Privacy Policy

We believe in openness and privacy. Four Key Asset and Block Management Limited ("Company" or "we" or "us") is a company registered in England and Wales. Our registered office is at 105 St Paul's Road, Highbury, London N1 2NA. Your privacy is of paramount importance — we respect your privacy and are committed to protecting it through our compliance with this policy.

We are a data controller for the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. You can contact us at info@fourkey.co.uk or 020 8050 4444.

This Privacy Policy is incorporated by reference into the Terms of Use. It explains our online and offline information practices, the kind of information we may collect, how we intend to use and share that information, and how you can opt out of a use or correct or change such information. All capitalised terms not defined herein will have the meanings set forth in the Terms.

Please take a moment to review this Privacy Policy, which governs the use of the Four Key Asset and Block Management Limited website. By using our website, you agree to our Terms and Conditions and this Privacy Policy.

If you do not agree with the terms of this Privacy Policy, please do not use this website.

This Privacy Policy applies to Personal Information that is collected and processed by us in the course of our business, including on our website ("Website"), web applications ("App"), forums, blogs, and other online or offline offerings (collectively, the "Services"). Anytime we use the word Website, it is deemed to include our App as well. All individuals whose responsibilities include the processing of personal information on behalf of the Company are expected to protect that data by adherence to this Privacy Policy.

Children Under the Age of 18

Our Website is not intended for children under 18 years of age. No one under age 18 may provide any information to us or access the Website. We do not knowingly collect personal information from children under 18. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete and anonymise that information and terminate the user account. If you believe we might have any information from or about a child under 18, please contact us at info@fourkey.co.uk.

Some of the ways that the Company may collect personal information include:

• You may provide personal information directly to the Company through registering on our Website, when you use the features on our Website, during the course of providing Services to you, interacting with the Services, participating in surveys, and requesting Services or information.
• As you navigate the Services, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below.

We endeavour to collect only that information which is relevant for the purposes of providing the Services to you.

3.1 Types of Personal Information We Collect

Company collects Personal Information regarding its current, prospective, and former clients, customers, users, visitors, and guests (collectively "Individuals").

Information You Provide Directly to Us. When you use the Services or engage in certain activities, we may ask you to provide some or all of the following:

• First and last name; birth date/age; gender
• Identification documents (Passport and/or Driving Licence)
• Bank account details; tenancy information
• Employment and income information; credit and referencing information
• Emergency contact details; property ownership information
• National Insurance Number (NIN)
• Race or colour; ancestry or national origin; religion or creed; mental or physical disability; sexual orientation; marital status; military and veteran status
• Address (including country and postal code); phone number; email address; title and department; company name
• Login ID and password; shipping information
• Technical information; your pictures or videos
• Records of interaction with Company representatives
• Usage details such as time, frequency, duration and pattern of use, features used, and amount of storage used
• Internet Protocol address, browser type and version, operating system, and other visitor details
• Browser history, search history, information on interaction with a website, application, or advertisement
• Any other information that is willingly shared by you

(collectively referred to as "Personal Information").

Communications with Us. We may collect personal information such as email address, phone number, or mailing address when you choose to request information about our Services, register for our newsletter, or otherwise communicate with us.

Surveys. From time to time we may contact you to participate in online surveys. All information collected from your participation is provided by you voluntarily.

Automatic Data Collection. We may collect certain information automatically through our Services, such as your Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, browser type and language, geo-location information, hardware type, operating system, and pages that you visit before and after using the Services.

Cookies. We use cookies and web beacons to collect information. Cookies are small text files placed in visitors' device browsers to store their preferences. Web beacons are electronic images that may be used in our Services or emails to help deliver cookies, count visits, and understand usage. See section 3.2 below for further detail.

Information Submitted Via Services. You agree that Company is free to use the content of any communications submitted by you via the Services, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or Services.

Information from Other Sources. We may receive information, including Personal Information about you from other sources, including through third-party services and organisations, to supplement information provided by you.

3.2 How Company Uses Your Information

We acquire, hold, use, and process personal information about Individuals for a variety of business purposes, including:

To Provide Products, Services, or Information Requested. Your Personal Information may be used to:

• Operate and improve the Website
• Provide technical support, including diagnosing and resolving issues you report
• Provide effective Services; perform customer relationship management
• Conduct studies, research, and analysis for improving our information, services, and technologies
• Contact you via phone, SMS, WhatsApp, email for appointments, technical issues, payment reminders, and administrative purposes
• Send promotional mailings from us or any of our partners
• Advertise products and services of the Company and third parties
• Administer or otherwise carry out our obligations in relation to any agreement you have with us
• Maintain and develop our business systems, including testing and upgrading
• Respond to subpoenas, court orders, or legal process
• Investigate, prevent, or take action regarding illegal activities or suspected fraud
• Aggregate Personal Information for research and statistical analysis
• Manage Individual information and accounts
• Process and verify payments; respond to questions, comments, and other requests
• Allow you to register for events

Administrative Purposes. Including to measure interest in our Services, develop new products, ensure internal quality control, verify Individual identity, and process payments.

Marketing Company Products and Services. Company may use personal information to provide you with materials about offers, products, and services that may be of interest, by phone, postal mail, facsimile, or email, as permitted by applicable law. You may contact us at any time to opt out.

Research and Development. Company may use personal information, alone or in aggregate, in order to optimally deliver our existing products and Services or develop new ones.

Direct Mail, Email and Outbound Telemarketing. Individuals who provide us with personal information may receive periodic emails, newsletters, mailings, or phone calls with information on our or our partners' products and services. We offer the option to decline these communications by following the instructions in Section 5.

De-Identified and Aggregated Information Use. Company may use personal information to create de-identified and/or aggregated information for research, internal analysis, analytics, and other legally permissible purposes.

Uses of Automatic Collection Technologies. Our use of technologies falls into the following categories: Operationally Necessary; Performance Related; Functionality Related; and Advertising or Targeting Related. If you would like to opt out of the technologies we employ, you may do so by blocking, deleting, or disabling them as your browser or device permits.

3.3 Third-Party Websites and Social Media Platforms

If you log in to our Services using your social media account, we will receive relevant information necessary to enable our Services and authenticate you. The Services may also contain links and interactive features with various social media platforms. We are unable to control uses of your information when you interact with a social media platform, and by using such services you assume the risk that your personal information provided may be viewed and used by third parties.

3.4 Third-Party Payment Processing

If you use the Services to make, receive, or facilitate payments, we and Third-Party applications may collect certain financial information from you to process transactions, including your name, email address, financial account information, and other billing information.

3.5 Incomplete Personal Information

Where indicated, it is obligatory to provide your personal information to us to enable us to process your application for our Products and/or Services. Should you decline to provide such obligatory personal information, we may not be able to process your application or provide you with our Products and/or Services.

3.6 Sources of Collection of Personal Information

We collect Personal Information from the following categories of sources: you/your devices directly; other users of our Services; visits to our offices; affiliates; government entities; consumer data resellers; business partners; and publicly accessible sources.

4.1 Information We Share

We do not sell your personal data. We may share your information as described in this Privacy Policy (e.g., with our third-party service providers; to comply with legal obligations; to protect and defend our rights and property) or with your permission.

• Vendors and Service Providers. We may share any information we receive with vendors and service providers including for: (i) provision of IT and related services who host, maintain and support our website, applications and business systems (including Cloudinary, Vercel, and Resend); (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Services.
• Business Partners. Company may share personal information with our business partners, and affiliates for our internal business purposes or to provide you with a product or service that you have requested. Company requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of personal information they maintain on our behalf.
• Professional advisers, including solicitors, accountants, auditors, and insurers where necessary for the operation of our business.
• Content Visible to Others. When you create a profile or post content to the Services, this information may be displayed to others.
• Marketing — Interest-Based Advertising and Third-Party Marketing. Through our Services, Company may allow third-party advertising partners to set tracking tools to collect information regarding your activities. If you prefer that we do not share your personal information with third-party advertising partners, you may opt out by following the instructions in Section 5.
• Disclosures to Protect Us or Others. We may access, preserve, and disclose your personal information if we believe doing so is required or appropriate to comply with law enforcement requests and legal process, protect rights and property, enforce Company policies, collect amounts owed, or prevent physical harm or financial loss.
• Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, reorganisation, bankruptcy, or sale of company assets, your information may be transferred as part of such a transaction.

4.2 International Data Transfers

We primarily process personal data within the United Kingdom. However, some of our third-party service providers may process or store personal data outside the United Kingdom. Where personal data is transferred outside the UK, we will ensure that such transfers are carried out in accordance with the UK GDPR and the Data Protection Act 2018, including through appropriate safeguards such as the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the European Commission's Standard Contractual Clauses.

We will implement appropriate technical and organisational measures to protect your data. Unfortunately, the transmission of information via the internet is not completely secure. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

5.1 General

You may have the right to object to and opt out of certain uses and disclosures of your Personal Information. Where you have consented to Company's processing of your Personal Information, you may withdraw that consent at any time by contacting us at info@fourkey.co.uk. Please note that withdrawal of consent does not affect the lawfulness of processing activities based on consent before its withdrawal.

5.2 Email and Telephone Communications

If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain non-promotional communications regarding Company and our Services and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms or this Privacy Policy).

5.3 Turning Off Cookies

You can erase or choose to block cookies from your computer except for functional cookies that are strictly necessary to make our Website available to you. You can configure your computer's browser to alert you when we attempt to send you a cookie with an option to accept or refuse the cookie. Please note that if you have turned cookies off, you may be prevented from using certain features of the Website.

Please be assured that we do not ever "sell" your Personal Information.

In accordance with applicable law, you may have the right to, once a year, free of charge:

• Request confirmation of whether we are processing your Personal Information
• Obtain access to or a copy of your Personal Information
• Receive an electronic copy of Personal Information that you have provided to us, or ask us to send that information to another company (the "right of data portability")
• Restrict our uses of your Personal Information
• Seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed Personal Information
• Withdraw your consent
• Request erasure of Personal Information held about you by us, subject to certain exceptions prescribed by law

Please include your full name, email address associated with your account, and a detailed description of your data request. To protect your privacy, Company will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.

Company retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defences, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

When determining the specific retention period, we take into account various criteria, such as the type of service provided to you, the nature and length of our relationship with you, and mandatory retention periods provided by law and the relevant statute of limitations. At the end of that retention period, your data will either be deleted completely or anonymised.

The security of your Personal Information is important to us. We have adopted reasonable security practices and procedures including role-based access, password protection, and encryption to ensure that the Personal Information collected is secure. We restrict access to your Personal Information to our employees, agents, third party service providers, partners, and agencies who need to know such Personal Information in relation to the Purposes specified in this Policy.

Despite our efforts and diligence, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.

9.1 Complaints

If you have any questions about our privacy practices or this Privacy Policy, or if you need to update or correct your Personal Information, please contact us at info@fourkey.co.uk and we will take all reasonable efforts to incorporate the changes within a reasonable period of time.

9.2 Grievance Officer

We have appointed a Grievance Officer to address any concerns or grievances that you may have regarding the processing of your Personal Information. Please write to our Grievance Officer at info@fourkey.co.uk and our officer will attempt to resolve your issues in a timely manner.

9.3 Information Commissioner's Office

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk or by calling 0303 123 1113.

We reserve the right, at any time, to modify this Privacy Policy. We will post a notification on our Website every time the Privacy Policy is changed. Each version of this Privacy Policy will be identified at the top of the page by its effective date. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you use the Services after the updated Privacy Policy is posted.

By providing us your Personal Information or by making use of the facilities or Services provided by the Website, you hereby consent to the collection, storage, processing, disclosure, and transfer of your Personal Information in accordance with the provisions of this Privacy Policy.

You acknowledge that you are providing your Personal Information out of your free will. You have the option not to provide us the Personal Information sought to be collected. You will also have an option to withdraw your consent at any point, provided such withdrawal of consent is intimated to us in writing. If you do not provide us your Personal Information or if you withdraw consent, we may restrict you from using the Website or Services.

We may update this privacy policy from time to time. The current version will always be available on this page. Continued use of the website after any changes constitutes your acceptance of the updated policy.