feasible.

Right to object (Art. 21 GDPR):

You have the right to object to data processing by us at any time. We will no longer process the personal data unless we demonstrate compliance with legal requirements to provide provable reasons for the further processing which are beyond your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

Objection to data processing based on the legal basis of “legitimate interest” (Art. 6 (1)(f) GDPR):

In addition, you have the right to object to the processing of your personal data at any time, insofar as this is based on a legitimate interest. We will then terminate the processing of your data, unless we demonstrate compelling legitimate grounds according to legal requirements which override your rights.

To enforce your rights, please use the details provided in the Contact section above. In doing so, please ensure that an unambiguous identification of your person is possible.

Withdrawal of consent (Art. 7 (3) GDPR):

Insofar as you have given us consent to process your personal data, you may revoke this consent at any time with future effect. The legality of data processing prior to your revocation remains unchanged. 

Objection to direct marketing

You can object to the processing of your personal data for advertising purposes ("advertising objection") at any time. Please note that, for organizational reasons, there may be an overlap between your objection and the use of your data in the context of an already ongoing campaign.

Right to lodge complaint with supervisory authority (Art. 57 (1)(f) GDPR)

You have the right to lodge a complaint with the following competent supervisory authority: 

Bayerisches Landesamt für Datenschutzaufsicht (BayLDA)

Address:

Promenade 18

91522 Ansbach

Germany

Contact Details:

Telefon: +49 (0) 981 180093-0

Telefax: +49 (0) 981 180093-800

E-Mail: poststelle@lda.bayern.de

Webpage: https://www.lda.bayern.de 

 

XVI. Your Rights - US

State specific privacy laws within the United States provide data subjects certain rights regarding the personal data that businesses collect and how the collected personal data is used. If you would like to exercise data subject right available to you, find the “Exercise your Rights” section below. Our data protection team will examine your request and respond to you as quickly as possible.

We may still use any aggregated and de-identified Personal data that does not identify any individual and may also retain and use your Personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our Agreements. We maintain and use all de-identified personal data in de-identified form. We do not attempt to reidentify it except to ensure our de-identification processes are in compliance with applicable law.

Dependent on the state of your residence, you may be provided the following rights:

 

California:

-         Right to know what personal information is being collected

-         Right to access your personal information.

-         Right to correct inaccurate personal information.

-         Right to delete personal information

-         Right to know what personal information is sold or shared and to whom.

-         Right to opt-out of sale or sharing of personal information for cross-context behavioral advertising

-         Right to data portability

-         Right to opt-out of processing for the purpose of profiling

-         Right to limit the use and disclosure of sensitive personal data

-         Right of no retaliation following opt-out or exercise of other rights

Virginia:

-         Right to confirm if personal data is processed

-         Right to access your personal information

-         Right to correction inaccuracies in your personal data

-         Right to delete your personal data

-         Right to obtain a copy of your personal data

-         Right to opt-out for the purpose of targeted advertising, sale of data, or profiling

-         Right to non-discrimination

-         Right to appeal

Colorado:

-         Right to confirm if personal data is processed

-         Right to access your personal information

-         Right to correction

-         Right to deletion

-         Right to opt-out of sale, targeted advertising, and profiling

-         Right to data portability

-         Right to non-discrimination

-         Right to appeal

Connecticut:

-         Right to confirm if personal data is processed

-         Right to access your personal information

-         Right to correction

-         Right to deletion

-         Right to data portability

-         Right to opt-out of sale, targeted advertising, and profiling

-         Right to Non-Discrimination

-         Right to appeal

Utah:

-         Right to confirm if personal data is processed

-         Right to access your personal information

-         Right to deletion

-         Right to data portability

-         Right to opt-out of sale and targeted advertising

-         Right to non-discrimination

Nevada:

-         Right to request that a company not sell your personal information for monetary consideration

XVII. Your Rights – Canada

Individuals located in Canada have certain rights pursuant to Canadian Privacy Laws. Subject to certain exceptions and limitations, and depending upon the jurisdiction where you reside, such rights may include:

a. The right to withdraw your consent to the collection, use or disclosure of your personal information.

b. The right to be informed of the existence, use, and disclosure of your personal information, and to be provided with an account of the use that has been made or is being made of this information as well as the third parties to which it has been disclosed (including a list of organizations to which your information may have disclosed).

c. The right to challenge the accuracy and completeness of your personal information, and have it amended, updated or rectified as appropriate.

d. The right to acquire information about Keenfinity’s policies and practices with respect to personal information, including: a description of the type of personal information held by Keenfinity and a general account of its use; a copy of any brochures or other information that explain our policies, standards, or codes; and information about what personal information is shared with or accessible to our affiliates.

e. The right to challenge Keenfinity’s compliance with the applicable Canadian Privacy Laws.

XVIII. How to Exercise Your Rights

To exercise your rights, submit a verifiable consumer request or access request, as applicable, to us by either:

-         Calling us at 089 6290-0

-         Sending an email to: dataprotection.keenfinity@bosch.com

To assist Keenfinity in processing your request when exercising your rights, supply the following information:

-         Full name

-         Phone number

-         Email address

-         Any information you can provide about your previous contact with Keenfinity GmbH (e.g. contact point / touchpoint with Keenfinity, screenshots, reference to a specific product/newsletter)

Only you (or based on your state of residence, an authorized agent authorized by you to act on your behalf – see Section Authorized Agent below for more information) may make a verifiable consumer request or access request, as applicable related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. Your verifiable consumer request or access request, as applicable, must:

-         Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.

-         Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal data if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request or access request does not require you to create an account with us, but if you already have an account with us, you may be required to make your request through that account.

We will only use personal data provided in a verifiable consumer request or access request, as applicable, to verify the requestor’s identity or authority to make the request.

XIX. Response Timing and Format

We endeavor to respond to a verifiable consumer request or access request, as applicable, within thirty (30) days of its receipt, or sooner where required by applicable law (including Canadian Privacy Laws). If we require more time (up 90 days in total), where permitted by applicable law, we will inform you of the reason and extension period in writing. Opt-out request will be honored as soon as feasibly possible, but no later than 15 days from the date we receive the request.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide in response to a verifiable consumer request will only cover the 12-month period preceding the verifiable consumer request's receipt, unless otherwise required by applicable law. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

For data portability requests, where applicable, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request or access request, as applicable, unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

XX. Personal Information Sales: Opt-Out and Opt-In Rights

Keenfninity ID© does not sell your personal information to third parties as defined by relevant laws. Therefore, we do not offer an opt-out.

XXI. Authorized Agent

I. California

As a California resident you may also exercise your request to know or request to delete through an authorized agent. When you submit your request through an authorized agent, we require that you:

1. Provide us a copy of your written permission for the authorized agent to submit the applicable request; and

2. Verify your own identity directly with us.

The foregoing does not apply when you have provided your authorized agent with a power of attorney pursuant to California Probate Code sections 4000 to 4465; provided, that we may require a copy of such power of attorney before fulfilling any request.

II. Colorado

As a Colorado resident you may also exercise your request to opt-out through an authorized agent. When you submit your request through an authorized agent, we require that you:

1. Provide us a copy of your written permission for the authorized agent to submit the applicable request; and

2. Verify your own identity directly with us.

XXII. Non-Discrimination

We will not discriminate against you for exercising any of your rights. Unless permitted by applicable law, we will not: (a) deny you goods or services; (b) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (c) provide you a different level or quality of goods or services; or (d) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

XXIII. Filing a Complaint

Regulatory authorities that oversee the privacy laws and regulations, including the Office of the Privacy Commissioner of Canada, advise individuals to file an objection or challenge with the relevant company before lodging a formal complaint with a regulatory authority. If you are dissatisfied with Keenfinity’s response to an objection or challenge filed under Article XX above, or you if wish to file a complaint with a regulatory authority first, you may do so as follows:

Under PIPEDA: You may file a complaint with the Office of the Privacy Commissioner of Canada. Depending upon the province where you live, you may also (or instead) have the right to file a complaint with the applicable provincial privacy commissioner/regulator.

Under PII Laws: You may file a complaint with the relevant state’s Attorney General’s office.

Under the US: You may file a complaint with the applicable state Attorneys General Office or regulatory agency.

 

XXIV. Changes to Data Protection Notice

Due to the constantly changing nature of Keenfinity GmbH business, Keenfinity GmbH reserves the right to change, update, revise and/or modify this Data Protection Notice at any time at Keenfinity GmbH’s sole discretion, and Keenfinity GmbH will post any new or revised Data Protection Notice here. Any such change, update, revision and/or modification will be effective immediately upon posting on this website, unless we are required to provide direct notice or obtain your consent pursuant to applicable laws. Use of information that Keenfinity GmbH gathers now will be subject to the Data Protection Notice in effect at the time of use. By using or navigating around the Website or Service or utilizing any of the services, you acknowledge that you have read and understood and agree to be bound by this Data Protection Notice in and the applicable Terms of Use. If you do not agree to be so bound, do not remain on the Website or Service. You are responsible for checking the Website and Service frequently to keep apprised of recent changes.

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The effective date of this Data Protection Notice is May 12, 2025.