Our Privacy Policy

Key Wellspring cares about your privacy. For this reason, we collect and use  personal information only as needed to deliver our products, services,  websites and mobile applications, and to communicate with you about the  same, or as you have requested (collectively, our “Services”). Your  personal information includes information such as:

  • Name
  • Address
  • Telephone number
  • Date of birth
  • Email address
  • Billing and payment information
  • Candidate information (for job applicants)
  • Other data collected that could directly or indirectly identify you.

Our Privacy Policy not only explains how and why we use your personal  information that we collect, but also how you can access, update or  otherwise take control of your personal information.  

If at any time you have questions about our practices or any of your  rights described below, you may reach our Data Protection Officer  (“DPO”)  by contacting  us at key wellspring.com. This inbox is actively monitored and managed  so that we can deliver an experience that you can confidently trust.

What information we collect, how we collect it, and why  

Much of what you likely consider personal information is collected directly from you when you:

  1. Purchase any of our Services (ex: billing  information, including name, address, credit card number, government  identification);
  2. request assistance from our customer support team (ex: phone number);
  3. complete contact forms or request newsletters or other information from us (ex: email); or
  4. participate in contests and surveys, apply for a job, or otherwise  participate in activities we promote that might require information  about you.

However, we also collect additional information when delivering our  Services to you to ensure necessary and optimal performance. These  methods of collection may not be as obvious to you, so we thought we’d  highlight and explain a bit more about what these might be (as they vary  from time to time):

Cookies and similar technologies on our websites  and our mobile applications allow us to track your browsing behavior,  links clicked, items purchased, your device type, and to collect various  data, including analytics, about how you use and interact with our  Services. These technologies automatically collect data when you use and  interact with our Services, including metadata, log files,  cookie/device IDs, page load time, server response time, and approximate  location information to measure website performance and improve our  systems, including optimizing DNS resolution, network routing and server  configurations. Specifically, interactions with the features, content  and links (including those of third-parties, such as social media  plugins) contained within the Services, Internet Protocol (IP) address,  browser type and settings, the date and time the Services were used,  information about browser configuration and plugins, language  preferences and cookie data, information about devices accessing the  Services, including type of device, what operating system is used,  device settings, application IDs, unique device identifiers and error  data is collected. All this allows us to provide you with more relevant  product offerings, a better experience on our sites and mobile  applications, and to collect, analyze and improve the performance of our  Services. We may also collect your location (IP address) so that we can  personalize our Services. For additional information, and to learn how  to manage the technologies we utilize, please visit our Cookie Policy. If you wish to opt out of interest-based advertising click here [or if located in the European Union click here]. Please note you will continue to receive generic ads.

Supplemented Data may be received about you from  other sources, including publicly available databases or third parties  from whom we have purchased data, in which case we may combine this data  with information we already have about you so that we can update,  expand and analyze the accuracy of our records, assess the  qualifications of a candidate for employment, identify new customers,  and provide products and services that may be of interest to you. If you  provide us personal information about others, or if others give us your  information, we will only use that information for the specific reason  for which it was provided to us.

How we utilize information.  

We strongly believe in both minimizing the data we collect and  limiting its use and purpose to only that (1) for which we have been  given permission, (2) as necessary to deliver the Services you purchase  or interact with, or (3) as we might be required or permitted for legal  compliance or other lawful purposes:

Delivering, improving, updating and enhancing our Services. We collect various information relating to your purchase, use and/or  interactions with our Services. We utilize this information to:

  • Improve and optimize the operation and performance of our Services (again, including our websites and mobile applications)
  • Diagnose problems with and identify any security risks, errors, or needed enhancements to the Services
  • Detect and prevent fraud and abuse of our Services and systems
  • Collecting aggregate statistics about use of the Services
  • Understand and analyze how you use our Services and what products and services are most relevant to you.

Much of the data collected is aggregated or statistical data about  how individuals use our Services, and is not linked to any personal  information.   

Sharing with trusted third parties. We  may share your personal information with affiliated companies within our  corporate family, with third parties with which we have partnered to  allow you to integrate their services into our own Services, and with  trusted third party service providers as necessary for them to perform  services on our behalf, such as:

  • Processing credit card payments
  • Serving advertisements
  • Conducting contests or surveys
  • Performing analysis of our Services and customers demographics
  • Communicating with you, such as by way email or survey delivery
  • Customer relationship management
  • Recruiting support and related services.

We only share your personal information as necessary for any third  party to provide the services as requested or as needed on our behalf.  These third parties (and any subcontractors they may be permitted to  use) are subject to strict data processing terms and conditions and are  prohibited from utilizing, sharing or retaining your personal  information for any purpose other than as they have been specifically  contracted for (or without your consent).

We may also share your information with third parties for the purpose  of facilitating / allowing a merger, acquisition or sale of all or  substantially all of our assets, in which case the acquiring company may  continue to utilize your data in the manner for which it was provided  and intended.

Communicating with you. We may contact  you directly or through a third party service provider regarding  products or services you have signed up or purchased from us, such as  necessary to deliver transactional or service related communications. We  may also contact you with offers for additional services we think  you’ll find valuable if you give us consent, or where allowed based upon  legitimate interests. You don’t need to provide consent as a condition  to purchase our goods or services. These contacts may include:

  • Email
  • Text (SMS) messages
  • Telephone calls
  • Messenger applications (e.g. WhatsApp, etc.)
  • Automated phone calls or text messages.

You may also update your subscription preferences with respect to  receiving communications from us and/or our partners by signing into  your account and visiting “Account Settings” page.

If we collect information from you in connection with a co-branded  offer, it will be clear at the point of collection who is collecting the  information and whose privacy policy applies. In addition, it will  describe any choice options you have in regards to the use and/or  sharing of your personal information with a co-branded partner, as well  as how to exercise those options. We are not responsible for the privacy  practices or the content of third-party sites. Please read the privacy  policy of any website you visit.

If you make use of a service that allows you to import contacts  (ex. using email marketing services to send emails on your behalf), we  will only use the contacts and any other personal information for the  requested service. If you believe that anyone has provided us with your  personal information and you would like to request that it be removed  from our database, please contact us at keywellspring.com.

Transfer of personal information abroad. If you  utilize our Services from a country other than the country where our  servers are located, your personal information may be transferred across  international borders. Also, when you call us or initiate a chat, we  may provide you with support from one of our global locations outside  your country of origin. 

Compliance with legal, regulatory and law enforcement requests. We cooperate with government and law enforcement officials and private  parties to enforce and comply with the law. We will disclose any  information about you to government or law enforcement officials or  private parties as we, in our sole discretion, believe necessary or  appropriate to respond to claims and legal process (such as subpoena  requests), to protect our property and rights or the property and rights  of a third party, to protect the safety of the public or any person, or  to prevent or stop activity we consider to be illegal or unethical.

To the extent we are legally permitted to do so, we will take  reasonable steps to notify you in the event that we are required to  provide your personal information to third parties as part of legal  process. We will also share your information to the extent necessary to  comply with British Law, rules, regulations and policies.. 

How we secure, store and retain your data.  

We follow generally accepted standards to store and  protect the personal information we collect, both during transmission  and once received and stored, including utilization of encryption where  appropriate.

We retain personal information only for as long as necessary to  provide the Services you have requested and thereafter for a variety of  legitimate legal or business purposes. These might include retention  periods:

  • mandated by law, contract or similar obligations applicable to our business operations;
  • for preserving, resolving, defending or enforcing our legal/contractual rights; or
  • needed to maintain adequate and accurate business and financial records.

If you have any questions about the security or retention of your personal information, you can contact us at keywellspring.com

If you make a request to delete your personal information and that  data is necessary for the products or services you have purchased, the  request will be honored only to the extent it is no longer necessary for  any Services purchased or required for our legitimate business purposes  or legal or contractual record keeping requirements.

Please “Contact Us” for any further questions you may have.