Your personal related data when using the Zalando zKey App

1. General Information and conditions of use

The Zalando zKey App (referred to as “zKey” in this policy) is a mobile phone application which will be available to employees on their mobile devices via Device Management and visitors can download zKey via the AppStore or PlayStore, resp.

zKey aims to assist employees and visitors to locate and find Zalando offices, meeting rooms, car parks and desks. zKey allows you to find the best way to your destination in the Zalando buildings covered by the App.

Use of zKey is voluntary and has no implications or consequences for your employment, work or function in your employing company or the Zalando Group in general.

If you choose to use zKey, you will be required to register (see section 2 “How can I register”). In using zKey you agree that your data may be used to the extent necessary as set out in this policy.

2. Who has access to zKey?

The following Zalando Users will have access:

2.1 Employees and workers of Zalando SE and affiliated companies who have a zalando.de e-mail address will be able to register.

2.2 Visitors will be provided guest registration details to access zKey.

3. How can I register?

Zalando Users are able to register, directly through the App which can be downloaded via Device Management or the AppStore or PlayStore.

Visitors must create a guest account in the Zalando Systems. Therefore it could be necessary to provide an email address and additional Information e.g. name, company and function which will be stored and documented within the Zalando systems.

4. What data is processed?

For the initial registration, the unique ID of your device and your Zalando email address are required.

For use of zKey in the basic setting:
device ID and timestamp of your device will be collected by beacons when you start your search. Beacons are receiving devices (located in and around Zalando SE offices) that record and process signals from mobile devices to help us identify registered users by matching unique device ID against our list of registered users as well as assist you in your navigation in the buildings. This will quickly provide you with information about your immediate surroundings in the area in which these beacons are located. Data about your location will only be used to process your navigation request. The transmission of the location data takes place via an encrypted connection and is pseudonymised. For the identification of your phone encrypted high standard security tokens will be used. Furthermore, we protect our websites and other systems against loss, destruction, access, alteration or distribution of your data by unauthorised persons through technical and organisational measures.

Your location data is also used to statistically evaluate the service in order to analyze the general situation of the building and rooms and to improve the service.

For use of Selectable Options:
You also have the opportunity to share with other users information about yourself such as your:
- location connected with additional information, like:
- a user name
- e-mail address
- a photo
- any additional information you are adding and generating yourself, like department, function, point of contact.
If you provide additional information, you can always deactivate all these selectable options at anytime.

Analytics data:
For the purpose of analyzing the functionality and security of zKey and to analyze the general room location situation in of the buildings. zKey, the app will use aggregated data that will not be connected to your user identity. For example: we analyze which routes are taken by the users of zKey and how effective and quickly routes are suggested to users.

5. What happens when I activate certain selectable Options?

If you choose to provide additional personal information about yourself via the Selectable Options, your data will be visible to all other users of zKey.

You are able to share your permanent or current locations (this could be your favorite area where people can meet you and can be identified as your ‘homezone’ or ‘favorite area’), your photo and job function to other users.

Your data will only be visible to other zKey users if you decide to upload and share your data. We will have no influence over what data you decide to show to others. You can always deactivate these options or change the uploaded information at anytime. In sharing information via the Selectable Options, you must not share inappropriate, explicit and/or offensive content. You must not share identities of other users. If they want to share personal information about them, they should register for access to zKey and create their own profile.

6. Who is processing my data?

The responsible controller for the purposes of Art. 4 (7) GDPR is Zalando SE, Valeska-Gert-Straße 5, 10243 Berlin (referred to as ‘ Zalando SE or we” in this policy). For further details: Imprint.

For running the application and processing your data we are using the technology and service of our system provider for zKey: Spaceti s.r.o. / Purkyňova 2121/3, Prague, Czechia, 110 00. Zalando SE has safeguarded processing of your personal data through a data processing agreement with Spaceti s.r.o.

7. What is the legal basis and purpose for processing my data?

On the legal basis of Art. 6 (1) a), 88 GDPR, § 26 BDSG (NEU) and for the purpose of Executing the zKey with your own mobile device to a freely selectable extent. Personal related data will only be used for this purpose.

8. Your rights according to GDPR:

Art. 13, 14 GDPR – Right to be informed, Art. 15 GDPR – Right of access to information: On request we will gladly inform you about the data stored about your person. The information is provided in text form. Contact see below, Art. 16 GDPR - the right of rectification, Art. 17 GDPR - the right of deletion, Art. 18 GDPR - the right to restrict processing, Art. 19 GDPR - notification, Art. 20 GDPR - the right to data transfer, Art. 21 GDPR – Right to object, Art. 22 GDPR - automated decisions in individual cases including profiling, Art. 23 GDPR - restrictions, Art. 77 GDPR - Right to lodge a complaint with a supervisory authority. The supervisory authority to which the complaint was submitted informs the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy. For your employer, this is the Berlin Commissioner for Data Protection and Freedom of Information. You can contact the data protection officer of Zalando SE at:

Datenschutz
Zalando SE
Valeska-Gert-Straße 5 ,
10243 Berlin,
Telefax: +49 (0)30 2759 46 93
E -Mail: datenschutz@zalando.de