Privacy Policy

1. Who Is Responsible for Your Personal Data?

The controller responsible for the processing of personal data through the Keep My Luggage Platform is:

Keep My Luggage
Legal entity: Zologic
Registered address: Martinus Nijhoffweg 44, 2548 EP, Netherlands
Company registration number: 55518079
Privacy contact: info@keepmyluggage.com

For the purposes of the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and other applicable data-protection legislation, Keep My Luggage acts as the data controller where it determines the purposes and means by which personal data is processed in connection with operation of the Platform, management of Bookings, administration of the Storage Host and City Operator networks, customer support, fraud prevention, security, accounting and other activities described in this Privacy Policy.

2. Categories of Individuals Whose Data We Process

Depending upon the manner in which you interact with Keep My Luggage, we may process personal data relating to Travellers who make or use Bookings, persons who communicate with customer support, Storage Hosts and their owners, employees or authorized representatives, prospective Storage Hosts who submit partnership applications, City Operators and prospective City Operators, persons who submit reviews or other feedback, persons who subscribe to communications where such functionality is offered, and individuals whose information must reasonably be processed in connection with fraud prevention, complaints, legal claims or regulatory compliance.

3. Personal Data We Collect

The categories of personal data collected by Keep My Luggage depend upon your relationship with us and the features of the Platform that you use. We do not necessarily collect every category described below from every individual.

3.1 Traveller and Booking Information

When you make or use a Booking, we may collect information including your name, email address, telephone number, selected Storage Location, city, booking date, scheduled drop-off and collection times, number of Bags, Booking Price, Booking Reference, QR code or other booking-verification identifier, booking status, payment status, cancellation or refund information, communications concerning the Booking and other information reasonably necessary to create, administer and complete the Storage Service.

3.2 Account Information

Where the Platform permits or requires creation of an account, we may process your username, email address, account identifier, account role, authentication information in protected form, account preferences, account status, login information and other information necessary to administer and secure the account. Passwords should be stored using secure one-way hashing mechanisms and are not intended to be available to Keep My Luggage personnel in readable form.

3.3 Storage Host Information

Where you apply to become or operate as a Storage Host, we may process your name, business name, email address, telephone number, business address, Storage Location address, geographical coordinates, operating hours, available storage capacity, pricing information, business registration information, tax information, identification or verification information where reasonably required, payment and payout information, bank account or IBAN details, earnings, commissions, payout history, reviews, communications and other information necessary to assess, establish and administer the Storage Host relationship.

3.4 City Operator Information

Where you apply to become or operate as a City Operator, we may process your name, contact details, allocated city or territory, account information, business information, contractual and operational records, Storage Host submissions and referrals, commission information, earnings, payout requests, payout history, bank account or IBAN information, tax information, communications and other information necessary for administration of the City Operator relationship.

3.5 Payment and Transaction Information

We process information concerning transactions conducted through the Platform, including the amount paid, currency, date and time, booking or transaction identifier, payment status, refunds and information received from our payment service providers. Payment card details may be collected and processed directly by an authorized payment service provider rather than stored by Keep My Luggage on its own systems.

3.6 Communications and Customer Support

When you communicate with Keep My Luggage, we may process the contents of emails, contact forms, support requests, complaints, claims, reviews and other communications, together with relevant contact information and technical or booking information required to investigate and respond to the matter.

3.7 Reviews and Feedback

Where you submit a rating, review or other feedback concerning a Storage Location or the Keep My Luggage service, we may process the review, rating, associated Booking Reference, submission date and information reasonably necessary to determine whether the review relates to a genuine transaction and complies with our applicable rules.

3.8 Technical and Usage Information

When you access the Platform, our systems may automatically process technical information including your Internet Protocol address, browser type, operating system, device type, requested URL, referring URL, date and time of requests, server response information, security events, session information and other technical data generated through normal operation of web servers and applications.

3.9 Location Information

Where location functionality is made available and you permit your device or browser to provide location information, we may process that information for the purpose of identifying relevant Storage Locations and improving search results. We may also derive an approximate geographical location from an Internet Protocol address for security, localization, fraud-prevention or service functionality purposes where permitted by applicable law.

4. Information We Ask You Not to Provide

Unless expressly requested for a lawful and necessary purpose, you should not provide Keep My Luggage with special categories of personal data concerning racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic information, biometric information used for unique identification, health information or information concerning a person’s sex life or sexual orientation. You should also avoid submitting unnecessary identification documents, financial credentials or other highly sensitive information through general contact forms, reviews or ordinary support communications.

5. Purposes and Legal Bases for Processing

Keep My Luggage processes personal data only where there is an appropriate legal basis under applicable data-protection law. Depending upon the processing activity, this may include performance of a contract, taking steps at the request of an individual before entering into a contract, compliance with a legal obligation, pursuit of legitimate interests, consent or another legal basis recognized by applicable law.

5.1 Providing and Administering Bookings

We process Traveller, booking, transaction and relevant contact information in order to search for available Storage Locations, create and confirm Bookings, process payments, generate Booking References and QR codes, provide Storage Location information, facilitate luggage drop-off and collection, communicate booking changes and administer cancellations and refunds. The principal legal basis for this processing is the performance of a contract or taking steps requested by the Traveller before entering into a contract.

5.2 Providing Information to the Storage Host

We may disclose to the Storage Host the personal and booking information reasonably necessary for the Storage Host to identify the Booking, verify the Traveller’s entitlement to use the Storage Service, accept and return Luggage, address operational issues and comply with applicable legal obligations. This processing is generally necessary for performance of the Booking and our legitimate interest in operating a secure and functional storage marketplace.

5.3 Payment Processing

We process transaction information and communicate with payment service providers for the purpose of authorizing payments, confirming transactions, issuing refunds, detecting fraudulent activity and maintaining appropriate financial records. Depending upon the particular processing activity, the legal basis may be performance of a contract, compliance with legal obligations or our legitimate interests in preventing fraud and protecting the financial integrity of the Platform.

5.4 Storage Host and City Operator Administration

We process Storage Host and City Operator information in order to assess applications, create and administer accounts, manage locations and territories, administer commissions and payouts, provide operational functionality, communicate concerning the commercial relationship, maintain financial and tax records, investigate disputes and enforce applicable agreements. The legal bases for such processing include performance of the relevant agreement, steps taken before entering into an agreement, compliance with legal obligations and our legitimate interests in operating and protecting the Keep My Luggage network.

5.5 Customer Support

We process contact information, booking information and communications in order to respond to questions, provide assistance, investigate complaints, resolve operational problems, process legitimate claims and maintain records concerning customer-service interactions. The legal basis may be performance of a contract or our legitimate interest in providing effective support and maintaining the quality and integrity of our services.

5.6 Fraud Prevention and Security

We may process account information, booking activity, transaction information, Internet Protocol addresses, device information, security logs and other relevant data for the purpose of identifying suspicious activity, preventing payment fraud, detecting account abuse, protecting Storage Hosts and Travellers, preventing unauthorized access, investigating security incidents and enforcing our Terms and Conditions. This processing is based principally upon our legitimate interests in protecting our users, systems, property and business against fraud, misuse and security threats and, where applicable, compliance with legal obligations.

5.7 Compliance with Law and Legal Claims

We may process and preserve personal data where reasonably necessary to comply with tax, accounting, regulatory, law-enforcement or other legal obligations, respond to lawful requests from competent authorities, establish or defend legal claims, enforce contractual rights, investigate suspected unlawful activity or protect the rights and safety of Keep My Luggage, its users or third parties. The applicable legal basis may be compliance with a legal obligation or our legitimate interest in protecting and enforcing legal rights.

5.8 Service Improvement and Analytics

We may process technical, usage and aggregated information for the purpose of understanding how the Platform is used, identifying technical problems, improving performance, developing functionality, measuring demand for Storage Locations and improving the Traveller, Storage Host and City Operator experience. Where analytics technologies require consent under applicable privacy or electronic-communications law, such technologies will be used on the basis of the consent choices made available to the user.

5.9 Marketing Communications

Where Keep My Luggage sends promotional communications, we will do so only where a lawful basis exists, including consent where required by applicable law or another lawful basis permitted for communications concerning similar services to existing customers. Recipients may withdraw consent or object to direct marketing at any time using the unsubscribe mechanism provided in the communication or by contacting Keep My Luggage.

6. Payment Processing and Stripe

Keep My Luggage may use Stripe or another authorized payment service provider to process payments made through the Platform. Where payment information is entered directly into a payment provider’s secure payment interface, the provider may collect and process payment card details directly and Keep My Luggage may receive only the transaction information, payment status, identifiers and limited payment information necessary to administer the Booking.

The payment service provider processes personal data in accordance with its own legal obligations and privacy documentation. Keep My Luggage does not require access to complete payment-card credentials where the payment architecture permits those credentials to be handled directly by the payment provider.

7. Storage Host and City Operator Bank Information

Bank account, IBAN, payout and related financial information supplied by Storage Hosts and City Operators is processed solely to the extent reasonably necessary to administer commissions, payouts, financial reconciliation, accounting, fraud prevention and applicable legal or tax obligations. Such information is not intended to be displayed publicly or disclosed to Travellers and access should be restricted to authorized personnel and service providers requiring the information for legitimate operational purposes.

8. Location Privacy and Storage Host Addresses

Keep My Luggage may intentionally restrict public access to the precise address, telephone number and geographical coordinates of a Storage Host before a confirmed Booking. Before booking, the Platform may instead display the city, approximate area or approximate geographical position of the Storage Location together with information necessary for the Traveller to evaluate the service.

Following successful completion of a qualifying Booking, precise location information may be disclosed to the Traveller where necessary to enable the Traveller to reach the Storage Location and receive the booked Storage Service. Such information is provided for the purpose of performing the Booking and must not be systematically extracted, commercially exploited or used to circumvent the Keep My Luggage Platform.

9. Who May Receive Personal Data?

Keep My Luggage does not sell personal data merely for monetary consideration. Personal data may, however, be disclosed to recipients where reasonably necessary for the purposes described in this Privacy Policy and where an appropriate legal basis exists.

Recipients may include the Storage Host responsible for a confirmed Booking; payment processors and financial service providers; hosting, infrastructure and information-technology providers; email and communications providers; professional advisers such as accountants, auditors and lawyers; fraud-prevention and security providers; analytics providers where permitted by applicable law and the user’s consent choices; City Operators where access to specific information is legitimately required for authorized operational functions; competent courts, law-enforcement bodies, tax authorities and other public authorities where disclosure is legally required; and prospective purchasers, investors or successors where necessary in connection with a legitimate corporate transaction and subject to appropriate confidentiality and legal safeguards.

We seek to provide each recipient only with the personal data reasonably necessary for the relevant purpose and require service providers acting on our behalf to process personal data consistently with applicable contractual and data-protection obligations.

10. Storage Hosts as Recipients of Traveller Data

A Storage Host may receive information concerning a Traveller and Booking where that information is necessary to perform the Storage Service. Storage Hosts must not use Traveller information obtained through Keep My Luggage for unrelated advertising, sale to third parties, unauthorized profiling or other purposes incompatible with the reason for which the information was disclosed.

A Storage Host may have independent legal obligations concerning information processed within its own business operations. Where a Storage Host independently determines the purposes and means of processing personal data outside the instructions and functionality provided by Keep My Luggage, the Storage Host may itself become responsible for complying with applicable data-protection obligations in relation to that processing.

11. City Operator Access to Personal Data

A City Operator shall receive access only to information reasonably required to perform the functions authorized under the applicable City Operator relationship. City Operators must maintain the confidentiality of personal data, implement reasonable security measures, refrain from using personal information for unauthorized purposes and comply with applicable data-protection obligations and contractual restrictions.

City Operators shall not receive unrestricted access to Traveller payment credentials, Storage Host bank information or other highly sensitive data merely because they administer a particular city or territory, and access to such information should be limited according to operational necessity and authorization.

12. International Transfers of Personal Data

Because Keep My Luggage may use service providers or operate Storage Host and City Operator relationships in more than one country, personal data may in certain circumstances be processed in or transferred to a country other than the country in which it was originally collected.

Where personal data protected by the GDPR or equivalent legislation is transferred outside the European Economic Area or another jurisdiction imposing international-transfer restrictions, Keep My Luggage will use an appropriate lawful transfer mechanism where required, which may include an adequacy decision, approved standard contractual clauses or another mechanism recognized under applicable data-protection law.

13. How Long We Retain Personal Data

Keep My Luggage retains personal data only for as long as reasonably necessary for the purposes for which it was collected and for any additional period required or permitted by applicable law. Different categories of personal data may therefore be retained for different periods.

Booking and transaction records may be retained for the period necessary to administer the Booking and thereafter for accounting, tax, fraud-prevention, dispute-resolution and legal-claims purposes; Storage Host and City Operator contractual and payout records may be retained throughout the applicable commercial relationship and for an appropriate period thereafter; support communications may be retained for the period reasonably necessary to resolve the matter and maintain appropriate records; and technical security logs may be retained for a period proportionate to the security and fraud-prevention purposes for which they are maintained.

Where a legal obligation requires information to be retained for a specified period, a request for erasure may not require deletion before expiry of that mandatory retention period. When personal data is no longer required, we will take reasonable steps to delete, anonymize or otherwise dispose of it securely.

14. Cookies and Similar Technologies

The Platform may use cookies, local storage and comparable technologies that are technically necessary for functions such as security, session management, authentication, booking functionality and user preferences. We may also use analytics, advertising or other non-essential technologies where permitted by applicable law.

Where applicable law requires consent before non-essential cookies or similar technologies may be stored or accessed, Keep My Luggage will provide an appropriate mechanism through which users can make and subsequently modify their choices. Further information concerning individual cookies, providers, purposes and retention periods should be provided in a separate Cookie Policy or cookie-preference interface where such technologies are deployed.

15. Security of Personal Data

Keep My Luggage implements technical and organizational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access and other forms of unlawful processing. Depending upon the nature of the information and systems involved, these measures may include encrypted network communications, access controls, authentication mechanisms, restricted administrative privileges, secure payment-provider integrations, software updates, logging, backups and other reasonable security practices.

Notwithstanding these measures, no Internet-based service, computer system or method of electronic storage can be guaranteed to be completely secure. In the event of a personal-data breach, Keep My Luggage will assess the circumstances and comply with applicable obligations concerning investigation, mitigation, regulatory notification and communication to affected individuals where required by law.

16. Your Rights Under the GDPR

Where the GDPR applies to the processing of your personal data, and subject to the conditions and limitations established by applicable law, you may have the right to obtain confirmation as to whether personal data concerning you is being processed and obtain access to that data; request correction of inaccurate or incomplete personal data; request erasure of personal data in circumstances in which the right to erasure applies; request restriction of processing; object to processing based upon legitimate interests; object at any time to processing for direct-marketing purposes; receive certain personal data in a structured, commonly used and machine-readable format and transmit that data to another controller where the right to data portability applies; and withdraw consent at any time where processing is based upon consent, without affecting the lawfulness of processing carried out before withdrawal.

You may also have rights concerning decisions based solely upon automated processing that produce legal effects or similarly significantly affect you, where the conditions established by applicable law are satisfied.

17. Exercising Your Privacy Rights

Requests concerning access, correction, deletion, restriction, portability, objection, withdrawal of consent or other data-protection rights may be submitted using the privacy contact details specified in this Privacy Policy. To protect personal data against unauthorized disclosure or deletion, Keep My Luggage may take reasonable steps to verify the identity and authority of a person submitting a request before acting upon it.

We will respond to valid requests within the period required by applicable law. Certain rights are subject to statutory exceptions and limitations, and we may retain information notwithstanding an erasure request where retention is required to comply with law, establish or defend legal claims, prevent fraud or satisfy another lawful ground for continued processing.

18. Right to Object

Where personal data is processed on the basis of our legitimate interests, you may have the right to object to that processing on grounds relating to your particular situation. Where personal data is processed for direct marketing, you have the right to object to such processing at any time, including profiling to the extent that it is related to direct marketing.

19. Right to Withdraw Consent

Where processing is based upon your consent, you may withdraw that consent at any time. Withdrawal of consent shall not affect the lawfulness of processing undertaken on the basis of consent before its withdrawal and shall not prevent continued processing where another lawful basis independently applies.

20. Right to Lodge a Complaint

If you believe that your personal data has been processed in violation of applicable data-protection law, you have the right to lodge a complaint with the competent data-protection supervisory authority, including, where the GDPR applies, the supervisory authority of the European Union or European Economic Area Member State in which you habitually reside, work or where the alleged infringement occurred.

We encourage individuals to contact Keep My Luggage first where appropriate so that we have an opportunity to investigate and address the concern, although doing so does not limit your right to approach a competent supervisory authority.

21. Children

The Keep My Luggage booking service is not intended to enable children to independently enter into storage contracts where they do not possess the legal capacity to do so. Persons making Bookings must satisfy the eligibility requirements specified in our Terms and Conditions. We do not knowingly seek to collect personal data from children for independent use of the booking service contrary to applicable law.

22. Third-Party Websites and Services

The Platform may contain links to third-party websites, maps, payment services, social networks or other external services. The privacy practices of independent third parties are governed by their respective privacy notices, and Keep My Luggage is not responsible for the manner in which an independent third party processes personal data outside the circumstances in which that party processes information on our behalf.

23. Business Transfers

If Keep My Luggage is involved in a merger, acquisition, corporate restructuring, financing, sale of assets or transfer of all or part of its business, personal data may be disclosed to professional advisers, prospective counterparties and successors where reasonably necessary for the transaction and subject to applicable confidentiality and data-protection requirements. Where required by law, affected individuals will be informed of material changes concerning the controller of their personal data.

24. Changes to This Privacy Policy

We may update this Privacy Policy where necessary to reflect changes to the Keep My Luggage Platform, our processing activities, service providers, Storage Host or City Operator arrangements, applicable law or regulatory guidance. The current version will be published on the Platform together with its effective or last-updated date, and material changes may additionally be communicated by email, account notification or another reasonable method where required or appropriate.

25. Contact Us

If you have questions concerning this Privacy Policy, wish to exercise a data-protection right or wish to raise a concern concerning the processing of your personal data, you may contact:

Keep My Luggage
Legal entity: Zologic
Registered address: Martinus Nijhoffweg 44, 2548 EP, Netherlands
Privacy email: info@keepmyluggage.com