Privacy Policy

Data collection on this website

Who is responsible for data collection on this website?
Data processing on this website is carried out by the website operator. Their contact details can be found in the section “Notice regarding the responsible party” in this privacy policy.

How do we collect your data?
Some of your data is collected when you provide it to us — for example, when you sign up for our waitlist or fill out our questionnaire. Other data is collected automatically, or with your consent, when you visit the website, through our IT systems or integrated services (e.g. technical data or usage behaviour). This data is collected automatically as soon as you enter this website, or — where consent is required — only after you have given your consent in the consent banner.

What do we use your data for?
Some of the data is collected in order to notify you once your selected collection becomes available, and to send you two short follow-up emails in that context. We use questionnaire responses collectively to help shape our collections. Other data serves the technical provision and security of the website, or — provided you have given your consent — the analysis of user behaviour and the performance measurement of our advertising.

What rights do you have regarding your data?
You have the right at any time to receive information free of charge about the origin, recipients, and purpose of your stored personal data. You also have the right to request the correction or deletion of this data. If you have given consent to data processing, you may revoke this consent at any time with future effect. Furthermore, you have the right, under certain circumstances, to request the restriction of the processing of your personal data, as well as to object to such processing. In addition, you have the right to lodge a complaint with the competent supervisory authority. If you have any questions about this or any other matter relating to data protection, you are welcome to contact us at any time: info@houseofginger.co.

External hosting
This website is hosted externally. The personal data collected on this website is stored on the servers of the hosting provider. This may include, in particular, IP addresses, waitlist and questionnaire data, meta and communication data, as well as other data generated through the use of a website.

External hosting is carried out for the purpose of fulfilling our contractual obligations towards our prospective and future customers (Art. 6(1)(b) GDPR) and in the interest of a secure, fast, and efficient provision of our online offering by a professional provider (Art. 6(1)(f) GDPR). Our hosting provider will only process your data to the extent necessary to fulfil its service obligations and will follow our instructions with regard to this data. We use the following hosting provider: Cloudflare, Inc., 101 Townsend Street, San Francisco, CA 94107, USA.

Cloudflare
We use the service “Cloudflare”. The provider is Cloudflare Inc., 101 Townsend St., San Francisco, CA 94107, USA (hereinafter “Cloudflare”). Cloudflare offers a globally distributed content delivery network with DNS. This means that the transfer of information between your browser and our website is technically routed through Cloudflare’s network. This enables Cloudflare to analyse the traffic between your browser and our website and to act as a filter between our servers and potentially malicious traffic from the internet. Cloudflare may also use cookies or similar technologies to recognise internet users, though solely for the purpose described here.

The use of Cloudflare is based on our legitimate interest in providing our website offering as error-free and securely as possible (Art. 6(1)(f) GDPR). The transfer of data to the USA is based on the standard contractual clauses of the EU Commission. Details and further information on security and data protection at Cloudflare can be found here: cloudflare.com/privacypolicy.

The company is certified under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA intended to ensure that data processing in the USA complies with European data protection standards. Every company certified under the DPF commits to complying with these data protection standards. Further information is available from the provider at the following link: dataprivacyframework.gov/participant/5666.

Data protection
We take the protection of your personal data very seriously. We treat your personal data as confidential and in accordance with statutory data protection regulations and this privacy policy. When you use this website, various pieces of personal data are collected. Personal data is data that can be used to personally identify you. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done. We would like to point out that data transmission over the internet (e.g. when communicating by email) may be subject to security vulnerabilities. Complete protection of data against access by third parties is not possible.

Notice regarding the responsible party
The party responsible for data processing on this website is:
Mitja Janzekovic
Pestalozzistr. 15a
80469 Munich, Germany
Phone: +49 172 3862260
Email: info@houseofginger.co
The responsible party is the natural or legal person who, alone or jointly with others, determines the purposes and means of the processing of personal data (e.g. names, email addresses, etc.).

Storage duration
Unless a more specific storage period has been stated within this privacy policy, your personal data will remain with us until the purpose for the data processing no longer applies. If you assert a legitimate request for deletion or revoke your consent to data processing, your data will be deleted, provided we have no other legally permissible grounds for storing your personal data (e.g. tax or commercial law retention periods); in the latter case, deletion will take place once those grounds no longer apply.

General information on the legal basis for data processing on this website
If you have given consent to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR, or Art. 9(2)(a) GDPR where special categories of data under Art. 9(1) GDPR are processed. In the case of explicit consent to the transfer of personal data to third countries, data processing is additionally based on Art. 49(1)(a) GDPR. Where you have consented to the storage of cookies or access to information on your device (e.g. via device fingerprinting), data processing is additionally based on § 25(1) TDDDG (German Telecommunications Digital Services Data Protection Act). Consent may be revoked at any time. Where your data is required for the performance of a contract or the implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. We further process your data where this is necessary to comply with a legal obligation, on the basis of Art. 6(1)(c) GDPR. Data processing may also be based on our legitimate interest under Art. 6(1)(f) GDPR. The specific legal basis applicable in each individual case is set out in the following sections of this privacy policy.

Recipients of personal data
In the course of our business activities, we work with various external parties. This sometimes requires the transfer of personal data to these external parties. We only pass on personal data to external parties where this is necessary for the performance of a contract, where we are legally obliged to do so (e.g. disclosure of data to tax authorities), where we have a legitimate interest under Art. 6(1)(f) GDPR in the disclosure, or where another legal basis permits the disclosure of data. When engaging processors, we only pass on our customers’ personal data on the basis of a valid data processing agreement. In the case of joint processing, an agreement on joint processing is concluded. We use the following recipients:

• Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) — storage of waitlist and questionnaire entries in a Google Sheet, as well as Google Analytics, provided you have given your consent.
• Resend, Inc. (2261 Market Street #5039, San Francisco, CA 94114, USA) — sends the waitlist and follow-up emails on our behalf.
• Cloudflare, Inc. (San Francisco, CA, USA) — hosting, spam protection (Turnstile), and, provided you have given your consent, recording of anonymised usage behaviour via Smartlook.
• Counter.dev — aggregated, cookie-free visitor counting with no personal reference.
• Meta Platforms Ireland Limited (Merrion Road, Dublin 4, Ireland) — Meta Pixel for measuring the performance of advertising campaigns, provided you have consented to advertising cookies; see Section 5.

Transfers to third countries
Some of the providers listed above (including Google, Meta, Cloudflare, and Resend) also process data on servers in the USA. Where this is the case, we base such transfers on the standard contractual clauses of the EU Commission (Art. 46(2)(c) GDPR) and — where the respective provider is certified accordingly — additionally on the “EU-US Data Privacy Framework” (DPF), an adequacy decision of the EU Commission. Further information on DPF certification can be found at www.dataprivacyframework.gov.

Revoking your consent to data processing
Many data processing operations are only possible with your explicit consent. You may revoke consent you have already given at any time. The lawfulness of the data processing carried out until the revocation remains unaffected by the revocation.

RIGHT TO OBJECT TO THE COLLECTION OF DATA IN SPECIAL CASES (ART. 21 GDPR): WHERE DATA PROCESSING IS BASED ON ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT AT ANY TIME, FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION, TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA; THIS ALSO APPLIES TO ANY PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR PERSONAL DATA CONCERNED, UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE PROCESSING SERVES THE ESTABLISHMENT, EXERCISE, OR DEFENCE OF LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21(1) GDPR). WHERE YOUR PERSONAL DATA IS PROCESSED FOR THE PURPOSE OF DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR SUCH MARKETING PURPOSES; THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS RELATED TO SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR THE PURPOSE OF DIRECT MARKETING (OBJECTION PURSUANT TO ART. 21(2) GDPR).

Right to lodge a complaint with the competent supervisory authority
In the event of breaches of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the member state of their habitual residence, place of work, or the place of the alleged breach. This right to complain exists without prejudice to any other administrative or judicial remedy.

Right to data portability
You have the right to have data that we process automatically on the basis of your consent or in fulfilment of a contract handed over to you or to a third party in a commonly used, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done insofar as it is technically feasible.

Right of access, rectification, erasure, and restriction of processing
Within the scope of applicable statutory provisions, you have the right at any time to request free information about your stored personal data, its origin and recipients, and the purpose of the data processing, and, where applicable, a right to rectification or erasure of this data. If you have any questions about this or any other matter relating to personal data, you are welcome to contact us at any time.

Right to restriction of processing
You have the right to request the restriction of the processing of your personal data. You may contact us at any time to do so. The right to request restriction of processing applies in the following cases:

• If you dispute the accuracy of your personal data stored by us, we generally need time to verify this. For the duration of this verification, you have the right to request the restriction of the processing of your personal data.
• If the processing of your personal data was/is unlawful, you may request the restriction of data processing instead of erasure.
• If we no longer need your personal data, but you need it to exercise, defend, or assert legal claims, you have the right to request the restriction of the processing of your personal data instead of its erasure.
• If you have lodged an objection pursuant to Art. 21(1) GDPR, a balancing of interests must be carried out between your interests and ours. As long as it has not yet been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, such data — other than being stored — may only be processed with your consent, or for the establishment, exercise, or defence of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of important public interest of the European Union or a member state.

Cookies and consent banner
Our website uses cookies. Necessary cookies, which are required to provide the website, are set on the basis of our legitimate interest (Art. 6(1)(f) GDPR). Analytics cookies (Google Analytics, Smartlook) and advertising cookies (Meta Pixel) are disabled by default and are only set once you actively consent in the consent banner (Art. 6(1)(a) GDPR, § 25(1) TDDDG). Your preference is stored locally in your browser and is not shared with any third party. You may withdraw your consent at any time with future effect via the consent banner.

Waitlist form
When you sign up for our waitlist, we collect your email address, the collection you selected, the language in which you visited the site, and — only if you came via a link with corresponding parameters — marketing identifiers (UTM parameters) that show us which channel you found us through. We use this data exclusively to inform you about the availability of the selected collection, and we do not pass it on to third parties without your consent. Processing is based on your consent (Art. 6(1)(a) GDPR) as well as on the performance of pre-contractual measures at your request (Art. 6(1)(b) GDPR). Your data remains with us until the collection has launched and any related follow-up steps have been completed, or until you ask us to delete it.

Questionnaire
When you fill out our questionnaire, we collect your answers regarding price, purchase intent, the occasion for which you would use the collection, and any information you add in the optional free-text field. Every question is optional; only at least one answer is required in order to submit. We evaluate this data collectively in order to decide on price, sizes, and content for our collections, and we do not pass it on to third parties without your consent. Processing is based on your consent (Art. 6(1)(a) GDPR). Your responses remain with us until the purpose of the evaluation no longer applies or until you ask us to delete them.

Inquiries by email, phone, or fax
If you contact us by email, phone, or fax, your inquiry — including all personal data arising from it (name, inquiry) — will be stored and processed by us for the purpose of handling your request. We do not pass this data on without your consent. Processing of this data is based on Art. 6(1)(b) GDPR, provided your inquiry is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, processing is based on our legitimate interest in the effective handling of inquiries addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR), where this was requested; consent may be revoked at any time. Data you have sent to us via contact inquiries remains with us until you ask us to delete it, revoke your consent to its storage, or the purpose for storing the data no longer applies (e.g. after your inquiry has been fully processed). Mandatory statutory provisions — in particular statutory retention periods — remain unaffected.

Google Analytics
This website uses, provided you have consented, features of the web analytics service Google Analytics. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Analytics allows us to evaluate the behaviour of website visitors (e.g. page views, time spent, origin) without linking this data to your name or email address. Use of this service is based on your consent (Art. 6(1)(a) GDPR, § 25(1) TDDDG). The transfer of data to the USA is based on the standard contractual clauses of the EU Commission and, where certified, additionally on the EU-US Data Privacy Framework. Further information: policies.google.com.

Smartlook
Provided you have consented to analytics, we additionally use Smartlook to record anonymised usage behaviour (e.g. click and scroll behaviour) in order to improve the website. This data is not linked to your name or email address. Use of this service is based on your consent (Art. 6(1)(a) GDPR, § 25(1) TDDDG).

Meta Pixel (Facebook/Instagram)
Provided you have consented to advertising cookies, this website uses Meta’s visitor action pixel for conversion measurement. The provider is Meta Platforms Ireland Limited, Merrion Road, Dublin 4, Ireland. According to Meta, the data collected is also transferred to the USA and other third countries. This allows the behaviour of site visitors to be tracked after they have been redirected to our website by clicking on a Meta advertisement. If you sign up for the waitlist or fill out the questionnaire, we additionally share this event with Meta server-side — including a one-way hash of your email address (not the address itself) — so that Meta can match it to an ad click. Use of this service is based on your consent (Art. 6(1)(a) GDPR, § 25(1) TDDDG).

Joint controllership (Art. 26 GDPR):Insofar as personal data is collected on our website and transferred to Meta using the Meta Pixel described here, we and Meta Platforms Ireland Limited are joint controllers for this collection and transfer (Art. 26 GDPR). This joint controllership is limited exclusively to the collection of data and its transfer to Meta; the subsequent processing by Meta is not part of this joint responsibility. Meta has set out the key points of this joint processing in its “Controller Addendum”: facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing the privacy information relating to the use of the Meta tool and for its data-protection-compliant implementation on our website; Meta is responsible for the security of Meta’s own products. You may exercise data subject rights (e.g. requests for information) regarding data processed by Facebook or Instagram directly with Meta; if you exercise them with us, we are obliged to forward them to Meta.

You can object to the use of your data for advertising purposes by Meta, for example via the remarketing settings under: facebook.com/ads/preferences, or, if you do not have a Facebook/Instagram account, via the European Interactive Digital Advertising Alliance at: youronlinechoices.com.

Counter.dev
In addition, regardless of your cookie choice, we use Counter.dev for aggregated, cookie-free visitor counting. This service does not collect any information that identifies you individually and therefore does not require consent. Use of this service is based on our legitimate interest in simple usage statistics (Art. 6(1)(f) GDPR).

House of Ginger is not directed at children, and we do not knowingly collect data from individuals under the age of 16.

If what we collect, or why, changes, we will update this page. We will additionally mention any material changes in our next email to you, should you be on the waitlist.