Privacy Policy

We believe in openness and privacy. Four Key Asset and Block Management Limited ("Company", "we", "us" or "our") is a company registered in England and Wales with its registered office at 105 St Paul's Road, Highbury, London N1 2NA. Your privacy is of paramount importance to us, and we are committed to protecting your personal information and processing it fairly, lawfully and transparently in accordance with applicable data protection law.

We are a data controller for the purposes of the UK General Data Protection Regulation ("UK GDPR"), the Data Protection Act 2018 and, where applicable, the Privacy and Electronic Communications (EC Directive) Regulations 2003 ("PECR"). 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. This Privacy Policy 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 capitalized 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 the Four Key Asset and Block Management Limited Terms and Conditions, including definitions, 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 by, processed by us in the course of our business, including on our website, https://www.fourkey.co.uk ("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. This Privacy Policy is intended to meet requirements globally.

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 you are under 18, do not use or provide any information on this Website or through any of its features or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete, anonymize 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 by us, interacting with the Services, participating in surveys, and requesting Services, or information and when you provide your personal information to us.
• 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 endeavor to collect only that information which is relevant for the purposes of providing the Services to you. Below are the ways we collect personal information and how we use it.

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").

In connection with our property and block management activities, the Individuals whose Personal Information we may collect and process include leaseholders, freeholders, landlords, tenants, residents, occupiers, directors and officers of resident management companies (RMCs), right to manage companies (RTMs) and freehold companies, prospective clients, contractors, suppliers, professional advisers, visitors to properties under our management and other individuals who communicate or otherwise deal with us.

Information You Provide Directly to Us. When you use the Services or engage in certain activities, such as registering for an account with Company on our Website, responding to surveys, requesting Services or information, or contacting us directly, we may ask you to provide some or all of the following types of information:

• First and last name,
• Birth date/age,
• Gender,
• Identification documents (Passport and/or Driving License),
• 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,
• If you have biometric authentication integration as part of the Services, then we may collect information concerning Your fingerprints, faceprints, and voiceprints, and iris or retina scans,
• Address (including country and pin/postal code),
• Phone number/mobile number,
• Email address,
• Title and department,
• Company name,
• Military and veteran status,
• Information provided on your resume, such as your education and employment experience, if you apply through LinkedIn, then we collect information you made available to us on LinkedIn,
• Technical information,
• Your pictures or videos that you may provide,
• Professional contact details of employees and other individuals associate with our business,
• Login ID and password,
• Shipping information,
• User details as provided at the time of registration or thereafter,
• Records of interaction with the Company representatives,
• Your usage details such as time, frequency, duration and pattern of use, features used and the amount of storage used,
• Master and transaction data and other data stored in Your user account,
• Internet Protocol address, browser type and version, browser language, referring URL, files accessed, errors generated, time zone, operating system and platform and other visitor details collected in Our log files,
• Browser history, search history, information on a consumer's 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 from you such as email address, phone number or mailing address, your picture or videos that you may provide, when you choose to request information about our Services, register for Company's newsletter, request to receive customer or technical support, or otherwise communicate with us.

Surveys. From time to time, we may contact you to participate in online surveys. If you do decide to participate, you may be asked to provide certain information which may include Personal Information. All information collected from your participation in our surveys is provided by you voluntarily. We may use such information to improve our products, Sites and/or services and in any manner consistent with the policies provided herein.

Posting on the Services. Company may offer publicly accessible pages, blogs, private messages, or community forums. You should be aware that, when you disclose information about yourself in on Company's pages, blogs, private messages, and community forums, the Services will collect the information you provide in such submissions, including any personal information. If you choose to submit content to any public area of the Services, such content will be considered "public" and will not be subject to the privacy protections set forth herein.

Automatic Data Collection. We may collect certain information automatically through our Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences.

Cookies. We use different technologies to collect information, including cookies and web beacons. Cookies are small text files placed in visitors' device browsers to store their preferences that can be recalled by a web server in the domain that placed the cookie. Whereas, web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. When you use our Website, we may automatically collect information about your visit, including via cookies, beacons, invisible tags, and similar technologies (collectively, "cookies") in your browser and on emails sent to you. This information may include Personal Information, such as your IP address, web browser, device type, and the web pages that you visit just before or just after you use the Website, as well as information about your interactions with the Websites, such as the date and time of your visit, and where you have clicked. Metrics collected by automated means may include: number of users; daily/weekly/monthly active users; rebuild frequency; rebuild time; image update frequency; editor usage split by editor type; web terminal, coder-cli, and SSH usage; metrics page and filter usage; services usage; devurl usage patterns; and resource allocation. Paid users may opt in to the collection of this information to enhance product performance but are otherwise opted out by default. Free users are automatically opted in to the collection of this information and they do not have an opt out option. In the event a free user converts to a paid subscription, they will be given the option to opt out. This information is only used for product development and enhancement. You can find more information about how we use cookies in the section 3.2 below.

• 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. Company will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so or it is otherwise necessary as part of the Services, such as to facilitate payment to you as a Pentester; (b) we first send notice to you that the materials or other information you submit to a particular part of a Service will be published or otherwise used with your name on it; or (c) we are required to do so by law.
• Information from Other Sources. We may receive information, including Personal Information about you from other sources, including through third-party services and organizations to supplement information provided by you. For example, if you access or use our Services through a third-party application, we may collect information about you from that third-party application that is public via your privacy settings or is otherwise available. This supplemental information allows us to verify information that you have provided to Company and to enhance our ability to provide you with information about our business, products, and Services. If you authorize us to collect information from a third party, or if you authorize a third party to send us information, and you later decide that you no longer want us to obtain that information, you may need to contact the third party source directly and request that they stop transmitting information to us.

3.2 Property and Block Management Information

In addition to the categories of Personal Information listed above, we may collect and process information relating to a property and its management, including property addresses and unit numbers; ownership and occupancy details; lease, tenancy and licence information; service charge, ground rent and reserve fund information; payment and account history; correspondence, enquiries and complaints; maintenance and repair records; arrears and disputes; insurance claims; major works and Section 20 consultation records; contractor and access information; keys, fobs, entry-system and access-control records; CCTV images where applicable; parking information; and health and safety, fire safety, building safety and emergency-management information.

3.3 Lawful Bases for Processing

We will only process Personal Information where we have a lawful basis under applicable data protection law. Depending on the circumstances, we may rely on: (a) performance of a contract or taking steps at your request before entering into a contract; (b) compliance with a legal obligation; (c) our legitimate interests or those of a third party, provided those interests are not overridden by your rights and interests; (d) your consent, where consent is required; or (e) protection of vital interests in an emergency.

Our legitimate interests may include the effective administration and management of properties; communicating with clients, residents and other relevant parties; maintaining accurate property and accounting records; protecting managed properties and our business; preventing fraud; handling complaints and disputes; establishing, exercising or defending legal claims; and operating and improving our business and systems.

3.3 (A) Accuracy of Your Personal Information

It is important that the Personal Information we hold about you is accurate and current. Please notify us if your Personal Information changes during your relationship with us so that we can keep our records accurate and up to date.

3.4 Property Management Purposes

We may use Personal Information to provide block, estate and asset management services; administer service charges, budgets and reserve funds; issue demands, statements and other property-management communications; arrange repairs, inspections, maintenance, contractor access, quotations and major works; conduct consultations including Section 20 consultations where applicable; manage insurance, claims and reinstatement works; investigate leaks, defects, nuisance and anti-social behaviour; administer health and safety, fire safety and building-safety obligations; manage parking and other communal facilities; respond to emergencies; instruct and liaise with professional advisers and service providers; deal with assignments, transfers, remortgages, notices, certificates and property enquiries including LPE1 or similar enquiries; recover arrears and other sums due; comply with court orders, statutory duties and regulatory requirements; and maintain appropriate records relating to the properties we manage.

The table below summarises the principal ways in which Four Key may use Personal Information in connection with its property and block management activities. The lawful basis that applies will depend on the circumstances and the relationship between Four Key, its client and the individual concerned.

3.5 CCTV, Access Control and Building Security

Where CCTV, door-entry, intercom, key-fob, access-control or similar security systems are used at a property managed by us, Personal Information such as images, access records or identification details may be processed for the purposes of protecting residents, visitors and property; preventing and investigating crime or unauthorised access; responding to incidents; and supporting the safe and effective management of the building.

The lawful basis will ordinarily be our legitimate interests and, where applicable, compliance with legal obligations. CCTV and access information will only be retained for as long as reasonably necessary for the relevant purpose, subject to any legal, insurance or evidential requirements.

3.6 Special Category and Criminal Offence Data

We do not seek to collect special category or criminal offence data unless it is necessary and lawful to do so. We may, for example, need limited health or disability information to make reasonable adjustments, respond to emergencies or address accessibility and safety requirements.

Where we process special category or criminal offence data, we will identify an appropriate condition under applicable data protection law in addition to a lawful basis under Article 6 UK GDPR.

3.7 Anti-Money Laundering, Identity and Due-Diligence Checks

Where applicable to the services we provide or where required by law, regulation, a client, insurer, bank or professional adviser, we may process identification, proof-of-address, ownership and related due-diligence information to verify identity, prevent fraud, carry out sanctions or anti-money-laundering checks and satisfy legal or regulatory requirements.

The lawful basis will depend on the circumstances and may include compliance with a legal obligation and/or our legitimate interests in protecting our business, clients and managed properties.

3.8 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 for various purposes including but not limited to the following:

• To operate and improve the Website;
• To provide technical support, including diagnosing and resolving any issues you report;
• To provide effective Services;
• For customer relationship management purposes;
• To perform studies, research and analysis for improving Our information, analysis, services and technologies; and ensuring that the content and advertising displayed are customized to Your interests and preferences;
• To contact You via phone, sms, whatsapp, email, etc. for appointments, technical issues, payment reminders, administrative purposes such as to manage your account, to provide information that you request and other security announcements;
• To send promotional mailings from Us or any of Our partners via sms, whatsapp, email or snail mail;
• To advertise products and Services of the Company and third parties;
• To transfer information about You if we are acquired by or merged with another company;
• To share with our business partners for provision of specific services you have ordered so as to enable them to provide effective services to You;
• To administer or otherwise carry out Our obligations in relation to any agreement You have with us;
• To build your profile on the Website;
• To maintain and develop our business systems, including testing and upgrading of these systems;
• To manage staff training and quality assurance;
• To respond to subpoenas, court orders, or legal process, or to establish or exercise Our legal rights or defend against legal claims, including but not limited to intellectual property infringements, defamation, or privacy rights;
• To investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our Terms of Use, breach of Our agreement with you or as otherwise required by law;
• To aggregate Personal Information for research, statistical analysis and business intelligence purposes, and to sell or otherwise transfer such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates;
• Generally, manage Individual information and accounts;
• To administer fees and provide You with invoices or resolve billing issues. We may use your information to verify your identity in order to process your payments;
• Respond to questions, comments, and other requests;
• To assess vulnerabilities and other bugs you discover in the course of your use of the Services;
• Provide access to certain areas, functionalities, and features of Company's Services;
• Contact you to answer requests for customer support or technical support; and
• Allow you to register for events.

(referred to as "Purpose(s)")

Administrative Purposes. Company may use personal information about you for its administrative purposes, including to:

• Measure interest in Company's Services;
• Develop new products and Services;
• Ensure internal quality control;
• Verify Individual identity;
• Communicate about Individual accounts and activities on Company's Services and systems, and, in Company's discretion, changes to any Company policy;
• Send email to the email address you provide to us to verify your account and for informational and operational purposes, such as Account management, customer service, or system maintenance;
• Process payment for products or services purchased;
• Process applications and transactions;
• Prevent potentially prohibited or illegal activities;
• Enforce our Terms.

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, including new content or Services. Company may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:

• To tailor content, advertisements, and offers;
• To notify you about offers, products, and services that may be of interest to you;
• To provide Services to you and our sponsors;
• For other purposes disclosed at the time that Individuals provide personal information; or
• Otherwise with your consent.

You may contact us at any time to opt-out of the use of your personal information for marketing purposes, as further described in Section 5 below.

• Research and Development. Company may use personal information alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services.
• Direct Mail, Email and Outbound Telemarketing. Individuals who provide us with personal information, or whose personal information we obtain from third parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on Company's or our business partners' products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions in Section 5 below.
• Services via Mobile Devices. From time to time, Company may provide Services that are specifically designed to be compatible and used on mobile devices. Company will collect certain information that your mobile device sends when you use such Services, like a device identifier, user settings, location information, mobile carrier, and the operating system of your device. Mobile versions of Company's Services may require that users log in with an account. In such cases, information about use of mobile versions of the Services may be associated with accounts. In addition, Company may enable Individuals to download an application, widget, or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools may transmit personal information to Company to enable Individuals to access accounts and to enable Company to track use of these tools. Some of these tools may enable users to email reports and other information from the tool. Company may use personal or non-identifiable information transmitted to Company to enhance these tools, to develop new tools, for quality improvement and as otherwise described in this Privacy Policy or in other notices Company provides.
• De-Identified and Aggregated Information Use. Company may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access Company's Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors' interest in and use of various portions or features of the Services. De-identified and/or aggregated information is not personal information, and Company may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Company and with third parties for our or their purposes in an de-identified and/or aggregated form that is designed to prevent anyone from identifying you.
• Sharing Content with Friends or Colleagues. Company's Services may offer various tools and functionalities to share content. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request but will not be collected or otherwise used by Company or any other third parties for any other purpose.
• Other Uses. Company may use Personal Information for which we have a legitimate interest, such as network and information security, direct marketing, disclosure to affiliated organizations, research (including marketing research), fraud prevention, or any other purpose disclosed to you at the time you provide personal information or with your consent.

Uses of Automatic Collection Technologies. Our use of the Technologies fall into the following general categories:

• Operationally Necessary. We may use cookies, web beacons, or other similar technologies that are necessary to the operation of our sites, services, applications, and tools. This includes technologies that allow you access to our sites, services, applications, and tools; that are required to identify irregular site behavior, prevent fraudulent activity and improve security; or that allow you to make use of our functions such as shopping-carts, saved search, or similar functions;
• Performance Related. We may use cookies, web beacons, or other similar technologies to assess the performance of our websites, applications, services, and tools, including as part of our analytic practices to help us understand how our visitors use our websites, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our website content, applications, services, or tools;
• Functionality Related. We may use cookies, web beacons, or other similar technologies that allow us to offer you enhanced functionality when accessing or using our sites, services, applications, or tools. This may include identifying you when you sign into our sites or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our sites;
• Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our sites or on third party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.

If you would like to opt-out of the Technologies we employ on our Services, you may do so by blocking, deleting, or disabling them as your browser or device permits.

3.8 (A) Website Analytics and Security Technologies

We may use third-party analytics services, such as Google Analytics, to help us understand how visitors use our Website. These services may process information including your IP address, device and browser information, pages visited, interactions with the Website and the date and time of visits. Where analytics cookies or similar technologies require consent, they will only be activated after the required consent has been obtained. Further information will be provided in our Cookie Policy.

Our Website may also use Google reCAPTCHA or similar security technologies to help protect online forms and the Website against spam, fraud and abuse. Where such technology is used, certain technical and usage information may be processed by the relevant provider in accordance with its privacy terms. This paragraph applies only where the relevant technology is deployed on the live Four Key Website.

3.9 Third-Party Websites and Social Media Platforms

If you log in to our Services using your social media account (for example, Facebook or Google) we will receive relevant information that is necessary to enable our Services and authenticate you. The social media network will provide us with access to certain information that you have provided to them, including your name, profile image and e-mail address. We use such information, together with any other information you directly provide to us when registering or using our Services, to create your account and to communicate with you about the information, products and services that you request from us. You may also be able to specifically request that we have access to the contacts in your social media account so that you can send a referral link to your family and friends. We will use, disclose and store all of this information in accordance with this Privacy Policy. The Services may contain links to other websites and other websites may reference or link to our Services. These other domains and websites are not controlled by us, and Company does not endorse or make any representations about third-party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

Company's Services may include publicly accessible blogs, community forums, or private messaging features. The Services may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our Site or other Services. You should be aware that personal information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the personal information provided by you may be viewed and used by third parties for any number of purposes.

3.10 Third-Party Payment Processing

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

3.11 Incomplete Personal Information

Where indicated (for example in registration/application forms), 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.

3.12 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;
• Visit our offices;
• Affiliates;
• Government entities;
• Consumer data resellers;
• Business partners;
• 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.

4.1 (A) Property-Management Recipients

In connection with our property and block management activities, and where lawful and necessary, we may disclose Personal Information to the following categories of recipient. We seek to limit disclosure to the information reasonably necessary for the relevant purpose.

• We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers (processors) to whom we entrust personal information include service providers for: (i) provision of IT and related services who host, maintain and support our website, applications and business systems (including Cloudinary and Vercel); (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. Company has executed appropriate contracts with the service providers that prohibit them from using or sharing personal information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
• Business Partners. Company may share personal information with our business partners, and affiliates for our and our affiliates' internal business purposes or to provide you with a product or service that you have requested. Company may also provide personal information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner's name will appear, along with Company. 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 and not to use it for any purpose other than the purpose for which Company provided them. Professional advisers, including solicitors, accountants, auditors and insurers where necessary for the operation of our business or to obtain professional advice.
• Content Visible to Others. When you create a Profile or post content to the Services, this information may be displayed to others. We are not responsible for privacy practices of the other users who will view and use the posted information.
• Marketing — Interest-Based Advertising and third-party Marketing. Through our Services, Company may allow third-party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected Personal Information (such as demographic information and past purchase history) we have collected with third-party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-Company related websites within their networks. This practice is commonly referred to as "interest-based advertising" or "personalized advertising." We may allow access to other data collected by the Services to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your personal information with third-party advertising partners, you may opt-out of such sharing at no cost by following the instructions in Section 5 below.
• Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your personal information, other account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours', ours' or others' rights, property, or safety; (iv) to enforce Company policies or contracts; (v) to collect amounts owed to Company; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable. In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
• Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. In such event, Company will endeavor to direct the transferee to use personal information in a manner that is consistent with the Privacy Policy in effect at the time such personal information was collected.

4.2 Use of Artificial Intelligence (AI) Technologies

Four Key Asset and Block Management Limited may use Artificial Intelligence ("AI") and other technology-assisted tools to support and enhance the delivery of our property and block management services. This may include tools that assist with administrative tasks, communications, document management, data analysis, customer and resident enquiries and operational efficiency. Where such tools process Personal Information, this may include information obtained through your communications and interactions with us, our Website or in connection with properties managed by us.

We will only process Personal Information using AI technologies where we have an appropriate lawful basis under applicable data protection law. Depending on the circumstances, this may include:

• Legitimate interests, where the use of AI assists us in operating our business, managing properties, improving our services or increasing operational efficiency and those interests are not overridden by your rights and interests;
• Consent, where consent is required by law, including in relation to certain optional or marketing-related activities; or
• Performance of a contract or compliance with a legal obligation, where the use of AI assists us in providing services we have agreed to provide or in complying with applicable legal or regulatory requirements.

We do not use AI to make solely automated decisions about individuals that produce legal or similarly significant effects without appropriate human involvement, except where such processing is permitted by applicable law. Where AI or automated tools assist our decision-making, we will maintain appropriate human oversight having regard to the nature and significance of the relevant processing.

Personal Information processed through AI technologies will be subject to appropriate technical and organisational safeguards. These may include data minimisation, access controls, security measures and appropriate contractual arrangements with third-party service providers.

We do not use Personal Information relating to our clients, leaseholders, residents or other individuals whose information we process in connection with our property management services to train publicly available AI models. Where we engage third-party providers of AI or technology-assisted services that process Personal Information on our behalf, we will take appropriate steps to ensure that such processing is subject to contractual and data protection requirements in accordance with applicable law.

We are committed to using AI technologies responsibly and transparently. If you have any questions regarding our use of AI in connection with your Personal Information or wish to exercise your data protection rights, please contact us at legal@fourkey.co.uk.

4.3 International Data Transfers

We primarily process personal data within the United Kingdom. However, some of our third-party service providers, including cloud-based software, IT support providers, and other business service providers, may process or store personal data outside the United Kingdom.

Where necessary in connection with the purposes described in this Privacy Policy, Personal Information may be transferred to, stored in, or accessed from countries outside the United Kingdom, including by third-party service providers engaged by Four Key. Where applicable, such transfers will be made in accordance with applicable data protection law and may be carried out on the basis of applicable adequacy regulations, appropriate safeguards, contractual arrangements, statutory exceptions or any other lawful transfer mechanism available from time to time.

Where personal data is transferred outside the UK, we will ensure that such transfers are carried out in accordance with the UK General Data Protection Regulation ("UK GDPR") and the Data Protection Act 2018. This may include transferring personal data to countries that have been recognized by the UK Government as providing an adequate level of protection or implementing appropriate safeguards such as the UK International Data Transfer Agreement (IDTA), the UK Addendum to the European Commission's Standard Contractual Clauses, or other lawful transfer mechanisms.

Where a transfer is not covered by applicable UK adequacy regulations, Four Key may, where required by applicable law and having regard to the circumstances of the relevant transfer, rely upon an appropriate safeguard, applicable exception or other lawful transfer mechanism. Such mechanisms may include the UK International Data Transfer Agreement ("IDTA"), the UK Addendum to the European Commission's Standard Contractual Clauses, or any other mechanism permitted under applicable UK data protection law. Any transfer risk assessment, data protection test, supplementary measure or other step will be undertaken or applied only to the extent required by applicable law in the circumstances of the relevant transfer.

We take reasonable steps to ensure that any recipient of personal data outside the UK provides an adequate level of protection for that data and processes it in accordance with applicable data protection laws.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of a site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

We will implement appropriate technical and organisational measures to protect your data, taking into account the nature, scope, context and purpose of the processing and the risks involved in processing. Unfortunately, the transmission of information via the internet is not completely secure. Although we will seek to protect your personal data, we cannot guarantee the security of your data transmitted to a site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

For further information about any international transfers of your personal data and the safeguards we apply, please contact us using the details set out in this Privacy Policy.

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. However, please note that such withdrawal of your consent does not affect the lawfulness of our processing activities based on consent before its withdrawal. To exercise any of this right, please contact us at legal@fourkey.co.uk.

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). We will also send you technical notices, updates, security alerts, support and administrative messages. Please be aware that you cannot opt out of receiving certain service messages from us, including necessary security alerts and legal notices.

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 and might affect certain functionality on the Website.

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

Subject to applicable data protection law, any applicable exemptions and the circumstances of the relevant processing, you may have the right to: (i) request confirmation as to whether we process your Personal Information and obtain access to it; (ii) request correction of inaccurate or incomplete Personal Information; (iii) request erasure of your Personal Information in certain circumstances; (iv) request restriction of processing in certain circumstances; (v) object to processing based on legitimate interests on grounds relating to your particular situation; (vi) object at any time to the processing of your Personal Information for direct marketing purposes; (vii) receive Personal Information you have provided to us in a structured, commonly used and machine-readable format and, where technically feasible, request its transmission to another controller, where the statutory right to data portability applies; (viii) withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing carried out before withdrawal; and (ix) where applicable, exercise rights in relation to decisions based solely on automated processing, including profiling, which produce legal effects concerning you or similarly significantly affect you.

These rights are not absolute and may be subject to conditions, limitations and exemptions under applicable data protection law.

In some cases, exercising the above rights may not be possible, and there may be circumstances in which Four Key is permitted or required to continue processing your Personal Information notwithstanding the exercise of a particular right, including where such continued processing is permitted or required by applicable law.

You will not ordinarily be required to pay a fee to exercise your data protection rights. However, where permitted by applicable law, Four Key may charge a reasonable fee or refuse to act on a request that is manifestly unfounded or excessive.

We may request such information as is reasonably necessary to verify your identity, clarify the scope of your request and ensure that Personal Information is not disclosed to a person who is not entitled to receive it. We will respond to valid requests within the time periods required by applicable data protection law and may extend such period where permitted by law.

In order to exercise any of the abovementioned rights, please contact us using one of the methods indicated at the beginning of this Privacy Policy.

RIGHT TO OBJECT: You have an absolute right to object at any time to the processing of your Personal Information for direct marketing purposes. Where we rely on legitimate interests for other processing, you may also object on grounds relating to your particular situation. We will consider and respond to any objection in accordance with applicable law.

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 defenses, 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 anonymized, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.

The following table provides an indicative summary of the retention approach for key categories of records. These periods are general guidelines and may be extended or shortened where a different period is required or justified by law, regulation, contract, insurance, litigation or another legitimate requirement.

The security of your Personal Information is important to us. We adopt reasonable and appropriate technical and organizational measures designed to protect Personal Information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Information. Such measures may include, where appropriate, role-based access controls, password protection, encryption, secure systems, staff awareness measures and appropriate contractual arrangements with third-party service providers. Access to Personal Information may be restricted to employees, agents, contractors, professional advisers, service providers and other persons who have a legitimate need to access such information for the purposes described in this Privacy Policy and who are subject to appropriate confidentiality or data protection obligations.

However, no method of transmission over the internet, electronic communication, information system or method of electronic storage can be guaranteed to be completely secure. Accordingly, whilst Four Key takes measures considered appropriate having regard to the nature, scope, context and purposes of the relevant processing and the risks involved, Four Key does not warrant or guarantee the absolute security of Personal Information or that its systems, or those of third-party service providers, will be completely free from unauthorized access, interference, loss, misuse, cyber incidents or other security risks.

To the fullest extent permitted by applicable law, Four Key shall not be responsible for any loss, damage, unauthorized access, disclosure or other consequence arising from circumstances outside its reasonable control, the acts or omissions of third parties, or inaccurate, incomplete, false, misleading or unlawfully provided information supplied by you or on your behalf. Nothing in this Privacy Policy excludes or limits any responsibility or liability which cannot lawfully be excluded or limited under applicable law.

You are responsible for taking reasonable steps to protect any account credentials, passwords, access details or other security information issued to or selected by you and for maintaining the confidentiality of such information. You should not disclose passwords or other confidential access credentials to any unauthorized person. Four Key shall not be responsible, to the extent permitted by applicable law, for consequences arising from your failure to take reasonable precautions to protect such information.

We may communicate with you electronically regarding security, privacy, administrative and service-related matters. Where a personal data breach occurs, Four Key will assess the circumstances and make such notifications to affected individuals, the Information Commissioner's Office or any other competent authority as may be required by applicable law. The method and timing of any notification will be determined having regard to the circumstances and applicable legal requirements.

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 or have any grievance with respect to the processing or use of your Personal Information, for any reason, you may send updates and corrections to us at legal@fourkey.co.uk and we will take all reasonable efforts to incorporate the changes within a reasonable period of time.

9.2 Data Protection Contact

If you have any concern or query regarding the processing of your Personal Information, or wish to exercise a data protection right, please contact our data protection contact at legal@fourkey.co.uk.

9.3 Information Commissioner's Office

You have the right to lodge a complaint with the Information Commissioner's Office ("ICO"), the UK supervisory authority for data protection matters, at ico.org.uk or by calling 0303 123 1113. We would, however, appreciate the opportunity to address your concerns before you approach the ICO. This does not affect your right to contact the ICO at any time.

We keep this Privacy Policy under regular review and may update it from time to time to reflect changes in our processing activities, legal requirements, regulatory guidance, technology or business operations. The current version will be made available on our Website and identified by its effective or last-updated date. Where required by law, or where a change materially affects how we use Personal Information, we will take reasonable steps to bring the change to the attention of affected individuals.

• Revision to the Privacy Policy. We may revise this Privacy Policy in our sole discretion, so review it periodically. If you continue to visit this Site and use the services made available to you after such changes have been made, you hereby provide your consent to the changes.
• Posting of Revised Privacy Policy. If there are any material changes to this Privacy Policy, Company will notify you by email or as otherwise required by applicable law. We will post any adjustments to the Privacy Policy on this web page, and the revised version will be effective immediately when it is posted (or upon notice as applicable). If you are concerned about how your information is used, bookmark this page and read this Privacy Policy periodically.
• New Uses of Personal Information. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt-out. Where consent of the Individual for the processing of Personal Information is otherwise required by law or contract, Company will endeavor to comply with the law or contract.

You should review this Privacy Policy periodically so that you remain informed about our current privacy practices. Where we rely on consent for a particular processing activity, any material change to that activity will be addressed in accordance with the requirements for valid consent under applicable law.

Any interpretation associated with this Privacy Policy will be made by our legal counsel. This Privacy Policy includes examples but is not intended to be restricted in its application to such examples, therefore where the word "including" is used, it means "including without limitations".

• By clicking on the "I accept" button at the end of the page containing the Privacy Policy, Terms of Use or 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 acknowledge that documents & data uploaded by You to get Our services & results from Us is considered to be legally owned or permitted to You. The Company should not be held responsible for damages arising out of such data provided by You.
• You acknowledge that the Company has no obligation to monitor the documents, data, links or other materials that You provide. You are responsible for evaluating all your data including for accuracy, completeness and reliability, and you bear all risk of using such data. The Company will not be responsible for any damages that you may incur as a result of the submission or use of any such data.
• You acknowledge that we test and analyze certain new features with some users before rolling the feature out to all users.
• You acknowledge that links, data, documents or other materials provided by You does not contain illegal or pornographic activities.
• You acknowledge that Our Services is an automated tool, therefore the results will depend on the quality of input given by You. Thus, the Company shall not be held liable for the end result or of the utility of the code/software that is autogenerated from Our platform.
• If you are providing Personal Information on behalf of a third party, then you hereby undertake and confirm that you have the legal authority to do so and to agree to this policy on behalf of such third party. If you are providing Personal Information on behalf of a minor, you hereby confirm that you are the parent or legal guardian of such minor.
• You hereby consent that the collection, storage, processing, disclosure and transfer of any Personal Information shall not cause any wrongful loss to You if it is done in accordance with the provisions of this Privacy Policy.
• 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 the consent is intimated to us in writing. (If you wish to withdraw your consent, please email legal@fourkey.co.uk). If you do not provide us Your Personal Information or if You withdraw the consent to provide us Personal Information at any point in time, We shall have the option not to fulfill the purposes for which the said Personal Information was sought and We may restrict you from using the Website or Services.

Four Key reserves the right to amend, update or replace this Privacy Policy from time to time, including to reflect changes in applicable law, regulatory requirements, our business operations, services or data-processing practices. The current version of this Privacy Policy will be made available on our Website and will take effect from the date specified in the updated Privacy Policy, unless otherwise stated.

Four Key will provide such notice of any amendment, update or change, and obtain any consent, only to the extent required by applicable law. Nothing in this Privacy Policy requires Four Key to provide any additional notice, obtain any additional consent or follow any procedure beyond that required by applicable law.