Introduction

Keeper Solutions is a market-leading software development partner for innovative FinTech, CleanTech and MedTech firms. We specialize in the highly regulated FinTech space and have forged long-lasting partnerships with multiple enterprise-level companies and fast-scaling start-ups in this sector, both in the United States and in Europe. Learn more about us https://keepersolutions.com/

We are committed to protecting your personal information and the following describes how we collect, process, and store your personal information in accordance with applicable laws, including, ePrivacy directive, the EU General Data protection Regulation no. 679/2016 (GDPR) and Irish data protection Acts 1988 to 2018.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website or send us an email, apply for a job, or enter into any business transaction with us. Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please exit our site and do not introduce any personal details.

We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the “Last Updated” date of this Privacy Policy. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the Site. 

You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Site after the date such revised Privacy Policy is posted.  Only subscribers to our “sign me up” newsletter will receive specific emailed notice of each such change or modification.

For the purpose of Data Protection Law, we are the data controller of your personal data. If you feel something is not addressed in this Privacy Policy or have further questions, please contact us at info@keepersolutions.com 

Responsibility over data collected

As defined by the GDPR, Keeper Solution (we) are Controller and Processor of the data collected via our websites, email exchange and business activities, which means we determine the purposes and means of the processing of the personal data.

To provide you the best service possible, for Marketing and recruiting activities your personal data may be transferred to our service providers, which assumes the role of Data Processors as they provide us back-office applications for our website and are permitted to use your information only for such purposes. All our service providers are bound by contractual agreements to keep your data private and secure. 

For subscriptions to our newsletters, and any other subscription campaigns, your data is managed directly by us.  

Job applications submitted through our site are processed by Us using an ATS (Application Tracking System) called the Breezy (See also: “How long do we keep your personal information”). Occasionally for specific roles, we may pass on your information to a recruitment management specialist to assist us with the recruitment and hiring processes. Should this be the case, you will be informed on the transition of your CV, which will be processed and kept by the recruitment specialists for the purposes of recruitment and hiring.

With a successful recruitment, the ATS data then automatically links into our HR System called HR Bamboo, for secure handling of employee data.

What information do we collect and why?

When interacting with us, we may collect information about you in a variety of ways, depending on the purpose of your contact.

Personal Data

Please note you are under no obligation to provide us with personal information of any kind, as you may opt to navigate our Sites for information purposes. Should you choose to engage with us, we may collect Personally identifiable information (PII), such as:

Your name, e-mail address and other identification or personal details (contact information, marketing preferences, feedback on the use of our services when voluntarily provided by you, in connection with sign-up for our newsletter or in connection with other interactions with us, e.g., using the chat or other communication functions, applying for jobs, quality customer satisfaction surveys or business-related queries. This allows us to interact and provide you with information. You may at any time choose to stop these interactions (see how below: Your rights as a data subject).

To perform our services, we will collect our Customer’s personnel’s professional emails and contact numbers. These shall be used solely for the purpose of performing contracted services.

Your personal data will not be used for automated decision-making, including profiling. Although, anonymized, it may be used for business analytics.

Business Identity Data, Company and Business Information

We might collect business identity data when you enter into any business transaction with us, to establish a contract and register your company in our invoicing system.

During our business activities we will have access to Business information under the scope of the services rendered. 

The company and business data we shall have access to shall be defined in the business contract, along with the confidentiality and security controls to be applied. All customer  data and information are handled as Confidential.

Derivative Data

This refers to information that our servers automatically collect when you access our Sites, such as your IP address, your browser type, your operating system, your access times, and the pages you have viewed directly before and after accessing the Site. This allows us to have statistics regarding the performance of our sites.

Cookies, Log Files and Tracking

Cookies are pieces of data that a website can place on your browser or device that the website can then read on future visits to facilitate the use of the website for the user. Our websites use cookies to store user information to provide users with personalized experiences and collect our users’ web history.

Cookies are used to keep track of your computer settings, such as which account you are logged on to, notifications, website access preferences. etc. We use cookies for Authentication, Security, Advertising, Performance, Analytics and Research. We also use social marketing and social media insights using third party cookies such as: Facebook and Google.

Using first party cookies and third-party cookies, we analyse and track users’ use of the Site, determine the popularity of certain content and better understand online activity. By accessing our sites, you consent to the collection and use of your information by these third-party providers. You are encouraged to review their privacy policy and contact them directly for responses to your questions.

We may also use third party website analytic tools such as Google Analytics, GA4 and Hotjar on our website that also deploy cookies to collect certain information concerning your use of our site. 

We embed videos from our official YouTube channel using YouTube’s privacy-enhanced mode. This mode may set cookies on your computer.

In addition to the cookies that we own, we may also use third-parties’ cookies on our Site to process the CVs that you submit to us.

As the owners of these cookies, you are entitled to information from these third parties regarding their privacy and security policies, and on how to opt-out from their cookies. You can find more information on our third-party cookie providers below:

Name of Provider                    Link                                   

Breezy HR                                  2022 Privacy Policy: Breezy Policies | Breezy HR

BambooHR                                BambooHR Privacy Notice

If you do not want any information to be collected and used by tracking technologies, you may disable this on your browser settings or install an Opt-out tool, or alternatively, you may install a cookie tracker tool that allows you to have more control over cookies.

You may regularly clean the cookie history for your browser if you so desire. If you do not wish to have all categories of cookies placed on your computer, you may either set your preferences accordingly through the cookie consent functionality provided on the Website or set your browsers to refuse cookies before using the Website.

To understand more about our cookies, please consult our Cookie policy.

Web beacons  

We further deploy other technologies, such as web beacons for email tracking sent by the system. A Web Beacon is made up of a clear file, usually a 1×1 pixel, that can track users like a cookie and is used on web pages and emails to unobtrusively check that a user has accessed some content.

Social plugins 

Social plug-ins are small pieces of software which create a link between your visit to our websites and the social media platform of a Third-Party Provider. When you visit our site, initially no personal data will be passed on to the providers of these plug-ins. Only when you press one of the plug-ins, personal data will be transferred. Through the integration of a plug-in, the plug-in provider receives the information that you have accessed a specific page of our online offer. Furthermore, the following data are transmitted (IP address, date and time of the request, time zone difference to the Greenwich Meantime, content of the request (concrete page), access status / http status code, amount of data transferred, request source website, browser, Operating system and interface, language, and version of the browser software). We use social plug-ins of the following Third-Party Providers: Facebook; Vimeo Video; LinkedIn; Pinterest; YouTube; Instagram.

Log files  

As with any other websites, we gather information and store it in log files which allows us to log user activity, which may be required for security, statistical and possibly legal purposes. Information collected in log files includes IP (internet protocol), browser type, internet service provider, operating system, geographic location, entry and  exit pages, files viewed and activity (including consent and closing account). We use this information to manage our website, analyse trends, understand the efficiency of the site by understanding our visitors’ use of it, and gather demographic statistics of our visitors, this all enables us to provide continuous improvement to our users.

What are Cookies, Log Files and Tracking for?

These technologies enable us to:

• Retain and evaluate information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive.
• Keep a record of the articles on our website that you have clicked on and use that information to target advertising on this website to you that is relevant to your interests, which we have identified based on articles you have read.

What information do we receive about you from other entities?

Social Media

Through your interaction on our website, we may also receive information about you from other entities. 

We may link the data you provide to Us, with other publicly available information about you that you have published on the Internet – this may include sources such as LinkedIn and other social media profiles.

We may search various databases – some publicly available and others not, which may include your personal data (including your CV or Resumé), to find possible candidates to fill Our job openings. Where We find you in this way, we will obtain your personal data from these sources.

We may receive your personal data from a third party who recommends you as a candidate for a specific job opening or for our business more generally.

How do we use your information?

Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Pending your use of our site and options, we may use information collected about you via the Site in various ways:

• Create and manage the business relationship through our CRM.
• Perform transactional associated business activities as needed.
• Respond to customer service requests and communicate with you in respect of job applications when necessary.
• Send you a newsletter (if subscribed).
• Provide support for the Site.
• Generate a personal profile about you to make future visits to the Site more personalized.
• Send you a satisfaction questionnaire regarding our service and products delivered.
• Offer new products, services, and/or recommendations to you.
• Notify you of updates to the Sites, Policies, Terms, and conditions.
• Deliver targeted advertising, coupons, newsletters, and other information regarding promotions and the Site to you.
• Increase the efficiency and operation of the Sites.
• Monitor and analyse usage and trends to improve your experience with the Sites.
• Compile anonymous statistical data and analysis for use internally or with third parties.
• Request feedback and contact you about your use of the Site.
• Resolve disputes and troubleshoot problems.
• Assist law enforcement if required or provide evidence of conformance if required.

Purpose of Processing Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our internet site, including to monitor the usage of our site.
• For the performance of a contract: the development, compliance and undertaking of the contracted services.
• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
• To manage Your requests: To attend and manage Your requests to Us.
• To find appropriate candidates to fill our job openings.
   
• To consider your application in respect of a role for which you have applied or in respect of other roles.
• To communicate with you in respect of the recruitment process.
• To help our service providers (such as recruitment agencies) and Partners (such as the job sites through which you may have applied) improve their services.

How is your information secured?

We work to protect the security of your personal information by using software and encryption protocols. We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personal customer information. Our security procedure means that we may ask you to verify your identity before we disclose personal information to you. We have chosen sub processors that ensure security by design and information security practices.

While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. 

As an online User, the security of your data also depends on the security features of your device, and your practices. We recommend following good online security practices. Learn more at https://www.gov.ie/en/campaigns/be-safe-online/# 

We rely on you to help us and help others. If you suspect a personal data breach or notice something irregular with our site or our brands, please contact us at info@keepersolutions.com

How long do we keep your personal information?

We will only retain your personal data for as long as is necessary for the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax and accounting or reporting requirements. We may retain your personal data, or records of transactions and consent for a longer period in the event of a complaint or to protect our organization in case of litigation.

In considering how long we keep your personal data, we will consider its relevance to our business and to legal and regulatory obligations, which apply to us. We have implemented technical and organizational measures to keep it safe.

When you apply for one of our jobs online via our website or an external website, all applications are fed and stored to our ATS (Application Tracking System) and our CRM (Customer Relation Management System). Your data is stored so that we can manage your  experience in this ATS and our CRM software.

When you apply for a job posted by us, the information we collect/you provide is used to determine whether or not you’re a good fit for current and future roles of our company. We’ll hold on to your data for up to 24 months and if it turns out we’d like to keep it around longer, we’ll reach out to you for consent first. We may retain your LinkedIn Profile to be able to contact you for future opportunities. 

How long do we keep Business Identity Data, Company, and Business information?

Business Identity Data, contacts and invoices are maintained to meet legal and fiscal obligations.  We keep your business information for as long as is required in order to fulfil the relevant purposes described in this privacy Notice, as may be required by law such as tax and accounting purposes or otherwise communicated to you.

Keeper solutions does not maintain any customer and business information once the services have been concluded.

Disclosure and transfers of data

Our processing facilities and those of our third-party service providers are situated within the European region. In some cases, we will be transferring personal data to countries outside the EU/EEA, in connection with our business. Such transfers will only take place under the governance of a lawful international data transfer agreement, that protects your rights and ensures the security of your data.

Should you use social media log-in features, or social-media plugins, the social media platforms may store your data in non-EU countries.

Should you send us your CV we might send it to the recruitment processors

Should you subscribe to our newsletter we might transfer your information to the marketing team.

We may on occasions pass your Personal Information to third parties exclusively to process work on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance. With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing purposes. We require these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice and relevant data protection laws.

We may disclose your Personal Information to meet legal obligations, regulations, or valid governmental requests. If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction.

Should we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity. If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party. You acknowledge that such transfers may occur, and that the transferee may decline honour commitments we made in this Privacy Policy.

Keeper solutions does not share any Customer Company or Business data with third parties.

Subcontract Developments

Subcontracting is the practice of assigning or outsourcing part of our obligations and tasks under a contract to another party known as the subcontractor. All our operational services are performed by Keeper Solutions personnel. Keeper Solutions does not subcontract developments.

What legal basis allows us to collect your data?

We may process Personal Data under the following conditions:

• Consent ( 6(1)(a) GDPR): We process personal data based on consent according to Art. 6(1)(a) GDPR, which you are free to give or refuse. You will see consent options when you visit our website for the first time. This means that we process your data with your authorization only.

You can change your decisions at any time. This is how you may change your authorization decisions:

• Should you wish to alter your cookie consent, you can exit the site, clean all the cookies from your internet browser, then re-enter our site, selecting the desired configuration.
• Should you wish to unsubscribe our newsletter, follow the instructions on the footer of the last email received.
• You can consult, revise, and correct the personal data that you have provided us by contacting us via email at info@keepersolutions.com
• Performance of a contract (Art. 6(1)(b) GDPR): Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof. If you register for our newsletter or subscribe to our mailing list or apply for a role via our site, we will process your Personal Data to the extent required to deliver the service requested.
• Legal obligations (Art. 6(1)(c) GDPR): We also process data for compliance with a legal obligation to which we are subject to ensure business administration, record keeping and compliance.
• Legitimate interests (Art. 6(1)(f) GDPR): Based on the data collected on the site with your consent, we may process anonymized data to pursue the Legitimate interest. This is to ensure improvement and customization of our websites, the services offered, and the products marketed.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your rights as a data subject

Under data protection law, you have rights we need to make you aware of. The rights available to you depend on our reason for processing your information. If we are processing your information for criminal law enforcement purposes your rights may be conditioned. 

If we process your personal data, then you have the following rights:

• Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
• Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
• Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
• Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
• Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
• Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.
• Automated decision making/profiling. You have the right to object to automated processing, including profiling. You also have the right not to be subject to the legal effects of automated processing or profiling.

Exercising your rights, managing information and opting out.

You can update or correct your Personal Data, remove it from our system or exercise any of your rights by making a request to us at the contact information provided below.

You may always opt-out of receiving future commercial e-mail messages from us or request that your information be removed from our site by emailing us at the address provided below. You may also unsubscribe from our marketing communications by clicking on the “unsubscribe” link located on the bottom of our emails or by sending us an email.

We have implemented the necessary technical features and operational procedures to support the exercising of your rights. You are not required to pay any charge for exercising your rights. 

Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, we will respond to you within 30 days of receiving your request. 

If for some reason access is denied, we will provide an explanation of why access has been denied.