We value your privacy. Protecting the personal data of Users is important to us. In this document (“Privacy Policy”) we explain how and why we process your personal data on our Website.


In this document, we also inform you what rights you have as a personal data subject. Certain terms used in the Privacy Policy, beginning with a capital letter which are not defined in this document, have the same meaning as given in the Terms and Conditions (“T&C”) of the Website.

We ensure that the personal data we obtain, is processed in a lawful manner and for legitimate purposes. We respect the right to privacy protection and ensure that your personal data is properly secured. Your personal data is processed in particular in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) also referred to as “GDPR”. The official text of the GDPR:

The data controller of personal data is a company registered in Hong Kong under the name of Digital Trade Keys Limited, registered office address:


Our contact details:

E-mail address:

Using contact forms or support systems available on the Website.

Digital Trade Keys ( , “we”, “us”, “our) is committed to respecting privacy and data protection compliance.


If you are a resident of the European Union, you are protected by, and enjoy additional, rights under the European Union’s General Data Protection Regulation 2016/679, also known as GDPR.

Personal Data that is processed automatically

When you visit our Website, and regardless of whether you place an order, we may automatically collect Personal Data about you or your device. We do not have the intention of identifying you with any such data, but it is possible to directly or indirectly identify you on the basis of such data. For this reason, this Policy informs you about our use of this data in a transparent way. Automatically collected Personal Data may include:

  1. Your name
  2. Your
  3. Your location (including country code) and time zone.
  4. Your demographic information including preferences and interests
  5. Other information relevant to customer surveys and/or offers
  6. Internet Protocol(IP”) addresses
  7. Cookies. 
  8. RetailCustomerID

We process the above data through cookies and similar techniques. More information about the cookies we use can be found in our cookie statement:

How do we collect personal data?

We collect personal information in a number of ways, including:

  • when you or a third-party contact us independently of our Site, such as by email, phone or in person
  • when you visit and interact with our Site and related software (including any mobile applications)
  • when you engage in transactions with us
  • when you sign up for an Account with or become a part of the affiliate programme
  • through cookies and other technologies that allow us to give you a better experience on our Site
  • when you contact us via our Site or sign up for our newsletter/mailing list

Personal Data that is provided by you

For the mere accessing of the website, it is not required to provide us with Personal Data. It is furthermore not required to set up an account.

When you place an order with us, create an account or have a question for us, we may process additional Personal Data about you. This includes the following Personal Data:

  1. Your first name and family name
  2. Your contact details
  3. Your address
  4. Your email address
  5. Your (mobile) phone number
  6. Your username/password
  7. Your IP address
  8. Your date of birth
  9. Any other contact details
If you choose to voluntarily provide us with Personal Data, other than the above, we advise you to limit this disclosure to the absolute minimum and not to provide us with any sensitive or special personal data, such as data revealing your race or ethnic origin, political views, religious or philosophical beliefs, membership of a union, or any genetic data, biometric data processed for the unique identification of a person, data on health, or data relating to a person’s sexual behavior or sexual orientation.

Data retention 

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of a legal dispute in respect of our relationship with you. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.


or what purposes do we process Personal Data?

  1. Our primary purposes for which we process your Personal Data are to offer you the best possible services, to optimize our Website and services and to ensure their continuity. More specifically, your Personal Data can be used for the following purposes:
    1. To fulfill your order: this seems obvious, but we may need certain Personal Information about you to process and fulfill your order.
    2. To personalize the Website: you have the option of adapting the Website experience to your needs, for example by changing the language of the Website. To remember your changes, we may process Personal Data about you, such as a unique ID and your IP address. If you have created an account, your preferences may be linked to your account.
    3. To improve our Website: we are constantly working to improve our Website and your user experience and add new functionality. Processing analytical data (in an aggregated form) is essential for this.
    4. To secure our Website: in order to offer you the best possible user experience, it is necessary to keep malicious third parties (e.g. hackers) out. We therefore constantly monitor our services and the use of our services. When we identify a potential threat, we can take immediate action to prevent disruption or unauthorized use of our services.
    5. To communicate with you: when you contact us, we process your contact information such as your name and e-mail address and any other Personal Data that you provide to us.
    6. For marketing purposes: your Personal Data can be used to provide you with newsletters and offers for our products and services.
    7. To comply with a legal obligation: we may be required by law or by a court order to process and / or transfer certain Personal Data.
  1. Your rights
    1. The GDPR guarantees you as a data subject certain rights: 
      1. Objection: Depending on the situation, you have the right to consent or object to the processing of your Personal Data and the conditions under which this processing takes place.  
      2. Access: You have the right to request from us, without constraint, at reasonable intervals and without excessive delay or expense, i) a confirmation as to whether or not Personal Data regarding you is being processed, ii) information on the purposes for which Personal Data is processed, iii) the categories of Personal Data concerned, and iv) the recipients or categories of recipients to whom the Personal Data is disclosed. You have the right to receive, in an intelligible form, a communication of the Personal Data being processed and of any available information as to the source(s). Furthermore, you have the right to knowledge of the underlying logic of the automated processing of Personal Data relating to you.
      3. Rectification, erasure, blocking or deletion: You, where appropriate, have the right to rectification, erasure, blocking or deletion of your Personal Data that is not processed in compliance with data protection laws and regulations, in particular when the nature of the data is incomplete or inaccurate. 
      4. Notification: You have the right to a notification to third parties to whom your Personal Data has been disclosed, when you have been granted any rectification, erasure, blocking or deletion as stated above, unless such notification proves to be impossible or requires a disproportionate effort from us.
      5. Withdraw consent: where we are processing personal data relating to you on the basis of your prior consent to that processing, you may withdraw your consent at any time.
      6. Complaint with relevant authority: You have the right to file a complaint with the relevant data protection authorities, e.g. the Autoriteit Persoonsgegevens in the Netherlands

Contact us

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us through the support and contact us links on the website or by logging into your user account and log

Changes to this privacy notice

We will change this privacy notice from time to time and any changes will be contained in a revised privacy notice posted on the website. This version of the privacy notice was last updated on 11 June 2021 and historic versions can be obtained by contacting us using the information.

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