Privacy Policy

LAST UPDATE: [2.12.2020]


Welcome to the Keywee’s (“COMPANY”, “Keywee”, “we”, “our”, and “us”) website (the “Site”). Keywee is a web-based solution to manage paid content distribution and content creation (“Services”).

This Privacy Policy (this “Privacy Policy”) explains what data we collect when you use our Site and/or the Services, why we collect it and how that data is used. It applies to personal data and other information collected by us from or about: (i) visitors to, or users of, our Site, whether accessed via computer, mobile device, or other device (collectively “Device”), (ii) prospective customers, (iii) current customers (“Customers”), and (iv) job applicants. This Privacy Policy also describes how you can reach us to update your personal information, access and control the use of the personal information, or get answers to questions you may have about our privacy practices at this Site. Please read this Privacy Policy carefully, because by accessing and using this Site your are acknowledging that you understand and agree to the terms of this Privacy Policy.

By using the Site and/or the Services, and providing us with your personal data, you consent to the processing of your personal data in the manner set out in this Privacy Policy. Your personal information may be collected, processed, and stored by Keywee or its services providers in the United States and other countries where our services reside. Please be aware that the privacy protections and legal requirements, including the right of authorities to access your personal information, in some of these countries may not be equivalent to those in your country. You hereby agree with and consent to the transfer of your personal data to the United States and other countries where Keywee operates.


When you interact with the Site, we may collect information that, alone or in combination with other information, could be used to identify you (“Personal Data”)

We obtain the categories of personal information listed below from the following categories of sources:

  • Directly from you as described herein;
  • Indirectly from you. For example, through information we collect in the course of providing services and products.
  • Directly and indirectly from activity on this Site.
  • From third-parties that interact with us in connection with the services and products we provide.

Personal Data That You Provide Through the Site:

When you create an account, order products or services, request information, communicate with customer service, subscribe to email lists, or apply for employment through the Site, we collect the following Personal Data from you:

  • First and last name
  • Title
  • Company name
  • Email address
  • Company Mailing address
  • Job Title
  • Company Phone number
  • Account password
  • Company Payment and billing information
  • Country location
  • Information about your connected devices (such as mobile phone, computer, or tablet) and how you interact with our products, services, apps, and websites (such as IP Address, browser type, unique device identifier, cookie data, and associated identifying and usage information)
  • Marketing profile information
  • Photographs and videos
  • Investor Information (name, address, phone number, and email address)
  • Inferences drawn from other personal information (such as personal preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes)

You will be informed what personal information is required and what information is optional when asked to submit personal information to us. By submitting personal information to Keywee at this Site, you hereby consent and opt-in to Keywee’s collection, use, and disclosure of such personal information.

We may combine the personal information you submit directly through this Site with other personal information we have collected from you, whether on-or offline. We may also combine it with information we receive about you from other sources, such as other companies, publicly available information sources (including from your publicly available social media profiles), and other third parties.

Automatically Collected Data:

When you visit the Site, we may automatically collect information about you through cookies and similar technologies. This information includes the browser or operating system that you use to access the Internet, your IP address, the date and time you may have viewed certain pages on the Site. Please see the “Use of cookies” section below to find out more about how we use cookies.

Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system version, and Internet browser type and version. We collect Device-specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information including phone number). We may associate your device identifiers or phone number with your Keywee account.

Your IP Address is identified and logged automatically in our server log files whenever a user visits this Site, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many web sites. We use IP Addresses for purposes such as calculating Site usage levels, helping diagnose server problems, and administering this Site.

Facebook Cookies and Other Third Party Technologies

We may use Facebook Cookies as part of our service to evaluate and customize content and advertising. For information about Facebook Cookies, please visit

We permit third-party advertising partners to use tracking technologies to collect information about your browsing activities over time and across different websites when you use the Site. For example, we use advertising services provided by third-party partners, such as Google, to market our service to you on other websites and online services. Through a process called “retargeting,” each service places a cookie on your browser when you visit the Site so that they can identify you and serve you ads on other sites around the web based on your browsing activity. To avoid use of this information for advertising by these third-party ad partners, you can change your browser settings to reject cookies or to notify you when cookies are set and you can select the Do Not Track option on your browser, though we have no control over and cannot confirm whether these third-party ad partners honor the Do Not Track browser signal. Additionally, many advertising companies are members of the NAI or DAA and/or provide opt-outs on those industry pages at or

Data Collected during Paid Content Distribution and Creation:

Our customers use our web-based solution to manage paid content distribution and content creation. In order to use our Services we may collect certain non-personally identifiable information. This information may includes: Masked IP address, browser type, Internet Service Provider, URL, computer (or mobile device’s) operating system and mobile device model.

We use this information in a number of ways, including: a) to help us ensure content is being deployed correctly, b) to help us understand how the content that we distribute is being viewed, and c) to help ensure that the content is both appropriate and relevant.

We may use cookies in association with our Services. Cookies are small files placed on the hard drive of your computer. We may use cookies to help us understand how our services are being used, to tailor how we distribute content, and to report on delivery on the content. Please see the “Use of cookies” section below to find out more about how we use cookies.



The information that Keywee collects about you and your Devices may be used:

  • To provide products and services and maintain customer relationships
  • To improve the quality, safety, and security of our products and services
  • To administer your account(s) and process your payments for products and services
  • To operate our websites and applications, including online registration processes
  • To autofill data fields on our websites or applications to improve online experience
  • To develop new products and services
  • To provide customer support and service
  • To provide information and product/service updates
  • For research, evaluation of use, and troubleshooting purposes
  • For marketing and analytics purposes
  • To customize and improve communication content
  • To comply with legal, regulatory, or contractual requirements

Communication with you in connection with these uses may be via mail, telephone, e-mail, text message, social media, or other electronic messages, or via our websites and applications.

We may disclose personal information that we collect or you provide as described in this Privacy Policy. The information may be disclosed to a third party for a business purpose to the following categories of third parties:

  • To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • To third parties to market their products or services to you if you have consented to these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • To our affiliates for related business purposes.

In addition, we use and disclose personal information collected through this Site as we believe to be necessary or appropriate: (a) as permitted by applicable law, including laws outside your country of residence; (b) to comply with any legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our Terms of Use; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. We may also use and disclose personal information collected through this Site in other ways, with your prior consent (unless we are permitted to do so without your consent under applicable law).

To provide the Services to Customers and respond to requests.

We use account-related data provided by Customers to us in connection with the purchase, sign-up, use or support of Customer account (such as usernames, email address and billing information) to provide you with access to the Services and/or the Site, contact you regarding your use of the Services and/or the Site or to notify you of important changes to the Services and/or the Site. For EU data subjects, such use is necessary for the performance of the contract between you and us.

When you ask for information about the Services (for example, when you ask us to send you offers or price information), we will use your contact information to respond to your requests. For EU data subjects, such use is necessary to respond to or implement your request prior to entering into a contract with us.

We also use and transfer personal information from or about you:

  • to send you important information regarding our relationship with you or regarding this Site, changes to our terms, conditions, and policies and/or other administrative information;
  • for our business purposes, such as marketing new products and services, data analysis, audits, developing new products or services, enhancing our Site, improving our products and services, identifying Site usage trends and determining the effectiveness of our Site.
  • to our third party service providers who provide services such as website hosting and moderating, mobile application hosting, data analysis, infrastructure provision, credit card processing, IT services, e-mail services, marketing services, auditing services, and other services, in order to enable them to provide services in connection with our performance of the Services;
  • to verify your information, approve your registration as a user of the Site, authenticate payments and process orders;
  • when we otherwise have your consent (if required by applicable law).

You may choose to receive certain communications from Keywee via your email address upon interaction with the Site. From time to time, Keywee may include surveys, information requests, or other features on the Site which ask you to provide personal information such as your name, telephone number, email address or mailing address. Any information you may provide will be used by Keywee to allow you to participate in the particular feature being offered. Keywee may also retain any information you provide in order to send you information about Keywee’s products and services that may be of interest to you. Keywee will provide you with the opportunity to opt-out of receiving such communications. We may use one or more service providers to administer these messages, but we do not share your email address with spammers or any other third parties without your permission.

You have the right to withdraw your consent that was provided to us at any time, including by following the instructions contained in each promotional communication we send you permitting you to “opt-out” of receiving future promotional information. In addition, if at any time you wish not to receive any future communications or you wish to have your name deleted from our mailing lists, please contact us at:

  • Email:
  • Postal Mail: 37 West 20th St, Suite 1010
    New York, NY 10011

Please note that we will continue to contact you via email to respond to your requests and regarding the provision of our Services.

To analyze, administer, support, improve use of the Site and the Services.

We use data relating to your use of the Site and/or the Services to analyze, administer, support and improve your access to and use of the Site and the Services. We may also compile, anonymize and/or aggregate your Personal Data and other data and use such anonymized and/or aggregated data for our business purposes, including sharing such data with affiliates and business partners. This aggregate information does not identify you.

To process applications for a job.

When you apply for employment through our Site, your contact details and data about your employment history and education may be collected by our provider of recruiting services and we will use such data to evaluate your job application, to conduct job interviews, and as is otherwise needed for recruitment. For EU data subjects, processing of this data is necessary to respond to your request to process your application for employment. If you do not provide this data, we will not be able to process the application that you send through our Site.

Other Uses of Personal Data.

We also may use your Personal Data in other ways for which we provide specific notice at the time of collection.

If you are an EU data subject, please see the “EU Data Subjects” section below for information on your rights in relation to your Personal Data.


We may share your Personal Data and other information with certain third parties without further notice to you, as set forth below:

  • Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions: providers of payment processing and fraud prevention, marketing, web analytics, hosting, email communication and customer support services, recruiting services. Pursuant to our instructions, these parties may access, process or store Personal Data in the course of performing their duties to us.
  • Business 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, your Personal Data and other information may be transferred to a successor or affiliate as part of that transaction along with other assets.
  • Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation or lawful requests by public authorities, including meeting national security or law enforcement requirements and applicable law, rule, order, or regulation, (ii) protect and defend the rights or property of COMPANY, (iii) act in urgent circumstances to protect the personal safety of users of the Site or the public, or (iv) protect against legal liability.

In the preceding twelve (12) months, we have not sold any personal information.

In the event that Keywee begins selling personal information, this Privacy Policy will be updated to reflect that sale and you will be notified of such update. Additionally, you will be provided the ability to opt-out of the sale of your personal information collected by Keywee by clicking a DO NOT SELL MY PERSONAL INFORMATION link.

In the last twelve (12) months, we have disclosed the following categories of personal information about consumers for a business purpose:

  • Personal identification information such as real name, postal address, online identifier, IP address, email address, and account number.
  • Internet or other electronic network activity, including but not limited to, browsing history, search history, and information regarding your interaction with the Site.
  • Payment information.



This section applies if you are an EU data subject (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway and, where applicable, Switzerland).

Data Controller.

COMPANY is the data controller for processing personal data provided to us through the Site. Our registered office is in 37 West 20th St, Suite 1010 New York, NY 10011.

Your Rights.

Subject to applicable law, you have the following rights in relation to your Personal Data:

  • Right of access: If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
  • Right to rectification: If your Personal Data is inaccurate or incomplete, you are entitled to have it rectified or completed. If we have shared your Personal Data with others, we will tell them about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.
  • Right to erasure: You may ask us to delete or remove your Personal Data and we will do so in some circumstances, such as where we no longer need it (we may not delete your data when other interests outweigh your right to deletion). If we have shared your data with others, we will tell them about the erasure where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.
  • Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of that Personal Data or object to us processing it. We will tell you before we lift any restriction on processing. If we have shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.
  • Right to data portability: You have the right to obtain your Personal Data from us that you consented to give us or that is necessary to perform a contract with you. We will give you your Personal Data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
  • Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so:
    • If we are relying on a legitimate interest to process your Personal Data — unless we demonstrate compelling legitimate grounds for the processing; or
      If we are processing your Personal Data for direct marketing.
  • Right to withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on your prior consent.
  • Right to lodge a complaint with the data protection authority:If you have a concern about our privacy practices, including the way we have handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.

You may exercise your rights by contacting us as indicated under “Contact Us” section below.

Legitimate Interest.

“Legitimate interests” means the interests of COMPANY in conducting and managing our organization. For example, we have a legitimate interest in processing your Personal Data to analyze how our products and services are being used by you, and to ensure network and information security, as described in this Privacy Policy. When we process your Personal Data for our legitimate interests, we make sure to consider and balance any potential impact on you, and your rights under data protection laws. Our legitimate interests do not automatically override your interests. We will not use your Personal Data for activities where our interests are overridden by the impact on you, unless we have your consent or those activities are otherwise required or permitted to by law. You have the right to object to processing that is based on our legitimate interests. For more information on your rights, please see “Your Rights” section above.


The following section of this Privacy Policy only applies to California residents. The California Consumer Privacy Act (the “CCPA”) grants users of our Site that are California residents certain rights in regards to our collection of personal information. These rights include:

  • The right to request the disclosures of (1) what personal information has been collected; (2) the categories of sources from which the personal information was collected; (3) the business or commercial purpose for collection or selling personal information; (4) the categories of third parties with whom the business shares personal information; and (5) the specific pieces of personal information Keywee has collected;
  • The right to request the deletion of their personal information that has been collected; and
  • The right to opt-out of the sale of their personal information.

Under the CCPA, a data subject may only make a personal information request twice in a 12-month period. Keywee will respond to such personal information request within 45 days of receiving the personal information request.

You may exercise your rights by contacting us as indicated under “Contact Us” section below.


Comments posted to public areas may be viewed, accessed and used by third parties subject to those third parties’ privacy practices and policies.


COMPANY does not knowingly collect Personal Data from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided Personal Data to COMPANY through this Site, please contact us at and we will endeavor to delete that information from our databases.


The Site may contain links to other websites not operated or controlled by us (“Third Party Sites”). The privacy practices described in this Privacy Policy do not apply to Third Party Sites. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact those sites directly for information on their privacy practices and policies.

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any site or web property (including, without limitation, any application) that is available through this Site or to which this Site contains a link. The availability of, or inclusion of a link to, any such site or property does not imply endorsement of it by us or by our affiliates.

Third parties may offer products and services on the Sites and collect information about you by requesting certain information necessary to provide a particular product or service. Keywee may also obtain certain information about its users from third party customer research group which Keywee uses to learn more about its customers. Keywee does not control the policies and practices of third parties in relation to the use and conducted by such third parties and any use or disclosure of such information by third parties is not governed by this Privacy Policy.


Through our Site, you can choose to access certain social media websites and services that are owned and/or controlled by third parties, such as Facebook, Twitter, Instagram, Pinterest and YouTube (“Social Media Services”). When you choose to access and use Social Media Services, including interacting with our pages on those sites, you will be sharing your Personal Data and other information with them. The information that you share with the Social Media Services will be governed by the specific privacy policies and terms of service of the Social Media Services and not by this Privacy Policy.


We maintain reasonable and appropriate security measures to protect Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in light of the risks inherent in processing this information. However, the Internet cannot be guaranteed to be fully secure and we cannot ensure or warrant the security of any information you provide to us. Please keep this in mind when providing us with your Personal Data. [see Annex A]


COMPANY uses cookies on the Site. A cookie is a piece of information sent to your browser from a website and stored on your computer’s hard drive. Cookies can help a website like ours recognize repeat users and allow a website to track web usage behavior. Cookies work by assigning a number to the user that has no meaning outside of the assigning website. We use cookies to collect information about your device, such as operating system and browser type.

The Site also uses pixel tags, a technology similar to cookies that is placed on a website or within the body of an email for the purpose of tracking activity on websites, or when emails are opened or accessed, and is often used in combination with cookies. Pixel tags, web beacons, clear GIFs, or other similar technologies may be used in connection with some Site pages to, among other things, track the action of Site users and compile statistics about Site usage and response rates.

Upon your first connection to our Site, you will be asked to confirm whether you agree to our use of cookies and similar technologies in accordance with this Policy, and if you accept we will store them on your computer.

Your selection of the “Do Not Track” option provided by your browser may not have any effect on our collection of cookie information for analytic and internal purposes. The only way to completely opt out of the collection of any information through cookies or other tracking technology is to actively manage the settings on your browser or Device to delete and disable cookies and other tracking/recording tools. Please note, depending on your type of Device or browser, it may not be possible to delete or disable all tracking mechanisms on your Device.


Your access to and use of our Site is subject to the Terms of Service.


This Privacy Policy is meant to guide Keywee with respect to personal information collected from or about you at this Site. While this Privacy Policy applies to personal information generally, the local laws, rules and regulations of jurisdictions that are applicable to Keywee (“Local Laws”) may require standards which are stricter than this Privacy Policy and, in such event, Keywee will comply with applicable Local Laws. Specific privacy policies may be adopted to address the specific privacy requirements of particular jurisdictions. All the information you provide may be transferred or accessed by entities around the world as described in this Privacy Policy. Your personal information may be stored and processed in any country where we have facilities or service providers, and by using our Site or by providing consent to us (where required by law), you specifically acknowledge, consent, and opt-in to the transfer of information to countries outside of your country of residence, including to the United States, which may provide for different data protection rules, and a lower standard of required protection than in your country. Irrespective of which country your personal data is transferred, we would only share your personal data under a “need to know” basis. In these circumstances we will, as required by applicable law, ensure that your privacy rights are adequately protected by organizational, technical, contractual, and/or other lawful means.


We may change this Privacy Policy at any time. We will post all changes to this Privacy Policy on this page. Please review the LAST UPDATE legend at the top of this page to see when this Privacy Policy was last revised. By continuing to use the Site and/or the Services or providing us with information following such a replacement Policy being uploaded, you agree that you will be deemed to have agreed to be bound by the Privacy Policy as changed.


If you have a complaint as to our use of your information, you may file a complaint with us, the GDPR supervisory authority (for EU residents), the California Attorney General (for California residents), any other governmental agency, and/or a judicial body.

A complaint may be submitted directly to Keywee by utilizing one of the contact methods described in the Contact Us Section of this Privacy Policy.


Please feel free to contact us if you have any questions about COMPANY’s Privacy Policy or the information practices of our Site.

You may contact us as follows: You may send an email to or send postal mail to:
37 West 20th St, Suite 1010 New York, NY 10011

Annex A

(1) Information Security Policies and Standards

COMPANY’s security measures shall include:

· Preventing unauthorized persons from gaining access to Personal Information Processing systems (physical access control);

· Preventing Personal Information Processing systems being used without authorization (logical access control);

· Ensuring that persons entitled to use a Personal Information Processing system gain access only to such Personal Information as they are entitled to access in accordance with their access rights and that, in the course of Processing or use and after storage, Personal Information cannot be read, copied, modified or deleted without authorization (data access control);

· Ensuring that Personal Information cannot be read, copied, modified or deleted without authorization during electronic transmission, transport or storage, and that the target entities for any transfer of Personal Information by means of data transmission facilities can be established and verified (data transfer control);

· Ensuring the establishment of an audit trail to document whether and by whom Personal Information have been entered into, modified in, or removed from Personal Information Processing (entry control);

· Ensuring that Personal Information are protected against accidental destruction or loss (availability control); and

· Ensuring that Personal Information collected for different purposes can be processed separately (separation control).

These measures are kept up to date, and revised whenever relevant changes are made to the information system that uses or houses personal data, or to how that system is organized.

(2) Network Security

The COMPANY maintains network security using commercially available equipment and industry standard techniques, including firewalls, intrusion detection and/or prevention systems, access control lists and routing protocols.

(3) Access Control

Only authorized staff can grant, modify or revoke access to an information system that uses or houses use Personal Information.

User administration procedures define user roles and their privileges, how access is granted, changed and terminated; addresses appropriate segregation of duties; and defines the logging/monitoring requirements and mechanisms.

The COMPANY implements commercially reasonable physical and electronic security to create and protect passwords.

(4) Business Continuity

The COMPANY implements appropriate disaster recovery and business resumption plans.