Version: January 2026
(In accordance with Regulation (EU) 2016/679 – General Data Protection Regulation (GDPR) and the Luxembourg law of 1 August 2018)

1. Who we are

This website, www.ginepro.lu, is operated by:

Gin(e)pro Sàrl-s, a simplified private limited company under Luxembourg law,
Registered with the Luxembourg Trade and Companies Register under number B255300
Head office: 7, rue Dwight Eisenhower, L-8321 Olm, Luxembourg
📧 Email: info@ginepro.lu

Gin(e)pro is the data controller for all processing of your personal data in connection with your interactions with our website and services.

2. When do we collect your data?

We collect personal data in the following situations:

• When you visit our website;

• When you create a customer account;

• When you make a purchase (online, by phone, or in person);

• When you contact us by email, phone, form, or social media;

• When cookies and analytics tools are used.

3. What data do we collect?

We may collect and process the following types of data:

• Identity and contact details (name, email, phone number…);

• Delivery and billing information;

• Order history;

• Technical data and browsing behavior (via cookies – see our Cookie Policy).

4. Why do we use your data?

We use your personal data for the following purposes:

• To process and deliver your orders;

• To create and manage your customer account;

• To respond to your requests or contact you;

• To improve our services and understand website traffic;

• To comply with legal obligations (e.g. invoicing, taxes);

• To protect our business from fraud or misuse.

5. What are the legal grounds for processing?

We only process your data if one of the following legal bases applies:

• ✅ Your consent (e.g. for marketing or optional cookies);

• ✅ Performance of a contract (e.g. processing an order);

• ✅ Compliance with a legal obligation (e.g. recordkeeping);

• ✅ Legitimate interest, provided it does not override your rights (e.g. fraud prevention, service improvement).

6. Who has access to your data?

Your data may be shared only with authorized recipients, including:

• Our internal teams (sales, billing, logistics);

• Trusted service providers (e.g. hosting, payment, accounting);

• Delivery partners and technical contractors;

• Public authorities when legally required.

We do not sell or rent your personal data.

All third parties are bound by contract to ensure confidentiality and security in accordance with the GDPR.

7. Transfers outside the EU

Some of your data may be transferred outside the European Economic Area, especially when using services like Google Analytics, social media tools, or certain payment providers.

In such cases, we ensure these transfers are legally secured through:

• Standard Contractual Clauses approved by the European Commission, or

• Other safeguards under the GDPR.

You may request more information or a copy of these safeguards by contacting info@ginepro.lu.

8. How long do we keep your data?

We retain your data only as long as necessary for the purposes stated, or to comply with legal obligations (e.g. accounting).

Examples:

• Order and billing data: up to 10 years (legal retention);

• Inactive account data: up to 3 years;

• Cookie data: according to cookie type (see Cookie Policy).

Once the retention period has expired, your data is securely deleted or anonymised.

9. What are your rights?

You have the following rights under the GDPR:

• 🔍 Access to your personal data;

• ✏️ Rectification of inaccurate data;

• ❌ Erasure of your data (under certain conditions);

• 🛑 Restriction of processing;

• 🔄 Data portability (receive and transfer your data);

• 🙅 Objection to processing based on legitimate interest;

• ✉️ Withdraw consent at any time (without affecting prior processing).

📩 To exercise any of these rights, please email us at: info@ginepro.lu

We will respond within one month, extendable by two months in complex cases.

10. Automated decision-making

🎯 We do not use any automated decision-making or profiling that would have legal or significant effects on you.

11. Data security

We apply technical and organizational measures to protect your data against unauthorized access, loss, or misuse (e.g. access control, encryption, firewall).

12. Updates to this policy

We may update this Privacy Policy at any time. The latest version will always be available on our website. We will inform you of major changes if applicable.

13. Complaints

If you believe your data has not been handled in accordance with the GDPR, you have the right to lodge a complaint with the Luxembourg data protection authority:

Commission Nationale pour la Protection des Données (CNPD)
1, Avenue du Rock’n’Roll, L-4361 Esch-sur-Alzette, Luxembourg
🌐 www.cnpd.lu