Privacy policy

1 Data Privacy Notice


1.1 General Information about the collection of personal data

In the following data privacy notice we would like to explain how we handle personal data transmitted to us when using our website or our offers. Personal data is any data, which can be related to you personally, e.g. name, address, email address or user behavior.


1.2 Data Controller


Angelo Sparacio

Kuhlweg 61

52074 Aachen



1.3 Which data does KEYGEM GmbH process?

KEYGEM GmbHoffers you a wide range of services, which you may use in a wide range of ways. Depending on whether you contact us online, by phone or otherwise and on which services you use, various data from different sources may come into play. Much of the data we process is provided by you yourself when you use our services or contact us, for example when you register and provide your name or email address or address. We do, however, also receive technical device and access data which is automatically collected when you interact with our services. When you visit our website, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the website, we collect information about the individual web pages or products that you view, what websites or search terms referred you to our website, and information about how you interact with the website.

We may also receive data on you from third parties, for example for credit rating agencies and payment service providers.


1.4 What does KEYGEM GmbHuse my data for?

KEYGEM GmbHprocesses your data in accordance with all applicable data protection laws. Of course, we observe the principles of data protection law for the processing of personal data. We therefore generally only process your data for the purposes explained to you in this Privacy Notice or shared when we collect the data. These are mainly purchase processing and the provision, personalization and development as well as security of our services. We use your data within the framework of the strict German and European data protection law, but also for other purposes such as personalized advertising and the optimization of business processes.

We process your data in the necessary scope to fulfil contracts and to provide and execute further services requested by you, as described in this Privacy Notice. The purposes of the necessary data processing therefore depend on the purpose of the contract agreed with you (including our General Terms and Conditions and any service-specific terms and conditions or terms of use) or services requested by you. The most important purposes are:

  • The provision, personalisation and needs-based design of our services such as the KEYGEM GmbHshop (including the respective website);
  • The execution of purchase agreements and customer service including dispatch and payment processing, claim management as well as the processing of returns, complaints and warranty claims;
  • The provision of messages, reports, newsletters and other direct communication, insofar as these are an integral component of our contractual services or the services requested by you;
  • The guarantee of the general security, operability and stability of our service including defence from attacks;
  • Non-promotional communication with you on technical, security-related and contractually relevant subjects (e.g. fraud warnings, account blocking or contractual changes);
  • The issuing, redemption, delivery of KEYGEM GmbH


1.5 KEYGEM GmbH legal basis for processing personal data

Insofar as the purpose relates to the execution of a contract agreed with you or the provision of a service requested by you, the legal basis is Article 6 (1) b GDPR. Otherwise, the legal basis is Article 6 (1) f GDPR, whereby we may use your personal data for the above purposes if we deem it necessary to do so for our legitimate interests.

If you have given us your consent for the processing of personal data, your consent is the primary basis of our data processing. Which of your data we process on the basis of your consent depends on the purpose of your consent. Typical purposes include:

  • Subscription to a newsletter;
  • The recording of telephone conversations which you have e.g. with our hotline;
  • The transmission of your data to third parties or to a country outside the European Union;
  • Processing of your location data by Google Maps in specific cases, such as offering information on the nearest pick-up points of your order.


1.6 Sharing your personal information

We share your personal information with third parties to help us use it, as described above. For example, we use Shopify to power our online store. You may read more about how Shopify processes your personal Information here:

Furthermore, we work with external shipping companies (e.g. DHL) to deliver orders. These shipping companies receive the following data to execute the relevant order:

  • Your name;
  • Your delivery address;
  • Your post number if applicable (if you wish to have the order delivered to a DHL packing station);
  • Your email address if applicable (if the shipping company wishes to inform you of the provisional delivery date by email).

We also use Google Analytics to help us understand how our customers use the website. You may read more about how Google processes your Personal Information here: You can also opt-out of Google Analytics here:

Finally, we may also share your personal information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.



1.7 Behavioural Advertising

As described above, we process your personal information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you may visit the Network Advertising Initiative’s (“NAI”) educational page at

You may opt out of targeted advertising by using the links below:

Additionally, you may opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at:


1.8 Cookies

The cookies used by our website may come from KEYGEM GmbH or advertising partners. If you only wish to accept the KEYGEM GmbH cookies, but not our advertising partners’ cookies, you can choose the corresponding setting in your browser (e.g. “block third-party cookies). Please note that we do not alter our website’s data collection and use practices when we see a DO Not Track signal from your browser.

Our services use three categories of cookies:

  • Necessary cookies: These cookies are required for optimal navigation and operation of the website. For example, these cookies are used to implement the basket function, such that the goods in your basket stay saved while you continue with the purchase. Only limited use of the website is possible without necessary cookies.
  • Statistical cookies: These cookies collect device and access data to analyze the use of our website, such as which areas of the website are used how (so-called surfing behavior), how fast content is loaded and whether errors occur. These cookies only contain anonymous or pseudonymous information and are solely used to improve our website and to find out what our users are interested in, as well as to measure how effective our advertising is. Statistical cookies can be blocked without adversely affecting the navigation and operation of the website.
  • Marketing cookies (“tracking cookies”): These cookies contain identifiers and collect device and access data, in order to adapt personalized advertising on KEYGEM GmbH website to your individual interests. Our advertising partners who operate online advertising networks also collect device and access data on our websites. This allows us to display personalized advertising on other websites and in other providers’ apps which fits your interests (so-called retargeting). Marketing cookies can be blocked without adversely affecting the navigation and operation of the website. Shopping personalization may, however, not be possible.


1.9 Retention Period

When you place an order through the Site, we will maintain your Order Information for our records unless and until you ask us to delete this information, if no other legislation states otherwise.


1.10 Data Subject Rights / Your Rights

You have the following legal data protection rights under the relevant legal conditions:

  • Right to information (Article 15 GDPR);
  • right to deletion (Article 17 GDPR);
  • right to correction (Article 16 GDPR);
  • right to restriction of processing (Article 18 GDPR);
  • right to data portability (Article 20 GDPR);
  • right to lodge a complaint with a supervisory authority (Article 77 GDPR);
  • right to withdraw consent (Article 7 (3) GDPR);
  • right to object to particular data processing measures (Article 21 GDPR).

If you want to exercise your data protection rights you can reach out to us by sending an email to

The respective privacy and data protection representative of the state of Baden-Wuerttemberg for your right to lodge a complaint with a supervisory authority may be contacted via the following website:


1.11 Changes to the Data Privacy Notice

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.


1.12 Contact us

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us via e‑mail at