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DATA PROTECTION DECLARATION

This data protection notice (the "Data Protection Notice") describes the principles according to which Keys Distribution GmbH (hereinafter "we" or "us") processes personal data collected via the website www.key.express (hereinafter "the Website") or in any other way by Keys Distribution GmbH. In particular, it informs you about what personal data we collect, for what purposes it is processed, to whom it may be disclosed, how long we keep it and what rights and options you may have in connection with the use of your personal data. "Personal data" means any information about an identified or identifiable natural person, such as name, address, email address, online identifier or telephone number. All personal data collected by us via the Website or otherwise will be processed in accordance with the legal provisions of the Swiss Federal Act on Data Protection ("FADP"), the Ordinance to the Swiss Federal Act on Data Protection ("FADP"), the Telecommunications Act ("TCA") and other data protection provisions of Liechtenstein or EU law that may be applicable, in particular the General Data Protection Regulation ("GDPR").

We collect and process personal data carefully and for the purposes described in this Data Protection Notice. In accordance with applicable law, we may also use your personal data in ways other than those described in this Data Protection Notice. In this case, we will provide specific privacy notices or statements at the time of collection and may seek your consent. We always make reasonable efforts to collect information in anonymous or pseudonymous form so that we cannot identify you. Personal information will not be sold or shared with third parties except as noted in this Data Protection Notice. In order for you to know what personal data we collect from you and for what purposes we use it, please take note of the information below.

OVERVIEW

WHO IS RESPONSIBLE FOR YOUR PERSONAL DATA?

WHAT DATA DO WE PROCESS WHEN YOU VISIT OUR WEBSITE?

WHAT DATA DO WE COLLECT WHEN YOU PURCHASE PRODUCT KEY(S) THROUGH OUR ONLINE STORE?

WHAT DATA DO WE COLLECT WHEN YOU REGISTER WITH US AS A CUSTOMER AND CREATE AN ACCOUNT?

WHAT OTHER DATA DO WE PROCESS IN THE COURSE OF OUR BUSINESS ACTIVITIES?

WHAT DATA DO WE COLLECT IF YOU CONTACT US?

WHAT DATA DO WE PROCESS FOR ADVERTISING PURPOSES?

WHAT DATA DO WE COLLECT WHEN YOU REGISTER FOR OUR NEWSLETTER?

WHAT ARE COOKIES? DO WE NEED COOKIES?

DO WE NEED TRACKING TOOLS? WHAT ARE TRACKING TOOLS?

WHAT IS GOOGLE ANALYTICS?

reCAPTCHA

LINKS AND SOCIAL MEDIA PLUG-INS

WHO DO WE SHARE YOUR PERSONAL DATA WITH?

TRANSFER OF PERSONAL DATA ABROAD

HOW LONG DO WE STORE INFORMATION ABOUT YOU?

DATA SECURITY

WHAT RIGHTS DO YOU HAVE?

APPLICABLE LAW AND VENUE

QUESTIONS ABOUT DATA PROTECTION?

CHANGES TO OUR PRIVACY POLICY

WHO IS RESPONSIBLE FOR YOUR PERSONAL DATA

Keys Distribution GmbH is the operator of the Website keys.express. Keys Distribution GmbH is therefore responsible for the collection, processing and use of your personal data and the compatibility of the data processing with the applicable data protection legislation.

The responsible person in the sense of the data protection legislation for the online store is

Keys Distribution GmbH

Technopark Liechtenstein

Schaanerstrasse 27

9490 Vaduz, Liechtenstein

Phone:      +423 7989130

E-mail:      welcome@ keys.express

Website:   www.keys.express

Keys Distribution GmbH determines the purposes and means of the processing of your personal data and is therefore responsible for the processing and use of your personal data in accordance with this Data Protection Notice.

If you have any questions regarding data protection, you can contact us at the e-mail address [email protected]

WHAT DATA DO WE PROCESS WHEN YOU VISIT OUR WEBSITE?

When you visit our Website, our servers temporarily store every access in a log file.

The following technical data is collected and stored by us without your intervention, as is generally the case with every connection to a web server:

    • the IP address of the requesting computer;
    • the name of the owner of the IP address range (usually your Internet access provider);
    • the date and time of the access;
    • the website from which the access was made (referrer URL), if applicable with the search word used;
    • the name and URL of the file accessed;
    • the status code (e.g. error message);
    • the operating system of your computer;
    • the browser you are using (type, version and language);
    • the transmission protocol used (e.g. HTTP/1.1); and
    • if applicable, your user name from a registration/authentication.

The collection and processing of this data is intended to enable the use of our Website (connection establishment), to ensure system security and stability on a permanent basis and to enable the optimization of our internet offering, as well as for internal statistical purposes so that trends can be identified on the basis of which we can improve our offerings accordingly. This is our legitimate interest in data processing. The IP address is also evaluated together with the other data in the event of attacks on the network infrastructure or other unauthorized or abusive website use for the purpose of clarification and defense and, if necessary, used in the context of criminal proceedings for identification and civil and criminal action against the users concerned. We have a legitimate interest in such data processing in order to prevent unauthorized access in the future and to improve our system stability accordingly.

WHAT DATA DO WE COLLECT WHEN YOU PURCHASE PRODUCT KEY(S) THROUGH OUR ONLINE STORE?

You have the possibility to obtain Product Key(s) directly via our Website as a registered customer, via your customer account, via your social media account (e.g. Google Login, LinkedIn Login or with your Apple Login) or as a guest without registration.

For this purpose, we require the following mandatory information:

    • Email address, password, address, country; and
    • Payment information.

We use this data as well as additional information voluntarily provided by you (e.g. company name, address, voucher/discount code) only to be able to offer you the product keys in the best possible way and, if necessary, to deliver them. The processing of this data is therefore necessary for the implementation of pre-contractual and contractual measures or is in our legitimate interest to provide you with a comprehensive service.

If you register or log in via your social media account (e.g. Google, LinkedIn or Apple), you do not have to remember users and passwords for various online services. Once you sign in, you can use your social media account to sign in to your keys.express account. You can also unlink these accounts at any time by either adjusting your privacy settings or social media profile, or disconnecting from your social media platform through the "My Profile" section on your account page.  When you log in to a social media account and click on the [sign-in or login button] of your social media account (e.g. Google, LinkedIn or Apple), you will be automatically redirected to the respective social media platform where you can log in using the username and password of the respective social media account. This will link your social media profile to our Website or services. Typically, your social media provider will notify you of what information may be shared with Keys Distribution GmbH. This may include the following data (as authorized by you to your social media provider):

    • Email address, age, or profile pictures stored in your account.

This data is used to set up, provide and personalize your account. Please note that your social media provider also receives data about our website services, including what you are doing. For the purpose and scope of the data collection and the further processing and use of the data by the social media provider, as well as your rights in this regard and setting options for protecting your privacy, please refer to the privacy policy of your social media provider.

WHAT DATA DO WE COLLECT WHEN YOU REGISTER WITH US AS A CUSTOMER AND CREATE AN ACCOUNT?

You have the possibility to open a customer account on our Website, through which you can easily use our online store as well as the associated services. For this purpose, we require the following mandatory information:

    • E-mail address; and
    • Payment information.

We use this data as well as additional information voluntarily provided by you (e.g. title, first name, last name, date of birth, company, VAT ID, address, country, language) only to be able to offer and deliver the product keys to you in the best possible way.

The processing of this data is therefore necessary for the implementation of pre-contractual and contractual measures or is in our legitimate interest to offer you a comprehensive service. Processing and use of data by the social media provider as well as your rights in this regard and setting options to protect your privacy, please refer to the privacy policy of your social media provider.

WHAT OTHER DATA DO WE PROCESS IN THE COURSE OF OUR BUSINESS ACTIVITIES?

What data do we collect when you obtain product keys directly from us?

You have the option of contacting us directly in person, for example by e-mail or telephone, to obtain product keys. For this we need the following information:

    • E-mail address; or
    • Postal address; and
    • Payment information.

We use this data as well as additional information voluntarily provided by you (e.g. company name, name, voucher/discount code) in order to be able to offer and deliver the product keys to you in the best possible way. The processing of this data is therefore necessary for the implementation of pre-contractual and contractual measures or is in our legitimate interest to offer you a comprehensive service.

WHAT DATA DO WE COLLECT IF YOU CONTACT US?

You have the opportunity to contact us and communicate with us, for example, by contact form, e-mail, telephone or other means.

For this we need the following information:

    • First name;
    • Name;
    • E-mail address;
    • Telephone number;
    • Country;
    • Message or comment.

We use this data as well as additional data provided by you (in particular company and address) only to be able to answer your contact request in the best possible and personalized way. The processing of this data is therefore in our legitimate interest to provide you with a professional and comprehensive service.

WHAT DATA DO WE PROCESS FOR ADVERTISING PURPOSES?

We use data that is made publicly available on the internet or that we have otherwise lawfully obtained in order to draw the attention of existing customers and potential new business customers to our offer. For this purpose, we process the following information:

    • E-mail address, if available; and
    • Business address.

We use this data, as well as additional business data available on the internet, to make direct advertising for our products. Unless we have a customer's consent to receive direct mail, we use only publicly available information about the company. Such information may contain personal data. The processing of publicly available information on companies (e.g. business address) and any personal data contained therein is in our legitimate interest to be able to conduct direct advertising.

As a data subject (natural or legal person), you may object to such processing free of charge at any time by contacting us at the e-mail address [email protected]

WHAT DATA DO WE COLLECT WHEN YOU REGISTER FOR OUR NEWSLETTER?

You have the option to subscribe to our newsletter. We use this exclusively to send you the subscribed information by e-mail. For this purpose, we need the following information:

    • E-mail address.

Based on your explicit consent, we will send you our newsletter on a regular basis. You can revoke this consent at any time; you will find a corresponding link in each newsletter.

WHAT ARE COOKIES? DO WE NEED COOKIES?

Cookies help in many aspects to make your visit to our Website easier, more pleasant and more meaningful. Cookies are information files that your web browser automatically stores on your computer's hard drive when you visit our Website. In particular, we use the following cookies:

    • Technically necessary cookies;
    • Performance cookies;
    • Functionality cookies; and
    • Advertising cookies.

For detailed information on the cookies we use, please refer to our Cookie Policy.

We use these cookies, for example, to be able to identify you as a registered user after you have registered on the Website, without you having to log in again when you call up another sub-page.

Most internet browsers accept cookies automatically. However, you can configure your browser so that no cookies are stored on your computer or a message always appears when you receive a new cookie.

Deactivating cookies may mean that you cannot use all the functions of our Website.

DO WE NEED TRACKING TOOLS? WHAT ARE TRACKING TOOLS?

For the purpose of demand-oriented design and continuous optimization of our Website, we use the web analytics service of Google Analytics. Cookies are used in this context.

The information generated by the cookies about your use of this Website is transmitted to the servers of the providers of these services, stored there and processed for us. In addition to the data listed under the heading "What data do we process when you visit our Website?", we may thereby obtain the following information:

    • Navigation path that a visitor takes on the Website;
    • The time spent on the Website or sub-page;
    • The sub-page on which the website is left;
    • The country, region or city from which access is made;
    • Terminal device (type, version, color depth, resolution, width and height of the browser window); and
    • Returning or new visitor.

The information is used to evaluate the use of the Website, to compile reports on website activity and to provide other services related to website and internet use for the purposes of market research and demand-oriented design of this Website. This information may also be transferred to third parties if this is required by law or if third parties process this data on our behalf.

WHAT IS GOOGLE ANALYTICS?

This Website uses Google Analytics, a web analytics service provided by Google Ireland Limited (hereinafter "Google").

Google Analytics is used exclusively with the extension "anonymizeIP" on this Website. This extension ensures anonymization of the IP address by shortening and excludes a direct personal reference.

Through the extension, the IP address is shortened beforehand by Google within member states of the European Union or in other contracting states of the Agreement on the EEA or Switzerland. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. The IP address transmitted by the corresponding browser within the scope of Google Analytics is not merged with other Google data.

On behalf of the site operator, Google will use the information obtained to evaluate the use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to the site operator. The legitimate interest in such data processing lies in the optimization of this Website, the analysis of the use of the Website and the adaptation of the content. This usage data also forms the basis for statistical, anonymous evaluations, so that trends can be identified, which we can use to improve our offers accordingly.

The collection by Google Analytics can be prevented by adjusting the cookie settings for this Website. The collection and storage of the IP address and the data generated by the cookies can also be revoked at any time with effect for the future.

The corresponding browser plugin can be downloaded and installed at the following link: https://tools.google.com/dlpage/gaoptout.

The site visitor can prevent the collection by Google Analytics on this Website by clicking on the following link. An opt-out cookie will be set, which will prevent future collection of data when visiting this Website.

Further information on data use by Google, settings and opt-out options can be found in Google's privacy policy (https://policies.google.com/privacy) and in the settings for the display of advertising by Google (https://adssettings.google.com/authenticated).

reCAPTCHA

To protect your requests via internet form, we use the service reCAPTCHA of the company of Google. The query serves to distinguish whether the input is made by a human being or improperly by automated, machine processing. The query includes the sending of the IP address and possibly other data required by Google for the service reCAPTCHA to Google. For this purpose, your input is transmitted to Google and used there. However, your IP address will be shortened beforehand by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area or Switzerland. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of this service. The IP address transmitted by your browser as part of reCAPTCHA will not be merged with other data from Google. The deviating data protection provisions of the Google company apply to this data.

LINKS AND SOCIAL MEDIA PLUG-INS

We have included links on our Website to the websites of some of our partners and to other relevant websites. If you access such links from our Website, data may be passed on to the owner of the website you are accessing. We have no influence on the data processing by operators of such websites.

In addition, we also use social media plug-ins such as Facebook, Twitter, LinkedIn and YouTube. We have no influence on the processing activities of these social media platforms. Therefore, please read the respective privacy policies before accessing the platform(s).

Please note that when you visit our Website, social media plug-ins can establish a direct connection between your browser and the server of the respective social media provider. The provider thereby receives the information that you have visited our site with your IP address. If you do not want a provider to be able to assign your visit to our site to your user account, please log out of your user account before visiting.

WHO DO WE SHARE YOUR PERSONAL DATA WITH?

We take the necessary measures to ensure that only our authorized personnel and our auxiliary persons who have the necessary knowledge, and to the extent necessary (according to the need-to-know principle), have access to your personal data in order to fulfill the purposes for which your personal data was collected.

We will only disclose your personal data to other third parties if you have expressly consented to this, if there is a legal obligation to do so or if this is necessary to enforce our rights, in particular to enforce claims arising from the contractual relationship. In addition, we share your data with third parties to the extent necessary in the context of the use of the Website and the execution of contracts (including outside the website), namely the processing of your orders.

We choose our partners and processors carefully and only when we have sufficient guarantees that they have appropriate technical and organizational measures in place in accordance with legal requirements. Our processors can only process personal data upon documented instructions from us. They are all subject to confidentiality requirements and may only use your personal data to the extent necessary to fulfill the purpose for which your personal data was collected, unless otherwise required by law.

We may disclose your personal data to the following possible categories of recipients in accordance with the purposes and legal bases for processing described above, to the extent necessary for the intended data processing:

    • Other companies in the Group
    • Our trusted processors (e.g., IT service providers);
    • Payment service providers, financial institutions;
    • Our consultants and other business partners;
    • The public, media, including social media sites of ours;
    • Administrative agencies, courts and other competent authorities;
    • Other parties to potential or actual legal proceedings.

We work with the following partners in connection with web hosting and payment processing:

Who is our web host?

A service provider to whom personal information collected through the Websites is or may be disclosed or accessed is our web host Nexcess, Cogent Data Center, Haarlemerstraatweg 133 - 135, 1165 MK Amsterdam, The Netherlands. The Websites are hosted on servers in the Netherlands.

Who are our factoring or payment providers?

We offer on our Website the possibility to pay via different payment providers. For this purpose, we work together with the providers listed below.

    • Bank in CH: PostFinance AG, Mingerstrasse 20, 3030 Bern
    • Bank in LI: Liechtenstein State Bank
    • Kauf auf Rechnung: in Eigenverwaltung
    • Kreditkarten: Mastercard, Visa und American Express über Payrexx AG
    • PayPal: PayPal Pte Ltd Singapur

By selecting the respective payment option, you agree that we may transmit personal data to the provider of the payment service. The transmission of personal data is for the purpose of payment administration. For the handling of personal data, please refer to the privacy policy of the respective payment provider.

TRANSFER OF PERSONAL DATA ABROAD

We are entitled to transfer your personal data for the purpose of the data processing described in this Data Protection Notice also to third party companies (contracted service providers and other business partners) at data locations abroad, around the world. These are obligated to data protection to the same extent as we are.

If the level of data protection in a country does not correspond to that in Switzerland or the EU, we ensure through contractual guarantees (e.g. based on EU standard clauses) and through technical and organizational measures that the protection of your personal data corresponds to that in Switzerland or the EU at all times. Furthermore, we may transfer your personal data abroad with your express consent, for the conclusion or performance of a contract with you or in connection with the establishment, exercise or enforcement of legal claims.

Does the same protection exist when data is transferred to the USA?

For the sake of completeness, we would like to point out for users who are resident or domiciled in Switzerland as well as in the EU that there are monitoring measures in place in the USA by US authorities which generally allow the storage of all personal data of all persons whose data has been transferred from Switzerland to the USA. This is done without any differentiation, limitation or exception based on the objective pursued and without any objective criterion that would make it possible to limit the access of the U.S. authorities to the data and their subsequent use to very specific, strictly limited purposes that are capable of justifying the intrusion associated both with the access to these data and with their use. In addition, we would like to point out that in the USA there are no legal remedies available to data subjects from Switzerland that would allow you to gain access to the data concerning you and to obtain its correction or deletion, or that there is no effective judicial legal protection against general access rights of US authorities. We explicitly draw your attention to this legal and factual situation in order to enable you to make an appropriately informed decision to consent to the use of your data.

We would also like to point out to users residing in a member state of the EU, the EEA or Switzerland that the USA does not have an adequate level of data protection from the perspective of the European Union as well as Switzerland - among other things due to the issues mentioned in this section. Insofar as we have explained in this Data Protection Notice that recipients of data (such as Google) are based in the USA, we will ensure through contractual arrangements with these companies that your data is protected with our partners with an appropriate level.

HOW LONG DO WE STORE INFORMATION ABOUT YOU?

We store personal data only for as long as it is necessary to use the above processing operations within the scope of our legitimate interest. For this reason, we will delete or anonymize personal data as soon as it is no longer necessary to achieve the purposes, but subject to (i) applicable legal or regulatory requirements to store personal data for a longer period of time (e.g., for tax or accounting reasons), or (ii) if we have an overriding interest (e.g., an interest for evidentiary reasons to establish, exercise and/or defend actual or potential legal claims, investigations or similar proceedings, including legal process we may enforce to preserve relevant information, or where we have an interest in non-personal analysis).

On this basis, we generally process personal data in compliance with the following rules and obligations:

    • We retain contractual data for longer periods, as this is required by statutory retention obligations. Retention obligations that oblige us to retain data result in particular from regulations on accounting, civil law and tax law. According to these regulations, business communication, concluded contracts and accounting vouchers must be kept for up to 10 years. As far as we do not need these data any more for the execution of the services for you, the data are blocked. This means that the data may then only be used for accounting and tax purposes.
    • For operational data containing data (e.g. logs, logs), we store personal data for a period of 3 - 6 months.
    • Personal data that is collected and generated in connection with a user account (e.g. your order history, discounts, orders and invoices) is generally stored by us until you request us to delete it or revoke your consent to store it.

DATA SECURITY

We have taken various technical and organizational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized use, disclosure or access, in particular where the processing involves the transmission of data over a network, and against all other unlawful forms of processing and misuse.

This Website uses SSL/TLS encryption for security reasons and to protect the transmission of confidential content, such as requests you send to us as the site operator. You can recognize an encrypted connection by the fact that the address line of the browser changes from "http://" to "https://" and by the lock symbol in your browser line.

If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

Keys Distribution GmbH may use third parties as processors to collect and process your personal data. The data processors we use will only process your personal data in accordance with our instructions and are required by law to take strict security precautions when handling personal data.

Unfortunately, the transmission of information over the Internet is not completely secure. Although we do our utmost to protect your personal data, we cannot guarantee the security of your data transmitted to us by electronic means (incl. e-mail); any transmission is at your own risk. For this reason, you are always free to submit your personal information to us by other means, such as by telephone. Once we have received your data, we apply strict procedures and rigorous security measures to prevent unauthorized access.

WHICH RIGHTS DO YOU HAVE?

You have a right to information, correction, deletion and restriction of processing as well as data portability.

You have the right to receive information about the personal data that we store about you upon request. In addition, you have the right to have incorrect data corrected and the right to have your personal data deleted, insofar as this does not conflict with a legal obligation to retain the data or an authorization that allows us to process the data.

You also have the right to demand that we return the data you have provided to us (right to data portability). Upon request, we will also transfer the data to a third party of your choice. You have the right to receive the data in a common file format.

You can contact us for the aforementioned purposes via the e-mail address [email protected]. In order to process your requests, we may, at our discretion, require proof of identity.

In many countries, you also have the right to file a complaint with the relevant data protection authority if you have concerns about how we process your data. For users located in Switzerland, the competent authority is the Federal Data Protection and Information Commissioner in Switzerland (http://www.edoeb.admin.ch). For users located in EU countries, you can find a list of supervisory authorities at

https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080

The aforementioned rights depend on the respective applicable data protection legislation and may therefore be either more limited or more comprehensive.

APPLICABLE LAW AND VENUE

What law do we apply? And where is the law applied?

This Data Protection Notice and the contracts concluded based on or in connection with this Data Protection Notice are governed by Liechtenstein law, unless the law of another country is mandatory applicable.

The place of jurisdiction is at the registered office of Keys Distribution GmbH in 9490 Vaduz, Liechtenstein, unless another place of jurisdiction is mandatory.

QUESTIONS ABOUT DATA PROTECTION?

Please, contact us!

If you have any questions or comments about our legal notices or data protection, please contact us at [email protected].

CHANGES TO OUR PRIVACY POLICY

This Data Protection Notice was last modified on 01/01/2024. This Data Protection Notice may be changed from time to time and without prior notice. Any changes to this Data Protection Notice will be effective when posted on the Website, unless otherwise noted. If we change the Data Protection Notice in a material way, we will notify you by email and/or prominent notice on our website or other appropriate means prior to the change becoming effective and update the "Effective Date" at the top of this page.

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