Privacy Policy

1. Introduction

Keyhowl (“Keyhowl,” “we,” “us,” or “our”) provides a software-as-a-service (SaaS) platform used by escape room businesses (“Customers”) to manage reservations. This Privacy Policy explains how we collect, process, and protect personal data when individuals (“Users” or “Players”) submit reservation requests through our Platform on behalf of a Customer.

Keyhowl acts as a data processor under applicable data protection laws. Our Customers act as data controllers and are solely responsible for determining the purposes and means of processing personal data collected through the reservation form.

2. Scope of this Policy

This Privacy Policy applies exclusively to personal data collected via the reservation form embedded on or linked from our Customers’ websites, used for making bookings with escape room businesses.

3. Personal Data We Collect

When a User makes a reservation through our Platform, we collect the following personal data on behalf of the Customer:

• Full name
• Email address
• Phone number
• Booking details (e.g., date, time, number of players)

4. Purpose and Legal Basis of Processing

Personal data is processed for the purpose of:

• Creating and managing reservations
• Enabling the escape room business to contact the User
• Facilitating administrative and logistical operations related to the booking

The legal basis for processing this data is typically the performance of a contract (to fulfill the booking request) or consent, as determined by the Customer (data controller).

5. Role of Keyhowl as Data Processor

Keyhowl processes personal data solely on documented instructions from the Customer and does not use this data for any independent purposes. We do not control, own, or make decisions regarding the personal data collected through the reservation form.

6. Data Retention

Keyhowl retains personal data on behalf of its Customers for as long as the Customer chooses. We do not delete or alter this data unless explicitly instructed by the relevant Customer. Each Customer is responsible for determining its own data retention policies.

7. Data Sharing and Sub-Processors

We may share personal data as follows:

• With the Customer: The escape room business with whom the User makes a booking has full access to the data and is solely responsible for its management.
• With Sub-Processors: We use trusted third-party service providers (e.g., cloud infrastructure, email delivery) to provide and maintain the Platform. These sub-processors are contractually bound to handle data securely and in accordance with applicable privacy laws.

Some data may be transferred outside the European Economic Area (EEA). In such cases, we ensure that appropriate safeguards are in place, including Standard Contractual Clauses (SCCs) approved by the European Commission.

8. Data Security

We implement industry-standard technical and organizational measures to safeguard personal data from unauthorized access, disclosure, alteration, or destruction. While we take reasonable precautions, no system can be guaranteed to be 100% secure.

9. User Rights and Requests

Users may have rights under applicable data protection laws, including:

• Right to access their data
• Right to rectify incorrect data
• Right to request deletion
• Right to object to or restrict processing
• Right to data portability

All requests regarding personal data should be directed to the escape room business with which the User made the reservation. Keyhowl, as a data processor, does not respond to data subject requests directly but will assist the Customer in responding as required by law.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. Any updates will be posted on this page with a revised effective date.

11. Contact Information

If you have any questions or concerns about this Privacy Policy, you may contact us at:
Email: [email protected]