This Privacy Policy explains how SuperKey SRL (“SuperKey”, “we”, “us”) processes personal data in connection with the provision of our concierge services (“Services”). We are committed to handling personal data transparently, lawfully, and securely.

Client accounts, registration, login, and initial data collection are managed by the Blackbell platform. Blackbell collects personal data directly from Clients and makes certain details available to SuperKey for the purpose of providing the Services.

SuperKey does not operate its own standalone customer account system and processes personal data received from Blackbell in accordance with this Privacy Policy and applicable data protection laws.

For the purposes of applicable data protection legislation, including the UK GDPR and EU GDPR where applicable, SuperKey SRL acts as an independent data controller in respect of personal data processed in connection with the Services it provides.

Depending on the nature of the request and information provided via the Blackbell platform, SuperKey may process the following categories of personal data:

– Identification details (full name)
– Contact details (email address and telephone number)
– Billing and invoicing details (billing address)
– Transactional information relating to requested services
– Service preferences and request details
– Communications exchanged in connection with the Services

SuperKey does not receive or store full payment card details. All payment processing is handled securely by third-party payment providers integrated with the Blackbell platform.

SuperKey processes personal data solely for purposes directly related to the provision of the Services, including:

– Managing and fulfilling client requests
– Purchasing tickets or making reservations on the Client’s behalf
– Creating accounts with third-party providers in the Client’s name where required
– Communicating with Clients regarding their requests
– Issuing invoices and maintaining accounting and financial records
– Complying with applicable legal and regulatory obligations

In order to fulfil certain requests, SuperKey may be required to provide Client personal data (such as name and email address) to third-party platforms operated by event organisers, venues, restaurants, or ticketing providers.

Where necessary, SuperKey may also create accounts in the Client’s name solely for the purpose of completing purchases or reservations on the Client’s behalf. Such processing is carried out strictly in accordance with the Client’s instructions and this Privacy Policy.

SuperKey processes personal data on one or more of the following legal bases:

– Performance of a contract (to provide the Services requested by the Client)
– Compliance with legal obligations (including accounting and tax requirements)
– Legitimate interests (to operate and manage the concierge service)
– Consent, where explicitly required

Personal data may be shared only where necessary to provide the Services, including with event organisers, venues, restaurants, ticketing platforms, invoicing providers, and payment processors.

SuperKey does not sell personal data and does not share personal data with third parties for marketing or advertising purposes.

Personal data is retained only for as long as necessary to fulfil the purposes for which it was processed, including contractual, accounting, and legal retention requirements.

SuperKey implements appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse, or disclosure.

Subject to applicable data protection laws, Clients have the right to:

– Access their personal data
– Request rectification or deletion
– Object to or restrict certain processing activities
– Request data portability
– Withdraw consent where processing is based on consent

Communications relating to the Services take place via the Blackbell platform. SuperKey does not use Client personal data for unsolicited marketing communications.

This Privacy Policy may be updated from time to time to reflect changes in legal requirements or operational practices. The most current version will be made available through the platform.

For questions regarding this Privacy Policy or the processing of personal data, Clients may contact SuperKey via the Blackbell platform.