EU Data Protection Directive

The controller in the sense of the General Data Protection Regulation (GDPR) is:
SellerX Commerce GmbH
c/o SellerX Germany GmbH
Chausseestraße 19
10115 Berlin
Germany
Email: service@kwmobile.com

Who are we and what is the scope of this privacy policy?

SellerX Commerce GmbH ("we", "us", "our" or "kwmobile") processes certain personal data to enable you to use our online shop operated on our website and our products. This privacy policy describes our data processing operations and informs you about your rights in connection with your personal data. The specific data processing operations described in this privacy policy may vary depending on how you use our website and services and which features you use.

This privacy policy applies to all websites operated under our domain (www.kwmobile.com), including our online shop and related activities such as organizing deliveries and conducting marketing activities. Please note that in some cases, our websites may contain links to external third-party websites that are neither operated by us nor covered by this privacy policy. To learn more about the data processing of these third parties, we recommend that you read their privacy policies.

If you order our products through a third-party website (e.g., Amazon), these third parties may process your personal data for their own purposes and act as independent controllers. Further information on this can be found in the respective privacy policies of these providers.

Further information about the cookies and similar technologies we use can be found in our Cookie Policy.

If you are located in the United Kingdom ("UK"), all references to the General Data Protection Regulation ("GDPR") refer to the corresponding provisions of the UK General Data Protection Regulation ("UK GDPR").

What personal data do we process, for what purposes and on what legal basis?

Provision of our services

For kwmobile, it is necessary to process your contact details such as name, telephone number, email address and delivery address, as well as your payment and order information (e.g., payment method, product information, order date and shipping method) in order to:

  • Execute purchase contracts including shipping, delivery and payment processing;
  • Respond to inquiries, manage your account and provide other customer service;
  • Process complaints and handle returns, grievances, and warranty claims;
  • Send you non-promotional service communications on technical, security-related or contractual matters (e.g., fraud warnings, account suspensions or contract changes);
  • Provide other services requested by you.

The legal basis for processing this data for the purposes mentioned above is the fulfillment of a contract pursuant to Art. 6 para. 1 lit. b GDPR.

In certain cases, we may also conduct credit checks to assess the risk of payment default. For this purpose, we may process limited identity data such as your date of birth and - where legally permissible - share relevant information with credit agencies. The legal basis for this is our legitimate interest in preventing payment defaults pursuant to Art. 6 para. 1 lit. f GDPR.

Marketing

We also process your contact details, including email address and telephone number, for marketing purposes. Where the content of marketing communications is personalized, we may also process your order history (i.e., previously purchased products) as well as your interests, which result from the cookies you have accepted. Further information on the cookies and similar technologies used can be found in our Cookie Policy.

Our marketing activities include, in particular:

  • Sending newsletters, reminders, product updates, recommendations, promotions and other marketing information by email;
  • Sending promotional messages via SMS as well as via WhatsApp or Facebook Messenger;
  • Displaying personalized advertising on social media platforms such as Facebook, Instagram and TikTok;
  • Sending push notifications, including marketing messages.

The legal basis for marketing communication and social media targeting is either your consent pursuant to Art. 6 para. 1 lit. a GDPR or our legitimate interest in direct marketing pursuant to Art. 6 para. 1 lit. f GDPR. If we send marketing emails based on legitimate interests, this is limited to existing customer advertising within the framework of applicable legal provisions (e.g., Section 7 (3) UWG in Germany). Please note that push notifications require your consent, which also constitutes the legal basis for processing the personal data collected for this purpose.

When you first register for our services, we would like to use your data for marketing communications and social media targeting to send you information about similar products or services you have shown interest in. You have the option to object to the use of your personal data for marketing purposes at any time, for example via the unsubscribe link in our emails or via your profile settings. If we ask for your consent instead, or if you later give it via functions of our website (e.g., to be informed as soon as an out-of-stock product is available again), the processing will be based on your consent.

In order to improve your user experience, send you personalized communications and offers, and enable you to collect loyalty points and receive personalized discounts, we collect certain information to assign you to a customer segment and create a customer profile (profiling). In addition to the personal data mentioned above, including your name and address data, the assigned segment and the created profile are based on the following information:

  • Your purchase history;
  • Device and network data;
  • Your behavior on our website and on third-party websites, provided you have accepted cookies;
  • Your interaction with our communication measures, including social media pages and tracking pixels;
  • Your birthday, if you have provided it.

The legal basis for the creation of these segments and profiles, as well as their use for personalizing our services and marketing communications, is our legitimate interest in conducting personalized marketing measures and your legitimate interest in receiving personalized discounts and recommendations based on your interests pursuant to Art. 6 para. 1 lit. f GDPR.

You have the right to object to the processing of your personal data for direct marketing purposes at any time pursuant to Art. 21 GDPR. If you object, we will no longer process your personal data for these purposes.

Blog

We may operate a blog on our website. This allows you to interact with our blog and other readers by leaving comments or subscribing to notifications when new comments or blog articles are published. If you leave a comment, your name or chosen username (pseudonym), which is publicly displayed on the website, as well as your email address and your IP address, which are not publicly visible, will be processed as personal data. The legal basis for this is our legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR to enable you to interact with our bloggers and other commentators, as well as your interest in such interaction. If you subscribe to notifications about new comments, the processing is based on your consent pursuant to Art. 6 para. 1 lit. a GDPR.

Community and Referral Program

We hope you are satisfied with our products and welcome your feedback and suggestions for improving or developing new products. For this purpose, we may operate a customer community on Facebook. We process group statistics, including the activity and engagement of members within the group, for example, to understand how you interact within the group, who the most active members are, and which posts generate the most engagement. The legal basis for this is our legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR to interact with our customers to improve our products, as well as your interest in interacting with us and providing feedback.

We have also set up a referral program through which you can recommend us and our products to your friends. For this purpose, you can either share your personal code with your friends or provide your friends' contact details so that they can be notified via the respective communication channel (e.g., by email). The legal basis for this is our legitimate interest in reaching potential new customers, your interest in sending recommendations to your friends, and your friends' interest in receiving recommendations that may be relevant to them. We inform your friend about your recommendation in the first communication and provide appropriate information about our privacy practices. We only contact your friend once, unless they actively respond to the communication. If your friend does not become a customer, we do not store their contact details. If you share your code and your friend uses it, or if you yourself are the friend who uses the code, we store this information in your customer profile to grant you discounts or other benefits related to the use of the code.

Further purposes

We may also use the aforementioned categories of personal data, as well as other data that may be considered personal data and has been collected through our technically necessary cookies or otherwise, for the following purposes:

  • Maintaining the security of our website and services, including preventing data breaches;
  • Fraud prevention;
  • Research and development of our website and services, provided the data is processed in aggregated, pseudonymized or anonymized form;
  • Compliance with legal obligations or judicial orders (e.g., to perform legal money laundering or "Know Your Customer" checks);
  • Establishment, exercise or defense of legal claims.

For these data processing operations, we rely on our legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR, in particular for fraud prevention, maintaining the security of our services, and enforcing or defending legal claims. If we need to process personal data to comply with legal obligations (e.g., due to applicable laws, regulations or court orders), the processing is based on Art. 6 para. 1 lit. c GDPR.

Where do we obtain your personal data from and with whom do we share it?

In principle, we process personal data that you provide to us directly or that arises from your use of our services. Our business operations also require us to engage service providers who assist us in providing our services and products. In this context, we may share your personal data with such service providers, as far as necessary and subject to appropriate contractual and technical safeguards. These service providers may include, in particular:

  • E-commerce platforms (e.g., Shopify);
  • Payment service providers;
  • Credit agencies for credit checks, if applicable;
  • Customer service and customer relationship management platforms;
  • Providers of customer support services (e.g., chat providers);
  • Marketing platforms and services, including social media platforms and conversion tracking services (e.g., Meta);
  • Delivery and shipping companies;
  • Debt collection service providers, if applicable;
  • Providers of loyalty, bonus or referral programs;
  • Companies belonging to the same corporate group as us;
  • Advisors, auditors or insurance companies;
  • Third parties in connection with a business transaction (e.g., a merger, acquisition or liquidation).

Furthermore, we may share personal data with law enforcement authorities or other relevant third parties if we are legally obliged to do so, if there is a corresponding judicial decision, or if this is necessary for the establishment, exercise or defense of legal claims.

Are you obliged to provide personal data, and what are the consequences of not providing it?

Unless otherwise stated in the explanations above regarding the respective legal bases, you are generally not obliged to provide us with personal data. However, in the cases of Art. 6 para. 1 lit. b GDPR, the personal data is necessary to conclude or fulfill a contract. If you do not provide us with the relevant personal data, we cannot conclude or carry out the contract. If you do not provide us with data in the cases of Art. 6 para. 1 lit. a or lit. f GDPR, you may not be able to use the corresponding parts of our services.

Do third parties act as joint controllers?

If personal event data is processed via Facebook social plugins, pixels or software development kits (SDKs) as part of the use of Facebook Business Tools, we act as joint controllers together with Meta Platforms Ireland Ltd. This also applies to the processing of personal data in connection with Facebook Page Insights, the aggregation of these events, and the provision of corresponding information to the administrators of the Facebook page. Further information on how Facebook processes your personal data, including the legal bases and your rights, can be found in Facebook's respective privacy policy.

We may also act as joint controllers with TikTok Technology Limited and/or TikTok Information Technologies UK Limited ("TikTok") if we use TikTok pixels, cookies, APIs or SDKs on our digital offerings (e.g., our website) to collect data for advertising purposes. Further information on data processing by TikTok can be found in TikTok's corresponding privacy policy.

Insofar as we use Google Ads services, we act as joint controllers with Google Ireland Ltd. Further information can be found in Google's privacy policy.

If we operate Pinterest advertising services on our website and transmit activity data to Pinterest via tags, API endpoints or other functions, we act as joint controllers with Pinterest Europe Limited. Further information can be found in Pinterest's privacy policy.

The essential content of the agreements pursuant to Art. 26 GDPR can be made available upon request.

Where is your personal data processed?

kwmobile is a European company based in Germany. However, we may also transfer your personal data to other countries within the EU/EEA area as well as to third countries. If personal data is transferred to third countries, we ensure that appropriate safeguards are in place, e.g.: adequacy decisions of the European Commission, participation in the EU-U.S. Data Privacy Framework, where applicable, standard contractual clauses pursuant to Art. 46 GDPR, or other appropriate safeguards permissible under applicable data protection law.

How is your personal data protected?

kwmobile has implemented comprehensive technical and organizational measures (TOMs) to protect your personal data. These measures are regularly reviewed and updated to comply with the latest technology.

In addition, we carefully vet our service providers and conclude corresponding agreements with them to ensure that they comply with our defined security requirements.

When do we delete your data?

Personal data is only stored for as long as it is necessary for the respective purposes. In addition, certain data is subject to statutory retention obligations, in particular under commercial and tax law provisions (e.g., Section 257 HGB and Section 147 AO). The corresponding retention periods are generally six or ten years. After the expiry of the statutory retention periods, the data concerned will be deleted, unless they are still required for contract fulfillment or for the assertion, exercise or defense of legal claims. Storage only takes place for the period necessary to achieve the respective purposes.

Do we carry out automated individual decision-making (including profiling)?

Automated decision-making within the meaning of Art. 22 GDPR does not take place. However, we may use profiling techniques to analyze customer preferences and personalize marketing communications.

What rights do you have regarding our data processing and how can you contact us?

In addition to your right to information through this Privacy Policy, you have the following rights under legal conditions:

  • Right to information about your personal data;
  • Right to rectification of inaccurate or incomplete data;
  • Right to erasure (“right to be forgotten”);
  • Right to restriction of processing;
  • Right to data portability;
  • Right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you;
  • Right to lodge a complaint with a supervisory authority.

You can lodge a complaint with the data protection supervisory authority of your habitual residence, your place of work, or our company headquarters.

Right to object

If we process your personal data based on legitimate interests, you have the right to object to this processing at any time with effect for the future. This applies in particular to the processing of personal data for direct marketing purposes. If you exercise your right to object, we will stop processing the data concerned. However, further processing may occur if we can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or if the processing is for the establishment, exercise, or defense of legal claims. If we process your personal data for direct marketing, you have the right to object to this processing at any time. In this case, we will no longer process your personal data for direct marketing purposes. The objection can be made informally. However, we recommend using the provided opt-out mechanisms or contacting us as described below.

Right to withdraw consent

According to Art. 7 para. 3 GDPR, you have the right to withdraw any consent given at any time with effect for the future. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. After withdrawing your consent, we will delete the personal data processed based on your consent, unless there is another legal basis for the processing. The withdrawal can be made informally. However, we recommend using the provided consent mechanisms or contacting us as described below.

Please note that we do not sell personal data. However, in the event of a corporate transaction, your personal data may be transferred to a new data controller.

How can you contact us?

To exercise your rights, you can send us an email to the following address: service@kwmobile.com.

To ensure that personal data is not disclosed to unauthorized persons, we may, in individual cases, request additional information to verify identity. Requests to exercise your rights will be answered within one month in accordance with legal requirements.

You can also reach us by post:
SellerX Commerce GmbH
Attn: Legal
c/o SellerX Germany GmbH
Chausseestraße 19
10115 Berlin

Please note that as an e-commerce operator, we predominantly process your data electronically. Upon request, we will therefore provide you with your personal data in a common machine-readable format (e.g., CSV or another common electronic format).

Data Protection Officer

SellerX Commerce GmbH
Attn: Legal
c/o SellerX Germany GmbH
Chausseestraße 19
10115 Berlin
Email: service@kwmobile.com

Last update

This privacy policy was last updated on 11/03/2026. We reserve the right to update this privacy policy at any time. The current version is always available on our website.