1. TERMS THAT WILL BE FOUND IN POLITICS.

1.1. The D-KEYS Platform is an application developer, a person who processes personal data, D-Keys Platform LLC.

1.2. User - a person who uses the "D-KEYS" application and/or the Dealer's services.

1.3. Dealer is a company that is usually located in the User's country of residence and provides installation services for equipment that will be used through the D-KEYS application.

2. WHAT DATA ARE WE PROCESSING AND FOR WHAT PURPOSE.

2.1. The user's phone number (required to be provided). Data processing is necessary for authorization, user verification, user identification, access to application functions, restoring access to the application, receiving notifications, and ensuring user safety when using the application.

2.2. The phone number of the child key (required to be provided). Data processing is necessary to authorize, verify the user of the child key, identify the user of the child key, gain access to the application functions, restore access to the application, receive notifications, and ensure the security of the child key user when using the application.

2.3. The user name of the child key (not required to be provided) is filled in at the user's request for their convenience. Data processing is necessary for the convenience of using the application and for displaying persons in the application interface who have been issued a child key.

2.4. The address of the use of an apartment building (required to be provided). Data processing is necessary to display the address in the application so that the user can see the address of the key. With additional integration of the dealer and the platform to link the dealer's personal account number to the installation location, gain access to the application functions, and make requests in case of equipment malfunction.

2.5. Photo/video images of the user and third parties (recorded by some types of devices). Data processing is necessary to control access to the entrance, to identify guests by the user, to prevent crimes and illegal actions, and to ensure the safety of life and health, as well as the safety of property.

2.6. Information transmitted by the dealer at the user's request through the D-KEYS Platform to fulfill the agreement between the application user and the dealer. Including, but not limited to: information about applications, balances, and tariffs.

2.7. The D-KEYS platform can process technical information that is automatically collected by the application software while the user is working with the D-KEYS application.

2.8. When working with the D-KEYS application, the database may store records of the visit time, phone settings, operating system, as well as other technical information necessary for the application to work.

2.9. The D-KEYS platform processes personal data to fulfill the contract concluded between the dealer and the user. In addition, processing is necessary for the correct operation of the application, as well as to ensure the safety of the home, including the safety of the user's life and health, and the safety of property.

2.10. The D-KEYS platform processes personal data in order to operate the D-KEYS application and provide possible functionality to the end users of the application, including establishing feedback with the user; notifying the user of the D-KEYS application about the action with the shared device.

2.11. When determining the volume and content of personal data processed, the D-KEYS Platform is guided by the purposes of data collection.

2.12. The processing of personal data is limited to achieving the specified goals.

3. DATA PROTECTION MEASURES. 

3.1. Data encryption during transmission (including using HTTPS);

3.2. Data storage on secure servers with limited access;

3.3. Authentication and control of access to data within the company;

3.4. Regular updating of the application security system;

3.5. Monitoring of activity and prevention of possible threats.

4. HOW MUCH DATA IS STORED.

4.1. The data provided during registration in the D-KEYS application is processed within the time period from the moment of user registration until the moment of deletion of his account. The D-KEYS platform stores data only for the period of the user's use of the registered account until it is deleted by the user after which it is safely deleted. The photo/video data received through the intercom equipment is stored for up to 100 days.

5. USER'S CONSENT.

5.1. Downloading installing and registering in the D-KEYS mobile application confirms the user's free informed and unambiguous consent (expression of will) to the processing of his personal data including the cross-border transfer of personal data.

5.2. The consent of the personal data subject to the processing and storage of personal data is expressed in electronic form by checking the box in the application.

5.3. If the user does not consent to the processing and does not agree with the Personal Data Policy, he is obliged to immediately delete the application from his device and refrain from using it.

6. INSTALL THE APPLICATION.

6.1. By itself, the installation of the application does not mean the beginning of the processing of the user's personal data. To install the application and continue using it, you need to download it, read the Privacy Policy and Personal Data Processing. Further, in order to use the application, the user must agree to the Policy and the processing of personal data, and check the box in the corresponding Application window.

7. AUTHORIZATION.

7.1. The transfer and processing of the user's personal and other data begins at the time of authorization in the application. To identify and activate the application, you must enter your phone number and complete authorization. Authorization is performed by making a call to the number specified by the user at the login and/or sending an SMS message with a confirmation code. Authorization is considered completed after entering an SMS message with the confirmation code and/or the number (part of the number) of the call that the user received to confirm the number in a special interface field. During the authorization process, the Platform transmits the phone number to companies that send codes via SMS or authorization through a call. Companies can be located in the territory of the user's state or in another territory. This data transfer is done solely for the purpose of user authorization. 

8. KEY REGISTRATION.

8.1. Keys can be registered in several ways, including those listed below.

8.2. For a general-purpose device by entering a 12-digit master key registration code, which is provided by the dealer to the user. The way the code is transmitted is determined by the relationship between the dealer and the user. In some cases, the code is transmitted via SMS, on a leaflet, in the D-KEYS application, via WhatsApp LLC.

8.3. Registration of the master key from an individual device that is installed in the apartment is performed using the 20-digit number indicated on the device (individual apartment device).

8.4. Registration of the master key using a QR code containing the necessary personal data for authorization, which is generated by the dealer and transmitted to the user in accordance with the agreement. In some cases, the QR code is transmitted on the flyer, via WhatsApp LLC.

8.5. The child key data is entered independently by the application user to provide access to the application functions.

9. USAGE.

9.1. Some requests made by the user are transferred to the dealer for processing in accordance with the agreement concluded between the dealer and the user. After processing the request, the dealer can transmit data for transmission in the application, for example, about: balance, bids, tariff. When requesting data, the user agrees to send a request and response in the dealer's form, in the standard way for the D-KEYS Platform, regardless of whether this data is completely anonymized or contains personal data. The dealer independently processes, receives, stores and protects relevant personal data in accordance with the requirements of applicable legislation. 

9.2. The D-KEYS application may contain links to other sites that are not managed by the D-KEYS Platform. The D-KEYS platform is not responsible for their content and recommends that you review the privacy policy of each site you visit, if any. 

10. LEGAL GROUNDS FOR PERSONAL DATA PROCESSING: 

10.1. The legal basis for the processing of personal data is a set of legal acts, pursuant to which and in accordance with which the D-KEYS Platform processes personal data, namely: 

- Council of Europe Convention No. 108 “On the Protection of Natural Persons with regard to Automated Processing of Personal Data" (Strasbourg, January 28, 1981)

- The Constitution of the Republic of Armenia, the Constitution of Georgia, the Constitution of the Republic of Kazakhstan, the Constitution of the Republic of Uzbekistan, the Constitution of the Republic of Moldova, the Constitution of Mongolia, the Constitution of the Russian Federation, as well as the Constitutions of other countries;

- regulatory legal acts in the field of civil legislation of the Republic of Armenia, Georgia, the Republic of Kazakhstan, the Republic of Uzbekistan, the Republic of Moldova, Mongolia, the Russian Federation, as well as other countries;

- normative legal acts in the field of housing legislation of the Republic of Armenia, Georgia, the Republic of Kazakhstan, the Republic of Uzbekistan, the Republic of Moldova, Mongolia, the Russian Federation, as well as other countries;

- other regulatory legal acts regulating relations related to the Platform's activities;

- Statutory documents of the "D-KEYS" platform;

- Contracts concluded between the D-KEYS Platform and Users;

- Contracts concluded between the D-KEYS Platform and counterparties;

- The user's consent to the processing of personal data. 

11. RIGHTS AND OBLIGATIONS: 

11.1. The D-KEYS Platform is obliged to use personal data exclusively for the purposes specified in this Policy.

11.2. The User has the right to require the D-KEYS Platform to clarify his Personal Data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing.

11.3. The D-KEYS Platform is obliged to ensure that personal data is kept confidential, not disclosed without the User's prior written permission, and not sold, exchanged, published, or otherwise disclosed by the User's personal data, except as provided for in this Privacy Policy.

11.4. The D-KEYS Platform has taken legal, organizational and technical measures to ensure the protection of the User's personal data during their processing from unauthorized, unlawful or accidental access to personal data, copying, provision, dissemination of personal data, as well as from other unlawful actions with respect to personal data.

11.5. The D-KEYS platform is obliged to block personal data related to the relevant user from the moment of the request or request of the User or his legal representative or the authorized body for the protection of the rights of personal data subjects for the verification period in case of identification of false personal data or illegal actions. 

12. POLICY CHANGES.

12.1. The D-KEYS Application may update the Policy from time to time. We will notify you of any changes by posting a new Policy on this page.

12.2. The D-KEYS platform monitors changes in legislation related to personal data in the European Union, in the countries of Armenia, Georgia, Mongolia, Moldova, Kazakhstan, Uzbekistan and the Russian Federation.

12.3. In case of changes to the Policy, the user who continues to use the application expresses his consent to the processing of personal data, as well as agrees with the new version of the Privacy and Personal Data Processing Policy. If the user does not agree, he is obliged to stop using and delete the application. 

13. CONTACTS OF THE “D-KEYS" PLATFORM.

13.1. You can contact the D-KEYS Platform for Policy-related issues by e-mail: info@d-keys.info.