Legal
Privacy Policy
Effective date: [EFFECTIVE DATE]
This policy explains how MKYCAPITAL LTD ("Keyrail", "we", "us"), 71-75 Shelton Street, London WC2H 9JQ, United Kingdom, handles personal data on the website keyrail.tech and in the Keyrail service. We keep it short because we collect little: no advertising, no tracking, no telemetry.
1. Two roles#
| Who you are | Our role | What applies |
|---|---|---|
| Visitor of keyrail.tech, waitlist subscriber, user of a vendor account (dashboard), person contacting us | Controller | This policy |
| End customer of a software vendor that uses Keyrail (you bought or use a desktop app licensed through Keyrail) | Processor acting on the vendor's instructions | The vendor's privacy policy and our Data Processing Agreement with the vendor. This policy describes our practices for information only. |
If you are an end customer and want to exercise your rights, contact the vendor of your software first. If you contact us, we will forward your request to the vendor.
2. Data we process as controller#
| Data | Source | Purpose | Legal basis | Retention |
|---|---|---|---|---|
| Email address and consent timestamp (waitlist), optional source tag | You, via the waitlist form | Tell you when Keyrail opens and send launch news | Consent (you can withdraw it at any time with the link in each email or by writing to us) | Until you unsubscribe, or 6 months after the public launch if you have not created an account |
| Account and user data: email, name, account name, role, sign-in times | You, at sign-up and in the dashboard | Provide the dashboard and the vendor API, send sign-in links and service emails | Performance of the contract (Terms of Service) | For the life of the account, then 30 days |
| Subscription data stored in the service: Paddle customer identifier, Paddle subscription identifier, plan, billing interval (monthly or yearly), billing status, end of the current billing period, scheduled cancellation date, date of the last billing event, plan change history in the account's audit log | Paddle, through signed notifications (webhooks) sent when the subscription changes | Apply the plan you paid for and its limits, let you change or cancel it, return the account to the Free plan at the end of a cancelled period | Performance of the contract (Terms of Service) | For the life of the account, then 30 days; identifiers of Paddle notifications are kept 90 days to ignore duplicates |
| Billing records visible in our Paddle seller account: name or company name, email, billing country and address, tax identification number if given, transactions, invoices and payout statements (no card data: Paddle never shares it with us) [TO VERIFY: exact fields shown in the Paddle seller dashboard] | Paddle | Support, accounting and tax obligations, handling refund and billing questions | Performance of the contract; legal obligation (accounting records) | Payout statements and accounting records: [10] years, as required by [APPLICABLE LAW]; the rest is kept by Paddle under its own policy |
| Support emails and their content | You | Answer your questions | Legitimate interest in providing support | 3 years after the last exchange |
| Salted SHA-256 hash of the IP address | Every API request | Rate limiting, abuse prevention and security | Legitimate interest in protecting the service | 30 days |
| Security and audit log entries (for example sign-ins, API key creation) | Your use of the service | Security, investigation of incidents | Legitimate interest in protecting the service and your account | 12 months, for every account (older entries are deleted daily); all entries are deleted with the account, 30 days after its closure |
We do not use your data for advertising, we do not sell it, and we do not build profiles.
Closing your account#
The account owner can close the account from the dashboard. Closing it cancels Keyrail's Paddle subscription at the end of the current billing period. For the next 30 days the dashboard can no longer be signed in to (download the data export before closing, or reopen the account to export it), while the licences already activated by your end customers keep validating and their payments keep being processed; new activations are refused. Until then, the single-use link emailed to the account owner at closure reopens the account. After 30 days, the account and all its data, including the audit log, are deleted from the service. Billing records kept by Paddle and our accounting records follow the retention stated above.
How billing works#
Keyrail's paid plans are sold by Paddle (Paddle.com Market Limited, or Paddle.com Inc. or Paddle.com (Canada) Ltd. depending on where you buy), which acts as reseller and merchant of record: you buy the plan from Paddle, which collects the payment, issues the invoice and handles VAT, sales taxes and refunds. Paddle is an independent controller of the data you give it at checkout and in its customer portal, under its own privacy notice (https://www.paddle.com/legal/privacy) [TO VERIFY ON PUBLICATION DATE].
When you click Upgrade in the dashboard, we send Paddle the email address of the account owner (to prefill the checkout) and the internal identifier of your Keyrail account (so that Paddle's notifications can be matched to it). The dashboard then loads Paddle's checkout script from Paddle's servers; it is not loaded anywhere else on keyrail.tech. Your card or other payment details are entered in Paddle's checkout and never reach us.
3. Data we process as processor (vendors' end customers)#
On behalf of each software vendor, the service stores, as described in our technical specification:
- end customer email and name, licence keys (hashed for lookup and encrypted for display), licence status and dates;
- for each activated machine: a hashed machine fingerprint (the raw machine identifier never leaves the device, and fingerprints are different for each product so they cannot be correlated across vendors), the machine name and platform if the app sends them, the app version, and the last time the licence was validated;
- events received from the vendor's payment provider (for example a subscription renewal or a refund) and the resulting changes of licence status;
- a salted hash of the IP address for rate limiting, kept 30 days.
We do not collect telemetry, usage analytics, crash reports or payment card data from vendors' applications. We send licence emails and sign-in links for the customer portal on the vendor's behalf.
If a vendor closes its Keyrail account, its end customers' data is kept for 30 days (activated licences keep validating and payments notified by the vendor's payment provider keep being processed, without licence emails), then deleted.
4. Website and cookies#
The website keyrail.tech does not use analytics, advertising or third-party tracking cookies. [TO CONFIRM BEFORE PUBLICATION: if privacy-friendly analytics are added later, describe them here.]
We use only strictly necessary cookies:
| Cookie | Purpose | Duration |
|---|---|---|
__Host-kr_session | Keeps you signed in to the dashboard | 30 days |
__Host-kr_portal | Keeps an end customer signed in to the customer portal | 7 days |
These cookies are HttpOnly, Secure and limited to the Keyrail domain. Because they are strictly necessary, they do not require consent.
When the account owner clicks Upgrade or Manage billing in the dashboard, Paddle's checkout or customer portal opens from Paddle's own domains and may use its own cookies or similar technologies, under Paddle's policies. Nothing from Paddle is loaded before that click. [TO VERIFY IN THE PADDLE SANDBOX BEFORE PUBLICATION: cookies and storage used by Paddle's checkout overlay.]
Our hosting provider processes technical data (such as IP addresses and request metadata) to deliver the website and protect it against attacks. See section 6.
5. Recipients#
We share personal data only with:
- the service providers listed on our sub-processors page (https://keyrail.tech/legal/subprocessors/), which process it on our instructions: hosting and database (Cloudflare) and email delivery (Brevo);
- Paddle, the reseller and merchant of record of our paid plans, which receives the account owner's email address and our account identifier when you start a checkout, and is an independent controller for the data it collects at checkout and in its customer portal (see section 2, "How billing works"). Paddle may process this data outside the European Economic Area, with the safeguards described in its privacy notice (its notice refers to Standard Contractual Clauses for transfers to countries without an adequacy decision) [TO VERIFY ON PUBLICATION DATE];
- our professional advisers (accountant, lawyer) under a duty of confidentiality;
- authorities, when required by law.
6. Where data is stored and international transfers#
The service database is hosted by Cloudflare in the European Union (Cloudflare D1 with EU jurisdiction). Email delivery is handled by Brevo, an EU company.
Cloudflare, Inc. is a US company and operates a global network: requests may be received and processed by Cloudflare data centres outside the European Economic Area before reaching the database, and Cloudflare may access data for support and security. These transfers are covered by Cloudflare's certification under the EU-US Data Privacy Framework and, as a fallback, by the European Commission's Standard Contractual Clauses incorporated in Cloudflare's Data Processing Addendum [TO VERIFY ON PUBLICATION DATE].
[IF ENTITY IS IN THE UK: Transfers from the EEA to the United Kingdom are covered by the European Commission's adequacy decision for the UK.] [IF ENTITY IS IN THE EU: Transfers to the UK, if any, are covered by the same adequacy decision.]
7. Security#
Secret API keys and session tokens are stored as hashes. Licence keys and the private keys used to sign certificates are encrypted (AES-256-GCM). All traffic uses HTTPS. Access to production systems is limited to the operator of the service and protected by multi-factor authentication. See our Data Processing Agreement for the full list of security measures.
8. Your rights#
Under the GDPR [and the UK GDPR], you have the right to access, rectify and erase your data, to restrict or object to its processing, to data portability, and to withdraw your consent at any time without affecting prior processing. To exercise them, write to privacy@keyrail.tech. We will answer within one month.
You also have the right to lodge a complaint with a supervisory authority, in particular in the country where you live or work. Our UK supervisory authority is the Information Commissioner's Office (ico.org.uk). As we have no establishment in the European Union, you may also complain to the supervisory authority of your EU Member State (in France, the CNIL, www.cnil.fr).
Our representative in the European Union under Article 27 GDPR is [EU REPRESENTATIVE NAME AND ADDRESS].
9. Children#
Keyrail is a business service and is not directed at children.
10. Changes#
We will publish any change to this policy on this page with a new effective date, and notify account owners by email of material changes.
11. Contact#
MKYCAPITAL LTD, 71-75 Shelton Street, London WC2H 9JQ, United Kingdom. Email: privacy@keyrail.tech.