Privacy policy

Last Updated: March 13, 2026

1. Information About the Controller and Data Collection

1.1 Controller Information

We are pleased that you are visiting our website and thank you for your interest. This Privacy Policy explains how we collect, use, and protect your personal data when you use our website or purchase our products.

Trade Name: Ginlerie
Legal Entity: Nexora
Business Address: Elzenhoven 2, 3162 PJ Rhoon, Netherlands
KVK Registration: 95810358
VAT Number: NL005175229B84
Email: support@ginlerie.com
Phone: +44 2037696963 (SMS only — no voice calls)

The controller is responsible for determining the purposes and means of processing personal data under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

1.2 Secure Data Transmission

For security reasons and to protect the transmission of personal data and other confidential content (e.g., orders or enquiries), this website uses SSL/TLS encryption. You can recognise an encrypted connection by the "https://" prefix and the lock symbol in your browser's address bar.

2. Data Collection When Visiting Our Website

2.1 Server Log Files

When you visit our website purely for informational purposes without registering or providing other information, we automatically collect data that your browser transmits to our server ("server log files"). This technical data is necessary to display the website and includes:

The webpage you visited
Date and time of access
Amount of data sent (in bytes)
Referrer URL (source from which you accessed the page)
Browser type and version
Operating system used
IP address (anonymized where possible)

Legal Basis: Article 6(1)(f) UK GDPR (legitimate interest in improving website stability and functionality). The data is not passed on to third parties or used for other purposes. We reserve the right to review server log files if there are specific indications of illegal use.

3. Cookies and Tracking Technologies

3.1 What Are Cookies?

Cookies are small text files stored on your device when you visit our website. They help us make our website more functional and user-friendly.

3.2 Types of Cookies We Use

Essential Cookies: Necessary for basic website functionality (e.g., shopping cart)
Functional Cookies: Remember your preferences and settings
Performance Cookies: Analyse how you use our website (e.g., Google Analytics)
Marketing Cookies: Track your browsing to show relevant ads (e.g., Facebook Pixel, Google Ads)

Session Cookies: Deleted when you close your browser
Persistent Cookies: Remain on your device for a predefined period (varies by cookie)

Legal Basis:

Essential cookies: Article 6(1)(b) UK GDPR (performance of contract)
Other cookies: Article 6(1)(a) UK GDPR (consent) or Article 6(1)(f) UK GDPR (legitimate interest)

3.4 Managing Cookies

You can configure your browser to be notified when cookies are set, accept or reject cookies on a case-by-case basis, or block all cookies entirely. Please note that disabling cookies may limit website functionality. You can also withdraw cookie consent at any time through our cookie banner or browser settings.

4. Personal Data We Collect

4.1 Information You Provide to Us

When you place an order or contact us, we collect:

Account & Order Information:

Full name
Email address
Billing address
Shipping address
Phone number (optional)
Payment information (processed by payment providers)
Order history
Product preferences

Contact Information:

Name
Email address
Phone number (if provided)
Message content

4.2 Information Collected Automatically

IP address
Browser type and version
Device type and operating system
Pages visited and time spent on pages
Referral source
Click patterns and interactions

5. How We Use Your Data

5.1 Order Fulfilment

Legal Basis: Article 6(1)(b) UK GDPR — Performance of Contract

Process and fulfil your orders
Manage payments and billing
Arrange shipping and delivery
Send order confirmations and shipping notifications
Handle returns and refunds
Provide customer support

5.2 Account Management

Legal Basis: Article 6(1)(b) UK GDPR

Create and maintain your customer account
Remember your preferences
Provide a personalised shopping experience

5.3 Communication

Legal Basis: Article 6(1)(b) or (f) UK GDPR

Respond to enquiries and support requests
Send transactional emails (order updates, shipping notifications)
Handle complaints and disputes

5.4 Marketing

Legal Basis: Article 6(1)(a) UK GDPR — Consent

Send newsletters and promotional emails (only with your consent)
Display personalised advertisements
Send review reminders
Inform you about new products and special offers

You can withdraw marketing consent at any time by clicking "unsubscribe" in any email or by contacting us directly.

5.5 Legal Compliance

Legal Basis: Article 6(1)(c) UK GDPR

Comply with tax and accounting requirements
Respond to legal requests
Prevent fraud and abuse
Enforce our Terms & Conditions

5.6 Website Improvement

Legal Basis: Article 6(1)(f) UK GDPR — Legitimate Interest

Analyse website usage and performance
Improve user experience
Test and develop new features
Conduct research and analytics

We share your personal data only with trusted third parties necessary for our business operations.

6.1 Service Providers

Shopify Inc. (E-commerce Platform)

Website hosting and management, order processing, payment gateway integration
Location: Canada (adequate protection under UK GDPR)
Privacy Policy: https://www.shopify.com/legal/privacy

Payment Processors

PayPal (Europe) S.à r.l. et Cie, S.C.A. (Luxembourg)
Stripe, Inc. (USA — Standard Contractual Clauses)
Credit card processors (PCI DSS compliant)
Purpose: Secure payment processing

Shipping Carriers

International courier services (Royal Mail, DPD, UPS, FedEx, and others)
Purpose: Deliver products to your address
Data shared: Name, address, phone number, tracking details

Email Service Providers

Purpose: Send transactional and marketing emails
Data shared: Email address, name, order information

6.2 Marketing and Analytics

Google LLC (USA)

Google Analytics (website analytics) and Google Ads (advertising)
Legal basis: Consent (Article 6(1)(a) UK GDPR)
Privacy Policy: https://policies.google.com/privacy

Meta Platforms (Facebook/Instagram)

Facebook Pixel (conversion tracking) and Instagram integration
Legal basis: Consent (Article 6(1)(a) UK GDPR)
Privacy Policy: https://www.facebook.com/privacy/policy

6.3 Legal Requirements

We may disclose your data to law enforcement agencies (when legally required), courts and regulatory authorities, legal advisors and accountants, and fraud prevention services.

6.4 Business Transfers

In the event of a merger, acquisition, or sale of assets, your data may be transferred to the new owner. You will be notified of any such change.

7. International Data Transfers

As we operate internationally and use service providers in different countries, your data may be transferred outside the United Kingdom.

7.1 Adequate Protection Mechanisms

Standard Contractual Clauses (SCCs): For transfers to countries without adequacy decisions
Adequacy Decisions: Canada (PIPEDA), EEA countries recognised by the UK
Data Privacy Framework: For US-based processors (where applicable)

7.2 Your Rights

You can request copies of the safeguards we use for international transfers by contacting us at support@ginlerie.com.

8. Data Retention

We retain your personal data only as long as necessary for the purposes outlined in this policy or as required by law.

8.1 Retention Periods

Data Type	Retention Period
Order data	7 years (tax and accounting requirements)
Account data	Until account deletion + 30 days
Marketing data	Until consent is withdrawn + 30 days
Contact enquiries	3 years after resolution
Website analytics	14–26 months (Google Analytics settings)
Cookie data	As specified in cookie settings (varies by type)

8.2 Deletion

After retention periods expire, your data is securely deleted or anonymised unless you have consented to further use, we are legally required to retain it, or it is necessary for legal claims.

9. Your Rights Under UK Data Protection Laws

As a customer, you have the following rights:

Right of Access (Article 15): Request a copy of your personal data
Right to Rectification (Article 16): Correct inaccurate data
Right to Erasure (Article 17): Request deletion ("right to be forgotten")
Right to Restriction (Article 18): Limit how we use your data
Right to Data Portability (Article 20): Receive your data in a structured format
Right to Object (Article 21): Object to processing based on legitimate interests
Right to Withdraw Consent (Article 7(3)): Withdraw consent at any time
Right to Lodge a Complaint (Article 77): File a complaint with the ICO

9.2 How to Exercise Your Rights

Email: support@ginlerie.com
SMS: +44 2037696963 (SMS only — no voice calls)
Mail: Nexora, Elzenhoven 2, 3162 PJ Rhoon, Netherlands
Business Hours: Monday – Saturday, 9:00 AM – 5:00 PM GMT

We will respond to your request within 30 days as required by UK GDPR.

9.3 UK Supervisory Authority

You have the right to lodge a complaint with:

Information Commissioner's Office (ICO)
Website: https://ico.org.uk
Helpline: 0303 123 1113
Address: Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

10. Direct Marketing

When you subscribe to our newsletter, we send regular updates about products, offers, and promotions.

Process: Double opt-in — you must confirm your subscription via email
Legal basis: Article 6(1)(a) UK GDPR (consent)
Data collected: Email address, name (optional), subscription date, IP address
Unsubscribe: Click the unsubscribe link in any newsletter or contact support@ginlerie.com

10.2 Marketing to Existing Customers

If you have purchased from us, we may send marketing emails about similar products under Article 6(1)(f) UK GDPR (legitimate interest). You can opt out at any time.

11.1 Facebook

We use Facebook plugins with privacy protection. Data transfer occurs only when you click the plugin.
Privacy Policy: https://www.facebook.com/privacy/policy

11.2 Instagram

Instagram plugins are embedded using privacy-enhanced methods. Data transfer occurs only upon interaction.
Privacy Policy: https://help.instagram.com/155833707900388

12. Web Analytics

12.1 Google Analytics

We use Google Analytics to analyse website traffic and user behaviour. Your IP address is anonymised.

Legal Basis: Article 6(1)(f) UK GDPR (legitimate interest) or consent
Opt-Out: https://tools.google.com/dlpage/gaoptout

13. Online Advertising

13.1 Google Ads

We use Google Ads to display relevant advertisements based on your interests.

Legal Basis: Article 6(1)(a) UK GDPR (consent via cookie banner)
Opt-Out: https://adssettings.google.com

13.2 Facebook Pixel

We use Facebook Pixel to track conversions and optimise ad campaigns.

Legal Basis: Article 6(1)(a) UK GDPR (consent)
Opt-Out: https://www.facebook.com/ads/preferences

14. Security Measures

We implement industry-standard security measures to protect your data, including:

SSL/TLS encryption for all data transmission
Secure servers with firewall protection
PCI DSS compliance for payment processing
Access controls limiting employee access to data
Regular security audits and vulnerability assessments
Data backup systems to prevent data loss

15. Data Breach Notification

In the event of a data breach that poses a risk to your rights and freedoms, we will notify affected individuals within 72 hours as required by UK GDPR, notify the ICO as required by law, and provide full information about the breach and remedial actions taken.

16. Children's Privacy

Our website and services are not directed to individuals under 18 years of age. We do not knowingly collect data from children. If you believe we have collected data from a child, please contact us immediately at support@ginlerie.com.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. Updates will be posted on this page with a revised "Last Updated" date. Continued use of our website after changes constitutes acceptance of the updated policy.

18. Contact Us & Exercise Your Rights