In this section, in accordance with the European legislation introduced by EU Regulation 679/2016 and with the Italian legislation (Legislative Decree no. 196/2003), information is provided on the processing of personal data of Users consulting the pages of the website (hereinafter: "Site") or using the purchasing services made available on it (hereinafter: "Users" or "Interested Parties").

This information is rendered exclusively for the Site and not also for the other websites that may be consulted by the user through the links present within the Site.

The Data Controller

The Data Controller of the processing of the personal data of the users of the Site is the Company ECOKEY PORTAL CO. LLC - office 3-110, ginger business center, Al Khabeesi Showroom building, Al Khabeesi, Dubai, UAE - REG. NUMBER: 1244913 PHONE: +971 569015205, e-mail:

E-mail to contact the owner and request deletion of your data, if collected, with your consent:


· ‘‘All credit/debit cards’ details and personally identifiable information will NOT be stored, sold, shared, rented or leased to any third parties’’

· WWW.ESDCODES.COM’will not pass any debit/credit card details to third parties’’

· WWW.ESDCODES.COM’takes appropriate steps to ensure data privacy and security including through various hardware and software methodologies. However WWW.ESDCODES.COM (website) cannot guarantee the security of any information that is disclosed online’’

· WWW.ESDCODES.COM is not responsible for the privacy policies of websites to which it links. If you provide any information to such third parties different rules regarding the collection and use of your personal information may apply. You should contact these entities directly if you have any questions about their use of the information that they collect.’’

· “The Website Policies and Terms & Conditions may be changed or updated occasionally to meet the requirements and standards. Therefore, the Customers’ are encouraged to frequently visit these sections to be updated about the changes on the website. Modifications will be effective on the day they are posted”.

A - Type of data processed

  1. Identifying data

In accordance with the European legislation introduced by EU Regulation 679/2016, consultation of the Site and the possible purchase of products sold on the Site may entail the processing of data capable of directly or indirectly identifying a natural person, such as: name, surname, residential address, email address, telephone number, IP address.

The Site does not require the Interested Party to provide any so-called "special" data, i.e., in accordance with the GDPR (art. 9), personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as genetic data, biometric data intended to uniquely identify a natural person, data relating to the person's health or sexual life or sexual orientation. In the event that the service requested requires the processing of such data, the data subject shall receive prior notice thereof and shall be asked to give his/her explicit consent.

      1. Banking data

By purchasing products on the Site, bank data such as the card number or bank account indicated to make the payment, cardholder and bank account holder will also be processed.

These data may be processed exclusively by third-party companies that manage the payment methods used on the site.

We would like to inform you that the Site uses the following payment services, please refer to their respective privacy policies for data processing:

III. Browsing data

Navigation data are data acquired automatically by the systems and programmes responsible for the operation of the Site and are necessary for the use of web services [e.g.

These data are acquired even in the absence of registration with the Site or a request for information.

Navigation data are used exclusively in aggregate form for the purpose of compiling anonymous statistics on consultation of the Site and to check that it is working properly, and do not allow the users concerned to be identified; moreover, they are deleted immediately after processing in anonymous form.

These data may, however, be used to ascertain liability in the event of computer crimes committed against the website.

  1. Data provided voluntarily by the user

The personal data voluntarily provided by the User (such as name, surname, telephone number, e-mail address) for the purpose of sending messages to the Website and/or purchasing the products made available are used solely for the purpose of responding to the User's needs and for complying with legal obligations.

The legal basis for such processing is the fulfilment of the services inherent to the requests made and the purchases made, as well as compliance with legal obligations.

The information that the User of the Site decides to make public through the services and tools made available to him/her is provided by the User knowingly and voluntarily, exempting the Site from any liability for any breach of the law.

The User is responsible for the processing of his/her personal data.

It is up to the User to verify that he/she has the permissions to enter personal data of third parties or content protected by national and international regulations.

  1. Data collected through analytical cookies

The Site also acquires data relating to the User through the use of cookies.

For more information on what data is processed through cookies, the types of cookies that are active and how to disable them, please refer to the cookie policy.

These cookies are used to track the user's browsing preferences and to collect statistical data. Users can disable these cookies by accessing their browser settings, as indicated in the Site's cookie policy.


B - Purpose of processing

The personal data collected is used for:

  • enable shipment by e-mail of products purchased by the User;
  • respond to contact requests sent by the User;
  • allow the use by the User of the Customer Service;
  • to collect anonymous statistical information on the use of the web portal;
  • to monitor the proper functioning of the web portal;
  • to send notices and newsletters, both in paper and electronic format, to the e-mail address provided by the User: in the event that the User decides to subscribe to the newsletter of only after having given his/her specific consent, his/her personal data will be processed by the Data Controller for the purpose of sending commercial or promotional communications, updates regarding, for example, exclusive offers, special events and promotions. To unsubscribe from the newsletter, simply click on the unsubscribe link at the bottom of the e-mails you receive or write to
  • the establishment of liability in the event of hypothetical computer crimes to the detriment of the website;
  • compliance with any other legal obligation not included in the preceding purposes.

The communication of data may be made only following a request by the Judicial Authority within the terms of the law.


C - Legal basis of processing

The legal basis for the processing of personal data is the performance of the services inherent in the relationship established by signing the Terms and Conditions, the consent of the person concerned, compliance with legal obligations and the legitimate interest of the Data Controller in carrying out processing necessary for such purposes.

  1. Execution of a contract

The Controller processes Personal Data relating to the User when the processing is necessary for the performance of a contract with the User and/or the execution of pre-contractual measures.

  1. Consent of the data subject

The optional, explicit and voluntary sending of electronic mail, messages or any type of communication addressed to the addresses indicated on this Site entails the subsequent acquisition of the sender's address, telephone number or any other personal data that will be used to respond to requests. Such processing takes place on the basis of the consent of the person concerned.

We ensure that such processing will be based on the principles of lawfulness, fairness, transparency, appropriateness, relevance and necessity referred to in Article 5(1) of the GDPR. Specific summary information will be progressively reported or displayed on the pages of the sites set up for particular services on request.

III. Compliance with legal obligations

The processing of personal data may take place without the consent of the data subject in the event that the Data Controller must comply with a legal obligation.

  1. Legitimate interest of the Data Controller

The Controller processes Personal Data relating to the User where the processing is necessary for the pursuit of the legitimate interest of the Controller or a third party.

  1. Optional supply of data

Aside from what is specified for the fulfilment of the contract or legal obligations, for cookies and navigation data, the user is free to provide or not to provide his/her personal data. However, failure to provide data may result in the impossibility of obtaining the service.


D - Methods and duration of processing

Personal data are processed using IT tools and in accordance with EU Regulation No. 679/2016.

The data processed will be stored for the time necessary for the purposes described in this statement and, therefore, for the minimum time necessary or until explicitly requested by the data subject and in any case within the time limits imposed by law.

The Data Controller undertakes to adopt all appropriate security measures to prevent the loss and alteration of personal data, as well as any unlawful and unauthorised use thereof.

The data shall be processed exclusively by parties authorised by the Data Controller, including any data processors, representatives and public entities for the fulfilment of the obligations provided for by law, who perform their respective processing activities as independent data controllers.

Subjects authorised by the Data Controller that may process data include, by way of example: sales and legal department staff, as well as third party technical service providers, hosting providers and IT companies (this list is not exhaustive). The processed data will not, however, be disclosed to unspecified recipients.

Subjects authorised by the Data Controller that may process data for profiling purposes include the online marketing platforms "Klaviyo" ( and "Omnisend" ( and "WordPress" (

The security of the information collected cannot be guaranteed against hacker attacks and, in general, against breaches of the security rules put in place for data protection.

In the event of attacks or breaches, however, these will be communicated to those concerned and to the competent authorities in accordance with the law.


E - Place of processing

The processing operations relating to the services of the web portal are carried out by staff identified and expressly designated according to the specific purposes of the services requested and subscribed to.

For the processing operations in question, the Data Controller may avail itself of the aid of external companies, forwarding agents, consultants, consortia, software and service providers operating, through identified and appointed personnel, within the scope of the intended purposes and in such a way as to guarantee maximum data security and confidentiality. In other cases, the personal data collected will not be disclosed to third parties, except with the express consent of the person concerned, except in cases where disclosure to third parties is necessary to comply with obligations imposed by laws, regulations or provisions of supervisory authorities, or is essential to protect the rights of other users or of the website itself.

Personal data will be processed and stored, solely for the purposes stated above and for safe keeping and storage, on remote servers operated by industry-leading providers who ensure compliance with high standards of data protection.

This may involve the transfer of data to countries outside the EU, where all or part of the aforementioned servers may be located.

In particular, personal data may be transferred outside the European Union to the company "WordPress" (, an e-commerce plug-in used by the Site managed by the Controller.

The processing and storage of data by the aforementioned provider will take place in a third country that is "adequate" within the meaning of the decision taken by the European Commission, including in particular the decision for the adequacy of the protection provided by the Canadian Personal Information Protection and Electronic Documents Act or the Privacy Shield (USA), or on the basis of a contractual obligation or standard contractual clauses approved by the European Commission, or binding corporate rules approved through the specific procedure set out in Art. 47 GDPR.

For the transfer of data to non-EU countries, there is normally no need to wait for national authorisation from the Garante. However, the Garante's authorisation will still be required if a data controller wishes to use specific contractual clauses that have not been recognised as adequate by a decision of the European Commission or administrative agreements concluded between public authorities.

The Garante's authorisation will still be required if a data controller wishes to use specific contractual clauses that have not been recognised as adequate by a decision of the European Commission or administrative agreements concluded between public authorities.

F - Rights of data subjects

In the course of processing, the data subject may exercise the following rights at any time:

  • obtain confirmation as to whether or not such data exists and, if so, to know its content and origin;
  • to verify the accuracy of the data and, if so, to request the rectification of inaccurate data, the integration of incomplete data or the updating of outdated data;
  • obtain the restriction of processing, where one of the cases provided for in Article 18 GDPR applies;
  • request the deletion of data processed in breach of the law, or in the presence of one of the other conditions envisaged by Article 17(1)(a), (b), (c), (e) and (f) GDPR;
  • to object in any case, for legitimate reasons, to their processing, or to object to their processing in the other cases provided for in Article 21(2) and (3) and 22 GDPR;
  • revoke at any time your freely given consent to the processing of your personal data for the purposes specified below;
  • obtain the release of the personal data undergoing processing in a format compatible with standard IT applications, in order to allow its transfer to other platforms of your choice, without impediments to the direct transmission of the processed data to another Data Controller, where such direct transmission is technically feasible (the so-called right to data portability);

Requests relating to the exercise of the aforementioned rights should be addressed to the Data Controller by e-mail (

In the event of failure or partial response from the Data Controller to the aforementioned requests, the data subject shall have the right to lodge a complaint with the Garante per la protezione dei dati personali ( or take legal action within the terms and according to the procedures provided for under Articles 77 et seq. of EU Regulation 2016/679 (GDPR).

G - Policy Updates

Future regulatory updates may lead to changes to the current policy, uploaded to the Site on 20.01.2023.

In the event of a change, the Data Controller will give notice thereof on the Site.