Privacy Policy


1) Introduction and Contact Details of the Controller

1.1 We are pleased that you are visiting our website and thank you for your interest. The following information will explain how we handle your personal data when you use our website. Personal data is any information that can be used to identify you personally.

1.2 The controller for data processing on this website, as defined by the General Data Protection Regulation (GDPR), is Kelly Burns, Software Key 24/7, 27 Coronation Street, TS13 4DW UK, England, Tel: +447947358991, Email: business@softwarekey247.com The controller is the natural or legal person who, alone or jointly with others, decides on the purposes and means of processing personal data.


2) Data Collection When Visiting Our Website

2.1 When you use our website for informational purposes only, i.e., if you do not register or otherwise provide us with information, we only collect data that your browser transmits to our server (so-called "server log files"). When you visit our website, we collect the following data, which is technically necessary for us to display the website to you:

Processing is carried out in accordance with Art. 6(1)(f) GDPR based on our legitimate interest in improving the stability and functionality of our website. The data will not be shared or used for any other purpose. However, we reserve the right to review the server log files retrospectively if there are specific indications of illegal use.

2.2 For security reasons and to protect the transmission of personal data and other confidential content (e.g., orders or inquiries to the controller), this website uses SSL or TLS encryption. You can recognize an encrypted connection by the string "https://" and the lock symbol in your browser line.


3) Hosting & Content Delivery Network

Microsoft Azure

We use the system of the following provider for hosting our website and displaying the pages: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA.

All data collected on our website is processed on the provider's servers.
We have concluded a data processing agreement with the provider, ensuring the protection of our website visitors' data and prohibiting unauthorized disclosure to third parties.

For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, ensuring compliance with the European data protection level based on an adequacy decision by the European Commission.


4) Cookies

To make visiting our website attractive and enable certain functions, we use cookies, which are small text files stored on your device. Some of these cookies are deleted automatically after closing the browser (so-called "session cookies"), while others remain on your device and allow us to recognize your browser on your next visit (so-called "persistent cookies"). In the latter case, you can find the storage duration in the cookie settings of your web browser.

If personal data is processed through individual cookies used by us, the processing is carried out either in accordance with Art. 6(1)(b) GDPR for the performance of the contract, in accordance with Art. 6(1)(a) GDPR in the event of consent given, or in accordance with Art. 6(1)(f) GDPR to protect our legitimate interests in the best possible functionality of the website and a customer-friendly and effective website visit design.

You can set your browser to inform you about the setting of cookies and individually decide on their acceptance or exclude the acceptance of cookies for certain cases or in general.

Please note that the functionality of our website may be restricted if cookies are not accepted.


5) Contacting Us

5.1 Trusted Shops

We use the services of the following provider for review reminders: Trusted Shops AG, Subbelrather Str. 15c, 50823 Cologne, Germany

Only with your explicit consent in accordance with Art. 6(1)(a) GDPR, we will transmit your email address and, if applicable, other customer data to the provider so that it can contact you via email with a review reminder.

You can revoke your consent at any time with future effect by contacting us or the provider.

We have concluded a data processing agreement with the provider, ensuring the protection of our website visitors' data and prohibiting unauthorized disclosure to third parties.

5.2 Trustpilot

We use the services of the following provider for review reminders: Trustpilot A/S, Pilestræde 58, 1112 Copenhagen, Denmark

Only with your explicit consent in accordance with Art. 6(1)(a) GDPR, we will transmit your email address and, if applicable, other customer data to the provider so that it can contact you via email with a review reminder.

You can revoke your consent at any time with future effect by contacting us or the provider.

We have concluded a data processing agreement with the provider, ensuring the protection of our website visitors' data and prohibiting unauthorized disclosure to third parties.

5.3 WhatsApp Business

We offer visitors to our website the opportunity to contact us via the messaging service WhatsApp, operated by WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. We use the "Business Version" of WhatsApp for this purpose.

If you contact us via WhatsApp in the context of a specific transaction (e.g., a placed order), we store and use the mobile number you use on WhatsApp, as well as – if provided – your first and last name, in accordance with Art. 6(1)(b) GDPR to process and respond to your request. Based on the same legal basis, we may ask you via WhatsApp to provide additional data (order number, customer number, address, or email address) to assign your request to a specific transaction.

If you use our WhatsApp contact for general inquiries (e.g., about the range of services, availability, or our website), we store and use the mobile number you use on WhatsApp, as well as – if provided – your first and last name, in accordance with Art. 6(1)(f) GDPR based on our legitimate interest in providing the requested information efficiently and promptly.

Your data will always be used solely to respond to your request via WhatsApp. It will not be shared with third parties.

Please note that WhatsApp Business has access to the address book of the mobile device we use for this purpose and automatically transfers phone numbers stored in the address book to a server of the parent company Meta Platforms Inc. in the USA. For the operation of our WhatsApp Business account, we use a mobile device whose address book only stores the WhatsApp contact data of users who have also contacted us via WhatsApp.

This ensures that every person whose WhatsApp contact data is stored in our address book has already consented to the transfer of their WhatsApp phone number from the address books of their chat contacts by accepting the WhatsApp terms of use on their device for the first time. The transfer of data from users who do not use WhatsApp and/or have not contacted us via WhatsApp is thus excluded.

For the purpose and scope of data collection and further processing and use of the data by WhatsApp, as well as your rights and settings options for protecting your privacy, please refer to WhatsApp's privacy policy: https://www.whatsapp.com/legal/?eea=1#privacy-policy

In the context of the aforementioned processing, data may be transferred to servers of Meta Platforms Inc. in the USA.

For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, ensuring compliance with the European data protection level based on an adequacy decision by the European Commission.

5.4 When contacting us (e.g., via contact form or email), personal data is processed exclusively for the purpose of processing and responding to your request and only to the extent necessary for this purpose.

If the data processing is carried out to implement pre-contractual measures taken at your request or, if you are already our customer, to execute the contract, the legal basis for this data processing is Art. 6(1)(b) GDPR.

We have a legitimate interest in responding to your requests efficiently and promptly in all other cases. The legal basis for data processing is then Art. 6(1)(f) GDPR.

Your data will be deleted if it can be inferred from the circumstances that the relevant facts have been conclusively clarified and if no statutory retention obligations conflict.


6) Data Processing When Opening a Customer Account and for Contract Execution

According to Art. 6(1)(b) GDPR, personal data will continue to be collected and processed if you provide it to us to execute a contract or open a customer account. Which data is collected can be seen from the respective input forms. Deleting your customer account is possible at any time and can be done by sending a message to the aforementioned controller's address. We store and use the data you provide for contract execution. After complete execution of the contract or deletion of your customer account, your data will be blocked concerning retention periods under tax and commercial law and deleted after these periods, unless you have expressly consented to further use of your data or we reserve the right to further data use permitted by law.


7) Use of Customer Data for Direct Advertising

7.1 Subscribe to our email newsletter

If you subscribe to our email newsletter, we will send you regular information about our offers. Mandatory information for sending the newsletter is only your email address. Providing further data is voluntary and will be used to address you personally. For sending the newsletter, we use the so-called double opt-in procedure. This means that we will only send you an email newsletter if you have explicitly confirmed that you consent to receive the newsletter. We will then send you a confirmation email asking you to confirm by clicking on a corresponding link that you want to receive newsletters in the future.

By activating the confirmation link, you give us your consent to use your personal data according to Art. 6(1)(a) GDPR. When you subscribe to the newsletter, we store your IP address entered by the Internet Service Provider (ISP), as well as the date and time of registration, to trace any potential misuse of your email address at a later date. The data collected by us when you subscribe to the newsletter will be used exclusively for advertising purposes via the newsletter. You can unsubscribe from the newsletter at any time via the link provided in the newsletter or by sending a corresponding message to the controller mentioned at the beginning. After unsubscribing, your email address will be immediately deleted from our newsletter distribution list unless you have expressly consented to further use of your data or we reserve the right to further data use permitted by law and about which we inform you in this declaration.

7.2 Newsletter dispatch via Brevo

Our email newsletters are sent via this provider: Brevo, a service provided by Sendinblue GmbH, Köpenicker Straße 126, 10179 Berlin, Germany

We share your email address and any other data mentioned in this privacy policy with the provider. The transfer is carried out according to Art. 6(1)(f) GDPR and serves our legitimate interest in using an effective, secure, and user-friendly newsletter system. The data you enter to receive the newsletter (e.g., email address) will be stored on the provider's servers in the EU.

The provider uses this information to send and statistically evaluate the newsletters on our behalf. For evaluation purposes, the sent emails contain so-called web beacons or tracking pixels, which represent single-pixel image files stored on our website. This allows us to determine whether a newsletter message has been opened and which links have been clicked. Additionally, technical information is collected (e.g., time of retrieval, IP address, browser type, and operating system). The data is collected exclusively pseudonymously and is not linked to your other personal data to prevent direct personal reference. This data is used exclusively for statistical analysis of newsletter campaigns. The results of these analyses can be used to better tailor future newsletters to the interests of recipients.

If you want to object to the data analysis for statistical evaluation purposes, you must unsubscribe from the newsletter.

We have concluded a data processing agreement with the provider, ensuring the protection of our website visitors' data and prohibiting unauthorized disclosure to third parties.


8) Data Processing for Order Processing

8.1 To process your order, we work with the following service provider(s), who support us wholly or partially in the execution of concluded contracts. Certain personal data is transmitted to these service providers according to the following information.

We share your payment details with the commissioned credit institution as part of the payment processing if this is necessary for payment processing. If we use payment service providers, we explicitly inform you below. The legal basis for the transfer of data is Art. 6(1)(b) GDPR.

8.2 Use of Payment Service Providers

PayPal

If you choose the PayPal payment method, the payment processing is carried out by PayPal (Europe) S.a.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter referred to as "PayPal"), to whom we transfer your provided information during the ordering process, along with the information about your order according to Art. 6(1)(b) GDPR. The transfer takes place exclusively for the purpose of processing payments and only to the extent necessary. For further information about PayPal's privacy policy, please visit: https://www.paypal.com/de/webapps/mpp/ua/privacy-full

8.3 Transfer of Personal Data to Shipping Service Providers

- DHL

If the delivery of goods is carried out by the transport service provider DHL (DHL Paket GmbH, Sträßchensweg 10, 53113 Bonn, Germany), we provide your email address and telephone number before delivering the goods according to Art. 6(1)(a) GDPR to coordinate a delivery date or to notify you about the delivery, only if you have explicitly consented to this during the ordering process. Otherwise, for delivery purposes according to Art. 6(1)(b) GDPR, we only share the name of the recipient and the delivery address with DHL. The data is transferred only to the extent necessary for the delivery of goods. In this case, prior coordination of the delivery date or delivery notification is not possible.

Consent can be revoked at any time with future effect to the above-mentioned controller or the transport service provider DHL.


9) Web Analysis Services

9.1 Google Analytics 4

This website uses Google Analytics 4, a service provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google"), to analyze website usage. When using Google Analytics 4, "cookies" are used by default. Cookies are text files stored on your device that allow analyzing your website usage. The information collected by cookies about your use of the website (including the IP address transmitted by your device and shortened by the last digits, see below) is usually transferred to a Google server and stored there. This can also result in transmission to the servers of Google LLC, based in the USA, and further processing of information there.

When using Google Analytics 4, the IP address transmitted by your device during your website use is always collected and processed by default and automatically in an anonymized manner so that all collected data excludes any direct personal reference. This automatic anonymization is carried out by shortening the IP address transmitted by your device by the last digits within the EU or EEA member states.

On our behalf, Google will use the information obtained to evaluate your use of the website, compile reports on website activities, and provide us with other services related to website and internet usage. The anonymized IP address transmitted by your browser as part of Google Analytics 4 is not combined with other Google data.

Google Analytics 4 enables us to generate statistics about the flow of visitors to our website as well as the demographics and interests of the visitors. User behavior of website visitors can also be used as a basis for creating and analyzing user groups, which can then be targeted by advertising measures. Data can also be linked across devices using a Google user ID to analyze website usage across all devices.

All processing described above, especially the setting of Google Analytics cookies for storing and reading information on the device you use to use the website, only takes place if you have given us your express consent according to Art. 6(1)(a) GDPR. Without your consent, Google Analytics 4 will not be used during your website visit. You can revoke your consent at any time with future effect. To exercise your right to revoke, please deactivate this service in the "cookie consent tool" provided on the website.

We have concluded an order processing agreement with Google, which ensures the protection of our website visitors' data and prohibits unauthorized disclosure to third parties.

Data transfers to the USA are based on the European Commission's standard contractual clauses (SCC). Further information about Google (Universal) Analytics 4 can be found here: https://policies.google.com/privacy?hl=en

9.2 - Google Optimize

This website also uses the web analysis service Google Optimize provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google"). Google Optimize analyzes the use of different versions of our website and helps us improve the user experience according to the behavior of our website users. Google Optimize is a sub-service of Google Analytics 4 (see section 9.1). Google Optimize uses cookies to allow website usage analysis. The information collected by cookies about your use of the website is usually transferred to a Google server and stored there. This can also result in transmission to the servers of Google LLC, based in the USA, and further processing of information there.

All processing described above, especially the setting of Google Optimize cookies for storing and reading information on the device you use to use the website, only takes place if you have given us your express consent according to Art. 6(1)(a) GDPR. Without your consent, Google Optimize will not be used during your website visit. You can revoke your consent at any time with future effect. To exercise your right to revoke, please deactivate this service in the "cookie consent tool" provided on the website.

Further information about Google Optimize and Google's privacy policy can be found here: https://policies.google.com/privacy?hl=en


10) Tools and Miscellaneous

10.1 Cookie Consent Tool

This website uses a cookie consent tool to obtain effective user consent for cookies and cookie-based applications requiring consent. The cookie consent tool is displayed to users as an interactive user interface on the website when accessing the page, where consent for certain cookies and cookie-based applications can be given by ticking the box. By using the tool, all cookies requiring consent are only loaded if the respective user grants consent by ticking the box. This ensures that such cookies are only set on the respective user's device if consent has been given.

The tool sets technically necessary cookies to save your cookie preferences. Personal user data is not processed in this context.

If, in individual cases, personal data (such as IP address) is processed to save, assign, or record cookie settings, it is done according to Art. 6(1)(f) GDPR based on our legitimate interest in legally compliant, user-specific, and user-friendly consent management for cookies and therefore in a legally compliant website design.

Further legal basis for processing is Art. 6(1)(c) GDPR. As the controller, we are subject to the legal obligation to make the use of technically unnecessary cookies dependent on the respective user's consent.

We have concluded an order processing agreement with the provider, ensuring the protection of our website visitors' data and prohibiting unauthorized disclosure to third parties.

Further information about the provider and the cookie consent tool used can be found in the respective user interface on our website.

10.2 Applications for Job Advertisements by Email

On our website, we advertise open positions that interested parties can apply for via email to the provided contact address.

To be included in the application process, applicants must provide us with all the personal data required for a well-founded and informed assessment and selection along with the application by email.

The required information includes general personal information (name, address, phone, or electronic contact) and performance-specific evidence of the qualifications required for a position. If necessary, health-related information may also be required, which must be given special consideration under labor and social law for the applicant's protection.

Upon receipt of the application sent via the provided email contact, the applicant's data will be stored and evaluated exclusively for the application purpose. During processing, the application will be forwarded to those responsible within our company. Further transfer to third parties does not take place.

The legal basis for this processing, including contacting for queries, is Art. 6(1)(b) GDPR (for processing in Germany in conjunction with Section 26(1) BDSG), according to which the application process is considered the initiation of an employment contract.

If special categories of personal data within the meaning of Art. 9(1) GDPR (e.g., health data such as information about severe disability) are requested from applicants, processing is carried out according to Art. 9(2)(b) GDPR to exercise rights and fulfill obligations under labor law, social security law, and social protection.

Cumulatively or alternatively, data processing can also be based on Art. 6(1)(f) GDPR based on our legitimate interest in effectively handling application submissions.

If the applicant is not selected during the evaluation described above or withdraws their application prematurely, their data transmitted by email and all electronic correspondence, including the original application email, will be deleted after six months at the latest following notification. This period is based on our legitimate interest in responding to any follow-up questions about the application and, if necessary, fulfilling our burden of proof obligations under regulations on equal treatment of applicants.

In the event of a successful application, the data provided will be further processed based on Art. 6(1)(b) GDPR (for processing in Germany in conjunction with Section 26(1) BDSG) for the purposes of the employment relationship.


11) Rights of the Data Subject

11.1 The applicable data protection law grants you comprehensive data subject rights (rights to information and intervention) toward the data controller regarding the processing of your personal data, which we inform you about below:

Right to information according to Art. 15 GDPR: You have the right to obtain information about your personal data processed by us, the purposes of processing, the categories of personal data processed, the recipients or categories of recipients to whom your data has been or will be disclosed, the planned storage period or the criteria for determining the storage period, the existence of a right to rectification, erasure, restriction of processing, objection to processing, complaint to a supervisory authority, the origin of your data if not collected from you by us, the existence of automated decision-making, including profiling and, if applicable, meaningful information about the logic involved and the scope and intended effects of such processing, and your right to be informed about the guarantees according to Art. 46 GDPR when your data is transferred to third countries;

Right to rectification according to Art. 16 GDPR: You have the right to demand the immediate correction of incorrect data concerning you and/or completion of your incomplete data stored by us;

Right to erasure according to Art. 17 GDPR: You have the right to demand the erasure of your personal data if the requirements of Art. 17(1) GDPR are met. However, this right does not exist if processing is necessary to exercise the right to freedom of expression and information, to fulfill a legal obligation, for reasons of public interest, or to establish, exercise, or defend legal claims;

Right to restriction of processing according to Art. 18 GDPR: You have the right to demand the restriction of the processing of your personal data as long as the accuracy of your data disputed by you is verified when you refuse the erasure of your data due to unlawful data processing and instead demand the restriction of processing your data when you need your data to establish, exercise, or defend legal claims after we no longer need this data after achieving the purpose, or when you have objected to your particular situation as long as it has not yet been determined whether our legitimate reasons prevail;

Right to information according to Art. 19 GDPR: If you have asserted the right to rectification, erasure, or restriction of processing against the data controller, the latter is obliged to notify all recipients to whom the personal data concerning you has been disclosed of this rectification, erasure, or restriction of processing unless this proves impossible or involves a disproportionate effort. You have the right to be informed about these recipients.

Right to data portability according to Art. 20 GDPR: You have the right to receive your provided personal data in a structured, commonly used, and machine-readable format or to demand transmission to another controller, if technically feasible;

Right to revoke consents granted according to Art. 7(3) GDPR: You have the right to revoke your consent to data processing at any time with future effect. In case of revocation, we will immediately delete the data concerned unless further processing can be based on a legal basis for processing without consent. Revocation of consent does not affect the lawfulness of processing based on consent before its revocation;

Right to complain according to Art. 77 GDPR: If you believe that the processing of your personal data violates the GDPR, you have the right to lodge a complaint with a supervisory authority, especially in the member state of your residence, workplace, or the place of the alleged infringement, without prejudice to any other administrative or judicial remedy.

11.2 Right to object If we process your personal data based on our overriding legitimate interest as part of a balancing of interests, you have the right to object to this processing at any time with future effect for reasons arising from your particular situation. If you exercise your right to object, we will cease processing the data concerned. However, further processing is reserved if we can prove compelling legitimate grounds for processing that override your interests, fundamental rights, and freedoms or if the processing serves to establish, exercise, or defend legal claims.

If your personal data is processed by us for direct advertising purposes, you have the right to object at any time to the processing of personal data concerning you for such advertising purposes. You can exercise the objection as described above.

If you exercise your right to object, we will stop processing the data concerned for direct advertising purposes.


12) Duration of Personal Data Storage

The duration of the personal data storage is based on the respective legal retention period (e.g., retention periods under commercial and tax law). After the period expires, the corresponding data is routinely deleted if it is no longer necessary for contract fulfillment or initiation and/or if there is no legitimate interest on our part in further storage.


This privacy policy was created using the Trusted Shops legal text in cooperation with FÖHLISCH Rechtsanwälte.