Privacy Policy

1. Introduction and scope

This Privacy Policy explains how The Key Circle (“TKC”, “we”, “us” or “our”), operated by The Keycircle Private Limited, handles personal data in connection with the TKC website, mobile application, customer and merchant accounts, merchant applications and related local-commerce services (collectively, the “Services”).

This policy is India-focused and applies subject to applicable law. It does not govern a merchant’s or third party’s independent handling of information under its own privacy practices.

2. Information we collect

Depending on how you use the Services, we may collect information you provide, information created through your use of TKC, information from participating merchants or service providers, and technical information collected by devices and systems.

3. Account and profile information

This may include your name, mobile number, email address, login and security information, preferences, profile details, account type and information needed to create, verify, maintain or support an account.

4. Merchant information

For merchant accounts and applications, we may collect business and representative details, contact information, location, business category, listings, licences or verification materials where applicable, offers, operating information and communications. The information requested will depend on the applicable onboarding process. Submitting an application does not guarantee approval.

5. Location information

With the permissions required by applicable law and your device settings, TKC may receive location information used for nearby discovery and other location-aware functionality. Precision and availability depend on the feature, device and permission selected. You can manage access through available device or browser controls.

6. Activity and usage information

We may collect searches, pages or screens viewed, feature usage, offer views and interactions, merchant interactions, preferences, referral or campaign activity, and the dates, times and manner in which the Services are used.

7. Device and technical information

This may include IP address, browser and operating-system information, device or application identifiers, language, network information, timestamps, crash and diagnostic data, security events and server logs.

8. Communications

We may retain enquiries, support requests, feedback, complaints, merchant application correspondence and other communications you send to TKC, together with information needed to respond and maintain appropriate records.

9. How we use personal data

Subject to applicable law and, where required, consent, we may use personal data to:

• provide, operate, maintain and secure the Services and accounts;
• support local merchant discovery, offers, Keys and rewards;
• process merchant applications and support participating merchants;
• personalise features and improve relevance;
• provide support and respond to requests or grievances;
• send service, safety and permitted promotional communications;
• detect technical problems, fraud, abuse and security threats;
• analyse performance and improve the Services; and
• comply with legal, regulatory and recordkeeping obligations.

10. Personalisation and recommendations

TKC may use profile information, preferences, location where enabled, searches, offer activity, merchant interactions and Keys activity to organise content and provide more relevant recommendations. Recommendations do not guarantee availability, suitability, savings or outcomes.

11. Location-based features

Location information may be used to show nearby merchants, local content or geographically relevant offers and to support safety, fraud prevention or service functionality where appropriate. Disabling location access may limit some features.

12. Keys and rewards data

TKC may maintain records concerning the earning, crediting, use, redemption where applicable, expiry, reversal and adjustment of Keys. These records may be used to operate the reward mechanism, answer account questions, prevent abuse and maintain platform integrity. Keys are an engagement and reward mechanism and are not treated as money or financial assets.

13. Merchant interactions

When you view, save, claim, use or otherwise interact with a merchant or offer, TKC may process and, where necessary for the requested interaction, share relevant information with that merchant. A merchant may independently process information it receives directly from you under its own privacy practices.

14. Notifications and communications

We may send account, security, support, transaction-related or other service communications. With consent or where otherwise permitted, we may also send offers, recommendations or promotional messages. You can use provided preference, unsubscribe, browser or device controls, although essential service messages may still be sent.

15. Sharing of information

We may share personal data only as reasonably necessary for the Services, as described in this policy, at your direction, with consent where required, or as permitted or required by applicable law. Recipients may include participating merchants, service providers, professional advisers, authorities and parties involved in a corporate transaction.

16. Service providers

Providers may support hosting, infrastructure, security, communications, analytics, customer support, identity or merchant verification, payments where applicable, and other platform operations. They may process information for the relevant service and subject to appropriate safeguards where required.

17. Legal and safety disclosures

We may preserve, use or disclose information where reasonably necessary to comply with law or legal process; respond to lawful requests; enforce applicable terms; investigate fraud, abuse or security incidents; or protect users, merchants, TKC or others.

18. Corporate transactions

Information may be disclosed in connection with a proposed or completed merger, financing, reorganisation, acquisition, sale of assets or similar corporate transaction, subject to applicable law and appropriate confidentiality or data-protection measures.

19. Data security

We use reasonable administrative, technical and organisational measures appropriate to the information and risks involved. No internet transmission or storage system can be guaranteed completely secure. You should protect your credentials and report suspected unauthorised activity.

20. Data retention

We retain personal data only for as long as reasonably necessary for the purpose collected and for providing the Services, account operation, fraud and security prevention, resolving disputes, legal or regulatory obligations, and legitimate business records where permitted. Periods may vary by category, context and legal requirement. We may delete or anonymise information when no longer reasonably required, subject to applicable law.

21. User choices and rights

Subject to applicable law and relevant exceptions, you may have rights to obtain information regarding processing, request correction, completion or updating, request erasure, withdraw consent, seek grievance redressal, and exercise other rights available under applicable law. We may need to verify your identity. Contact founder@thekeycircle.in.

22. Consent and withdrawal

Where processing is based on consent, you may withdraw it through an available product control or by contacting us. Withdrawal does not affect processing already undertaken lawfully, may limit features that require the relevant information, and does not prevent retention where required or permitted by law.

23. Children

TKC does not intend to process children’s personal data in a manner contrary to applicable law. Eligibility and consent requirements for younger users apply as communicated for the relevant Services. If you believe a child’s information was provided contrary to law, please contact us.

24. International and cross-border processing

Service providers or systems may process information outside your state or country. Where this occurs, TKC will act subject to applicable Indian law and use safeguards where required.

25. Third-party services

The Services may link to or interoperate with merchants, payment providers and other third parties. Their independent services are governed by their own terms and privacy policies.

26. Cookies and similar technologies

The website may use technologies needed for operation, security and preferences. It currently does not include non-essential advertising or analytics scripts. If such technologies are introduced, TKC will provide information and consent or preference controls where required. Browser settings may also control cookies.

27. Security incidents

If a personal-data or security incident occurs, TKC will investigate and take reasonable containment and remediation steps. We will notify affected persons and relevant authorities where required by applicable law.

28. Changes to this Privacy Policy

We may update this policy as the Services, practices or legal requirements change. The effective or updated date will be revised when the policy is updated, and material changes communicated through an appropriate channel where required.

29. Contact and grievance redressal

Please describe your request sufficiently for us to review it. We may ask for information reasonably necessary to verify identity, locate records and respond, subject to applicable law.