1. Identity of K-Locks
Phone: 00353 (0) 45-834288
Mobile: 00353 (0)87-943 5102
Our customers may submit inquiries regarding personal data protection, privacy and security matters to CEO Kieran Kellegher, firstname.lastname@example.org
2. What information do we collect?
You may visit our site anonymously.
K-Locks does not collect data, other than your email details for return correspondence.
K-Locks does not send mailings.
K-Locks does not pass on or sell your details to third parties.
3. What do we use your information for?
Any of the information we collect from you may be used for one or more of the following purposes:
3.1. To personalize your experience (the information will help K-Locks better respond to your individual needs).
3.2. To identify you as a contracting party.
3.3. The e-mail address you provide, may be used to send you information and updates pertaining to your enquiry.
4. Legal basis
4.1. EU General Data Protection Regulation (GDPR)
The processing of your data is either based on your consent or in case the processing is necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract, cf. GDPR art. 6(1)(a)-(b).
If the processing is based on your consent, you may at any time withdraw your consent by contacting us using the contact information in clause 1.
In order to enter into a contract regarding a purchase from K-Locks, you must provide us with the required personal data. If you do not provide us with all the required information, it will not be possible to deliver the Service.
4.2. Children’s Online Privacy Protection Act Compliance
K-Locks is in compliance with the requirements of the Children’s Online Privacy Protection Act. We will not intentionally collect any information from anyone under 18 years of age. Our website, products and services are all directed at people who are at least 18 years old or older.
5. How do we protect your information?
K-Locks implements the following technical, physical and organizational measures to maintain the safety of your personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized use, unauthorized modification, disclosure or access and against all other unlawful forms of processing.
The Service utilizes the extensive features of the cloud environment to ensure high availability, like continuous data backup. All failover mechanisms are fully automated.
No personal data is stored permanently outside K-Locks cloud platforms. The physical security is thereby maintained by K-Locks subcontractors, see clause 7. Microsoft’s data centres comply with industry standards such as ISO 27001 for physical security and availability, e.g. by using security staff around the clock, two-factor access control using biometric and card readers, barriers, fencing, security cameras and other measures.
To ensure integrity, all data transits are encrypted to align with best practices for protecting confidentiality and data integrity. E.g. all supplied credit card information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our payment gateway provider’s database only to be accessible by those who are authorized to access such systems and who are required to keep the information confidential.
For data in transit, the Service uses industry-standard transport protocols between devices and Microsoft data centres and within data centres themselves.
All personnel are subject to full confidentiality and any subcontractors and sub-processors are required to sign a confidentiality agreement if not full confidentiality is part of the main agreement between the parties.
Whenever personal data is accessed by authorized personnel the access is only possible over an encrypted connection. When accessing the data in a database, the IP number of the person accessing the data must also be pre-authorized to obtain access.
On premise devices storing personal data temporarily is at all times, except when not being actively used or relocated under uninterrupted supervision, locked in a safe. Personal data are never stored on mobile media like USB sticks and DVD’s.
K-Locks will at all times keep you informed about changes to the processes to protect data privacy and security, including practices and policies. You may at any time request information on where and how data is stored, secured and used. K-Locks will also provide the summaries of any independent audits of the Service.
All access to personal data is blocked by default, using a zero privileges policy. Access to personal data is restricted to individually authorized personnel. K-Locks Security and Privacy Officer issues authorizations and maintains a log of granted authorizations. Authorized personnel are granted a minimum access on a need-to-have basis through our AAD.
5.6. The ability to intervene
K-Locks enables your rights of access, rectification, erasure, blocking and objection mainly by providing built-in functions for data handling in the Service Manager, by offering the option to send instructions through K-Locks helpdesk and also by informing about and offering the customer the possibility of objection when K-Locks is planning to implement changes to relevant practices and policies.
K-Locks uses security reports to monitor access patterns and to proactively identify and mitigate potential threats. Administrative operations, including system access, are logged to provide an audit trail if unauthorized or accidental changes are made.
System performance and availability is monitored from both internal and external monitoring services.
5.8. Personal Data breach notification
In the event that your data is compromised, K-Locks will notify you and competent Supervisory Authority(ies) within 72 hours by e-mail with information about the extent of the breach, affected data, any impact on the Service and K-Locks's action plan for measures to secure the data and limit any possible detrimental effect on the data subjects.
"Personal data breach" means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed in connection with the provision of the Service.
6. Do we disclose any information to outside parties?
K-Locks does not sell, trade or otherwise transfer to outside parties any personally identifiable information.
This does not include trusted third parties or subcontractors who assist us in operating our website, conducting our business, or servicing you. Such trusted parties may have access to personally identifiable information on a need-to-know basis and will be contractually obliged to keep your information confidential.
We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect our or others’ rights, property, or safety. Furthermore, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
6.1. Subcontractors/trusted third parties
The subcontractors Microsoft Ireland Operations Ltd, Dublin, Ireland and Fujitsu A/S, Ballerup, Denmark are following and being audited against the standards of ISO/IEC 27001. The main subcontractor Microsoft has also adopted the international code of practice for cloud privacy, ISO/IEC 27018. The sub-processor E-conomic International A/S is certified in “International Standards on Assurance Engagements 3000” (ISAE 3000).
K-Locks will monitor subcontractors’ and sub-processors’ maintenance of these standards and audits to ensure that data protection requirements are fulfilled.
Any intended changes concerning the addition or replacement of subcontractors or sub-processors handling personal data will be announced to you with at least 3 months’ notice. You retain at all times the possibility to object to such changes or to terminate the contract with K-Locks.
6.2 Legally required disclosure
K-Locks will not disclose the customer’s data to law enforcement except when instructed by you or where it is required by law. When governments make a lawful demand for customer data from K-Locks, K-Locks strives to limit the disclosure. K-Locks will only release specific data mandated by the relevant legal demand.
If compelled to disclose your data, K-Locks will promptly notify you and provide a copy of the demand unless legally prohibited from doing so.
7. Third party links
Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked websites. Nonetheless, we seek to protect the integrity of our website and welcome any feedback about these websites.
8. Where do we store the information?
No stored data will be transferred, backed up and/or recovered by K-Locks outside of the European Union.
8.1. Personal data location
All data are stored in databases and file repositories hosted in an Azure data centre at K-Locks cloud vendor, Microsoft Ireland Operations Ltd in Dublin. All data are automatically replicated in real time to secondary hot failover databases and file repositories in Microsoft’s data centre in Amsterdam, Netherlands.
Databases are continuously backed up to enable restore to any point in time within a retention period of 35 days. Backups are stored on file storage at the same geographical location as the database.
A copy of the Account Data is also stored in K-Locks cloud accounting system, Economic International A/S, Copenhagen, Denmark, hosted in a data centre operated by Fujitsu A/S.
8.2. Installation of software on cloud customer’s system
No installation of software is required to use the Service. The login-protected Service Manager is accessible through a standard web browser, automatically using an encrypted https-connection for all communications between your browser and K-Locks server to protect any data from being intercepted during network transfers.
9. Access, data portability, migration, and transfer back assistance
You may at any time obtain confirmation from K-Locks as to whether or not personal data concerning you are being processed.
You may at any time order a complete data copy, which you may transmit to another controller of the data. Your data will be delivered within 10 working days by K-Locks as spreadsheet files in Microsoft Excel-format. Logical relations between datasets will be preserved in form of unique identifiers. You are required to pay €1,000 + any applicable taxes on delivery for each data copy order.
10. Request for rectification, restriction or erasure of the personal data
You may at any time obtain without undue delay rectification of inaccurate personal data concerning you, cf. clause 5.6.
10.2. Restriction of processing personal data
You may at any time request K-Locks to restrict the processing of personal data when one of the following applies:
a. if you contest the accuracy of the personal data, for a period enabling K-Locks to verify the accuracy of the personal data;
b. if the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead; or
c. if K-Locks no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims.
You may without undue delay request the erasure of personal data concerning you, and K-Locks shall erase the personal data without undue delay when one of the following applies:
a. if the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
b. if you withdraw your consent on which the processing is based, and where there is no other legal ground for the processing;
c. if you object to the processing in case the processing is for direct marketing purposes;
d. if the personal data have been unlawfully processed; or
e. if the personal data have to be erased for compliance with a legal obligation in EU or national law.
11. Data retention
11.1. Data retention policy
Account Data will due to tax regulations be retained for up to five full fiscal years from your cancellation of your account.
Configuration Data and System Generated Data will be erased immediately when you cancel the account.
End User Data will be erased on an ongoing basis after 12 months from registration, and immediately when you cancel the account.
11.2. Data retention for compliance with legal requirements
You cannot require K-Locks to change any of the default retention periods, except for the reasons for erasure pursuant to clause 11.3, but may suggest changes for compliance with specific sector laws and regulations.
11.3. Data restitution and/or deletion
No data except Account Data will be retained after the termination of the contract. You may request a data copy before termination. You must not cancel the Service account until the data copy has been delivered, as K-Locks otherwise will not be able to deliver the data copy.
K-Locks uses the extensive range of built-in logging features and audits trails provided by Microsoft on its Azure cloud platform. K-Locks also logs all system updates, configuration changes and access to provide an audit-trail if unauthorized or accidental changes are made.
You may request a data protection audit performed by an independent third party who is also accepted by K-Locks. You will pay €5,000 plus applicable taxes for an audit request along with €200 per hour K-Locks is spending in connection with the audit as well as any other costs related to the audit, including the auditor.
K-Locks will cooperate with you in order to ensure compliance with applicable data protection provisions, e.g. to enable you to effectively guarantee the exercise of data subjects’ rights (right of access, rectification, erasure, blocking, opposition), to manage incidents including forensic analysis in case of security breach.
14. Your consent
You may at any time lodge a complaint with a supervisory authority regarding K-Locks collection and processing of your personal data. In Denmark, you can lodge a complaint with the Danish Data Protection Agency.