Webscale Pty Ltd (KeyPay Ltd) EU/UK Privacy Policy and Data Processing Agreement Update
Frequently Asked Questions
At KeyPay your privacy is a top priority, which is why we’re committed to protecting your personal data and keeping it secure. Please find below responses to the most frequently asked questions regarding our recent Privacy Policy updates.
Privacy Policy Updates
Why am I being contacted about the KeyPay EU/UK Privacy Policy?
You are receiving this communication as you are now, or have previously been a customer, user, or contact of KeyPay and have provided us with your personal data. We retain data in accordance with law and our data retention policy. Unless you have exercised your right to have your personal data deleted from our systems, you may still receive notifications about updates to our Privacy Policy.
Why are you updating the Privacy Policy?
We are updating our Privacy Policy to reflect the changes in our business as we further develop our products and have begun offering new services to our customers. To review our updated Privacy Policy, please click here.
What’s changing in KeyPay’s EU/UK Privacy Policy?
The most significant changes to our Privacy Policy are listed below:
- Increased scope of the policy
The update to the Privacy Policy gives clarity on the scope of the policy and gives detail on the coverage of the full suite of our products and services including any new features of our KeyPay Platform, or other service offerings. - Changes to the style and structure of the policy
We have separated many of the categories of the policy into sub-categories to make the policy more user-friendly and show how we handle personal data based on the different services we provide.
(The following sections below have been changed or added as a part of this update)
- What personal information do we collect?
We have included more detail in relation to the types of personal data we may collect when providing our services. This section covers the types of personal data collected so we can provide our products and services, as applicable to you. - How and why do we use this information?
This section provides better clarification on the legal basis on which we might collect personal data from you to provide you with our products and services. This section also covers the purposes for our collection of your personal data. This includes collection of personal data for the purposes of fulfilling our contractual obligations, for our business purposes, collection based on your consent, and to meet legal obligations. - How we share your Personal Data
We have provided more detail on how we share your personal data based on the different products and services we provide, with third parties and across the Employment Hero Group (as KeyPay is an entity belonging to the Employment Hero Group). Specifically, we have updated how we share your personal data when providing our KeyPay Platform and apps, and any related services.
We also cover the adequate transfer mechanisms put in place when transferring personal data out of the EU or UK. This includes the application of the Standard Contractual Clause as agreed to in our Data Processing Agreement. - What rights do you have?
This section outlines your data subject rights. We have clarified your rights to opt-out of receiving marketing communications. - How long will you retain my data?
This section has been updated to address the implementation of the retention periods set out by our internal data retention policy and any applicable laws which govern how long we can retain data.
Will KeyPay share my personal data with third parties?
We share your personal data with third parties only to the extent necessary to provide you with our products and services. Our updated Privacy Policy explains when and why we may share personal data with third parties.
Does KeyPay sell my personal data?
No, we do not sell your personal data to any third parties. Any sharing of personal data with third parties is carried out only for the purposes of operating our business and providing our products and services to our customers. Any sharing of personal data is done securely and in accordance with data protection laws and our Privacy Policy.
When did this change take place?
These changes take place as of 23 December 2022.
Does KeyPay comply with data protection laws?
We take your privacy and protection of personal data seriously and we are committed to complying with the Privacy Laws applicable in the countries within which we operate, including the General Data Protection Regulation ((EU) 2016/679) (EU GDPR) and UK GDPR (as implemented through the Data Protection Act 2018).
Does this Privacy Policy cover GDPR compliance?
Yes. This Privacy Policy is designed to comply with our obligations under the General Data Protection Regulation ((EU) 2016/679) (EU GDPR). We also have a standard Privacy Policy that applies globally.
Is my personal data stored securely at KeyPay?
Data Processing Agreement Updates
Does KeyPay have a Data Processing Agreement in place?
Yes. We recently updated our Data Processing Agreement which covers our processing activities carried out as a data processor on behalf of our customers. Our updated Data Processing Agreement can be found here.
What is a Data Processing Agreement?
A Data Processing Agreement between a data controller (our Customer) and a data processor (KeyPay) which covers the agreed processing and disclosure of personal data carried out for the purpose of providing our products and services to our customers, and other related business purposes.
Why has KeyPay updated its Data Processing Agreement?
Our Data Processing Agreement has been updated to be more user-friendly for those who agree to it and to ensure our compliance with the GDPR as we carry out data processing activities. Our updated Data Processing Agreement also reflects our business changes including our recent acquisition, the provision of additional products and services, and updated features in our KeyPay Platform.
What changes have been made to the Data Processing Agreement?
The Data Processing Agreement has been updated to accurately provide for the current processing activities we carry out when providing our products and services.
- As a business that operates in the UK, this Data Processing Agreement now also applies the UK GDPR with reference to the International Data Transfer Addendum to the EU Standard Contractual Clauses.
- The updated Data Processing Agreement also clearly outlines the roles and obligations of the parties, our methods for changing the Sub-processor list and how you can be notified (we have also included a requirement for Customers to subscribe to receive notifications of updates to the Sub-Processors list), the transfer mechanisms in place for international transfer of personal data, and the obligations that must be met in case of a data breach.
- The schedules to the Data Processing Agreement have been updated with the details of our processing activities in line with the updates to our Privacy Policy.
When will the changes to the Data Processing Agreement apply?
The changes will take effect from 23 December 2022. Your continued use of our services without any objection for 30 days after being notified of the update will constitute your acceptance of the revised Data Processing Agreement.
What if I do not agree with the changes to the Data Processing Agreement?
If you do not agree to the terms of the updated Data Processing Agreement, then you are required to inform us of this within 30 days of being notified of the changes, and you may need to stop using our services. If you continue using our services, then this will constitute acceptance of the terms of the Data Processing Agreement.
What can I do if I have questions about these changes?
If you have any questions or concerns about the changes made to our privacy policy, please reach out to us via email at privacy@keypay.com.