Definitions
Keibell App Platform - refers to the set of applications and systems provided by Keibell App to
Users and EnterprisesUser - a person that signs up to the Keibell AppUser Account - the user account of UserEnterprise - a customer of Keibell App that is entitled to use the Keibell App Platform based on a separate contract with Keibell AppKeibell App Mobile Application - a part of Keibell App Platform that serves Users to manage their User Account and data, manage their reservations, orders and other services provided by Enterprises, to communicate with Enterprises, and to use other services as provided by EnterprisesKeibell App Hotelier Panel - a part of Keibell App Platform that serves Users to act on behalf of Enterprises or Keibell AppKeibell App Administrator Panel - a part of Keibell App Hotelier Panel controlled by a single Enterprise where Users can manage data, settings, reservations, orders, applications, customers and use other functionalities as available in Keibell App Platform for and on behalf of that Enterprise. For a person to be able to access Keibell App Administrator Panel the person has to be a User and has to have an Keibell App Hotelier Panel Profile
Keibell App ServicesWhen you create a User Account and use Keibell App Platform we may collect and process the following categories of personal data:
Keibell App Website
When you visit Keibell App website, sign up for our events/webinars or for a newsletter, book a demo with Keibell App or contact Keibell App via our website we may collect and process the following categories of personal data:
Keibell App Customer Verification
In order to verify identity of our customers who enter into contractual relationships with us for the provision of Keibell App services we collect and process the following categories of personal data of company representatives and ultimate beneficial owners:
Keibell App Customer Services
When you attend a presentation call of Keibell App Platform or you contact Keibell App via our customer service center, we may collect and process the following categories of personal data:
Keibell App Careers
When you apply for a job at Keibell App we may collect and process the following categories of personal data:
Keibell App ServicesWhen you create a User Account with Keibell App Platform, we process your log-in data (your email address) and data relating to the services you reserve or order, including past services and orders.
If your reservation or order is with an accommodation provider, we also process information required for the accommodation registration card.
If you are invited to a Keibell App Hotelier Panel, we process what Keibell App Hotelier Pane within the Keibell App Platform have access rights to.
We process the data for the purpose and on the legal basis of delivering the functionalities of Keibell App Mobile Application to you.
Keibell App Website
Keibell App may use your data for marketing purposes, i.e., if you sign up for our newsletter or other marketing communication or which may, according to your past preferences, be of interest to you. These communications shall strictly adhere to applicable legal regulations. Advertising and marketing materials of other parties shall be sent to you only if you opted in to receive these communications, via our website email or otherwise. The legal ground for the processing of your data for marketing purposes is consent or our legitimate interests.
Your decision about receiving marketing communication may be withheld in accordance with the opt-out rules described in each marketing email or other form of communication via the unsubscribe option in the footer of every email. Opting out can be done also via changing the settings of your User Account or by directly contacting Keibell App. If you opt out, Keibell App shall retain only such data that is necessary for the provision of services to you in accordance with the rules set out in this policy.
Keibell App Customer Verification
Keibell App collects all the information and data needed for customer verification and submits this data to the payment processing providers to facilitate the KYC (know your customer) process mandated by anti-terrorism, anti-money laundering, anti-terrorist financing, financial services and other applicable laws and regulations. As a part of this process Keibell App as well carries out
verification of identity and status of company representatives and ultimate beneficial owners (such as whether the persons are politically exposed persons) via a third-party provider. Please find more information about the customer verification process in our Merchant terms . Keibell App processes this data on the legal basis of performance of contract and legitimate interest of Keibell App for the purpose of verifying customer identity.
Keibell App Customer Services
Keibell App records calls with its clients and processes associated personal data based on legitimate interest for the purposes of evidence of the proper provision of services and defense against any client claims.
We notify our clients about the recording at the beginning of every call. By continuing the phone call, you agree with the recording taking place and capturing expressions of a personal nature. If you wish to get in touch with us in a different way, please contact us at support@keibell.com.
We record calls (audio and video) with our clients and potential clients for the purposes of internal training, business intelligence and note taking. This recording is always based on your consent with the recording taking place before the recording starts. By consenting to the call recording, you agree with the recording taking place and capturing expressions of personal nature. You can withdraw your consent at any time by sending a message to support@keibell.com., in which case we will delete the recording.
Keibell App Careers
If you apply for any open job positions at Keibell App through Keibell App website or other means, we will process personal data you provide us with for the purposes of evaluating your application and information contained therein to assess whether you are a suitable candidate for any of our positions. We may also conduct pre-employment screening of job applicants to verify inter alia the truthfulness of the information contained in your CV and other documents you provide us with. For particular positions, you may be asked to provide us with your criminal record as well. The pre-employment screening is always done in such a way that its proportionality, adequacy and compliance with applicable law is assured. The legal ground for processing this data is the performance of contract or pre-contractual relations or your consent (where applicable). The respective Keibell App affiliate to which you applied for a job position shall be considered as data controller.
We may keep your CV in our internal database in order to consider you for future positions at Keibell App ,subject to your consent. You can withdraw your consent at any time in your User account or by sending a message to support@keibell.com .
Legal obligations
In some instances, legal regulations impose obligations on us under which we are obliged to process personal data. Such cases are for instance tax and accounting laws and the provision of some data to public authorities based on law. Thus, we can process your data for the purpose of fulfilling our legal obligations and archiving our internal records. The legal ground for processing of such data is compliance with legal obligations.
Our websites use cookies to collect information about individuals who visit our website. Cookies are small, encrypted text files that are stored on your computer or other device. Cookies help us to operate our website, and provide important features and functionality on our website. They help us to understand how our website is being used. At the same time, we use cookies for statistical and analytical purposes, for example to track and monitor what country, what pages and what method was used to visit our website as well as to enable personalization.
Additionally, cookies help us deliver online advertising that we believe is most relevant to you. Cookies are also used for profiling. Cookies can help us to understand how our website is being used, for example, by telling us if you get an error message as you browse. For more information about cookies please visit https://www.allaboutcookies.org .
We use the following types of cookies:
We may collect the following data via cookies:
IP address, gender, time zone, browser settings, operating system, information about website visits including the URL, search terms, information about what you viewed or searched on our website, page response times, download errors, length of visits to certain pages, page interaction information, (such as scrolling, clicks, and mouse-overs).
When you visit our websites, you shall be informed through a cookie banner placed at the bottom of the website that we collect cookies. The banner allows you to manage what kind of cookies can be collected by Keibell App. You can change the settings and withdraw your consent at any time through the Privacy settings provided on the bottom of our websites.
When we collect essential cookies the legal ground for the processing of this data is legitimate interest. It is not possible to disable these cookies through the Privacy settings as our websites might not function properly when you disable this type of cookie. However, if you still wish to do so, you may follow the instructions below in the section Disabling cookies.
When we store data or gain access to data already stored in your terminal equipment such as your PC or mobile device for analytical, functional, or advertising purposes we only do so once you have given us your consent.
Keibell App emails and/or websites and the communications generated from using and/or registering for Keibell App services and/or platform, such as promotional emails, may contain electronic images known as “web beacons”. Web beacons generally work in conjunction with cookies, and we may use them in the same way we use cookies (see above).
Apart from cookies, we also use other technologies that allow us to analyze your behaviour on our websites and alert us if any feature of the website does not operate properly. The current tools we use are Sentry (error monitoring system) and Hotjar (analytical tool).
We use Hotjar in order to better understand our users’ needs and to optimize our services and user experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g., how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf.
Disabling cookies
If you do not wish cookies to be collected, you may restrict, block or delete the cookies at any time by modifying your browser configuration. Although each browser is parameterized differently, cookie configuration is normally located on the “Preferences” or “Tools” menu. If you turn off cookies, the functionality of our website may be limited (in the case of essential cookies you may not be able to access our website).
If you wish to prevent new cookies from being installed or if you wish to delete existing cookies you can find the instructions on the links below. The exact procedure depends on which browser you are using:
For mobile devices you can limit tracking via the privacy setting on your device (disabling the advertising identifier), for instructions please see https://www.networkadvertising.org/mobile-choice/ .
Furthermore, you can use a third-party tool to opt out of targeted advertising. Available third-party opt-out tools include the Digital Advertising Alliance , the Network Advertising Initiative , and the European Interactive Digital Advertising Alliance (Europe only).
To opt out from receiving cross-device site advertising (i.e., tracking a user across devices) you can access your device settings or visit and employ the controls described on the NAI’s Mobile Choices page .
We also use so-called social plugins from the following social networks on our websites: (i) facebook.com, (ii) twitter.com, (iii) linkedin.com (“plugins”), which are indicated by their logos on our websites. When you visit our websites, your browser establishes a direct connection with the servers on which these plugins run. The content of the plugins is transferred directly by Facebook/Twitter/LinkedIn to your browser, which then integrates it into our website. Integration of the plugins causes Facebook/Twitter/LinkedIn to receive the information that you have accessed on the corresponding page of our website. If you are logged with Facebook/Twitter/LinkedIn it will be able to assign your visit to your account on these social networks.
Please note that an exchange of this information already takes place when you visit our website regardless of whether you interact with the plugin or not. If you do not want Facebook/Twitter/LinkedIn to gather data about you via our website, you must log out of them before visiting our website. For more information regarding how these social networks process your data in their privacy policies:
Facebook https://www.facebook.com/privacy/explanation
Twitter https://twitter.com/en/privacy
LinkedIn https://www.linkedin.com/legal/privacy-policy
Generally personal data shall be kept for as long as necessary for the purpose for which it was processed. The length of time that Keibell App will hold your personal data will also depend on the legal basis on which your data is processed. Shall the processing be based on legitimate interest, your data will be processed for as long as the given legitimate interest of Keibell App is in place. For data kept based on legal obligations, the data-retention period is prescribed by applicable legal regulations. For data processed based on performance of a contract, the data is processed for the duration of the contractual relationship and for an applicable limitation period. Shall the processing be based on your consent, your personal data shall be erased after you withdraw your consent. Please bear in mind that the same data may as well be processed based on other legal basis in which case your withdrawal of consent might not mean a full erasure of your data.
Keibell App shall neither collect an excessive amount of personal data nor other information which is not relevant for the purposes for which the personal data is collected.
If you create a User Account, we will process your data for the period of your registration with Keibell App. You can delete your User Account at any time. You can as well manage what data is processed about you via your User Account.
Personal data that Keibell App collects as part of the customer verification process is processed for the duration of the contractual relationship between Keibell App and its customers and 5 years after the termination of the contractual relationship.
Keibell App shall not store data provided by you or collected automatically during the phone calls for a longer period than what is necessary, given the purposes for which they were provided or collected. Moreover, you can withdraw your consent to process your data at any time by sending a message to privacy@Keibell App.com, in which case we will remove your data from our system.
The personal data of successful applicants is processed and retained in line with our employee Privacy Policy. The personal data of unsuccessful applicants that provided us with their consent for considering them for future positions at Keibell App is processed for the period for which the consent was given, whereas you may withdraw your consent at any time. The personal data of unsuccessful applicants that have not provided us their consent for retaining their personal data are retained for as long as the given legitimate interest of Keibell App to protect itself from legal claims and effectuate the hiring process.
Your personal data shall not be shared with any third party except for the following situations:
In order to allow you to manage various reservations/orders made with Enterprises, Keibell App may share your personal data with Enterprises for the sole purpose of making and managing your reservation/order as well as other services as offered by Enterprises.
Categories of Processors
Keibell App uses trusted third-party providers that in some instances process personal data on behalf of Keibell App and based on instructions provided by Keibell App. Keibell App may use the following categories of providers (processors under GDPR):
Transfers to Third Countries
Keibell App will transfer your data to countries outside the EU/European Economic Area only if such a transfer is compliant with applicable legal regulations. That means, for instance, that our provider is seated in a country for which the European Commission issued a decision that it provides an adequate level of personal data protection, standard contractual clauses and/or other transfer mechanisms are in place that ensure adequate safeguards with respect to the protection of privacy and fundamental rights and freedoms of individuals and, if necessary, additional measures are applied to ensure that the data subject is granted a level of protection essentially equivalent to that guaranteed by the GDPR.
Keibell App shall ensure that your personal data is stored securely. Therefore, Keibell App has introduced adequate physical, technical, and organizational measures and plans to protect and secure all information collected via Keibell App Services.
The aim is to eliminate the unauthorized or unlawful processing of your personal data, or accidental, unauthorized, or unlawful access, use, transferring, processing, copying, transmitting, alteration, loss or damage of your personal data. Despite all efforts and meeting all rules set out by applicable legal regulations, it is not possible to guarantee the security of your data if it is transferred or transmitted in an insecure way.
Keibell App protects your data in particular in the following ways:
You can find more information about Security in Keibell App Platform in Keibell App Platform Documentation .
These measures do not deprive you of your duties to undertake proper steps in order to secure your own personal data. You should, inter alia, regularly change your passwords. On the other hand, you should not, inter alia, use predictable usernames and/or passwords, share your password with other persons, or grant access to your User Account and/or disclose your personal data to other persons. Keibell App will never ask you for your password in any unsolicited communication. Please notify our data protection officer immediately upon any unauthorized use of your User Account or any other suspected breach of security.
Where the EU General Data Protection Regulation 2016/679 (“GDPR”) applies to the processing of your personal data you are entitled under the GDPR to the following rights:
Right of access
You are entitled to be informed inter alia about what personal data Keibell App processes about you, for what purposes, and who are the recipients of your personal data.
Right to rectification
You have a right for any of your incomplete, inaccurate, or out-of-date personal data to be rectified.
Right to erasure (‘right to be forgotten’)
You are entitled to the erasure of certain personal data that we have collected and processed about you. Please be aware that Keibell App might be allowed or even obliged to keep some of the personal data despite your deletion request.
Right to restriction of processing
In given cases such as when we process inaccurate personal data about you, or you deem the processing as no longer necessary, you may ask for a restriction of the processing.
Right to data portability
You have a right to receive personal data you provide us with in a structured, commonly used, and machine-readable format and to have it transmitted to another controller where technically feasible.
Right to object
You are entitled to object, on grounds relating to your particular situation, at any time to the processing of personal data that concerns you and is carried out in the public interest or for the purposes of legitimate interests pursued by Keibell App, including profiling.
The exercise of your rights may be limited shall Keibell App be obliged to keep any of your personal data for the purpose of compliance with legal obligations, for the establishment, exercise or defense of legal claims or any other compelling reasons as provided by the relevant data protection law.
Right to not be subject to automated decision making
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision: (a) is necessary for entering into, or performance of, a contract between you and Keibell App (b) is authorized by law and the law lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or (c) is based on your explicit consent. Keibell App does not make decisions based solely on automated processing that would have significant effects for Keibell App user. For completeness, Keibell App uses cookies and similar technologies the use of which may amount to profiling. For information on how to withdraw your consent for the use of cookies or disable cookies, please see chapter III. Cookies of this Privacy Policy.
Should you wish to exercise any of your rights, you may contact us at support@keibell.com.
Right to file a complaint
If you wish to file a complaint in regard to the processing of your personal data by Keibell App, you may contact our DPO at support@keibell.com. who will undertake to resolve the issue. You also have the right to lodge a complaint with our supervisory authority seated in Agencia Española de Protección de Datos (AEPD) ( https://www.aepd.es/es ), or with the supervisory authority of the particular affiliate (for contact details please see: https://edpb.europa.eu/about-edpb/board/members_en ).
Keibell App shall, from time to time, change and update the terms of this Privacy Policy. You shall be informed of any changes to this Privacy Policy by the publishing of an updated version on Keibell App website, and you may also obtain a copy of the amended Privacy Policy either via your User Account or via the email address you have provided to Keibell App.
The English-language version of this Privacy Policy shall be controlling in all respects and shall prevail in case of any inconsistencies with translated versions Keibell App may provide, if any.
Should you wish to know more about Keibell App, its protection of your privacy, or about this Privacy Policy, you can contact Keibell App at support@keibell.com .
Please help Keibell App ensure that your data is up to date. If you believe that some of the data processed by Keibell App is incorrect, please contact Keibell App at support@keibell.com.