Privacy Policy

Last updated: December 2025

1. Introduction

Keen Digital Agency ("we", "our", or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our CRM and operations management system (the "Portal"). We comply with the General Data Protection Regulation (GDPR) and other applicable data protection laws.

2. Data Controller

Keen Digital Agency is the data controller responsible for your personal data.

Malta • info@keen.com.mt • +356 2034 2034

3. Information We Collect

Personal Data: Name, email address, phone number, job title, and department
Account Data: Login credentials, user preferences, and security settings
Usage Data: Activity logs, time entries, attendance records, and system interactions
Technical Data: IP addresses, browser type, device information, and access times
Business Data: Client information, project details, invoices, and documents you create or manage

4. How We Use Your Information

To provide and maintain our Portal services
To manage your account and authenticate your access
To track time, attendance, and project management activities
To process invoices, payments, and financial operations
To send notifications and important service updates
To improve our services and user experience
To ensure security and prevent unauthorized access
To comply with legal obligations

5. Legal Basis for Processing

Contract: Processing necessary for the performance of your employment or service contract
Legal Obligation: Processing necessary for compliance with legal requirements
Legitimate Interests: Processing necessary for our legitimate business interests
Consent: Where you have given explicit consent for specific processing activities

6. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including to satisfy legal, accounting, or reporting requirements.

Session data: Retained for security monitoring purposes
Login history: Retained for security audit purposes
Activity logs: Retained based on business and legal requirements
Financial records: Retained as required by tax and accounting laws

7. Your Rights Under GDPR

Right of Access: Request copies of your personal data
Right to Rectification: Request correction of inaccurate data
Right to Erasure: Request deletion of your personal data ("right to be forgotten")
Right to Restrict Processing: Request limitation of data processing
Right to Data Portability: Request transfer of your data in a machine-readable format
Right to Object: Object to processing based on legitimate interests
Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent

To exercise these rights, contact us at privacy@keen.com.mt.

8. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include encryption of data in transit and at rest, two-factor authentication, session management, IP whitelisting, regular security audits, and role-based access controls.

9. Third-Party Services

We may share your data with trusted third-party service providers including payment processors (Stripe), email service providers (Mailgun), document signing services (BoldSign), accounting systems (Odoo), and cloud storage providers. All third-party providers are required to maintain the confidentiality and security of your data.

10. International Data Transfers

Your data may be transferred to and processed in countries outside the European Economic Area (EEA). When we transfer data internationally, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last updated" date.

12. Contact Us

If you have any questions about this Privacy Policy or our data practices, or if you wish to exercise your data protection rights, please contact our Data Protection Officer:

Keen Digital Agency
Email: privacy@keen.com.mt