Privacy Policy

Dated: 2025-07-28
1. Introduction

Alzefgames Limited, a company incorporated under the laws of Ireland, registration number 792563 (“COMPANY”), respects your privacy and are committed to protecting your personal data. This Privacy Policy explains how the COMPANY handles your personal data when you visit this website, https://keys-digital.com (“Platform”). All personal data is processed in compliance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and applicable data protection laws.

When you first visit our Platform, we will request your consent for the use of cookies in accordance with this Privacy Policy. The Platform also includes privacy controls that allow you to manage how your personal data is processed, including preferences for receiving marketing communications.

If you have any inquiries or wish to exercise your data protection rights, you can contact us at [email protected]. In case of discrepancies between different language versions of this Privacy Policy, the English version prevails unless stated otherwise.

Definitions:

  • Personal Data: Any information relating to an identified or identifiable person.
  • User: An individual using the Platform.
  • Vendor: A service provider or partner.
  • Platform: The COMPANY’s website or digital interface.
2. Data Protection principles

The COMPANY adheres to the following principles when processing personal data:

  • Lawfulness, fairness, and transparency – Data is processed lawfully, fairly, and transparently.
  • Purpose limitation – Data is collected for specified, explicit, and legitimate purposes.
  • Data minimization – Only necessary and relevant data is processed.
  • Accuracy – Data is kept accurate and up to date.
  • Storage limitation – Data is retained only as long as necessary.
  • Integrity and confidentiality – Data is securely stored and protected against unauthorized processing, loss, or destruction.

All personal data processed by the COMPANY is treated as strictly confidential and accessed only by authorized person

3. How We Use Your Personal Data

This section outlines:

  • Categories of personal data we process.
  • Sources of personal data not directly provided by you.
  • Purposes and legal bases for processing.
3.1 Categories of Personal Data and Purposes
  • Usage Data – Includes IP address, location, browser type, operating system, referral source, session duration, and Platform navigation. Collected via cookies for analytics and service improvements. (Legal basis: Legitimate interest)
  • Account Data – Includes name, email, phone number, and purchase history. Used to provide services and maintain your account. (Legal basis: Performance of contract for account use; Legitimate interest for fraud prevention and support)
  • Transaction Data – Includes contact details, bank details, and payment history. Used for processing payments and compliance. (Legal basis: Performance of contract; Legitimate interest)
  • AML Data – Includes address, ID documents, and source of wealth documentation. Required for anti-money laundering compliance. (Legal basis: Legal obligation; Legitimate interest)
  • Fraud Detection Data – Includes account, transaction, and device data to identify suspicious behavior. (Legal basis: Legitimate interest)
  • Direct Marketing Data – Includes email and messaging preferences. (Legal basis: Consent; Legitimate interest for existing customer communications)
  • Correspondence Data – Includes communications for support or disputes. (Legal basis: Legitimate interest)
  • Chat Data – Includes chat messages used for service functionality and moderation. (Legal basis: Consent)
  • Legal Claims Data – Includes any data required for legal matters. (Legal basis: Legal obligation; Legitimate interest)
  • Insurance and Risk Management Data – Used to manage insurance coverage and legal inquiries. (Legal basis: Legitimate interest)
3.2 Data Sharing

Your data may be shared with:

  • Users or Vendors – For fulfilling contracts.
  • Affiliated companies – For administration and IT.
  • Insurers and legal advisors – For legal obligations.
  • Fraud prevention partners – To reduce security threats.
  • Payment providers – To handle transactions securely.
  • Other service providers – E.g., cloud storage, analytics, communications tools.

Some providers may be outside the EEA. In such cases, the COMPANY uses:

  • Standard Contractual Clauses (SCCs) approved by the European Commission.
  • Additional technical and organizational safeguards (e.g., encryption).

Transfers may occur to countries such as the United States or Canada, where the COMPANY ensures adequate protection through data processing agreements.

4. Data retention

We retain personal data only for as long as necessary:

  • Account Data – Up to 5 years after last activity.
  • Transaction Data – Up to 10 years.
  • AML Data – As required by law.
  • Fraud Detection Data – As long as needed to prevent fraud.
  • Marketing Data – Until consent is withdrawn or the account is deleted.
  • Correspondence Data – Up to 6 months.
  • Chat Data – Until consent withdrawal or account deletion.

Longer retention may apply to meet legal, regulatory, or fraud-prevention requirements.

5. Marketing Communications

With your consent, we send marketing communications via email or Platform notifications. If you have previously used our services, we may contact you about similar offerings unless you opt out.

You may withdraw from marketing communications at any time by:

  • Clicking “unsubscribe” in any email.
  • Changing your preferences in your account.
  • Contacting [email protected].

Note: Unsubscribing does not affect service-related emails.

6. Your Rights

Under the GDPR, you have the following rights:

  • Access – Receive a copy of your personal data.
  • Rectification – Correct inaccurate data.
  • Erasure – Request deletion under legal grounds.
  • Restriction – Limit processing under specific conditions.
  • Objection – Object to processing based on legitimate interests.
  • Data Portability – Receive your data in a machine-readable format.
  • Withdraw Consent – Withdraw consent where applicable.
  • Complaint – File a complaint with a supervisory authority.

Requests can be submitted to [email protected].

7. Cookies

We use cookies to enhance your experience on our Platform. These include:

  • Necessary Cookies – For core site functions.
  • Analytical Cookies – For measuring site use.
  • Preference Cookies – To save settings.
  • Marketing Cookies – For personalized content.

Manage cookies via browser settings or the “Cookie Preferences” link in the footer.

Third-Party Services

  • Google AdSense – Uses cookies for targeting ads.
  • External Links – We may link to other websites. The COMPANY is not responsible for their privacy practices.

For a full list of cookies, their purposes, and durations, see our Cookie Policy.

8. Children's Data

Our Platform is intended for users aged 18 and older (or the legal age in your country). If we discover that data has been collected from minors, it will be deleted.

9. Data Updates & Policy Changes

Please keep your personal data up to date. Notify us of any changes.

We may update this Privacy Policy from time to time. Material changes will be communicated via email or Platform notifications.

For any questions, contact: [email protected].

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