Privacy Policy

4. Purpose of Data Processing

We process your personal data for the following purposes:

4.1 Essential Service Delivery:

• Provide and manage the digital wardrobe service and Keypitt™ profile
• Authenticate users and ensure secure hand-in and retrieval of belongings
• Send service messages (e.g. KeyPass delivery, wardrobe closing reminders, lost & found communication)
• Process payments and issue receipts
• Maintain platform security, backups, and performance

4.2 Marketing:

• Send marketing messages via SMS, email or push notification, where you have consented as described in Section 10.
• Enable venues that have activated the Marketing Dashboard feature to send marketing communications to you through the Keypitt™ system, where you have consented, as described in Section 5.

We never sell or rent personal data to third parties.

5.The Marketing Dashboard Feature and Joint Controllership

5.1 Overview

Some venues that use the Keypitt™ platform activate an optional feature called the Marketing Dashboard. When a venue has activated this feature, it becomes a joint data controller with Keypitt™ for the strictly limited purposes described in this section. This joint controllership arrangement is governed by a written agreement between Keypitt™ and the venue, made pursuant to Article 26 of the GDPR.

Joint controllership applies only to:

• The display of your factual visit history at that venue through the Marketing Dashboard
• The manual selection of guests for marketing purposes using predefined filters within the Keypitt™ system
• The dispatch of SMS, push notifications and email marketing campaigns to you via the Keypitt™ system

Joint controllership does not apply to any other aspect of the Keypitt™ service, including data hosting, security, data subject rights handling, or any processing carried out across multiple venues unless expressly agreed upon between the affected venues.

5.2 What the Venue Can See

Where a venue has activated the Marketing Dashboard, its authorised staff can view information about guests who have visited that venue only, through a read-only dashboard within the Keypitt™ platform:

• Your profile information (only the information that you have voluntarily added to your profile)
• Factual historical visit data
• Marketing opt-in status

5.3 What the Venue Cannot Do

Venues cannot:

• View your contact data
• Export, download, or extract your personal data from the Keypitt™ system
• Send marketing messages to you outside the Keypitt™ system
• Combine your data with data held in any external system
• Use your data for any purpose other than sending marketing communications through Keypitt™ with your consent
• Access data relating to your visits to other venues of different ownership
• The action of extracting, copying, or secondary use of your personal data – including by screenshot or equivalent means – is strictly prohibited under the venue’s agreement with Keypitt™.

5.4 Responsibilities Under the Joint Controllership Arrangement

Even where a venue acts as joint data controller for the Marketing Processing:

• Keypitt™ remains your primary contact for all data rights requests and privacy enquiries.
• Keypitt™ controls and enforces all consent and opt-out preferences – if you have opted out of marketing Keypitt™’s system will prevent any campaign from being sent to you, and the venue has no technical ability to override this
• Keypitt™ is the technical sender of all campaigns
• Keypitt™ handles all data subject rights requests, security, breach notification, data retention, and sub-processor management

The venue’s role is limited to determining campaign content and selecting recipients. You may exercise your rights under GDPR against either Keypitt™ or the venue, but in practice Keypitt™ is best placed to assist you and will handle all such requests.

6. Legal Basis for Processing

We rely on the following lawful bases under GDPR Art. 6:

Contractual Necessity (Art. 6(1)(b))

Processing necessary to provide and operate the Keypitt™ services, including account creation, service delivery, transactions, and related communications.

Legal Obligation (Art. 6(1)(c))

Processing necessary to comply with applicable legal obligations, including accounting, tax, and regulatory requirements, as well as responding to lawful requests from public authorities.

Legitimate Interests (Art. 6(1)(f))

Processing necessary for our legitimate interests, such as maintaining the security and reliability of the platform, preventing fraud or misuse, and improving our services through aggregated or anonymised analysis.

Where we rely on legitimate interests, we ensure that these interests are balanced against your fundamental rights and freedoms.

Consent (Art. 6(1)(a))

Where required, we rely on your consent for optional features, additional profile information, or certain communications. You may withdraw your consent at any time without affecting the lawfulness of processing carried out before the withdrawal.

7.Data Retention Policy

The user’s account data is retained for a maximum of three years after your last KeyPass activity. Transaction records may be stored longer if required by accounting or legal obligations; these are then anonymised or pseudonymised. You may request deletion or anonymisation of your profile at any time (see section 11).

8. Data Security

Keypitt™ uses industry-standard security measures to protect your personal data from unauthorised access, alteration, disclosure, or destruction. All data is encrypted in transit (TLS) and at rest (AES-256). Access is limited to authorised Keypitt™ personnel and trusted providers who require it to perform their duties and are bound by confidentiality.

9. Sharing and Disclosure of Personal Data

Keypitt ApS does not sell Users’ Personal Data. Keypitt ApS only shares and give access to Users’ data in the following limited circumstances: 

• with sub-processors necessary to operate the platform (see below in this Section 5). We share data with trusted sub-processors who host, transmit, or process data on behalf of Keypitt™ under strict data processing agreements. See the sub-processor table below.
• with group companies or a successor entity in the event of a merger, acquisition or sale of Keypitt ApS’ business, on the basis of Keypitt ApS’ legitimate interest in conducting the transaction (Art. 6(1)(f) of the GDPR);
• By Legal and regulatory requests, where required to do so by applicable law, court order, competent authority or legal process (Art. 6(1)(c) of the GDPR), or to establish or defend legal claims (Art. 6(1)(f) of the GDPR);
• where necessary to investigate or prevent illegal activity, suspected fraud, or threats to the physical safety of any person (Art. 6(1)(f) of the GDPR).

Future integration partners: If we enable new features involving additional partners, we will provide advance notice and obtain your consent where required by GDPR.

Venues and event staff:

• To facilitate wardrobe operations (e.g. verifying your identity in case your device is inaccessible)
• If you have voluntarily added e.g. a profile photo or name, venue staff may see this to ensure correct item retrieval at check-in or check-out alongside history of interaction. 
• Where a venue has activated the Marketing Dashboard feature, authorised venue staff may view your factual visit history for that venue
• Venues cannot export, copy, or independently use your data

Sub-processors